ML19308B337
| ML19308B337 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/21/1979 |
| From: | Heward R METROPOLITAN EDISON CO. |
| To: | Jay Collins NRC - TMI-2 OPERATIONS/SUPPORT TASK FORCE |
| Shared Package | |
| ML19308B334 | List: |
| References | |
| NUDOCS 7912280437 | |
| Download: ML19308B337 (22) | |
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Metropolitan Edison Company f4" (')
Post Of fice Box 480 W'[-
Middletown, Pennsylvania 17057 717 944-4041
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Writer's Direct Dial Number
Subject:
Radiation Protection Plan Date:
11/21/79 To:
J.T. Collins As per our discussion of 11/19/79, I am transmitting to you a draft copy of the Radiation Protection Plan.
I would appreciate any comments you might have.
Upon completion of Met-Ed internal reviews, the final copy will be sent to you on 11/28/79.
i R.W. Heward, Jr.
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R.C. Arnold I
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l Metropohtan Edson Company is a Member of me General Pubhc Utst.es System 7912280 37-
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Chapter 1 Introduction The accident which occurred,at TMI Unit 2 has created an environment s.
of radiological conditions which is unique to the Nuclear power industry.
These conditions include extreme contamination control problems and work in unusually high beta radiation fields. The accident has also focused 4 tremendous amount of attention on these problems. The uniqueness of these conditions makes it imperative that Metropolitan Edison Company have a Radiological Protection Program which is an inte-gral part of the Recovery Program which is an integral part of the Reco.ery Operat ions at TMI Unit 2.
This program must funct ion ef fec-tively to assure that radiation exposure to station personnel involved with the Recovery and the off-site public is maintained As-Low-As-Reasonably-Achievable ( ALARA).
In order to funct ion ef fect ively it must involve every individual and all elements of the TMI Unit 2 organization. The Metropolitan Edison Company and General Public Utilities Management is firmly committed to a strong Radiological Protection Program and has led in its development.
Radiation exposure is detrimental to health in that there is risk associated with even small exposures to radiation. However, the risk from exposures within the occupational exposure limits will not be significantly higher than hhat from working in a normally safe industry.
Nevertheless, it is necessary to control exposures to levels as low as reasonably achievable. All individuals will be expected to be respon-f sible for maintaining their exposure as low as possible within the scope i
of the work they are required to perform. No excuse will be tolerated for not complying with the specific requirements of all radiological i
control procedures.
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The Metropolitan Edisnn Company uses as the bases for the Radiological Protection Program the egulations and guidelines of the Nuclear Regu-s..
latory Commission. This Radiation Protection Plan establishes the polices which shall be used to implement the Radiological Protection Program. The Radiological Controls Procedure Manual will be used to put the policies into effect.
3 This Radiation Protection Plan deals with the problems to be encoun-tered at Unit 2.
The Unit 2 program will be independent of activities at Unit 1, although there will be some interface such as in the common use of craft personnel and Radiological Support Services under the jurisdiction of Unit 2.
Strict compliance with the RCPM is the responsibility of each employer and his supervisor at TMI-2.
To assist in and verify this compli-ance, Radiological Control Technician and Foremen shall be available.
Radiological Control Engineering personnel shall provide technical sup port and continual reviews to verify the implementation and ef fective-ness of the Program. A Radiological Protection Inspector shall perform continuous surveillance of the Program for the Senior Vice President -
I Nuclear Operations. Periodic Technical Reviews shall be conducted, in the form of a comprehensive system of planned audit, by technically qualified personnel who are independent of TMI Unit 2 Radiological Controls Department. The Generation Review Group will also conduct a semi-annual review. Three reviews shall encompass the safety-related subject included in Appendix A of Regulatory Guide 1.33 " Quality Assurance Program Requirements (Operation)" as follows:
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Access control to radiation areas, u
Radiation Vork Permit system.
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Radiation survey's 3)
Airborne radioactivity monitoring 4)
Contamination control 5)
Respiratory protection 2.
6)
Training in radiation protection 7)
Personnel monitoring 8)
Bioassay program 9)
Implementation of ALARA program l
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Chapter 2 Radiological Controls Depaetment Metropolitan Edison's str'okg. commitment to a Radiological Controls 2.1 Program rests with the Senior Vice President - Met-Ed and line manage-ment is responsib!e for implementing this commitment with the opera-tion, maintenance, and recovery of Unit 2.
Because of this commitment the Manager - Radiological Controls is l
responsible to the Senior Vice President Met-Ed for establishing policy, providing advice, and technical assistance on all matters concerning radiological controls. The Radiological Controls organization is illustrated in figure 2-1.
1 2.2 Qualifications for the persons in key positions in the organization are strong managers, technical expertise in radiological controls and those qualifications as described in ANSI-3.1-1978 and Regulatory Guide 1.8.
Persons who do not specifically satisfy.the requirements of ANSI-3.1-1978 and Regulatory Guide 1.8, shall have deputies appointed who shall meet these qualifications.
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Sr. Vice President Met-Ed Other Departments Manager Radiological Controls Implementation, Radiological ield' Operations of Rad-controls Formulation and imp ementation of l
Radiological Training Rad Con training programs Radiological Technical Support e
er Radiological Conuob Radiological Technical Support section as well as Unit 2 Recovery Operation Implementation of Dosimetry
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Dosimetry Program i.
Functional Administrative and Material : pport of Radiological Support Services Rad Control Program 8
l RADIATION C0tTEROLS ORGANIZATION UNIT II Figure 2-1 a
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Chapter 4 Standards for Radioactive Contamination Control 4.1 The large amounts of radidactive materials released from the reactor building and the magnitude of th"e 'contaminat ion control ef fort which shall be required during the reactor recovery activities makes it necessary to set a standard which shall be effective and can be efficiently used. Therefore, the criteria to be used for determining if an area, 7r item is contaminated is 100 cpm above background as measured by a pancake-type GM probe (e.g. HP-210 or HP-260) passed slowly over the surface being monitored.
If the surface contamination is greater than this criteria, the item shall not be unconditionally released as or to an unrestricted until a smear has been made to deter-mine the amount of removable contamination is than 1000 dpm/ 100 cm.
If the removable contamination level exceeds this criteria, the item or area shall be handled in accordance with the RCPM.
4.2 If all the surfaces of an item cannot be effectively surveyed with the reference probe, the item shall be dissassembled for survey or a smear survey shall be made in accordance with the RCPM. The criteria for whether the smear indicates a contaminated condition is 100 cpm above background using the reference probe in close geometry to the smear.
4.3 An evaluation of alpha contamination shall be made if there is reason -
to believe that alpha activity may be present. The criteria for alpha contamination is 20 dpm/100 cm as measured with an alpha survey probe or a smear.
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l Chapter 5 Radiation Exposure Control 5.1 ALARA Program I -.
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The ALARA philosophy prevades all phases of design, construction, operation, maintenance, modification and deact ivation.
It brings to bear the resources, technology and methodology, which can be applied to reduce the sources of radiation and radioactivity, to limited access 2
to radiation areas and radioactive materials, and to optimize the pro-tective measures used to minimize. radiation exposure to personnel.
The application of the ALARA philosophy includes evaluation of economics, schedules, engineering parameters, the radiological environment and the consequences associated with the available alternatives related to these areas of concern.
The ALARA program shall involve line management from all department 5 taking an active role in radiation exposure control and reduction.
It shall also involve an extensive effort from Radiological Technical Support in providing the radiological evaluation and guidance to aid line manage-ment in their dose reduction efforts. Those operations involving the potential for significant exposure to radiation shall require preplanning and a review by Radiological Technical Support prior to approval. The criteria for this review shall be promulgated in the Radiological Controls Procedures Manual.
5.2 Restricted Areas 5.2.1 A restricted area is any area to which access is sontrolled for the purpose of protection of individuals from exposure to radiation and radioactive materials. The restricted areas which shall be used to control personnel access to radiation and
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radioactive mater,ials shall be defined and posted in accordance with 10 CFR 20.203 ich.the following modifications.
Each High Radiation Area shall be barricaded and conspicuously posted as a High Radt.ation Area, and personnel desiring entrance shall obtain a Radiatien Work Permit. Any area accessible to personnel where a major pertion of the body could receive in any one hour a dose in excess of one thousand (1000) arem, shall be locked to prevent unauthorized entry. The keys to these locked barricades shall be maintained under the administrative control of the Radiological Controls Foremen and the Shift Supervisor on duty, in accordance with - RCPM.
Access to these areas will be limited to those persons author-ude ized{RadiologicalControlsDepartment. The basic entry require-is the wearing of TLD badges, self readip'ng dosimeter (or ments equivalent) and appropriate protective clothing.
Special protect ive clothing requirements will be developed for work involving the high beta radiation fields which shall be en-countered during the Recovery Operations. Additionally, any individual entering a high radiation area shall have a dose rate indicating instrument to aid in minimizing his radiation exposure.
5.2.2 Protected Area The Protected Area is a special restricted area in that pescannel access is controlled for radiological controls purposes as well as security purposes. Personnel must be wearing their assigned TLD while inside the Protected Area.
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5.3 Respiratory Protection Pro' gram of Metropol' tan Edison directs the Unit 2 Recovery oper-l; The management ations and maintenance such that th'e exposure of personnel to airborne radioactive material is minimized. The Radiological Controls Department is required to assure that inhalation hazards are identified throughout the plant and that the most effective and pract ical means for coping with them are employed.
The primary method of minimizing inhalation hazards is to prevent radio-active material release to accessible areas of the plant.
Secondarily, engineering controls shall be used to the extent practicable to minimize the need to work in areas with airborne radioactivity.
In certain cases where the prevention or control methods are inadequate in minimizing inhalation exposures of personnel, including those where exposures cannot be maintained within the limitations of 10 CFR 20.103, the Radiological Controls Department can prescribe the use of approved respiratory protection devices. Such devices are designed to limit the content of radioactive material in the inhaled air of individuals wearing them in work areas containing airborne radioactive material.
Such devices are to be prescribed in accordance with Radiological. Con-trols Procedures Manual to provide the most effective and prac-tical match of inhalation protection required for the type and level of radioactive containment involved.
Prescription of respiratory protection devices is limited to those work situations for which no other effective and practical prevention or i
control method exists. This policy means that minimization of inhalation
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exposures is accomplished by methods other than through the use of respiratory protection devices for situations that are not infrequent
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non-routine jobs or those created by emergency conditions. The Radio-logical Controls Department will verify that other methods are inef-fective or impractical before prescribing the use of respiratory pro-tection devices.
Once prescribed, the devices are to be used and worn in accordance with...
logical Controls Procedures Manual which include specific instructions to personnel concerning the relief from respirator use for reasons of user discomfort, equipment malfunction, or any other condition necessitating relief.
Individuals shall be properly trained and fitted in the use of respiratory protect ive devices. Training and fitting are to be accomplished in accordance with the Radiological Controls Procedures Manual.
The following respiratory equipment maintenance items are required prior to re-issue of equipment:
1.
Respirators will be checked for contamination and mechanical defects.
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Respirators will be sanitized.
3.
Filter canisters and cartridges will be discarded after use.
5.4 Radiation Work Permit The Radiation Work Permit ( R*JP) is used to assure that radiological controls are properly prescribed to maintain radiation exposures
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ALARA and to perform an ALARA man-ram accounting on all work ef forts I
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5.4.2 It is the responsibility of the working party supervisor to originatetheRadiat\\onWorkPermit.
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5.5 Radiological Surveys and Records 5.5.1 The radiation protection program will include radiation survey for air activity, removable surface contamination and radiat ion.
5.5.2 Radiation Surveys Beta gamma dose rate, surface contamination, and airborne contamination surveys shall be conducted at regular intervals in various plant areas in accordance with RCAM. Unusual condi-tions detected in the performance of either a routine or special survey shall immediately be brought to the attention of Radio-logical Controls personnel.
5.5.3 Records Records and reports required to show compliance with Federal Regulations shall be maintained on file.
Information frem routine and special radiological surveys shall be recorded on appropriate survey forms.
Radiological Control program records whether considered primary, secondary or sup-port ing records shall be maintained until authorized by the NRC to do otherwise.
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Chapter 6 Radiation Exposure Mohitoring Program 6.1 Policy It is the responsibility of each individual to wear his assigned TLD and self reading dosimeter in the manner prescribed in RCPM The loss or damage of any personnel monitoring device requires the immediate notifi-a cation of a Radiological Controls personnel.
6.2 Personnel External Monitoring Program 6.2.1 All personnel assigned to work in restricted areas including the Protected Area shall be issued a TLD badge. The official determination of accumulated external radiation is made from the TLD.
6.2.2 A self-reading dosimeter will be issued, in addition to a TLD to certain individuals where the conditions of werk make a day to day indication of exposure desirable. Dosimeters shall be read, recorded, and re-zerced regularly by Radiological Controls per-sonnel. A form for recording individual dosimeter readings will be kept at each Rad,iological Controls, Control Point. Dosi-meter records will furnish the exposure data for the administrative control of radiation exposure. Personnel finding their self reading dosimeter off-scale shall leave the radiation area immediately and notify Radiological Controls Department.
6.2.3 Special dosimetry devices shall be issued at the discretion of the Radiological Controls Department. Such devices may include l
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extremity monitoring badges or special dosimeters for measuring skin exposure in high beta radiat ion fields.
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6.2.4 TLD badges shall be processed at monthly intervals or more frequently. The TLD badge of any individual shall be processed immediately at an'/ time that an overexposure has occurred or is suspected.
6.3 Personnel Internal Exposure Monitoring 6.3.1 An internal exposure monitoring (bioassay) program shall be maintained consistent with the requirements of Title 10, Code of Federal Regulations, Part 20. The internal exposure monitoring program at TMI is accomplished enrough the implementation of a system of routine and special whole body counts, fecal analyses, and urinalyses, in order to:
Determine the magnitude of a suspected or known uptake a.
and to provide data for the evaluation of the dose equiva-lent of uptakes of radioactive material, b.
Provide a baseline record for subsequent evaluations of uptakes, and, Monitor the ef fect iveness of' respiratory protection c.
measures utilitted at TMI.
I 6.3.2 All individuals who enter restricted areas will be included in the bioassay program.
6.4 Plant Radiation Monitoring Radiation levels within the plant shall be monitored by a combination of portable survey semi portable instruments (continuous air monitors, hand and foot monitors, portal monitors) and fixed monitors (i.e.. remote area monitors, effluent act ivity monitors). These instruments will be main-tained and periodically calibrated to assure a consistent, reliable and
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predictable response to radiation levels in the plant and any changes thereto.
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Chapter 7 Radiological Contro1' Training 7.1 Radiation Control Training' Objectives 1.
The primary objectives of the Radiation Protection Training Program shall be to:
a.
Ensure that all personnel involved are instructed about the biological effects of radiation and the risks associated with the acceptance of radiation exposure.
b.
Provide the information needed to enable each person to co;. ply with health physics procedures and respond properly to warnings and alarms under both normal and emergency conditions.
c.
Provide the information needed to ensure that individuals can maintain their own exposurs ALARA and ensure that ALARA considerations can be appropriately reflected in decisions which af fect the exposure of othes.
d.
Provide the information needed to enable each person to comply with NRC regulations and TMI Unit 2 Technical Specifications.
i 7.2 Radiological Controls Training i
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Ceneral Radiological Control training shall be given to personnel whose work assignments do not require unescorted access to areas controlled by Radiation Work Permits.
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Intermediate Radiological Control shall be given to personnel whose assignmer.ts require unescorted access to areas controlled by Radiation Work Permits.
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Initial training shall be given for the qualification of new 7-1
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Radiological Control' Technicians.
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Retraining shall be gIVen to.all Radiological Control Technicians.
Management has a strong commitment to ensure that retraining is being accomplished adequately.
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Respiratory Protection Training shall b. given to personnel whose work assignments require that they wear respiratory protection equipment.
6.
Task-specific Training shall be given to personnel who have been assigned to a task which involves significant radiological hazard should receive indoctrination in the specific hazards in the work place, in appropriate special radiation protection procedures, ALARA considerations, and the use of special protective clothing, respir-ators, and equipment.
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.e Chapter 8. Rrdieretiva M ;tarials Csntrol Progrra 8.1 The Unit 2 Recovery Operations will generate more radioactive materials F'~.
than normally generated at a' nuclear power facil-ity.
The following chapter summarizes the standards and guidelines needed to assure com-pliance with Federal regulations regarding the transfer possession and use of radioactive materials.
8.2 Responsible supervision shall notify Radiological Controls as soon as possible after becoming aware that radioactive materials will be received, or shipped at TMI Unit 2.
8.3 Upon receipt of any radioactive material, the Radiological Controls Department shall be promptly notified. A Radiological Controls repre-sentative shall monitor all radioactive material received and advise as to handling or storage. Receipt of radioactive material shall be in accordance with the RCPM.
8.4 Prior to the shipment of any radioactive material, a Radiological Ccntrols representative shall survey the material. The shipment shall be monitored after packaging to ensure compliance with all existing Federal and State Regulations covering such, shipments.
Shipments of radioactive material shall be made in accordance with 10 CFR 71 and additionally, in the case of spent fuel assemblies, in accordance with the provisions of the facility license.
8.5 All radioactive materials gene, rated during the Recovery Operations j
shall be handled in accordance with the requirements of 10 CFR 20, 30, 40 and 70.
As an aid to assure compliance, an accountability program 1
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x 8.6 Radiological Controls shall periodically perform inventories of speci-fically licensed radioactive sources on site.
Records shall be kept of all inventories, receipt, transfer, disposal, leak tests, and any other information pertinent to byproduct material.
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Chapt'er 9 ' RADIOACTIVE WASTE DISPOSAL 9.1 S__ cope
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The release of all plant radiBactive effluents shall be subject to the regulations specified in 10 CFR 20.106 and the provisions of the i
Technical Specifications.
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Chrpter 10 Investigction and Natificction of Incidante 10.1 Formal notification of various governmental agencies shall be required u...
in the event of a serious rddieti.on incident or emergency. To assure compliance with the requirements of 10 CFR 20.403, all communication with the Federal and State agencies shall be handled in accordance with the RCPM which specifies all communication requirements in connection with radiological emergencies and overexposure incidents.
c 10.2 All radiological emergencies and overexposure incidents shall be inves-tigated. This investigation shall be conducted to determine the probable causes of the incident and the management systems which should be improved to prevent a recurrence.
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