ML19290G610

Responds to NRC 800908 Ltr Re Violations Noted in Health Physics Appraisal Rept 50-298/80-07.Corrective Actions: Procedures Revised to Include Necessary Guidance in Choosing Personnel & Training Program Restructured

ML19290G610
Person / Time
Site:	Cooper
Issue date:	10/11/1980
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19290G607	List: ML19290G610
References
LQA8000433, NUDOCS 8012180128
Download: ML19290G610 (13)

Text

.

3ENERALov8'CE

. 2 44601 Nebraska Publ.ic Power D.istrict c. SC,x 419. ;cLuM BLS.

a~cm.m uoN Esu S A A5 KA LCA3000433 October 11, 1980 Mr. Karl 7. Seyfrit, Direc:or U.S. Nuclear Regulatory Commission Office of Inspecticn and Enforcement Regicn IV 511 Ryan Plaza Drive Sui a 1000 Arling:en, Texas 75011

Subject:

N??D Response to Eealth Physics Appraisal Program, II Inspection Report No. 50-298/30-07

Dear Mr. Seyfrit:

This letter is vri::en in response to your letter dated September 3, 1980 ::ansmit:ing II Inspection Repor: No. 50-298/30-07. A respense war to be submitted within 20 days upon receipt of your letter; however, we requested (by telephone) and were granted an extension. Several items that "fou considered significant weaknesses in our program were listed in Appendix A of your letter. Inree items of apparent non-compliance were listed in Appendix 3. 'Je have listed :he findings as stated in each Appendix vich our response following each finding.

Appendix A - Significant Appraisal Findings Statement of indinz A. Personnel selection, qualification and training cri:eria for heal:h physics staff me Sers have not been established in written Station procedures to assure : hat appoin =ents :o the health physics staff vill meet the recuirements of Technical Specification 5.1.1, which references ANSI NIS.1-1971, and :he guidance established in NRC Regulatory Guide 1.3. In addition, the initial training program for health physics staff is not structured to assure na :he qualification cri eria are net prior :o appointment to responsible positions.

801u,8o \0

Mr. Karl 7. Seyfri:

Oc:cber 11, 1980 Page 2.

Response

Corree:ive Action In Our review of :he abovt finding, we feel our station precedures nay be lacking in guidance in some areas necessary to ensure :he nNSI 13.1-1971 cri:eria are zet, bu: feel station anage=ent has always been aware of the intent of ANSI 13.1-1971. A later revision of this standard, ANSI /ANS 3.1-1973, and Regulatory Guide 1.3 are used as guidelines in the selectica, qualificatien, and training of our plant staff. Ad-di:icnal guidance should be included in Station Operating ? ocedure 1.3 to ensure that the individual appointed :o the Che=istry and Hualth Physics Supervisor posi:1cn, who is the Radiation Protection Manager, meets the require =ents of Regulatory Guide 1.3.

Station Operating Procedure 1.5 outlines the steps that rust be com-pleted when an individual is :o be e= ployed by Nebraska Public Power District for work at Cooper Nuclear Station.

These steps include requirements for detailed infor=ation en personal data, education, : raining, f o r=e* -414 *ary histo ry, personal references, background check, and physical exa=1 nation. Intcrviews are also conducted.

If an inddvidual's infor=ation and interview results art f avorable and Cooper Nuclear Station's =anagement feels this individual is capable of becoming qualified, if not already so, the individual say be employed as a Health Physics Technician. Station =anagement has always fel: that prospective e=picyees should have a rombination of education, expe r-ience, ueal:h, and skills that will enable them to perform their level of responsibility satisiac:orily and should be capable of becoming qualified if not already qualifi=d. Section 1.5.3.C of Procedure 1.5 states, "If not already qualified by experience and related technical training, opwrators, technicians, and naintenance personnel shall be trained by on-the-job training; by participation in initial calibration,

esting, and equipment a_ceptance progra=s; or by related technical training." This is al=ost a direc: quote from ANSI 13.1-1971 and the later revision to this standard, ANSI /ANS 3.1-1973.

As stated in the Appraisal Report (Section 2.3.3, Health Physics Staff Training), "Iach H.P. Technician has an extensive training checklist which covers virtually all the job functions in the Health Physics department. . .When a new can is qualified for a particular job ar pra-cedure, that fact is :cted on the list by date and person doing the training. The checklist is very comprehensive and provides a good record for quald.fication at each stage of training." When an H.P.

Mr. Karl V. Seyfri Oc:cber 11, 1980

? age 3.

Technician has co=pleted training and has de=onstra:ed his ability to perfors a job fune: ice, we feel he is qualified to perfor: : hat func-tion. As stated above, this training and qualification list covers virtually all :he H.P. Technician's scope of responsi'oilities. Cnca a

echnician has completed all af the ite=s on the : raining checklist, he is qualified to perfor= all the duties of a Health Phjsics Technician.

If 1: takes the individual two years :o comple:e the qualification list, then he is fully ANS! 13.1-1971 qualified. If he comple:es :he qual-ification list in less than two years, he is allowed :o perform only

hose functions for which he is qualified to gain experience. Also, within this :vo year period he will have attended a for=al of fsite radiation protec: ion course, usually at a university.

The state =ent of finding above states, ".... prior to appointment to responsible positions." When an individual is hired as a H.P. Tech-nician, his titi a is H.P. Technician whether or not he is ANSI 13.1-1971 qualified. The indivifual will then progress :hrough our training and qualification program. Individuals in training are permit:ed :o perform work for which qualification has been de=enstrated in order to obtain the required experience.

Corrective Actions Which Will 3e Taken Procedure 1.3 vill be Tvised to include the necessary guidance and clarifications to ensure the requirezcats of (NSI 13.1-1971 and the guidance of Regulatory Guide 1.3 are 2 21 filled. Cur Health Physics Technician training program is being restructured to provide qualif-ication and requalification training on a sore timely basis and to also provide for the documentation of each phase of that training.

Date When Correc:it' Actions Will 3e Cocoleted The above corrective actions will be co=pleted by March 1,1981.

Statemen: of Finding

3. Internal expcsure control program procedures containing necessary biologim.1 =cdels and calculational techniques have not been estab-lished to assess the results of direct and indirec: bicassay reas-urements in :er s of intake limits specified in 10 CFR 20.103 and internal desize:ry guidance available in ANSI . 343-1973, "!n ernal dosimetry for 21xed fission and ac:ivation products." In adcition, Station procedures do not fully i=ple=ent :he requirements of 10 CFR 20.203(d) (1)(11) and 10 CFR 20.103(b) in regard to defining an airbo rn a radica. ivity area, ensuring consideration of engineering controls fot airborne radioac:1vi:7 areas, defining :he 10 M?C-RR control measure and evaluating exposures which exceed this control measure to assure against recirrence.

Mr. Karl 7. Seyfri:

October 11, 1980 Page a.

Rescense Corrective Action A review of our respiratory protection progra=, bicassay-whole bcdy counting program, area posting procedures and exposure li=1:ations was pe rf o rmed. 3ased upon the results of that review, we conclude that c:ntrary to the above state =ent of finding, that:

1) Station ? ccedure 9.1.2.1 (Radiation Contamination, and Airbor=e Radioactivity L1=1:s), See:1cn II.C sta:es, "Even though the deses quoted in the standards are per=issible all effort should be direc:ed toward =aintaining exposures as low as reasonably achiev-able (ALARA)."

2) Section 7I.3.1 (same procedure) states, " Exposure to airborne radioactivity concentrations approaching the MPC's should be pre-vented."

3) See:icn V!.3.a (sa=e procedure) states, "The nu=ber of hcurs worked in areas where XFC values are exceeded will be docu=ented by the S'4P sign-in sheet. If an individual exceeds 2 MFC hcurs/ day or 10 MFC hours / week, this will be entered in his exposure record."

4) Station Procedure 9.1.2.2 (Area Posting and Access Control),

See:1on VI. A. 3.1 defines airborne radioactivity area, "any area, accessible :o personnel, in which airborne radicactive nacerials, co= posed wholly or partly of licensed =aterial, exist in concen-

ations whieh: (1) are in excess of amounts specified in Appendix 3, Table 1, Column 1 of 10 CFR 20 or (2) averaged over the nu=ber of hours in any week during which individuals are in the area, exceed 25" of the a=ounts specified in Appendix 3, Table 1, Colurn i of 10 CFR 20."

3) Sta:icn ? ccedure 9.1.5 (Respiratory ? ogra=), Section IT states, "The pri=ary objective of a respiratory progra= is to 11=1: :ne inhalation of airborne radioactive =aterial. Th.s objective is nor= ally acco=plished by the applications of engineering controls, including process, containment, and ventilatien equipment. '4 hen it is impracticable to apply process or other engineering :entrols to 11=1: concentrations of airbcrne radioactivity, other precauticnary procedures, such as increased survei._ance, li=iting of working ti=es, or provision of respiratory protective equip =ent, shall be used to =ain:ain intake as low as is reasonably achievable. In general, the use of respirators is less desirable in providing respiratory protection than is the use af process, containment, and ventilation :echniques or time li=itations."

Mr. Karl 7. Seyfri:

Cctober 11, 1980 Page 5.

6) Section IV.C.a (same procedure) states, "A MPC-H Log, Attach =en:

"3" (CMS Health Physics Data Form CNS HP-25), will be documented anv :1:e an individual exceeds 2 MFC Hrs / Day :: 10 MFC Hrs / Week;

7) Section IV.C.S (same procedure), states, " Station =anagement shall, as a precautionary procedure, use process or other engineering controls, to the extent practicable, to limi: concentrations of radioac:ive =aterial in air to levels ALARA; when it is i=p rac-ticable to apply these centrols, other precautionary procedures, such as 11=itatien of working times, or provisions of respiratory protective equipment shall be used in airborne si:uations to =ain-tain uptake ALARA."

5) Sta: ion Precedure 9.1.3 (Radiatien Safety Standards),Section VI.A.1 defines the 40 MPC-HR centrols.

We feel that we have adequately defined and implemented the requirements in 10 CFR 20.203(d)(1)(ii) and 10 C7R 20.103(b), however, we agree that necessary steps have not been included to evaluate exposures which exceed these centrol reasures, Corrective Actions Which Will Be Taken Revisions :o Station Procedures 9.1.5, Respiratory Program, and 9.1.3, 31oassay-Whole 3ody Counting, vill be vri::en :o include necessary guidance, biological =cdels, and calculatienal techniques to access internal exposure in :he event the centrol neasures of 10 CFR 20.2C)

(d)(1)(ii) and 10 CFR 20.103(b) are exceeded. ANSI N343-1978, and International Cocsissien on Radiological Protec:1cn publications will be used as a guide in the revising of these procedures.

When the precedures have been written and approved, a training session will be scheduled for the Heal:h Physics Technicians :cvering the ap-proved additions. This ::aining session will also review the total respiratory protection and bicassay prograss.

Date When Corrective Actions Will 3e Cocoleted The revision of the above sentioned procedures and the training session 4111 be co=pleted by March 1, 1981.

Mr. Kari 7. Seyfri:

October 11, 1980 Page 6.

Statement of Finding C. Personnel contamination =cni:oring precedures for workers exiting the reactor building are not in accordance with good practice, in that workers are not required to scnitor for contamination wi:h a sensitive instrument, such as a frisker or hand and foot noni:or, prior :o exiting from the reactor building airlock. Personnel contamination =onitoring at this point was observed to be limited to passing through a rela:1vely insensi:1ve portal soni:or.

Response

Corrective Ac:icn A frisker is also available at exit of the reactor building airlock near the portal seni:or. Difficulties exist with the use of friskers; i.e.

the dfstance :he probe is held from bcdy, and speed with ;hich the probe is passed over the bcdy. We feel hand and foot monitors are not the definite answer. They de not =enitor other parts of the body tha: are susceptible to becoming contaminated, although the hands and feet are

he mos: likely :o become contaminated. Also, problems exist with keeping these monitors in good condi: ion and able :o perform a good survey of hands and feet. We do not feel either type instrument is suitable for providing good monitoring capabill:1es in timely exits of the reactor building.

Prior :o :he spring outage of 1980, CNS management had pursued an al-ternative method, that of a liquid scintillation walk through type non-itor that surveys the whole body. The vendor of such an instrument was contacted and its application discussed. This instrument was described as being very sensitive and capable of detecting contamination as low as

hat of a frisker. We inquired as to arranging a de custratien, rental or purchase, but these instru=ents would not be available for 9-13 onths.

This vendor was contacted again October 6, 1980. The vendor stated that production of this monitor has been increased 2nd that avr.11aoili:7 was approximately 90 davs. The vendor also stated a demonstration would be arranged within six months.

_ Corrective Action That Will 3e Taken We will ecutinue to investigate this type of onitoring devire. If, during the de=enstration it proves to be as sensitive as inc;cated and its application appropriate, we will pursue possible installation at the exit of :he reactor building.

Mr. Karl V. Seyfri:

Cetober 11, 1980 Page 7.

Oate When Corrective Actions 2111 3e Concleted If :he de=enstra:icn of this nev :ype of =cni:or indicates : hat it will fulfill our needs and availability does not change, one or more will be installed by October 1, 1981.

Appendix 3 - Notice of Violation Statecent of Infraction A. Technical Specification 5.1.4 states, "The minimum qualifica:icns, training, replace =ent training, and retraining of plant pe rsonnel at the 1:e of fuel loading or appoint =ent to the ac:ive posi:1cn shall meet the requirements as described in the A=erican National Standards Institute N13.1-1971, "Selectica and Training of Per-sonnel for Nuclear Power Plants." Section 4.5.2 of ANSI N13.1-1971 states, in part, " Technicians in respcnsible pesi: ions shall have a mini =us of :wo years of working experience in their specialty."

Centrary to the above requirement, at :he time of :he appraisal, two health physics :echnicians having approxi=a:ely six and ten

=enths of working experience in their specialty, respectively, had been appoin:ed to respcusible positions en :he heal:h physics stai!.

Corrective Stecs Which Have 3een Taken and Results Achieved We have reviewed the statement of _nfraction as well as the qualifi-cations, training, and experience of the two :e.:hnicians in question.

It is agreed that the :wo :echnicians do not eet the =inimum o f two years of working experience La their speciali:y as per Section 4.5.2 of ANSI N13.1-1971; however, we believe the wording in ANSI /ANS-3.1-1973 is more appropriate in meeting our goals for qualifica:icns of nuclear power plant personnel. The following is quoted fres Section 4.1 of that standard.

" Nuclear pcwer plant personnel shall have a :c=bina:icn of education, experience, health, and skills coccensurate with their functicnal level of responsib111:7 which provides reasonable assurance that decisions and ac:1cns during nor:al and abnor=al conditions will be such that the plant is operated in a safe and efficient =anner."

Mr. Kari 7. Seyfri Oc:cber 11, 1980 Page 3.

Cther appropriate parts of the standard are quoted to aid in under-standing our posi: ion.

3.2.a " Individuals in training or apprentice posi: ions are not censidered technicians or =aintenance personnel for purpcses of defining qualifica:icns in See:1on " Qualifications," but are per:1::ed to perform work for which qualification has been de=custra:ed."

4.5 "Cperator-Technician-Maintenance Personnel. The qualifi-cations of personnel described belcw are for the licensed operators and journey =en level personnel. Individuals in training or apprentice posi:icns are per:1::ed :o perform work for which qualification has been de=cnstrated in order :o obtain the required experience."

The selection and training of health physics technicians was to be conducted with the above criteria in sind. The program in use was described in Section 2.0 of the appraisal report. A review of :hese Health Physics Technicians' training and experience agains: this program was perfor:ed.

Technician "A" has a 3achelor of Science Degree in Engineering !?.ch-cology, which included extensive inscraction in nuclear engineer ng and experience in radioisotope counting laboratory instrumentation. Je was also a member of the studen: chapter of the A=erican Nuclear Society.

? ior to entering college, he served in the Navy as an electronics

=aintenance :echnician, with work involving instrument calibration and repair. This individual was hired in November 1979 and had six cenths experience a: Cooper Nuclear Station at the time of the appraisal in-spection. He has received :uch training and experience and is qualified to perfors many of the Health Physics Technicians' func:icns. We believe :he Navy exper;ence, his : raining and experience vnile obtaining his degree, his experience at this station, and our : raining and qual-ification program nake his qualified for :he jobs he has been performing.

Technician "3" has a 3achelor of Science Degree in 31 ology. This in-dividual was initially hired in January 1979. This was en a par: ti=e basis while he ccepletec :he few recaining academic hcurs required for his degree. His nor=al work week was 30-40 hours during this time period. He was given training and gained =uch axperience, including outage experience. He was hired on a full :ime basis August 1979, after having cc=pleted his 3achelor of Science degref. requiremen:s. We feel

Mr. Karl V. Seyfri:

October 11, 1980 Page 9.

he actually had 16 =cnths expe:ience at the time of the appraisal 19-specticn as opposed to :he ten acnchs stated in the aeove finding. He has attended a Radiation Protection Course a: Harvard "niversity and has received :uch ::aining and experience and is qualified to perform : st of the Health Physics Technician functicas. We believe :he above men-

icned ::aining and experience, along with our qualification ar gran

= ate hi= qualified for the j obs he has beer pe rf o r=ing.

We have also reviewed the sign of f sheets for the Health Physics Training Cutline for :he two technicians. We f:und : hat :he sheets were 00: up to date a :he time of the appraisal. We also f:und that the tech-nicians had been performing sc=e func:icns that had not been properly signed of f in the training records. We believe the personnel were qualified to perfor= these functions but we had not recorded this determination as required by our pr: gram. Thus, we believe 2 nera appropriate non-ccepliance would !; ave been that we were ac: :ceplying wi:h our prescribed progra= for qualificati:n and training of :he Health Physics Tecanicians.

Corrective Stecs Which Will 3e Taken to Avcid yurther Items of Non-coroliance

1. We have updated the qualification and training records of these technicians.

2. Appropriate persennel have been infor ed that the technicians are not to perfor= asks independently unless : hey are properly qual-ified and the records shew these qualifications.

3. We are censidering a request for Technical Specificatien Change to change Sectica 6.1.4 Oc reference ANS/ ANSI 3.1-1973 instead of ANS!

N-13-1971.

Date When Full Octoliance Will Pe chieved The above items 1 and 2 have been cocpleted. We vill inform you by Nove:ber 1,1980 as :o our planned acticns regarding a Technical Spec-ifica ica change.

Statement cf :nfraction

3. Technical Specification 6.3.5 s:ates, in part, "...each high rad-iation area shall be barricaded and conspicuously posted as a High Radiation Area and entrance theretc shall be controlled by re-quiring notification and per=ission of the shif t superriser. Any individual or group of individuals permitted to enter such areas shall be provided with a radiation eni:oring device which con-tinuously indicates the radiati:n dose rate in the area."

Y.r. Karl 7. Seyfri:

Cc:cber 11, 1980 Page 10.

Cen::ary to the above require =ent, during the period M_ay 5-16, 1980, individuals were observed entering the reactor dryvell, a high radiation area, vi:hout notifying the shift supervisor and vi:hout being provided with sufficient radiation nenitoring devices Oc continuously indicate the radiation dose rate in the area in which they were working.

Rescense Discussion We believe Section 6.3.f of our Technica: Specification is overly re-s rie:1ve in regards :o notification and permission of :he Shif t Super-visor and the requiring of radiation =enitoring devices.

Paragraph 20.203'c)(3) of 10 C7R 20 states, "any license, or applicant for a license, =ay apply to the Cc==issica for approval of methods not included in subparagraphs (2) and (4) of :his paragraph for controlling access :o high radiation areas. The Cc==13sion vill approve the pro-posed al:arnatives if the licensee or applicant de=enstrates that the alternate =ethods of control vill prevent unauthorized entry into a high radiation area, and that :he require =ent of subparagraph (3) of :his paragraph is set." Subparagraph (3) pertains to leaving a high rad-iation area and is not perrinent :o this issue. We believe that Par-agraph 20.203(c)(2) of 10 CFR 20 actually pertains to control of access to high radiation areas so : hat a persen does not vander into an area unkncvingly and receive personnel exposure without knowing the a=ounts of exposure taken. We believe our present systa= centro 13 work in the dryvell such : hat this vill not happen.

Our present syste= cutlines that all work in :he dryvell vill be covered by a Special Work Per:1: (SWP). Station Procedure 9.1.1.4 outlines :he generation of SW?'s. Cne of :he SWP require =ents is for the Shif t Supervisor to review and approve all SW?'s before they are posted at the work area. The SWP outlines levels of radiation and contamination for the work area, sets protective clothing requirements, instructions for working in the area and provides for the logging in and out of dosimeter readings. In addition to the SW7, Health Physics personnel nay conduct special surveillances associated with a high exposure or high conta=in-ation job. Exa=ples vould be C2D re= oval :o centrol high level con-

a=ination or instrue:ing verkers in a high exposure area on applicable ALARA techniques in the i==ediate work 2rea; however, they will not conduct continuous surveillance in high exposure areas because ve feel

his would be unnecessary exposure. Other techniques we have used to keep exposures lov is additional shielding vi:hin the work areas and addi:ional postings of radiation levels in an ef for: Oc kee; workers

Mr. Kari 7. Seyfrit October 11, 1980 Page 11.

aware of expcsure ra:es. Health Physics persennel routinely make : curs througn :he drywell work areas :o insure good controls are being main-tained. We also have three portable radiation =eni:oring units vi:h adjustable alars set:ings that are used in the upper par: of :ha drywell to =enitor and alert personnel in event of a significan: change of the radiation reading in the dryvell.

We believe our ce: hod of SWP generation in which the Shif t Supervisor grants approval of the SW7 provides the necessary notifica:ica and shows permission. We notice that the April 1,1973 wording of S:andard Tech.

Specs. eli=inates :he wording requiring direct per=ission and notifi-ca:1on of :he Shif Supe rviso r. It is further noted that :he Standard Technical Specifications list alternatives :o providing radiation non-1:oring devices which continuously indicates the radiation dose rate.

One al:ernative is for an integrated dose instru=ent.

Personnel working in :he dryvell area wear a TLD and a dosimeter. The desizecer is read and logged upon entering the dryvell area. I: can be read while in the area if there is any question or concern about the integrated dose. The desi=eter is read and logged af ter exi:ing :he area. In :his way, each person knows the integrated dose : hat was received while in the area. The TLD can also be read if there is a question or concern about des 1=ecer readings.

Another alternative is for continuous Heal:h Physics coverage, but we feel :his is not a good ALARA practice. We believe our method of con-trol is acceptable and that we have de=enstrated this by successful use of our controls. We further believe : hat our above described =ethods have worked successfully through six =ajor outages and many shorter outages over a 64 year period. We have not exceeded any exposure limits and have been able :o keep :ocal personnel exposure te a low level compared :o other cocparable plants.

Corrective Steos Which Have 3een Taken and Resul:s Achieved The outage was terminated and, thus, the access :o he drywell as discussed in :he statement of infraccion does cot exist. We have thoroughly reviewed our current =ethods of :cntrol of access :o high radiation areas and consider them currently acceptable.

Corrective Steos Which Will be Taken to Avoid Further Itecs of Ncn-cocoliance We are considering other methods of conitoring exposure if :his is really required by this particular regulation. We also feel it would be necessary :o take a Technical Specification change.

Mr. Karl V. Seyfri:

October 11, 1980 Page 12.

Date When Full Co=eliance Will be Achieved We are currently La full ec= 11ance; hcwever, we plan :o rescive this issue prior :o our next refueling outage at which time che same cen-dizions and concerns will exist.

Statemen of Infraction C. 10 C73 20.103, " Exposure of individuals :o concentrations of radio-active =aterials in air in restricted areas," states in Section (c), "When respiratory protective equipcent is used to lini: the inhalation of airborne radicac:ive caterial pursuant :o paragraph (b) (2) of this secticn, the licensee may make allowance for such use in esti=ating exposure of individuals to such naterials pro-vided : hat such equipment is used as stipulated in Regulatory Gaide 3.15, " Acceptable Programs for Respiratory Protection. "

Regulatory Guide 3.15 sta:es, in part, Paragraph C. 2, "Respirato ry protec:ive equipment is to be selected to provide a pr:tection factor greater :han the cultiple by which peak concentrations of radioacti"e material are expected to exceed the values specified in Table 1, Colu=n 1 of Appendix 3 to 10 CFR Part 20."

Centrary to the above require =ents, cn April 22, 1980, a painter perfor=ing experi= ental grinding in the torus was provided a res-piratory protective device with a protection factor of 50 during a period in which the peak concentration of a =ixture of airborne radionuclides exceeded the concentration specified in Table 1, Colu=n 1 of Appendix 3 :o 10 CFR Part 20, by a fac:cr of approx-i=a:ely 143.

Rescense Correc:ive Steos Which Have 3een Taken and Results Achieved A review of this incident was conducted. This review indicated :he airborne cencentr ? ciens in the work area were usually <1 MPC wi:h certain activities causing concentratices to go above i MFC but did not exceed 30 M?Cs. The requirements as stated in Regulatory Guide 3.15, Paragraph C.2 are, " ...by which peak concentrations of radicactive

=aterial are excected to exceed :he values specified in Table 1, Colu=n 1 of Appendix 3 to 10 CFR Part 20." Fr:m the data collected, the radio-active airborne concentration was not ex ec ed to exceed the protection factor (30) of the respirator chosen. Industrial safety hazards were

Mr. Karl V. Seyfri:

Oc:cber 11, 1980 Page 13.

also considered when this respirator was chosen. The work area had tripping and falling hazards involved. Respiratory protection equipment with higher protectica factors involved the use of air lines or as in the case of SC3A, weight on the workers' back, which would increase the risk of tripping or fslling.

As stated in the above infraction, this was a short time experimental grinding operation to decernine if this type grinding would solve a surface preparation problem. 3eeAuse of the resul: ant high airborne concentrations, this operation was ter=inated i==ediately.

Corrective Steos Which Will 3e Taken to Avoid Further Noncocoliance This incident was discussed at length wi h the Health Physics staff.

The selection of the proper respiratory protection equipcent was e=pha-sired and will be re-e=phasized during our respiratory protection pro-gram training in the near future. In addi:ica, Statica Procedure 9.1.3 (Respiratory Program) will be revised to clarify the proper selection of respiratory protection equipment.

Date When Full Cocoliance Will 3e Achieved We are in compliance with :he above regulations at the present time.

Procedure 9.1.5 c;11 be revised and approved by January 1,1981.

Training on the procedure change will be co=pleted by March 1,1981.

If fvu have any questions regarding details of this response, please contact L. C. Lessor or J. V. Sayer at the site.

Sincerely, e ~

,%.s

a. .. Pilan Director of Licensing and Quality Assurrance JMP:LCL:cg