ML20004C705
| ML20004C705 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/23/1981 |
| From: | Donaldson D, Gilchrist R, Murray B, Galen Smith, Wadman W Battelle Memorial Institute, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20004C697 | List: |
| References | |
| 50-277-80-18, 50-278-80-10, NUDOCS 8106040542 | |
| Download: ML20004C705 (78) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION I HEALTH PHYSICS APPRAISAL Report No. 50-277/80-18 50-2'io/80-10 Docket Nos. 50-277 50-278 License Nos.
DPR-44 Category C DPR-56 Licensee:
Philadelphia Electric Company (PECO) 2301 Market Street Philadelphia, Pennsylvhnia 19101 Facility Name:
Peach Bottom Atomic Power Station (PBAPS), Units 2 & 3 Appra
-1 at:
Delta, Pennsylvania Appraisal Conducted:
June 16-27, 1980 (Health Physics)
July 7-11, 1980 (Emergency Planning)
Team Members:
/0/3//[O Blaine,4urray, TeagVLeader, NRC Dat(
$hY$0 R. L. Gilchrist, f parch Scientist, Battelle
/Date 7
Laboratories Alsso7&mm JohtMo g E'W. Wadman, Consulta Battelle Laboratories Eate/
Ls e Ane-e,w D. Donaldson, Radiation Specialist, NRC
')atit 33M Approved by:
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l G. H.} Smi h, Mief,Wuel Facility and
/Date' Mai er a s Safety Branch rg106040 N l
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TABLE OF CONTENTS Introduction Persons Contacted 1.0 Radiation Protection Organization 1.1-Description 1.2 Responsiblitties 1.3 Staffing 1.4 Management Oversight i
L1.5 Conclusions 2.0 Personnel Selecticq, Qualification'and Training
'2.1 Selection Criteria 2.2. Qualification Criteria-2.3 Training Program 2.3.1 r ganization e
2.3.2 General Employee Training and Retraining 2.3.3 Radiation Protection Technicians Training 2.3.4 Specialized Training 2.4 ' Conclusions 4
3.0 Exposure Control 3.1 External Exposure Control i
3.1.1 Dosimetry Program 3.1.2 Records and Reports 3.1.3 Exposure Review and Limite'fons
'3.1.4 Conclusions L
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? :4.. Interna 1LExposure Control-3
- 3. 2.1 -
-Dosimetry Program-3.2.2
. Respiratory Protection'
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3.2.3 Conclusions 3.3 LSurveys and AccessL Control-
- 1. 3.1-Procedures s
3.3.2
. Alpha Surveys 3.3.3 Neutron Surveys 3.3.4 Airborne Surveys 3.3.5 Radiation Work Permit 3.3.6 Radiation Protection Instrumentation 3.3.7 Supplies and Equipment 3.3.8 Housekeeping 3.3.9 Conclusions 4
4.0 Radio' active Waste Management Systems t
4.1 Organization 4.2 Gaseous Radwaste 4.3. Liquid Radwaste 4.4 Solid Radwaste 4.5 Filter Systems 4.6 Effluent Monitors
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4.7 Effluent Release Controls 4.8 Conclusions 5.0 Facilities and Equipment i
5.1 Health Physics Facilities l
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-5.2. Radiochemistry Facilities 5.3. Conclusions-6.0 <ALARA
- 7. 0 Internal Audi.t Program
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'8.0; Health ~ Physics Procedures.
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-9.0 'AdministrationJof, Emergency Planning
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.10.0 Emergency' Organization
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.11.0 Emergency ~ Plan Training
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- l'2.0 Emergency' Facilities and Equipment 13.0 Emergency Plan'Implementir.g Procedures.
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. INTRODUCTION
-The~ purpose of this special. appraisal was.to perform a comprehensive evaluation of the licensee's radiation protection program..This: appraisal included an evaluation of the adequacy and' effectiveness of areas for which explict regulatory-requirements may not currently exist. zThe appraisal effort was directed
.towards evaluating the licensee's capability and performance rather than the identification of specific items of noncompliance. The objectives and details
. of-the appraisal program were contained in Mr Stello's letter of January 22,
- 1980. 'The appraisal inc.luded 315 onsite hours by four appraisers.
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PERSONS CONTACTED (PECO)
- S. Li Daltroff, Vice President,. Electric Production
- J.'W. Gallagher, Manager, Electric Production Department
~* M..J. Cooney, Superintendent, Generation Division-Nuclear
-+* W. T.' Ullrich, Superintendent, _ Peach Bottom Atomic Power Station
+* R._S.-Fleischmann, Assistant Station Superintendent
- R. Costaglirola, Corporate QA Department -
- J. E. Winzenried, Engineer -Technical C. E. Anderson, Operations Engineer J. W.-Spencer, Engineer Maintenance D. C. Smith, Outage Manager P. Pauly, Radwaste Supervisor C.=P. Lauletta, Training Coordinator.
+* N. F. Gazda, Health Physicist / Radiation Protection Manager
- J._J..Maisler, Technical Support Health Physicist
- C._A. Mengers, Onsite QA Department
- J. A. Valinski, Health Physics Supervisor M. C.'Simpson,-Health Physics Support Services Engineer D. A. Barron, Dosimetry / Bioassay Technical Assistant C._S. Nelson, Special. Project / Health Physics
+* W. J. Knapp, Supervising Engineer
+ R. Scholz, Supervisor,, Chemistry
-The appraisers also interviewed several other licensee. and contractor health physics technicians.
- Denotes those individuals present during the exit interview on June 27, 1980.
+ Denotes those individuals present during the exit interview on July 11, 1980.
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7 1~.0. Radiation-Protection Organization' 1.1 Description.
Documents Reviewed.
Appendix A Technical Specifications, Section 6, Figure 6.22.
' Application for Amendment of Facility Operating Licenses OPR44-and DPR56, May 1980.
The Itcensee's present Radiation Protection Department'(RPD) is shown in Figure No. 1.
This arrangement reflects the organization as it appears on the organization chart in Figure 6.2-2 of the' Technical Specifications.
In May 1980, the licensee ^ submitted a
' Technical Specification change request _which included a proposed revision of the Radiation Protection Organization.
The proposed revision is depicted in Figure No.
2.'
The Appraisal Team has concerns regarding both the present organization and the proposed change to the Technical Specifications.
These concerns include:
(2) The present organization shown in Figure No.
I has the Enginee'r Health Physicist (Radiation Protection Manager) reporting through the Engineer Technical to the' Assistant Station Superintendent.
Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable," recommends that the individual responsible for radiation protect' ion activities be independent of station divisions such as technical support.
The Radiation Protection Manager (RPM) should have direct recourse to responsible management personnel in order to resolve questions related to the conduct of the radiation protection program. As Figure No.1 indicates, the RPM did not report directly to the Station Superintendent.
However, the RPM did have access to the Station Superintencent in order to resolve radiation protection matters.
(See Section 1.4.2 of this report.)
(2) The proposed Technical Specification change has the Health Physicist (RPM) reporting through the engineer Technical.
In addition, the proposed change includes splitting health physics (HP) activities into two parallel groups:
(a) Health Physicist (Field) and (b) Health Physics (Support).
The Health Physicist (Field) would be the designated RPM. The field and support groups wculd occupy equal positions within the licensee's
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organization.
i Figure No. 3 shows the various program a'reas for the proposed organiza-
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tion. As Figure No. 3 indicates, the program would consist of several related responsibilities.
However, the responsibility for l'
directing the overall radiation protection program would not be j
vested in one individual.
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<1.2iResponsibilities:
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IPkcedure1NoWHP0/CO-4, " Radiation Work PEnits,"> Revision lNo.
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J 'Phoded0reshadnot$ ban.~establishedthatdescribeditheresponsibil.itiesi 4
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7and authoritiestof!the Radiation Protection Department and-thet
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?Radwaste:Supervisore 'In additioni job descriptions had/not been?
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' icompleted=for all, positions:withinithe Radiat,fonl Protection-Department.
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l, w It:was{noted that?certain-department procedures.did; address.: specific!
i responsibilities related to.a particular activity.. For example,..
Procedure:No.7HP0/CO-4, " Radiation' Work: Permits)(RWP)," states.thatl -
fan Health 1 Physics-Technician has:the authority to suspend activities' E
e' l covered by?a RWPcifithe technician, deems work conditions' unsafe.'.
_ However,:an' administrative procedure (s)'had not be~en~ developed.that.
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addressed' the responsibilitiesf and authorities lfor; a comprehensiv-p',.
' radiation' protection program'.1 TJobidescriptions had been' issued for?
Ji.ndividuals at the technician.. level, but;similar job descriptions; had not been established for supervisory personnal.
Representatives-l lin the RPD stated that they would~not be hesitant in stoppingLa job-r p
- which, in Jtheie opinion, was considered unsafe even:though they:did '
not know if such authority existed'in written. procedures.
1'.3: ! Staffina -
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-The' number ofshealth physics person'nel onsite during the appraisal-appeared' sufficient to. provide. adequate.co'verage at both supervision f
and technician levels Staffing.for. health. physics field activities included about 20 licensee and 80 contractor personnel.
In addition,-
about'30 persons'were assigned as specialists in dosimetry; respiratory
-protection, sample analyses, and ~ administrative and clerical support A.
ta=the radiation protection. program.
Comments received from personnel-
.within the RPD-and~other departments such as operations and maintenance 1
indicated:that enough health _ physics personnel were usually available n
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- to provide proper coverage for routine, backshift, and outage conditions.
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-An HP technician was assigned to each shift. The primary responsibility l
-for.the Shift HP was to support the operations shift crew.
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number of contractor health physics personnel onsite at any particular time fluctuated' depending on activities in progress.
The Appraisal Team noted that several responsible health physics positions were filled by contractor personnel.
This included the c
. responsibility for overseeing health physics activities at major s
9 access control points such as the drywell, torus, refueling floor
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and~2pecial jobs.
The Appraisal Team was concerned that responsible HP positions associated with major maintenance / modification activities Y
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were not_occuppied by. licensee'~ personnel.
In certain' situations,'
' contractor personnel were responsible for overseeing work performed:
i by: licensee HP technicians.. The = licensee - stated that individual s
~ were selected to fill responsible senior positions based on'the most-
-qualified person available regardlesstif.the individual'was a. contractor.
Lor licensee' employee;.Some contractor.'HP' technicians-had been employed; full time at Pe'ach Bottom for the'past-3-4_ years..
As' a. result, these_ contractors were by' virtue of their experience-
.the most. qualified--individuals to fill applicable-' responsible positions
-when adequately qualified 11_censee-personnel were 'not available.
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LThe'_ licensee had adhered to the policy. of building' their.HP. technician -
staff by hiring inexperienced personnel and acheiving.the necessary-J competence; level through'an internal training-program and on-the-job experience. -The.HP training program wa's initiated about three years t
- ago and had graduated four classes of about 12 technicians per-
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class... A fifth class is. scheduled to start in June,-1980. This program is to-continue until the licensee ~has trained an adequate i
' number of HP technicians to handle the normal and supervisory HP duties.
In the meantime, the licensee's staff will be supplemented
~ with contractor technicians.
hl.4 Manageme..i Oversight
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1' 1.4.1 Management Adequacy-1-
l The planning, organization, and direction provided by.the RPD supervision needed_ improvement.
Several supervisory-positions were either filled with inexperienced individuals-or with' individuals with several years experience who were-not up-to-date regarding current health physics practices.
Certain job descriptions required a college degree.in 1
order to qualify for a particular supervisory position.
Some supervisory positions _were filled with recent college graduates that lacked practi. cal experience in the area
.they were required to supervise.
In other situations, the Appraisal Team noted that individuals that had been in i
supervisory positions for several years were'not fami_ liar with the recommendations in current standards and guides.
Excessive turnover of personnel within the RPD did not appear to be a chronic problem. The annual turnover rate I
was usually less than 10 percent.
Frequently, individuals L
that left the RPD were either promoted or transferred to L
another department. The health physics technicians worked i
an average of 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> of overtime per year.
The licensee's health physic technicians could not be reouired to work' l
over, time; therefore, the amount of overtime worked by a
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particular technician varied depending on how much overtime l.
for which an individual volunteered.
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_The Appraisal Team. observed that the_ majority of.the RPD staff displayed an interest in their. work and' accomplished their assigned responsibilities in a professional manner.
- The RPO technicians did not belong to a. bargaining unit.
The RPO supervision stated that, in their opinion, the absence of a bargaining unit contributed to a more effective department because supervision was not required-to devote time and effort in processing allegations and other union-related matters.
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<The disparity-between wages for-licensee and contractor technicians was'a frequently mentioned as a point of
. contention by the licensee personnel.
Equally qualified licensee and contractor technicians worked side-by-side on.
the same -job.
However, the financial benefits. received by the contractors were much higher.. Both the licensee and contractor personnel _ stated that the low wage-structure was the primary reason for the large number of full time contractor technicians currently onsite.
1.4.2 Onsite Support The RPM received the support of plant management.
The Station Superintendent maintained an "open door" policy.
This policy provided a readi-ly accessible avenue. for the RPM to discuss health physics matters and resolved problem
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areas..The RPM stated it was not uncommon to discuss health physics activities with the Station Superintendent on a daily basis or whenever problems developed. The Appraisal Team noted that good working relationships existed between the RPM and other departments. As mentioned' in Section 1.1, the RPM reported through the Engineer Technicial to the Station Superintendent. The Engineer Technical stated that less than 10 percent of his time was devoted to RPM matters. The Engineer Technical had supervisory responsibilities in several different areas (See Figure No.~1) and only became involved with RPM matters if problems developed that required his attention.
The RPM routinely by passed the Engineer Technical and dealt directly with the Station Superintendent regarding the resolution of problem areas.
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1.4.3 Offsite Support The onsite RPO received' minimal' corporate level technical-support regarding health physics matters. An individual (Supervising Engineer) was located at the corporate office ifor the purpose of providing support to the onsite group.
A formal, approved job description had not been established
- for the Supervising Engineer. The' licensee stated that-the Supervising Engineer functioned in an advisory capacity and had no direct control over the day-to-day aspects of the RPM.
The Supervising Engineer did not conduct formal reviews of the RPM nor had he been. included as a team member for audits conducted by the QA/QC Department.
The Appraisal Team concluded that the contribution from the corporate level regarding RPD management oversight was weak and ineffective.
1.4.4 Communications
'The exchange of information between the RPM'and other departments regarding general plant conditions and activities appeared adequate.
Daily planning meetings were the principal means for providing the exchange of information.
These meetings were attended by the various department supervisors, including the RPM, during which time the status of various plant conditions and projects were discussed.
Good working relationships also appeared to exist among RPM personnel. However, several technicians commented that.
the exchange of information between RPM supervision and the technicians regarding planned work was not always in enough detail to ensure proper health physics coverage.
Personnel within the RPM stated that they were given an opportunity to pr ovide input regarding department policies and procedures.
1.5 Cenclusions 1.
The following items are identified as significant findings.
-Improvements in these areas are required in order to achieve an acceptable program:
a.
Job / position descriptions had not been established for all positions within the Radiation Protection and Racwaste Departments.
b.
Administrative procedures had not been developed which define the authorities and responsibilities for the Radiation Protection Department.
c.
An inordinate-reliance was placed on contr:wtor HP technicians.
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The following" items should'be considered for. improvement ~ of the program, but do not' warrant. inclusion.as Appendix A. items:
- a.
.The Radiation Protection-Manager was'not' independent of!
, station divisions such as technical support as. recommended in Regulatory Guide _8.8 in that he-reported.to sk. tion =.
.managementLthrough the Engineer: Technical-to the Assistant'
-Station Superintendent.
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.TheJresponsib111ty.for' directing the. radiation' protection program activities had not been delegated to one. individual, c.
-The support provided to'the onsite_RPD bytthe corporate-Supervising Engineer appeared weak-and' ineffective..
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PSAPS ORGANIZATIOff FIGURE N0;'1.
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STATION SUPERINTENDENT ASSISTANT STATIM SUPERINTENDENT
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- l OPERATION?. ENGINEER CLERICAL AND SECURITY ENGINEER TECHNICAL EIIGINEER MAINTENAftCE EleGINEER REACTOR ENGINEER I&C ENGINEER HEALTH PHYSICS ENGINEER CHENISTRY ENGINEERS TECHNICIANS d
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PROPOSED TECHNICAL SPECI FICATION CHANCE.
- FIGURE NO. 2
'i STATION SUPERINTENDENT ASSISTANT STATION SUPERINTENDENT I
OPERATIONS ENGINEER CLERICAL AND SECURITY.
ENGINEER TECHNICAL ENGINEER MAINTENANCE ENGINEER REAC10R ENGINEER ikC -
HEALTH PHYSICIST ENGINEER CHEMISTRY ENGINEERS' HEALTH PHYSICS TECHNICAL SUPPORT-TECHNICIANS a
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PROPOSED RADIATION DEPARTMENT ORGANIZATION' FIGURE N0.I3 TO STATION.
SUPERINTENDENT
-R.*d)lATION PROTECTION SUPERVISBNG ENGINEER s
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TECHNICAL ENGINEER 8-g E
S HEALT H PliYS I C I ST ( F I ELD )--------------------------------------------
AlEALTH PHYS I C'S ( SU PPORT )
.(RADIATION PROTECTION MANAGER) a HP SUPERVISOR a
UNIT 2 l
HP SUPERVISOR 8
SUPPORT SERVICES
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tiLLU PLANNING (ALARA) s.--------------
HP TRAINING COORDINATOR QUALI TY ' CONTROL ( F I ELD) ---------- 1 INSTRUCTORS s
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DOSlHETRY/ BIOASSAY DISPOSAL (MAINT. ORG. )
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PLANT SERVICES ASSIGNMENT COORDlHATORS eI RADIOACTIVE MATERIAL CREW LEADERS AND l
' SHIPMENT / RECEIPT TECilNICIANS e
RESPIRATORY PROTECTION /
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-1 2.0 LPersonnel Selection, Qualification 'and Training i
-2.1 Selection Criteria Documents Reviewed Procedure HP0/CO-80, 'Cor. tract, Health Physics.Technican Entry Procedure," Re' vision 1, June 5,1979.
PEco Job Descriptions (Used primarily for percentage of manpower
. commitment) for the following positions:. Special Projects,-HP.
Support. Services Physicist, Dosimetry and Bioassay Technical Assistant (TA), Health Physics-Training Coordinator, Health Physics Instructors TA, Health Physics Plant Services Physicist,
. Rad Material Shipments / Receipt TA, and Respiratory Protection /
Laundry TA.
Philadelphia Electric Company Assistant' Technician Training-Program, January 1980.
Philadelphia Electric Company Technician "C" Training Program, February 1980.
The only formal selection criteria identified at the Peach Bottom facility was HP0/CO-80, " Contract Health Physics Technician Entry Procedure." This procedure outlined tha method by which contractor health physics technicians were evaluated and processed prior to entry onsite for work. The procedure appeared to adequately address.
the areas of evaluation and verification of health physics related experience and complied with ANSI N18.1-1971. However, the procedure-was written for a general health physics technician position and was not job specific.
The procadure stated " Assignments of a technician to cover a job will be evaluated on the experience of the technician on a case by case basis." This statement appeared to be the only i
job' description for the general health physics technicians.
The HP0/CO-80 procedure did contain the necessary statements with regards to education and experience factors for assignments to the junior, senior and crew leader technician positions as recommended in ANSI-N18.1-1971.
However, there were no other formal documents which listed the education and/or experience necessary for individual job assignments.
The permanent P'
'adelphia Electric Company health physics technicians were hired by the corporate office.
These individuals were selected from high school graduates who have had some background in math, physics and chemistry. However, it was not certain that this was a mandatory requirement for employment.
These technicians were then placed in a 4 1/2. month training program and were classified as
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11 Assistant Technicians.
They remained Arsistant Technicians for 15 '
- months before they were allowed to take an oral and written examination to qualify for technician ^1evel "C".
They remained a level "C" for-112. months before they were allowed to take another oral and written examination to qualify for a technician level'"B".
They remained a level "B" technician for approximately 30 months, during which time they were' allowed to move to a Senior Health Physics Technician or a Senior Chemistry Technician. At the completion of the level "B"
time requirement, they take.an oral-and written examination to move to the final progression, a level "A" technician. The selection criteria'necessary to move through the various levels of technicians -
hr.J been established for the Assistant. Technician and the level "C" and "B" technicians.
This-area will be further addressed section 2.3, Training Program.
The Pe'nnsylvania Electric Company health physics technical staff were-also ht_ red through the corporate office.
These individuals
- were selected from industry or from college and often placed into a position where they had no previous experience.
It did not appear that any selection criteria were used in the hiring of these individuals.
In the case of the Respiratory Protection Supervisc. and the Dosimetry Suoervisor,-formal education and experience factors did not appear to have been taken into consideration prior to their being hired.
2.2 Qualification Criteria Documents Reviewed Procedure HP0/CO-80, " Contract Health Physics Technician Entry Procedure," Revision 1, June 5, 1979.
Philadelphia Electric Company Health Physics Technician Training and Qualification Record Forms.
Philadelphia Electric Company Assistant Technician Training Program, January 1980.
Philadelphia Electric Company Technician "C" Training Program, February 1980.
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The:HP0/CO-80 procedure outlined the general qualification requirements for the radiation protection contract technicians.
However, this procedure did not address the individual positions to which the i
radiation protection technicians will be assigned.
The health physics technician training and qualification record form (when completed) was used to document that the incoming technician had read and understood the 36 procedures listed on it.
It also documented l
that the individuals had received instructions in the use of 11 i
instruments used by PEco at the Peach Bottom Facilit.y.
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.the radiation' protection organization.
It appeared that the promotion process was. handled primarily by the Station Superintendent.
Based on personal interviews, review of resumes, and comparison of qualifications to ANSI N18.1-1971, the majority of personnel appeared to be qualified to perform their jobs.
However, the following.
positions'did not appear to be staffed with adequately qualified personnel:
Dosimetry Supervisor - The individual filling.the position of -
Dosimetry Supervisor (Support Services Supervisor) was a recent
- graduate with a Master of Science in Health Physics and no experience in internal or external dosimetry.
This individual's knowledge of dosimetry and ' dosimetry standards.(e.g., ANSI' N343)-appeared to be extremely limited.
In addition to this fact, ANSI N18.1-1971 requires that all supervisors have a minimum of four years experience in the job that they are supervising.
Respiratory Protection Supervisor - Although the current Respiratory Protection S.upervisor had not had formal education in this field, he appears to be adequately qualified to perform his job.
However, the responsibilities of the Respiratory Protection Supervisor were being relinquished to a new individual who did not have formal' training and lacks sufficient experience.
The
- hange of responsibilities did not involve formal classroom
. raining but rather relied on on-the-job training.
2.3 Training Program Docuients Reviewed Pensylvania Electric Company Assistant Technician Training Program, January 1980.
Pennsylvania Electric Company Technician "C" Training Program, February 1980.
Philadelphia Electric Company Health Physics Technician Training L
and Qualification Form.
Philadelphia Elect.-ic Company General Employee Training, " Radiation Health and Safety, Security, Emergency Procedures, and Quality Assurance Quiz", October 1978.
Procedure Number HP0/C0-81, " Training of Women Concerning Prenatal Radiation Exposure," May 1.6, 1979.
Procedure Number A50, " Training Procedure," Revision 6, April 26, 1979.
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_ Procedure Number'HP0/CO-9A, " Respiratory Protection Training -
and Fitting," Revision 4, October.9,1979.-
g In addition to'the above.procedurer reviewed, the appraisers attended-the general employee t' raining and.the. radiation work-employee site
- specific; training.-
- 2.3.1
~ 0rganization The PBAPS had a training coordinator who was responsible-for the-administration of all. Peach Bottom training programs.-
These programs included the health physics. technician-training, general employee-radiation protection training, site specific radiation protection training and special
' training as may be deemed necessary by the-various department supervisors. However, the Health Physics Instructor was-currently reporting to the Radiation Protection Manager (RPM). Therefore, the RPM was'also responsible for various aspects of the training.
Under the present program, the Training Coordinator was responsible for.the classroom training of the health physics technicians. The RPM was responsible for ensuring that the health physics technicians have completed the on-the-job portion of the training program.
The RPM was also responsible'for ensuring the technical adequacy of the lecture provided.to the health physics technicians and general employee training.
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administration of the training program was identified as an assumed responsibility and'was not formally defined in any procedure.
It appeared that this lack of clearly defined responsibility had caused a breakdown in the training program.
Discussions with several permanent health physics technicians revealed that the training program as formally defined was not being fully implemented.
(See Section 2.3.3.)
2.3.2 General Employee Training and Retraining The licensee's radiation protection training program, required that all personnel entering the facility receive either general employee training or site-specific radiation protection training.
Exceptions were made to this rule (e.g., a truck driver); however, this indiv'idual must be escorted at ail times by a PECo guard.
The general employee radiation protection training program was a four-hour course, which all employees must take and make a passing grade o' 70% on a comprehensive exam..The exceptions to the gene.al employee training program were those individuals who can clearly demonstrate previous t
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'the' site-specific one hour. program and must pass the same
. general (aployee-radiation protection test and make a
' grade of ;i:0% or better. Any individual,who failed this exam must take the full;four-hour general employee training-program and retake the exam.
The general employee radiation protection. training program and~ site-specific training program were. reviewed and found
.to be adequate.: However, it appeared that additional time could be devoted to the following areas:. radiation
. protection. instrumentation, procedures, emergency warning systems, and internal exposure.
The radiation. protection program required an annual attendance at the gene.al employee training for all'non-PECo personnel.
The Philadelphia Electric Company personnel and the contractor radiation protection technician personnel were allowed to take an annual bypass exam.
This examination was the same exam given to the people taking the general employee training for the first time.
If an individual makes a score of 70% or better on the examination they were not
' required to.take the general employee training over.
However, a scora of less than 70% required that the employees retake the general employee training.
This procedure allows' employees to retake.the bypass exam each yaar without ever receiving annual retraining.
Unless the exam-is reviewed frequently (biannually) and reflects the state-of-the-art information, the bypass process is considered a poor practice.
Refresher training should occur annually, as a minimum.
Refresher training could inform workers of important new developments in radiation protection procedures, equipment, and regulations that have an immediate impact on their work.
Recent plant radiation protection problems and the solution of such problems could also be discussed by the radiation protection staff.
Discussions with the training staff indicated a support for the elimination of the annual bypass exam.
2.3.3 Radiation Protection Technicians The PBAPS training program for radiation protection technicians was an extensive formal program.
The licensee's corporate office hired high school graduates who had high school l
courses in algebra, chemistry, physics and other scienc7s.
l These individuals were then placed in a four and a half month training program.
Parts of the training program were presented by a vendor and other parts were presented
[
by the licensee. The training program was composed of the following modules:
t
P.
.c g
- 2 4
15 mathematics and physical sciences - 5 weeks
- boiling water reactor technology - 2 weeks
- health ~ physics fundamentals - 2 weeks-principles of chemistry - 2 weeks radiation protection-- 4 weeks review - I week-Some of the module's included approximately 50% in plant
-time and 50% in-classroom time. At the completion of each module, the students were required to pass.a comprehensive exam._ Upon completion of the academic program, a two and one half. day. review of plant procedures was undertaken C
prior to entry into the plant.
At the completion of formal training, students were classified as Assistant Technicians and were assigned to a senior level "B" or above technician in the plant.
During the on-the-job training,-the students were required to complete a training manual which had a skill requirement and a sign-off by the next level or above technician. The
. technicians were scheduled to attend nine 2-nour review sessions durino the 15 months they were Assistant Technicians.
At the completion'of the 15-month time requirement, completing the on-the-job training manual and on the recommendation of the supervisor, the technician was allowed to take a qualifying examination to become a level "C" technician.
Technicians that successfully complete the examination (80% passing grade) were classified a technician level "C".
The minimum time to progress from a Technician "C" to the Technician "B" qualifying examination was 12 months.
During this 12-month period, the level "C" technician was required to complete formal training consisting of 139 hours0.00161 days <br />0.0386 hours <br />2.29828e-4 weeks <br />5.28895e-5 months <br /> of classroom training, laboratory training, and examinations.
The training program was composed of the following modules:
(
chemistry lectures - 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> in plant chemistry, counting room, and plant systems
(
training - 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> l
l emergency plans and procedures - 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> e
i
-+
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m
,,L
. b.
+
'16 P
g.7 health physics review -'28. hours health physics' audit: examination - 4: hours
.' health physics chemistry ex' amination
'8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> a
~~
.All~ level "C" technicians were required to complete an on-the-job training. manual prior to the: site administered-qualifying examination.- The specific. objective 1of the
- training manual'was to li.st the skills,! systems, and
-subjects in which the-trainee had shown competence, experi-ence,;and knowledge.
. At' the completion of. the level "C'.' training program,: the.
~
techntcians were given a comprehensive examination..for-the.next level."B"...Upon completion;of.this: examination (80%. passing grade),,the technicia'ns: remain a level "B" technician for 30 months. At the. completion.of the' level-
"B". program,.the technician after passing-an examination progresses to a-level "A" where he remained for 12 months.-
The level "B" and level A" technician programs had not been currently completed.
It was recognized by the appraisers that this training program as it was defined in the training modules, had-the-potential _for being'an' excellent. program.
However, discussions' with technicians and training instructors revealed a lack of compliance with the training modules.
Because of-demands on the technicians' time and the instructors' time during the outage,-the classroom modules for the technicians of all levels were not being performed.. When the modules I
were performed it was usually in a hurried manner and a-t very short period of time where the retention factor may be very minimal.
Several of the technicians reported to the appraisers that the-training manual sign-off was'often performed in the last'two weeks of the qualification-period. This was primarily dueLto pressures of daily activities, which did not allow for sufficient training time.
t 2.3.4 Specialized Training Specialized training for internal dosimetry (i.e., whole body counter), external dosimetry, respirator fitting
+
booth and other high technology areas was accomplished through on-the-job training.
The individuals who were assuming the responsibility for these positions were given instructions by the technician leaving that position. In some circumstances, the technician leaving terminated prict to the hiring of the new technician. Without formal job descriptions and procedures for each function, this I
1~.
.. ~
n, s
17 on-the-job training practice can propagate' bad work habits.
It also allowed for a large variation in personal.interpreta-tion of job requirements for the various functions..
2.'4 : Conclusions 1.
.The following items are identified as significant findings.
Improvements in these areas are required.in order-to achieve an acceptable program.
A forma 1' training / qualification program had not been a.
established for individuals respon'sible for technical areas such as TLD systems, external dosimetry, internal dosimetry, and respiratory protection.
b.
Formal job descriptions and selection criteria had not been established for licensee and contractor personnel.
c.
Requirements had not been established for an annual general employee retraining. program, i
d.
A training program'had not been established for the HP professional staff.
e.
Some individuals in supervisory positions lacked practical experience in the areas they were assigned to supervise.
2.
The 'ollowing items should be considered for improvement of the program, but do not warrant inclusion as Appendix A 1,tems:
a.
Classroom training modules had not been established for the radiation protection technician training program.
b.
A scheduled program had not been established to eliminate the urgent rush to complete on-the-job training at the end of each year.
3.0 Exposure Control 3.1 External Exposure Control 3.1.1 Dosimetry Program Documents Reviewed l
Procedure HPA-10, " General Dosimetry Operations," Revision 1, 12/76 y
Procedure HPA-10A, " Reading Harshaw Badges," Revision 0, 1/77 I
i
F
.s,
'~'
1
.o.
18 Procedure HPA-108, " Routine. Radiation Monitor Update,"'
. Revision 0, 1/77 Procedure HPA-10C, " Daily Harshaw Radiation. Computer Operations, Revision 1, 1/78 Procedure.HPA-100, "Harshaw Reader Calibration," Revision 1,.
7/79 Procedure HPA-10F, " Monthly TLD Computer Operations,"
Revision 1, 12/78 Procedure HPA-10H, " Determination of Proper Harshaw Badge Color'," Revision 0, 1/78 Procedure HPA-51, " Calibration of Direct Reading Dosimeters,"
Revision 5, 8/78 Procedure HPA-79, " Determination of Personnel Dose-Due to Neutron Exposure," Revision 0, 2/79 Procedure HP0-CO-13, " Issuance of Personnel Dosimetric Devices," Revision 1, 11/76.
Procedure HP0/C0-13a, " Control of Personnel Dosimetry _
Badges," Revision 5, 7/79 Procedure HP0/CO-13b, " Management of Lost or Found Personnel Dosimetry Badges," Revision 4, 4/78 f'
Procedure HP0/CO-15, " Departure from the Facility," Revision 2, 9/79 Procedure HP0/CO-32, " Quality Control of Personnel Dosimetry,"
Revision 3, 3/79 Incident / Exposure Investigation File Contamination Incident Log Computer Programs PREM PREM 2 Dose Card Creation 4
Monthly Log / Dose 6
Periodic Summary Report 8
Monthly Dose Summary Report
n L
j:
19 9
Record Dose Summary Report 29 Harshaw/Eberline Statistical Analysis Annual Whole Body Exposure vs. Range,' January 1, 1978 -
December 31, 1978 Annual Whole Body. Exposure vs. Range, January 1, 1979 -
December 31,-1979 ManREM Summary, January 1, 1978 - December 31, 1978 ManREM Summary, January 1, 1979 - December 31, 1979 Lost Badge Reports Spiked Badge Data File Audit of the Eberline Co. OP98, dated May 1980 Audit of Radiation Management Corp., October 1979 program The personnel monitoring program included the issuance of both thermoluminescent dos 1 meters (TLDs) obtained from an offsite vendor and T'Os and 'self reading pocket dosimeters from the licensee's in-house dosimetry program.
The beta and gamma dose information recorded by the licensee to satisfy 10-CFR 20.202 and 10 CFR 20.401 requirements was obtained from TLD results supplied by their offsite vendor.
Neutron dose information was established from the evaltation of neutron area survey results and correlating the dose levels with the stay-time an individual spent in a neutron field.
Vendor Supplied TL0s The licensee's procedures required that workers and frequent visitors be assigned a vendor supplied TLD.
These TLDs were collected and processed each month.
Several problems regarding the licensee's personnel monitoring program had been identified in previous Region I inspections (See IE Inspection Reports 50-277/79-07, 50-278/79-D6, 50-277/79-16, l
and 50-278/79-18).
Since the licensee enters the information L
received from the offsite vendor as part of the individual's L
permanent dose history, the Appraisal Team was concerned if the previously identified problems had been resolved.
The Appraisal Team determined that most of the previously identified deficiencies continued to exist.
The licensee l
had not established an acceptable quality assurance / quality
~.
20' control (QA/QC): program to ensure that results received from the offsite vendor were valid.
Procedure HP0/CO mentioned that annually, 30 personnel dosimetric devicas shall-be exposed.to a known amount of radiation in the range of 10-50 mrem, 100-500 mrem, and 1-5 rem..The
. appraisers expressed concern regarding the length of time
'between QC checks in that.the procedure only required annual checks.
Procedure HP0/CO-32 did not contain guidance regarding the types'of radiation (e.g., beta, gamma neutron).
- to be empisyed during-the checks.
The licensee's QC procedure did not include nor reference.the recommendations of ANSI-N13.11. " Criteria for Testing Personnel Dosimetry Performance." The licensee's records indicated that QC checks had only included gamma levels; beta QC checks had' not been included.
Region I inspections had identified disagreement between the vendor-supplied and in-house TLD results..For the same monitoring period, the vendor-supplied results were consistently lower than the results from the licensee's inhouse program. As follow up to the Region's concerns, the licensee provided about 40 vendor TLDs in late 1979 which were exposed to various gamma, beta and beta plus gamma radiation levels by an NBS traceable NRC contractor.
The vendor's results for this study showed that the gamma values were low by about 20% and the beta values low for-most TLDs by 100-300%.
The licensee also conducted two studies involving 786 vendor TLDs which were exposured to various gamma levels by a licensee contractor.
The results of this study also showed that the vendor supplied gamma values were low bv about 10 - 30 %.
The licensee's study did not include an evaluation of beta dases.
In April 1980, the licensee visited the offsite vendor for the purpose of auditing their program. The audit report ontained information regarding how TLDs are received and handled, the identification of an operator error that probably contributed to the low gamma results, and a statistical evaluation of the 786 TLDs.
However, the audit report did not address several basic issues such as:
(1) the adequacy of the vendor's QA/QC program, (2) the vendor's performance results during their participation in i
the Health Physics Society / ANSI cross-check program, and (3) the vendor's beta monitoring capabilities.
l The problems associated with the failure of the offsite vendor to provide reliable beta monitoring results had been discussed with the licensee by Region I on s:veral occasions prior to the April 1980 audit.
t l
^
i i
21 However, the audit did not include an evaluation of the vendor's beta monitoring capabilities.
Region I had
-expressed concerns that the beta and gamma dose results provided by the 'offsite vendor were consistently lower
-than the values obtained from their in-house TLD program.
.Since the licensee used the information from the offsite vendor for their permanent records, there was concern that the licensee _had not evaluated all significant discrepancies between the two results to assure that the proper values were entered on the individuals permanent dose records.
A major shortcoming with the personnel monitoring program was the failure to establish an adequate QA/QC program.
Procedure HPO-CO-32 did not provide adequate guidance regarding:
(1) frequency of QC checks, (2) reference of applicable ANSI recommendations and (4) details on how to resolve identified descrepancies. The licensee had documented that disagreement existed between the offsite vendor and their in-house results.
However, the procedures did not provide guidance as to the resolution of these problems.
In-House Program The licensee had established an in-house TLD and self-reading pocket dosimeter program to supplement the monthly results obtained from the offsite TLD vendor. A primary objective of the in-house system was to provide a current, running total of dose results to ensure that established dose limits were not exceeded.
Each individual that received a vendor supplied TLD was also issued an in-house TLD.
The in-house TLDs were ccliected and processed each day.
These daily results were entered in a computer program that provided the licensee with current daily, weekly, quarte:ly, and yearly dose information.
Self-reading 4
pocket dosimeters were issued to individuals prior to entering an Radiation Work Permit (RWP) area.
The pocket dosimeter results were legged on the RWP as the individual left the RWP area.
The in-house TLD system employed state-of-the-art equipment.
Two TLD readers were available which allowed for daily processing of TLDs.
The in-house equipment was operated by RPD personnel assigned to the Health Phy' sics Support section.
An adequate QA/QC program had not been established for the in-house program.
Essentially, the same QA/QC deficiencies existed for the in-house program as were previously discussed l
regarding the offsite vendor. The QA/QC program did not adequately describe:
(1) the types of QC tests to be i
1
e e,
22 conducted-(2) the kind of radiation sources to be used,
'(3) the frequency.for such tests (4) acceptance criteria and (4) detailed guidance for proper-rasolution of identified problems.
In addition, the self-reading oocket dosimeter
~
.QC program did not meet the recommendations of Regulatory-Guide 8.4.. Procedure HPA51, " Calibration of.-Direct Reading Dosimeters," only required that-pocket chambers be calibrated annually; Regulatory Guide 8.4 recommends a six-month calibration frequency.
The individual assigned'to supervise the in-house TLD program was a recent college graduate with only limited practical experience in TLD programs.
This individual was -
- not familiar with published standards related to establishing an adequate QA/QC program.
The licensee had'not established a formal training course for suparvisors.or technicians assigned to operate the in-house equipment.
Experience was obtained by informal on-the-job training.
(See Section 2.3 of this report)
Neutron Monitoring The licensee terminated the use of neutron personnel monitoring devices.in February 1980.
Since that time, neutron doses had been established from the evaluation of neutron survey results and assigning a dose value based on the individual's stay time in the neutron field.
The Appraisal Team identified deficiencies associated with the calibration of the neutron survey meters.
(See Section 3.3.3. of this report) As a result, the licensee's program for evaluating neutron doses appeared inadequate.
3.1.2 Records and Reports The licensee appeared to have an adequate number of personnel available to process dose information in a timely manner.
The licensee records indicated that reports required by 10 CFR 19.13 and 10 CFR 21408 and 409 were submitted as required.. The information required by Form NRC 4' and 5 was available and current. The information received from the offsite TLD vendor was recorded on the individual's permanent record in a timely manner.
3.1.3 Exposure Review and Limitations The licensee performed routine (daily) reviews of o.se information. The licensee was aware of which workers were approaching their dose limit and controlled any additional dose accordingly.
Since the licensee had not established a formal ALARA program (See Section 6 0), the dose information was not used as part of a comprehensive ALARA program, including plotting dose trends.
23 The RPD personnel were aware that discrepancies existed between the offsite vendor and their-in-house TLD results.
However, a procedure had not been established to provide guidance regarding proper resolution of these discrepancies.
As a result, a'backleg existed on identified problems that had never been resolved.
The RPD program regarding: (1) access control, (2) surveys, and (3) posting and labcIling are discussed in Section 3.3.
3.1.4 Conclusions The following items are identiffed as significant-findings:
Improvements in these areas are required in order to achieve anf acceptable prograin:
a; Adequate QA/QC programs had not been established for the offsite TLD vendor and the licensee's in-house dosimetry program.
b.
The-differences between the offsite vendor and the licensee's'in-house TLD results had not'been resolved.
3.2 Internal Exposure Control 3.2.1 Dosimetry Program Documents Reviewed Procedure HP0/C0-26, " Personnel Bio 63say Program,"
t Revision No. 3, August 11, 1978.
Procedure No. HP0/CO-26A, " Operation of the Whole Body Counter," Revision No. 1, June 5, 1979.
Bioassay results for the period January to June 1980.
The Peach Bottom Atomic Power Station (PBABS) used a whole body counting system as the primary component of the bioassay program. The licensee's system consisted of a 256 multichannel analyzer connected to a NaI (TI) detector.
This system was housed in a permanent structure (Security Building) at the Peach Bottom site.
The sy' stem was leased from an offsite vendor who acts as the technical consultant for the system. Most of the operation of the whole body i
counter was performed by a computer program.
Thers were no other whole body counting capabilities available onsite.
l
7 s24 The data from a fite-minute whole body count 'were:immediately printed by the computer.
This data included the radionuclide, (source activity, percent error and percent of investigation
- level.
The investigation: level was approximately 5% of a L
Maximum Permissible Body Burden (MPBB)..All of the calculations were performed by a~ computer using a specially developed computer program. However, the individual required to operate the system was not familiar with the contents of the computer program.
The licensee's bioassay program was described in-procedure HP0/CO-26. This procedure addresses'the following areas:
References (10 CFR, Reg. Guide 8.9, ICRP Publications 2,
6,' 9, 10, 10A and 12)
Precautions Bisassay initiation procedure Partial responsibility statement Action points (general, whole body counts and urine specimens)
Records The appraisers noted that the information contained in Procedure HP0/C0-26, lacked many of the recommendations of ANSI N343-1978, " Internal Dosimetry for Mixed Fission and Activation Products."
Procedure HP0/C0-26 required that all personnel (PECo and contractors) whose previous employment involved exposure to radiation or radioactive materials be whole' body counted prior to entering the plant. The procedure also stated that a bioassay should be considered for a representative sample of personnel involved in a major. shutdown, and when ingestion, inhalation or absorption of radioactive material was se.pected.
It was also stated that all permanent Peach Bottom personnel should have a bioassay performed routinely.
The licensee was attempting to provide baseline and termina-tion whole body counts for all personnel working in the power block. However, this requirement was not defined in any current procedure. The responsibility for ensuring workers received a whole body count was reported to be assigned to each supervisor.
This responsibility was not defined in any current procedure. An_d it was not apparent that all supervisors were aware of their responsibility.
o
w 25 The HP0/CO-26. procedure discussed urine and fecal analyses program responsibility and concentration action levels.L However, the-procedure was deficient in the following areas:
No guidance was given as to the size of the urine or fecal sample. required. The sample size should be sufficient to allow proper sensitivity of analysis.
Urine sample volume should be at least 250 milliliter and could range to approximately 1.4 liters per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. -The sample collection time and period'of expected or potential uptake was not_identfied in the records of individuals having prior urine analysis.-
The method for collection, handling, sample preparation, and shipment of urine and fecal samples was'not
. identi fi ed.
There was no guidance in the use of blanks and. spiked samples for insuring a quality bioassay (excreta and urine samples) program.. Ofscussions with the dosimetry supervisor confirmed that spiked samples were not' currently being used. The present dosimetry super-visor could not remember t un last time an audit had been performed on the veraor providing bioassay analyses.
2 The procedure did not adequately address-the action to be taken in the event where a MpBB'value was i
exceeded.
There were no instructions as to the cioassay sampling frequency based on effective half-life.
The licensee's whole body gemma counting system malfunctioned on the 19th and 27th of May 1980.
In lieu of whole body counting, 33 urine samples were collected on the 19th of May and 22 urine samples were collected on the 27th of May. These were the only urine samples that had been collected by the licensee since January 1,1980.
Prior to January 1, 1980, it appeared from the records of previous urine analyses that only divers and individuals unable to t eceive a whole body count were given urine analyses. At the time of this appraisal, the results from the May urine samples had not been received.
However, the appraisers reviewed previous urine analyses by the lic*ensee's contractor.
The results were reported in total activity only and not by individual radionuclides.
Operation of Whole Body Counter l
The whole body counting system was operated by a contractor I
health physics technician, who was instructed to report abnormal conditions to the pEco Josimetry Supervisor.
l-l
c 0
O' 26 This individual had not received formal training on the operation of this instrument, and stated that prior to working with this system she had never worked with a whole body counting system. She was given approximately 2 days of on-the-job training by the previous health physics contractor technician. When questioned about the system, it was obvious that the technician had sufficient knowledge for starting, operating, and stopping the instrument.
However, she had no comprehension of the technical operation, purpose, or results of the whole body counter.
The technical direction for the whole body counter was the 7esponsib111ty of the Dosimetry Supervisor and his technical assistant. The Dosimetry Supervisor recently graduated from college (with a Master of Science in Health Physics) and had.been involved with operating the system for only a few months. He had no previous health physics or internal /
external dosimetry experience prior to coming to work at Peach Bottom. The Dosimetry Technical Assistant had been employed by PECo for the past three years as a contract health physics technician. Approximately four months prior to the inspection he had bean assigned to the Dosimetry Section.
He stated that prior to this time he had received no training in internal / external dosimetry.
(See also Section 2.3 of this report)
A copy of procedure HP0/CO-26 was located at the whole body counter however, no other re.'erence material was present.
Both the supervisor and the technical at
+4nt stated that they were familiar with the reference
'al listed in the procedure.
However, neither individua... s familiar with ANSI N343, " Internal Dosimetry for Mixed Fission and Activation Products." Although both individuals stated that they had seen copies of ICRP Reports 2, 6, 9, 10, 10A and 12, neither individual had ever performed the detailed calculations in any of these documents. They indicated that in the ev'ent of an internal deposition of a significant level (a significant level was determined to be an arbitrary number), the Radiation Protection Manager would be notified and he would be responsible for performing the calculations.
3.2.2 QA/QC Prooram The QA/QC program was included in Procedure HP0/C0-26A, Revision 1.
This program consisted of a daily source check with cesium-137 and cobalt-60 sources.
-- ---a p-m-
"w W~
=
27 The procedure also called for a background check in the morning, once during the day., and once in the evening.
The sources were used primarily to determine the proper "zero" and " gain" setting.
The activity of the sources used was unknown. The procedure for calibration of-the whole body counter did not provide for quantitative calibra-tion of the instrument.
The daily. calibrations were per-formed by placing the cesium-137 and cobalt-60 cylindrical sources in approximately the center of the counting bed.
The sources were originally provided by the whole body counter vendor who had in turn obtained the sources from an independent isotope laboratory.
The sources were counted for approximately five minutes and the results displayed on a screen.
The spectrum was then checked with a stored spectrum and the results reported to the Dosimetry Superviror if th:re was a significant difference.
- However, the activity of either source was unknown and what was considered a significant difference was speculative..The use of calibration sources which are traceabla to the National Bureau of Standards is recommended by ANSI N343-1978, Section 15.2.
The licensee's calibration program did not include calibration points ranging between 60-20,000 nCi as recommended in ANSI N343-1978, Section 15.2.
The daily calibration procedure did not use a standard body phantom.
The licensee did not have the records of the last NBS traceable calibration i
(performed in February 1977) using a phanton; however, the vendor did supply the records.
Since February 1977, the only calibration performed had been witn the check sources of unknown activities.
Calibration reference points had not been established for radionuclides with gamma energies below cesium-137 (0.662 MeV). A standard calibration point had not been determined for such radionuclides as iodine-131 (0.364 MeV).
Cesium-137 and cobalt-60 were the only two radionuclides used to maintain the energy calibration of the system.
The whole body' counter was situated near the main plant entrance in a facility with no additional shielding.
Although Procedure HP0/CO-26A called for a background check and source check in the evening hours, this was not done.
It was noted that the background varied, however, the procedure specifying the method for performing backgrounds did not stipulate steps to be taken in the event of an elevated background.
i n
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E,-
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t i
28 3.2.2 -
Respiratory Protection Documents Reviewed Procedure'HP0/CO-3. " Area SurveyAtrborne Radioactive Contamination." Revision 4, 05/09/77.
HP0/CO-9, " Respiratory Protection Program," Revision 7, 10/09/79.
Procedure HP0/CO-9A, " Respiratory Protection Training and Fitting," Revision 4, 10/09/79.
Procedure HP0/CO-98, '* Respiratory Protective. Equipment, Selection, and Use," Revision 3, 10/09/79.
The only individual fully aware of the storage locations and inventory of all the SC8As was the Respiratory Protection Supervisor. When questioned on the quality of air, no one was certain as to the type of breathing air available. The Radiation Protection Manager attempted to produce the certificates on the quality of air for the SCBA (self-contained breathing apparatus), however, the certificates could not be found.
It was necessary for _the RPM to request that the vendor supply certificates verifying that the SC8A breathing air was a type "D" or better quality.
The licensee had not established a comprehensive engineering i
controls program to prevent the spread of airborne activity for maintenance projects. There appeared to be a limited i
use of glove boxes, hoods and tents for the purpose of reducing airborne contamination.
In addition to the o
I limited engineering controls, little decontamination was performed for the purpose of reducing mask use.
(See Section 6.0 for comments regarding the ALARA program.)
4 The congestion found in the respirator repair room which hindered good working conditions is discossed in Section 5.0.
Surveillance The Respiratory Protection Supervisor and the Radiation Protection Manager stated that continuous air monitors (CAMS) were used as an early warning of airborne contamination.
The CAMS were located in strategic areas throughout the plant.
In the event of an airborne release, the CAMS would signify the need for respiratory protection in that area. However, on several tours through the plant, the appraisers found CAMS that were either nonfunctional or functioning improperly.
For example,. CAM No. I showed a chart reading of 4000 counts / min beta activity while the
{,
1 9.-
29
'instru ant's seter reading was 300 counts / min beta. When the senior health physics ~ technician assigned to that area was questioned: about the discrepancy, he stated that he-did not rely on the CM because it was unreliable. He stated and it had been verified that the cms were not -
~
being properly calibrated. On a. subsequent tour of the plant 5 ~ days later, CM No. I displayed 5000 counts / min
-beta activity on the chart compared to 400_coun.ts/ min beta activity on the meter.
The sampler was observed laboring 3
at'less than-1 ft / min with intermittent increas'es to 3 3
ft / min air flow.- Other cms that were operating at less.
3 than the indicated 5 ft / min also had discrepancies between chart and meter readings.
Training The Respiratory Protection Supervisor was respons'ible for the operation of the fitting booth and for conducting the training of all individuals wearing respiratory protection.
Prior to assuming responsibility for this program in _
October 1977, the Respiratory Protection Supervisor had no prior experience. In this field.
Upon employment with PEco he received some training on the booth operation and maintenance of the mask. However, there was no special training given in respiratory protection. On his own initiative, the individual became familiar with Regulatory Guide 8.15 and NUREG 0041.
Subsequently, he has hired a technician who was responsible for the daily operation of the fitting booth and testing portion of the respiratory protection program.
This individual, likewise, had not re elved any formal training in the operation of the booth aro/or philosophy of respiratory protection.
Respiratory protection training given to the general employees and the mask-fitting of those employees appears to be adequate.
However, additional training needs to be given to the Repi,atory protection Supervisor and to the technician responsible for operating the mask-fitting booth.
(See Section_2.3 of this report) 3.2.3 Conclusions 1.
The following items are identified as.significant findings.
Improvements in these areas are required in order to achieve an acceptable program:
a.
An adequate whole body counter QA/QC program had not been established.
b.
Formal procedures had not been established for collection, handling, shipping, and processing excreta bioassay samples.
r 30 c.
Formal procedures had not been established that detatl'ed the action to be taken if an individual received a significant internal deposition of radioactive material.
2.
In addition to the above items, the following matters should be considered for improvement of the program:
a.
There were no provisions for a backup in the event the onsite whole body counting system should fail.
b.
Procedures did not clearly assign the responsibility for assuring appropriate individuals 'are whole body counted at the proper frequency, nor did they specify-the frequency at which individuals in various work categories are to be counted.
c.
A management policy statement had not been issued by the licensee regarding a commitment to a respiratory protection program.
3.3 Surveys and Access Control Documents Reviewed Procedure HP0/CO-1, " Radiation Dose Rate Survey Techniques,"
Revision 5, November 6, 1978 Procedure HP0/CO-2, " Contamination Survey Techniques and Evaluations, Revision 2, May 9, 1977 Procedure HP0/CO-3, Airborne Activity Survey Techniques,"
Revision 4, May 9, 1977 Procedure HP0/CO-3a, " Airborne Activity Survey Techniques-Constant Air Monitors," Revision 1, August 4,1978 Procedure HP0/CO-3b " Airborne Activity Survey Techniques-Portable Fixed Filter Samplers," Revision 1, May 9,1977 Procedure HP0/CO-3c, " Airborne Activity Survey Techniques-Charcoal Cartridges," Revision 1, May 9, 1977 Procedure HP0/C0-4, " Radiation Work Permits," Revision 15, April 17, 1980 Procedure HP0/CO-6, " Personnel Contamination Survey Techniques,"
Revision 5, March 30, 1978 y
31 Procedure HP0/CO-11 " Establishing and Posting Radiol,ogically Controlled Areas," Revision 7, November.30, 1978' Procedure HP0/CO-24," Access to Primary Containment (Drywell and Torus)," Revision 14, March 21, 1980
-Procedure HP0/CO-72," Access to Tip and Torus Area," Revision 2,. January 31, 1978 Procedure HP0/CO-74," Transport and Temporary Storage of Radioactive Trash," Revision 2, November 17, 1978 Procedure HP0/CO-100, " Health Physics Guides used in the Control of Exposure to Radioactive Material," Revision 6, September 20, 1979 Surveillance Test 7.9.1, " Radiation Survey After Refueling,"
performed June 1, 1978, October 26, 1978, and November 20, 1979.
The appraisers also reviewed selected procedures and records regarding radiation,. contamination, and airborne surveys for the period January 1, 1979 - June 24, 1980.
The appraisers conducted several tours of various work areas during normal and offshift hours betweer. June 16-26, 1980 to observe survey and control practices..The appraisers conducted independent radiation measurements and accompanied technicians while they accomplished routine survey activities. The following items were noted:
3.3.1 Pror2dures The licensee's procedures did not address requirements and frequencies for conducting routine surveys of areas not covered by a RWP.
The licensee was conducting routine daily / weekly beta gamma contamination and radiation surveys of various plant areas. The appraisers noted that the licensee's beta gamma survey program appeared adequate, but the program was not described in the health physics procedures.
The survey schedule appeared on a hand-written data sheet, but was not referenced in any of the approved plant procedures.
The appraisers had concerns that the licensee was not committed, in plant procedures, to a defined survey program.
In its present for' mat, the survey program could be terminated or significantly altered without going through the normal plant procedure review process. A licensee representative stated that the present beta gamma survey schedule was initiated by one of the senior technicians several years ago.
However, the program l
was never included as part of the plant health physics procedures.
i
v.
32 Thel data recorded on Surveillance Test 7.9.1, " Radiation Survey After Refueling," did~not indicate the operating i
~
power level.during the survey. The recorded radiation
~ 0 levels varied considerably between.various startup surveys.
' Without listing the power. level for each survey, it was not possible to determine if adverse trends:were~occuring..
- ST 7.9.1 only required that surveys be performed at power levels greater than 20%. The' appraisers also noted that-the survey meters used to perform the surveys.were not
- identified on ST 7.9.1.
3.3.2 Alpha Surveys The licensee.had not established.an alpha survey-program.
Airborne and contamination. samples had not been analyzed in order to determine if alpha activity;is a problem.
- None of the health physics procedures referenced requirements
'l f:r routine or special.in plant ~ alpha survey programs.
The licensee representative responsible for.the survey program stated that the only alpha surveys that have been.
performed were receiving' surveys for new fuel assemblies.
~
The licensee representative responsible for the survey program stated that, in his opinion, alpha activity was not a problem at nuclear' power plants and it would be' a waste of time and effort.to conduct such surveys. The
- appraisers referenced several publications regarding alpha studies that have been performed at various nuclear power-plants and suggested that survey activities could be l
~ discussed with other licensees that have found alpha emitters to be a significant problem.
[
10 CFR 20.201(b) " Surveys," requires that each licensee i
shall make or cause to be made such surveys as may be.
necessary for him to comply with the regulations.
Failure a
to perform alpha surveys in order to demonstrate compliance.
with 10 CFR 20.103 is considered an item of noncompliance.
3.3.3 Neutron Surveys 4
The portable neutron survey meters used to evaluate neutron-radiation levels had not been properly calibrated. During i
a review of the licensee's neutron survey program the appraisers observed that the records indicated that neutron survey meters were calibrated at 4 mrem /hr, 40 mrem /hr, 400 mrem /hr, and 4000 mrem /hr.
The appraisers questioned the_ licensee as to the type of neutron source used to obtain these calibration points. The licensee stated that i
the meters were calibrated by an offsite vendor.
The licensee stated that they were not familiar with the actual' calibration procedure used by.their vendor, but assumed that the mrem /hr calibration points were established I
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33 from a neutron source (s). The appraisers requested that the vendor be contacted for the purpose of discussing the calibration procedure.
Ensuing discussions revealed that the vendor neither possessed nor used a neutron source.
The vendor's procedure by passed the detector and only involved an electronic check of the count rate circuit with a pulse generator. Therefore, the licensee was unable to verify the operability of the detector portion.
of the survey meter which in turn raised the question regarding the validity of the' entire neutron survey program.
The survey data recorded on Surveillance Test 7.9.1 " Radiation Survey After Refueling" performed for Unit No. 3 on June 1, 1978 and November 20, 1979 and Unit No. 2 on October 26, 1978 indicated that neutron radiation levels, except for the turbine area, were consistantly higher than gamma levels. The appraisers stated that neutron calibration program did not appear to satisfy the recommendations of ANSI N323-1978, " Radiation Protection Instrumentation Test and Calibration." It could not be established whether actual neutron radiation levels were higher or lower that the' values recorded on Surveillance Test-7.9.1.
The data obtained from neutron surveys was entered on the worker's Form NRC-5 to document compliance with 10 CFR 20.101 (See Section 3.1.1 of this report.) Since the neutron survey meters had not been properly calibrated, the dose information recorded on Form NRC-5 could not'be substantiated.
10 CFR 20.201(b) " Surveys," requires that each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations. As used in the regulations survey means an evaluation of radiations hazards.
Failure to properly evaluate neutron radiation levels in order to demonstrate compliance with 10 CFR 20.101 is considered an item of noncompliance.
It was also noted that discrepancies existed regarding calibration data for other survey meters.
For example, the calibration dats for the Eberline R0-2A ion chamber survey meters showed about 15 separate calibration points.
These points were the same points listed in the licensee's procedures that were used when calibrations'were performed onsite by the licensee. However,-the appraisers were informed that calibrations were actually to be performed in accordance with the offsite vendor's calibration procedures.
The vendor's procedures specified five calibration points that were different from the 15 that appeared on the data sheets. The lack of a proper neutron calibration program plus the inconsistencies with other calibrations casts a N
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34 shadow of doubt over the entire survey meter calibration program..The licensee stated that they assumed that their vendor was providing quality work, but a QA/QC audit had not been performed to confirm their assumption.
3.3.4 Airborne Surveys
.An' adequate continuous air monitoring program had not been established to provide immediate warning-to workers in the event of high airborne releases within the plant.
The licensee maintained a rather extensive bata gamma grab air sampling program for routine area surveillance and special surveys of non-routine work areas.
Low volume air samples were obtained over a 4-6 ho'r collection period with u
analysis usually completed within another hour. Data obtained from the grab sampling program were used to established protective equipment requirements and MPC-hour records. However, the grab sampling program did not provide prompt warning to workers should a significant airborne release occur. The licensee had about nine constant air monitors (CAMS) in the plant, but the following deficiencies were noted which prevented an adequate continuous' air monitoring program from being maintained:
The licensee had not established a program to ensure that the CAMS were properly calibrated and maintained.
The responsibility for calibration and maintenance of the CAMS had not been assigned to an individual aad/or department.
,A program had not been established to ensure that CAMS were checked for operability at an acceptable frequency (e.g. once per shift).
It was noted that several CAMS were out of service due to maintenance problems.
The recorder strip charts for several CAMS weresout of paper.
The observed flow rate for several CAMS was less than 2 CFM.
The recommended flow rate was 5 CFM.
With certain CAMS, there was disagreement between the values indicated on the count rate meter and the strip chart.
For example, the rate meter for one CAM indicated a value of 400 counts per minute (cpm) whereas the strip chart indicated 5000 cpm.
CAMS were moved from one locatio_n to the next without notifying the access control point HP technicians.
x 35.
Breathing Zone Samples A breathing zone'(lapel samples) sample program had not
~
been established to verify the Itcensee's routine grab samples. The licensee' maintained a rather comprehensive grab sample =(high and low volume air samples) program _that.
provides information regarding general area airborne ~
concentrations. -Mc#ever, a program had not been' established to, provide-MPC values based on actual breathing' zone samples.
. Area Air Samples'
'The licensee appeared to maintain an adequate general area beta gamma air. sampling program..The lack of alpha and breathing zone sampies were discussed previously in' this section. Observations made during the appraisal indicated
'that sufficient general area beta gamma samples were
~ btained prior to starting a work and periodically during o'the job. Analysis of air samples were accomplished in a timely manner (e.g. usually less than one hour).
- 3. 3.5.
Radiation Work Permit (RWP)
-The licensee _'s RWP program was reviewed. This included a review of both active and terminated RWPs.
Some minor
. editorial descrepancies were noted in Procedure HP0/CO-4,
" Radiation Work Permits," but in general the licensee 4
maintained a comprehensive RWP program. The appraisers made daily tours of Units 2 and 3 anc visited the access control points estabitsbed in conjunction with the Unit 2 outage. The appraisers observed jobs in progress in the drywell, torus, refueling floor, reactor building, and turbine area.
It appeared that radiological work ~ activities l
were properly controlled. The appraisers noted some minor violations of procedures, but overall, workers appeared to comply with the requirements specified on the specific RWP.
The RWPs contained requirements for updating work conditions at established frequencies based on the particular job.
Surveys were performed on tools and equipment prior to leaving a work area.
3.3.6 Radiation Protection Instrumentation Documents Reviewed i
^
Procedure HPA-5, " Operation.of Liquid Scintillation Counter," Revision 1, August 18, 1978.
i.
Procedure HPA-31, " Calibration of GM Detector Model E400." Revision 1, February 11, 1980
g l
36 Procedure HPA-32, " Calibration of Teletector Model-6112, Revision 1, February 11, 1980.
Procedure HPA-35, " Calibration of Ionization Chamber R02, " Revision 1, February 11, 1980.
Procedure HPA-39,." Calibration of Alpha Scintillation Detector Model PAC-45," Revision 1, Febiuary 11, 1980.
Procedure HPA-40, " Calibration of the Eberline Portable Neutron REM Counter Model PNR-4," Revision 1, Febraury 11, 1980.
~ Procedure HPA-52, " Calibration of Radiation Monitor Model RM14," Revision 2, August 17, 1978.
Procedure HPA-53, " Calibration of the Eberline Portal Monitor," Revision'1, August 4, 1978.
Procedure HPA-63d, " Calibration of Ventilation Systems Radiation Monitors," Revision 1, November 29, 1978.
Procedure HPA-63f, " Calibration of Liquid Process.
Monitors," Revision 0, March 17, 1975.
Surveillance Test 4.9.A, "Frisker Calibration and Source Check," Revision 2, April 14,1980.
Surveillance Test 4.9.B, " Portal Monitor Calibration and Source Check," Revision 2, April 18, 1979 A review was made of the health physics instrumentation capabilities (portable, semi portable, fixed, process radiation monitors and area radiations monitors) associated with the radiation protection program.
This included a review of instrumentation, maintenance work, documentation and records.
The overall radiation instrument calibration program was fragmented and poorly organized.
The responsibility for the program was not assigned to an individual or department.
For example:
(1) The Chemistry Department was responsible for the calibration program regarding portable, semi-fixed, and air samplers.
Some of these instruments were calibrated onsito while other were calibrated by an offsite vendor.
(2) The I&C Department was responsible for calibrating portal monitors.
(3) Calibration of the pocket dosimeters, TLDs, and the whole body counter was the responsibility of the Health Physics Support Section. _The responsibility for calibrating the CAMS had not been assigned to any department.
i 4--
---9
^
' n,'
37 The range identification marking were obliterated on several Eberline R0-2A survey meters. -Consequently, it was not possible for the user'to read which range the meter.was set on..During tours of the access control points, the appraisers noted that the painted numbers
-associated with the range selector switch'had been rubbed-off due to manipulation of the range switch. LTheirange-
-selection for.the R0-2A meters were 0-50 R/hr, 0-5R/hr, 0-50 mR/hr and 0-500 mR/hr. The appraiser. inspected 13
_RO-2A meters located at various access control points and-
.noted.that one or more.of the~ range markings were rubbed off from meters numbers 208, 213, 248, 259, 262, and 562..
Several of the contractor HP technicians onsite for this refueling outage stated that they had never used the R0-2A meter. prior to their assignment to Peach Bottom and were not familiar with the operating characteristics of the instrument.
i An. adequate number of instruments such as portable survey meters,. grab air samplers, contamination friskers, dosimeters,.
i and portal monitors were available. A few technicians stated that it was sometimes difficult to locate ion chamber survey meters, but the problem appeared.to be one 4-of proper distribution.of.the meters instead of an actual.
shortage of instruments.
Friskers were located at selected control points.in the plant for monitoring personnel,
-tools,'and equipment. Workers were required to exit through portal monitors positioned at the reactor and security butidings. A calibration sticker was affixed to:
each. instrument.
The sticker indicated the last calibration and next due date.
The licensee's records indicated that calibrations-were performed at the prescribed frequencies.
On a tour through the facilities, the appraisers noted that the check sources used for ensuring proper operation of the portable instrumentation were not clearly marked as to the exposure rate.
There were no criteria for rejection should the instrument respond poorly to the check source.
t When questioned about the check sources, neither the Radiation Protection Manager nor the shift Radiation Protection Supervisor was aware of what the proper check source exposure rates were.
Numerous technicians. stated that the sources were used primarily to ensure that the j
meter moved when_placed in proximity of the' sources.
The calibration procedures for friskers and portal monitors call for a calibration check with a check source.
The procedure did'not specify the source strength, rejection cr:teria, or the desired level of detection.
Check sources 5 :
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~ (reference ANSI N323-1978,." Radiation Protection Instrumen-
~
tatEn Test and Calibration") should.be used in a constant and v roducible manner for all' calibrations. ~ Reference readinh should be obtained for one point on each scale or
~ decade.nsmally used.
Ifsthe instrument response to the referenceLreadingl varies by more than plus or minus 20%,
the instrument should be returned for repair and/or calibra-l
' tion. -The check source should have sufficient strength.to i
ensure desired level of detection and' sensitivity.-
t' 3.3.7 Supplies and Eautoment The. appraisers reviewed the inventories of~ health physics suppl.ies,Lequipment,'and instruments available to support the radiation protection program.- The lack of adequate
- CAMS for jobs with high airborne' potential wa's identified as a chronic problem. Aside frc.a 49 inadequate CAM program, 4
the licensee's inventories of su';h items as anti-contamination
- clothing, survey meters, air samplers, containers and
.dosimetery devices appeared adequate..The HP tech ~-nicians stated that short term shortages of specific items may occur, but in general adequate inventories.were-maintained.
An adequate sample counting program was maintained to permit timely analysis of smear and beta gamma air samples.
3.3.8 Housekeeping i
4
~ Housekeeping conditions observed during the appraisal appeared adequate.
The appraisers noted that there was j
some accumulation of used anti-contamination clothing and
^
equipment at access control points and job sites, but.
clean-up crews normally removed the materials in a' timely manner.
Several licensee and contractor personnel stated that an extensive housekeeping effort was completed in
~
anticipation of the Appraisal Team visit. A number of people were concerned that the same level of housekeeping would not be maintained after the Appraisal Team left the site. The NRC resident inspectors also commented that poor housekeeping practices had been a chronic problem in 2
the past. The licensee personnel responsible for supervising the housekeeping effort stated that about 150 contractors were assigned full time tc janitorial activities during the outage.
This number is reduced to about 90 for normal operating status.
The supervisory personnel responsible for housekeeping activities ~ stated that the housekeeping L
effort would be more effective if was better organized.
Formal procedures had not been developed and no uniform method had been established for responding to housekeeping p
requests received from various departments.
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39 3.3.9 Conclusions 1..
The following items are identified as significant findings.
Improvements in these areas are required in order to achieve an acceptable program.
a.
An in plant alpha contamination.and airborne survey program had not been established.
b.
Adequate calibrations had not been performed on the neutron survey meters.
c.
Comprehensive in plant continuous air monitoring and breathing zone sampling programs had not been established.
2.
In addition to the above items, the following matters should be considered for improvement of the program, a.
The licensee's procedures did not address requirements and frequencies for conducting routine surveys of areas not covered by a RWP.
b.
The reactor power levels and specific survey meters utilized were not recorded for startup surveys.
c.
The instrument calibration program was fragmented and poorly organized, d.
The range identification markings had been rubbed off from several Eberline R0-2A survey meters.
4.0 Radioactive Waste Management System Documents Reviewed Surveillance Test 7.4.4, "In place 00P Leak Test, Halide Leak Test and Carbon Sample Laboratory Analysis or The "A" SGTS Filter Train," June, 1980.
Surveillance Test 7.4.6, "In place DOP Leak Test, Halide Leak Test and Carbon Sample Laboratory Analysis of the "B" SGTS Filter Train," June, 1980.
f
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~40 Surveillance Test 7.7.1 " Control Room Emergency Ventilation Filter Efficiency
-Test," March, 1980.
Surveillance Test 7.6.5, " Refuel Floor Vent Exhaust Radiation Monitor Cali-bration," January, 1979 - April, 1980.
Surveillance Test 7.6.6, " Reactor Area Vent Exhaust Radiation Monitor Calibration," January,1979 - April,1980.
Surveillance Test 7.6.1.a, " Quantitative Analysis of Gamma Emitters In
~ Off-Gas." January - August,1979.
Surveillance Test 7.6.1.j, " Determination of Total Noble Gas Release Rate and Maxium Percent of Technical Specification Limits," January - December 1979.
Surveillance Test 7.6.1.h, " Determination of Strontium-89 & 90 and Alpha Activity on Plant Effluent Particular Filters," January,1979 - April, 1980.
Surveillance Test 4.4, " Main Stack Gas Monitor Functional Test," January, 1979 - April, 1980.
Surveillance Test 4.4.4, " Main Stack Gas Monitor Calibration," September, 1979.
Surveillance Test 4.7, " Building Exhaust Stack Radiation Monitors Functional Test" January - December,1979.
Surveillance Test 4.7.1, " Building Exhaust Stack Check Source Calibration,"
January - December, 1979.
Surveillance Test 7.2.1.9, " Determination of Dose Equivalent Equipment uC1/gm I-131 In Primary Coolant" January,1979 - April,1980.
Surveillance Test 7.5.1.C, " Identification of Tritium in Liquid Radwaste Releases," January,1979 - April,1980.
I Surveillance Test 7.6.2, " Calibration of Main Stack Monitors, July, 1979 - April, 1980.
Surveillance Test 7.6.3, " Calibration of Unit 2 Roof Vent and Unit 3 Roof Vent Monitors with a Known Radioactive Source," March, 1979.
Procedure HP0/CO-17A, " Responsibility for the Safe Transfer, Packaging, and Transport of Low-Level Radioactive Material," Revision 0, October 20, 1979.
Procedure HP0/CO-19, " Preparation of Radwaste Samples and Analysis,"
i Revision 2, January 18, 1978.
j
l
'41 Procedure HP0/CO-70, " Manual Capping of Solid Radwaste Drums," Revision 0, August 4, 1973.
Procedure HP0/CO-71A, " Filling, Capping and Storage of Spent Resins,"
Revision 2, January 3, 1980.
Procedure HP0/CO-718, " Sampling and Analysis of. Spent Resins," Revision 1, February 5, 1979.
Procedure HP0/CO-71C, " Loading of a Radwaste Cask," Revision 4, December 18, 1979.
Procedure HP0/CO-71C Appendix A, Loading and Closing HN-100 and HN-600 Casks," Revision 3, January 3,'1980.
Procedure HP0/CO-71C Appendix B," Loading and Closing the HH-200 Radwaste Cask," Revision 3, November 3, 1979.
Procedure HP0/CO-71C Appendix C " Loading and Closing the CNSI 6244 Type B Cask," Revision, 0, February 1, 1980.
Procedure HP0/CO-71C Appendix 0, " Loading and C hsing CNS-15-160B and CNS-15-1605 Casks," Revision 0, April 18, 1980.
Procedure HP0/CO-710, " Compacting and Storage of Compacted Radioactive Trash," Revision 2, October 1, 1979.
Procedure HPC /CO-71C Appendix E, " Loading and C'osing HN-300 Cask,"
Revision 0, April 18, 1980.
Procedure HP0/CO-71F, "Verfication of Burial Site Criteria For Radwaste Shipping," Revision 1, November 28, 1979.
Procedure HP0/CO-71F-1, " Burial Site Criteria for Barnwell, South Carolina, Revision 1, November 28. 1979.
Procedure HP0/CO-71F-2. " Burial Site Criteria For Beatty, Nevada," Revision 0, October 1, 1979.
Procedure HP0/CO-71G, " Loading of a Radwaste Truck or Van," Revision 1, January 3, 1980.
Procedure HP0/CO-71-H, " Packaging and Storage of Non-Compacted Radioactive Trash in LSA Containers," Revision 0, October 1, 1979.
Procedure S.10.4.8.A, " Drumming System Normal Operation," Revision 2, January 23, 1980.
Procedure HP0/CO-18, " Processing Liquid Radioactive Waste," Revision 7, May 22, 1979.
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~
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1 T Q,e s.
u 42 st,.
'Radwaste Program
-The appra'isers riviewed the following aspects of the licensee's radwaste program:
- g
- organization liquid and gaseous waste processing systems solid waste' system effluent monitors effluent release controls analyses of effluent releases -
4.1 Organization An individual had been designated as the Radwaste Supervisor. This
~ individual reported to the Operations Shift Superintendent.. A job description had not been developed for the Radwaste Supervisor. As a result, the specific job responsibilities were not documented.
(See also Section 1 of this report) Actual operation of the liquid radwastefequipment was accomplished by the Assistant Plant-Operator (AP0) assigned to each shift crew. Helper Operators and Auxiliary Operators were. assigned to operate the waste compactor and gaseous radwaste system. The appraisers reviewed the training pre; rams for-personnel responsible for operating the radwaste equipment.
The training program consisted of both formal classroom lectures and on-the-job training. The majority of the training was devoted to the AP0s responsible for operating the liquid waste system.
Training was also provided to helpers and Auxiliary Operators. A health physics technician was assigned to provide full-time coverage in the radwaste facility during the day shift.
4.2 Gaseous Radwaste The gaseous radwaste system included the subsystems that process and dispose of the gases from the main condenser air ejectors, the mechanical vacuum pump, and the turbine steam packing exhauster condenser.
Gases from the air ejector off gas systems, the mechanical vacuum pumps and the turbine steam packing Lxhausters of each unit, as well as, the standby gas treatment system, which serves both units, were exhausted from a 500 ft. stack. The air ejector off gas subsystem consists of recombiner-compressor train, hold-up lino, HEPA filters, isolation valves, dilution fans, and the stack. The air ejector off gas subsystem including the recombiner and compressor train provitas about 92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br /> holdup of the air ejector off gases.
I I
43
'4.3 Liquid Radwaste The liquid radwaste system collects, processes, stores, monitors, and disposes of 1R"'d wastes from both Units 2 and 3.
Wastes were collected in sumps d drain tanks, and then transferred to tanks in the. adwaste building for disposal.
Between 80,000-120,000 gallons of liquid waste were processed each day.
The licensee stated that the liquid system was usually able to handle the amounts of waste generated, but that the system must operate at near full capacity in ceder to prevent a backlog of waste material. The licensee did not maintain an alternate or stand-by system.
The ifcensee stated that the system was essentially unchanged from that originally installed and no 10 CFR 50.59 modifications had been made.
The licensee stated that normally the process tanks provide adequate storage capacity, however, plant conditions had required periodic use of the surga tank.
4.4 Solid Radwaste The solid radwaste system collects and processes wastes for offsite shipment and disposal.
This system was a contiguous part of the liquid radwaste system.
The system was designed to process wet and dry solid wastes. Wet wastes were dewatered and packaged in 55 gallon drums. The licensee's solid r.dwaste system did not include a solidification process such as concrete or urea formaldehyde (UF).
Wet wastes result from the processing of spent demineralizer resins, spent filter material from the drain subsystems, and from the water cleanup systems.
The esstes are in the form of spent demineraliter resins and filter sludge slurry which were collected in the four backwash receiving tanks or in the waste sludge tanks.
The slurry collected in the backwash receiving tanks was pumped on a batch basis to one of the corresponding phase separators. The slurry was then pumped from either the phase separators or the waste sludge tank to the centrifutes.
The centrifuge supernatant flows by gravity to the waste collector tank.
The de-watered solid material was discharged hy gravity to a hopper below each centrifuge. Drums were positioned under a hopper by remote operation of a conveyor. Gravity loading of a drum was via remote operation of the hopper valves.
When full, the drum was moved to the capping station for remote lid placement and then moved by the aveyor system to a temporary storage area. The licensee no..Ily processes about 70 drums per week of wet solid waste and a like number of compacted dry waste.
In addition, about 20-25 boxes of non-compactable solid waste was shipped each month.
The.following problems were identified regarding the solid radwaste system:
i
i 44 The sparger mixing system associated with the phase separators was such that " funneling" occurred around the. sides of the separators. This resulted in a manual effort after each cycle to remove the material that had collected around the sides of the separators.
A licensee representative stated that replacing
-the sparger mixing system with a mechanical mixer would correct I
.this problem..
The drum capping machine was not working properly..The capping system was originally designed as an automatic remote unit.
However, problems had developed with the system which required that many drum lids must be manually fitted while on the conveyor belt or during loading operations for offsite shipments.
An'ALARA evaluation of the solid radwaste program had not been performed.
(See section 6.0) 4.5 Filter Systems A testing program had not been established for those HEPA filters and charcoal adsorber systems which were not included as Technical Specification requirements.
Systems for which a testing program had not been established included:
reactor building equipment cell exhaust off gas filter system rccombiner building (Unit-3 vent) radwaste facility (Unit-2 vent) turbine building equipment cell exhaust A licensee representative stated that the recombiner and off gas filters had been tested once previously, but the test results could not be located. The licensee stated that it was doubtfull if any of the other systems had ever been tested since initial pre-operational testing.
The licensee had established an adequate program for testing filter systems identified in the Technical Specifications.
4.6 Effluent Monitors The main stack and both unit vent monitors were not calibrated over their full range.
The main stack monitor had a full scale read-out between 1E-01 and 1E+06 counts per second (cps). The results recorded on surveillance Test 7.6.2, " Calibration of Main Stack Monitors" indicated that the highest calibration point was less than 10 percent of the full scale range.
Typical calibration points were between 30-1100 cp.s.
The Unit 2 and 3 roof vents monitors had a full scale range of IE+08 counts per l
o 45 minute (cpm).
The results recorded on Surveillance Test 7.6.3,
" Calibration of Unit-2 Roof Vent and Unit-3 Roof Vent Monitors with a known Radioactive Source" indicated that the calibration points ranged between 4.8E+03 cpm and 6.25 E+05 cpm. These calibration points are less than 10 percent of the full scale range.
~4.7 ' Effluent Controls The appraisers. examined gaseous and itquid effluent controls. The licensee's records for the period January 1,1979 - May 1,1980 indicated that gaseous releases were within Technical Specification limits. - The following aspects of the liquid release program were examined and found to be adequate:
compliance with Technical Specification sampling and analytical requirements.
release rates alarm set points sampling techniques release pathways review and approval of release permits prior to discharge records and reports Shipping The appraisers reviewed the licensee's radioactive waste shipping program. This included a review of selected shipments made between January 1, 1979 - May, 1980.
The licensee's program appeared to satisfy Department of Transporation (00T) and 10 CFR 71 requirements.
4.8 Conclusions 1.
The following item was identified as a significant finding.
Improvements in this area are required in order to achieve on acceptable program.
Full range calibrations had not been performed o'n the effluent monitors.
2.
The following items should be considered for improvements of the program, but do not warrent inclusion as Appendix A items:
a 46 a.
The drum capping machine was not operating properly.
b.-
Those filter systems which are not listed as Technical
- Specification items were not included for routine surveil-lance testing.
5.0 Facilities and Equipment 5.1 Health Physics Facilities' The.various areas normally associated with health physics departments were reviewed and it was noted that the Health Physics Department did not have dedicated counting room and the Chemistry Group performs all counting within the facility.
Further, the appraisers noted that no calibration facility was established for the calibration of instruments. An operational check source was available outside of the Health Physics Technicians' Office.
Adequate faciltities did exist for personnel decontamination.
Such a facility was located in the radwaste area and readily accessible to personnel from either Unit 2 or 3.
Throughout Unit 2 and Unit 3 there were adequate instrumentation and decontamination materials to perform a safe and thorough decontamination job.
Change rooms were located throughout the facility.
Basically, they were set up as a portable area which afforded little or no privacy, contained no lockers, and were at times distant from the work site.
There were no separate provisions for females.
Access control points were located at major work sites and were manned by HP technicians. The access control points seemed to be adequate and contained the required materials, anti-C's, and instru-mentation for the performance of the required work.
Protective equipment decontamination facilities seemed to be adequate in the area where the actual decontamination of the equipment was performed.
Need for better air flow control was apparent as nortable fans were set up to accomplish a movement of air.
Proper.ir movement would be better if established by an exhaust system from the facility itself.
Storage seemed to be a major problem and items ready fo~
and partially processed through the decontamination facility were stored in passageways and other areas where floor space could be found.
The testing room in which some repair and retest of various respiratory equipment were performed was badly cramped and required the removal of items stored in 55 gallon drums away from test bench facilities in order for technicans to continue their work function in that area.
Tools and parts decontamination areas were typically located close to the work area, were basically semi portable in nature, and were suitable and adequate for a temporary use situation.
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t 47 Instrument storage for portable. instrumentation near the Health Physics Office was adequato. However, such was not the case at the access control points where Sn?truments were frequently stored on the floor and were noted to be nicked and bumped on numerous occasions.
The Dostmetry Office had both adequate office and work space with a suitable layout.
Records storage in. free-standing files appeared to be apprcaching the storage limit.
Respiratory testing and fitting for personnel, although in older facilities, appeared to be cdequate for the purposes intended.
The training facilities where classroom training was held, although in somewhat cramped and older fact 11 ties, were nonetheless adequate to perform the required functions.
5.2 Radiochemistry Facilities The radiat'on chemistry facilities were reviewed and the following it==5 v:re noted. Analytical laboratories for radiation chemistry
- unctions were found to be adequate. One minor problem in the industrial hygiene considerations was observed, in which mid-room fume hoods were mounted on peninsular lab bench structures permitting eddy currents from passing personnel to disturb the face velocity
. air flow of these devices.
It appeared based upon the floit indicator flags on the hood sash that the air flow may not ha -ie sate.
Measurements were not made in this area.
The Chemistry Department Office space was typical of that found in health physics.
Department personnel were cramped with no space for quiet conversation or interviews.
It would appear that there was adequate space for sample storage for normal operations, however there would be questions as to the ability to store samples obtained during accident situations.
Sampline areas were found to be adequate for normal operations.
Accider c sampling capabilities were not yet in place.
Counting rou s in the radiation chemistry areas were found to be m
optimally used, had adequate ventilation, but were not designed for accident sample counting capabilities.
No space for additional instruments nor personnel was available, and there were no back up capabilities in the event of a major outage of the fa'cility due to major contamination or other such problems, which would render the facility unusable or inaccessible.
The facilties were appropriate for normal situations.
u' 48 5.3 Conclusions
- Facilities in the general functional areas of Health' Physics and Chemistry were adequate for normal operations.
6.0 ALARA Program The licensee had not implemented a formal, comprehensive ALARA program as
, described.in Regulatory Guide 8.8.
The appraisers observed that there were certain. aspects within the health physics program that would be included as part of an ALARA program.
For example:
high radiation areas were properly controlled; a special.CR0 (control rod drive) rebuild area had been constructed; workers adhered to RWP requirements; high ?adiation, radiation, contaminated, and airborne areas were properly posted; and
~ adequate health phy sics coverage was available. However, a dedicated
-ALARA program had not been established. The lack of an ALARA program had
.been. identified as a deficiency by the licensee's internal audit program in 1978. However, the licensee had not taken action to establish an ALARA_ program which should have included the-following additional' items /
actions:
a.
A written management policy or commitment to an'ALARA program had not been~ issued.
b'.
' A procedure had not been established to implement an ALARA program.
c.
The responsibility and authority for an ALARA program had not been assigned to an individual in upper management.
d.
The Radiation Protection Manager's responsibilities to an ALARA program was not described in procedures, e.,
-A program for ALARA preplanning and review of proposed projects and modifications had not been established, i
f.
-A progrom regarding ALARA goals and objectives for exposure reduction r
and engineering controls had not been established.
g.
A program for ALARA postjob critiques had not been established.
Based on the findings of this appraisal the fo' lowing item is identified E
as a significant finding.
Improvements are required in this area in
]
order to achieve an acceptable program.
A formal:ALARA program had not been estabitsbed.
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49 7.0 Internal Audit Program
-Documents Reviewed-Operation and Safety Review Committee'(OSR) audit, " Audit of Health Physics and Chemistry," 12/78 OSR Audit, " Surveillance Testing," February 20, 1979-QA_ Audit A 78-20, " Shipping Neutron Source Holders," September 6, 1978 QA Audit A 78-31, " Health Physics," November 12, 1978 QA Surveillance S 78-5, " Radiation Area Signs, January 19, 1978 QA Surveillance S 78-8, " Shipment of Solid Radwaste," February 27, 1978~
QA Surveillance S 70-14, " Radiation Work Permits for Unit 3," March 27, 1978 QA Audit A 79-15,."Onsite Radiological Monitoring and Liquid and Gaseous Effluent Releases," June 18, 1979 QA Audit A 79-19, " Fuel Receipt Inspection" QA Surveillance S 79-02, " Radioactive Waste Shipment Cask Repair and Shipment," January 22, 1979 QA Surveillance S 79-21, "Radwaste Preparation and Shipment," December 12, 1979 QA Audit A 80-01, " Dosimetry Progra.," January, 1980 QA Surveillance S 80-06, " Housekeeping Practices,"
QA Audit A 80-04, " Radiochemical Analysis / Chemical Analyses-Tech Specs,"
March 28, 1980 Engineering and Research Audit Qual 1-3-9, "Eberline QA Program, April 16, 1980 Engineering and Rer arch Audit Qual 1-3-9, RMC QA Program, February 27, 1980 Peach Bottom QA Manual Audits cf radiation protection activities were performed by various on and offsite licensee organziations and consultants.
In-house audits were conducted by the QA Department, Operation and Safety Review Committee, and the Engineering and Research Department.
The audit responsibilities for the QA Department and the Operation and Safety Review Committee sere specified in the QA Manual and Section 6 of the Technical Spacifications, respectively.
r -
_ i 4
[r 50 The generalLeategories of audits performed by the three licensee groups were (1) The.QA Department was responsible for auditing typical plant.
- activities..(2) The OSR audit responsibilities are described in the
- Technical Specifications and (3) The Engineering and Research Department conducted technical audits of offsite vendors.
The audits performed by o
the licensee were generally a review to ensure that activities were performed in accordance with established procedures. Audit reports of onsite procedures to ensure compliance with procedures were rather detailed'
- and identified several significant deficiencies. Corrective action responses to deficiencies were usually submitted in.a timely manner.
The appraisers noted that the licensee's audit teams did not include a team member with health physics experience (e.g. Regulatory Guide 1.8 qualified). The audits were rather thorough to ensure compliance with established procedures. However, the audit reports did not contain many recommendations regarding changes that should be made to existing proced-ures or improvements in the organization and staffing of Radiation Protec-tion Department.
The lack of a team member with health physics experience was also evident i
in audits of offsite vendors.
For example, the licensee visited the
~'
cffsite vendor in April, 1980, that provided personnel monitoring se,
'ce.
(See Section 3.1 of this report) for comments regarding personnel mon.eoring program).
However, the audit report did not evaluate vendor's beta calibration program nor the performance in their cross-check QA program.
It was also noted that the audit schedule did not include an audit of the vendor providing survey meter calibration services and TLD quality control irradiations.
See Section 3.3 of this report for comments regarding the calibration program.
Conclusions The following item is identified as a significant finding.
Improvement
- in this area is required in order to achieve an acceptable program.
An audit had not been performed on the.offsite vendor providing calibration services for portable survey meters and TLD quality control irradiations.
-The following item should be considered for improvement of the program, but does not warrent inclusion as a significant finding.
The audit team had not included a member with health physics experience.
51 8.0 Health Physics Procedures Documents Reviewed MPA - Procedure Series HP0/CO-Procedure Series A-Procedure Series ST-Procedure Series RCA - Procedure Series CA-Procedure Series The licensee health physics procedures were reviewed for the technical content, adequacy, usefulness and revistoa status.
The individual procedures that were found to be inadequate are discussed in the respective sections of this report.
This section pertains to the format, development, review, a1d changes.
It was found that a number v? the procedures lacked technical references (e.g., ANSI Standards, NCRP Reports and IAEA Standards).
This lack of technical raferences was exemplified in a lack of understanding of the state-of-the-art techniques within the technical staff at PBAPS.
Sevgral of the procedrres were found to be unclear and fragmented (e.g., RWP a.nd ALARA).
Conclusion Based upon the findings of the appraisal, the licensee procedures were found to be adequate. However, the following item should be considered for program improvement:
Th.e licensee's health physics procedures should be thoroughly reviewed and revised, as appropriate, to provide better quality and technical depth.
9.0 Administration of Emerc~ency Planning
'An-individual at the corporate office in Philadelphia is assigned overall responsibility for administering the Peach Bottom Atomic Power Station Emergency Plan. At the site level there is no clear assig'nment of overall responsibility.
The performance of specific tasks related to the maintenance of a constant state of readiness, i.e., training, equipment maintenance and procedure changes, etc'. is conducted by varicus site personnel. No single individual onsite continuously manages the day-to-day preparedness effort, bringing it together in a coherent manner.
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Based on'the above findings, this portion of the licensees program appeared acceptable, however, the following item should be considered for improvement:
Formal assignment of a member of the station staff to act as an Emergency Planning Coordinator.
10.0 Emergency Organization 10.1 Onsite Organization The appraisers reviewed the licensee's Emergency Plan, dated April 1979, and Emergency Plan Implementing Procedures and held discussions with licensee personnel to evaluate the adequacy of the definition of the onsite emergency organization and the assignment of emergency duties and responsibilities.
This evaluation was preliminary to determining the adequacy of the licensee's Emergency Plan Implementing Procedures and Emergency Plan Training Program.
~
The starting point for the evaluation of the onsite emergency organiza-tion was Section 0.2.3 and Figure 0.2.2 of the Emergancy Plan.
These references established the following 13 emergency duty titles and. outlined the-duties and responsibilities to be performed by the noted persons.
Emergency Director Shift Superintendent Station Superintendent Assistant Superintendent Radiation Survey Team Leader Health Physics qualified individuals Health Physics Engineers Radiation Survey Team Members Health physics and Chemistry qualified individuals Fire.and Damage Team Leader Shift Supervisor Maintenance Engineers Fire and Damage Team Members Personnel qualified in fire fighting procedures and practice-Personnel Safety Team Leader Plant Operators Health Physicist-Personnel Safety Team Members Personnel qualified in health physics and first-aid procedures and practices Security Team Leader Security Sergeant Security Supervisor Assistant Superintendert I
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Secur!ty Team Members Personne1' qualified in plant security features and practices Reentry Team Leader Assistant Superintendent Technical Engineer Reentry Team Members Personnel qualified in radiation survey procedures'and practices and plant operation and layout-Recovery and Restoration Team Station Superintendent Assistant Superintendent Recovery-and Restoration Team Members of plant technical staff, as well, as managerial and maintenance supervisory personnel Next, the appraisers compared.the Emergency Plan description of the onsite emergency organization with Appendices 0-1 through D-7 of EP-35 to verify that the licensee had implemented the assignment of individuals.to the various emergency positions described in the Emegency Plan. This comparison indicated that individuals were assigned to each of the 13 emergency positions des ribed in the Emergency Plan. Although not discussed in the current Emergency Plan, Appendix D-7 to EP-35 listed individuals assigned to positions in the Technical Supp:rt Center Team.
The appraisers next compared the normal duty titles of the individuals listed in Appendices 0-1 through D-7 of EP-35 with the generic descriptions of the individuals who would fill the positions.
This comparison indicated that, under emergency conditions, radiochemistry function would be assigned to the Radiation Survey Team (RST).
Individuals listed in Appendix 0-2 of EP-35 as being RST members were all from the health physics group. None were from the chemistry area.
Discussions with several individuals selected from Appendix 0-2 and with the health physics and chemistry supervisors confirmed that the assigned individuals had little or no chemistry experience and would be unable to perform these functions under emergency-conditions. With regard to the. scope o' duties assigned, the appraisers determined that there was no clear organizational consideration for the continuity of critical radiation prttection functions during emergencies. Discussion with licensee personnel assi'gned to the onse.e eme gency organization indicated trat radiation functions wcoid be handled on an "ad hoc" basis, pro 0 ably under the oversight of.the Radiation Survey Team Leader (RSTL).
The appraisers determined that this approach would overburden the RSTL since he would be split between environmental monitoring and radiation protection functions.
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~54
-The appraisers also noted several minor _ organizational l discrepancies between^the Emergency Plan and Emergency Plan Implementing Procedures:
_(EPs). : Appendix D-5 of EP-35 listed the Assistant Superintendent as 1the Security Team Leader, whereas EP-10 and the Emergency. Plan assigned this responsbility.to the Security Supervisor. The procedural guidance of EP-20 conflicted with the Emergency Plan organization
- description and with the;organizationfchart of EP-10. - The Emegency U
Plan and EP-10.showed the Assistant Superintendent in charge of '
-i
' reentry.
EP-20 stated that reentry will be headed by the Emergency Director and went on to; state that reentry would be performed by the a
Radiation Survey. Team (RST). -.The:latter-statement seems to indicate that, in ' fact, that the RSTL wil1' be in charge of: a reentry.
Based on the findings in the above area, the following improvements are needed to achieve an: acceptable program:
.a.
-Provisions.for. including station' chemistry personnel in the emergency organization'to perform such activities under emergency conditions.
+
b.
Provisions for the organizational assignment of responsibility for continuity of the radiation protection program during x
emergencjes.
c.
Correction of procedural discrepancies in relation to leadershf o of the Security and Reentry Teams.
f
-10.2 Offsite Organization The appraise'rs perforecd a similar review of the licensee's emergency i
planning documents to evaluate the adequacy of the definition of the offsite licensee emergency ~ organization.
Section 0.2.4 and Figure O.2.3 of the-Emergency Plan established the following six emergency
-duty titles with the b' road responsibilities to be performed by the noted persons.
Emergency Control Officer VP, Electric P oduction Manager, Electric Production Site Emergency Coordinator Superintendent, Generation Division - Nuclear Superintendent, Services Division 4
l-Offsite Emergency Coordinator Superintendent, Generation Division - Fossil-Hydro i
Superintendent, Services Division i
Emergency Information Officer Manager, Public Information Assis:: ant Manager, Public Information
j' t
55 Emergency Technical Support Manager,-Engineering and Research'
' Officer Chief Mechanical-Engineer Emergency Security Officer.
.ManagerLof Claims-Security Director;of Security The.above individuals would augument the onsite organization in the
- areas of environs' monitoring, logistical / suppor t, technical support, notification and release of information' to the news media.' The positions described were limited to-the management positions and did
.not address 1the' elements of the offsite emergency organization which
'would perform. tasks under the oversight of.the defined management structure.
- The licensee did not have plans developed for_ supplementing the~ HP staff beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
There were, however, provisions for contractors-to provide technical assistance to the emorgency crganization..The interface between the portion of-the offsite organization which'will
. provide REMP support to the onsite organization was not clear.
In addition, the authority and responsibility limits of the Emergency.
Control Officer in relation to the Emergency Director were.not specified.
Based on the findings in the abovo area, this portion of~the licensee's program appears acceptable, however, the following items should be considered forLimprovement:
a.
Description of the interface between the offsite and onsite groups responsible for the emergency REMP; and, b.
Description of the interface between the Emergency Director and Emergency Control Officer, to include the limits on their respective authority / responsibilities in relation to that '
interface.
11.0 Emergency Plan-Training
.The licensee's program for training individuals assigned emergency duties and responsibilities was outlined in. Section 0.10 of the Emergency Plan.
This description is implemented by Administrative Procedure A-50.
The auditor reviewed training documentation and held discussions with licensee
. personnel to evaluate the adequacy of the program.
The licensee's training program documented in Procedure A-50 was general in its'decription of the scope, nature and content of the training to be provjded.
The program did specify an annual training frequency, but
.provided no details regarding the use of standard lesson plans, the inclusion of members of the licensee's offsite support organization or the assignment of qualified instructors.
~
e-56-
~
m Procedure A-50 specified that:
"Nembersoftheonsiteemergencyorganizationshallreceivetraining by means of the conduction of onsite emergency plan surveillance tests and. drills.- Critiques and refresher training conducted by a staff member of operations supervisor. shall immediately follow the drill or surveillance test.
Staff or operations supervisor judgement with. respect to-the conduction of drills and surveillance tests shall determine the adequacy of and necessity for additional refresher training.
The Training Coordinator shall be responsible for developing lesson plans for orientation training and maintaining a record of session attendance."
The aforementioned portions of_A-50 constituted the entire' description of
.the' training program.
The training group had one lesson plan as part of the Operator Requalifica-tic:. Program. Quizzes were given at the end.
The appraisers reviewed theLlesson plan and several versions of quizzes,- and noted that the lesson plan contained no clearly stated student performance objective and was general in approach.
The lesson was presented via lecture only and the quizzes were 5-7 questions, multiple choice.
The ippraisers determined that the licensee's training program failed to provide adequate assurance
-that attendees would effectively perform their Emergency Plan responsibilities.
Training of various othar team members appeared to be conducted on an "ad hoc" basis by the team leaders or their designees.
Discussion with several team leaders indicated a wide range in the content and method.
In no case were tests given.
Certain members of the emergency organization did not appear to be included in the training program.
The appraisers reviewed training records and was unab'le to verify that the scope and content of the training was in line with the emergency duties which individuals would perform.
Documentation appeared fragmented.
Discussions with individuals in the Training Department indicated that the Training Department only administered that portion of the Emergency Plan Training falling under the Operator Requalification Program. The, so called, Specialist Team Training was to be performed by the team leaders.
Based on the findings in the above area, the following improvements are needed to achieve an acceptable program:
Development of lesson plans containing clearly stated student perform-ance objectives and a means to verify performance against the objectives for each emergency job function of the onsite, offsite and local services support organizations.
-57 Development of provisions for assigning qualified instructors.
Development of a means~ to document training performed which is consistent and adequate to substantiate that training completed was
.in accordance with.the-training procedure.
12.0 Emergency Facilities and Equipment 12.1 Emergency Kits and Emergency Survey Instrumentation The licensee had pre positioned emergency supplies and survey instra-mentation at specified locations. The equipment.and their locations were described in Procedures ST/EP. 3C, Emergency Equipment Inventory and Operational Check.
The auditors conducted a sampling. inventory and verified that equipment was in place and operational.
'Within the range of ' emergency equipment, the licensee had provisions for extremity monitoring using ring TLDs and for the detection and measurement of radiation fields up to 1000 R/hr.
There was a capability
-8 to detect and measure radioiodine concentrations in air of 5 x 10 uCi/cc. There was an onsite capability for filling self-contained breathing devices using a 7-bottle air cascade. system.
This system 3
3 provides'2,100 ft of breathing air with 5,400 ft additional in reserve.
ST/EPs 3A, 3B and 3C contained provisions for routine inventories, calibratior.s and operational checks of emergency equipment. A review of the most recent records of these activities indicated that the licensee's equipment was in a state of readiness.
Based on the findings in the above area, this portion of the licensee's program appeared acceptable.
12.2 Area and Process Radiation Monitors The appraisers inspected the area and process radiation monitor readouts in the control room and noted that all monitors required to assess accident consequences were available and operable.
Based on the findings in the above area, this portion of the licensee's program appeared acceptable.
12.3 Meteorological Instrumentation The appraisers reviewed the operability of the licensee's meteorological instrumentation and noted that all data needed to assess the radiological consequences of an accident were available and that associated instrumentation was in-service.
~
. Based on the findings in the above area, this portian of the licensee's program appeared acceptable.
1
.2
-58 12.4 Emergency Operation Centers (EOCs)
The licensee had provisions' for principal and_ alternate EOCs from
~
which direction, evaluation and coordination of all licensee onsite emergency activities would be performed.
The appraisers noted that two of the centers (the North Substation and Delta Service Building) appeared to have. insufficient space to accommodate the numbers of people who would be present in response to a serious emergency.
In addition, the appraisers determined.that communications available at the EOCs would be inadequate to support a serious emergency. With~
regard to the availability of equipment and supplies available in the EOCs-to support EOC operations, the appraisers noted several short-comings.
There were no provisions for low-and high-range beta / gamma survey meters, air sampling and counting or personnel dosimetry devices for'EOC personnel. The appraisers noted that the licensee was developing plans for upgrading the E0Cs in conjunction with implementation of a revised Emergency Plan.
Based on the findings in the above area, this portion of the licensee's
~
program appears accepta'cle and in accordance with the existing Emergency Plan, however, the following items should be considered for-improvement:
a.
Increase in tae numbers and types of communication devices / nets available in the EOCs.
b.
Provisions for monitoring the radiological conditions in the EOCs by having high-and low-range beta / gamma survey and air sampling and counting capabilities.
12.5 Medical Treatment Facilities The licensee has provisions for the treatment of individuals who may tue contaminated and injured. A treatment facility is located at the 135-foot elevation of the radwaste building.
The appraisers noted that the treatment room was Kept locked.
Keys were in the control room.
The facility was accessible to a stretcher being carried by two individuals and was equipped with a full-range of first-aid, medical and decontamination supplies and equipment.
There was an operable, calibrated contamination survey instrument located therein and communications were available in the form of a telephone and plant page.
Procedures for decontamination and first-aid were also 1
available in the facility.
Based on the above findings, the licensee's program appeared acceptable.
12.6 Decontamination-Facilities
'. addition to the special decontamination provisions for injured persons, the licensee also maintains a personnel decontamination area which is used routinely. This a sole-use area with dedicated sFowers, basins and contamination survey meters.
59 The licensee's provisions for decontaminat'ing personnel at assembly /
reassembly areas subsequent to an evacuation of the facility or site were weak.
Evacuees would assemble at the EOCs (220 kV Substation,
~,.
PUB or Delta Service Building). 'Other than the availability of water, no other provision had been made at these locations.
Based on the findings in the above area,. this portion of the licensee's program appears acceptable, however, the following item shpuld be considered for improvement:
a.
. Decontamination provisions at assembly / reassembly points for individuals or vehicles and equipment which may be evacuated from the site.
12.7 Protective ~ Facilities and Equipment
.The licensee's evacuation assembly areas were designated as the three EOCs. The' availability of three areas provides flexibility for relocating evacuees in an area not threatened by a radioactive release. The appraisers noted, however, that the assembly areas were inadequate to accommodate the sheltering of the number of persons expected to be present. The nonavailability of sheltering would restrict the licensee's protective action options and,.in inclement weather, could result in evacuees interfering with EOC activities. As discussed in Paragraph 10.6 above, provisions for monitoring / decontaminating evacuees who may be contaminated were minimal at the assembly areas.
There appeared to be adequate consideration of protective clothing and equipment for emergency workers who would be in or reenter the facility.
Charcoal adsorber cartridges for respirators were stored in a warehouse and stocks of protective clothing were available in plant and at the EOCs.
' Based on the findings in the above area, this portion of the licensee's program appears adequate, however, the following item should be considered for improvement:
a.
Provisions for sheltering and decontaminating evacuees at assembly areas.
12.8 Reserve Emergency Supplies and Equipment In response to serious emergencies resulting in the n'eed for equipment and supply resources beyond the stocks in emergency kits, the licensee intends to rely upon the normal inventory of survey instruments, dosimetry and protective clothing, etc.
The appraisers held discussions with licensee personnel and determined that a policy of emergency stock level mr.intenance was pursued.
60
.lDiscussion and' evaluation of the adequacy of the stockage of instru-mentation and' supplies to support the routine radiation protection program is discussed elsewhere in this report.
Based'on the findings in the above area, this portion of the licensee's-program appears acceptable.
12.9 Exganded Support Facilities The appraisers held discussions with licensee personnel in relation to the availability of designated work facilities-and equipment-resources available for the expected increase of health physics personnel under accident conditions. 'This discussion indicated that, presently, such_ provisions had not been made.
Based on the findings in the above area should be considered for improvements.
a.
-Provisions for accommodating the influx of health physics support personnel in response to a serious emergency.
13.0 Emergency Plan Implementing Procedures 13.1 General The appraisers ~ performed reviews of the licensee's procedures which implement and interface with the Emergency Plan.
The purpose of these reviews was to determine the adequacy of the various procedures in relation to their use in detecting and assessing actual or potential emergencies and implementing protective or corrective measures.
13.2 Procedures for Emergency, Abnormal and Alarm Conditions The appraisers reviewed a sampling of the licensee's emergency, abnormal and alarm response procedures to determine whether they were clearly interfaced with the Emergency Plan to permit timely detection of and response to actual or potential emergency conditions by the operations staff.
The appraisers noted that there was an interface with the Emergency Plan Implementing Procedures in the form of an instructional step to consider implementation of the Emergency Plan as a followup action.
Based on the findings in the above area, this portion of the licensee's program appeared acceptable.
i 13.3 Implementing Instructions Five procedures (EPs 45, 46, 47, 48 and 49) developed by the licensee were intended to specify what and when various pre planned actions 1
are to be taken in response to four graded clas_ses of emergencies.
r 61 The r.mergency classes covered by these procedures were designated as Class I Emergency.(EP-45), Class II Emergency (EP-46), Class III Ewergency - Plant or. Site Radiation Emergency (EP-47),- Class.IV Er.ergency - Excessive Gaseous Relaase (EP-48) and Class V_ Emergency -
Fxcessive Liquid. Release (EP-49).
These procedures serve to orchestrate the implementation of other, more specific procedures which. describe how specific response actions are to be performed. -The-ap' praisers' evaluation of the five Implemen-ting Instructior.3, however,. indicated tcat their form and content were such.that.their utility was less than optimal.
The.first' observation which contributed to the less than optimum use related to the physical location of the five Implementing Instructions.
- The licensee had 32 procedures specifically written to implement the Emergency: Plan. During an emergency, the five Implementing Instructions-(EPs-45, 46, 47, 48 and 49) would chronologically be the first to.be
- implemented, yet they were positioned at the end of the procedure book and were not tabbed for ease of use.
In addition to the cumbersome physical arrangement, there were
.several shortcomings in the form and content of the five Implementing Instructions.- First and foremost among these shortcomings was the failure of the procedures to contain emergency action levels (EALs)
. and protective action guides (PAGs) based on readily available information clearly specified for each class of emergency. Of the five procedures, only.one (EP-47) contained action levels of any clarity.
Even these, however, were not clearly presented as EALs for the declaration of the particular class of emergency, but rather were presented more in the form of protective action guides for
- plant or site evacuation.
The procedures were not written from the overall perspective of the Emergency Director but instead included a mix of normal dt.y titles and emergency organization titles and instructions for various team leaders.
The procedures failed to provide guidelines for areas in which the user would be permitted to exercise judgement in the implementation of specific actions, in the interpretation of EALs or the application of protective action guides or the making of recommen-dations relating thereto.
The Implementing Instructions did contain references to other specific applicable procedures.
Generally, these references appeared in the body of the procedures at the point where implementat' ion of another function or procedure is to be performed.
Based on the findings in the above area, this portion of the licensee's program appears acceptable, however, the following items should be considered for improvement:
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Rearrangement of procedure chronology, placing implementing-instructions first and tabbing them for ready access; b.
Development and inclusion of clearly defined EALs in the implemen-ting instruction for each class of emergency;
-c.
Revision of procedures to reflect their use by-the Emergency Director to orchestrate the implementation of other more specific procedures; d.
Provision of guidance to the Emergency Director in theLapplication of judgement in the-implementation of specific actions, in the interpretation of EALs or the ' application of protective action guides or the making of recommendations relating thereto, and; e.
Consistency in the use of emergency duties. titles in specifying who is to perform certain actions rather than~ mixing normal
. duty titles with emergency duty titles.
13.4' Implementing Procedures 13.4.1 Notifications The licensee's provisions for notifying personnel that an emergency exists at the Peach Bottom' site were contained in EPs-45, 46, 47, 48, 49, 6, 22 and 35.
Notifications were, however, determined to be inadequate in timing and method.
For Class I Emergencies, EP-45, important notifications were incorporated into the "Immediate Action Steps" of the procedure.
The action levels for performing certain of these notifications were, however, unclear and based on individual judgement without benefit of guidance.
For example, the procedure stated, " call for offsite medical support if deemed necessary or advisable." The methods for performing the various notifications were not specified or referenced and the procedure appeared to presuppose that the Station Superintendent would be onsite.
For Class II Emergencies, EP-46 exhibited similar shortcomings yet were more numerous due to the more extensive activation of the emergency organization.
This procedure too appeared to presuppose that the Station Superintendent would be readily available since the responsibility for notifying Emergency Team Leaders and the corporate office was assigned to the Station Superintendent specifically. Since the procedure specifies a normal duty title which is unique to a single person (Station Superintendent) rather than a generic emergency duty title (such as. Emergency Director) this could result in delayed notification.
Regarding the 4
7 3-t 63 action levels.for making notifications, Procedure EP-46
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' stated that the Technical Engineer should be notified to activate the Technical Support Center for a Class IIB emergency. The appraisers noted, however, that a Class.
IIB emergency.was not defined anywhere in the Emergency Plan or procedures.
'For Class ~ III Emergencies, important notifications are again~ precipitated on the notification of the Station Superintendent..Important notifications to the PEMA and NRC are made by the Superintendent, Generation Division -
Nuclear-or Superintendent, Serviciss' Division after their having been notified by the-Station Superintendent.
For the most serious classiof emergencies,. Class IV, the
. licensee's notification system has.a built-in 20 minute delay resulting from the setup of a conference call between-senior managers.
The appraisers concluded that the licensee's overall notification scheme was cumbersome and vulnerable to breakdown due to the over-reliance on a preliminary contact with the. Station Superintendent, the lack of clarity in relation to notificatinn action levels and lack of backups at key points in the notification chain.
This vulnerability would be particularly acute during periods of minimal staffing such as backshifts, weekends and holidays.
Based on the-findings in the above area, the following improvements are needed to achieve an acceptable program:
a.
Incorporation of important notifications into "Immediate Action Steps" of each implementing instructions.
b.
Specification of action levels for notification of the site emergency organization, offsite emergency organization, contractors, local services support groups and local, state and Federl agencies.
c.
Development of pre planned messages a 1 announcements for initial notifications, d.
Elimination of the conference call prior to the initiation of notifications to PEMA an'd the NRC.
e.
Provisions for initiating notifications without first requiring notification of the Station Superintendent.
64.
13.4.2-
-Assessment Actions-13.4.2.1 General The' appraisers reviewed the licensee's' provisions for assessing the actual and potential consequences-of emergencies. The purpose of-this review was-to evaluate the adequacy of'the' system for.
gathering information and data upon which to base dec"stons to escalate, de-escalate, take.
- corrective actions or recommend or implement protective actions onsite and offsite. The review considered the licensee's integration of all available sources of information relating ~to actual or potential radiological conditions in plant or in the environs.
13.4.2.2 In-Plant Radiological Surveys-Within the range of Emergency Plan Implementing Procedures, the licensee had made no detailed provisions governing the conduct of in plant radiclogical surveys during emerger,cies.
The Implementing Instructions did, however, instruct the Shift Supervisor to initiate surveys of this type.
Based on the above findings, the following improvement is needed to achieve an acceptable program:
Development of a procedural description of the method and equipment to be used to perform emergency in plant radio-logical surveys.
13.4.2.3 Onsite and Offsite Radiological Surveys r
The appraisers reviewed the licensee's provisions l
for performi g environmental radiological surveys in the event of an emergency.
The auditors l
determined that these provisions were fragmented and not procedurally cohesive.
Within the range of EPs, there were no procedures governing the command and control or step-by-step activities for the conduct of onsite and offsite radiological surveys. Within the range of health physics procedures, however, there were procedures which described _how onsite and offsite
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' surveys should be performed (HP0/C0-66) and how various. pieces of equipment (HP0/CO-60 through
- 67) are to be operated. The data sheets.for the survey operations were.not, however, associated
.with the HPC/COs, but were.rather an attachment
-to.EP-48.
The collective group of HP0/C0 procedures and
.the EP-48 data sheets-did not address or consider a number of. aspects.
The: data sheets did not providi a means to record the:
date and time of each survey; the names of the individuals making the survey; the instrument used (by type and-serial. number); mode of instrument operation; or raw air sample count data upon which calculations were based. There were no pre planned survey points or routes specified in the procedures and minimum sample labeling requirements were not detailed.
The procedures also failed to specify the primary and backup means of communications to be used by the teams.
Based on the findings in the above area, this portion of the licensee's program appears acceptable, however, the'following item shoul,d be considered for improvement:
Development of procedures governing the conduct of onsite and offsite monitoring which consolidate the various HP0/COs and EPs into
?. cohesive scheme.
13.4.2.4 Initial Assessment of Offsite Consequences Implementing Instruct ons EPs-48 and 49 described the licensee's provisions for assessing offsite radiological hazards resulting from excessive gaseous or liquid releases.
These procedures identified the sources of information (area and process radiation monitors and meteorological instruments) to be used to perform the initial assessment actions.
There were provisions for estimating gaseous release rates if the normal range monitors should be offscale'.
-The appraisers noted that the gaseous release procedure (EP-48) did not provide for the projection of thyroid exposure.
The projection procedure only addressed whole body exposures due to noble gases.
In addition, there were no provisions for comparing the results of calculations with
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for the ' purpose of considering the need for.
-protectiva action reccmmenda*,fon.
In this regard, there were no-provisions for immediate notification to state and local agencies in the event ^1nitial assessment actions indicated an actual or: potential exposure to the whole. body or thyroid in excess of the lower limits of the PAGs.
Based on the' findings in the above: area, the following improvements are needed to achieve an acceptable program:
a.
~ Action levels and protective action guides which will be used by assessment personnel as a basis for considering or initiating emergency maasures to terminate, or mitigate
'the actuai~or projected consequences determined from the assessment process.
b.
The means for initially projecting exposures to the thyroids of offsite individuals.
c.
Provisions for immediate notification of state and local agencies in the event that initial assessment actions indicated an actual or potential exposure to the whole body or thyroid in excess of protective action guides.
d.
Provisions for trend analysis of assessment data.
s 13.4.2.5 Radiological Environmental Monitoring Program (REMP)
Initially, the licensee's emergency REMP consists of radiation and air surveys performed by survey teams under the direction of the RSTL.
Subsequently, in accordance with EP-23, the licensee will
-recover samples from fixed air monitoring stations and environmental TLDs. There were also provisions for surface water, vegetation and milk sampling.
The responsibility for administering the emregency REMP is assigned to the Engineering and Research Department.
The responsibilities are stated in a general manner. These responsibilities are the arranging for recovery of and expeditious analysis of samples and coo.rdinating the recovery /
analysis and data acquisition.
Further definition
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.concerning_ hew and by whom these responsibilities will be performed was not specified.
Based on the findings in the above area, this portion of the' licensee's. program appears acceptable ~,
however, the following item should be considered for improvement:
Specification of the methods and personnel for recovery, analysis, and interpretation of REMP data anu subsequent dissemination of results.
13.4.2.6 Personnel Monitoring and Decentamination.
Procedure EP-24 described provisions for monitoring and decontaminating vehicles. There was no equivalent procedure covering personnel monitoring and decontamination.
EP-17, Procedure for-Assembly Areas contained two brief steps which highlighted the need for contamination monitoring and exposure evaluation but provided~no substantiva guidance. There was reference to decontamination procedures. As discussed in Paragraph 10.6, decontamination supplies at assembly areas were determined to be inadequate, causing the auditors to conclude that the licensee would have difficulty implementing the general requirement for decontam-ination.of evacuees under emergency conditions.
There were, however, provisions for recording the results of personnel contamination surveys.
Based on the findings in the above area, the following improve-ments are needed to achieve an acceptable program:
a.
Specification of contamination levels that require decontamination to include reference to decontamination procedures for various levels and types of contamination including skin contamination with radioiodine.
b.
Specification of personnel contamination i
action levels which will req'uire further assessment to include designation of the element of the emergency organization responsible for performing the followup assessment.
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4 c.
. Description of the means.for providing collected personnel. contamination /monitorirg data and information to'the individual or organizational element responsible for the radiation protection program during emergencies.
-13.4.2.7 Evacuation of Onsite Areas The appraisers reviewed the licensee's procedural provisions for evacuating specified areas, buildings and the site.
There were clearly defined action : levels, assembly / reassembly areas and provisions for warning individuals onsite and providing clear iristruct, ions regarding their actions in the event of an emregency.
Based on the findings in the above area, this portion of. tha licensee's progr6m appears acceptable, however, the following item should be considered for improvement:
Marking of primary and secondary evacuation routes with conspicuously posted arrows, signs, floor markings or other readily visible means.
13.4.2.8 Personnel Accountability Accountability procedures specified when accounta-bility is to be performed and to w' ' acccuntability reports are made.
There was a mear.
.o ascertain the whereabouts of individuals repe.ed as missing by canvassing supervisors and dispatching of a search and rescue team.
Based on the findings in the above area, this portion'of the licensee's program appears acceptable.
13.4.2.9 Onsite First Aid / Rescue EPs-19 and 31, 32 and 33 described provisions for locating, recovering, transporting and l
treating injured persons who may also be contaminated.
The action levels and interface for using the offsite medical treatment facility, local physicians and ambulance were specified.
The procedures referenced interfacing health physics procedures for personnel decontamination and all four of I
~ the EPs interfaced well.
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69 Based on-the findings in the above area, this portion of.the licensee's program appears acceptable.
13.4.2.10 Radiation Protection During Emergencies The licensee, did not.have procedures which reflect such radiation protection topics as personnel dosimetry,_ exposure records, access controls, dose assessments and the means for limiting or preventing exposure of-individuals under emergency. conditions.
Certain:of.these aspects were at least partially covered in the various EPs relating to team activities. There was not, however, a clear.means to insure'some degree of continuity to the radiation protection program during emergencies.
This finding related in part to the licensee's-inadequate provisions
'for in plant surveys discussed.in Paragraph i
11.4.2.2 of this report. The auditors noted' that the various routine health physics procedures.
covering the aforelisted topics did not reflect
,their. applicability.during emergencies.
Based on the findings in the above area,.the following improvements are needed to. achieve an acceptable program:
Development of a radiation protection program for use during emergencies which address the following areas:
a.
Personnel dosimetry (availability, use and processing);
b.
Exposure records; c.
Positive access controls; d.
Instructions to emergency workers (licensee as well as contractor or.
other persons / agencies augmenting the onsite emergency organization) regarding i
radiological conditions; e.
Dose assessment of exposed / contaminated persons; f.
Provisions for preventing re-exposure of individuals or limiting further l
exposure; r.
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Special controls to be implemented for emergency conditions; and-h.
Plans for expan' ding the respiratory
. protection ~ program in the event of an accident, e.g., expanded supply of respirators, provisions-for expanded decontamination facilities, provisions for promptly' refilling air bottles; etc.
13.4.2.11 Recovery EP-20,. Reentry and Recovery Following?an Emergency Evacuation, was reviewea for adequacy., The
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' procedure'specified the organizational authority for declaring that a recovery mode is to be entered.
There were provisions for evaluating the in plant and out-of plant radiological conditions as a basis for declaring an end to the emergency and the start of' recovery, but there were no_ provisions for evaluating the actual or potential operating conditions of the plant.
In addition, there were no provisions for notifying the various participating individuals and agencies before assuming a recovery mode of operation.
Based on the findings in the above area, this portion of the'liceisee's program appears acceptable, however, the following items should be considereed for improvement:
a.
Specification of provisions for an evaluation of plant operating conditions as well as the in plant and out-of plant radiological conditions in any decision to enter recovery.
b.
Provisions for notification to various individuals and agencies that must be completed before a recovery mode may be assumed.
13.4.3 Repair / Corrective Actions The licensee did not have procedural provisions governing
.the concept of operations to be followed by repair / corrective action teams during emergency situations (e.g., valve manipulations, rad-waste operations, etc.).
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71 Based on' the findings. in the above area, the following improvement is needed to achieve an acceptable program:
~ Development of a procedure to describe the concept of-the operations for repair or corrective action activities
,to include specification of'the individuals to whom the team will report, the steps to assure that the team is composed of individuals with proper skills, and that individuals are properly briefed as to the radiological. conditions, stay times, etc.~ prior to the conduct of any-repair or corrective action operation.
13.5 Supplementary procedures The appraisers. conducted a review of procedures related to maintaining a constant state of readiness.
13.5~1 Inventory, Operational Check and Calibration of Emergency Equiement and Facilities Surveillance Test / Emergency Plan (ST/EP) Procedures 1, 3A, 38 and 3C described the licensee's provisions for maintaining-emergency supplies,-equipment and facilities in a constant state of readiness.
The procedures provided an inventory listing of equipment and specified the interval at which inspections are to be performed.
The responsibility for performing the readiness checks was delineate; but the followup mechanism for correcting noted deficiencies was weak with the exception of deficiencies correctable by issuing a maintenance request.
Based on the findings in the above area, this portion of the licensee's program appears acceptable, however, the following item should be considered for improvement.
Development.of a method for correcting and tracking noted inventory / readiness check deficiencies.
13.5.2 Drills and Exercises ST/EPs 4. 5, 7, 8 and 39 described the licensee's provisions for conducting drill to evaluate and test the timing and l
content of procedures and evaluate the adequacy of facilities and equipment.
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-The procedures provi.de for the preparation of a' scenario' and for~use of observers only during conduct of the annual-
- Class IV Emergency Exercise.
In general, the ST/EPs governing the conduct of drills. listed a chronology ~of-actions to be performed by the various participants and-did not' fully describe the administrative guide-lines to..
.be followed in developing a scenario, selecting observer, critiquing ~results and implementing corrective actions.
These shortcomings were most significant in relation to ST/EP 2, Plant Radiation Emergency Drill-(Evacuation Drill); ST/EP 4, Emergency Health Physics and Medical Drill; and ST/EP 5, Fire Drill.
Shift Supervision is responsible for initiating the drills and in all but one instance (ST/EP 2), there were no provisions for following corrective actions for drill identified problems.
. Based on the findings in the above area, the following items should be considered for improvement:
a.
Administration of drills and exercises by an Emergency Planning Coordinator.
b.
Provisions to conduct each drill or exercise in accordance with a scenario' developed in advance of the. drill.
c.
Documentation and evaluation of all observer and participant comments as part of each drill or exercise; d.
Management controls to assign responsibility for t
corrective actions and assignment cf completion dates to assure that assigned corrective actions are completed in accordance with an established schedule and are adequate to resolve the noted deficiency for each type of drill or exercise; i
e.
Provisions for backshift drills and exercises.
14.0 Exit Interview The Appraisal Team met with the licensee representatives identified under
" Persons' Contacted" (See page 5 of this repert) at the conclusion of the HP Appraisal on June 27, and July 11, 1980 to discuss the appraisal findings.
The Appraisal Team summarized the major appraisal findings.
The licensee was informed that they would be expected to respond, in writing, to the significant findings listed in Appendix A to the letter forwarding the appraisal report. The licensee was informed that any
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items of noncompliance would be handled as in past Region I inspection,s.
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'The Appraisa' Team also discussed :averal weaknesses that were not included l
.as Appendix A. items, but should be considered for improvement of the radiation protection program.
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