ML19290B650
| ML19290B650 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/07/1979 |
| From: | Arnold R, Heward R METROPOLITAN EDISON CO. |
| To: | |
| Shared Package | |
| ML19290B649 | List: |
| References | |
| PROC-791207, NUDOCS 7912130441 | |
| Download: ML19290B650 (18) | |
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THREE MILE ISLAND NUCLEAR STATION UNIT 2 RADIATION PROTECTION PLAN 12 r-19
/ R.W. Heward, Jr.
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- Manacer, diological Controls Department 4-7-7Y R.C.Arfold Senior Vice President, Met-Ed 1553 040 Changes to this document require approval by these signators.
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Article 1 - Foundation for the TMI-2 Radioloaical Controls Program This document, the Three Mile Island Unit 2 Radiation Protection Plan, sets forth the philosophies and basic policies of Metropolitan Edison Comany and General Public Utilities Corporation concerning their TMI-2 Rautological Controls Program. These philosophies and policies are based on and stem from the regulations of the Nuclear Regulatory Commission (NRC) as contained in Title 10 of the Code of Federal Regula-tions, Parts 19, 20, 50, and 71, and appropriate Regulatory Guides. The TMI-2 Radiation Protection Plan is based on these references, therefore they are not repeated throughout the remainder of this document.
Specific details as to how the TMI-2 Radiation Protection Plan is implemented shall be promulgated in the TMI-2 Radiological Controls Procedures Manual (RCPM); further referencer to the TMI-2 RCPM are not repeated throughout this document.
The TMI-2 RCPM will consist of revisions of procedures which existed in the previous HPP 1600 and 1700 series and additional procedures deemed necessary. This TMI-2 Radiation Protection Plan is the first part of the TMI-2 RCPM.
Policies and procedures governing release of radioactive liquids and gases to the environment and the disposal of solid radioactive waste are not addressed in this TMI-2 Radiation Protection Plan, but are addressed elsewhere.
Verbatim compliance with the TMI-2 RCPM is mandatory.
In 'he event a procedure cannot be followed exactly, work under that p ocedLee shall be stopped and shall not commence again until the procedure has been corrected.
This TMI-2 Radiation Protection Plan and the new TMI-2 RCPM are being written primarily because of the unique radiological situation existing at TMI Unit 2.
Thus, the procedures have direct applicability w
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Revision 0 12/07/79 only to TMI Unit 2 and apply to Unit 1 only insofar as they are specifi-cally made applicable.
The TMI-2 Radiological Controls Program is to be fully integrated into each and every phase of the recovery effort at TMI Unit 2.
The accident which occurred at TMI Unit 2 has created an environment of radiological conditions unique to the nuclear power industry.
The TMI-2 Radiological Controls Program when carried out as specified will assure that the recovery of Unit 2 even under these unique conditions will be completed with personnel who work at the site incurring radiation exposure as low as can reasonably be achieved.
In order to meet this objective, the program must be carried out by each person involved in the TMI-2 activities.
There is no element, group, or person involved in the TMI-2 recovery who 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 recovery operation will be achieved if each individual carries out his or her responsibility.
The performance of each manager and supervisor must demonstrate support for the commitment by top management of General Public Utilities Corporation and Metropolitan Edison Company to a strong, effective Radiological Controls Program.
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Revision 0 12/07/79 Article 2 - Responsibilities of Workers Although personnel specially trained in radiological controls nor-mally 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 follow-ing rules shall be followed by individuals to minimize radiological problems:
1.
Obey 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.
Wear TLD and self reading dosimeter where required by signs or by radiological control personnel.
4.
Keep track of personal radiation exposure status and avoid ex-ceeding 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 anticantamination clothing and respiratory protection properly and wherever required by signs or radiological control personnel.
9.
Remove anticontamination clothing and respiratory protection properly 3
to minimize spread of contamination.
10.
Frisk or be frisked for contamination when leaving a contaminated area or a radiological control point.
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For a knowd 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.
13.
Place contaminated tools, equipment and solid waste on dispos-able surfaces (for example, sheet plastic) when rot in use and inside plastic bags when work is finished.
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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 personnel prior to work in areas where radioactive contamination exists and immediate!y 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 problems for others and be alert for the possibilities that the activities of others may change the radiological conditions to which you are exposed.
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Article 3 - Audits, Reviews and Reports on the TMI-2 Radiological Controls Program As indicated in Article 2, each individual is responsible for maintaining his or her radiation exposure as low as reasonably achiev-able while completing the scope of work they are required to perform.
Each will be required to comply with the applicable procedures of the TMI-2 RCPM and the specific radiological controls prescribed for work which theysare engaged.
In order to ensure that these requirements are being met and to assist all site personnel in understanding and complying with these re quirements, 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 radirlogical technical support 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 fc radiological difficulties.
3.
Radiological audits shall be conducted throughout the Radio-logical Controls Program on a continuous basis. This audit function shall report directly to the highest level of manac ment in the TMI-2 organization and shall be outside the Radi logical Controls Department. AwrittenreportofthefindiI of this audit shall be prepared and issued every 2 weeks.
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Periodic technical reviews shall be conducted of the TMI-2 Radiological Controls Program by technically qualified persons from ou tside the Radiological Controls Department.
These reviews shall cover everything in the TMI-2 Radiation Protection Plan and all procedures in the TMI-2 RCPM on at least an annual basis.
5 The Plant Operations Review Committee shall review and comment 4
on the TMI-?. 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-2 Radiological Controls Program.
7 In addition to these reviews and audits, a system shall be em-played to identify radiological control deficiencies.
A radiological 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-2 RCPM embodying the following concepts. A Radiological Deficiency Report may be initiated by any individual who observes a deviation from good radiological practices.
These reports shall be evaluated by Radiological Technical Support for desirable or necessary corrective action.
The purpose of this system is to identify all deficiencies, regardless of how small or inconsequential, correction of which will result in an improved Radiological Controls Program.
Radiological 6o 1553 046 We-
Revision 0 12/07/79 Technical Support shall prepare a monthly report summarizing the Radiological Deficiency Report findings and corrective
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action taken.
8 The Nuclear Regulatory Commission (NRC) also inspects and reviews the TMI-2 Radiological Controls Program.
The TMI-2 Radiation Protection Plan and any changes thereto shall be submitted to the NRC for approval.
Changes to the initial TMI-2 RCPM will be submitted to the NRC for comment.
Sub-sequent changes to the TMI-2 RCPM will be submitted to the NRC for information.
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 actions and improvements needed.
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le 4 - Radiological Control Traininq i
to 1.z Periodic radiological control training shall be g ven l conditions to ensure each person understands the. radiologica ibility to minimize which he is exposed, understands his respons responsi-his own exposure to radiation, and understands his own dures.
bilities for complying with radiological control proce l receive Personnel occupationally exposed to radiation shal ciated instruction on the effects of radiation and the risks a with radiation exposure.
to those General radiological indoctrination shall be given h
understand 2.
not directly involved with radiation so that t ey s radiation not to enter areas requiring TLDs and not to cros The indoctrination shall include explanation of the barriers.
radiological environment in which they work.
l who Radiological control training shall be given to personne These personnel shall be_ required to pass a 3.
require TL0s.
lify by written exam-written examination, and they shall requa ination at least annually.
f para-In addition to the training and written examinations o lled by 4.
graph 3, those who require access to areas contro i
training Radiation Work Permits shall receive more extens ve ination on and shall be required to pass a radiological exam dosimetry, frisking, their practical abilities, including use of d response to un-anticontamination clothing, respirators, an Retraining, and both written and practical usual situations.
lly.
In addition, examinations shall be conducted at least annua I
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spot checks shall be made that they retain the required know-
,;- ;,2 ledge during the period between examinations.
Special briefings and extra. training including us'e of mockups where applicable, shall be conducted for work involving higher than usual exposures to radiation and radioactivity.
5.
Radiological control technicians and their foremen shall re-ceive theoretical and practical training and training for un-usual situations. They shall pass both written and oral exam-inations, in which the passing grade for foremen shall be higher than the passing grade for technicians.
Periodic prac-tical drills and oral drills shall be required for each tech-nician and foreman. Annual requalification shall be required including both written and oral examinations.
Radiological control technician assistants shall perform specific functions under direction of a qualified technician or foreman and only after being qualified for the specific function.
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Article 5 - Control of External Exposure
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Control of radiation exposure is based on the assumption that any exposure no matter how small involves some risk; however, exposure with-in the accepted limits represents a risk small compared with nonnal 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 low as reasonably achievable (ALARA).
Line management from all tepartments 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 established for each major job and for each year. Work involving radia-tion exposure shall be preplanned. Major exposure jobs shall require that radiological controls be incorporated in the design, that written procedures be prepared, and that pre-job t,riefing and rehearsals be con-ducted prior to commencing 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 cdnspicuously posted as a High Radiation Area, and personnel desiring en-l i
trance shall obtain a Radiation Work Permit (RWP). Any indi-L vidual 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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Any area accessible to personnel where a major portion of the
-."h body could receive in any one hour a dose in excess of one
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th'ousand mrem, shall be locked to prevent unauthorized entry.
.The keys tii these locked barricades shall be maintained under the administrative control of the Lead Radiological Controls Foreman on duty in accordance with the RCPM.
Radiological Controls personnel shall be exempt from the RWP issuance requirement.during the performance 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. Unusual conditions detected in the performance of either a routine or special survey shall immediately be brought to the attention of Radiological Controls
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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 5-The policy of Metropolitan Edison Company and General Public Utilities Corporation is not to h. ave any significant internal exposure to personnel from radioactivity associated with Three Mile Island Unit 2.
For personnel exposed to radioactivity 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-2 Radiation Protection Plan to minimize internal radioactivity, such as control of surface contamina-tion and control of wounds, are not repeated in this article. The following controls are to minimize internal exposure from 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 radioactivity.
Internal radioactivity shall be measured at least annually in each person who works in an area requiring a radiation work permit; this p r-1553 052 33,o
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includes each person who wears respiratory protection.
Internal radioactivity shall be measured promptly in each person who receives radioactive contamination on his skin,.and in each person who is suspected of inhaling
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sufficient radioactivity to cause measurable internal radioactivity.
Each measurement of internal radioactivity above a level near background shall be reviewed to determine the cause and to assist in minimizing internal ex,20sures.
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Article 7 - Control of Radio Revision 0 Radioactive surface contamiactive Contamin 12/07/79 minimize possible inhalation or ination sha'11 be controlled in mize buildup of radioactivity i ngestion of radioactivity and to er to radioactivity and to minimize thn the environmert.
mini-Measures to contain shall be taken in order to mini ie number and exten simplify subsequent decontaminatim ze personnel radiation exp aminated re, to anticontamination clothing on, and to minimize the need to rel Emphasis in planning, traini y on mizing the numbers of occurrence ng and working shall be placed in occurrences in which radi s and amounts of radioactivity i on mini-limits of the TMI-2 RCPM on aoactive surface contamin nvolved xceeds the for radioactive surface co t person's skin or in areas not n amination.
controlled reviewed in detail to determiEach such occurrence shall be control of radioactivity.
ne how to correct deficiencies
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Article 8
' Control'of'R d j,1-A radioactive material coa ioactive Material
/b ensure radioactive material i ntrol system shall be establi h personnel could unknowingl not lost or s
s ed to exposed and to prevent the um y be spread of radioactivity to a This system shall include the f llreas where the public might b ncontrolled 1
The number owing requirements:
e affected.
o shall be minimized.of areas in which rad 4
e materials are 2
Any new radioactive mate i stored before use by the Manag r al storage area shall be approved 3
The numbers of radioactier Radiological Controls ve items and activity in storage shall b the amount of radio-4 Radioactive itemt shall b e minimized.
removing them from a restrie identified as radioactive b f 5
Radioactive materials re cted area.
e ore removed from a restrictedmoved from the Prote or area ecurity Area Area shall be procedure which ensures thcontrolled in acc r ty an accountability erly handled during transf e materials are not lost or i shall require periodic invThis accountability proced er.
mprop-which remain outside such entory of radioactive materi l ure 6
Each incoming or areas.
as shall be handled in strictoutgoing shipment of radioa
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ctive material procedures.
compliance with detailed w i 1553 055 Each case in which radioa r tten be reviewed in detail to dctive material is lost or u Enel might unknowingly receiveetermine the potential radin I
, to ation exposure control of radioactive mate i correct deficiencies, and to i r als.
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_ Article 9
_Orcanization for Radiological Controls 12/07/79 A radiological control program cannot be strong a d left solely to the Radiological Controls Depart effective if n
ment.
Each worker and supervisor has responsibility for radiological control the organization for the entire Three Mile Isl; consequently, organization for radiological control.
and Unit 2 represents the However the Manager Radiological Controls is responsible for en-suring that a high quality radiological controls pro and maintained.
gram is established To assist him, a Radiological Controls Departm organized as shown in Figure 1 ent is Qualifications for the key radiological managers in NRC R Guide 1.8, Rev.1-R, (1975) will be met as f egulatory ar as practicable.
Where the combination of strong manager and exp trols cannot practicably be obtained in the serience in rad'olog be appointed so that the combination of key maname person, a de meet the NRC requirements.
ager 'and his deputy will O Or.:
artion of the TMI-2 radiological controls program i program for personnel radiation exposures to be as the ALARA To accomplish this s low as reasonably achievable.
to have radiological engineering as part of hieach engine s assignment.
Thus, most radiological engineering functions are performed i rather than in the Radiological Controls Departm n engineering groups ent.
nation of the TMI-2 ALARA program, howeverThe overall coordi-Technical Support in the Radiological Controls D, is assigned t i
epartment.
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Senior Vice President - Met-Ed 12/07/79 Mw.. _
'i Manager -
Line Radiological Controls Management 4
Prepares procedures used in Radio-Radiological logical Controls Department. Tech-Technical nical support for all groups in Support Radiological Controls Department.
Coordinates ALARA Program.
' Radiological Radiological control technicians Field Operation' and their supervisors.
Train radiological control tech-Radiological nicians and their supervisors.
Trai ni ng Oversee radiological control training of workers.
Inplementation of Dosimetry Dosimetry program.
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Radiation instrument calibration Radiological and repair, respirator testing, Support Services bicassay, radiological laboratory, radiation health.
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Figure 1 TMI-2 Radiological Controls Organization 2 e --
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