ML20004D153
| ML20004D153 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/28/1980 |
| From: | Hadlock D, Murray B, Ryan R, Galen Smith, Terc N, Wadman W Battelle Memorial Institute, PACIFIC NORTHWEST NATION, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20004D142 | List: |
| References | |
| 50-245-80-12, 50-366-80-11, NUDOCS 8106080478 | |
| Download: ML20004D153 (84) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT O
REGION I Health Physics Appraisal Report Nos. 50-245/80-12 50-336/80-11 License No. OPR-21 DPR-65 Category:
C Licensee:
Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101 Facility: Millstone Nuclear Power Station (MNPS) Units 1 and 2 Appraisal at:
Waterford, Connecticut Appraisal Conducted:
August 11-22, 1980 Team Members:
//[JN[hd Blaine Murray, Teap/ Leader, NRC D' ate l
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N.M.Terc,RadiationSpecialist,NRC/
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D. E. Hadlock, Research Scientist, D&te d/l Battelle Laboratories
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//ht/go W. W. Wadman, Consu % nt,
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R.~M.Ryan,ConsultantpattelleLaboratories Cate '
Approved By:
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G. H. / Smith, Chief, Fuel facility and Datte Mathrials Safety Branch
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2 TABLE OF CONTENTS Introduction Persons Contacted
- 1. 0 Radiation Protection Organization 1.1 Description
- 1. 2 Responsibilities
- 1. 3 Staffing
- 1. 4 Management Oversight 1.5 Conclusions 2.0 Personnel Selection, Qualifications, and Training 3.0 Exposure Control 3.1 External Exposure Control 3.1.1 Dosimetry Program 3.1.2 Quality Assurance / Quality Control 3.1. 3 Records and Reports 3.1. 4 Exposure Review and Limitations 3.1.5 Conclusions 3.2 Internal Exposure Control 3.2.1 Dosimetry Program 3.2.2 Respiratory Protection 3.2.3 Conclusions 3.3 Surveys and Access Control 3.3.1 Program 3.3.2 Conclusions 4.0 Radioactive Waste Management 4.1 Unit 1 4.2 Unit 2 4.3 Effluent Release Control 4.4 Effluent Monitoring 4.5 Solid Waste 4.6 Conclusions 5.0 Radiation Protection Instrumentation j
6.0 Facilities and Equipment 7.0 ALARA
3 8.0 Audits 9.0 Radiation Protection Procedures 10.0 Administration of Emergency Plan 11.0 Emergency Organization 11.1 Onsite Organization 11.2 Angmentation of Onsite Organization 12.0 Emergency Training / Retaining,
13.0 Emergency Facilities and Equipment 13.1 Emergency Kits and Emergency Survey Instrumentation 13.2 Fixed Facilities and Instrumentation for Radiological Accident Assessment 13.2.1 Area and Process Monitors 13.2.2 Meteorological Instrumentation 13.3 Emergency Communication Equipment 13.4 Emergency Operation Center (5) 13.5 Medical Treatment Facilities 13.6 Decontamination Facilities 13.7 Protective Facilities and Equipment 13.8 Damage Control, Corrective Action and/or Maintenance Equipment and Supplier 13.9 Reserve Emergency Supplies and Equipment 13.10 Expanded Support Facilities 14.0 Emergency Implementing Procedures 14.1 General Content and Format 14.2 Emergency Operating Procedures 14.3 Implementing Instructions l
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4 14.4 Implementing Procedures 14.4.1 Notification 14.4.2 Offsite Radiological Surveys 14.4.3 Onsite (Out-of-Plant) Radiological Surveys 14.4.4 Inplant Radiological Surveys 14.4.5 Personnel Monitoring and Decontamination 14.4.6 Evacuation of Onsite Areas 14.4.7 Personnel Accountability 14.4.8 Assessment Actions 14.4.9 Radiological Environmental Monitoring Program 14.4.10 Onsite First-Aid / Record 14.4.11 Security During Emergencies 14.4.12 Radiation Protection During Emergencies 14.4.13 Recovery 14.4.14 Repair / Corrective Actions 14.5 Supplementary Procedures -
Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies 15.0 Exit Interview
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5 INTRODUCTION The purpose of this special appraisal was to perform a comprehensive evalua-tion of the licensee's radiation protection program.
This appraisal included an evaluation of the adequacy and effectiveness of areas for which explicit regulatory requirements may not currently exist.
The appraisal effort was directed towards evaluating ^the licensee's capability and performance rather than the identifica-tion 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 included 390 onsite hours by five appraisers.
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6 Persons Contacted Northeast Utilities Service Company (NUSCO)
- W. Fee, Executive Vice President, Engineering and Operations
- J. P. Cagnetta, Assistant Vice President, Nuclear and Environmental Engineering
- C. F. Sears, Director, Nuclear Engineering
- R. C. Rodgers, Chief, Radiological Assessment Branch
- J. F. Opeka, System Superintendent - Nuclear Operations D. R. Stands, Radiological Assessment Branch A. S. Klotz, Radiological Assessment Branch Northeast Nuclear Energy Company (NNECO)
E. J. Mroczka, Station Superintendent
- E. C. Farrell, Station Services Superintendent
- A. G. Cheatham, Radiological Services Supervisor W. Romberg, Operations Supervisor (Unit 1)
J. Heg, Assistant Operations Supervisor (Unit 2)
V. Papadopoli, Quality Assurance Supervisor F. Teeple, Instrument and Control Supervisor (Unit 1)
H. Haynes, Instrument and Control Supervisor (Unit 2)
- E. R. Spruill, Health Physics Supervisor J. Kangley, Chemistry Supervisor
- J. E. Lane, Health Physicist E. Brezinski, ALARA Coordinator (Unit 1)
D. Fitts, ALARA Coordinator (Unit 2)
R. Lent, Radiation Protection Supervisor (Unit 1)
F. Whitaker, Radiation Protection Supervisor (Unit 2)
M. Brennan, Health Physics Foreman, (Unit 1)
J. Funk, Health Physics Foreman (Unit 2)
D. Wilkers, Instrument and Control Supervisor D. Clark, Shift Supervisor R. Walker, Shift Supervisor J. Bangasser, Security Coordinator J. Robertson, Chemist The Appraisal Team also interviewed several other licensee and contractor technicians.
- Denotes those individuals present at the exit interview.
7
- 1. 0 Radiation Protection Organization 1.1 Description Documents Review Procedure ACP-0A-1.01, " Millstone Administration, Revision 2, 1/30/80 Appendix A Technical Specifications, Section 6.
The licensee's organization of the Radiation Protection Department is shown in Figure No. 1.
This arrangement reflects the organization as it existed during this appraisal. Within the organization, the Health Physics Supervisor was designated as the Radiation Protection Manager (RPM).
The Appraisal Team notea that the licensee's organi-zation did not satisfy the recommendations of Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As is Reasonably Achievable,"
in that, the RPM did not report directly to station management.
c gulatory Guide 8.8 recommends that the individual responsible for e
radiation protection activities be independent of station divisions.
The RPM should have direct recourse to responsible management per-sonnel in order to resolve questions related to the conduct of the radiation protection program.
As Figure No. 1 indicates, the RPM reported through the Radiological Services Supervisor and Station Services Superintendent.
The Station Services Superintendent in turn reported directly to the Station Superintendent.
Even tnough the RPM did not report directly to the Station Superintendent, the RPM stated he had access to the Station Superintendent to discuss radiological matters.
(See Section 1.4.2 of this report).
It was noted that both the Radiological Services Supervisor and the Health Physics Supervisor satisfied Regulatory Guide 1.8, " Personnel Selection and Training," requirements for the RPM.
1.2 Responsibilities Documents Reviewed Procedure ACP-0A-1.02 " Organization and Responsibilities," Revision 10, 1/30/80 Procedure ACP-0A-1.03, " Assumption of Responsibilities by Key Personnel," Revision 3, 1/30/80 Job Descriptions for the following positions:
Station Services Superintendent Chief, Radiological Assessment Branch
8 Radiological Services Supervisor Health Physics Supervisor Radiation Protection Supervisor Health Physicist ALARA Coordinator Health Physics Foreman Health Physics Technicians A, B, and C Assistant Health Physics Technician Chemistry Supervisor Chemist Chemistry Foreman Chemistry Technician Assistant Chemistry Technician Radiation Records Clerk Station Nurse Procedure ACP 6.02, " Maintenance of Occupational Radiation Exposures As Low As Is Reasonably Achievable," Revision 6, June 16, 1980 The licensee had developed adequate job descriptions for the various positions within the RPD.
The job descriptions covered such items as job summary, reporting chain, primary duties, respcasibilities, and training and experience requiremants.
In general, the licens'ee's personnel were familiar with the requirements in their job descrip-tions even though some technicians stated that they did not have a copy of their position description.
Procedures had not been developed that outlined the responsibilities and authorities assigned to the RPD.
Administrative Control Procedures (ACP) and Health Physics Procedures (4900 and 900/2900 series) con-tained instructions and guidance for specific task related activities, but the procedures did not contain policy statements regarding respon-sibilities and authorities for the RPD.
The appraisers discussed stop work authority and the enforcement of health physics procedures with various members of the PTD.
Representatives from the RPD stated that oral instructions had been given which stated that members
9 of the RPD have the authority to terminate any job they considered unsafe.
Each of tne technicians interviewed stated that they would not be hesitant to stop a job they considered unsafe even though they did not know if such authority existed in written procedures.
The appraisers noted that Procedure ACP-6.02 stated that the health physics staff had stop work authority when radiological condition or job practices were unsafe.
- 1. 3 Staffing The number of health physics personnel onsite during the appraisal appeared sufficient to provide adequate coverage at both the super-vision and technician level.
Staffing for health physics field activities included about 30 licensee and 50 contractor personnel.
In addition, about 15 persons were assigned as specialists in dosi-metry, respiratory protection, sample analyses, and as administrative and clerical help to support the radiation protection program.
Comments provided by personnel within the RPD and other departments, such as, operations and maintenance indicated that adequate health physics personnel were usually available to provide proper health physics coverage for routine, backshift and outage conditions.
Health physics technicians were assigned to provide backshift coverage both during outages and routine conditi.ons.
The number of contractor health physics personnel onsite at any particular time fluctuated depending on activities in progress.
A large number of health physics contractor personnel were c u ite during this appraisal to provide coverage during the Unit 2 scheduled refueling outage.
1.4 Management Oversight 1.4.1 Management Adequacy The planning, organization, and direction provided by the RPD super-vision appeared adequate.
The RPD technicians worked an average of about 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> of overtime per year per individual.
The Appraisal Team noted that respons.ble RPD positions were normally filled with licensee per-sonnel.
Contractor technicians reported through a designated licensee individual.
Excessive turnover of RPD personnel did not appear to be a chronic problem.
The annual turnover rate was usually less than 10 percent.
Frequently, individuals that left the RPD were either promoted or transferred to another department.
The RPD technicians did not belong to a bargaining unit.
The RPD supervision stated that, in their opinion, the absence of a bargaining unit contributed to a more effective department due to the time and effort supervision was not required to devote to processing allega-tions and other union related matters.
10 The Appraisal Team observed that the majority of the RPD staff dis-played a positive attitude toward their work and accomplished their assigned responsibilities in a professional manner.
1.4.2 Onsite Support The RPD received the support of plant management.
The Station Superintendent maintained an "open door" policy.
This policy pro-vided a readily accessible avenue for the RPD to discuss health physics matters and to resolve problem areas.
The Appraisal Team noted that good working relationships existed between the RPD and other departments.
As mentioned in Section 1.1, the RPD reported through the Station Services Superintendent to the Station Superin-tendent.
The Station Services Superintendent stated that about 30 percent of his time was devoted to RPD matters.
1.4.3 Corporate Support Documents reviewed Licensee Manual, " Corporate Management Program For Maintaining Occupational Radiation Exposure As how As Reasonably Achievable."
Jurisdiction Statement For P.adiological Assessment Branch.
The onsite RPD received strong support from the corporate level Radiological Assessment Branch (RAB).
This branch was well organized and consisted of about 30 members which provided technical and special projects support to the onsite RPD.
It was noted that several current members of the RAB staff had extensive previous full time experience in the onsite RPD.
A licensee representative stated that, as much as possible, RAB vacancies are filled with individuals from the onsite RPD.
The RAB had lead responsibility for the design and implementation in the following program areas:
In-house TLD system ALARA program Respiratory equipment facility l
Dose assessments Radiological training Computer system for RPD records Audits of the RPD i
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11 1.4.4 Communications The exchange of information between the RPD 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 varicus department supervisors, including those of the RPD, during which time the status of various plant conditions and projects were discussed.
Personnel within the RPD stated that they were given an opportunity to provide input regarding department policies and procedures.
Good working relationships also appeared to exist among RPD personnel.
However, several technicians commented that the exchange of information between RPD supervision and the technicians was not always in enough detail to ensure proper health physics coverage.
1.5 Conclusions 1.
The following item is identified as.a significiant finding.
Im-provecent in this area is required in order to achieve an acceptable program:
Administrative procedures had not been developed to define the authorities aad responsibilities for the Radiation Protection Department.
2.
The following item should be considered for improvement of the program, but does not warrent inclusion as an Appendix A item:
The Radiation Protection Manager did not report directly to station management as recommended in Regulatory Guide 8.8.
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FIGURE 1 RADIATION PROTECTION DEPARTMENT ORGANIZATION CORPORATE RADIOLOGICAL Al5ESSMENT BRANCH.
I STATION SUPERINTENDENT I
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STATION SERVICES SUPERINTENDENT I
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GENERAL SERVICES SUPERVISOR QUALITY SERVICES SUPERVISOR RADIOLOGICAL SERVICES SUPERVISOR CHEMISTRY SUPERVISOR HEALTH PHYSICS SUPERVISOR STATION NURSE CHEMIST (RADIATION PROTECTION MANAGER)
CHEMISTRY CHEMISTRY HEALTH PHYSICST FOREMAN FOREMAN i
UNIT 1 UNIT 2 ALARA COORDINATORS UNIT 1 TECHNICIANS TECHNICIANS (2)
(4)
UNIT 2 RADIATION PROTECTION SUPERVISOR RADIATION PROTECT ON SUPERVISOR j
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UNIT 1 UNIT 2 HEALTH PH SICS FOREMAN RADWASTE HEALTH PH SICS FOREMAN HEALTH PHYSICS FOREM t
UNIT 1 UNIT 2 (SUPPORT)
. _P TECHNICIANS HP TECHNICIANS HP TECHNICIAN 5 H
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(6)
(5) 4
12 2.0 Personnel Selection, Qualification, and Training Documents Reviewed Standardized Procedure No. 21, " Station Health Physics Technician and Foreman Training Program," Draft 2, July 1980 Standardized Procedure No. 20, " Contracted Health Physics Technician and Foreman Training Program," Draft 2, July 1980.
Procedure ACP-8.03, " Health Physics Training and Retraining for Company and Contractor Personnel, " Revision 2, September 8, 1978 PROGRAM The appraisal of the Millstone program associated with personnel selection, qualification, and training was accomplished by: attendance at portions of various training lectures given to contractor personnel; attendance at a portion of the procedures training given to contractor health physics (HP) personnel; discussions with supervisory personnel in the Radiation Protection Department and the Site Training Director; and the review of various personnel training records.
The selection criteria for plant radiation protection personnel were based on the NRC Regulatery Guide 1.8 " Personnel Selection and Training" and ANSI N18.1-1971 " Selection and Training of Nuclear Powar Plant Personnel."
The selection criteria were job related and adet;uate job descriptions were available.
i The selection criteria for contractor HP personnel were evaluated.
The senior contractor HPs were required to meet the same criteria as plant radiation protection personnel.
However, specific job descriptions for the contractor HPs' functions at MNPS and procedures for reviewing and verifying contractor resumes did not exist.
Unfilled openings in the MNPS Radiation Protection Department and the short supply of contractor HPs have led corporate headquarters to evaluate the i
need for an in-house training program for HP plant personnel.
This program was being designed to provide health physics education and training to Millstone personnel for the purpose of developing adequately qualified radiation protection technicians from other departments within the licensee's organization.
Currently, all plant radiation protection technicians and foremen had received an intensive two-week radiation protection training program con-ducted by the corporate professional staff.
This two-week c2
" was planned to be presented annually to new radiation protection personnu as retrain-ing for the existing radiation protection technicians.
Another grogram was also being developed by corporate to provide a professional level course for radiation protection supervisors and the HP professional staff.
All radiation protection personnel received yearly training by the MNPS Training Department in topics of industrial health and safety, security,
13 and fire protection.
Formal written exams were given at the completion of the training and were used for evaluations.
Plant personnel other than those in radiation protection received an annual two-day course on radiological health and safety.
This course included the information outlined in NRC Draft Regulatory Guide OH717-4, dated August 1979,
" Radiation Protection Training for Light Water Cooled Nuclear Power Plant Personnel." This two-day course also included some hands-on-training.
Contractor personnel other than contractor HPs also received this training and the hands-on experience.
Written exams were used to determine successful completion of the training.
Training requirements had not been developed for escorted visitors.
They were not required to attend any lecture on security, radiation protection, emergency response or general safety.
Consideration should be gfven to establish an information program for escorted visitors in the form of handouts and a :' art lecture, and document that such information was provided.
During the appraisal, a review of the existing training facilities was made.
The appraisal was conducted at the beginning of an outage and was, therefore, during a peak period of training.
Although there was some interference between the Respiratory Protection Testing Area hands-on training and tne contractor lecture in radiation protection training, the facilities.seemed adequate.
Plans had been completed for construction of a new training facility.
The planned facility should greatly reduce the loads on the existing training facility and prove more efficient in accommodating personnel.
Conclusions 1.
The following items are identified as significant findings.
Improvement in these areas are required in order to achieve an acceptable program:
A procedure had not been developed to provide guidance regardirig screening and acceptance criteria for prospective contractor health I
physics personnel.
Job / position descriptions had not been developed for contractor health physics personnel.
2.
The following item should be considered for improvement of the program:
A procedure had not been developed regardine indoctrination requirements for escorted visitors.
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14 3.0 Exposure Control 3.1 External Exposure Control 3.1.1 Dosimetry Program Documents Reviewed Frocedure HP-4902, " External Radiation 6xposure Control and Dcsimetry Issue, Revision 0, 7/1/80 Procedure HF-4903, " Neutron Radiation Exposure," Revision 0, 7/1/80 Procedure HP-4904, " Noble Gas Exposure," Revision 0, 7/1/80 Memo From R. C. Rodgers to MNPS, " Neutron Exposure at CY and Millstone -
Draft Administrative Guides," 7/29/80 Procedure HP-901/2901-A, " Radiation Exposure Cards," Revision 2, 7/1/80 Procedure HP-906-2906, " Radiation Incidents - Reporting Requirements,"
Revision 3, 1/26/79 Procedure HP-907/2907, " Personnel Exposure Evaluation and Investigation,
Revision 4, 7/1/80 Procedure ACP 6.06, " Radiation Monttoring System Administration,"
Revision 0, 3/29/79 PROGRAM The external dosimetry program at the MNPS consisted of the assessment of radiation dose by a newly installed thermoluminescent dosimetry (TLD) system and also by radiation surveys for neutron dose (Procedure HP 4903),
and noble gas exposures (Procedure HP 4904).
Procedure HP 4902 provided guidance and instruction for personnel monitoring dosimetry at the plant.
The in-house dosimetry program, initially established in June 1980, was l
operated by the corporate Radiological Assessment Branch TLD Laboratory.
The TLDs were delivered to the MNPS site where they were distributed ready for assignment and use.
The dosimeters were issued by the Radiation Protection Department for a one month period, then returned to the corporate TLD laboratory for analysis.
The data from the analysis was then fed into the HELPORE (Health Physics Occupational Exposure System) Computer System.
The output from the software programs is available via terminais at MNPS.
The TLD laboratory had state-of-the art equipnent including two manual TLD readers, two aubmatic TLD readers, a computer, and various accessories necessary to equip an acceptable personnel dosimetry program.
The laboratory had published an operation manual which l
15 included sections on administrative procedures, radiation protection, calibrations, and equipment operation.
A track etch film was used as a backup to the neutron survey meter readings until such time that the TLD laboratory can calibrate and supply neutron albedo badges to MNPS.
(Memo from R. C. Rodgers.)
The product of stay-time calculation and radiation survey meter (Eberline PNR-4) readings were entered into the personnel files as neutron dose.
Pocket ionization chambers (PIC) of various ranges were used to maintain a daily accounting of personnel exposures.
This accounting of PIC readings was entered on RWPs and on an exposure record card carried by the worker.
The RWP information was read into the corporate computer on a daily basis by the RPD and was available immediately, dependent only on computer turnaround.
Printouts of plant personnel exposures were printed daily by RPD.
Printouts of personnel exposures by RPD for other departments and/or contractors were usually obtained weekly but during cutages a hi:;her frequency (daily) was used.
When the TLD data were read into the computer at the end of the month, the PIC readings were dumpted.
Discrepancies between TLD and PIC exceeding 150 mreu or 25% were investigated by the MNPS HP department.
However, records of these investigations were back-logged one to two months.
3.1.2 Quality Assurance / Quality Control (QA/QC)
The licensee had not established an adequate QA/QC program regarding their in-house TLD system.
The beta and gamma dose information recorded by the licensee to satisfy 10 CFR 20.202 and 10 CFR 20.401 require-ments was obtained from their in-house TLD program.
However, the TLD system was never properly calibrated prior to being put into use.
The licensee stated that the vendor had performed various response tests at the vendor's facility on a TLD system similar to licensee's about two years previously.
In addition, the onsite Radiation Protection Depart-ment had " spiked" several TLDs and the TLD results were in close agreement with the known exposure.
However, the corporate RAB had not established an adequate QA/QC program that included the applicable recommendations from ANSI-N13.11-1978, " Criteria for Testing Personnel Dosimetry Performance," and ANSI N323-1978, " Radiation Protection Instrument Test and Calibration." The following basic aspects were missing from the licensee QA/QC program:
Verification of several calibration points over the expected range of the TLD reader Specification of the types (energies) of calibration sources Specification of the use of NBS traceable calibration sources Esta>1ishment of the frequency for calibrations Establishment of calibration acceptance limits
16 Resolution of unacceptable calibration results It was noted that the self-reading pocket dosimetry QA/QC program satisfied the recommendations of Regulatory Guide 8.4.
90 All TLDs were response tested with a Sr-Y source and each was assigned a relative response factor.
TLD acceptance criteria forpurchaseofnewTLDsfromthevendorhag0been established.
The PICS were also beta response tested to Sr-Y and depleted uranium sources by means of conversion factors.
Itappearedghatpenetratigg radiation doses were equated to a depth of 800 mgs/cm and 7 mgs/cm for beta radiation.
3.1.3 Records and Reports The licensee appeared to have an adequate number of personnel available to process dose information in a timely manner.
The licensee's records indicated that the reports required by 10 CFR 19.13 and 10 CFR 20.407, 408, and 405 were submitted as required.
The information required by Form NRC 4 and 5 was available and current.
3.1.4 Exposure Review and Limitations The licensee performed routine (daily) reviews of dose information.
The licensee had developed a computer program that provided daily, weekly, quarterly, and yearly dose information.
The licensee was aware of which workers were approaching their dose limits and controlled any additional dose accordingly.
Programs regarding access control, surveys, and posting and labelling are discussed in Section 3.3.
3.1. 5 Conclusions The licensee had the necessary facilities, equipment and qualified eersonnel to maintain an adequate external personnel monitoring program.
However, the following item is identified as significant findings.
Improvements in these area is required in order to achieve an acceptable program.
An adequate QA/QC program had not been established for the TLD system.
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17 3.2 Internal Exposure Control 3.2.1 Dosimetry Program Documents Reviewed Procedure HP-4907, " Bioassay," Revision 1, 8/1/80 Procedure HP 908/2908E, "Whole Body Counting," Revision 4,8/11/80 Procedure HP 4909, " Personnel Monitoring and Decontamination," Revision 0, 8/1/80 PROGRAM Three NaI whole body counters were the basic systems used in the licensee's internal dosimetry (bioassay) program. One whole body counter was permanently located in the reactor facility near the health physics administrative area.
In addition, two mobile units had been brought onsite to assist with the increased counting require-ments associated with the Unit-2 refueling outage.
Each counter consisted of a NaI detector and an associated multichannel analyzer.
All three counters were leased from an offsite vendor.
Data in the form of gross gamma counts were imr.;ediately available onsite for selected radionuclides. This raw data provided the licensee with an early indication if established action levels for gamma emitters were exceeded. Data were relayed via telephone / teletype to the vendor's offsite office where further analyses were performed. The vendor pro-vided a formal report after about two weeks which contained the various radionuclides identified and the associated maximum permissible body burdens (MPBB) or maximum permissible organ burdens (MP0B).
The licensee had not conducted excreta bioassay analyses to supplement the gamma analyses obtained from the whole body counts.
Procedure HP 4907 contains guidance regarding an excreta bioassay program, however, the licensee had not collected and analyzed samples for alpha, beta, and weak gama emitters.
The licensee's procedures required that each worker be whole body counted prior to entrance into a radiation controlled area and counted prior to termination of his work period.
Quality Assurance /Ouality Control (QA/0C)
The licensee had not established a QA/QC program that satisfied the recommendations of ANSI N343-1978 " Internal Dosimetry for Mixed Fission and Activation Products," for radioactive material detected in the body by direct (in vivo) measurement or excreta samples.
Procedures HP-4907 and HP-908/2908E briefly mention a limited 0A/0C program.
- However, the procedures did not adequately address such items as:
18 Calibration of the whole body systems prior to initial use Participation in an intercalibration program Calibration points established between 60-20,000 nCi Use of a phantom model that will permit reproducibility Calibration sources having calibrations traceable to the National Bureau of Standards (NBS)
Calibration acceptance limits Background limits Sensitivity requirements and Collection, packaging, shipping, and analyses of excreta samples Even though an adequate QA/QC program had not been established, the appraisers noted that whole body counting systems probably had the capabilities of meeting the sensitivity recommendations of ANSI N343 (e.g. 5% of the MPOB for selected radionuclides).
Thelicensee'scurrentQQCprogrgconsistedofcheckingthegainand channel alignment using Cs and Co solid disc sources.
These sources were not contained in a phanton model nor had the activity of the sources been verified.
Exposure Review Internal dosimetry data were reviewed by health physics supervision.
Whole body counts that exceeded established action levels were identified for immadiate onsite review.
The licensee also reviewed the routine formal whole cody counting reports submitted by their offsite equipment vendor.
The licensee had not established a formal program for comparing bioassay data against their air sampling program.
Responsibility Procedure HP4907 identifies the Health Physics Supervisor as bei.g i
responsible for the bioassay program.
Contractor health physics technicians were assigned to operate the whole body counters.
The contractors in turn reported to the licensee's health physics supervision.
Training f formal training program had not been established for the whole body counter operators.
Training was received through informal on-the-job training (0JT).
The appraisers noted that the operators were capable
19 regarding the mechanichl manipulations of the controls, but the operators were not familiar with the basic technical aspects of whole body counting.
For example, the operators stated that they did not possess a copy of nor were they familiar with the information contained in ANSI-N343.
3.2.2 Respiratory Protection Program Documents Reviewed Procedure ACP-6.05, " Basic Policy Regarding Use of Respirators, 8/1/80 Procedure HP-4907, " Bioassay," Revision 1, 8/1/80 Procedure HP-908/2908E, "Whole Body Counting," Revision 4, 8/11/80 Letter from W. G. Counsil to B. H. Grier, " Millstone Respiratory Protective Equipment," July 24, 1980.
Procedure HP-4909, " Personnel Meritoring and Decontamination," Revision 0, 8/1/80 Procedure HP-4912, " Radiation Work Permit Completion and Flow Control" Revision 0, 7/1/80 Procedure HP-4931 " Selection and Use of Respiratory Protection Equip-ment," Revision 0, 8/1/80 Procedure HP-4932, " Maintenance and Quality Assurance Program for Respiratory Protection Equipment," Revision 0, 8/1/80 Procedure HP-4933, " Breathing Air Supply and Utilization," Revision 0, 8/1/80 Procedure HP-4934, " Medical Screening Program for Respiratory Users,"
Revision 0, 8/1/80 Procedure HP-4935, " Respiratory Manfit Testing Using the Sodium Chloride Aerosol Test System," Revision 0, 8/1/80 Procedure HP-904/29348, " Calibration of Healta Physics Air Sampling Equipment," Revision 2, 5/2/80 Procedure HP-908/2908D, " Continuous Air Monitoring Operation and Interpretation," Revision 3, 1/1/80 PROGRAM The licensee did not have an approved respiratory protection program and as such did not take credit for protection factors.
On July 23, 1980, the licensee notified the NRC Region I office of their intention to make allowance for the use of respiratory protective equipment in accordance
20 with 10 CFR 20.103(e) commencing on or about September 1, 1980. The licensee's proposed program was contained in the procedures listed above.
The appraisers reviewed the proposed respiratory protection program and noted that it appeared to comply with 10 CFR 20.103, Regulatory Guide 8.15, and NUREG 0041.
Even though the licensee did not have an approved program, the licensee had maintained the practice of issuing respiratory protection devices if a worker entered a known or suspected area with high airborne radioactivity. The licensee had an adequate inventory of NIOSH approved air-purifying and atmosphere supplying respirators and self-contained breathing apparatus (SCBA). A sodium chloride booth was installed as part of the respiratory fitting and testing program.
In addition, the licensee was in the process of instal-ling a state-of-the-art respiratory cleaning, testing and repair facility. A medical evaluation program had been established prior to the July 23, 1980 submittal for workers issued respiratory protection equipment.
The licensee had established an engineering controls program to limit the inhalation and spread of airborne radioactive materials.
This included the construction of tents and associated portable HEPA filter systems around work area with high airborne potential.
Much of the engineering control program was related to the licensee's ALARA program.
See Section 7.
Procedure HP-4933 addressed the breathing air requirements.
This procedure referenced NUREG 0041 and applicable compressed gas assoc-iation requirements. However, the licensee was not able to locate the necessary docrentation that would verify that the offsite vendor responsibit for initial filling and refilling of SCBA bottles met the requirements for grade D breathing air.
The appraisers attended a respirator fitting and training session.
The course was well-organized and followed tb6 recommendations of Regulatory Guide 8.15 and f.UREG 0041. The studeats received practical experienced in donning various types of respiratory equipment and field leak test techniques.
i A formal training prog am had not been established for the respiratory fitting booth operators. The fitting booth operators received 0]T covering the mechanical aspects of sodium chloride test equipment.
However, only limited time was devoted to the technical portion of the respiratory protection program.
For example, the operators were not familiar with the information and requirements contained in Regulatory Guide 8.15 and NUREG 0041.
21 3.2.3 Conclusions The licensee has the necessary facilities, and equipment to provide an adequate internal dosimetry program.
However, the following items are identified as significant findings.
Improvement in these areas are required in order to achieve an acceptable program.
1.
An adequate whole body counter QA/QC program had not been established.
2.
A formal training program had not been established for individuals assigned to operate the whole body counterc and the respirator fitting booth.
3.
Excreta samples had not been collected and analyzed to supplement gamma results from the whole body counts.
4.
A program had not been established to compare bioassay and air sample results.
5.
The licensee had not determined whether air in SCBA bottles met breathing air specifications.
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22 3.3 Surveys, Access Control Documents R,eviewed 4
Procedure HP-4903, " Neutron Radiation Exposure," Revision 0, 7/1/80 Procedure HP-4904, " Noble Gas Exposure," Revision 0, 7/1/80 Procedure HP-4905, " Radiological Surveys," Revision 1, 8/11/80 Procedure HP-4906, " Posting of Radiological Controlled Areas," Revision 0, 7/1/80 Procedure HP-4908, " Protective Clothing," Revision 0, 8/1/80 Procedure HP-4909, " Personnel Monitoring and Decontamination," Revision 0, 8/1/80 Procedure HP-4912, " Radiation Work Permit Completion and Flow Control,"
Revision 0, 7/1/80 Procedure HP-905/2905, " Control and Accountability of Radioactive Materials, Revision 6, 12/28/79 Procedura HP-29098, " Smear Test for Sealed Source Contamination," Revision 1, 12/12/78 Procedure HP-915/2915, " Health Physics Surveys," Revision 13, 7/1/80 Procedure HP-920, " Containment Entrance Unit 1," Revision 6, 7/27/79 Procedure HP-2920, " Containment Entry," Revision 3, 7/19/79 Procedure 2902A, " Radiological Work Procedure for Steam Generator Work," Revision 2, 3/10/79 Procedure HP-922, Venting the Turbine and Condenser," Revision 3, 5/30/80 Memo A. G. Cheatham to Health Physics Personnel," Respiratory Protection, 4/10/79 PROGRAM The appraisal team reviewed selected procedures and records regarding radiation, contamination, and airborne surveys for the period January 1, 1979 - August 20, 1980.
The appraisal team also conducted several tours of various work areas during normal and offshift hours between August 11-21, 1980, to observe survey and control practices.
The appraisal team conducted independent radiation measurements and accompanied health physics technicians while they performed routine and special survey activities.
l
23 Health physics survey records maintained by the licensee for Ur.its 1 & 2 were identical in format. Differences in the two systems were the result of plant conditions (BWR vs. PWR) and the layout of each unit.
The primary records which document the survev program were the radio-logical posting (signs, adhesive labels, etc) at the area of interest, the radiological survey form, and the radiation wo:'k permit (RWP).
The radiological posting for both units consisted for the most part of standardized (preprinted) hard plastic signs for radiation / contamination and high radiation areas.
At some locations, the standard posting was augmented by " hot spot" stickers and substituted with snap-on signs with various radiological statas inserts.
The radiological posting criteria from procedure HP-9J2/2902 were as follows:
Controlled Area -
Major portion of the oody could receive in any one hour a dcee in excess of 0.5 mrem.
Radiation Area -
Major portion of the body could receive in any one hour a dose in excess of 2.5 mrem.
High Radiation Area-Major portion of the body could receive in any one hour a dose in excess of 100 mrem.
Contaminated Area-Loosesurfgcecontaminationexistsabove100g dpm/100 cm beta gamma and/or 100 dpm/100 cm alpha.
Radioactive material posting was accomplished by the placement of
" caution / danger radioactive material" stickers based on the following criteria from Procedure HP-905/2905:
Radioactive Material -
Activity greater than or equal to Appendix C in 10 CFR 20.
Loose surface contamination levels equal 2
toorgreaterthan1000dpmfl00cm beta-gamma and or 100 dpm/100 cm alpha.
I Radiation levels greater than 0.1 mrem /hr
[
at one inch.
Contact dose rates in excess of 50 mrem /hr were te he indicated on the posting when storage was within a Controlled Area.
However, when temporary storage was maintained outside of the Controlled Areas contact dose rates in excess of 0.1 mrem /hr were indicated on the posting.
The radiological survey form that was used in both units consisted of a data block and a diagram of the area surveyed.
The data block contained unit number; date/ time of survey; surveyor / reviewer signatures; i
24 instruments / efficiencies used; reactor power at time of survey; and contamination results.
The diagrams were either predrawn with an assigned radiation survey figure number or sketched by the surveyor for special (non-routine) surveys.
Radiological surveys were divided into three types as follows: routine surveys, RWP surveys, and special surveys (decontamination, chemistry sampling, shipping, etc.).
Lch individual type of survey was further subdivided into dose rate, contamination level, and airborne level surveys with routine require-ments outlined on the Unit 1 and 2 " Survey Frequency Matrix" forms in Procedure HP-4905.
Radiation Work Permits (RWPs) were used extensively throughout both units.
Depending upon the type of work to be performed, RWPs were required for entry into high radiation areas, contaminated areas, and airborne radioactivity areas greater than 70% of MPC.
The areas re-quiring RWPs were posted with a "RWP Required" sig.7 or a statement added to the standard posting as outlined previously.
Operations, health physics, s Nemistry, and maintenance were issued a blanket RWP for routine work so:h as plant tours and inspections.
The RWP (Form HP-903/2903-1) was subdivided into four areas as follows:
job description, survey measurements, personnel requirements /special instructions, and approval signatures.
The department requesting the work provided a job description and man-hour estimate so that ALARA reviews and radiation protection were adequately supplied.
Survey results were supplied by the health physics group, shich in turn prescribed personnel requirements (dosimetry, protective clothing, health physics coverage, etc.) and special instruments.
The above information was documented on a new RWP every shift with approval by the Health Physics Supervisor (cr Senior Health Physics Technician),
the Operational Shift Supervisor, and the ALARA Coordinator (if greater than 10 man-rem) before implementation in the field.
The appraisers observed that radiologico posting in both units con-l sistently did not indicate the status of the area or material posted.
Title 10 CFR Part 20.203 (a) (2) states that the licen.ee may provide s
on or near radiological warning signs additional information which may be appropriate in aiding individuals to minimize exposure to radiation or to radioactive material.
The areas observed for posting were Unit 1 (Turbine Building, Reactor Building, and Rad Waste Building) and i
l Unit 2 (Containment Building, and Auxiliary Building).
Radiation areas were posted with a preprinted sign with the wording:
CAUTION RADIATION AREA PERSONNEL MONITORING DEVICES REQUIRED FOR ENTRY and in some cases the wording "RWP Required for Entry" would be j
adued if applicable.
No indication was made on the posting of wnen the area was last surveyed or what the actual radiation level was w-
25 except that it was between 2.5 mrem /hr and 100 mrem /hr.
Thus, the only source of survey data available to workers besides the brief description on an RWP was the survey files in the Health Physics Office.
Radiological posting for contaminated areas consisted of a preprinted sign with the wording:
CAUTION CONTAMINATED AREA RWP REQUIRED FOR ENTRY The appraisers, in talking with plant personnel and from observation of radiological posting in the field, found that posting for contamination did not indicate the level of activity in the posted area.
The con-taminationpostingigdicatedthattheactivitylevelsweregreater 2 than 1000 dpm/100 cm beta gamma and/or greater than 100 dpm/100 cm alpha with the actual level not being stated.
High Radiation Area posting was similar to Radiation Area posting in that the actual level inside the area was not indicated (only that it was greater than 100 mrem /hr).
Radiological posting for airborne activity areas consisted of a sign with the following wording:
CAUTION AIRBORNE RADIOACTIVITY AREA The source of the airborne activity was not indicated.
For example, in the Unit 1 Turbine Building on the 14'6" level an Airborne Radio-activity Area was posted with no indication that it was a noble gas radioactivity area which presents an immersion problem.
Posting of " hot spots" within Radiation or High Ractiation Areas was accomplished by " hot spot" stickers without the survey data being indicated.
When " hot spots" were located within a Radiation or High Radiation Area, no indication was given on the posting of the radia-tion level or specific location of the " hot spot" to warn personnel entering the area.
In addition, standard " hot spot" stickers were not always used.
For example, on the control rod drive mechanism (CRDM) control lines on the 14'6" level of the Unit 1 Reactor Building.
The overhead piping of the CRDM units were marked with yellow tape and a number indicating the radiation level of the " hot spots."
Reference was not made on the tape that it was posting for a " hot spot" or that the number represented a known exposure rate.
The storage of radioactive materials in yellow poly bags was posted by the application of a Radioactive Materials sticker to the bag.
In all cases observed by the appraisers, no indication was given on the Radioactive Material sticker regarding radiation levels, con-tamination levels or date of survey.
In particular, se/eral bags of contaminated equipment were placed outside the Equipment Decon-tamination Room on the 14'6" level of the Unit 1 Turbine Building without any indication of the radiological status of the equipment to be decontaminated.
26 i
The aisers in observing survey records consistently found that surveys performed did not indicate the reason the survey was being taken or any discussion / remarks on the findings of the survey.
These observations were made after reviewing selected surveys from Unit 1 from the period July 1, 1980 to August 11, 1980 and from Unit 2 for the period July 1, 1980 to August 20, 1980.
As required by Procedure HP-4905, " Radiological Surveys" the purpose for performing the survey (such as routine, RWP, decontamination, etc.)
shall be indicated on each survey form.
However, the survey form does not provide a space for this data.
In addition, Unit 2 surveys con-sistently lacked this, whereas, Unit 1 surveys provided this infor-mation (written in the margins) more frequently than Unit 2 but not adequately.
The survey form used by both plants was inadequate, in that, it did not provide space for data required by Procedure HP-4905.
In addition, to not having a " Reason for Survey" section it lacked an airborne radioactivity concentration and " Instrument Calibration Due Date" section as required by procedure.
An explanation of survey results by the surveyor was not documented on the survey forms reviewed by the appraisers.
Even tnough this was not required by the procedures, the lack of it made the surveys incomplete.
Selected Radiation Work Permits (RWPs) were reviewed for Unit 1 from January 1, 1980 to August 11, 1980 and for Unit 2, for the period July 1, 1980 to August 20, 1980.
The appraisers observed that radia-tion work permits did not specify protective clothing or respira-tory protective equipment requirements consistently based on the type of work and the radiological conditions.
In particular, the, specification of respiratory protection for airborne concentrations was based solely on health physics judgement without any guidelines being established in the procedures.
For example, the following RWPs for Unit 1 were issued without respira-tory protection or lapel air samplers being required.
Maximum Contamination Level 2 RWP#
Issued (Units in dpm/100cm )
2165 6-21-80 400,000 2181 6-22-80 400,000 2187 6-23-80 300,000
- 2199 6-23-80 300,000
- 2258 6-25-80 300,000
- Decontamination to be performed within the area.
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27 A oral management guidelins requiring air sampling and/or respiratory protective equipment for areas with contamination levels above 100,000 2
dpm/100 cm beta gamma was promulgated but was not observed to be used at either unit by the appraisers.
The airborne column on the Radiation Work Pe..uit was consistently left blank in Unit 1 so one could not easily determine whether an air sample had been taken.
In additiun to the deficiencies in health physics controls listed above, the following two incidents occurred during the appraisal visit regarding the Unit 1 RWP program.
10 CFR 20.201(b) " Surveys," require that such surveys be conducted as may be necessary to comply with the regulations contained in each section of Part 20.
A " survey," as defined in paragraph 20.201(a) means "an evaluation of the radiation hazards incident to production, use, releese, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. When appro-priate, such evaluations include a physical survey of the location of the materials and equipment, and measurements of levels of radia-tion or concentrations of radioactive materials present." The licensees Procedure HP-4905," Radiological Surveys", Revision 1, dated August 11, 1980, further amplifies survey requirements.
Section 8.3.5 of Procedure HP-4905 states: "For jobs where radioactive contamination may become airborne, e.g., scraping, grinding, or welding on contaminated surfaces, respirators should be required.
Suitable breathing zone air samples should be taken and analyzed.
Only after the airborne activity has been evaluatad and if appropriate, should the respirator requirement be dropped."
In addition, A. G. Cheatham's memo to Health Physics Personnel, dated April 10, 1979, states in part: (1) Static air samples must be taken during each evaluation of a potential airborne causing job and shall be taken as close as possible to the individual's breathing zone (within 12" normally),
(2) air surveys are required whenever performing physical work on a component or niaterial with loose contamination greater than 100,000 dpm where airborne activity may be created, and (3) respiratory protection is required whenever the particulate and iodine activity combined fraction exceeds 70% of MPC, or at t;.e start of any job where there is a potential for airborne until the actual air concentration is determined.
a.
Incident No. 1 On August 13, 1980, three contractor workers were contaminated while workin.1 in the Unit 1 torus bay area.
The workers were conducting eddy current testing, as authorized by RWP 802842, on the torus support structures when contaminated.
Decontamination procedures were accomplished on the workers followed by whole body analysis wig the licensee's onsite counter.
The whole body analyses indicated Co internal lung burdens of 23% for worker A, 13% for worker B, and 5% for worker C.
l
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28 Contamination surveys performed in the torus bay area before theeddycurrenttestingstartedindicagedloosesurfacecon-tamination levels of 150,000 dpm/100 cm beta gamma.
- However, an air sample was not collected and analy7.ed prior to starting work nor was breathing zone air sampling conducted during the work.
Failure to perform adequate surveys u.s considered an item of noncompliance.
This item of noncompliance was reported as part of the monthly NRC Resident Inspection Report.
b.
Inci_ dent No. 2 On August 21, 1980, an appraisal team member noted that three workers were permitted to work in the Unit 1, Shut Down Pump Room during the morning of August 21, 1980 without proper health physics controls.
Radiation Work Permit No. 802934 authorized the workers to replace insulation in the pump room.
Contamination i
surveys conducted on August 19, 1980, indicatgdsurfacecontamina-tion levels " greater than" 500,000 dpm/100 cm beta gamma.
How-ever, no surveys were conducted prior, to or during work activities to establish airborne radioactive concentrations.
In addition, the RWP did not require the use of respiratory protection equip-ment.
Failure to conduct the required surveys is an apparent item of noncompliance agai.ast 10 CFR 20.201(b) in that the licensee had not determined whether 10 CFR 20.103 limits were exceeded.
l The licensee maintained a record of MPC-brs for each worker that entered an airborne area.
Adequate sampling equipment, both grab and lapel samplers, and laboratory counting equipment were available for collection and analysis of air samples.
- However, the appraisers had concerns that proper MPC-hrs were not always recorded.
These concerns are expressed in the above discussions regarding the apparent items of noncompliance.
The licensee's records indicated that MPC-hrs values had not exceeded 10 CFR 20.103 limits.
It appeared that additional continuous air monitors (CAMS) could be used in order to provide more comprehensive air monitoring and immediate warning to workers should a significant airborne release occurs.
Each unit had about four CAMS in operation.
Additional CAMS would provide increased monitoring and immediate indication of airborne problems for areas not presently being monitored.
3.4 Conclusions 1.
The following item is identified as an item of noncompliance.
Improvement in this arca is required in order to achieve an acceptable program.
a
29 Adequate air surveys were not performed and respiratory protection equipment was not specified for areas with high loose surface contamination levels. This item appears in Appendix B to this report.
?.
The following items should be considered for improvement of the program, but do not warrant inclusion as Appendix A items.
a.
The posting of radiation controlled areas should be more explicit in providing more details regarding the nature of the radiological conditions.
b.
The Radiation Work Permit should be designed to contain more information regarding radiological conditions.
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b 30 4.0 Radioactive Waste Management System 1
1 Documents Reviewed Unit 1 and 2 Environmental Technicial Specifications Annual Environmental Reports for 1978 and 1979 Technical Specifications Testing Requirements For:
Unit 1, Standby Gas Treatment System Unit 2, Enclosure Building Filtration System I
Unit 2, Storag Pool Area Ventilation System Unit 2, Control Room Emergency Ventilation System Procedure SP 836, " Stack Gas Monitor System Functional Test and Calibration,"
Unit 1 Procedure IC 4U6K, " Stack Gas Radiation Monitor Calibration," Unit 1 1
Procedure SP 4060, " Reactor Building Exhaust Duct and Refuel Floor High Radiation Monitor Function Test," Unit 1 Procedure SP 406P, "Radwaste Effluent Radiation Monitor Drawer Calibration,"
Unit 1 Procedure SP 406T, " Air Ejector Off-Gas Isolation Radiation Monitor Detector Calibration Test," Unit 1
{
Procedure SP 831, " Radioactive Service Water Effluent Monitor Calibration,"
l Unit 1 Procedure SP 2404N, " Unit 2 Stack Gaseous Process Radiation Monitor" Procedure SP 2404-0, " Waste Gas Process Radiation Monitor," Unit 2 Procedure SP 2404B, " Clean Liquid Radwaste Process Radiation Monitor Functional Test," Unit 2 Procedure SP 2404L, " Clean Liquid Radwaste Process Radiation Monitor Calibration, Unit 2 Procedure SP 2404A, " Aerated Liquid Radwaste Process Radiation Monitor Function Test," Unit 2 Procedure SP 24045, " Spent Fuel Pool Area Radiation Monitor Calibration,"
Ur.it 2 u..-..
l 31 Safety Evaluation of Unit 1 Low Level Radiation Waste Disposhl, May 2, 1980 Procedure ACP-6.07, " Management of Radioactive Waste,",% vision 2, June 27,1980 The appraisal.eam reviewed the gaseous, liquid and solid waste systems associated with Units 1 and 2.
Each unit maintained separate gaseous, liquid, and solidification systems.
A solid waste compactor located in Unit 1 served both Units.
The Operations Departments were responsible for supervising radwaste activities at both Units.
Health physics coverage was provided by the RPD as needed, 4.1 Unit 1 GASEOUS The Unit 1 gaseous waste system included an Augmented (A0G) Off-Gas system cen-structed after the initial operating licensee (0L) was issued.
The A0G included a HEPA filter and refrigerated charcoal system.
The annual average release rate had been less than 100 uci/sec.
The review of gaseous release records and statements by the licensee indicated that the Unit 1 gaseous radwaste system had been relatively free of operational problems.
A routine efficiency and leak test program had not been established for filter systems not listed as Technical Specification requirements.
The licensee's records indicated that the following systems not been tested:
Stack Off-Gas (HEPA and Charcoal)
(
Radwaste Ventilation (HEPA and Charcoal)
It was also noted that the Unit 1 Control itcom was not equipped with a filter system that could be activated in the event of high airborne concen-trations.
LIQCID Liquid radioactive wastes that enter the solidification process originate from the condensate demineralizer, regeneration waste neutralization tank, floor drain collector tanks, or other tanks where radioactive liquid were stored.
The liquid wastes were collected and processed through a waste concentrator.
The primary dissolved solid in concentrated waste was sodium sulfate formed by the combination of sulfuric acid and sodium hydroxide used in demineralizer regenerations.
Urea-Formaldehyde (UF) was used as the solidification agent.
Liquid wastes were concentrated by evaporation and then stored in concentrated waste storage tanks.
As part of the solidification process, wastes l
were homogeneously mixed in the concentrared waste storage tanks, then i
transferred into a measuring tank, mixed with UF, and poured into a shipping i
liner ~for shipment offsite.
Demineralizer resins and used filter media from the reactor water clean-up filters and radwaste process filters were dewatered in a centrifuge
32 4
system.
After confrifuging, the dry resin / filter wastes were metered j
into 55 gallon drums for eventual shipment offsite.
The original resin / filter waste processing did not include a solidification process.
In May 1980, the licensee modified their resin / filter waste system to include a mobile dewatering cask and solidification system.
The addition of the mobile waste system permits the solidification of resin / filter material by the use of UF.
This allowed the licensae to by pass the centrifuge and avoid several waste handling problems associated with the original system.
The licensee submitted a 10 CFR 50.59 evaluation of the j
mobile system to the NRC on May 2, 1980.
Interviews with licensee personnel involved with the waste program revealed that the Unit 1 liquid waste system had been plagued with a variety of problems.
The systems must operate at full capacity in order to handle the waste being generated.
Two items identified as specific problems areas were the large amounts of wastes from the concentrate demineralizers and problems with the centrifuge system.
The lack of a dedicated radwaste supervisor / engineer was also identified as a problem.
The Unit 1 liquid and solid waste systems had deteriorated during recent years and was in need of considerable main-tenance.
A licensee representative stated that a dedicated supervisor was needed to devote sufficient time to overseeing the necessary overdue main-tenance and operation of the system.
l Currently, one Plant Equipment Operator (PEO) was assigned full time as a radwaste operator during the day shift.
In addition, other PE0s from the operation shift crew were assigned to operate the system as required.
Training for the radwaste PEOs was provided by on-the-job training (0JT).
It was the responsibility of PE0s supervisor to review the progress of i
new trainees and document when the individual had completed the required r
OJT.
A formal radwaste operator course, including lesson plans and class-room instruction, had not been established.
The Training Department did not participate in the radwaste training program.
4.2 Unit 2 GASEOUS The Unit 2 gaseous wastes were processed through a degasifier then stored in gas decay tanks prior to release via the main stack along with Unit I releases.
The licensee's release records for the period January 1, 1979 -
June 1, 1980, indicated that Unit 2 releases were within Technical Speci-1 fication limits.
It was noted that gas decay tanks are normally held for 60 days before relessed.
The licensee stated that there had been no j
particular problems associated with operation of the gaseous system.
Gaseous wastes were processed in a timely manner and the system had operated l
within the design criteria.
l l
l 1
l
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l 33 An efficiency and le'ak test program had not been established for filter systems not listed in the Technical Specifications.
Filter systems that were not included in a testing program included:
Containment Purge Radwaste Area Turbine Building LIQUID No significant problems were identified regarding the operation of the Unit 2 liquid and solid waste systems.
The licensee stated that the liquid waste system had operated properly and provided adequate storage capacity.
Urea-Formaldehyde was used as the solidification agent.
Only limited waste materials had been generated from the liquid waste system that required solidification.
The licensee's records indicated that approx-imately 300 cubic feet of solidified waste had been processed during 1978-1980.
The assignment of personnel to operated the radwaste system and associated training program for Unit 2 was similar to that established at Unit 1.
A permanent, full time, radwaste PE0 was assigned to the day shift.
Each operations shift crew also had one PE0 designated as a radwaste operator.
Training for the radwsste operators was provided by OJT.
The radwaste PE0's supervisor was responsible for reviewing the training and signing the OJT training checklist.
A formal training program, with input from the Training Department, had not been established.
The licensee stated that the Unit 2 radwaste systems were not in the deteriorated condition as existed in Unit 1, however, the addition of a dedicated Unit 2 Radwaste Supervisor / Engineer was menticned as a needed addition to ennre the continged successful operation of the systems.
l 4.3 Effluent Release Control u
l Documegts Reviewed l
l, Procedure No. CP-28098; " Liquid Waste Discharge;" Revision No. 9; l
April 8, 1980.
l Procedure No. CP-2809C; " Gaseous Waste Discharge;" Rev0, ion No. 2; November 7, 1976.
Form No. CP-809A-2, " Millstone Unit I Liquid Discharge Permit;"
Revision No. 2; April 12, 1979.
For:n No. CP-28098-4; " Millstone Unit II Liquid Discharge Permit;"
Revision No. 3; May 9, 1979.
Form No. CP-28098-7; " Aerated / Coolant Waste Monitor Set Point Worksheet;" Revision No. 1; April 8, 1980
34 Form No. CP-814/2814-3; " Stack Particulate and Iodine Worksheet, Millstone Unit No. 1;" Revision No. 2; February 29, 1980.
Procedure No. SP-646.3; "SGTS High Efficiency Filter Pressure Drop Test;" Revision No. 2; March 26, 1980.
Procedure No. SP-646.4; "SGTS Charcoal Filter and Particulate Filter and Particulate Filter Efficiency Test;"
Procedure No. SP-2609D; " Enclosure Building Filtration System (EBFS)
Filter Testing - Annual;" Revision No. 2; December 26, 1978.
Procedure No. SP-2609E; " Enclosure Building Filtration System (EBFS)
Testing - Refueling;" Revision No.1; Noven.ber 21, 1978.
Procedure No. SP-2609F; " Control Room Ventilation System (CRAC) Filter Testing - Annual;" Revision No. 0; October 14, 1976.
PROGRAM The licensee controlled the discharge of liquid and gaseous effluents by the use of radiochemical analysis, HEPA/ charcoal filtration, and in-line radiation monitors.
The radiochemistry program was divided among onsite and offsite analyses.
Onsiteanalgge50were performed in the radiochemistry laboratory.
Routine analyses for Sr and gross alpha, were performed by an offsite vendor.
Radiochemical analysis was used as the primary method of determining the dilution ratio for liquid we J.e discharges.
As a backup mechanism, the in-line detectors were used to actuate trip values in order to terminate the liquid discharge flow.
Alarm set points were determined for each discharge basad on dilution flow rate, discharge flow rate, activity in waste tank, and a reduction factor which took into account the MPC values.
In-line detectors for gaseous waste discharges were used to measure the activity levels released to the environment.
In addition, automatic isolation valves, actuated by the in-line detectors were capable of preventing gaseous discharges when limits were exceeded.
Filter testing including D0P, pressure drop, flow rate, etc., were performed on a routine basis to ensure compliance with Technical Specification requirements.
The appraisers reviewed selected gaseous and liquid discharge permits from Unit 1 and 2 for the period January 1, 1980 to August 11, 1980 and found that releases were within technical Specification limits.
The monitoring of the total activity release limit of 1.25 curies /
calendar quarter (excluding tritium and dissolved gases) was followed very closely.
The alarm set point for liquid waste discharges from the coolant monitor 5 tanks was calculated on form CP-28098-7 with a maximum value of 9.5 x 10 counts per minute (cpm).
35 An alert set point called for by the procedure was also used to inform personnel that the activity level was 1/2 of the alarm value.
TheUgit 2 liquid discharge detector had a background of approximately 5 x 10 countsperminute(cpm)duetochroniccontaminationfrompgevious discharges.
The alert set point was not reset above 5 x 10 cpm thus causing it to be ineffectual.
The documentation used for radiochemical analysis and discharge permies ensured that all Technical Specifications and release rates were adhered to and well-monitored.
In the collection of samples for this documenta-tion, the appraisers observed that the samples were representative of the waste; however, the sampling procedure did not address emergency radio-logical sampling techniques.
The Technical Specifications for testing the HEPA filters and charcoal absorber banks for the Enclosure Building and Control Room of Unit 2 and the Standby Gas Treatment System (SGTS) for Unit 1 were adequate.
The documentation of results on forms SP-2609 (A thru F) and SP-646 (0.3 thru 0.8) was reviewed for the latest set of tests (1979, 1980) and was consistent with the requirements of the Technical Specifications.
4.4 Effluent Monitoring The calibration and functional test programs for gaseous and liquid effluent release monitoring on both units were reviewed.
The licensee's records indicated that calibrations and function tests were completed in accordance with established procedures.
Each unit had developed separate calibra-tion and test programs.
The responsibilities for the programs were assigned to various departments including Instrument and Control (I&C), Chemistry and Radiation Protection and Operations.
In the monitoring program the following problems were identified:
The Unit 2 liquid effluent monitors had excessive background count rates.
The licensee's records for the period January 1,1980 through August 15, 1980, indicated that chronic backgrounds for the clean liquid radwaste monitor and the aerated liquid radwaste monitor were about 100,000 cpm.
The appraisers were concerned that the high backgrounds would interfere with the required sensitivity necessary to terminate releases based on present alarm set points.
The licensee stated that they were aware of the high backgrounds and a system modification had been initiated to correct the problem.
The calibration procedures did not include calibration points at approximately 1/4, 1/2 and 3/4 of the full range gead-out.
The full range scale for the effluent monitors was 10 cpm; however, the calibration records indicated that calibrations were only per-formed at about 10000 - 60,000 cpm.
As a result, the only cali-bration points established were less than 10 percent of the full range read-out.
36 Documentation was not available to verify that the count rates obtained from the solid sources used during celibration of the effluent monitors could be correlated to known (NBS traceable) gas and/or liquid concentrations.
The licensee's original cali-bration program included calibrating the effluent monitors with known gas and liquid concentrations. The count rates obtained from the known concentrations where then compared to count rates l
observed from a series of solid sources.
Several of the original solid sources had been replaced. _ Comparison of the observed count rates from the solid sources against known gas and liquid contrations had not been accomplished for replacement sources.
4.5 Solid Waste a
Documents Reviewed Procedure No. ACP-QA-6.04; " Radioactive Material Shipping Requirements;" Revision No. 12; 4
Procedure No. ACP-6.07; " Management of Radioactive Waste;"
i Revision No. 2; Procedure No. HPP-928/2928; " Shipment of Radioactive Materials;"
Revision No. 2 Procedure No. HPP-928/2928; " Shipment of Radioactive Materials;"
Revision No. 9; January 15, 1980.
Procedure No. HPP-928/2928 A-1; " Shipment of Radioactively Contaminated Protective Clothing;" Revision No. 0; June 8, 1978.
Procedure No. HPP-928/2928 A-2; " Shipment of Solidified Radio-active Waste;" Revision No. 2; December 20, 1979.
i Procedure No. HPP-928/2928 A-3; " Ship:nent of Radioactively Contaminated and/or Noncompactable Waste;" Revision No. 2; January 15, 1980.
Procedure No. HPP-928/2928 A-4; " Shipment of Radioactive Spens Resin / Filter Media Waste;" Revision No. 2; January 15, 1980.
Procedure No. HPP-928/2928 A-5; " Shipment of "Large Quanity" Radioactive Material;" Revision No. 2; December 20, 1979.
Report No. SF-224; "USNRC Certified Cask Receipt Inspection Report;" Revision Nc. 9; June 13, 1979.
Form No. SF-602; " Radioactive Shipment Checklist;" Revision No. 8 March 6, 1979.
Radioactive Waste Shipment Audit for Units 1 and 2; Performed by the Millstone Quality Assurance Group on September 20, 1979.
37 Program The Radioactive Waste / Material Shipment Program was supervised by the Unit I Health Physics Supervisor.
At the onset of the refueling outage for Unit 2, a representative of the Northeast Utilities Service Company -
NUSCO replaced the Northeast Nuclear Energy Company - NNECO Unit 1 Health Physics Supervisor.
This was designed as a full-time position in order to accommodate the increased supervisor man hours that would be required during the outage.
The shipment procedures and forms were based on the guidelines set forth in 10 CFR 20, 10 CFR 71, and the regulations for shipment established by the Department of Transportation (00T).
A typical shipment of solid waste to an offsite vendor consisted of a shipment package containing the following record forms as a minimum:
Barnwell radioactive shipment record State of Connecticut radioactive permit Chem Nuclear shipmer :s form Millstone isotopic analysis Millstone survey records Millstone radioactive shipment checklist In addition to solid radioactive waste (solidified 11guid waste, low specific activity, a.1d irradiated metal) other shipments of laundry and spent resin were puformed routinely with similiar shipment record packages.
Records of each shipment were kept onsite with a monthly and semi-annual summary report of waste type, container size, container inventory, and curie content sent to corporate headquarters.
In conjunction with health physics, the QA Department inspected shipment containers both on arrival and departure for damage and excess liquid to ensure compliance with established procedures.
A reduction in offsite shipment volume was accompl,ished by evaporating liquid waste and then solidfying the evaporator bottoms (sludge) for transport.
In addition. on August 20, 1980, an offsite vendor (Chem Nuclear) setup a portable unit to handle the contaminated laundry generated during the outage.
As an example of shipment inventory generated, the first six months of shipments for 1980 consisted of the following:
211 LSA drums (55 gal. each) from Unit 1.
3 41 Spent resin drums (7.5 ft each) from Unit 1.
3 43 Solidified liquid waste shipments (322 ft each) from Unit 1.
3 38 LSA boxes (175 ft each) from Unit 1.
1600 LSA laundry drums (55 gal. each) from Unit 2.
38 The appraisers observed that radioactive shipments for Unit 1 typically did not have documutation on the survey record forms that alpha con-tamination surveys had been performed.
However, the Radioactive Material Shipment Records form (RMSR) contained within the same shipment package did have alpha contamination surveys documented.
Unit 2 shipment records did not show this discrepancy except in a few isolated cases.
As a example, the following radioactive shipments for Unit 1 contained alpha contamination survey results on the RMSR whereas on the attached survey form there was no alpha contamination documentation.
RMSR # C0-51-1 RMSR # 80-59-1 RMSR # 80-65-1 RMSR # 80-81-1 RMSR # 80-82-1 RMSR # 80-85-1 The documentation on the survey forms was inadequate, in that, the locations from which contamination smears were taken could not be traced for future reference.
Procedure No. HP-4905 " Radiological Surveys" defined uncontaminated equip-2 mentasthathavingloosesurfacecontaginationoflessthan1000dpm/100cm beta gamma and less than 100 dpm/100 cm alpha.
As outlined in Procedure No. ACP-QA-6.04 " Radioactive Material Shipping Requirements", the outside surface of ship,.ing containers must be less than the above limits.
Department of Transpgrtation (00T) shipping requirements call f r less 2
than 2200 dpm/100 cm beta gamma and less than 220 dpm/100 cm alpha.
l The Millstone requirements were more restrictive than,the 00T limits and l
were found to be adequate.
However, the appraisers observed that the Radioactive Material Shipment Records forms (RMSR) and the survey forms were not always documented with the Millstone limits.
In Unit 2 for exampig,betagammaandlessthan220dpm/100cmonRMSRForm-80-1-2,onesu I
100 cm alphgwhereasthe other survey forgs document less than 1000 dpm/100 cm beta gamma and less than 100 dpm/100 alpha.
Asanotherexample,theRadioactiveMajerial l
ShipmentRecordForm80-76-2documgntslessthan1000dpm/100cm beta-gamma and less then 100 dpm/100 cm alpha.
This inconsistency in document-l ing contamination survey results did not present a problem in that the DOT regulations were not violated (even though Millstone procedures were).
- However, in the judgement of the appraisers it did point out that some health physics staff members were not familiar with shipment guidelines.
l
39 The determination of transuranic (alpha) concentrations in radioactive waste shipments was based on an analysis done by an offsite vendor.
A sample o between {3yeactor coolant water was isotopically analyzed with a ratio Cs and gross alpha then being determined.
The assumption that was made for radioactive waste or resin shipments was that the isotopic ratio of these two would be similiar to thI39bove ratio for reactor coolant.
By then performing an onsite analysis for Cs and using the reactor coolant ratio determined above, concentration could be determined.
If this exceeded 10 uCi/ gram, an offsite analysis was performed for transuranic concentra-tions.
AstudybytheElectricalPowerReyggrchInstitute{jyRI) deter-mined that this ratio should be made with Ce instead of Cs.
This study was acknowledged by chemistry supervision but no corrective action was initiated.
4.6 Conclusions 1.
The following items were identified as significant findings.
Improvements in these areas are required in order to achieve an acceptable program.
a.
The Unit 2 liquid effluent monitors had excessive background count rates.
b.
A correlation to known gas / liquid concentrations had not been established for the solid sources used to calibrate the effluent monitors.
c.
Calibration points had not been established for the effluent monitors at 1/4, 1/2, and 3/4 of the full-range readout.
d.
A dedicated Radwaste Supervisor / Engineer position had not been esttblished at eithar Unit.
e.
A formal radwaste operator training program had not been established.
2.
The following items should be considered for improvement of the program, but do not warrant inclusion as Appendix A items:
l a.
Contamination survey results for offsite shipments were not always properly recorded on the shipping papers, b.
The analytical procedures for determining alpha concentrations in solid radwat te shipments had not been up-dated to reflect the results of recent industry studies.
l
40 5.0 Radiation Protection Instrumentation Documents Reviewed Procedure HP-904/2904, " Calibration of Health Physics Instruments," Revision 3, 5/2/80 Procedure HP-904/2904A, " Calibration of Count Rate Instruments and Laboratory Scalers," Revision 2, 6/6/80 Procedure HP-904/29048, " Calibration of Health Physics Air Sampling Equipment,"
Revision 2, 5/2/80 Procedure HP-904/2904C, " Calibration of Special Survey Meters," Revision 1, 2/13/80 Procedure HP-904/29040, " Calibration of Fixed Monitors, Revision 2, 8/1/80 Procedure HP-908/290c, " Health Physics Dose Rate Instrumentation," Revision 1, 3/22/79 Procedure HP-908/2908A, " Health Physics Count Rate Instrumentation, Revision 2, 3/22/79 Procedure HP-908/2908B, " Health Physics Air Sampler Instrumentation, Revision 1, 3/22/79 Procedure HP 908/2908C, " Health Physics Spectrometer Instrumentation,"
l Revision 7, 8/1/80 Procedure HP-908/29080, " Continuous Air Monitor Operation and Interpre-tation, Revision 3, 1/1/80 Procedure HP-C08/2908F, " Measuring the Radiation Intensity of the J. L.
Shepard Calibration Unit, Revision 0, 5/3/77 Procedure HP-908/2908H, " Calibration of PNR-4 arid RM-16 Neutron Rate Meters Utilizing BF-3 Bonner Sphera " Revision 2, 6/8/79 Procedure HP-909/2909, " Routine Inspection, Inventory and Calibration of Equipment," r.evision 8, 8/1/80 PROGRAM The appraisal team reviewed the radiation protection instrumentation pro-gram including partable survey meters, continuous and grab air samplers, l
personnel friskers, portal monitors, area radiation monitors, process and l
effluent monitors, and laboratory counting equipment.
Findings regarding i
effluent monitors are also found in Section 4.0.
The review included determining the adequacy for such items as:
(1) inventory (2) calibration and reference checks, and (3) maintenance.
l
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41 The appraisal was accomplished by reviewing procedures related to radia-tion protection instrumentation and conducting discussions with:
per-sonnel in the Chemistry Department who were responsible for calibrating process monitors; personnel in the Radiation Protection Department who were responsible for area and portable instrument calibrations; and also with personnel in Instrumentation and Control Department who were responsible for repair of these instruments.
A review was also made of the Technical Specification requirements of Units 1 and 2 related to instrument calibra-tion.
~
Calibration of process monitors was accomplished utilizing solid sources.
However, the intensity of radioactivity from these sources was insufficient to allow a calibration over a representative portion of the instrument's range.
The sources used were representative of the isotopes expected to be encountered, providing a representative energy calibration check.
The calibrations were documented and were in acccrdance with existing Chemistry Department procedures.
(See Section 4.4 of this report.)
Calibration of portable instruments was performed by the Radiation Protection Department.
An NBS traceable cesium-137 source (routinely checked with a Victoreen condenser "R" chamber calibrated at NBS) housed in a calibrator was used for the gamma sensitive instruments, a depleted uranium plaque was used for the beta calibrations, and an AmBe neutron source, located at Haddam Neck Nuclear Power Station, was used for neutron instrument calibration.
Minor instrument repairs and battery changes were done by the Radiation Protection Department, and other repairs of a major nature were done by Instrumentation and Control (I&C) Section.
Procedure HP904/2904, provided instruction for calibration of the portable beta-gamma survey meters.
The documentation of the portable instrument calibrations should be improved in that forms were not properly filled out.
During the appraisal, the appraisers found numerous instances where calibration sheets indicated instru-ments were in-service and out of calibration, when in fact, they were out-o f-service.
The nuuscr cod kir.ds of portable radiatica protection ' survey meters appeared adequate.
The use of shoulder straps on survey meters appeared to reduce damage by droppir.g.
An adequate number of instruments were available for l
dose rate and ccntamination measurements.
The number of air samplers, both grab type and lapel, were also of sufficient quantity.
- However, placement additional Continuous Air Monitors (CAMS) would provide a more comprehensive air monitoring program to cnsure that workers are provided immediate warning in the event of high airborne concentrations.
The licensee had about four CAMS in operation in each unit.
Additional CAMS would provide for monitoring capabilities for those areas not currently l
being covered.
The inventory tracking system for all HP instruments was less than desirable and an effort should be made to substantially improve the on going inventory control program.
1 1
s
42 Calibration of friskers and laboratory scalers was outlined in Procedure HP-904/2904A.
Count rate meters equipped with GM detectors were used as personnel friskers.
The count rate meters were electronically calibrated but no evidence existed that the detectors (HP210) were calibrated with a radioactive source.
The above procedure, in Section 5.1.18, states "Using an open planchet Co-60 source, the efficiency of the probe may be checked."
The radiation protection personnel at the plant use this statement as being optional and rarely record instrument efficiencies.
The appraisers observed that when calibrations were done, the efficiencies were usually 15 to 16%
(cpm /dpm).
However, in calculating dpm the radiation protection technicians used a standard factor of 10 for convenience which is about 40% high.
Field checks were made of frisker-type instruments by simply observing background radiations.
No documentation of source field checks were evident during the appraisal.
Laboratory scalers were electronically checked by I&C on a yearly basis, a voltage plateau was run every three months, and weekly an efficiency check using an NBS traceable source was accomplished.
Each day a background and performance check was run as outlined in Section 5.5.5. of Procedure HP-904/2904A.
Documentation of scaler and rate meter checks were up to date and available.
Health physics air sampling equipment was calibrated according to Procedure HP-904/2904B and calibration documentation was available.
Procedure HP-904/2904D outlines the steps taken to calibrate the area radiation monitoring system.
The monitor was removed from service by I&C and Radiation Protection Department personnel.
It was calibrated on a cali-brator in a manner similar to the portable survey meters.
When calibra-tion was complete it was re-installed.
Documentation was available for the calibrations.
Continuous air monitors (CAMS) were used at the MNPS as " trend indicators."
These CAMS were electronically calibrated by I&C and provided alarm set points by the Radiation Protection Department.
These set points were from the vendor's literature and were the same for all the CAMS.
The CAMS did not appear to be calibrated to radioactive iodine, er noble gases.
Procedure HP-908/2908 listed the Alarm Set Points as follows:
Alarm Set Points (NMC)
-9 3
Particulate 5400 cpm (2x10 uCi/cm )
-9 3
Iodine 2300 cpm (7x10 uCi/cm )
-6 3
Gaseous 90 cpm (1x10 uCi/cm )
Alarm Set Points (AM-2)
-9 3
Particulate 1500 cpm (3x10 uCi/cm )
. m.
43 The procedure also indicated in Section 5.6.6 to refer to "Section 5.2.2 to determine activity present." However, Section 5.2 did not relate to radioactivi ty.
Section 5.12.4 provides an equation for calculating the airborne con-centration in mci /cc of particulates:
A(uCi/cc)=(1.47x10-12) (net cpm)
Using the alarm set poing of 5400 cpm A(uCi/cc) in the above equation, this calculates to be 7.9x10 umCi/cc value.
This was the equilibrium value (5400 cpm) and would occur in about a two-hour sampling period.
The CAMS were not calibrated to NBS traceable radioactive sources at a minimum of three points on each range and did not include the 20% and 80%
of full scale points.
Reevaluation of the set points is necessary to meet the established airborne criteria in Procedure HP908/2908.
Conclusions 1.
The following items are identified as significant' findings.
Improvements in these areas are required in order to achieve an acceptable program.
a.
The GM detectors for the personnel frisker units were not calibrated /
response tested with a radioactive source.
b.
Calibration of the CAMS did not include establishing reliable MPC action levels.
2.
The following items should be cansidered for improvement of the program but do not warrant inclusion af. Appendix A items:
a.
An effective inventory tracking system had not been established for HP instruments, b.
Calibration data forms were not always completed.
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44 6.0 Health Physics Facilities and Equipment Documents Reviewed Procedure No. ACP-QA-4.01; " Plant Housekeeping;" Revision No. 7; March 16, 1979.
The health physics facilities for Units 1 and 2 were comprised of the following:
Unit 1 and 2 Health Physics Technician / Foreman Offices (14'6" Unit 1).
Dosimetry isSte (14'6" Unit 1).
Instrument calibration (14'6" Unit 1).
Combined counting room and computer terminals (14' 6" Unit 1)
Respiratory decontamination (14'6" Unit 1).
Respiratory issue / testing (14'6" Unit 1).
Respiratory fit / training (Outage Building).
Training room (Outage Building).
Unit 2 control point (36'6" Unit 2 - during outage).
Related facilities included:
Contaminated equipment storage (various locations).
Equipment decontamination room (14'6" Unit 1).
Change areas (various locations).
Personnel decontamination room (14'6" Unit 1).
Medical (14'6" Unit 1).
Whole body counter (14'6" Unit 1, trailer).
Chemistry lab / counting room (14'6" Unit 1).
Contaminated instrument calibration (65' Unit 1).
Frisker stations with shielded frisking booths were situated at various location within Units 1 and 2.
Background readings at both shielded and unshielded stations averaged 100 counts per minute (cpm).
The frisking stations presented an adequate control against the spread of contamination.
45 Along with the frisking stations, in most cases, change areas were set up with bins to hold the various types of protective clothing and accessories.
The appraisers observed that change areas for protective clothing were not centralized in each unit or adequately designed.
For example, in Unit 1 Turbine Building, a change area for protective clothing was established on the 14'6" level with two coat racks, a few lockers, and no separate facilities for women.
On the 14'6" 42', 65' and 82' levels in the Reactor Building of Unit 1 change areas had been set up.
Of these protective clothing change areas, only the 82' level had lockers (3 lockers) and none of them were designed to accomodate both sexes.
Two change areas existed for Unit 2, one being on the 14'6" level and the other on the 36' 6" of the Auxiliary Building.
During the outage the 14'6" inches level change area was used by contractor personnel.
The appraisers observed that the protective clothing change areas did not provide sufficient lockers for personnel use or separate change facilities for both sexes as established in OSHA guidelines.
The appraisers observed that all of the protective clothing change areas were well-stocked for normal and emergency conditions.
However, the change areas consistently lacked lockers for the workers' use.
Permanent staff members had their own lockers in the men's and women's locker room on the 14'6" level of Unit 1 but the changing of protective clothing was not allowed there.
Contractor personnel had the use of the lockers in the Outage Building, but this was not convenient due to the distance from contaminated work locations.
In addition, the appraisers observed that personal decontamination facilities such as showers or sinks were not located within close proximity to the protective clothing change areas.
This called for the transporting of contaminated personnel over a distance to decontamination facilities, thus increasing the probability contamina-tion spread.
Housekeeping conditions in both units were unacceptable.
The appraisal team noted that numerous rooms, hallways and other available spaces had been designated as temporary radioactive material storage areas.
These areas contained a variety of contaminated tools, equipment, and waste materials.
The observed housekeeping conditions:
(1) did not comply with good ALARA practices, (2) posed fire hazards, and (3) made personnel access into and out of certain areas difficult.
Conditions at the change areas were only observed to be acceptable at the beginning of each day.
Otherwise, the floor and benches, especially in Unit 2 change areas, were cluttered with used clothing and trash.
The friskers at the 36'6" (control point) and the 14'6" levels of the Auxiliary Building for Unit 2 were found by the appraisers to have high backgrounds.
This was due to the fact that contaminated equipment storage areas were established next to them.
For example, at the 14'6" level frisking station a temporary contaminated equipment storage area consisting of five drum:, with a 150 mR/hr " hot spot" was set up during
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46 the outage.
In order to allow continued use of the frisker station, temporary shielding had been installed to reduce the background radiation level to less than 300 cpm beta gamma.
Unit 1 followed this same policy with permanently established /ences in contaminated eauipment storage areas for both units overflowing.
It was also observed that contaminated items such as ladders existed at many of these storage areas.
This suggested to the appraisers that once an item was contaminated it was never used again in a noncontaminated area.
This results in a generation of unnecessary radioactive waste.
In observing the office space available to health physics technicians and foremen, the appraisers determined that insufficient space was available to these staff members to perform their routine duties.
Specifically, counting of radioactive samples was performed in the same office as Radio-active Work Permit (RWP) issue, the documentation of survey results, and the making of coffee.
This was an unacceptable setup since the counting of samples should be performed in a dedicated counting room which did not exist.
In addition, the use of an area for respiratory fitting / training in the Outage Building was observed by the appraisers to interfere with the training of radiation zone workers.
Both of these activities were running simultaneously much of the time.
This situation was deemed to be acceptable but not desirable.
The facilities for issue, decontainination and testing of respirators, along with the current inventory of respirators, were found to be acceptable.
The appraisers observed that the facilities available for chemical analysis and sampling were adequate.
A strong emphasis was placed on cold and radioactive sample analysis segregation.
Conclusions 1.
The following item is identified as a significant finding.
Improve-ment in this area is required in order to achieve an acceptable program.
Housekeeping conditions in both units were unacceptable.
2.
The following items should be considered for improvement of the l
program, but do not warrant inclusion as Appendix A items:
a.
A dedicated health physics counting laboratory had not been established.
b.
Personnel clothing lockers were not available at the change areas.
j c.
Separate change areas were not available for female workers.
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47 7.0 ALARA Documents Reviewed Licensee Manual, " Corporate Management Program for Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable," May 1980 Procedure ACP-6.02, " Maintenance of Occupational Radiation Exposures As Low Is Reasonably Achievable," Revision 6, June 16, 1980 Procedure ACP-6.02A, "ALARA Deficiency Reports," Revision 0, February 1,1980 Procedure MAP-2.14. " Millstone ALARA Committee, July 14, 1980 Corporate 1979 Annual ALARA Report Unit 1 and Unic 2 ALARA Review Packages for Jobs Estimated to be greater than 10 man-rem fer the period January 1, 1979 - August 1, 1980 ALARA Deficiency Reports (Form SF-831) for the Period January 1,1980 -
August 1, 1980 The licer.see had established ALARA procedures that satisfied the recommendations of Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable," and Regulatory Guide 8.10, " Operating Philosphy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable."
The licensee's ALARA program contained the following elements:
A management policy statement committing the licensee to an ALARA program, Upper-level management support for the ALARA program, Establishment of an ALARA committee, Designation of individuals responsible for development and implementation of the ALARA program, Identifying the authorities and responsibilities of individuals assigned to implement the program, Description of the ALARA program, and Instructions for implementing the ALARA program.
The licensees had established an ALARA Coordinator position at each unit.
See Figure No. 1.
Each full-time coordinator was also suppcrted by additional personnel as needed.
For example, during the Unit 2 refueling outage in progress during this appraisal, three ALARA Engineers and two clerks were assigned full-time to the Unit 2 ALARA Coordinator.
The ALARA Coordinator was responsible for assuring that each ALARA review package associated with an identified job was properly
48 processed and completed regarding such items as preplanning, training, ALARA audits, post-job critiques and ALARA files.
The licensee had established various action levels for the following job categories:
Jobs Estimated At Less Than 1 Person-Rem No ALARA review was required prior to approval of a Radiation Work Permit (RWP) for jobs estimated at less than one person-rem.
The RWP requirements were intended to include ALARA considerations.
Jobs Estimated at 1-10 Person-Rem The Job / Task Leader, RPD, and the Unit Radiation Protection Supervisor were collectively responsible for the ALARA evaluation for jobs estimated between 1-10 person-rem.
The Unit Radiation Protection Supervisor was responsible for the final pre-job ALARA review.
Copies of the ALARA review were reviewed by the Health Physics Supervisor and forwarded to the Unit ALARA Coordinator for post-job review and record retention.
Jobs Estimated At Greater Than 10 Person-Rem The Unit ALARA Coordinator and the Job / Task Leader were responsible for completion of the ALARA review package associated with jobs estimated at greater than 10 person-rem.
Included as part of the revicw was a meeting including the Station Services Superintendent, Unit Superintendent, Health Physics Supervisor, Jcb/Taks L'eader and the Unit ALARA Coordinator to discuss ALARA controls for the job.
Discussions with the Unit ALARA Coordinators revealed that the necessary information was not always available to permit the completion of the ALARA review package in a timely manner.
For example, when the appraisal team started their appraisal of the licensee's Unit-2 ALARA program on August 12, 1980, 11 jobs had been identified as expected to exceed the 10 person-rem level.
However, the ALARA review packages had not been completed for seven of the jobs even though the refueling outage was scheduled to begin on August 16, 1980.
The ALARA Coordinator stated that the following problems prevented completion of the ALARA review packages in a timely manner:
(1) Poor coordination existed between corporate engineering and the ALARA group.
The ALARA Co'ordinator stated that in many instances where the job was initiated by corporated engineering, the responsible ALARA review group did not receive early notification of the proposed job.
As a result, an ALARA evaluation was not started during the initial stages of the job.
(2) The Job / Task Leaders were not designated in a timely manner to allow adequate time for proper job revitw and training between the Job / Task Leader and the ALARA group.
For the 1980 Unit 2 refueling outage, certain jobs were identified several months prior to the rocheduled outage.
However, the designation of Job / Task Leaders had not yet been made two weeks prior to the outage.
(3) The selection of offsite contractors that would be responsible for completing the scheduled jobs was not accomplished in a timely manner.
Essentially, the same problems existed regarding the
49 selection of contractors as with the designation of Job / Task Leaders.
The selection of contractors had not been made two weeks prior to the outage.
This delay resulted in the ALARA training for contractor personnel being cramped into a limited time frame.
The appraisal team noted that individuals with very little practical health physics experience were selected as ALARA Coordinators.
The position description for ALARA Coordinator required a Bachelor's Degree in a science or engineering discipline related to health physics or equiva-lent professional experience.
The Unit 1 and Unit 2 coordinators had been in their positions for about one and two years, respectively.
Both individuals had been hirc.d directly cut of college and had only limited professional haalth physics experience prior to accepting the coordinator positions.
As such, initially the coordinators did not have extensive health physics backgrounds to rely on when conducting an ALARA evaluation.
Conclusions The ALARA program is considered adequate.
The following items are identified for improvement of the program, but do not warrant inclusion as an Appendix A item:
a.
A program had not been established to provide early coordination between corporate engineering and the ALARA group.
b.
Selection of Job / Tasks Leaders and offsite contractors had not been made.in a timely manner to allow adequate time for ALARA review and training.
c.
Individuals with limited practical health physics experience had been selected to fill the ALARA coordinator positions.
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50 8.
Audits Documents Reviewed Licensee Manual, " Corporate Management Program For Maintaining Occupational Radiation Exposures As Low As Reasonably Achievable," Part B-Procedure No. 3, Audits of the Station's Health Physics Program, Revision 1, April 28, 1980 Monthly, quarterly and special corporate audit results of the Millstone health physics program for the period January 1, 1979 - July 1, 1980 Procedure ACP-8.03, " Health Physics Training and Retraining For Company and Contractor Personnel," Revision 2, September 8, 1978 Procedure ACP-8.01, " Millstone Station Training," Revision No. 1, January 10, 1980 Procedure ACP-QA-9.01, " Internal Inplant Audit Program," Revision 7, October 12, 1979 Procedure ACP-QA-9.05 " Monitoring of QA Activities" Site Audit No. A58010, " Chemistry - To Verify Compliance with Applicable ACPs and USNRC Regulatory Guide 4.15," April 1, 1980 Site Audit No. A58002, " Health Physics, Radwaste, ALARA - To Veri *y Compliance with Applicable Procedures," January 25, 1980 Site Audit No. A50241, " Chemistry - Verify Compliance with Applicable ACPs and Chemistry Procedures," October 29, 1979 Site Audit No. A50239, " Audit of Low Level Radioactive biaste Transfer, Packaging and Transportation," September 6, 1979 l
Site Audit No. A50216, " Health Physics - Verify Compliance with the ACPs Governing Operations of the Health Physics Department," January 8, 1979 Nuclear Review Board (NRB) - Audit Procedure, March 29, 1978 Nuclear Review Board Audits:
(1) NRB Audit 79-1, August, 1979, (2) NRB l
Audit 78-2, December, 1978 l
l PROGRAM Audits of RPD activities were performed by the following organizations:
Corporate - Radiological Assessment Branch (RA3)
Nuclear Review Board Site QA/QC
51 Corporate - Radiological Assessment Branch (RAB) Audits The RAB had established a detailed audit program.
The RAB audits covered the following areas:
External Exposure Control Dosimetry Radiation Work Permits Surveys Posting Control of Posted Areas Personnel Contamination Control Radioactive Material Control Control of Airborne Areas Respiratory Protaction Internal Dosimetry Portable Instrument Calibration Source Inventory and Leak Tests Radioactive Shipments l
Counting Room Instrumentation Area Monitors ALARA Procedures Radiological Emergency Plan Training Reports and Notifications to Workers l
Special HP Procedures The RAB performed monthly onsite audits.
The audit schedule was such that each area listed above was audited at least annually.
The RAB auditors had considerable inplant health physics experience l
prior the joining the corporate RAB.
As as result, the auditors l
were familiar with the requirements for an adequate health physics i
program.
For each area audited, the audit procedures listed the requirements (10 CFR 20 & Technical Specification) that were used while conducting the audit.
52 The RAB audit procedures included formal documentation of audit findings and the plant's response to identified deficiencies.
It was noted that the plant had responded in a timely manner to the identified deficiencies.
In addition to the routine monthly audits, the RAB also performed special audits prior to refueling and/or major maintenance outages.
Nuclear Review Board Audit Section 6 of the Technical Specifications requires the Nr.B to perform annual audits of RPD activites.
Input for the NRB audit reports consists of findings identified during the routine RAB audit pro-gram.
As such, independent NRB audits were not performed.
The NRB audits usually included a summary of RAB findings.
Onsite QA/AC Audits The onsite Quality Services Department also conducted aun ts of RPD activities.
These audits were designed to ensure that approved RPD procedures were followed.
The audit format included the selection of specific RPD procedures and verification by the auditors that the procedures were satisfied.
The onsite QA/QC audit group did not have a member with a health physics background.
Therefore, the audit findings only included the failure to adhere to the steps included in a particular procedure.
The audit reports did not contain comments regarding suggested changes to existing procedures or the RPD program based on the auditor's professional health physics experience.
Responses to the onsite QA/QC audit findings were made in a timely manner.
==
Conclusions:==
The audit program is considered adequate.
The following item is identified for improvement of the program, but does not warrent in-clusion as an Appendix A item:
The onsite QA/QC group did not include a member with practical health physics experience during audits of the RPD.
t 53 1
9.0 Radiation Protection Procedures Documents Reviewed Procedure HP-4901, " Document Control," Revision 0, 7/1/80 4900 Series, " Controlled Standardized Health Physics Procedures," Issued By the Corporate Office.
900/2900 Series, " Millstone Health Physics Procedures," Issued by the Onsite Radiation Protection Department.
800/2800 Series, " Millstone Chemistry Procedures," Issued by Onsite Chemistry Department.
Selected Administrative Control Procedures (ACP)
PROGRAM 1
The appraisal team spent considerable time reviewing the procedures listed under " Documents Reviewed" in the various sections of this appraisal report.
The procedures were reviewed basically for format and content. -The appraisal team believes that quality procedures are a vital element to ensure a successful radiation protection program.
Proper procedures are necessary to provide guidance for the radiation protection department staff during daily work activities and to ensure the continuation of established work practices when personnel changes occurred within the department.
The appraisal team did note that there were a few instances where failure to follow procedures did occur, but overali the licensee appeared to comply with their existing procedures.
The appraisal team was concerned that j
procedures were not always written in sufficient detail to provide adequate guidance.
Most of the significant findings identified in the " Conclusions" for the various sections of this report occurred because procedures did not t
include adequate guidance to perform the required function.
The RPD procedures followed the generic style recommended in ANSI N18.7-1976,"
Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants," and Regulatory Guide 1.33, " Quality Assurance Pro-gram Requirements."
It was noted that the word "should" was frequently used to denote a requirement instead of "shall" as recommended in ANfi N18.7-1976.
This concern had also been identified by the licensee through an in-house QA/QC audit conducted in June 1980.
Most of the RPD procedures i
had been revised or re-issued during the previous year.
The RPD staff stated that they were given an opportunity to provide input during the 4
development and review of the procedures.
Several HP technicians stated that sometimes numerous procedures were issued as a group and adequate time was not allowed to review each procedure and become familiar with its content before it was put into use.
Conclusions 1.
The following item is identified as a significant finding.
Improvement in this area is required in order to achieve an acceptable program.
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Procedures did not always provide sufficient guidance in order to perform the required function.
2.
The following items should be considered for improvement of the program, but do not warrant inclusion as Appendix A items.
a.
The use of words "shall", "should," and "may" in RPD procedures did not agree with the recommendations of ANSI N18.7-1976.
b.
Procedures were sometimes put into use before the staff had adequate time to review the procedures and become famiitar with their content.
10.0 Administration of Emergency Pla.,
10.1 Responsibility Assigned The Radiological Services Supervisor was formally assigned overall responsibility for the Station Emergency Plan and implementing pro-cedures.
He reported to the Station Services Superintendent and acted with the lattar's authority in all emergency planning matters.
The assignment was one of five major areas of basic responsibility.
The individual stated, that as a result of his other duties, he devoted approximately ten percent of his time to emergency planning functions.
The Chief, Radiological Assessment Department at NUSCO headquarters, acted as corporate counterpart to the Radiological Services Supervisor.
l He provided technical guidance and was responsible for writing the l
Emergency Plan and Emergency Plan Implementatior Procedures.
The appraisers determined that although adequate resources were being devoted to the administrative aspects of the emergency planning program, discrepancies found during the health physics appraisal appeared to indicate lack of a unified management approach.
The diversity of the functions assigned to the Radiological Services Supervisor (a total of twenty-two) impeded the over-all coordination and control necessary to integrate all aspects of the emergency planning program.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be con-sidered for improvement:
Provision of a unified approach to emergency planning it the site by assigning n individual at the site to the over-all coordination, review and follow-up of all emergency planning and preparedness functions, including field testing of procedures and eouipment.
l l
55 11.0 Emergency Organization 11.1 Onsite Organization 1he appraise:'s reviewed the licensee's Emergency Plan and Implementation Procedures and held discussions with licensee personnel to evaluate the adequacy and clarity of the onsite emergency organization, includ-ing assignment of emergency duties and responsibilities.
The functional areas of emergency activity of the onsite emergency organization were as follows:
Functional Area of Emergency Activity Location Personnel Assigned Site Emergency Organization Site Emergency Statian Superintendent Directcr Operations Center or Unit Superintendent (EOC) or Station Services Superintendents Manager, Control Room Control Room Shift Supervisor Operations Manager, Onsite Technical Site E0C Duty Officer Support Manager, Radiological Con-Site Technical Health Physics Supervisor sequence Assessment Support Center or Chemistry Supervisor (TSC) or Radiological Services Supervisor or Health Physicist or Chemist or ALARA Coordinators Manager, External Commu-Site EOC Training Department nications Personnel Manager, On-Site Resources
.On-Site Resource Maintenance Supervisor Center or Instrument & Control Supervisor or General Services Supervisor Manager, Security Site EOC Security Shift Superviser Manager, Site Engineering Site EOC Quality Assurance Support Supervisor or Quality Assurance Engineer
56 Each of the above emergency managers had distinct functions to perform covering the various emergency response activities, as follows:
Emergency Manager Function Site Emergency Organization Director Supervision / coordination of all site emergency operations Notification of local, State and Federal authorities Manager, Control Initial Classification of Room Operations Accident Notification of Site and Corporate Management Mitigation of Consequences Notification of Duty Officer Manager of Radiological Consequence Assessment Dispatc5 of On-Site and Off-Site Monitoring Teams Dose Projections Health Physics Meteorological Data Acquisition and Release of Information Manager of Technical Provision of Technical Advice Support Center to Director, Site Emergency Organization and Control Room Operations Development of Out-of-Normal Operations Procedures Manager of External Provision of Official Technical Communications Reports to Government Agencies Provision of Technical Information to Northeast Utilities Repre-sentative Provision of Summary of All l
Managers' Logged Reports l
Manager of Security Establishment of Security Assistance in Personnel Accountability l
Manager of Onsite Resources Center Accountability of Personnel Identification of Personnel and Specialties Determination of Equipment Availability Personnel Search & Rescue 1
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57 Emergency Manager Function Manager of Site Engineering S oport Quality Assurance Records Plant Procedures Engineering Drawings and Plant Systems The appraisers noted that the licensee's description of the site's emer-gency organization did not clearly specify all emergency functions at the working level.
There were no organizational delineations regard-ing the levels of the hierarchy for the following emergency functions:
personnel monitoring and decontamination, repair and corrective actions, and radiation protection.
Some of these ware implied within the general term " health physics" (e.g., personnel monitoring and decontami-nation, radiation protection) while other functions were not addressed.
The licensee's Emergency Plan did not clearly provide for a Site Emer-gency Organization Director at all times, including an individual onsite at the time of the accident, having the authority and responsibility to make the notification to outside agencies.
The Emergency Plan called for the Shift Supervisor to initially classify the event, but the notification of federal, state and local agencies was left to the Duty Officer.
A revision of Emergency Plan Implement-ing Procedure OP501/2501, Rev.10, dated 7/12/80, paragraph 2, clearly assigned to the Shift Supervisor the responsibility and authority to act, in effect, as Site Emergency Organization Director until relieved.
This revision was reviewed by the auditors during this appraisal.
The licensee's Emergency Plan and Implementing Procedures clearly specified the functional responsibilities assigned to the Site Emer-gency Organization Director, but did not explicitly indicate which of these actions may be delegated to other members of the emergency organization.
The concept of operation for site persor... I during periods of minimal staffing (e.g., backshifts, weekends) was not clearly addressed in the Emergency Plan or Procedures.
Guidelines were not provided for the optimum use of personnel during periods of minical staffing, so that diverse functions were assigned to be simultaneously performed by one individual.
As an example, various actions are to be parformed during the same time-frame by the health physics technician during a Site or a General Emergency.
The licensee had specified the persons who may be assigned to manage the various emergency functions.
For these emergency managers the authorities, responsibilities and actions were specified.
The assign-ment of persons to emergency functions at a working level, however, were not specified, except for members of the Emergency Radiation Monitoring Teams.
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58 The Emergency 7'an and Implementing Procedures did not clearly establish the relationship between the normal job titles and the emergency organization for other than management personnel.
In a similar manner, the relationship between the NUSCO headquarter's normal and emergency response organizations was unclear.
The licensee had made limited provisions for continuous emergency organization operation, iricluding man power planning.
The Manager of the Onsite Resources Center is responsible for identifying specialties of persons at the Onsite Resource Center and organizing station person-nel for relief shift work.
The corporate (NUSCO) Manager of Resources is responsible for coordinating the acquisition of manpower and equip-ment from within Northeast Utilities or from contractors and consul-tants to support continuous emergency organization operation.
Based on the above findings, improvement is required in the following area to achieve an acceptable program:
Conclusions a)
Provisions were not established for a specific and complete organizational delineation, reaching the icwer levels of the emergency command hierarchy to include non-supervisory personnel, for all the distinct emergency functions including:
personnel monitoring and decontamination, repair and corrective actions, and radiation protection during emergencies.
In addition, the following items should be considered for improvement:
b)
Specification of which actions are not to be delegated by the Director of Site Emergency Operations.
I c)
Clarification of the concept of operation for site personnel during periods of minimal staffing and provide guidelines for the optimum use of personnel under those conditions by providing procedural specification 3 regarding priority actions.
d)
Clarification of interfaces between the normal and emergency organizations including the relationship between normal and emergency assignments for other-than-supervisory personnel.
e)
Clarification of interfaces between corporate and site emergency functions.
l
59 11.2 Augmentation of Onsite Organization The licensee's Emergency Plan identified corporate personnel who will augmcat the plant staff in the areas of environs monitoring, logistical support for emergency personnel, technical support for planning and re-entry / recovery operations, notification of govern-mental authorities, release of information to news media, and coor-dination with governmental authorities.
The licensee also had plans for supplementing the health physics staff beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under accident conditions.
Contractors and private organizations who may be requested to provide technical assistance and augmentation of the emergency organization were identified in agreement letters which appeared as an appendix to the licensee's Emergency Plan.
Letters of Agreement specified the organizational capabi'ity to be provided, including ambulance, medical, hospital, and fire fighting organization.
The authorities, responsibi-lities and limits on the actions of the contractors, private organi-zations, and local services support group were also specified in the Letters of Agreement.
Conclusions Based on the above findings this portion of the licensee's program appears to be acceptable.
12.0 Emergency Training / Retraining The licensee's program for training employees who were assigned em ugency duties was described in Sectior 9.1 of the Emergency Plan and in Adminis-trative Control Procedure, ACP 8.06, Rev. 5, " Emergency Plan Training",
dated 2/19/80.
In addition, several memoranda from the Station Superinten-dent, referred to the need for ret vining in aspects of related to the
" lessons learned" from the Three Mile Island incident.
Training / retraining for members of the onsite emergency organization was required to be performed on a semi-annual basis.
In addition, training /
retraining was required to be performed annually for the offsite partici-pating agencies as listed in Appendix Z of the Emergency Plan Procedure (OP 501/2501) with attendance being on a voluntary basis.
In accordance with the Emergency Plan, training was performed within the following five categories:
60 Emergency Plan This training for all new employees consisted of one training session reviewing the scope, emergency classifications, and required actions by individuals.
Site Emergency Organization Managers This training included items applicable to the responsibilities and actions of 'fe various emergency managers during emergencies.
Emergency Monitoring Team Training for personnel assigned to Emergercy Monitoring Teams which included operation of instruments and interpretation of results.
Fire Team (Fire Brigades)
Training for personnel assigned to fire teams and included handling fire and rescue apparatus, fire prevention, fire fighting techniques, emergency breathing apparatus, radiological hazards, etc.
The auditors reviewed documents and records related to emergency training, and held discussions with training instructors and with licensee personnel assigned to the various functional areas of emergency activity.
l Training was documented in the form of date entries and test scores received l
for the following categories:
Site Emergency Operations Directors, Managers Site Engineering Support, Managers of Communications, Managers of Onsite l
Resources, Managers of Radiological Consequence Assessment, Emergency Duty Officers and Emergency Monitoring Team members.
The majority of the Site Emergency Organization Managers training for 1979 l
occurred during the end of December.
Several emergency Duty Officers received their last training in November and October 1979 according to training records reviewed.
Two persons who started to work after January 1980 and were assigned to be emergency managers had no documented Emergency l
Plan training.
Telephone conversations with these individuals revealed that they had only received self-training in the form of reading material.
Other emergency Duty Officers stated that they had received emergency train-ing as late as July 1980, although no documentation to that effect was found.
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61 The content of the tests given to emergency managers showed that, in some cases, (e.g., Manager of Control Room Operations, Site Emergency Organiza-tion Director) the verification of vit?1 emergency actions (e.g., classifi-cation of emergencies) was not addressed.
Discussions with Shift Supervi-sors indicated that there was a need for more extensive training in the classification of emergencies.
Actual training consisted largely of assigned reading materials, and self-administered tests.
During discussions with a number of members of the environmental Emergency Monitoring Teams, individuals stated that training had been of a general nature and had not included practical exercises to make them familar with 1
instruments and procedures.
To verify the adequacy of the training of the i
Emergency Monitoring Teams, the appraisers randomly selected several individuals assigned to Emergency Monitoring Teams and requested that tney demonstrate the collection and analysis of a sample in accordance with the pertinent Emergency Plan Implementing Procedures.
During these practical exercises, some merabers of the Emergency Monitoring Teams did not know where to find the instruments required to perform their emergency function.
In other cases they did not know which instruments were to be used or how to operate them.
Still others were not familiar with the procedures and were unable to identify the proper procedure in order to perform their 4
assigned duties.
The licensee had lesson plans for some of the emergency functions, includ-ing emergency managers and Emergency Monitoring Teams, but not for other emergency functions such as:
search and rescue, decontamination, repair /
corrective action, radiation protection during emergencies, and plant chemistry.
The lesson plans that were available contained clearly stated student per-formance objectives.
The appraisers could not, however, based on training records, determine that all required training had been completed.
In some cases records did not reflect the scope, content or nature of the training that actually took place.
In other cases, there were no attendance records.
Discussions with personnel, however, corroborated that training did take place.
Based on a review of existing lesson plans and discussions with licensee personnel, the appraisers determined that training did not include information on what might be expected under unusual plant conditions (e.g., components and areas with high radiation levels, magnitude of radiation increases, changed nuclide composition, etc.).
The initial training and periodic retraining programs had not been integrated under the Training Department.
As a consequence, the Training Department only trained Emergency Monitoring Teams.
Emergency managers trained themselves through reading material and self-administered tests, followed by a discussion of the test content.
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62 There was no formal emergency training program in radiation protection during emergencies for:
Chemistry, Repair / Corrective Action Teams, Search and Rescue Teams and state and local agencies.
The appraisers also determined that there was no training documentation for offsite agencies with the exception of a letter dated August 27, 1979 to the Jordan Fire Department in Waterford, Connecticut.
In this letter the licensee invited the Jordan Fire Department personnel to attend training ses-sions.
Discussions with the Training Coordinator indicated that formal training sessions for offsite agencies had yet not been conducted during i
1980 as required by their Administrative Control Procedure ACP 8.06 "Emer-gency Plan Training", Rev.
, Paragraph 6.5.
The Training Coordinator stated that offsite agencies had been invited to participate in annual drills, but that other formal lecture / discussion-type training had not been conducted.
Training of the onsite emergency srganization did not include practical exercises and/or tests in which each individual demonstrated his ability to perform his assigned emergency function and where on-the-spot correction of erroneous or inadequate performance could be made with addi.tional training.
In some cases, the instructor only briefly demonstrated some aspects of the expected performance.
The training program did not specify the frequency, scope and nature of the emergency training to be provided to the different categories o# emergency personnel.
Provisions to evaluate the ability of the individuals to per-i form their emergency duties had only been considered for the emergency managers.
Even in this case, however, conditions, tasks and standards of performance to make this performance evaluation were lacking.
Tests, when used, were nominal and general in content.
They did not address the i
required actions of the individuals.
For other functions of the emergency organization, at the working (team) level, there were no testir.g or evalua-tion requirements of any kind.
Documentation of trainiag was inadequate in that training records did not reflect all the training that had taken place, and were not specific enough l
to clearly identify who was trained, the content, depth and scope of train-j ing, or by whom the training was performed.
The appraisers determined that one of the reasons for this appeared to be that training responsibilities and i
training records were spread throughout the facility.
In the case of emergency managers, one of the managers was selected to conduct training for each type of emergency manager category.
It was his responsibility to transmit records to the Training Department.
The only emergency response group actually trained by the Training Department was the Emergency Moni-toring Team.
This group consisted of 106 people selected from different work areas, (e.g., Shift Supervisors, Cperators, Plant Equipment Operators, Chemistry Technicians, etc.).
Training records for this group did not
63 specify when the training took place, the subject or topics covered, the scope and depth, or the type of evaluation and results.
No attendance lists were available.
The only records available were dates and names, which indicated when training was given.
The appraisers held discussions with a number of emergency team members who stated they had received no training related to their specific emergency function and any training they received was of a general nature, lasting one hour or less.
A small per-centage of those interviewed believed they would be able to perform pro-perly.
This conclusion was mainly based on their training and experience at facilities other than Millstone Point.
The individuals responsible for conducting each category of emergency training were not specified by position or title nor were there formal selection or qualification criteria for instructors.
Furthermore, there were no provisions to train members of the emergency organization in changes to procedures and equipment which may have occurred in the period of time between the scheduled training / retraining sessions.
Conclusions 1.
Based on the above findings improvements in the following areas are required to achieve an acceptable program:
a)
Lesson plans were not developed for each functional area of emergency activity including:
Emergency Repair / Corrective Action, Search and Rescue, Radiation Protection During Emergencies, Radiochemistry and Training for Offsite Agencies.
b)
Means were not provided to evaluate the ability of each individual to perform his emergency duties through the development of stand-ards of performance or a method for qualifying personnel in their assigned emargency functions.
2.
In addition, the following matters should be considered for improve-I ment of this area:
a)
Development of a centralized system for maintaining emergency training records to adequately document all training / retraining, including attendees' names, location, date, time, instructor, subject, scope of topics covered, tests given, practical exer-cises, individual performance appraisal, etc. for each emergency function.
I b)
Provision of a means to train all members of the emergency organi-zation in any pertinent changes to procedures or equipment which occur in the period between the scheduled training / retraining sessions.
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64 c)
Specification by posi+ ion or title of the individuals who are responsible for conducting each category of emergency training, and the formal selection and qualification criteria to be applied to these instructors.
13.0 EMERGENCY FACILITIES AND EQUIPMENT 13.1 Emergency Kits and Emergency Survey Instrumentation The licensee had pre positioned emerger.cy supplies and survey instru-mentation at various specified locations throughout the facility.
Emergency kits and equipment were found to be located as specified in the plan and procedures.
Procedure HP909/2909, " Routine inspections, inventory and calibration of equipment", provided a listing of equip-ment to be found in each of the specified locations and established a monthly frequency for inspection.
The appraisers reviewed records of the last twelve inventories and verified that they had been properly performed.
The appraisers noted that the inventory procedures contained several ambiguities.
The inventory list for the Emergency Operation Center (E0C) referred to " twelve portable dose rate meters" and the list for the Alternate E0C referred to "six portable dcse meters" without speci-fying the type of instrument required for the type and magnitude of the radiation fields and the specific uses expected during an emergency.
l This same ambiguity appeared on the inventory list for onsite radiol-ogical kits.
(See Section 14.5.1 below) The broad designations in the listing could result in the placement of any type of " portable survey meter" (and not necessarily the type with the intended detection and response characteristics in the emergency kits).
Furthermore, the inventory also gave a choice between one instrument / detector (PS-2-2/
HP210) or an equivalent type without specifying which ones would be equivalent.
This could result in the substitution of equipment for which the operating characteristics have not been considered.
Since this instrument was intended for use in radioactive measurements sub-stitution could result in erroneous airborne radiciodine determinations.
Equipment to be used by teams re-entering the facility, or portions l
l thereof, did not include provisions for extremity monitoring or for the l
detection and measurement of radiation fields up to 1000 R/hr.
There were, however, instruments capable of measuring up to 1000 R/hr located at the Alternate E0C.
The licensee had the capability to detect ans measure radioiodine concentrations in air with a sensitivity of at least 5 x 10-8 mci /cc for gross beta gamma determinations.
The counting instrument used was 1
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9 65 an Eberline PS-2-2 scaler coupled with a HP210 shielded beta gamma probe.
The licensee used silver-loaded silica gel cartridges as the samplinp media.
The appraisers noted that with this detection system, a high radiation background due to the presence of noble gases from a plume would incresse the minimum level of detectability.
In order to prevent this, the user would have to move to a low background area to perform the analysis.
The licensee's procedure HP909/2909, " Routine inspections, inventory and calibration of equipment", (Rev. 7), included routine battery and instrument response checks for emergency instrumentation as part of the monthly inventory.
However, adequate operability (i.e., reproduci-bility of measurements) checks were not performed on emergency survey instrumentation.
The appraisers held discussions with the licensee to emphasize the need for each test, before instrumentation is used.
(See Section 14.5.1 below.)
The licensee had a policy of maintaining an adequate state-of-the-art supply of survey instrumentation.
Engineering personnel at the NUSCO corporate headquarters have a continuing program to evaluate new instrumentation.
As a result, new portable scalers, Eberline Model PS 2-2 and silver-loaded silica gel cartridges where introduced.
In addition, high range detection instruments (i.e., teletectors) and continuous airborne monitors were placed on order to further upgrade the emergency instrument inventory.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following improvement item should be considered:
Provision of high range (up to 1000 R/hr) survey instruments in EOC emergency response cabinet.s or kits to be used by teams who may reenter the facility.
13.2 Fixed Facilities and Instrumentation for Radiological Accident Assessment l
l 13.2.1 Area and Process Monitors The appraisers inspected read-outs of area and process monitors located in the control room and noted that all monitors were available and operable.
Monitors were determined to have sufficient operating l
characteristics to access the accident conditions for which the Emer-gency Plan was designed to cope.
l
66 In addition to the fixed process monitcrs, the licensee installed two post-TMI, high-range stack monitors.
The readings have been correlated with gaseous effluent emissions through the stack and are used to determine stack release rates.
One of these monitors was common to both Millstone units.
Different conversion factors are applied depending upon the unit from which the release is coming.
The second high-range monitor was connected to Unit 2 roof stack and vent to monitor any release through that pathway.
Both detectors were shielded to preclude the adverse effects of high background radiation which may occur during accident conditions.
Readout locations were such, that they appeared to be readily observable.
The appraiser discussed the calibration methods of fixed area and process monitors with Instrumentation and Control Department personnel.
Calibra-tions were performed using two sources, both of which yielded count rates in the same region of the monitors' range instead of using the source strengths which would cover a broader region of the monitor's range so that linearity could be verified for the significant region of the entire range.
(See Section 5.0 above.)
Conclusion Based on the above findings, with the exception of the calibration item discussed in Section 5.0 of this report, this portion of the licensee's program appears to be acceptable.
13.2.2 Meteorologicil Instrumentation Tl asee's meteorological instrumentation consists of wind speed, wi.. alrection, temperature and relative humidity sensors, located on a meteorological tower, at various heights from 33 feet to 447 feet.
In addition, there is a capability to obtain temperature l
differences between the various elevations.
I Meteorological readouts were located in a small building at the bottom of the met.eorology tower, the Millstone Unit I Control Room and the l
NUSCO corporate headquarters in Berlin, Connecticut.
Readouts in the Control Rocm and at the site meteorology tower were both analog and digital.
The licensee had no provisions for vital or redundant power.
Provisions were made, however, for obtaining representative, real-time meteorologi-cal information through Traveller's Weather, Inc. in the event there was an onsite power failure.
The appraiser noted that existing dose l
assessment procedures made no reference to this backup provision (see Section 14.4.8 below.).
Meteorological instruments were being maintained on a routine schedule.
Operability checks were performed weekly.
Operability checks and calibration were performed in accordance with
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67 written procedures al.d appeared to be adequate.
Inoperable instrumentation was promptly restored, as shown by the ifcensee's calibration, operability and maintenanca records.
Conclusions Based on the above findings this portion of the licensee's program appears to be acceptable, but the following matter should be con-sidered for improvement:
Provision of vital or redundant power for ontite meteorological instrumentation.
13.3 Emergency Communication Equipment The licensee's emergency communications equipment was found to be con-figured and located as specified in the Emergency Plan and Procedures.
The licensee utilizes a siren type alarm to indicate a radiological emergency, and/or the need for evacuation of personnel, and the public address system in the event of fire.
The licensee did not have dif-ferent alarms to indicate distinct events.
The licensee had provisions for testing the site evacuation alarm ca a mnnthly basis, bot no provisions for routinely checki.ig the operability of other emergency communication device and equipmeat.
Communication links had backups.
The site E0C had dedicated telephone lines to various key offsite agencies (state, local, and NRC) and regular telephone lines were available as backups.
Additional communi-cations were available in the control rooms in the form of:
State and Waterford Police radios, CONVEX (Connecticut Valley Exchange) radio, telephones and Gaitronics plant paging system.
The site EOC and control room had backup supplies of batteries to power telephones #or approximately eight hours.
l The appraisc.s concluded that onsite and offsite communirst;ons appeared l
to be adequate to support the performance of vital funct vis in trans-mitting and receiving information throughout the course of an emergency.
Conclusions Based or the above findings, this portion of the licensee's program l
appears to be acceptable.
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68 13.4 Emergency Operation Center (s)
The licensee had a principal Emergency Operation Center (EOC) from which the direction, evaluation and coordination of all activities related to an emergency would be performed.
The principal EOC was located on the third floor of the Condensate Polishing Facility Build-ing and was used routinely as a classroom.
This building was located between the Units 2 and 3 Turbine Buildings.
The Alternate EOC (AEOC) was located at the licensee's Niantic Information Center in Niantic, Connecticut.
The location of both EOCs appeared to be adequate.
Both, the E0C and AEOC had the equipment and supplies required to perform their mission, including: low and high range beta gamma survey meters; air samplers with capability for particulate and radioiodine sampling; personnel dosimetry devices; check sources; copies of the site Emergency Plan and Implementation Procedures; state and local emergency plans and procedures; site map (USGS 7 1/2 minute map marked with cardinal polar coordinates and 22 1/2 degree sectors, with the first sector splitting North and covering the plume response emergency planning zone); applicable sections of the FSAR and Environmental Report; isopleths; survey forms, to include some plant layouts; writing materials and note pads; a clock; and communication devices (e.g., telephones, portable radiotransmitters, etc.).
The E0C and AE00 were found deficient in the following emergency equipment / supplies:
first-aid kits; monitoring equipment capable of quantitatively differentiating between various radionuclides; sufficient number of personnel dosimetry devices (e.g., there were only 10 TLDs at AE0C); drawings /models/ photos / plant layouts for job planning and training for re-entry; ar.d decontamination supplies.
The map had to markings for pre-selected monitoring locations to indicate where monitoring teams would be sent or for indicating TLD or environmental sampling locations.
There were also no provisions for emergency power in either Emergency Operation Center.
Conclusions Based on the above findings this portion of the licensee's program appears to be acceptable, but the following matters should be consid-ered for improvement:
a.
Provision of E0C/AE0C monitoring equipment capable of quantitatively differentiating between variour radionuclides.
69 b.
Establishment of pre-selected locations on maps to indicate environmental monitoring points and fixed environmental TLD and air sampling locations.
c.
Provision of drawings, photos and plant layouts in the EOC/AEOC for reentry planning and training.
d.
Expanded provisions for dosimetry devices to accommodate the number of persons expected to perform various emergency functions at the E0C or AEOC.
e.
First-aid and decontamination supplies at the EOC/AEOC.
f.
Emergency power for the EOC/AE0C.
13.5 Medical Treatment Facilities The licensee maintains onsite provisions and facilities for the treat-ment of individuals who may be injured and/or contaminated.
A first-aid station is located on the first floor of the Service Building.
It is normally staffed by a registered nurse during the day shift.
During outages a registered nurse is onsite at all times.
The first-aid facility was accessible to a stretcher being carried by two individuals.
It was located in the same building / floor as the decontamination shower, which was adjacent to the Health Physics Control Point.
The head nurse indicated that injured / contaminated personnel were decontaminated at the Health Physics Control Point.
The nurse on duty performs decontamination by flushing with sterile water and washing the area with soap.
Radioactivity measurements are performed by health physics personnel using survey instruments available at their station.
There were communications readily available (e.g., telephone, and public address system) and various stretchers and first-aid kits were located throughout the facility.
Procedures for treatment and decontamination of personnel were avail-i able.
(Health Physics Procedure HP932/2932, Rev. 3; and Medical Directives, A0 Mac Donga11, 4/3/80).
No decontamination supplies were available at the first-aid station.
The licensee appeared to maintain adequately located and luipped first-aid treatment areas to handle injured and/or contam.nated workers.
Arrangements for treating contaminated and/or injured patients had also been made with the Lawrence and Memorial Hospital in New London l
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70 and the Middlesex Memorial Hospital in Middletown, whose hospital staffs were trained and equipped te handle such patients.
Additional medical consultation services had been arranged with the Radiation Management Corporation.
Conclusions Based on the above findings this portion of the licensee's program appears to be acceptable.
13.6 Decontamination Facilities The licensee had provisfors for personnel decontamination on the first floor of the Service Building, in close proximity to the Health Physics Control Point and the onsite medical facility (first aid station).
The licensee had not, however, made provisions for decontamination at each personnel assembly / reassembly area.
Only water and one decontaminant, (e.g., detergent) were found at the dedicated decontamination shower located near the Health Physics Control Point.
No special chemicals (e.g. titanium dioxide, potassium perman-ganate, etc.) for decontamination were available.
Liquid waste result-ing from decontamination operations is processed through the liquid radwaste system.
Decontamination procedures were available at the first-aid and health physics stations.
Conclusions Based on the above findings, improvement in the following arcs is required to achieve an acceptable program:
Provisions for personnel decontamination, including stockage of necessary equipment and decontaminants were not made for decontamination in assenbly areas.
1.3.7 Protective Fpcilities and Equipment The second floor of the Condensate Polishing Facility (CPF) was desig-nated as the assembly area for all persons located inside the protected area.
Non employees located outside the protected area assemble just outside of the facility fence, in an open space, northwest of the facility.
The above assembly areas appeared to have sufficient space to accomo-dating personnel as required, however, there was no assurance that the shic!Ging and ventilation characteristics of the CPF were adequate to protect the safety of personnel.
The licensee had stocked a large number of paper coveralls, respirators with canisters, and cloth and y.-..,
71 rubber gloves in the CPF.
Portable air-samplers, friskers, silver-loaded silica gel cartridges, and a gamma radiation monitor with a high radiation alarm were also available in the general area.
There was a room available for first-aid treatment, along with one do739 first-aid kits and fifteen folding beds.
The appraisers noted that there were no decontamination provisions, survey instrumentation, or respiratory protection devices available for persons gathered at the Northwest Assembly Area.
(See also Section 13.6 of this report.)
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be con-sidered for improvement:
Evaluation of the adequacy of the Condensate Polishing Facility for use as an assembly area under emergency conditions.
13.8 Damage Control, Corrective Action end/or Maintenance Equipment and Supplies Damage control equipment consisting of fire hose stations, fire extin-guishers, fire hydrants and portable lanterns were located at various points throughout the operating units.
Self-contained breathing devices were also placed at strategic locations throughout the facility.
A chlorine tank car repair kit was available to seal the cover of the chlerine tank car in the event of valve leakage and selected spare parts were stored in the warehouse for failed equipment repair.
In addition, the licensee had " cherry pickers," cranes and snow scoopers readily available for use.
conclusions l
Based on the above findings, this portion of the licensee's program appears to be acceptable.
13.9 Reserve Emergency Supplies and Equipment The licensee relies upon the normal station inventory cf supplies to support a majority of their emergency response activities.
In some cases, (e.g., dosimetry for the environmental monitoring program and personnel dosimetry) the licensee relies on corporate support and l
Haddam Neck Plant for additional emergency survey instrumentation.
There were minimum stock levels established for expendables, such as protective clothing, polybags, etc., to ensure their availability.
The l
72 licensee appeared to have maintained stock levels to ensure their availability.
The licensee also eppeared to be maintaining adequate reserves of normal supplies to handle emergency situations.
Conclusions Based on the above findings, this portion of the licensee's prog"am appears to be acceptable.
13.10 Expanded Support Facilities The appraisers and licensee representatives discussed the work facilities required fer the increase of personnel expected during emergencies.
This aspect was not addressed in the license 1's current planning effort and should be considered for improvement.
14.0 Emergency Implementing Procedures 14.1 General Content and Format The general content and format of the licensee's procedures for imple-menting the Emergency Plan were evaluated to determine general useabi-lity.
At the time of the appraisal, the licensee had one overall Emergency Plan Procedure, consisting of twenty-five appendices.
The appendices specified the various implementation actions.
Subsequent to, and as a result of the appraisal, the licensee added one appendix and revised two others.
The licensee's procedures generally specified the individual and organizational elements having the authority and responsibility for performing tasks covered by the procedures.
Action steps were generally displayed in a sequentia' manner.
Procedural steps which required other functions to be performed did not, however, always contain references to the interfacing procedures.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Inclusion of-cross referencing in the implementation procedures to interfacing procedures.
, - -. ~ ~ _,
73 14.2EmergencyOderatingPro,cedures The appraisers reviewed a sampling of the licensee's Emergency Operating Procedures developed pursuant Regulatory Guide 1.33 for Units 1 and 2.
This review indicated that the majority of the procedures did not contain a step in the "i.nmediate action section" which required evalua-tion of emergency coaditions in relation to Emergency Action Levels contained in the Emergency Plan and Emergency Implementing Instructions, or contain instructions for classifying a situation and implementing the appropriate instructions within the Emergency Plan.
Conclusions Based on the above findings, improvement in the following area is required to achieve an acceptable program:
References in the Emergency Plan Implementating Instructions were not incorporated, nor was information provided in.the Emergency Operating Procedures to lead the user to evaluate emergency conditions in accordance with Emergency Action Levels (EALs) and take necessary actions to initiate the Emergency Plan.
14.3 Implementing Instructions The licensee had a separate procedure for each class of emergency specified in the Emergency Plan.
The classification system represented in these procedures was graded.
Each procedure specified the Emergency j
Action Levels (EALs) to be considered in implementing a response to i
(
each class of emergency.
Generally, these Emergency Action Levels were based on installed control room instrumentation.
The Imnlementing Instructions were written to orchestrate the implementU. ion of other more specific Implementation Procedures which had been developed to support tne implementation of the Emergency Plan.
In reviewing the Implementing Instructions, the appraisers held discussions l
with several Shift Supervisors and determined that the EALs for the l
Site and General Emergency categories were not clearly understood by the intended users and that the EAls did not reflect the specific instrumentation upon which the EALs were based.
The appraisers held a discussion with licensee management and expressed this finding.
As a consequence, the licensee issued a procedure change on August 21, 1980, in which the EALs for the Site and General Emergency classifi-cations were clarified.
The appraisers reviewed this change and found that it had addressed the areas of concern.
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74 Implementing Instructions were written such that the Site Emergency Organization Director's duties, responsibilities and actions were specified.
Conclusions Based on the above findings, this portion of the licensee's program appears 19 be acceptable.
14.4 Implementing Procedures 14.4.1 Notification The sequence of notifications to alert or mobilize the onsite emergency organization and supporting agencies was speci"ied for each class of emergency.
Important notifications that would be immediate in nature were incorporated into the "imrediate action steps" of the Implementing Instructions.
The licersee utilized pre planned messages, announcements and alarms for initial notifi-cations. The content and form for these notifications and a listing of persons and agencies to be notified were ir.
ded in the relevant procedures.
The means to be used to make s ti fica-tions were specified and where telephone numbers would be required, they were specified. The appraisers noted, however, that there was no authentication scheme for initial notifications to offsite authorities.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following item should be considered for improvement:
Development of means for authenticating initial notifications to offsite authorities.
14.4.2 Offsite Radiological Surveys The methods and equipment to be used to perform emergency offsite radiological surveys were specified in the procedures gaverning the activities of the offsite radiological survey teams.
The appraisers noted, however, that the licensee had no specified pre-planned survey points or routes.
(Refer to Section 13.4 above.)
The procedure for offsite radiological surveys for airborne radio-active materials had provisions for recoriing the location, time, date, instruments used (by type / serial no.), mode of instrument
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e 75 use, duration of sampling and background radiation levels.
Instructions were provided to ensure that each sample will be uniquely labeled for later identification and re-analysis.
The appraisers determined that data sheets for recording offsite direct radiation readings were inadequate, since they did not include provisions for recording information similar to that for air surveys.
The instructions for labeling environmental soil, vegetation and water samples did not include or refer to data sheets or labeling instructions which specified sufficient data for a 'anique identification of samples.
The licensee had specified the means by which sample data would be provided to the organizational element responsible for emer-gency assessment functions.
The site Emergency Operations Center had been designated as the central sample collection point.
Team communications and backup means were described in the procedures, but provisions for transportation were unclear.
Conclusions Based on the above findingss, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement:
a)
Provisions for recording radiation survey information and environmental soil, vegetation and water sampler information, which provides a unique identification of l
each reading / sample.
1 b)
Description of the means of transportation for off-site Radiation Monitoring Teams.
14.4.3 Onsite (Out-of-Plant) Radiological Surveys Emergency Plan Procedure OP Snl/2501 Appendix G, was intended to specify the methods and equipment to be used to perform emergency i
l onsite (out-of plant) radiological surveys.
The procedure had no clear provisions for recording data and did n.,t specify pre planned survey points.
The appraisers noted that form OP 501/2501-12 was listed on the inventory record for the emergency kit used by the team performing such surveys.
This I
form contained sketches of the site and space to record sample /
reading locations and radiation readings.
Other information such j
as date, time, name of individuals performing survey, instrument used, type and serial number, mode, and duration of each reading were lacking.
I l
1 76 l
The procedure made reference to communication of results by radio or telephone but did not indicate that data should be recorded and submitted at the end of the survey for further evaluation and record keeping.
Transportation for survey personnel was not addressed in this procedure.
Conclusions Based on the above findings, this portion of the licensee's pro-gram appears to be acceptable, but the following matters should be considered for improvement:
a)
Provisions for recording information obtained during the conduct of onsite (out-of plant) radiological surveys and for subsequent delivery of data to the proper element of the emergency organization b)
Clarification of t.ansportation means for onsite (out-of plant) radiological surveys.
14.4.4 Inplant Radiological Surveys The appraisers noted that there were no specified emergency imple-mentation procedures for the performance of inplant radiological surveys.
(See Paragraph 14.4.12 of this report)
Conclusions Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Provisions were not made for inplant radiological surveys during emergency conditions.
14.4.5 Personnel Monitoring and Decontamination The licensee's Emergency Plan Implementing Procedures did not provide clear guidance for monitoring all individuals leaving -
restricted areas or other areas known or suspected to be contami-nated.
Emergency Procedure OP 501/ 2501 Appendix H, addressed the monitoring of individuals assembled at the Northwest Assembly Area.
This assembly area, however, is only for non-employees outside the protected area.
The procedure failed to address the second floor of the Condensate Polishing Facility, which was the designated assembly area for all persons inside the protected area.
77 The procedures did not discuss decontamination of contaminated individuals found at the Northwest Assembly Area.
Rather, the Manager of Radiological Consequence Assessment would make an "ad hoc" determination of where and how decontamination will be done.
Licensee's Health Physics Procedure HP 4909, " Personnel monitor-ing and decontamination", made no reference to Emergency Plan Implementing Procedures, and vice versa.
Procedure HP4909 appeared to be applicable only to routine operations and not for site or general emergency conditions where the facilities and equipment described in HP4909 are unavailable due to evacuation from the facility.
4 Procedure HP4909 provided a means for recording name, of indivi-duals decontaminated and other relevant data.
It did not specifi-cally discuss radioiodine skin contamination or the logistics for decontaminating a large number of individuals.
Conclusions Based on the above findings, improvement in this area is required to achieve an acceptable program:
Procedures for personnel decontamination failed to include references to applicable Emergency Plan Implement-ing Procedures, and logistics (e.g., manpower, instru-mentation allocation) and techniques for decontaminating a large number of individuals in assembly areas during emergency conditions.
14.4.6 Evacuation of Onsite Areas The licensee's Emergency Plan Implementation Procedures did not clearly specify action levels that will require evacuation of particular areas or buildings.
The classification of an emer-gency, however, as an Alert, Site or General emergency results in the use of the p'ublic address system for announcements and the sounding of the site evacuation alarm.
Since the emergency categories are triggered by specific observable plant parameters, I
the EAL for evacuation is the declaration of the emergency.
l Within the Unusual Event category the evacuation alarm may not be l
required.
In these cases, evacuation of specific areas or build-i ings is left to the discretion of the Shift Supervisor, who is required to provide instructions over the public address system.
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78 Yellow copy - Operations Engineer QC was required to review all MWO's prior to implementation to establish inspection hold points and to identify activities to witness.
Record reviews and interviews revealed that QC had reviewed MWC's for these requirements.
A master MWO log was maintained in the maintenance office and reflected the current status of MW0's.
In addition, the Blue copies of outstanding MWO's were filed in the maintenance office by functional account numbers.
These blue copies provided a ready reference to all outstanding MW0's of a given system.
However, AD 1848.07, Section 6.2.1(4), specified the blue to the Condensate Polishing Facility Building.
In addition, Emer-gency Implementing Procedures directed personnel reporting to the site (called in) to proceed to the Onsite Resources Center (second floor of the Condensate Polishing Facility) by way of the Unit 3 Security Access Point.
The appraisers noted that primary and second-ary evacuation routes were clearly marked with conspicuously posted arrows or other visible means.
The licensee had provisions for concise oral announcements over the facility public address system to describe immediate actions for non-essential personnel.
Emergency Plan Implementing Proce-dures included reference to personnel accountability and specific procedures for performing accountability.
Although the evacuation procedure addressed the monitoring of personnel for radioactive contamination, it did not reference decontamination procedures, or provide instructions on actions to be taken if personnel in the assembly areas were found to be contaminated.
(See Section 14.4.5 above.)
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable.
14.4.7 Personnel Acco'untability l
Personnel accountability actions are the responsibility of the Manager of Security and are incorporated within each of the procedures which deal with the different types of emergency classes. According to the licensee, evacuation and accountabi-lity could be performed within 60 minutes.
Procedures did not clearly instruct security personnel to provide accountability reports to the Onsite Resources Center, which was specifically directed by procedure to provide the completed Personnel Account-ability List to the Site Emergency Organization Director.
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79 The procedures related to the Site Emergency Organization Director's actions reference the Rescue Procedure (Appendix N of the Emergency Plan Implementing Procedure) to ascertain the whereabouts of individuals reported missing.
The Site Emergency Check List, also provided space to indicate the time when rescue procedures were initiated.
The Rescue Procedure (Appendix N of OP 501/2501) basically addressed the rescue of injured personnel in high radiation areas but did not address search operations for the purpose of locating missing personnel.
The appraisers deter-mined that the procedure could, however, be used for that purpose.
Provisions for continuous accountability were not addressed by the licensee's emergency procedures.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Clear description of the responsibilities for personnel accountability, the sequence of actions to provide account-ability measures including a clear reference to search and rescue actions, and procedures for personnel account-ability.
14.4.8 Assessment Actions The system for gathering information and data upon which to base decisions to escalate, de escalate, take corrective actions, or recommend protective actions onsite and offsite was based on:
effluent monitor readings, area radiation monitor readings, offsite environmental surveys and other surveys performed by emergency personnel.
Applicable procedures identified the sources of information available to calculate the source term of releases of radioactive material, the magnitude of the release and any resulting contamination.
Action levels and protective action l
guides were specified which would be used by assessment personnel as a basis for considering or initiating emergency measures to terminate or mitigate the actual cr projected consequences deter-mined by the assessment process.
Procedures relied upon installed control room instrumentation for initial dose projections with these initial results corroborated and refined by environmental surveys.
The appraisers found no,provi-sions for initially assessing offsite radiological consequences I
l in the event all plant effluent monitors (including the post TMI interim monitor) were inoperable.
In addition, dose-assessment l
_.. _. _ _ -. _ _ _. _, _ _ _ _ _ _ _ _ _. _ _ _,. _. _ _ _ _. ~.. -. _ _
80 procedures made no reference to alternate means for obtaining meteorological information should onsite instrumentation become inoperable.
Dose assessment calculations are the responsibility of the Managers of Radiological Consequence Assessment, using data provided by offsite radiation monitoring teams.
At the comple-tion of dose assessment, the Site Emergency Organization Direc-tor would be notified of results.
It is not clear, from here how or who will provide immediate notification of state and local agencies in the event initial assessment actions indicate an actual or potential exposure to the whole body or thyroid of persons in the plume exposure emergency planning zone (EPZ) in excess of the lower limits of the Environmental Protection Agency (EPA) Protective Action Guides.
There were no clear provisions fe-trend analyses of assessment data and procedures did not call toi a continuous update of assessment information to offsite agencies who would be respon-sible for implementing protective action in behalf of the general population.
Procedures relating to assessment of offsite radiological conse-quences included provisions for environmental soil, vegetation and water sampling and analysis, but did not address the use of the data.
The appraisers determined that the assessment procedure would not provide a timely estimate of conditions due to its length and complexity.
The appraisers discussed this with the licensee.
As a consequence, the licensee, implemented a new Dose Assessment Procedure, before the end of the appraisal.
Training in this new procedure was provided to personnel assigned to perform the assessment functions.
The appraisers reviewed the new procedure and deternined that it provided a capability for a timely esti-mation o'r conditions.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following items should be considered for improvement:
a)
Incorporation of alternate source of meteorological data in the event onsite instrumentation became inoperable.
81 b)
Inclusion of clear instructions for immediate notifi-cation of agencies responsible for implementing protec-tive actions in behalf of the general population should assessment actions indicate that projected doses have exceeded or will exceed the lower limits of the established PAGs.
14.4.9 Radiological Environmental Monitoring Program The licensee had provisions for implementation of a radiological environmental monitoring program during emergencies.
The program included the assignment of duties for collection and evaluation of data relative to environmental TLDs, soil, vegetation, water, milk and animal feed samples.
The above functions would be performed under the direction of the NUSCO corporate Manager of Radiological Consequence Assessment, who forms part of the NUSCO corporate emergency response organization.
The licensee appeared to have a coordinated structure for emergency environmental monitoring.
Samples would be evaluated by the Haddam Neck plant and by Interex Corporation.
The licensee appears to have adequate TLD reading capability.
Emergency response procedures for the radiological environmental monitoring programs were incorporated in the 11U500 Engineering Operations Procedure (NE0 5.02), and in the Environmental Services Section procedures.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable.
14.4.10 Onsite First-Aid / Rescue Emergency Plan Procedure OP-501/2501 Appendix M, " Personnel Emer-gency" described pre planned response to an onsite first-aid or medical emergency.
The procedure described the action for assist-ing personnel who have become injured, excessively contaminated, potentially over-exposed to internal / external radiation, or any I
combination of these conditions.
The methods for receiving, recovering, transporting and handling persons and the interface and conditions for using offsite medical treatment facilities were described.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable.
82 14.4.11 Security During Emergencies The security measures to be p'sced in effect during emergencies were specified in the Security Procedure SEC 1231 and in the various emergency procedures for each emergency category.
Action steps in the security procedures provided a means for security and accountability during emergencies, but did not specify compensatory security measures in the event the guard-house had to be evacuated.
Cc..clusions Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following area should be considered for improvement:
Development of compensatory security measures for implemen-tation in the event the guardhouse has to be evacuated.
14.4.12 Radiation Protect!on During Emergencies The licensee's radiation protection procedures did not clearly reflect their applicability during emergencies.
Detailed organi-zational and procedural methods were not in place to cover the following areas during emergencies:
personnel dosimetry, exposure records, positive access control, dose assessment, decontamination, etc.
Conclusions Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Provisions were not made for continuity of critical radia-tion protection procedures and functions during emergency conditions.
14.4.13 Recovery Procedure OP 501/2501, Appendix P "Re-entry and recovery from an emergency condition", provided guidelines for limiting per',ennel exposures during a re-entry and recovery following an emergency.
The organizational authority for declaring that a recovery phase is to be entered was not specified.
There were no provisions for evaluating plant operating conditions in this procedure, however,
83 out-of plant as-well-as in plant radiological condition evaluations were called for prior to assuming a recovery mode.
Conclusions Based on the above findings, this portion of the licensee's pro-gram appears to be acceptable, but the following matter should be considered for improvcment:
Clarification of the organizational authority for declar-ing that a recovery phase has been entered.
14.4.14 Repair / Corrective Actions The appraisers noted that the licensee had not considered and addressed repair / corrective actions which may be necessary or prudent as part of their emergency response.
The appraisers stated that this item needed immediate attention.
As a consequence, by the end of the audit, the licensee had incorporated to their Emergency Plan Procedure OP 501/
2501, Appendix W " Emergency Repair". This procedure addressed the concept of operations for repair and corrective actions related to plant operations, briefings as to radiological conditions, personnel dosimetry, and stay times.
The procedure was reviewed by the appraisers and found to be satisfactory.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable.
14.5 Supplementary Procedures-Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies The appraisers inventory procedure for emergency surslies and equip-ment, Health Physics Procedure HP 909/2909 " Routine inspections, inventory and calibration of equipment", provided an inventory listing of all equipment reserved for use during emergencies and specified the location of the equipment.
The procedure also specified the frequency at which emergency equipment is to be inventoried and operationally checked.
Operational checks for communication equipment, however, were not addressed.
The appraisers noted that survey meters were not specified individually l
by type and model but were simply addressed as "6 survey meters".
l (See Section 13.1 above) l l
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T 84 The appraisers also noted that adequate operability (reproducibility of measurements) tests had not been developed for survey instruments used to determine the amount of airborne radioiodine.
The appraisers stated that, based on this, the licensee could not insure that the emergency instruments would provide reliable data.
Conclusions Based on the above findings, this portion of the licensee's program appears to be acceptable but the following matters should be considered l
for improvement:
a)
Specification of survey meters by type and model in inventories of emergency supplies and eqJipment.
b)
Development of provisions for operability tests for emergency radiation survey meters, to include detector systems for measur-ing airborne radioiodine.
c)
Provi ions for testing energency related communication equipment on a routine basis.
15.0 Exit Interview The appraisal team met with the licensee representatives identified under
" Persons Contacted" at the conclusion of the appraisal on August 22, 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 l
to the letter forwarding the appraisal report.
The licensee war informed that items of noncompliance would be handled in the same manner as in past Region I inspections.
The appraisal team also discussed several weaknesses that were not significant enough to be included as Appendix A items, but which should l
be considered for improvement of the radiation protection program.
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