IR 05000445/1998015
| ML20195H696 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/19/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20195H678 | List: |
| References | |
| 50-445-98-15, 50-446-98-15, NUDOCS 9811240077 | |
| Download: ML20195H696 (13) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-445 50-446
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License Nos.:
NPF-87 ~
NPF-89 Report No.:
50-445/98-15
.50-446/98-15 Licensee:
TU Electric Facility:
Comanche Peak Steam Electric Station, Units 1 and 2 i
Location:
Dates:
November 2-6,1998 inspector:
J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch Approved By:
Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety i
Attachment:
Supplemental Information
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i 9811240077 981119 PDR ADOCK 05000445 G
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-2-EXECUTIVE SUMMARY Comanche Peak Steam Electric Station, Units 1 and 2 NRC inspection Report 50-445/98-15; 50 446/98-15 This announced routine inspection reviewed radiation protection program activities. Areas -
reviewed included: external and internal exposure controls, controls of radioactive material and contamination, surveying and monitoring, and quality assurance of radiation protection activities.
Plant Suocort The external exposure control program was effectively implemented. Proper dosimetry
was worn by radiation workers. Radiation areas and high radiation areas were properly posted and controlled. Visual aids were used to identify ALARA low dose waiting areas.
Keys for locked high radiation areas were maintained and controlled properly. General access permits and radiation work permits were clearly written.- A good pre-job ALARA briefing for the transfer of spent resin was conducted. Radiation protection job coverage was appropriate for radiological work observed. Proper thermoluminescent dosimeters were used for measuring neutron doses (Section R1.1).
Radiation workers did not know the function or meaning of the electronic dosimeter
alarms (Section R1.1).
An effective internal exposure program was implemented. Good air sampling and
respiratory protection programs were maintained. Whole-body counting systems were properly calibrated. Internal dose assessments were properly performed (Section R1.2).
Radioactive material, laundry, and trash containers were properly labeled and controlled.
- The personnel contamination program was implemented properly. Good radioactive source inventory and leak testing programs were in place. The calibration and source response check programs for neutron and portable radiation survey instruments were implemented properly (Section R1.3).
Housekeeping throughout the radiological controlled area was very good (Section R1.3).
- An effective radiation protection nuclear overview evaluation progiam was maintained.
- The nuclear overview evaluations and radiation protection department self assessments p.ovided management with a good assessment of the radiation protection program.
Timely, effective corrective actions were implemented in response to assessment findings. No negativo trends were identified during the review of radiological ONE Form reports written since January 1997 (Section R7.1).
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-3-Report Details Summary of Plant Status Both' units operated at 100 percent power during the inspection.
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IV. Plant Support i
R1 Radiological Protection and Chemistry Controls R1.1 External Exoosure Controls a.
Insoection Scoce (83750)
Selected radiation workers and radiation protection personnel involved in the external exposure control program were interviewed. Several tours of the radiological controHed area were performed. The following items were reviewed:
Radiological controlled area access controls
Control of high radiation areas and high radiation area keys
General access permits and radiation work permits
Job coverage by radiation protection personnel a
Personnel dosimetry
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Observations and Findinos The inspector observed activities at the radiological controlled area access / egress control point and noted that station workers used the computerized log-in/out and personnel contamination monitoring equipment properly. Radiation protection personnel present in this area provided timely response and direction to station workers who alarmed the personnel contamination monitors or needed assistance using the computerized log-in/out equipment. All radiation workers observed wore their dosimetry properly.
The inspector conducted several tours of the radiological controlled area and performed independent radiation measurements to confirm the appropriateness of radiological post ngs. The inspector observed that radiation areas and high radiation areas were properly controlled and posted. All Technical Specification required locked high radiation area doors were locked and posted properly. Radiological postings and survey maps displayed at the entry to rooms correctly specified radiological conditions in the room. All radiological postings were clearly and conspicuously posted.
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ALARA low dose waiting areas throughout the plant were clearly identified with yellow L
signs. The licensee informed the inspector that in the near future, these ALARA low
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dose waiting areas will be more conspicuously identified by large bright fluorescent l
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The inspector performed an inventory of the locked high radiation area keys. Based on l
l the inventory of high radiation area keys and review of the high radiation area key log, l
the inspector determined that all keys for locked radiation areas were properly t
controlled. The inspector verified that a high radiation area key inventory was performed by the shift lead radiation protection technician at the close of each shift and l
documented in the radiation protection shift log. The inspector determined that a good high radiation area key control program was implemented.
The inspector reviewed randomly selected general access permits (GAPS) and radiation work permits (RWPs) and noted that the permits were written in a clear, consistent manner and contained appropriate radiological controlinformation. The GAPS and RWPs were subdivided into specific tasks that helped workers clearly understand the radiological controls and monitoring requirements for each task. Additionally, the
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numbering system used for the GAPS and RWPs made it easier to review job history information. The same number was used for similar work with the exception of the year designator.
The inspector observed the removal of a spent fuel pool filter from the filter housing and its transfer to a shielded container for storage until shipment for disposal. Good ALARA j
practices were employed using remote handling equipment and appropriate shielding, The work area was properly posted during changing radiological conditions. An air sampler was properly placed in the work area to assess radiological airborne conditions.
Radiation protection job coverage was appropriate for the radiological work observed.
On November 4,1998, the inspector attended the pre-job ALARA briefing for the transfer of spent resin from the spent resin storage tank to a high integrity container located in the fuel handling building. The briefing was conducted in a professional manner. During the pre-job briefing, the sequence of job activities was discussed and
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personnel assignments were made. Questions concerning the job sequence and work process were discussed and resolved during the briefing. The inspector observed that experienced personnel were used for the task. During the briefing, the radiation work permit for the job was distributed to tha workers for review, and the measured and anticipated radiological conditions were presented and discussed. Additionally, the inspector observed a majority of the resin transfer activities. Radiation protection technicians provided continuous radiation protection coverage during the resin transfer and properly monitored both personnel dose and radiological conditions. The spent resin transfer was performed according to station procedures with minimal radiation exposure to the workers.
The inspector conducted field interviews with six radiation workers from various craf ts.
The interviews revealed that the workers were generally knowledgeable of the radiological conditions specified on their general access permit but had limited knowledge of their electronic dosimeter alarm settings and the meanings of the two
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alarm settings. Fifty percent of the workers interviewed knew the correct values for the
alarm settings specified on their general access permit. However, they stated that the l
electronic dosimeter alarm settings were low and high alarms, and they did not know that one alarm setting was for accumulated dose and that the other was for dose rate.
However, everyone interviewed knew to leave the area and contact radiation protection i
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personnelif their electronic dosimeter alarmed. The lack of knowledge concerning the
electronic dosimeter alarm settings by radiation workers was discussed with the l
radiation protection manager, and he further discussed this issue with other rtation
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managers. The radiation protection manager also discussed this issue with his staff and
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assigned radiation protection personnel at the radiological controlled access point to question station workers concerning their general access permit requirements to ensure
. that each worker knew and understood the radiological conditions specified on the general access permit and the meanings of the electronic dosimeter alarm settings to heighten awareness and understanding of the general access permit requirements. A review of radiation worker training revealed that the electronic dosimeter alarm settings l
and their meanings were described and explained in the radiation worker training. The l
inspector's observation was discussed with training department personnel, who stated
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that the electronic dosimeter alarm settings and their meanings will be reemphasized in future radiation worker training presentations.
The inspector determined that personnel entries into the two reactor containment I
buildings during reactor operations had remained relatively constant, approximately 30 containment entries per unit per year, during the past 2 years. The inspector reviewed neutron doses for workers that entered containment at power between January 1997 and October 1998. The inspector noted that the highest individual neutron dose was 40 l
millirems in 1997 and 221 millirems in 1998. This high individual neutron dose in 1998 l
resulted from in-core thimble tube work performed in Unit-1 during power operation.
l In 1990, a vendor, with the assistance of the licensee conducted a spectral analysis j
study to determine the neutron energies inside the Unit-1 reactor containmer t building
during reactor operations. The analysis determined that the neutron energies ranged l
from approximately 85 to 200 kilo-electron volts (kev). A similar study was conducted in 1993 inside the Unit 2 reactor containment building. The neutron energies ranged from 86 to 358 kev.
l The licensee processed its thermoluminescent dosimeters on site and was certified by the National Voluntary Laboratory Accreditation Program for all categories with the exception of category 1 which pertains to accident low energy photons. Neutron doses were based on the use of a correction factor that was developed using a tissue equivalent proportional counter to determine the neutron fluence and energy spectra encountered in both reactor containment buildings during reactor operations. A two-chip lithium-6 dosimeter was used by the licensee for evaluating neutron doses to personnel.
Tha inspector determined that the licensee used proper thermoluminescent dosimeters for establishing personnel neutron doses.
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Conclusions
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The external exposure control program was effectively implemented. Radiation protection personnel at the radiological controlled area access / egress control point provided timely response and direction to station workers who alarmed the personnel l
contamination monitor or needed assistance using the computerized log-in/out equipment. Proper dosimetry was worn by radiation workers. Radiation areas and high
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l radiation areas were conspicuously and clearly posted. Visual aids were used to l
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6-identify ALARA low dose waiting areas. Keys for locked high radiation areas were maintained and controlled properly. General access permits and radiation work permits were clearly writan. A good pre-job ALARA briefing for the transfer of spent rmin was conducted. Radiation protection job coverage was appropriate for radioloc~. work observed. Radiation workers did not know the function or meaning of the actronic dosimeter alarms. Neutron personnel dosimeters provided an accurate response to the neutron energies workers would encounter during containment entries.
R1.2 Internal Exoosure Controls a.
Inspection Scope (83750)
Selected radiation protection personnel involved with the internal exposure control program were interviewed. The following items were reviewed:
Air sampling program
Respiratory protection program
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Whole-body counting program, including the calibration and quality control of the
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counting systems Intemal dose assessment program
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Observations and Findinas During tours of the radiological controlled area, the inspector observed the use and placement of continuous air monitors. The continuous air monitors were placed appropriately and properly monitored radiological airborne conditions in specific work areas throughout the radiological controlled area. The inspector observed that all air monitoring equipment located in the radiological conuolled area had current calibration dates and documented operational checks.
Five full-faced, negative-pressure respirators were issued for radiological work during 1997 and 1998. From a review of the respirator issue log, the inspector determined that respirators were properly issued to qualified individuals, and proper total effective dose equivalent /as low as is reasonably achievable (TEDE/ALARA) evaluations were
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completed to justify respirator use. No problems were noted with the respirator issue and control program.
Whole-body counters were calibrated using standards traceable to the National Institute of Standards and Technology. The inspector noted that an acceptable phantom was used along with radiation standard sources that covered energy ranges between 88 -
1836 kev. The whole-body counters were calibrated annually, and quality control (source) checks were properly performed prior to use each day. The inspector concluded that proper whole-body counter calibration and quality control programs were establishe. _. _ _. _ _
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Internal dose assessments were reviewed. There were no whole body counts performed between January 1997 and October 1998 which exceeded the licensee's I
action level of 50 millirem for recording a committed effective dose equivalent.
However, during an investigation of a contamination event conducted in 1998, the
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licensee determined by successive whole body counts that an individual had ingested measurable quantities of cobalt-58 and cobalt-60. As a result of the investigation, the worker was assigned a committed effective dose equivalent of 23 millirems. No problems were noted by the inspector during the review of the methodologies used to
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determine internal dose.
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Conclusions An effective internal exposure program was implemented. Good air sampling and respiratory protection programs were maintained. Whole-body counting systems were
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properly calibrated and performance checked. ' Internal dose assessments were properly performed.
R1.3 Control of Radioactive Materials and Contamination: Surveyina and Monitorina a.
Inspection Scope (83750)
Areas reviewed included:
l Control of radioactive material
Housekeeping in the radiological controlled area
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Radioactive scurce control and leak testing programs j
Portable instrumentation calibration and performance check programs
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Observations and Findinas During tours or toe radiological controlled area, the inspector noted that all radioactive l
material containers were properly labeled and controlled. All laundry and trash l
containers were properly maintained. Contaminated areas were properly posted and
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clearly marked with tape and rope.
The inspector observed that housekeeping throughout the radiological controlled area
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A re'z!sw of personnel contamination logs revealed that pertinent information was l
proper;y documented. The inspector noted that there were 507 personnel l
contamination events identified in 1997.122 of these events were investigated based on procedural criteria. Between January 1 and September 30,1998, there were 398 personnel contamination events of which 60 were investigated. During the
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investigations, follow-up contamination surveys were performed to locate the source of
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contamination.
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The inspector reviewed the radioactive source inventory and leak testing records for the
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last 12 months. The inspector randomly selected ten radioactive sources from an
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8-inventory list provided by the licensee. All ten radioactive sources were found in their designated locations as documented in the individual radioactive source files and on the I
inventory list. The radioactive sources were properly stored and labeled. From a review of the last two semi annual radioactive source inventory lists and leak testing results, the inspector determined that the radioactive source inventory and leak testing programs were performed in accordance with station procedures.
The inspector reviewed the portable radiation survey instrument program, including the calibration and repair of instrurnentation. All portable radiation survey instrumentation cbserved in usa in the radiological controlled area was properly calibrated and source response checked in accordance with station procedures. The inspector determined that instrumentation calibration and maintenance records were well maintained. The portable radiation survey instrumentation was properly calibrated using standard sources traceable to the NationalInstitute of Standards and Technology.
The licensee used a vendor to calibrate the portable neutron instrumentation.
Calibration certificates documented that the neutron survey meters were calibrated using a plutonium-beryllium (PuBe) source, which was traceable to the National Institute of Standards and Technology. The neutron survey meters were calibrated to exposure rates that adequately covered the normal exposure rates of 5 - 300 millirem per hour encountered in the reactor containment buildings at 100 percent reactor power. Prior to use, portable neutron instrumentation was source response checked using a PuBe source. The inspector concluded that proper neutron survey instrument calibration and quality control programs were implemented.
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Conclusions Radioactive material, laundry, and trash containers were properly labeled and controlled.
Housekeeping throughout the radiological controlled area was very good. The personnel contamination program was implemented properly. Good radioactive source inventory and leak testing programs were in place. The cahoration and source responde check programs for neutron and portable radiation survey instruments were implemented properly, R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Quality Assurance Evaluations. Radiation Department Self-Assessments. and i
Radioloaical ONE Form Reports a.
Inspection Scope (83750)
The following items were reviewed:
Nuclear overview evaluations performed since January 1,1997
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Radiation protection department self-assessments performed since January 1,
1997 Radiological ONE Form reports written since January 1,1997
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Observations and Findinas
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Nuclear Overview Evaluation Reports Eight nuclear overview radiation protection evaluations were performed since January 1997. These evaluations covered a broad range of radiation protection activities and provided management with a good assessment of the radiation protection program.
Five unresolved items and nine deficiencies were identified by the licensee during the performance of the evaluations. The deficiencies were documented in ONE Form reports. The inspector determined that the corrective actions for the deficiencies were appropriate to prevent reoccurrence, and the deficiencies were closed in a timely manner. The radiation protection department and nuclear overview department management were appropriately involved in resolving program deficiencies.
Radiation Protection Department Self-Assessments Since January 1997 five radiation protection department self-assessments were performed by radiation protection supervision. The self-assessments were well written and covered a number of radiation protection program activities. The inspector determined that the reports provided a good assessment of the radiation protection program areas reviewed.
Radioloaical ONE Form Reports The inspector reviewed selected radiological ONE Form reports written since January 1, 1997, and determined that the licensee's threshold for documenting events was proper.
Corrective actions to prevent a reoccurrence appeared to be effective to resolve the original problem and, in general, ONE Form reports were closed in a timely manner.
The inspector identified no negative trends during this review.
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Conclusions An effective radiation protection nuclear overview evaluation piogram was maintained.
The nuclear overview evaluations and radiation protection department self-assessments provided management with a good assessment of the radiation protection program.
Timely, effective corrective actions were implemented in response to assessment findings. No negative trends were identified during the review of radiological ONE Form reports written since January 1997, i
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-10-V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on November 6,1998. The licensee acknowledged the findings presented. No proprietary information was identified.
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ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
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Licensee A. Barnette, Supervisor, Radiation Protection l
J. Blaikie, Health Physicist, Radiation Protection
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S. Bradley, Supervisor, Radiation Protection R. Carr, Supervisor, Radiation Protection L
J. Curtis, Manager, Radiation Protection
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D. Davis, Manager, Nuclear Overview Department R. Fishencord, Supervisor, Radiation Protection R. Garcia, Lead Technician, Radiation Protection l
A. Hinkley, Lead Technician, Radiation Protection T. Hope, Manager, Regulatory Affairs D, Kay, Supervisor, Radiation Protection D. Leigh, Supervisor, Nuclear Overview D. McAfee, Programs Manager, Nuclear Overview R. McGaughy, Nuclear Specialist, Nuclear Overview D. Moore, Manager, Operations
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D. O'Connor, Health Physicist, Radiation Protection M. Oliver, Supervisor, Technical Training C, Wilkerson, Senior Engineer, Regulatory Affairs NRC A. Gody, Jr., Senior Resident inspector S. Schwind, Resident Inspector
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INSPECTION PROCEDURE USED 83750 Occupational Radiation Exposure LIST OF DOCUMENTS REVIEWED List of radiological ONE Form reports (01/01/97 - 10/31/98)
Nuclear Ovgrview Department Evaluation Reports NOE EVAL-97 000004
" Radiation Protection," conducted January 6-9,1997 NOE EVAL 97-000029
" Control of Radioactive Material," conducted February 410,1997
NOE EVAL-97-000044
" Radiation Protection Dosimetry Program," conducted March 411, l.
1997 f
NOE EVAL-97-000076
" Radioactive Work Permits," conducted May 5 30,1997 NOE EVAL 97-000082
" Radiation Protection Reorganization," conducted June 16-23,1997
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2-l NOE EVAL 97 000094
"ALARA: Internal and External Exposure Controls, Control of High
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Radiation Areas," conducted July 5 29,1997
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NOE EVAL-97-000102
" Radiation Protection Program," conducted September 312,1997 NOE-EVAL 98-000054
" Radiation Protection Program," conducted September 3-25,1998 l
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Radiation Protection Deoartment Self-Assessments
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" Source Inventory Program," conducted April 15,1997
-" Radiation Protection Document Retrieval," conducted April 21-25,1997 -
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" Radiation Protection Reorganization," conducted August 1997 l
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" Respiratory Protection Program," conducted February 17-27,1998
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" Contamination Control" conducted March 3-9 1998
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Station Administrative Procedures
' STA-652
" Radioactive Material Control," Revision 7 l
STA 653
" Contamination Control Program," Revision 6 STA-655
" Exposure Monitoring Program," Revision 6 STA 659
" Respiratory Protection Program," Revision 8 STA 660
" Control of High Radiation Areas," Revision 7 i'
Radiation Protection Instructions-RPI110
" Radiation Protection Shift Activities," Revision 6 RPI-212
" Radioactive Source Control," Revision 7
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RPI-400
" Decontamination Program," Revision 7 RPI 402 Personnel Decontamination," Revision 12 l'
RPI507
" Internal Dose Calculation," Revision 3 l
RPI-508
" Calibration of the Stand-up Whole Body Counter," Revision 5
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RPI509
" Personnel Dosimetry Processing Program," Revision 5
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-3-RPI 515
"" Neutron Dose Measurement and Recording," Revision 9 I
' RPI-516
" Dose Determination," Revision 12 RPI602-
" Radiological Surveillance and Posting," Revision 7 RPI-606
" Radiation Work and Genera! Access Permits," Revision 9 RPI-700
" Sealed Source Leak Testing," Revision 8 RPI-802
" Performance of Source Checks," Revision 4 RPI-902
" Issue and Control of Respiratory Protection Equipment," Revision 9 l
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