ML19257A626

Radiation Protection Plan.

ML19257A626
Person / Time
Site:	Three Mile Island
Issue date:	12/12/1979
From:	Herbein J, Potts W METROPOLITAN EDISON CO.
To:
Shared Package
ML19257A624	List: ML19257A626
References
NUDOCS 8001070038
Download: ML19257A626 (19)

Text

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THREE MILE ISLAND f1VCLEAR STATION

', UNIT I .

RADIATION PROTECTION PLAN

/ / ' V izlst/19

/ W. E. Potts ' '

Manager - Radiological Controls ml , r

' ') s

/.2l/Zf79 J./G. Herbein Vice President, Met-Ed Changes to this document require approval by these positions.

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TABLE OF CONTENTS Page No.

Article 1 Foundat, ion of the TMI-I Radiological Control 2.0 Program' Article 2 Responsibilities of Workers 4.0 Article 3 Audits and Reports on the TMI-I Radiological 6.0 Control Program Article 4 Radiological Control Training 9.0 Article 5, Control of External Exposure 11.0 Article 6 Control of Internal Exposure 13.0 Article 7 Control of Radioactive Contamination 15.0 Article 8 Control of Radioactive Materials 16.0 Article 9 Organization for Radiological Controls 17.0 Figure 1 TMI-I Radiological Controls Organization 18.0 1.0 1692 039

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" Article 1 - Foundation for the TMI-I Radiological Controls Program This document, the Three Mile Island Unit I Radiation Protection Plan, sets forth the philosophies and basic policies of Metropolitan Edison Ccmpany and General Public Ut.ilities Corporation concerning their TMI-I Radiological Controls Program. Theie philosophies and policies are based on and stem from the regulations of the Nuclear Regulatory Comminion (NRC) as contained in Title 10 of the Code of Federal Regulations, Parts 19, 20, 50, and 71, and ,

appropriate-Regulatory Guides. The TMI-I Radiation Protection Plan is based on these references, therefore they are not repeated throughout the remainder of this document.

Specific details as to hcw the TMI-I Radiation Protection Plan is implemented shall be prcmulgated in the TMI-I Radiological Controls Procedures Manual (RCPM), further references to the TMI-I RCFM are not repeated throughcut this document. The TMI-I RCPM will consist of revisions of procedures which existed in the previous HPP 1600 and 1700 series with additional procedures deemed necessary. The procedures have direct applicability only to TMI Unit I.

This TMI-I Radiological Controls Plan is the first part of the TMI-I RCPM.

Requirements governing release of radioactive liquids and gases to the environ-ment and the disposal of solid radioactive waste are addressed in Unit I-Technical Specifications.

Verbatim compliance with the TMI-I RCPM is mandatory. In the event a procedure cannot be followed exactly, work under that procedure shall be stopped and shall not commence again until the procedure has been corrected.

This TMI-I Radiation Protection Plan and the new TMI-I RCPM are being written primarily to increase the effectiveness of The Radiological Control Program at TMI Unit I. The TMI-I Radiological Controls Program is to be fully integr.ated into each and every phase of the activities at TMI Unit I. The TMI-I Radiological Controls Program when carried out as specified wijl{ gsjur0 4 0 2.0

that the activities of Unit I will be complet2d with personnel who work at the site incurring radiation exposure as low as can reasonably be achieved.

In order to meet this objective, tha program must be carried out by each person involved jn the .TMI-I activities. There is no element, group, or person involved in the TMI-I activity wh'o does not have some degree of responsibility for the Radiological Controls Program. Failure of any person to recognize this responsibility or to comply with issued procedures will not ,

be tolerated. A radiologically safe activity will be achieved if each individual carries out his or her responsibility.

The performance of each manager and supervisor must demonstrate support for the co:nmitment by top management of General Public Utilities Corporation and Metropolitan Edison Company to a strong, effective Radiological Controls Program.

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Article 2 - Responsibilities of Workers Although personnel specially trained in radiological controls normally oversee radioactive work, each individual involved in this work must constantly remain aware of the potential radiological problems. Each individual's actions directly affect his exposure, contamination, and overall radiological problems associated with the work. The following rules shall be followed by individuals to minimize radiological problems: ,

1. Cbey promptly "stop-work" and " evacuate" orders of radiological control personnel.

2. Obey posted, oral and written radiological control instructions, including instructions on Radiation Work Permits.

3. Near TLD and self reading dosimeter where required by signs or by radiological control personnel.

4. Keep track of personal radiation exposure status and avoid exceading exposure limits.

5. Remain in as low a radiation area as practicable to accomplish work.

6. Do not loiter in radiation areas.

7. Do not smoke, eat, or chew in contaminated areas.

8. Wear anticontamination clothing and respiratory protection properly and wherever required by signs or radiological control perscnnel.

9. Remove anticontamination clothing and respiratory protection properly to minimize spread of contamin6 tion.

10. Frisk or be frisked for contamination when leaving a contaminated area or a radiological control point,

11. For a known or possible radioactive spill, minimize its spread and notify radiological control personnel promptly.

12. Do not unnecessarily touch a contaminated surface or allow clothing, tools, or other equipment to do so.

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13. Place contaminated tools, equipment and solid waste on disposable surfaces (for, example,sheetplastic)whennotinuseandinside plastic bags when work is finished.

14. Limit the amount of material that has to be decontaminated or disposed of as radioactive waste.

15. Report the presence of open wounds to radiological control and medical perscnnel prior to work in areas where radioactive contamina-tion exists and immediately if a wound occurs while in such an area.

16. Assure a mentally alert and physically sound condition for performing assigned work.

17. Ensure that your activities do not create radiological pecbleas for others and be alert for the possibilities that the activities of others may change the radiological conditions to which you are exposed, 5-169.2 043

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' Article 3 - Audits, Reviews and Reports on the TMI-l Radiological Controls Program As indicated.in Article 2, each individual is responsible for maintaining his or her radiation exposure as low as reasonably achievable wl..le completing the scope of work they,.are required to perform. Each will be required to comply with the applicable procedures of the TMI-l RCPM and the specific radiological controls prescribed for work in which they are engaged.

In order to ensure that these requirements are being met and to assist' all site personnel in understanding and complying with these requirements, the following audit and review procedures shall be used:

1. Radiological control technicians shall monitor and aid the performance of each individual insofar as radiological work practices are concerned.

2. The radiological engineering staff shall review on a regular basis the performance of the radiological control technicians. This review includes shift coverage on those jobs which are considered likely to have a high potential for r$diological difficulties.

3. Radiological audits shall be conducted throughout the Radiological Controls Program on a continuous basis. This audit function shall report directly to the highest level of management in the TMI-1 organization and shall be outside the Radiological Controls Department.

A written report of the findings of this audit shall be prepared and issued at least monthly.

4. Periodic technical reviews shall be conducted of the TMI-l Radiological Controls Program by technically qualified persons from outside the Radiological Controls Department. These reviews shall cover everything in the TMI-l Radiation Protection Plan and all procedures in the TMI-l

' RCPM on at least an annual basis.

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5. The Plant Operations Review Committee shall review and ccanent on the TMI-l Radiation Protection Plan and any changes thereto. They also have the responsibility to review those procedures requested by the Manager Radiological Controls.

6. Periodically, the services of an'outside consultant will be retained to provide evaluation and guidance on ways to improve the TMI-l Radiological Controls Program. ,

7. In addition to these reviews and audits, a system shall be employed to identify radiological control deficiencies. A radiologicJ control deficiency is defined as either a violation of an established procedure or a practice which could and should be improved. Such deficiencies are recorded in a Radiological Deficiency Report. This system shall be specified in the TMI-l RCPM embcdying the folicwing concepts. A Radiological Deficiency Report may be initiated by any individual who observes & deviation from good radiological practices.

These reports shall be evaluated by Rpdiological Engineering for. desirable or necessary corrective action. The purpose of this system is to identify all deficiencies, regardless of hcw small or inconsequential, correction of which will result in an improved Radiological Controls Program. Radiological Engineering shall prepare a monthly report summarizing the Radiological Deficiency Report findings and corrective action taken.

8. The Nuclear Regulatory Commission (NRC) also inspects and reviews the TMI-l Radiological Controls Program. The TMI-l Radiation Protection Plan and any changes thereto shall be submitted to the NRC for approval.

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9. In the event all the preceding measures fail to prevent a radiological incident, an investigation shall be conducted to determine the causes of the incident and to determine the corrective 'ictions' and improveme$ts needed.

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Article 4 - Ra liological Control Training

1. Periodic radiological control training shall be given to ensure each person understands the radiological conditions to which he ir. expcsed,. understands his responsibility to minimize his own

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exposure to ' radiation, and understands his own responsibilities for complying with radiological control procedures. Personnel occupationally exposed to radiation shall receive instruction on ,

the ef fects of radiation and the risks associated with radiation exposure.

2. General radiological indoctrination shall be given to those not directly involved with radiation so that they understand not to enter areas requiring TLDs and not to cross radiation barriers.

The indoctrination shall include explanation of the radiological environment in which they work.

3. Radiological control training shall be given to personnel who require TLDs. These personnel shall be required to pass a written examination, and they shall requalify by written examination at least annually.

4. In addition to the training and written examinations of paragraph 3, those who require access to areas controlled by Radiation ' Jock Permits shall receive more extensive training and shall be required to pass a radiological examination an their practical abilities, including use of dosimetry, frisking, anticontamination clothing, respirators, and response to unusual situations. Retraining, and both written and practical examinations shall be conducted at least annually. In addition spot checks shall be made that they retain the required -

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knowledge during the period between examinations. Special briefings and extra training including use of mockups where applicable, shall be conducted for work involving higher than usual exposures to radiation a,nd radioactivity. .

5. Radiological control technicians and their foremen shall receive theoretical and practical training and training for unusual s i tua tions . They shall pass both written and oral examinations, in which the passing grade for foremen shall be higher than the passing grade for technicians. Periodic practical drills and oral drills shall be required for each technician and foreman. Annual requalifica-tion shall be required including both written and oral exarainations.

Radiological control technician assistants shall perform specific functions under direction of a qualified technician or foreman dnd only af ter being qualified for the specific function.

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Article 5 - Control of External Exposure Control of radiation exposure is based on the assumption that any exposure no matter how small involves some risk; however, exposure within the accepted 1,imits represents a risk small compared with normal hazards of life. Therefore the policy of Metropolitan Edison Company and General Public Utilities Corporation is to maintain exposures to individuals and total manrems as icw as reasonably achievable (ALARA). .

Line management from all departments as well as each individual worker shall take an active role in radiation exposure reduction.

To aid in exposure reduction, administrative radiation exposure control levels shall be established. Radiation exposure goals shall be establishec for each outage and for each year. Work .nvolving radiation exposure shall be preplanned. Major exposure jobs shall require that radiological controls be incorporated into the work procedure and that pre-job briefing and rehearsals be conducted prior to con.mencing work.

Work involving significant exposure to radiation shall be controlled by a Radiation Work Permit.

Restricted areas used to control personnel access to radiation and radioactive materials shall be defined, access controlled, and posted in accordance with 10 CFR 20.203 with the following modifications:

1. Each High Radiation Area shall be barricaded and conspicuously posted as a High Radiation Area,.and personnel desiring entrance shall o~otain a Radiation Work Permit (RWP). Any individual entering a High Radiation Area shall (a) use a dose rate monitoring device or (b) use a radiation dose rate integrating device which alarms at a preset dose level, or (c) assure that a radiological control technician provides periodic radiation surveillance with a dose rate monitoring instrument.

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2. Any area accessible to personnel where a major portion of the body could receive in any one hour a dose.in excess of one thousand mrem, shall be locked to prevent unauthorized entry.

The keys to..these locked barricades shall be maintained under the administ'rative control of the Radiological Controls Foreman on duty in accordance with the RCPM.

Radiological Controls personnel shall be exempt from the R'.4P issuance ,

requirements during the perfomance of their assigned radiation protection duties providing they are following radiological control procedures for entry into High Radiation Areas.

To evaluate radiological conditions, radiation surveys shall be conducted for air activity, removable surface contamination and external radiation at regular intervals. Unsusual conditions detected in the par-formance of either a routine or special survey shall immediately be brought to the attention of Radiological Controls Management. The instruments required to conduct the surveys shall be maintained and periodically calibrated to assure a consistent, reliable and predictable response to radiation levels.

Records of surveys shall be maintained on file.

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' Article 6 - Control of Internal Exposure, The policy of Metropolitan Edisa Company and General Public Utilities Corporation is not to have any significant internal exposure to personnel from radioactivity associated with Three Mile Island Unit 1. For personnel exposed to radioactivi'ty during their work,' this means that no one should receive from internal radioactivity more than one tenth of their permitted annual radiation exposure. ,

Controls in other parts of this TMI-l Radiation Protection Plan to minimize internal radioactivity, such as control of surface contamination and control of wounds, are not repeated in this article. The follcwing controls are to minimize internal exposure frcm airborne radioactivity:

1. Engineering controls and controls on personnel access shall be applied to the maximum extent practicable so that radioactive work does not increase the amounts of airborne radioactivity inhaled.

When no other controls are practicable, respirators shall be used.

Those who may need to use respirators.shall be medically qualified, trained, tested for respirator efficiency, and requalified in this respirator program at least annually.

2. Airborne radioactivity shall be measured regularly in areas where personnel may be exposed. Continuous monitoring shall be performed to supplement periodic measurements during work which has the potential to cause a worker to receive measurable internal radioac tivi ty.

Internal radioactivity shall be measured at least annually in each person who works in an area requiring a Radiation Work Permit; this includes each person who wears respiratory protection. Internal radioactivity shall be measured promptly in each person who receives radioactive contamination on his

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skin, and in each person who is suspected of inhali dioactivity to cause measurable internal radioactivity. Each me. :ernal radioactivity above a level near background shall be .. ermine the cause and to assist in minimizing internal exposur 0

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Article 7 - Control of Radioactive Contamination Radioactive surface con *. amination shall be controlled in order to minimize possible inhalation or ingestion of radioactivity and to minimize buildup of radioactivjty in the environment. Measures to contain radioactivity and to minimize the number and extent of ar'eas contaminated shall be taken in order to minimize personnel radiation exposure, to simplify subsequent decontamination, and to minimize the need to rely on anticontamination -

clothing.

Emphasis in planning, training and working shall be placed on minimizing the numbers of occurrences and amounts of radioactivity involved in occurrences in which radioactive surface contamination exceeds the limits of the TMI-l RCPM on a person's skin or in areas not controlled for radioactive surface contamination. Each such occurrence shall be reviewed in detail to deterasine how to correct deficiencies and improve control of radioactivity.

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Article 8 - Control of Radioactive Materialc A radioactive material control system shall be established to ensure radioactive material is not lost or misplaced in a location where personnel could unknowingly be , exposed and to prevent the uncontrolled spread of radio-activity to areas wheFe the public might be affected. This system shall include the following requirements:

l. The number of areas in which radioactive materials are stored ,

shall be minimized.

2. Any new radioactive material storaga area shall be approved before use by the Manager Radiological Controls.

3 The numbers of radioactive items and the amount of radioactivity in storage shall be minimized.

4. Radioactive items shall be identified as radioactive before removing them fi m a restricted area.

5. Radioactive materials removed from the Protected Security Area or removed from a restricted area outsid;e the Protected Security Area shall be controlled in accordance with an acccuntability procedure which ensures the materials are not lost or improperly handled during transfer. This accountability procedure shall require pericdic inventory of radioactive materials which remain outside such areas.

6. Each inccming or outgoing shipment of radioactive material shall be handled in strict ccmpliance with detailed written procedures.

Each case in which radioactive material is lost or unaccounted for shall be reviewed in detail to determine the potential radiation exposure personnel might unknowingly receive, to correct deficiencies, and to improve control of radioactive materials.

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Article 9_ - Organization for Radiological Controls A radiological control program cannot be strong and effective if left solely to the Radiological Controls Department. Each worker and supervisor has responsibility for radiological control; consequently, the organization for the entire Three FMle Island Unit 1 rep' resents the organization for radiological control.

However the Manager Radiologi. cal Controls is responsible for ensuring .

that a high quality radiological controls program is established and maintained.

To assist him, a Radiological Controls Department 1. organized as shcwn in Figure 1.

At times when demands upon the Radiological Control Department are sufficiently heavy to require a temporary increase in staff qualified contractor personnel will be used. These personnel will be fully integrated into the department under the direction of the Manager - Radiological Cor.trols.

Qualifications for the key radiological managers in NRC Regu'atory Guide 1.8, Rev.1-R, (1975) will be met as far as practicable. 'lhere the ccabination of strong manager and experience in radiological ~ controls cannot practic2bly be cbtained in the same person, the combination of the qualifications of the Manager - Radiological Controls and his supervisors will meet Regulatory Guide 1.8, Rev l-R (1975).

One portion of the TMI-l radiological controls program is tne ALARA program for personnel radiation exposures to be as low as reasonably achievable. To accomplish this each individual who provides work instructions, procedures and directions has to have constant awareness of radiological conditions as part of his assignment. Thus, most efforts to reduce radiation exposure are performed by individuals other than those in the Radiological Controls Department. The overall coordination of the TMI-l ALARA program, however, is assigned to Radiological Engineering in the Radiological Controls Department.

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Vice-President -

Met-Ed i Manager -

, Radiological Controls i

Adminis trative and Clerical Support I

Supervisor Supervisor Radiological Radiological Control Technicians Engineering I

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is Radiological Radiological t Control Technicians Engineers Foremen .

Radiological Control Technicians

! Figure 1 TMI-I Radiological Controls Department Organization i C7s

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