ML19323A059

Amend 17 to Restart Rept, App 7A,Revision 2 to Radiation Protection Plan

ML19323A059
Person / Time
Site:	Three Mile Island
Issue date:	04/03/1980
From:	Herbein J, Potts W METROPOLITAN EDISON CO.
To:
Shared Package
ML19323A058	List: ML19323A057 ML19323A059
References
NUDOCS 8004170106
Download: ML19323A059 (24)

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l APPENDIX 7A  !

UIREE MILE ISLAND NUCLEAR STATION I l

UNIT 1 i RADIATION PROTECTION PLAN l

t REVISION 2

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Am. 17 8004170[08,*

• Revision 2 i April 3, 1980 O .

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k THREE MILE ISLAND NUCLEAR STATION

, UNIT 1 a' i RADIATION PROTECTION PLAN O ==. .

F

/W. E. Potts  !

Manager, Radiological Controls ,

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G. Herbein ,

ice President Generation, Met-Ed  !

Changes to this document require approval by these positions.

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Revision 1 January 16, 1980 '

o 'IHREE MILE ISIx;D NUCLEAR STATION i

IJNIT 1 i i

PADIATICN PRum.;nCN PLAN  !

i Table of Contents ~

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Pace No. j

. i Article 1 Fourdation for the 'IMI-1 Radiological '

Controls P W- 2 J Article 2 Responsibilities of Workers 5 .:

Article 3 Audits, Reviews and Reports on the 'IMI-l  !

Radiological Controls Pr 4 cua 7 Article 4 Radiological Centrols Training 10 Article 5 Control of External Exposure 12 Article 6 Centrol of Internal Exposure 15  ;

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C) Article 7 Centrol of Radioactive ccntamination i

17 i Article 8 Control of Radioactive Materials 18 Article 9 Organiration for Radiological Controls 20 l

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Rcvision 2 April 3, 1980 Article 1 - Foundation for the TMI-1 Radiological Controls Program This document, the Three Mile Island Unit 1 Radiation Protection Plan, sets forth the philosophies, basic policies and objectives of a '

Metropolitan Edison Company and General Public Utilities Corporation concerning their THI-1 Radiological Controls Program. The objective

. .x; i of the radiological controls program is to control radiation hazards to *

~ ~- . A avoid accidental radiation exposures, to maintain exposures within the .

, regulatory requirements, and also to maintain exposures to workers and '

the general population as low as is reasonably achievable. These .

philosophies, policies, and objectives are based on and implement from the regulations of the Nuclear Regulatory Commission (NRC) as contained in Title 10 of the Code of Federal Regulations, Parts 19, 20, 50, and 71, I

j and appropriate Regulatory Guides, specifically 8.2 (1973), 8.4 (1973),

8.8 Rev. 3 (1978), 8.9 (1973), 8.10 Rev.1-R. (1975), 8.13 Rev.1 (1975),

8.14 (1977), and 8.15 (1976). The TMI-l Radiaticn Protection Plan is f based,on these references, therefore they are not repeated throughout t

the remainder of this document.

Specific details as to how the TMI-l Radiation Protection Plan is implemented shall be promugated in the TMI-1 Radiological Controls Procedures Manual (RCPM) and shall include those applicable procedures '

addressed in Reg. Guide 1.33 Rev. 2 (1978), App. A, paragraph 7, and paragraph 8 (aa), (bb); further references to the TMI-1 RCPM are not repeated throughout this document. The TMI-l RCPM will consist of revisions to procedures which existed in the previous HPP 1600 and 1700 l i series, applicable Administrative procedures, and additional procedures I

deemed necessary. This TMI-l Radiation Protection Plan is the first '

part of the TMI-l RCPM. Requirements governing release of radioactive O- liquids and gases to the environment and the disposal of i

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Rivisica. 1 January 16, 1980 solid ra,11oactive waste are not addressed in this M-1 Radiation Protection Plan, but are addressed in the Envircr_ mental Technical Specifications.

Verbatim cwpliance with the 'IMI-l RCPM is car.datory. In the event a s ucedure cannot be followed exactly, work under that procedure shall be stopped and shall not ccrmance again until the procedure hu been corrected.

This 'IMI-l Radiation Protection Plan and the new 'IMI-l RCPM are being written prinarily to increase the effectiveness of the Radiological Controls ,

Frc,.=u at 'IMI Ltit 1. 'Ihus, the s ucedures have direct applicability only to 'IMI Unit 1. P. h m shall provide adequate guidance and specify apsupulate methods or techniques to insure that the performance of each' activity is in accordance with sound radiological control principles, and is i in compliance with applicable regulatory provisions. The RCPM shall be prepared, reviewed, approved, and controlled as described in the RCPM Airinistrative procedures.

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The 'IMI-l Radiological Controls program is to be fully integrated into  :

l each and every phase of options at 'IMI Unit 1. 'Ihe 'IMI-l Radiological l

Controls Program when carried out as specified will assure that the operation i

of Unit 1 will be performed with personnel who work at the site incurring radiation exposure as low as can reasonably be achieved.

In order to meet this objec*.ive, the ppm must be carried out by each pon involved in the 'IME-l activities. There is no group or m on involved in the 'IMI-l operations who does not have some degree of responsibility for the Radiological Centrols Program. Failure of any person to recognize this responsibility or to comply with issued procedures will not be tolerated.

A radiologically safe option will be achieved if each individual carries out I

his or her responsibility. t l

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h perfomce of each nanager and supervisor must demonstrate  :

support for the excit:mnt by cop nanagement of General Public Utilities .

Corporation and Metropolitan Edison w,any to a strow, effdW radi.ological controls p.v..

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l m ie-1 . 9 _ o sm sm414 *4 es of wo+a-s Although personnel specially trained in radiological controls nor-mally oversee radioactive work, each individual involved in this work r:ust constantly retain aware of the potential radiological problerns.  ;

Each individual is responsible for maintaining his or her exposure as 1

i low as reasonably achievable. Each individual's actions directly affect

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l his exposure, etcrcination, and overall radiological problerts associated with the work. 'Ibe following rules shall be followedby individuals to minimize radiological problans:

l. Obey promptly "stop-work" and " evacuate" orders of radiologieb control persormel.

2. Obey posted, oral, and written radiological control instruccions  :

and procedures, including instructions on Radiation Work Permits.

s 3. Wear 'ILD and self reading dosimeter where required by signs or 1.=.

by radiological control personnel. Report loss or unexpected exposure and offscale dosimeter to Radiological Control Depaent.

4. Kcep track of personal radiation exposure status a:x1 avoid ex-c W 4ng exposure limits.

S. Rema4n in as low a radiation area as practicable to aco:xnplish work.

6. Ib not loiter in radiation areas.

7. Ib not smoke, eat, or chew in wnLucinated areas.

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

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

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10. Msk or be frisked for contarination when leaving a contaminated area or a radiological control point. Notify Radiological ,

Controls personnel if contamination is found.

11. For a known or possible radioactive spill, mininize its spread and notify radiological control p rsonnel promptly.

12. Do not unnecessarily touch a ccntaminated surface or allow -

clothing, tools, or other equi 1 rent to do so. -

13. place contaminated tools, equi;rnent'and solid waste on dispos-able surfaces (for example, sheet plastic) when not in use and inside plastic bags when work is finished.

14. Limit the'ar: cunt of material that has to be deud adnated or disposed of as radioactive waste. i

15. Notify Radiological Controls pe.ml of faulty or alarring ,

radiation protection equi; ment.  !

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16. Report the presence of open wounds to radiological control and , j medical perscenel prior to work in areas where radioactive contarr ination exists and imTediately if a wound occurs while in [

such an area.

17. Notify Radiological Controls personnel upcn returning to the site afte medical administration of radiopharmaceuticals. f

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

19. Ensure that your activities do not create radiological problems for others and be alert for the possibilities that the activities  !

l of others may change the radiological conditions to which you are exposed. I O 6.0

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Article 3 - Audits. Reviews and Reoorts on the TMI-l Radiological O 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 ,

t 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, a system of audit and review procedures shall be established including criteria for timely and appropriate corrective action. The following audit and review procedures shall be used:

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1. Radiological control technicians shall monitor and sid the ,

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Per<ormaace of each indivieu i iasor r as reeioiosicai work  :

practices are concerned.  !

'2. The Radiological Engineering shall review on a regular f

basis the performance of the radiological control technicians. l This review includes shift coverage on those jobs which are can'sidered likely to have a high potential for radiological i

difficulties. I i

3. Radiological assessments shall be conducted throughout the Radiological Controls Program on a continuous basis. This I i

assessment function shall report directly to the highest level l 1

of management in the TMI-1 organization and shall be outside  !

the Radiological Controls Department. A written report of I l

the findings of this assessment shall be prepared and issued i O evers = oath-7.0 1

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v 4. Quality Assurance audits shall be conducted of the M-1 Radiological controls Program by technically qualified persons frcm outside the Radiological Controls Departnent. These audits will be condteted in accordance with procedures as outlined in the M -1 Quality Assurance Plan. The Quality Assurance ,

Methods, Operations and Audit group will schedule these audits and will provide pesonnel from their own department and/or outside contractors as appropriate to conduct the audits. These audits shall cover the applicable portions of the Quality Assuk rance Plan, the M-1 Radiation Protection Plan and all procedures in the M-1 RCPM on at least an annual basis.

5. '1he Plant Operations Review C:ntnittee shall review and ccanent cn the M-1 Radiation Protecticn Plan and any changes thereto.

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They also have the responsibility'to review those procedures requested by the Manager-Radiological Cbntrols.

6. Periodically, the services of an outside consultant will be retained to provide evaluation and guidance cn ways to improve the M-1 Radiological Centrols Program.

7. In additien to these reviews and ruiits, a system shall be erployed to identify radiological centrol deficiencies. A radiological control deficiency is definad as either a violaticn of an l established procedure or a practice which could and should i

I be inprcrred. Such deficiencies are recorded in a Radiological l Deficiency Report. This system shall be s#fied in the l

l M-1 RGM erbodying the follo.fing concepts. A Radiological Deficiency Report may be initiated by any individual who O

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(]) deserves a deviation from good radiological practices. These reports shall be evaluated by Radiological Engineering for i

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

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an improved Radiological Controls Program. Radiological i Engineering shall prepare 'a monthly report summarizing the ' - '; ' '

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Radiological Deficiency Report findings and corrective action l taken.

8. The Nuclear Regulatory Commission (NRC) also inspects and reviews the TMI-l Radiological Controls Program. The TMI-l P

l Radiation Protection Plan and any changes thereto shall be submitted to the NRC after implementation.

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({} In the event all the preceding measures fail to prevent a _

radiological incident, and investigation shall be conducted .

to determine the causes of the incident and to determine the l corrective actions and improvements needed.

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% A: ticle 4 - Radiolocical Controls Traininc j

1. Periodic radiological control training shall be given to '

ensure each person understands the radiological conditions to which he is exposed, understands his respo.uibility to minindze  ;

his cwn exposure to radiation, and understand his own responsi-bilities for cxxtplying with radiological . control procedures.

Perscrinel occupationally exposed to radiation shall receive instruction on the effeca of radiation and the risks associated with radiation exposure. ,

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2. General radiological indoctrination shall be given to those l 1

not directly involved with radiation so that they understand '

not to enter areas requiring 'ILDs and not to cross radiation barriers. The indoctrination shall include explanation of the . '

radiological environment in which they work. k O s 3. Radiological control training shall be given to perscnnel requiring

, access to a rastricted area. 'Ihese persomel shall be required to pass a written examination, and they shP.11 requalify by written {

exatm. nation at least annually.

4. In addition to the training and written examinations of para-graph 3, those who require access to areas centrolled by '

Radiation Work Permits shall receive more extensive training '

and !all be required to pass a radiological examination on their practical abilities, including use of dosimetry, frisking,  ;

i anticentamination clothing, respirators, and response to un-usual situations. Retraining, and both written and practical'  ;

examinations shall be conducted at least annually. _In addition, O

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Revision 1 January- 16, 1980 spot checks shall be made that they retain the required kncw-O ledge during the period between examinations Special briefings and e:e.ra training including use of neckups where applicable, snall be conducted for work involving higher than usual exposures to radiation and radioactivity. 1

5. Radiological control technicians and their forenen shall re- ""

ceive theoretical and practical training and tratri g for un-l usual situations. Tra2.ning shall also be given der changes to procedures, equipment and prograres. They shall Inss both written and oral examinations, in which the pessing grade for foremen'  ;

shall be higher than the passing grade for technicians. periodic practical 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 O .a .

control technician assistants shall perform specific functions under direction of a qualified technician or foreman and only '

a#ter being qualified for the specific function.

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Revision 2 April 3, 1980 Article 5 - Control of External Exoosure 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 normal ,

hazards of, life. Therefore the policy of Metropolitan Edison Company  ;

and General Public Utilities Corporation is to maintain exposures to  :

. individuals and total man-rems as low as is 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 man-rem exposure goals shall be  ;

established for each major job and for each year. Work involving radiation ~ f exposure shall be preplanned. Major exposure jobs shall require that ,

radiological controls be incorporated in the 3design, that written procedures by prepared, and that pre-job briefing and rehearsals be conducted prior to comencing work. A Radiation Work Permit will be required for any work or  ;

entry to restricted areas that would involve or create any of the following:  ;

(a) high radiation area, (b) airborne radioactivity. area, and (c) contami-nated area, or (d) those radiation areas specified in applicable procedures.  ;

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Restricted areas used to control personnel access to radiation and l 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 conspi-cuously posted as a High Radiation Area, and personnel desiring entrance shall obtain a Radiation Work Permit  !

(RWP). Any individual entering a High Radiation Area i

shall (a) use a continuously indicating-dose l- 12.0

Revicion 1 January 16 1980 rate ronitoring device or (b) use a radiation dose rate integrating device which alarrs at a preset dose level, or (c) ,

assure that a radiological control technician provides periodic radiation surveillance with a dose rate nonitoring instrurent.

2. Any area accessible to personnel where a najor portion of the body could receive in any one hour a dose in excess of one -

thmn==nd mram, shall be locked to prevent unauthorized entry. -

The keys to these locked barricades sha'1 1 be maintained under the =Aministrative control of the Radiological Centtrols Foreman on duty in accordance with the RCPM. '

Radiological Cbntrols personnel shall be exempt from the R:.'P issuance .6ement during the psfaumance of their assigned '

radiation protection duties providing they are following radiological control s h ares for entry into High Radiation Areas. '

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'Ib evaluate radiological conditions, radiation surveys shall i i

be conducted for air activity, renovable surface contamination and

! ' external radiation at regular intervals. Surveys are perf W in ,

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order to (a) nonitor the suitability of control measures, (b) 1 evaluate the needs for additional controls, (c) evaluate trends for AIARA purposes, and (d) evaluate radiological conditions in i areas routinely entered without radiation work permit coverage.

Surveys in unrestricted areas are provided to insure the effective i j control of radioactive naterial. Unusual conditions detected - ,

in the perfornance of either a routine or special survey shall '

i imrediately be brought to the attention of Radiological C' ontrols  !

t Management. Portable radiation survey instruments will be

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Revision 1 January 16, 1980 g calibrated senu.nannually, except for dose rate measuring instruments,

-V which will be celibrated quarterly, to assure a consistent, reliable and predictable response to radiaticn levels. Records of surveys shall be maintained on file. An A&ninistrative program will be used to verify the m1ibration cf personnel and field nonitoring

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Revision 2 April 3,1980 Article 6 - Control of Internal Exoosure i The policy of Metropolitan Edison Company and General Public ,

i 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 radioactivity during their work, this means that no one should receive from internal radioactivity more than _ r one tenth of the radiation exposure that 10 CFR 20 would allow one to accumulate in a year.

Controls in other parts of this TMI-l Radiation Protection Plan to minimize internal radioactivity, such as control of surface contamina .

tion and control of wounds, are not repeated in thisa ' rticle. The following controls are to minimize internal exposure from airborne j radioactivity:

1. Engineering controls and controls on personnel access shall O

be appiied to the maximum extent si.acticabie so that raeio- .

active work does not increase the amounts of airborne radio-activity inhaled. When no other controls are practicable, respirators shall be used. Those who may need to use respi-rators 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 I where personnel may be exposed. Continuous monitoring 1

l representative of air the person is breathing shall be l performed to supplement periodic measurements during work I which has the potential to cause a worker to receive measurable

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internal radioactivity. l l O internel redioectivsty sheii be measured at ieast ennueiiy in each person who works in an area requiring a radiation work-permit; this 15.0 l

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Revision 1 January 16, 1980 includes each person who wears respiratory protection. Internal radio-activity shall be rceasured prongtly in each person who receives radioactive j oontaminatien on his skin, and in each person who is suspected of inhalirs I

sufficient radioactivity to cause measurable internal radioactivity. j Each measurement of internal radioactivity above a level near background shall be revieyed to determine the cause and to assist in miriM_?ing  !

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Revisicn 2 April 3, 1980 Article 7 - Control of Radioactive Cont' amination O

Radioactive surface contamination shall be controlled in order to minimize possible inhalation or ingestion of radioactivity and to mini-mize build up of radioactivity in the environment. Measures to contain radioactivity and to minimize the number and extent of areas contaminated .

shall be taken in order to minimize personnel radiation exposure, to simplify subsequent personnel and area or facility decontamination, and to minimize the need to rely on anticantamination clothing.

The release for uncontrolled use surface contamination level and skin contamination action level for beta-gamma activity shall be 1000 dpm/100cm2 for smearable contamination and 0.lmR/hr for total contamination. The preferable ertsurement technique is with a pancake i frisker. 1000 dpm is equivalent to 100 cpm on the pancake frisker.

i For alpha activity, the surface contamination. level for uncontrolled O .

release and skin contamination action level is 100 dpm/100cm ,".

Emphasis in planning, training and working shall be placed on mini-mizing the numbers of occurrences and amounts of radioactivity involved in occurrences of radioactive surface contamination of a person's skin or of areas not controlled for radioactive surface contamination. Each such occurrence shall be reviewed in detail to determine how to enrrect ,

deficiencies and improve control of radioactivity.  !

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January 16, 1980 Article 8 - Control of Radioactive Paterials In addition to the definition of 10CiR20, any raterial having a dose .

rate measured with a beta ga:ma survey meter at 1 inch exceeding 0.1 rR/hr or with surface contamination in excess of the limits specified in Article 7 shall be handled as radioactive. A radioactive raterial i

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control system shall be established to ensure radioactive naterial is not lost or misplaced in a location where personnel could unkro<ingly be exposed to radiation and to prevent the uncontrolled spread of radioac'.ivity to areas where the public might be affected. This system shall include the following requirements:

1. The number of areas in which radioactive materials are stored shall be minimized. l t

2. Any new radioactive raterial storage area shall be approved before use by the Manager-Radiological Controls.

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The nunbers of radioactive iters and the amount of radio-activity in storage shall be mininized.

4. Radioactive iters shall be identified as radioactive before removing them from a restricted area.

5. Radioactive raterials removed frcm the Protected Security Area or renoved frcm a restricted area outside the Protected Security Area shall be controlled in accordance with an accountability procedure which ensures the naterials are not lost or improp-erly handled during transfer or subject to unauthorized renoval.

This accountability procedure shall require inventory of radioactive materials which remain outside such areas.

6. Each inccming or outgoing shipnent of radioactive material Shall be handled in strict empliance with detailed written O

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Each case in which radioactive caterial is lost or unaccounted for shall be reviewed in. detail to detemine the potential radiation exposure [

pe.sonnel might unknowingly receive, to correct deficiencies, and to l 1.Tprove ccritrol of radioactive naterials.

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l Revision 2 April 3, 1980 O article 9 - Oroemizetion for Redioio24ce, Controis l A radiological control program cannot be strong and effective if left solely to the Radiological Controls Department. Each worker and I'

supervisor has responsibility for radiological control; consequentl'y, the organization for the entire Three Mile Island Unit i represents the organization for radiological control.

However, the Manager-Radiological Controls is responsible for en-suring that a high quality radiological controls program is established and maintained. It is the responsibility of the Radiological Control Department to evaluate radiological conditions and recommend precautionary measures. To assist the Manager-Radiological Controls, a Radiological Controls Department is organized as shewn in Figure 1.

At times when demands upon the Radiological Control Department are O sufficiently heavy to require a temporary increase in staff, qualified  !

contractor personnel will be used. These personnel will be fully inte-grated into the department under the direction of the Manager-Radiological Controls.  !

Qualifications for the key radiological managers in NRC Regulatary Guide 1.8, Rev.1-R, (1975) will be met as fas as practicable. Where the combination of strong manager and experience in radiological controls cannot practicable be obtained in the same person, a deputy will be appointed who meets the NRC's requirements.

One portion of the TMI-1 radiological- controls program is the ALARA program for personnel radiation exposures to be as low as reasonably achievable. To accomplish this each engineer involved with TMI-1 has to have radiological engineering as part of his assignment. Thus, most i

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, January 16, 1980 l rather than in the Radiological Controls Department. The overall coordi-nation of the 24I-1 ICRA pr: gram, however, is assigned to Radiological

! Wwring in e.h3 Radiological Cbatrols Depaht. ,

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F O O O '

l Vice-President Met-Ed Hanager -

Radiological Controls Radiological Controls, Manager f

Administrative and Clerical Support i

i Supervisor Radiological Supervisor Radiological Control Technicians Engineering P

Rad 101ogical Radiological Control Technicians Engineers Foremen - - - -

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. _Techn._icians E

o Figure 1 THI-I Radiological Controh Department Organization ,

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