ML20005E348
| ML20005E348 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/28/1989 |
| From: | QUADREX CORP. |
| To: | |
| Shared Package | |
| ML20005E345 | List: |
| References | |
| NUDOCS 9001050096 | |
| Download: ML20005E348 (145) | |
Text
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e: o EVA111ATICII 0F TM PURT CA1BOUlf l NUC12AR STAT 10tt RADIATIOli
! PROTECT 100t EIGIANCll3ENT PROGRAM A REPORT SUBMITTED BY:
QUADREK ENVIRol0 ENTAL COMPANY 1940 N.W. 67TH PIACE CAINESVI11E, FIDRIDA NOVEMBR 28, 1989 e
l 9001050096 891227 PDR ADOCK 05000205 P_ PNV a
- l. o i
i, 1.0 EXECUTIVE StBRERY Quadrex Environmental Company was contracted by the Omaha Public Power District (OPPD) to evaluate the status ' of the Fort Calhoun Nuclear Station ;
Radiation Protection Enhancement Program. Dr. Wilson C. McArthur and Mr. {
B.
George Kniazewycz pe rformed the evaluation during the period of ,
September 18 to September 29, 1989, i-Three primary goals for the evaluation were determined as follows:
- 1. Evaluate the general attitude of the Radiation Protection '
Department as related to the Radiation Protection Enhancement I
! Program. '
- 2. Evaluate the Radiation Protuction Department commitammte that i
encompass the enhancement program and determine if the results ,
and/or direction taken are adequate and meet or exceed industry ,
practices / standards. '
In addition to these commitments, three audits were conducted r over the past two years that have resulted in 374 items identified (findings, concerns, and recommendations). These audits were performed by Stone and Webster. Cheaston, and ;
Hydro Nuclear Services. These items were reviewed as a part of the evaluation.
- 3. Evaluate the e f feeriveness the of Radiation Protection Enhancement Program to meet its assigned mission and recommend changes or additions that would contribute to the enhancement pro 6 ram and support the concept of meeting or exceeding industry practices / standards.
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The' Radiation Protection Enhancement Program was initiated in the fall of '
1988 with a commitment to review the status of the enhancement program twelve months later. This report is designed to satisfy this commitment. ;
t ATTITUnt i
The attitude evaluation consisted of eleven (11) questions with six (6) ;
questions receiving a numerical rating from 1 to 10 (1 being low and 10 as '
I excellent) and five questions requiring a verbal response. Overall, the '
responses were positive in that the nineteen (19) people interviewed -
reported a better than average nuclear program at FCS and a better than i average attitude toward the success of the Radiation Protection Enhancement i Program.
The verbal response questions were directed toward identifying i what specific tasks should be accomplished to further enhance the program.
Most of the verbal responses centered around five areast 1) record keeping >
should be a high priority, 2) Panasonic TLD System operation, 3) data base manatement system operation (PRISN), 4) phasing in new procedures, and 5) implementation of new Access Control Plan.
t COMNITNENTS The commitments that serve as the basic Enhancement Program are well under ful'1 control by the Radiation Protection Department with milestones being met.
Of the 131 items on the November 10, 1989 Commitment Tracking System List, practically all vere in one of the following categories:
o Closed i
o Superseded, or o Date targeted for completion with high ,
confidence of completion on schedule '
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, . . .. . . _ - _ - - _ . . =. ..
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- he evaluation team researched each of the 131 commitment items from both a reported status by the responsible FCS person and a confirmation of the status by observation of the corrective action (e.g., item e49 Whola Rody Countine Promram . Piemaa innlement a crearam to nerform randam whole hadv countine of narmannel earformine work in radioinnically uncontrolled arame.
The evaluation team reviewed the prepared response, the effected procedure and change, the fact that ten percent of those using respirators are whole !
body counted, and compared this practice with the rest of the industry.
The resolution for Item e49 is adequate, meets industry practices and will !
be closed shortly by licensing.) Each of the 131 commitments were evaluated in this manner.
Similarly, the 374 item audit " punch list" was evaluated and items were categorized as one of the following:
l o Closed by reference to corrective action taken, o closed as non applicable at FCS with reason, o Covered by Commitment Tracking System, and j
o~ Considered to be' opinion of auditor and not a 1
necessary requirement for FCS i
The Enhancement Program, as defined by the Commitment Tracking System, is considered by the evaluation team to provide the resources for an effective Radiation Protection Program. The additional 374 item list is considered to be a good " check source" as qualified individuals have provided their input via audits of the FCS Radiation Protection Program.
The corrective actions taken for increased staffing, selection of personnel, the Respiratory Protection Program and the Instrumentation Program, deserve recognition. The staff has almost doubled, providing infusion of new personnel and adequate time for training. Staffing is substantially above previouc levels and reflects OPPD's commitment to F047/24
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enhancing the radiation protection function. All of the three supervisory
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positions are filled by personnel new to OPPD. While this may cause some -
short term adjustment problems, the overall impact is considered positive !
as new skills and experience are brought to the FCS program. Discussion ;
with these new individuals reveals technical competence, a professional i*
attitude and support of the programmatic changes at OFFD. It is expected that these individuals will raise the program to a pro active and effective f level commensurate with the goals of the department, plant, and OPPD. The -
major challenge of the human rerource element of the program will be to l execute these interfaces during a. hectic .1990. This has been discussed '
l with the line supervision and their support is evident. Goals and objectives for 1990 are being considered at this time (October 1989). ~
Radwaste facilities appear adequate, especially with the upcoming ,
completion of the Radwaste Building. Attention to detail of the turnover '
and start up are necessary to ensure that the facility is readily I integrated into the plans for 1990 and beyond, s
Organizational ' interfaces including Training, Operations, Chemistry, '
Maintenance and others need to be formalized and strengthened. This should occur as the new supervisory personnel complete their assimilation into FCS.
EFFECTIVENESS 1
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The enhancement program is considered by the evaluation team to be efftetive in the development of an efficient and well organized Radiation Protection Program. One can look at the last few months of operation and see that the following factors demonstrate the transition to a quality program:
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o Lack of enforcement action in the Radiation Protection Program.
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$ 0: I o Performance indicators are on target and/or !
moving in a positive direction, and i
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o overall morale is good with acceptance of ~
personnel to meet upcoming challenges.
i Regarding recommendations to enhance the Program, consideration should be '
given to:
- 1) Implementing the Planned Access Control Modifications "
- 2) Developing the Data Base Management program for use throughout the Radiation Prot,ection Department
- 3) Closely evaluating a Radiation Litigation (Litigation Avoidance) Program '
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- 4) Providing Root Cause Analysis training for coordinators and supervisors I
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- 5) Implementing an ALARA Awareness training program for engineering, maintenance, I&C, operations, etc.
- 6) Paying close attention to the division of responsibilities for the Supervisor Radiation Protection and the Corporate support efforts.
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- 7) Developing a computerized Radwaste Management Program for vaste processing, storage, transportation and disposal.
One must keep in mind that a major effort has been made to arrive at this point in the enhancement of the Radiation Protection Program. The Plan had to be developed first that has been accomplished. The basic elements of the program have been up graded, as follows:
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o Procedures implemented September 1, 1989, '
o New organization with a full complement of personnel, i
o Resources, i.e., equipment, space and facilities, are either in place or completion date has been set, and '
o Milestone dates are being met.
One might say that all the " ingredients" are in place new staff members, revised procedures, ne's facilities, and resources. Therefore, the program will require some cima to develop the working relationships and to i
" fine tune" the program. This should be a positive time with a goal of approximately one year to complete an excellent Radiation Protection '
Program.
There is a potential for a SALP 1 rating for the Radiation Protection Program at the end of this evaluation period, however, one !
should not be dismayed if a SALP 2 is given. If progress continues, one r would expect a definite SALP 1 rating during the next evaluation period.
The program, in summary, is evaluated to be effective whcn compared to 1
industry practices / standards. The challenge is taking these elements and integrating the human elements into it. The establishment of definitive goals and objectives in 1990, coupled with aggressive management support, are expected to result in the continuation of a successful and effective R.P. program. ,
I.
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2.0 IM11tDDOCTION I i
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The Quadrox-Environmental Company (QEC) was contracted by the Omaha Public '
i Power District (OPPD) via contract No. SO48828 dated August 30, 1989 to j perform an independent assessment of the Fort Calhoun Station (FCS) '
Radiation Protection Enhancement Program.
Dr. Wilson C. McArthur was selected as the evaluation team leader due to ,
his many years of experience in the nuclest industry and based upon his expertise in performing evaluations of this nature. Dr. McArthur was assisted by Mr. B. George Kniazewycz, an expert in the packaging, handling, transportation and burial of radioactive waste. The resumes of Dr.
McArthur and Mr. Kniazewyez are included as Appendix 1.
The SALP report for Fort Calhoun Station for the period October 1, 1986 to April 30, 1988 reported weaknessas in Radiological Controls grading the performance as a 3. The previous SALP report, from March 1, 1985 to September 30, 1986 graded the Radiological Controls Pro 6 ram at a level 2. ,
Specific concerns in the October 1, 1986 to April 30, 1988 SALP report were:
- Lack of proper management oversight
- Violations identified during this period resulted in two penalties being assessed based on three Severity Level III violations with corrective action not considered effective.
- Procedures were identified as fra6mented and difficult to follow and personnel were not familiar with them.
- Staff size was considered adequate but not sufficient to include training / retraining.
- The Radwaste program was considered well defined and only had received two deficiencies identified by the licensee's quality assurance department.
The NRC recommended that the improvement program should be finalized with major milestones identified and completion dates established.
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'l The SALP report covering the period of May 1.1988 through April 30, 1989 :
indicated an overall improvement in the management and operation of FCS.
r Radiological controls were upgraded from a 3 to a 2. The NRC stated that FCS should continue on going efforts and complete the implementation of the radiological protection enhancement program. During the enforcement ;
conference a discussion of an event concerning individuals entering a high radiation area (VHRA) without proper dosimetry took place.
Several independent audits / evaluations were performed over the last few years that pointed to definite wealmamman in the RP Premram when compared l to industry standarda. These audits are in addition to those audita and I L
assessments performed by the Nuclear Regulatory Commission (NRC) and the ,
Institute of Nuclear Power Operations (INPO) respectively.
! i In addition to interim audits by OPPD, the following audits / evaluations .t were conducted:
- 1. Cheaston '
l l 2. Stone and Webster
- 3. Hydro Nuclear As a result of the NRC. INPO. internal OPPD and the three independent audits / evaluations. an FCS Enhancement Program evolved. One of the tasks in the Enhancement Program, which was initiated in late 1988, was to use an .
independent firm to evaluate the progress of the FCS Enhancement Program after one (1) year. That is the crimary purpose of this report.
I To accomplish the identified primary purpose. QEC and OPPD personnel agreed to the following goals for the FCS Enhancement Program evaluation:
- 1. Evaluate the general attitude of the Radiation Protection l
Enhancement Program.
- 2. Evaluate the Radiation Protection Department commitments that encompass the Enhancement Program and determine if the results and/or direction are adequate and meet or exceed industry practices / standards, l
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- 3. Evaluate the effectivenema the of Radiation Protection
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Enhancement Program to meet its assigned mission and recommend ,
changes, or additions, that would contribute to the Enhancament Program and support the concept of meeting or exceeding industry practices / standards. !
1 Consistent with these goals, the evaluation contains the following sections: -
1 Section h 3 L
1 Executive Summary 2
Introduction 3
Radiation Protection Erhancement Program Evaluation 4 Summary t
b l- Accendices Appendix 1 Resumes Appendix 2 Persons Contacted I
During Evaluation Appendix 3 References F047/24
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3.0 *=diation Protection rahane- ' Prorram Evaluations '
' The FCS Radiation Protection Enhancen$nt Program evaluation was performed l during the period of September 18. 1989 through September 29, 1989. '
The evaluation consisted of several steps consisting primarily of:
- 1. Interview of RP personnel.
- 2. Review of previous audits by the NRC, evaluations performed by INPO and audits / evaluations performed by Chomston, Stone and Webster, Hydro Nuclear and OPPD '
- 3. Independent review of the following documents:
FCS Radiation Protection Plan
- 4. Walk through and observation of radiological work practices
- 5. Comparison of FCS RP program elements to INPO criteria and good practices as observed in the industry. '
One must keep in mind that the purpose of this evaluation was to determine the " status" of the FCS RP Enhancement Program un.t to perform a detailed i
audit resulting in findings, concerns and corrective actions. With this I purpose identified, the evaluation centered around two documents: !
i
- 1. Commitment Trackine System List consisting of 131 tasks identified as the " Enhancement Program".
- 2. Radiation Protection Enhancement Procram Action Plan which contains 374 action items as " gleaned" from the following sources; e Nuclear Re6ulatory Commission Institute of Nuclear Power Operation R
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- Stone and Webster Engineering Company
- Cheaston e Hydro Nuclear Services no Commitment Tracking Systen 1.is t was considered the main working document for the Enhancement Program. Therefore, major emphasis was placed h
l on evaluating the status of these tasks. De second document was considered to be a good " check source
- in which well qualified individuals have provided their input via audits / evaluations of the FCS Radiation Protection Program. Most of the independent audits / evaluations were i
- provided early on. The Hydro. Nuclear Services audit, however, is more l'
l recent and systematic in its approach. The 374 action iten list contains all of these findings, concerns and/or recommendations. Some of these items are redundant. However, to be thorough, all items are addressed.
As des" Coed in Section 2, the three primary goals for the evaluation are I
ceno..wr. around the words:
i l
- Attitude e Commitments, and
- Effectiveness.
The evaluation proceeded using these principle concepts.
ATTITUDE I
ne goal was to " evaluate the general attitude of the Radiation Protection Department as related to the Enhancement Program." Nineteen people responded to the eleven questions that are shown in the questionnaire in Table 21. Six of the questions required a numerical answer with a response between one and ten, with one being the lowest evaluation and ten being the highest evaluation. The remaining five questions are used to highlight concerns and accomplishments. Is it recognized by the evaluation team that this is a very subjective analysis, however, our experience has i
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shown that the referred questions do give a measure of overall attituta and car. Otermine a trend that may prove detrimental to the program if f
% checked. In most interview cases, the individual being questioned was e in a controlled and comfortable situation with the further instruction that -
I the information was to be used as a " rough" measurement and that individual i responses would not be passed on to others.
As one can ses from Figure 21, the overall response was better than ;
average. These questions have been used at other nuclear power plants with ;
a much greater overall negative response than seen at FCS. Individually, there were only a few measurements below five in response to the six questions. There was certainly a good general attitude that the RP Enhancement Program would result in a better RP program.
The five verbal response questions provided information that appeared ,
consistent, relative to general concerns or attitudes toward what the RP '
department personnel considered priority items and/or areas that should receive attention. ,
The items that provided the greatest response were:
l o
Concern for the radiation exposure record keeping process. Most of I those that stated a concern were aware that efforts are being made to clear the active records and then to resolve the inactive records.
Present schedule shows active records completed this year and in active records requiring a full year thereafter. Litigation probability was stated as the prime concern.
o Need to formalize Data. Base Management use throughout the RP department. For example, current radwaste shipping manifests are prepared by hand, o
Many questioned the need for a Corporate Radiation Protection Support group with p.nt operating nuclear plant. '
o Access control needs to be improved.
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The general attitude is that present plant management (Peterson) will f listen to problems this creates a good cooperative attitude ,
o There is a perceived culture difference between those that have been at FCS for five plus years and the more recently hired personnel, !
o Performance Indicators appear to be showing that there is better '
control of the plant now. I o New procedures, in general, are good. Opinion ranges from afull of bugs a to "a few bugs need to be worked out".
t 1
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nat2 2-1 l RADIAT100t PROTECTIOtt DEPAILTMENT QUESTICIOWLIRE 1.
Based on your knowledge of the industry, other power plants, vendors, etc., how would you evaluate the nuclear program at FCS?
2.
Based on your knowledge of other RP programs in the industry, how does the FCS RF progran compare in overall quality?
3.
Does the completion and full implementation of the RP enhancement program give the vision of a more effective or efficient RP progras?
4 Based on your knowledge of the industry, how does the FCS radwaste program measure up?
(
- 5. How would you rate the training that you have received at FCS?
5.
Based upon your knowledge of RP technology, how does the FCS RP equipment, resources and facilities measure up from the viewpoint of i
meeting state of the art and/or industry standards?
7.
k' hat would you consider to be the Ihrt.g highest priority items to be accomplished in the RP program?
B.
k' hat would you consider to be the three highest priority items to-be accomplished in the FCS radvaste program?
9.
k* hat would you consider the strengths of the FCS RP program to be?
10.
k' hat would you consider the strengths of the FCS radwaste program to be?
11.
k' hat 2ne thing would you do to improve the RP program if you had the j resources and the management support to do so?
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FIG RE 2-1 FCS ATTITUDE SURVEY !
i 10 = excellent 5 = avg. i = very poor ,
8
- 7 - L g
5 -
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- s -
- ggi i
- 3 .
'y& .
j . -
- g _
x -:t .
, _ ss Ed g
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4 o .. - .
l i !
! Programs at FCS -
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Nuclear E Hadiation Protection I I RP Enhancement l
~"
Itadwaste ES Training I I Technolegy ;
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n
_ _ . _ _ _ _ _ _ . _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ ___.__ - _ _ _ - _ ~ _ _ - -m_ __ + - - - _ _ _ . _ - . - ~ - -
,--_~m. . _ ,+--, - ,.. - --.w.- . r_iwg.w.. .--u- , -. .w..,-. . . - - - , - . _ ,,...-_w.nw- , -
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Commitaanta t i
The Commitment Tracking System List was the resource used to take a '
a snap shot
- view of the RP Enhancement Program. Each of the 131 tasks were ,
reviewed as to current status and then a member of the evaluation team ;
oo' served the results of the response where feasible. For example, ites l
l e49, illudt. Radv Countin' Pronram, the evaluation team reviewed the prepared ;
response, the revised procedures and the commitment to Whole Body Count ten (10) por cent of those using respirators. The evaluation team observed {
the fact that ten percent of those using respirators were receiving whole body counts. This practice is consistent with good industry practices and F
will be closed shortly by licensing. The evaluation team addressed each of the 131 tasks in a similar manner. Table 3 1 provides a brief review of '
the status for each of the 131 tasks that make up the Commitment Tracking System List. Of the 131 tasks, the following status has been determined:
103 are closed 11 are under review by licensine for closure >
8 have been superseded 7
9 are QRan tasks l 131 total '
t Each of the open tasks has been addressed, assigned and are scheduled for r completion.
Table 32 addresses the additional 374 item list. These items were categori:ed as one of the following: '
l Catererv Definition 1 Closed by reference to corrective action taken 2 Closed as non applicable to FCS with reason 3
Covered by Commitment Tracking System 4 Considered to be opinion of auditor and not a necessary requirement for FCS, F047/24
1 i i The majority of these items have either been fully resolved or were ;
integrated into the Commitment Tracking System. As previously stated this list serves as a good " check source" to make sure that concerns have been addressed. .
Since the initiation of the Enhancement Program, the RF staff has doubled in size and has selected three experienced supervisors that report to the Supervisor Radiation Protection. While this any cause some short tore adjustments , the overall impact of the recently hired and experienced >
supervisors is a positive addition as new skills and expertise are brought '
to the FCS program. Discussions with these recently hired supervisors reveals technical competence, a professional attitude and full support of the programmatic changes at FCS. With their capabilities, it is expected that they will have a positive impact and revise the program to a t pro active and effective level commensurate with the goals of the department, plant, and OPPD. The major challenge of the human resource element of the program will be to effectively integrate these new j supervisory styles during an expected hectic 1990. This integration process has been discussed with the newly hired line supervision and their
- support is evident.
Since this is the appropriate time to review and develop goals for 1990, this goal development process should be an excellent way to bring the supervisors into a common focus orBanized team plan.
Radwaste facilities appear adequate, especially with the upcoming completion of the Radwaste Building. Attention to detail of the turnover and start up are necessary to ensure that the facility is readily ,
integrated into the plans for 1990 and beyond.
The evaluation revealed that the recommendations / commitments relating to radwaste have been met by the combination of additional personnel; new organization new, arrangements; revised and upgraded programs and implementing procedures; new facilities under development; and enhanced management support.
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- i Vith the new RF organization in place, interfaces with training, operation, ,
chemistry, maintenance, I6,C , and others need to be formalized and st rengthened.
This should occur as the new supervisory personnel complete their assimilation into FCS.
EFFECTIVE 1tESS f
1 The measurement of effectiveness of a program is subjective and depends l strongly on the experience of the evaluators and their expertise to assoas status with a short " snapshot" view of the program. With this in mind, the
- l evaluation team depended upon several factors in evaluating program j
effectiveness. These factors are:
t
- 1. Attitude
. How do the incumbents Ital about the program? Do they believe that they are part of a good and improving program?
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- 2. Induarry Practices /Standarda .
Based upon previous audits and evaluations performed by the evaluation team, a set of industry l
l practices / standards have been developed. These are based upon ,
I NRC requirements, INPO standards, good practices and experience, and comparing strong and weak RP programs in the industry.
- 3. _ Track Record" . How well has the program performed over the most recent span of time?
4 Commitments to Enhance the Prorram . Are the set of commitments conducive to improving the program?
- 5. Manarement Sundort Again, a subjective measuJe. However, based upon experience, certain factors become important.
ATTITUDE FCS RP personnel exhibit a better than average attitude as measured in the brief attitude evaluation described in Table 2 1. Perhaps as important was F047/24
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the attitude " felt" by the evaluators during the two week on. site survey. ;
here was an " air" of commitment to improving the RP program. The Supervisor. Radiation Protection has a track record in the industry for l performing well and exhibiting good people management. Similar attitudes l
were observed in the outlook of the three supervisors. Therefore, attitude i
was considered a positive attribute of the Enhancement Program.
INDUSTRY PeAf*TICEE/STANnieMS Although not required for the evaluation, audit. check documents were used '
that reference NRC regulations INPO documents, good practices, etc. hose l
documents are normally used for a detailed audit of an RP program. The
{ purpose for usin6 these documents was to validate the program against l industry practices / standards, i overall, the FCS RP program meets good industty practices / standards as now described with some items scheduled for implementation shortly.
P l
l TRACK RECORD l
As referenced in Section 2, the FCS RP has recently climbed from a SALP 3 to a SALP 2. The RP Enhancement Program was initiated in the fall of 1988.
These two factors plus the selection of an experienced Supervisor Radiation Protection and key supervisors that report to this position indicate a commitment to RP program improvement.
If one looks at the last few months of operation, several factors begin to demonstrate the transition to a quality program:
o Lack of enforcement action in the RP program, o Performance indicators are demonstrating improvement.
o Overall morale is good with acceptance of personnel to meet upcoming challenges.
A good, positive track record is developing.
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ccMut'neruts To rauwer ntr pitoen_Ax i
i It is the decision of the evaluation team that the RP Enhancement Program
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is conducive to improving the RF program. That is, the Enhancement Program can bring the RP program to a point .. a point at which the program must i operate with all the "new things" for a period of time to work out I potential problems. Por example: i l
- 1. New procedures were just implemented . September 1,1989.
- 2. New key personnel have recently filled lead positions.
- 3. Resources i.e. equipment, space and facilities, are either in place or a completion date has been set. .
4 Milestone dates are being met.
I h
All the factors above, when put together, " define" an RP program that i
should be at or above industry standards. However, the program will require some time to develop the relationships and to " fine tune" the program. This is a positive position to be in and a period of one (1) year should lead to a program of excellence in RP. The FCS RP Department is meeting milestone dates. -
l MANACEMENT SUPPORT i
The RP program is properly focused and with management's continued support, should reach the goal of a SAi.P 1 evaluation shortly.
One of the goals of the evaluation was to recommend those items that, in the opinion of the evaluation team, would further enhance the RP program.
In this mode, the following considerations are offered:
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- 1. Implementing the planned Access Control Modifications -
traffic (f , levels are too high in outage situations- and adds to the confusion and pressure of these important functions.
2.
Developing the Data. Base Management program - for use throughout the RP Department ~- the use - of ~ computer sof tware is not : always the best way. However, in some instances, where large numbers of
, records, statistics and tracking / trending are involved, much time and accuracy can be gained.
6
- 3. Closely evaluate a Radiation Litigation (Litigation Avoidance)
Program - The current record up-date is proceeding in the right direction. The completion of inactive records is important. The importance doesn't center so much around a completion date as it does an active effort to bring the records up to date. In the nuclear industry there is a concern that utilities be prepared to I handle such litigation by management concern for oversight and audits of programs and activities. .The position should be that "we have done everything reasonably possible within the present technology to protect our employees, contractors and the public from harmful effects of the plant's environment."
4 i n t de Root Cause Analysis training for coordinators and l
supervisors -
there are some excellent training programs _
available in this area. Not the highly analytical approaches but i '
the down-to earth "how do we find the specific reasons for the problem and correct this problem for good?"
5.
Implement an ALARA awareness training program for engineering, maintenance, I6C, operations, etc. This
- - is already under consideration by FCS management.
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6.- - Pay close attention to the division of responsibilities for the l
Supervisor Radiation Protection and the Corporate Support efforts
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as un professional as it may seen, some one unit utilities have
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'had much difficulty with this problem. However, success has been )
. accomplished with profassionals and a clear cut ~ division of l' responsibil(ties.
,. 7. Develop a computerized Radwasta Management Program for waste 1
processing, _ storage, transportation and disposal - the cost of burial for low-level waste and the potential for violations in transportation, once this waste leaves the hands of the utility and is controlled by others, dictates that extreme care be taken.
There are many inexpensive programs on the market and a good programmer working with a knowledgeable radwaste expert can l develop a software program post-haste. l l=
lL The Radwaste Management Program including the Process control Program, .
Vaste Minimization Program and Contamination Control Program have been l
- developed and implemented through a large number of new and/or revised l; procedures. Both the- programs and procedures require a period of
! " tweaking" to ensure their operability and pertinence to the practices at FCS. This is on-going and should continue for a period of three to six months. Several observations are made for FCS consideration as follows: ,
1
- a. The Process Control Program (PCP) should be examined to ensure " mixed wastes" are adequately addressed.
.b.
The PCP presented in RW 200 should be examined for consistency with RW AD-100 and other " programmatic" procedures and programs which directly or indirectly interface.
1
- c. It is suggested that all process parameters, sampling characteristics, l
plant design features, etc., relating to the PCP be examined and documented somewhere to minimize future questions or concerns relating F047/24 >
l to factors such as representative sampling, scaling factors. PCP process boundaries . and conditions, waste. characteristics, etc. The u
1' PCP is programmatic in nature and should be relatively-independent of '
l- vendor services or changes in hardware since it addresses FCS' efforts to control waste treatment processes. '
d.
The list of references in Section 6 of RW AD-100 is of limited use since I.E. bulletins, industry practices, etc.,
are issued on an infrequent but continuous basis and should be reviewer 1 against the FCS programs and- procedures when received.
I 1 If procedures such as RW AD 100 are revised every time a new bulletin or notice is issued, the administrative problem can be substantial with negligible benefit.
Similarly, listing references of particular revisions of a procedure, manual or regulation also adds substantial administrative problems in j attempting to revise procedures on a continuous basis. For example, changes to Department of Transportation rules or State disposal licenses are quite common.
The handling of hazardous waste on site should be closely examined to ensure the interface with Radwaste is appropriate at FCS. This applies to L . storage, handling and transportation. The shipping of hazardous waste and radioactive wastes by two organizations may cause many problems for FCS, L The' value of a single, highly-trained organization dealing with radvaste l-mixed waste and hazardous waste should be evaluated.
The substantial paperwork requirements for radwaste classification, inventory, storage and shipping make computerization and automation a very important part of an effective radwaste program. The automation of FCS procedures and practices dealing with these waste management activities should be given serious consideration and a high priority.
F047/24
- t The handling, analysis and disposal of very low level radioactive materials and wastes ("Below Regulatory Concern" . BRC), should receive substantial attention -in FCS radweste activities during the next year. This is important in. ensuring the new radwaste facility is fully utilized to ;
support FCS needs in the 1990s in areas such as vaste segregation, storage, etc.
As with any complex program, the success of the RP program can only be determined when ' compared to clearly established goals and obj ectives.
These are needed for 1990 and should be specified at all organizational' levels. '
F047/24
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One must keep in mind that a major effort has been made to arrive at this point in the enhancement of the Radiation Protection Program. The Plan had to be developed first that has been accomplished.
The basic elements of l the program have been up-graded, as follows:
Procedures implemented September 1, 1989.
New organization with a full complement of personnel.
Resources, i . e . ', equipment, space and facilities. are either in
= place or completion date has been set. 1
+
The Committment Tracking System Concerns and Responses are approximately 854 closed. I Milestone dates are being met, i
one might say that all the " ingredients" are in place new staff members, .
revised procedures, new facilities, and resources. Therefore, the program .
will require some time to develop the working relationships and to I
" fine-tune" the program. This should be a positive time with a goal of \
.l approximately one year to complete ' and excellent Radiation Protection !
Program.
There is a potential for a SALP 1 rating for the Radiation )
Protection Program at the end of this evaluation period, however, one should not be dismayed if a SALP 2 is given. If progress continues, one l would expect a SALP 1 rating during the evaluation period.
The program, in summary, is evaluated to be effective when compared to industry standards. The challenge is taking these elements and integrating the human elements into it. The establishement of definitive goals and obj ectives coupled with aggressive management support, are expected to result in a successful and effective Radiation Protection Program.
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APPENDIX 1 r.
i RESUMES Dr. Wilson C. McArthur-
-Mr. B. George Kniazewycz '
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1 QUADREX ENVIRONMENTAL COMPANY y
- Vilson C. McArthur MANACER. ' DECONTAMINATION AND DECOMMISSIONINC 1
Ernerience Himhlimhts o- :
i Directed and performed consulting 'in the armas of management and team .
development, training, radweste, radiation protection, and performed L audits and evaluations for utilities. Developed and improved new i
. technological concepts Containers , . and Robotics.such as Boric' Acid Reclamation, High Integrity o
Has recently directed several major field projects in decontamination and decommissioning.
F o
.company, Directed the efforts of a leading radwaste service and equipment o
Principal Project Engineer for a Pressurized Water Reactor, directed the interface . with the engineering and ,
Provided original design for PWR radwasteconstruction organizations.
for BWR radwaste system. system and backfit design
j o Held the - lead position in directing the technological direction and L business development efforts of the . Texas Nuclear Corporation after i o the company was purchased by the Nuclear Chicago Corporation..
l- -Responsible Teams (IRT).
for organizing Quality Circles and Independent Review
- L o Has served as President of the Nuclear Society and Health Physics state / local sections of the American Society.
o Published and presented over fifty technical papers and teports in the
.fields o f. radiation protection instrumentation, waste mana6ement, o
computer applications, organization and mana6ement, ,
circles. and quality L 'o Developed technology exchange programs in the Far East and Europe.
Professional Exnerience 1987 - Present
- j. Ouadrex Environmental Coracany, Cainesville, Florida.
Manager, Decontamination and Decommissioning, l' Responsible for the technical and project management efforts of QEC in the areas of management development, training, radiation protection, radioactive and hazardous waste management. Fic1d services projects include decontamination of a tritium contaminated facility, decommissioning of an incinerator' and l decontamination of a DOE extruder facility.
1982 - 1987 KLM Engineerine. Incoroorated, Walnut Creek, California. Principal. Responsible for developing, maintaining and assuring the quality
- l. Responsible for of work.
I radwaste, radiation protection consultation and new business development. Specific areas review, of expertise were manaBement and organitation training, radiation protection, l ALARA.
Q'W f p
. Wilson C. LMcArthur Page 2' 4
radioactive- and toxic chemical waste' storage, packaging, shipment, ar4d burial. processing, Experienced I in andengineering services, specifically decontamination decommissioning -technology, transportation and.
field processing of waste.
Was-. involved .in the
- development of Robotics, High Integrity Containers, and Membrane Technology;(Boric Acid Reclamation).
i Assistad 'several utility organizations at nuclear power .
plants in developing a positive management style. '!his -
process corrective consisted action.
of an audit of existing programs and through procedural development of management processes, changes, training programs. and improved i
time and effort Devoted a considerable amount of to working . with health - physics 1 organizations and PWR's during and the Plant Superintendents in both BWR's helping them develop startup' a
and operational- phases, full understanding of' their individual roles, as well as the relationship of health
. physics to the rest of the plant.
i 1978 .
1982 EDS Nuclear (now Innell)
Division Manager for and luA Cornoration both Impell Successfully -managed a and TERA. l concerned with solving .the consulting ' group primarily I industry's t problems in health physics and handling of wastes, bothday to radioactive and toxic-chemical. The effort resulted in i a number ofvaste radioactive conceptual designs for, the backfit of ,
processing systems. Expertise in l
AIARA methodology was developed in the process of l creating several completed dose reduction j (ALARA) programs and in the performance of plant ALARA < and radiation protection audits. Developed a exchange pro 5 ram in Japan, t.echnology {
Italy. Republic of China, and. 1 1977 --1978 Hittman Vice Nuclear and Develonment Corcoration President and General Manager. Directed a field j services organization that packages and transports radioactive burial waste (fuel cycle and non fuel cycle) to grounds.
I Responsibilities also included the design the of low level development of radioactive waste containers and waste Directly responsible processing equipeent.
for decontamination decommissioning, Experience includes and unusual radwaste problem projects .
manufacturing. and responsibility for the design, installation of radvaste solidification systems, both cement and polymer.
1971 1977 Carolina Power & Licht Was Principal Nuclear Project En61ncer for the Shearon Harris Power Plant.
Functions included design, construction interface, and the management of 75 engineering personnel.
Prior to the position, was
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Vilson C. McArthur Page 3 responsible for Radwaste Retrofit Designs at H.B.
Robinson 2, Brunswick 1 and 2, and Shearon Harris, and innovative CP&L plants.direction in Health Physics programs at all .
1967 1969 Nuclear Chicaen Cornoration/ Ten = Nuclear Experience includes the_-design and fabrication of radiation monitoring . equipment and low energy particle accelerators. Both nuclear power plants and, high designenergy physics laboratories are a part of thisi experience.
Involved in original research for the development of the Thermally Stimulated Emission of p Exo electrons (TSEE) dosimetric concept, Education o
o Ph.D., Radiological Physics, Purdue University, 1970 o M.S.
B.S., , Radiation Physics, University of North Carolina, 1965 Physics, East Carolina University, 1963 i
professional Affiliations. Ramistration. Licenses. Societies. and Awards i o
o Nuclear Engineer, State of California Registration #1717 o
certified Hasards Control Manager Masters. Level Registration s1337 o American Nuclear. Society, Past President of North Carolina Section Chairman, Committee. Edison Electric Institute, Steam Generator Safety Valve 1 o-o Member of several AIF Committees o
Who's-Who in Technology, 1981 - present ...
Who's Who in the West, 1980 present Selected presentations and Publications i o
?
"Characterisation of the North Carolina State Reactor for Radiological Experimentation," MastersUniversity Research
-of North Carolina, 1965. Thesis, University o "The Dosimetric Properties Stimulated Emission of Exo-Electrons,"of Lithium Fluoride using Thermally University, 1971. Doctoral Thesis, Purdue o Ziemer, P. L., McArthur, W. C., McManaman, V. L. and Smith, C. O., j
" Characteristics of Selected Phospors for Stimulated Exo-Electron o Emission", RISO Report 249, Danish AEC, Riso Roskilde, 1972.
" Proposed Society 10CFR50 Annual Meeting, Appendix 1974 1 A Developing Rachet." Health Physics o
"A Radwaste System Philosophy and Design for the 1990's." Health o
Physics Society Annual Meeting, 1974
" RUBY A Dynamic Radioactivity Model." Health Physics Society Annual Meeting, 1974
~
o
" Design1974 Meeting, Methods for Reducing In Plant Exposure," Health Physics Annual o
" Reduction Design of In-Plant Feedback," 1975. Personnel Exposure - Operating Experience as a o
" Responsibility Begins at 21 or ?,"
1975. Health Physics Annual Meeting, l
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' Vilain C. McArthur Page 4 I
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' 1975, "Is Your Exposure as low as Practicable 7," Power Engineering, August o
"A Nuclear Power Plant
' Pergamon Press, September,1975. Radiation Monitorin6 System," Health Physics o
_i
" Radiation- Monitoring- Systems: Current Status and Future Prospects,"
invited Keynote Speaker, 1977 IEEE Annual Meeting, San Francisco, {
L:
California. _;
o " Health Physica ' Problems Associated' with '
the Dismantling and Decontamination of the Illinois Institute of Technology Research.
.o Institute (IITRI) Reactor," Health Physics Annual Meeting, 1978 i
> 1.ight Water Reactor Vaste Management System = Emphasis - Upon Volume !
Raduction (by Membrane Technology) and Economics,
- Topical ' conference - 'l o on Reactor Operating Experience, Arlington, Texas, August 1979 - !
"The- Status of Low lovel Radioactive Waeta Disposal Bow to . Plan a ~i Disaster," ~ Mid Year Wasta Management, 1979.Health Physics Society Symposium on Low lavel o
"AIARA From Vorking Lavel to Management," Health Physics Society ,
o Annual: Meeting, Seactie, Washington, July,1980, i
" Volume Reduction Plant Its Impact on Ionizing Radiation Exposure of Power Personnel,"
-July,.1980, Health Physics Annual Meeting, Seattle, Washington.
o "A Computer-Based ALARA Cost Benefit Analysis for Operating Plants,"
American - Nuclear South Carolina, March Society 28-31,Power1982. Division Topical Meeting, Columbia, o
" Data Requirements for Meaningful long-Tern Epidemiology Study of the j Commercial' Nuclear Power Industry," 16th Health Physics Society !
Mid-Year 1983, ' Topical Symposium, Albuquerque, New Mexico, January 9-13, o o
"The Role of ' Quality Circles' in Nuclear Power Plant Operation,"
Health 1983. Physics Society Annual Meeting, Baltimore, Maryland, June, o
" Application of Microcomputers in Stren6thening On-Site Health Physics at Nuclear, Maryland, Baltimore Power - Plants June, 1983.," Health Physics Society Annual Meeting, ;
o
" Laboratory Requirements and Procedures for Compliance with the Requirements of 10C Baltimore, Maryland, R61,"
June, Health Physics Society Annual Meeting, 1983.
o {
" Pre-Operational Nuclear Power Plant Radiation Protection Programs," l Health 1983. Physics Society Annual Meetin6, Baltimore, Maryland, June, l o
"A1 ARA: Working Level to Management - An Update," Radiation Protection Management, Vol . 1, No . 2, Janua ry 1984, pp . 15 - 24 o "You Cet What You Pay For -
Applications of Computers in Health Physics Programs at Nuclear Power Plants," Health Physics Society o Annual Meeting, New Orleans, Louisiana, June, 1984 {
" Litigation Management j Annual Meeting, Chicago, A Practical Approach," Health Physics Society Illinois, May 26 31, 1985.
o
" Quality Circles in Nuclear Plant Operations," Invited Paper -
ASQC o Energy Division, San Francisco, California. April 10, 1985.
"High Integrity Arizona, March.Containers,"
1986. Waste Management '86 Symposium, Tucson, o "The Implementation of Remote Technology for Decontamination Activities," 19th Annual Mid Year Health Physics Society Symposium, Knoxville, Tennessee, February, 1986.
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,i 'Jilson C. McArthur Page 5
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-U - " Impact of 10Cf1t20 Changes on Radiological Controls." Invited paper at the 1988 IEEE Symposium on Nuclear Power Systems. November 10-12, 1988. P li 4 k
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I RESUME B. GEORGE KNIAZEWYCZ Mr. Kniazewycz has nearly 20 years of experience in the hazardous an se management area and is a recognized expert in the design of radwaste, wast teduction, and solidification systems. He has eatensive experience onal health physics, in operati
-i radiation monitoring, and operational suppoit systems for nuclear p is res d .
ponsible for KLM's radwaste and hazardous waste management, de and hazardous waste facilities. His acent worlt has in ,
1 peocessing facilities for energetic and hazardous wastes, introduction of m i
- thenuclear cor power plant environments, and development of utility radw design,porate level through actual plant radwaste organizanon. He has been re various LWRs, and has published numerous ,
gement atticles on a
and computer and robotic applications in nuclear plants. Pmat R&D activ development of High Integrity Con'*Wt Systems, an innovative penneable applicatio membranes for LWR gaseous waste processtag and development and co Bonc Acid Reclamadon System. Mr. Kniazewycz is currently directi or technology robotic applications in hazardous environments, membrane ystems, development Containment Systems.of nuclear and medical waste versions of KLM's propneta
' . n egrity decommmisioning and remediation projects which nation, d technologies, have I
practices and procedures. These include the use of mobile robotics to surv and inaccessable spill areas, disposal of chemotherapeuticmajor hos waste and reme sital's chemical laboratories, and D&D planning including or a $15 all radiologic permitting of an mobile infrared incinerator in South enguvering studies to develop a multi-incinerator hazatdous waste treatment site Prior to this as Manager of Technology (CAE) activities as well as other computer based servicrs. When with a large m,Mr.
Assersm nsulting firm was responsible for all consulting services relating '.o ALARA s, and health decommissioning, radwaste and water treatment, security, analysis, reliability and and operating nuclear plant support. This included tite development, insta industry's technically most sophisticated nuclears security. system M e
r.
for a twi Kniazewycz has performed numerous studies of n.sclear and ng hazardous and has performed numerous radwaste, chemistry an ,
Mr. Kniazewycz's purchase of the various A/E experience radwaste includes system components responsibility which com for and the design arise the Clinch River Breed er Reactor Plant radwaste system. This included a redefinition of the poten initiation of system design changes to incorporate appropriate - -
echnology. He state-of n the art t provided guidance relative to the cost-beneftt design of ALARA for in plan .
Mr. Kniazewycz has extensive utility experience with. This a majorincludes southeast utilit positions BGK(10r:9) as test coordinator for periodic tests (including ,
waste processing :
t of 7
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- and system modifications relating to radwaste.
1 of specifications for volume reduction, solidification, and other nu .
monitoring system presently utilized throughou ALAR A design guide and program, which became the basis four-unit FWR and other nuclear plants. a for a titatment and laundry waste processing, expanded e additional-liq; evaporators and fluid bed dryer technology to produce a " free-flowing radwaste; solidification, and expanded the scope of water inventory analysis an i logging computer coupled with an interactive control board intertied to monitoring system. As lead radwaste engineer for all nuclear i
zojects, he contmued similar work -}
! and set design criteria for a new three umt PWR. He pa,ynei and procured a new specifications 1
solidification system, waste evaporator, ultrasonic resin cicaner, and retrof .
Edt1 cation i L
o B.E., Chemical Engineering, Vanderbilt University, Nashville, Tennessee,1969 i
M.S., Nuclear Engineenng, University of Tennessee, Knoxville, Tennessee,1971) '
.i Professionni Affilistinne Revistration l and 1.icenses. Societies and Awards -l 1
Professional Engineer, State of North Carolina Registration No. 6962 l
i Chemical Engineer, State of Louisiana Registration No.19792 Nuclear Engineer, State of Califomia Registration No.1959 AEC Traineeship, 1970-1971 l AIChE, ASME, Health Physics Society, AlfE, fEEE, SME, ANS, and NSPE L
- Working Committee - ANS N33.3 Hydrogen Control in Primary Containment, 1973-1974 Working Committee - Atomic Industrial Forum, 1986 87 AIChE, National Speakers Bureau Tour participant 1976-1977 Member, Chemical Engineer Product Research Panel .
1975-1978
{
ASME Radwaste System Committee Member, Utilities Subcommittee,1976-present Utilities / Manufacturers Robotic Users Group 1986-Present 1
.BGK(t o/s9) !
2cf7
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b National Society of Professional Engineers -I.cgislative Governm Issue Expert--
Who's Who in Technology,1981 - present
- Who's Who in the West,1980 - present h
i RAlarvad ",..--.^- ;!rr.: Anti Publicationt p
" Design Methods for Reducing In Plant Esposure," Health Physics Annu , .
}
" RUBY - A Dynamic Radioacdvity Model," Health Physics Society Annu , .
1974; rem 10CFR50 Appendix I A Developing Rachet?," Health Physics g, Soci s
- "A Radwaste System Philosophy and Design for the 1990's "ety Health Physics Meeting,1974 ,
Annual-l-
l; - paper, No. 77 PWR-27, Syg,r.J ,1975,"The Treatment of Radwast "Is Your Exposure as Low as Practicabic7," Power Engineering, August,1975.
O
[ "A Nuclear.
September,- 1975.-Power Plant Radiation Monitoring System," Health Physics, Pe ,
" Reduction ofIn-Plant Personnel Exposure - Operating Experience as a De .
" Responsibility Begins at 21 or 7," Health Physics Annual Meeting,1975.
c L ,
"The WA/NE-5, Role Decemberof Volume 5,1976. Reduction Processes in LWR Radwaste Treatmen
."Engineering Reduction and Control in a Changing World,"of Nuclear Power Plant Internal Wastes," presen November,1976.
"'Ihe Environmental November,1976. Har.ards of Radioactive Waste Disposal," AIChE National .
p "Workshop, VolumeJanuary,1977, ReductionNew - AOrleans, New Technology Louisiana. for the '80's, " Reactor Radwaste M l "Is the Steel Drum the Answer?," Symposium:
May 23 27,1977, Atlanta, Georgia. Management of IAw-Level Radioactive W3ste.
Physics Society Meeting, Atlanta, Georgia, July S-8,1977."An ,
ea t Inte
" Radiation Monitoring Systems: !
1977 IEEE Annual Meeting, San Francisco, Califomia. Current Status and Future Pr l
. Box (tors 9) an
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" Design and Operating Considerations for Commercial LWR Volu August,1977. i c on Systems," ANS,
" Production UCRL of Solidified 13740, August,1977. High-Level Wastes A Cost Comparison o cation Processes," I
[
." Economic ASME RadioactiveConsiderations for LWR Radioactive Waste ManagementCourse, September Waste 1977M
, , o, Illinois. ,
i "An Analysis Processes," iCapital and Operating Costs Associated with High Leve UCid 80064,1978. u 1
aste Solidiftcation
" Radioactive 0032, July,1978.Waste Management Study:
Review of Waste Projection Models," NUREGICE-Data 1978. Base for the Generic Environmental a a e nformation aste Management,'.'
impact S L
i Science," Matenal Performance, Volume , .
pon Material 18, No I1,
" Characteristics of Defense High-Leve1 Waste," NUREG/CR4685 Ma
" Light Water Reactor Waste Management System Emphasis e uction (by Upon V Membrane Technology) and Economics," Topical Confemnce
' Arlington, Texas, August,'1979. xperience, on
" Spent Fuel Data Base: Commercial Light Water Reactors," UCRL 15186
" LWR Radioactive Waste Management System, An Overview with Em
- Science," Material Performance, Volume 18, No.11, pp. 39 45, Novem
" Security: From Regttiations to O Meeting, November 11-15,1979. perations - A Case History," invited paper,1979 Winter AN
" inventory and Sources of Transuranic Solid Waste," UCRL , ,
n 1.
15239, M
" Transuranic Contammated Waste Functional Definition and Implem March,1980.
"April,1980.
Transuranic Contaminated Waste Containereport, , Characte "ALARA From Woking Level to Management," Health Washington, July,1980.
, eattic. Physics So
~
Health Physics Annual Meeting, Seattle, Washington, nnel," J "Report, Transuranic July,1980.
Contaminated Waste Form Characteriza UGKf10fRM
Health Physics Society Seminar, August 8 9,1980."Cunen e
" Volume Reduction Techniques in Low-Level Radioactive Waste Mana NUREG Report, in preparation (1980). gement," Volume 13, "The Role of'Qualit Meeting, Baltimore, y Ciseles'in Maryland, June 1983. Nuclear Power Plant Operation," Health Phy Plants," Health Physics Society Annual Meeung, .
wer B Health Physics Society Annual Meeting, Baltimore, Ma ,
Meeting, Baltimore, Maryland, June 1983." Pre-Operational nual Nuc "ALARA:
Baltimore, Working Maryland, Level June 1983. to Management--An Update,"nnual Health Meeting, Physics
" Review of Operatin Symposium, Tucson,g LWR Exponence with Membrane Technology," Waste M Arizona,1983. .
L Techm. fogies," Waste Management '83 Symposium, .
uction
" Data Requirements for Meaningful Long-Term Epidemiology ear Study o Powcr Industry,"
Mexico,1983. 16th Major Topical Symposium, Health ,
Physics rque, New Soc "ALARA:
a No. 2, January 1984, pp.15 24. Working level to Management An Update, , .,
'1984 Lessons Learned from HP Computer Systems ,
e 17th Management '84 Symposium, Tucson, Arizona, March , aste 1984.
"Waste,"
Development DOFJER/80104-7,and Fabrication April 1984. of a Prototype Fiberglass Container active for Management '84 Symposium, Tucson, Arizona, March 1984. ,
"Waste,"
Development andApril DOE /ER/80104-7, Fabrication 1984. of a Prototype Piberglass Container ve for DO Power Plants," Heahh Physics Society Annualear Meeun .
. BoK(InrA0 - ..
m
'1 Society Annual Meeting,New Orleans, Wisiana, ,
ealth Physics Jun j "Nine Mile Point Unit 1 Radwaste Modifications-Haalth Physics Pla NMPC),llealth Physics Society AnnualMeeting,NewOrleans
, e .
Lou and C. A. Gerber, NMPC), Amedcan June 1984. ,
s, wt T.Nuclear L. Irving ns, I.ouisiana, S
)
Protection Management. October 19g4, c on Program," pp. 67-74. Radiation -" Ma Technology," DOE /ER/80145 01, June 1985." A Volume Reduction Developmen
" Integrated Wastewater Treatment Purification System Developme June 1985. ,
port BMO TR 85-41, !
IIcalth Physics Society Symposium, Knoxville, .
nnualMidyear Febr
- "High Integrity Containers," Waste Management '86 Symposiu ,
u.
"1986, Boric Acid Reclamation System (B ARS)," Waste ,
Managemen ucson, March 1 - Symposium, Tucson, March 1986."A Remote Technologies ,
nagement '86 App "1986.Surveyor
- at Nine Mile Point," 31st Annual Meeting of Health Phy i s cs Society, Pittsburgh, July L
"The Surveyor July 1986, pp. 71-72. Mobile Surveillance System," Radiation .. .
Protection
" Application of Robotic and Remotely Operated Technology to Ha and Clean up," Haztech International Exhibition ande Conference,,
Operations D
t Conference of ANS, Pittsburgh, September 1986,"The , s egional Imp
" Experience with the Surveyor
- Mobile Robot in Radioacti American Nucicar Society 1986 Winter Meeting, Washington er 1986.
Novembve Work
" Experience of the Surveyor Symposium, Tucson, Arizona, March 1987. Mobile Robot at Nine Mile Point," Waste M Robotics in Hostile Environments, Pasco, Washington .
ems and Tucson, Arizona, March 1987."KLM's Boric Acid Reclamation ymposium, System DoK(10/s9) 6 o(7 _ _ _ _ _ _ _ , . _ _ _ _ _ , _
h
_Pittsburgh Robotic Based Laboratory Conference and Exposition,Automation Atlantic City, March System 1987 for Ro "The Surveyor
- Mobile Surveillance S Management, Vol.'4, July / August .591987,
- 66. pp.ystem at Nine Mile Point," Radiation Water Conference, Pittsburg, Novs.h 1987."KLM's Optim eeting International e
'~
' Che-i-M Waste" CalifomikrvDepartment of Health Se i ces, December i987xchange Regeneration
~
' Air Force Astronautics I mi-wtory, June 1988Develonmen ihmtney. AFAL-TR 88 028, Tyndell AFB, FL, November 1989Deveinnment of a Disnnuhle C ystem HQ AFESC/RDVS, i
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.. . . . . . . . . . . - .-.-. . . . . . . - - . . . . - . ~ . . . . . . . . - . . . . - . - -- . . . . .
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e i'u1 APPENDIX 2 i
i PERSONS CONTACTED
.e DURING EVMl!ATION -
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i Persons Contacted.During Evaluation 3
-1.
Mr. Gary Peterson Plant Manager t
- 2. Mr. ~ John P. Bobba Supervisor - Radiation Protection 'l
, 3. Mr. Dave lavett Supervisor Radiation Protection :
Operations
- 4. Mr. Richard Sexton Supervisor-Radiological Health and~
Engineerius
- 5. Mr. Preston Swafford Supervisor Radioactive Waste Operations '
l l' '
l- 6. Ms. Margaret Welch Radiological Health Coordinator-
- 7. Mr. Ken Steele Radiological Health Coordinator
' 8. Mr. Randal Cords Health Physicist ,
- 9. Mr. A.G. Christensen Radiological Operations Coordinator 10.'Mr. Al Bilau Radwaste Operations Coordinator
- 11. Ms. Marilyn Hawes Chemistry Specialist
- 12. Mr. Craig Crawford Respiratory Protection Coordinator
- 13. Mr. Joe Mattice RWP Surveillance & AIARA Coordinator
- 14. Mr. Ed Parsons Acting Supervisor Radiological Health and Engineering
- 15. Mr. Chuck Anderson Acting Radiological Instrumentation
& Equipment Coordinator F047/24
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- 16. Mr. Mac McGrath Acting Radiological Operations 3 Coordinator 7 17. Mr. Randy Hodgson Senior Radiation Protection Technician-
- 18. Mr.-Ed Gundal Contamination Control Coordinator I 'l l l
- 19. Mr. Mark Breuf Acting Radwaste Operation Coordinator l 1
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- 20. Mr. Steve Gebers Supervisor Radiological Services (Cerporate) l
- 21. Mr. Scott Dixon Senior Radiation Protection j 1
Technician. .
. 22. Ms. Londa Haskell Radiological Engineering il 1
1 Coordinator 1 l
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-4' a~ j l-APPENDIX 3 '
l.
REFERENCES
- 1. Systematic Assessment- of License Performance (SALP) e NRC letter dated November 14, 1988 to OPPD covering the period October 1, 1986 through April 30,.1988. !
- NRC letter dated June 2,1989 to OPPD covering the period May 1, L 1988 through April 30, 1989.
- 2. OPPD Functional Position Descriptions b
- 3. INPO Evaluation of Fort Calhoun, April 1989 '
INPO Evaluation of Fort Calhoun, April 1988 INPO Evaluation of Fort Calhoun, November 1986 l
L 4. " Fort Calhoun Nuclear Power Station Health Physics Program Assessment" Chemston Technology, Inc. , May 2,1988
- 5. Omaha Public Power District Radiation Protection Program Assessment, July 11, 1988 to July 22, 1988 Hydro Nuclear Services, Inc.
- 6. Fort Calhoun Nuclear Station, " Radiation Protection Enhancement Program Action Plan", Hydro Nuclear Services
- 7. Radiological Vaste Minimization Poliev, OPPD Nuclear Policy Manual, March 31, 1989
- 8. Poliev for Maintainine Excesures to Radiation and Radioactive Material at Fort Calhoun Station as Low as Reasonably Achievable, OPPD Nuclear Policy Manual, March 31, 1989 F047/24
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. .f-
- 9. Renoiratory
, Protection Poliev, OPPD Nuclear Policy Manual, March 31,
'1989 -
4
- 10. Nuclear _ Operations Division Goals and 1989 Objectives, March 23, 1989
- 11. AIARA D=M ation - Rwnomure Pronram, Section 11.3, Revision 2, Quality i Assurance Plan
' 12. Occunational Radiation Ernosure AIARA (As law As Raamonably Achievable), Number 9.03, OPPD Supervisor manual August 1.1984 t
- 13. Response to NRC Inspection Report 50-285/88-05 '
1
- 14. Project Implementation Plan (PR 11) for Occunational Radiation Fvnosure Manarement system (OREM), August 25, 1989 L
- 15. Complete set of Newly Revised RP procedures
- 16. OPPD Plan to Respond to Stone and Webster Independent Nuclear Appraisal Recommendations, August 1988
- 17. Omaha Public Power District, Nuclear Operations Division, Policy / Procedure No. G-1 " Radiation Protection Program Coordinating
[ Group Charter" July, 1988
- 18. Fort Calhoun Station Unit No. 1, Operatin6 Manual, Administrative l- Procedures, Standing Order No. G 5 " Fort Calhoun Station Plant Review Committee (PRC)" December, 1988
- 19. Fort Calhoun Station, Technical Specifications Section 5.5.2 " Safety Audit and Review Committee"
- 20. Fort Calhoun Station Unit No. 1, Operating Manual Administrative Procedures, Standing Order No. R-4 " Station Incident Reports" November, 1988 F047/24
7 i
ej . ,
i 21, Fort Calhoun Station Unit No.1, Operating Manual Administrative >
Procedures, Standing Order No. R 11 " Notification of Significant Events" January 1989
[,
. 22. Omaha Public Power District, Nuclear Operations Division Quality Procedure NOD QP-12. " Reporting of Defects and Non Compliance to the Nuclear Regulatory Commission" Auguse, 1988 4
- 23. Fort Calhoun Station Unit No. 1, Operating Manual Administrative Procedures, Standing Order No. R-3 " Reportable Occurrences" March,1987
- 24. Omaha Public Power District, Nuclear Operations Division, Quality Procedura NOD--QP-18, " Management Investigative Safety Team (MIST)"
August, 1988
- 25. Omaha Public Power District, " Quality Assurance Plan for Fort Calhoun. ,
-Station" August, 1988 1
- 26. Omaha Public Power District, Nuclear Operations Division, Quality Procedure, NOD-QP 8, " Nuclear Network System" 1
F047/24
g *
+ -
.e ,-
l :.
ColeRDIENT TRACKING SYSTEK LIST
- \
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e i;
4 l
5 Page 1*
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^
~ (ND5h OLE.!C POER DISTRICT CDellTIENT TRACKils EYSTEN COERS M IE50ES ITEN 8 (XBEElti 0 ' RSJECT Tie ( IE50E I CID640412 'IEpilWITORS IEVIDI MILABLE ERJIPIENT lue (2. DIED. EVALUATilBI CDelETED IN DTER ALTElBmTIVES TO PRWIM Fit.L OF '04, 1 2 YESTS A S CIRLI S IWY (XILINS FOR HAllBI IUDillES AWAILAR.E FOR LE VIA P.O.
EWilDeBIT 9035053. EEllPIENT ElIIVED 12/4/06 -
AIS IEVIDED BY M EVdlamillBI 1951 :
lile FRSS 10 K SRTIFRCTORf. - ;
2 CIDI50492 RelESICE. IEVIEW: IEVIEW IEDOGSATIW1 IN iMER CLDED. PRIEE31ES FOR EVIBl llE EIXBOGIRTlWI 04 ESRIBils PERllBIC EVIEls F FRSS IN 19902, IP903, 28 9904. -!
IIRDIEJEIDL DEFICIDE!Es perman IEVIDED BY M EVILim- '
g TI(BITEAM.
l-lL 3 CID850601 EXESSIVE PDIB30El. EVELIP IIFROWED IETIEEILOGY, (1 DIED. SSElllEDED BY tt IWOWE.
I ilRDIATI(Bl EXPORES MDIAT!WI PROTECT![BI ElHWEDENT PRE 881 I l
l1 4 CID060650 ALARA 1881 RDI FiliulE C35LETE A BID 0llAL lEVIDI WI (2.0ED. BOTH RADIAT!!BI PROTECT!91 MAN 101 FIGulE LEED IN ALAlm IllDialL AIS 19303 PElWI M E Ell Elelf COST ANALYSES FOR THIS IEVIDi. BBC FC4:-630-88 DE28BITD TE 51001118.IEVlW F S3 00 0/11181 IEN. CURElm.Y, F-303 llTILIZES $10,000/1121 lei. TO E EVALUATED DURINS 81001115. IEYlDi:
F Ppmnst 1
5 CIWMA1 RADIAT!WI ETECTION F(LLOW T)510 ON PROCDUE Ale CLDEED. FCS WILL NOT PullRE lELEAliE l !IstEENTATION OF STATE OF TE OF SLIGHTLY CONTlWillflTG IIATERIAL DLE.
l ART EEllPIENT TO EFFICIENTLY TO PG.!TICAL LplCERTAINTY. SEE FC-IIP-' -
KTECT RADIDACTIVITY 232-69, DATG 5/3/89 (IEEIR TO FISICAll01. NOTE: A BRC PR.!CY, PEllF0lBED BY EPRl/Nt31AIN MS BEEN PIESENTED TO NRC. BEST ESilllATES SIG 10 MONTHS-2 YEAllS FOR FINlt.
l ESLLATIGl.
6 CID860684 RAD LEVEL. ESTABLISH A 'DDl!NiltE' LEVEL CLDEED. CURIENTLY, DDilNilES LEVEL.S OF MD10 ACTIVITY ALL0ldAOLE TO HAVE NOT BEEN EST.'lII.19ED. UTILITIES' DISPOSE CONTMINATED MTERIAL CAN SullMIT AN EIDFTIWi LSEDI 10CFR20 302 WITH REASONABLE DEBIEE (F EEESS BASED ON PREVIOLE SLElllTTALS.
7 CID860813 URA MlHIEN FISURE C0lWLETE A bided!AL REVIEW ON OPEN. REFERENCE CID86065 BOTH -
$3000/MN-REM FIGUE USED IN ALL MDIATION PROTECTION Mlut. AND ALAM COST BOEFIT ANALYSES TO RP-303 PROVIDE FOR A BIDei!E. IIEVIEW DETERMIE IF IT IS ACCEPTABLE OF $3000/ MAN-REM FIGullE. ESPONE DLE 11/15/89.
8 CID870466 PASS CAPABILITY: 86 15 0 EVALUATE ' PASS
- PROCEDUES FOR CLOSED. 01-SL-2 OPEMTIIE INSTillE-EVALURTIWi; FINDINS EP. 4-1 MDIOLOSICAL EALTH CCAdSIMHATIONS T136 REVIEED BY JtE MTTICE o
4J . 1
- {
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WW54 PlR.!C PGER DISTRICT CDellTIENT T151D'196 SYlRDI L >
l> CGESS RS lESORES
(
- l. . ITDI 8 CGEM 8 ={
SLBJECT TAS(: Eggs i l
i
!!/30/88 FOR H.P. CG SIDE milGE.
IEVIEW 61116 ETAllE IWS RFFICIDIT.
'9- CID870654 He PROTECTION EVIEW 8081FDATE EXISTINS - 0.0ED. PROEDUES IIG.15E ABERATE : 'l ppnsm TO MDIATION PROTECTIIBf IERillEIENTS. IP 804 GDITAlls 1W58R. AIS VERIFY S!lpi TO VERY HIDI VHRA CSITIllLS.
fulD AIEAR AIE POSTED
- h 10 - CID881%0 IEpilulTOR NAINTENRIE IIS4. DENT IIFIEIVEB MillTEISUE CLDED. - CDplETE 161 ET (F EB-L IIS IEPRIA PEERNS FOR PIMTOR PICTECTISI PEEIRES IMED -
IEpillATORS AS STATED 9/j/09. PROEDUES lEVIDED BY l
EVILIATI(Bi TEAM SS FGas TO E '
~ DETAILED Ale RFFICIDIT. IEE FC-IP - ,
311-89 FOR CLORE IGEL
!! CID88141 REWillATORY PROTECTION CGSILIDATE 4 Ilpfl0VE INVENTURY CL0 LED. Pil0BlWI IN(1.15ED IN IGl i
l 4 ISSURIG PROERNES & CGlill(LS pensma SEE FC-lp-309 89 DATED 1 CtKESilN6 RESPIMTORY Pfl0TECTION : 7/13/89 FOR CLORNE IGEL GENTITY t AIS QUALITY (F llSTitaElfiS lEVIDED Ale ColpARED TO OTIER pilR'S IIS FBIS j TO E SATISFilCTORY.
12 CID88142- CDRIELATION CLDIED. CGGSI IS panamn Pfl0 VIE BETTER COREl.ATION 3*
KinEEN DIFFElENT ASPECTS OF TE ADERATELY IN Deli PROIDIMB. EE RESPIMTORY PROTECTillN PR06MM FC-IP 347-89 DATED 8/2/89.' ' TE AS STATED IESPillATORY Pil0 TECTI (Bi PROBMM Pil0CEDURES HAVE BEEN llEVIDED BY PRC.
13 CID88143 RESP!MTOR EVALUAll0NS EVALUATE RESPIMTORS PER RES. CLOSED. FCS HA6 NIOSH CERTIFIED 3' GUIDE 8.15 8 lulEE-0041 TO RESplMTORS AND CA1841STERS. EVALUA-DETERMIE EFFECTIVENESS AGAINST TION TEAM REVIEED REELATORY GUIDE CEMICALS, RAD 1010 DINE, ETC. 8.15 APS NUREG-0041 REQUlHDENTS .
AGAINST THE FCS PR06AM Ale DETER-MIED TE PROGRAM llRS SATISFACTORY.
SEE FC-RP-302-89, DATED 7/5/89.
14 CID881%7 FRISKER STATION lP6AADE TE FRISHER STAT!(DIS CLOSED. FRISKER STAT!36 AIE LOCATED AS STATED IN IER 88-05 RESPONSE ON ALL FLDDRS AS IPPOSED TO DIE LOCA-TION PREVIOUSLY. FRISIER STATIG4S ERE OBSERVED POSTED WITH PROPER IN-STRUCT10NS FOR FRISKING. SEEFC-C-308-88 DATED 8/16/88.
15 CID881473 MATERIALS DETERMIE SPECIFICALLY lHICH CLOSED. t00ER AND QUANTITY OF MTI-ANTICONTMINATION MATERIALS HAVE C'S, LAB COATS, RESPIRATORS, ETC.,
QUALITY AND AVAILABILITY PROBLD G WERE REVIEED AND EEDS FOR GJTAGES REVIEED 8/3/88. EVALUATION TEM RE-VIEED TE NEEDS AND FulfG RESPONSE TO BE SATISFACTORY.
16 CID881475 RAD AREA LOCK liplDENT KEY CGiTRG. PR06RM TO CLOSED. RESPONSE CD(TRIED IN S.O.
3 . l<
l- .}
1 INHL PIE.lc PSER DISTRICT CWellTIENT TRAIXIls SYSTEN 1 CGElBE A2 IEptBES U
i ilTEM 8 CtBENI e SIREI Tilm IEWOE
, ' CSITIEL LOCKS IN RCA DOORS OUTSIE ' 6-26, PLANT KEYS, NS 15004, RSID-y CONTAleENT L0slCa. AwA anmets am!W EVRL , j p L5tTI(M DELE WRB A EVISIS TO PG = '
CEDUE IN PE TO 18154 IN H.P. TEDI WITH AppilipillATE Emilpigli TO TWBRIT .
DE AIEA. fpplEpt! ATE ATTDITim fBSL IE50EES TO THIS (SEIBl.
_17l CID881477' 19 PRERNI DATE ESTAIL191 CGplETIM DATES FOR CLDED. IEp!ARTORY PMCT!W s IEpilulTORY PIDETimi PIERNul AS PIEBASI CIBplETELY EVIED IIS - '
STATED IN IER 88-05 IEBUEE [5%RlWED TO LEET llOWTRY STIBORMB.
18 CID881478 Q.0 THINS = DEVELip NINiltal A111PTABLE LSSER LIGISIS EVIS TO QJE.
STRISARD6 FOR ITES F P110TECTIVE 4/10/89 lEle Flpt RISE. TO ,
Q.0THilE 164101 Wit.L BE BIBBA Pil0VIDED DECEMARY lilNiltfl llc 0ipollATED IN PURCHASilEi SPEC. STiteARDS F0ll PIDETIVE CLOTH!lEL EVilLUATimi TEAM IEVIDED IEBOE AGRilET ll80STRY STNORMS AND FRAS.'
SillleAM6 SATISFETINY.-
19 :CID881575- IIPil PflG:EDURE DEVEL!P 185 ISSLE DE IIADIAT191 finKD. IIRDIATIOl PIETECTim l PROTECT!DN IWWull IlplDENiilli IWWut. LEVIED IIS IMED JUS WILL ' '
L PROCDulE E lEVIDED PER13L35LY. lugMIL '
l IEVIDED Ale Fase 70 IEET llelBTRY STANDAllDS. ,
- 20 .CID881579 RADIO NATERIALS RESPOW TO VIOLATION REliARDING CLOSED.' 5.0. 6-27 ISSED 4/29/88. .
l INDIVIDUAL PASSING THRU 8 ALAllN ON 4/12/88 NilC WITIEEEED SEVERAL I _;
T}E RADIAT!W PORTAL NONITOR BUT INDIVIDUALS PASS!lE AN flullDI WIT)GJT FRILED TO CONTACT TECH.~ CONTACTING HN H.P.' A CGWUTER PRINT-0UT WAS USED TO LOCATE Ale <
1NTERVIEW TtE PERiiG8EL. A CL0 lie-BY ,
OUT-OF-SERVICE lollTOR WAS flPPAIENTLY l FALSE ALAltilidi. CORECTIVE ACTIM IS SATISFACTORY._
L 21- CID8816% VHRA KEY liplDENT KEY CNTRG. PR0611AN FOR CLOSED. 6fl0lp OllDER 89-IP41, CGi-LOCKSETS ON VHRA AND BARRIERS TRG. OF VHRA KEYS, filO lEIE) Fil0N OLIISIDE CNTAD0ENT BOBBA TO ALL RP PERSGGEL DATED L 2/15/89 SATISFACTORILY CLOSES THIS TASK. THIS ITDI IIEEIVES OlHiOIN6 REVIEW BY NANAGDENT.
22 CID881727 ANSI CREDIT CHANGE S.O. 6-53 REGARDING CLOSED, A TWO FOR GE ANSI CREDIT, C354tKf'S LNDERSTANDING OF ANSI lellCH IS CONSISTENT WITH T}E !!SUSTRY, CREDIT FOR ELT'S HAS BEDi INITIATED.
23 CID881729 ISCLAT10N OF VERY HIGH PROVIDE CG54.ETI(N DATE FOR Q.0 SED. THIS AEA WAS OBSERVED TO RADIATIGiAREAS ISOLATING VHRA AT BACK OF RAIL BE PROPERLY R0 PED 4FF AND PLACARDED.
1 i
ORDIR PWLIC PSER DISTRICT QuellTIGli TROINE SYSTDI C3 Gips te K90 ES JTER 4 CGEWI I SLBJECT TR8( EW48K 24 CIDM1741 POSTING 8 REVISE PROCDUE @4 TO PROVIK CLOJD. POST!IS FM Rf50RT F MIN 1481 ST40RRD6 FOR PET!WS 5740A86 FOR CSNL F RWAK 40 Rf90RT F PorTINS FOR C3fiMillhTION NAB WEMD DV EWIL-SUFADE (IBfifullmiltel NEAS (fliliti 7051 fue FR88 TO E WITIl-FACTORY. !
25 CIDt41745 911FT 7U1504R MWLD fet IlplDeff F00gLl!G (LIED. EVIDED FC C-MH4, IRfD ,
9 9NIFT RAIDER SYSTDI 4/86/06, DRISTDel TO NWl 28 9 '
DilFT LOOB (FC-11091. WIFT M A N NER SYSTDIIEETS IIRSTUf STNSAMB.
26 CIDul?47 REFIMTORY PROTECT!DN TAME flNY APPR(PRIATE ACTION CLDE. EpilRTORY PISTET!W t RESA51NB TEDeilDL REVIEW 0F Pil0BRM WRS IEDI CDOLffELY IEVIE.
E9PillRTORY Pil0TECT!DN PROGMM BY PROBRM AND pirrrme IEy!DE3 py ll8EPEeDIT (DRILLifDli EVllLURTION TEAll fue FRIS 70 IET l llR ETRY STAlenWB.
27 CID881749 AllDIATION PROTECT!DN MNuRL - IEVIDI fl@ EVISE ECTION l 0F CLDED. ECTI M t.0, UM DillATIWl ,
SECT!DN 1 IIADIATION PROTECTION Mpull TO 850 STAFTINE, OF leiW 159 SEFilES i DEFIE CulB61FICATIGS (1M5tFICATI(Bi IENGetBILITIES.
REFONSIBILITY DEFINITIONE AIE SATIFACTORY FOR 59 -
Als AllE RlRTER fupLIFIO BY Ja M9CRIPTIONS FOR DIDI PERITitBL 28 CID681760 D Dl!STRY AND flADIAT!DN WRIFY CRP LESSON PLAN Wil6 CLDED. TilAIN!W PillMUt IEEIVG l J
PROTECTION LEBSONS IIEVIDIED PY APRIL 15, 1968 !$0 82RDITAT!W We IS IEVIEE PERIODICALLY PY RFERVISOR-ilRDIATION j PROTECT!DN OR NIS ST EF. MATERIALS I USED FOR GET AND RP filRINIE EE REVIEED AND FDLDS SAT!9F.lCTORY BY l l EVALWi!DN TEM.
l 29 CID681761 RESP!IIATORYI ' di 6605/13 IIEVIEW LACK F CO@lODISIVE AND CLOSD. RESpillATORY Pfl0 TECTI (pi DREAN!!D ESPIRATORY PROTECT!DN PR06flNI REVISO me GlEATLY PR06flRM AS STATG !@l0KD. PROGilWI IEETS INRETRY STANDARDS.
30 CID681771 RP D$RT DEFIE ICT@L W0llKING ORGAN!!AT!DN CLOSED. REVIEEDflP-AD-100, AND POSIT 10N ESCRIPTION IN TE ORGAN!!AT!DN AND STilFFIl6, Ale TECH SPECS FOR RADIATION ALL POSITION K SCRIPTIONS. DNILU- l PROTECTION TEDNICIM AT!DN TEM FOUND K9CRIPTIDIS lEIE CLEAR AND CONCISE AND EET INDUSTRY l STANDARDS.
31 CIDB81772 CONTM INATION LIMIT CO@LETE AND IMPLDENT LONS SHOLLD BE CLOSD. CONTMINATION l TERM ACTION PLAN DEALING LIMITS ARE DEFIED BY ngl PROCDURES.
VITH CONTMINAT!DN LIMITS PROGRM WAS REVIEED AND OBSEINED BY INTO UPGil@ED RP M21UAL EVALUAT10N TEM AND FOLDID TD LEET INDUSTRY STANDA US.
. _ ~ - -_. .- . . .. -. - . - - . .
, , t Page$ ,
Omm MLIC POER DISTRICT C!Ist!TIBfT TRROK!IS SYSTD !
CtBEM 100 EWOGES IT. , C .. S C1 1. E :
1 32 C10061773 'P PRO D UIE DENE ROIAfitM PROTECTION Q.0ED. ALL p passet gg !
PRIEBUES W ORGAN!!G see MEN LEVIED 481MED 9/1/85. A l QB5eGSM QMIRY IEV!W F PWIRMS, WITH l 8ETAllD LEV!W F DElIFIC PD-WILIES,1308 EWILIST!W TWII TO l
M QBCL151R T6517 PERIRMS AE !
M.L WRITTW NS WEL WE A IENUL !
NGaff F T!IE 10185 Rft PERBE, !
PIRIBUES AIE OWII!D NO (2- l PIGGSM.
33 CID641774 IEPIMTOR UBRE VERIFY WRITTD POLICY STAfDENT Q.DED. A lEDIM10H PISTECTitBI i FOR E91MTOR USAE HRE BED PtLICY HRE IEDI ISED BY W.L. JOIES, i liplDENTED DATG 3/31/09. PE.!CY IS CWS!fTDIT WITH 9000 ll8LETW PilRCT!!IS.
34 C10842225 AIR SIUDLING ETHODS PLDE DEVELtp fue PIF1tIDLBULIZE Q.0ED. EVILURT!W 1958 I 001018E FOR AIR SippLile IET)cDS IEVIElED AIR WupLle llSTE8BITA- ;
ANDFIEDUDCY. PLEA K 00Q9Gil TION PROEDUES,19203 (AIR WU5 LIE i t
AS R Wi!T A CIFY TO Ll(IISilE CILLECT!Di me IIELYSISI 20 M IlhDIAT!!M PROTECT!W PUWI. PD- !
SilllN IEETS IWLETW ffSORMB.
35 CID682228 RE!Af ttM A@ CONilut! NATION PLDIE DEVEllP life PROCDLWILIZE Q0ED. IEVIDED 19801, 19002, l SUINEYS DETAllD EllDIMI FOR M Ale IIP 204 life (EEINED IFEllllT!WE. j FEOLENCY Ale TYPE OF flADIATION Pil06RilN IS SAT! FACTORY NS IEETS t AND CWITANINATION SURVEY 3 TO E !@uBTRYFTA@ARDS.
TAKDi DURING RADIO. W0llK l
26 CIDB82229 SUINEY DATA DOCullENTAT10N PLEASE DEVELOP PROCDUMLl!D CLD E . RP202, llEllLOGICAL SulNEY, i ETHODS FOR DOCLIENTIN6 SUINEY Pil0VIDES DETH003.06Y FOR D003ENTING
]
DATA OBTAllED AS STATD. PLEASE SulNEY DATA. ETicD IS SATIFRCTORY DOCL8ENT YOUR ACTIONS AND SLRNIT Rie NEETS INDUST R STileA0 6.
A COPY TO LICD61N6 l 37 C10842230 RAD!! LOGICAL NOCEDURE FOR ISSLE A IIAD!tLOGICAL PROCDUE CLOSED. PROCDUES FOR EllNEYllE SUINEYlN6 EW FLEL BUNDLES FOR SURVEYING OF G FLEL EDELES G FUEL RMDLES IS CONTAllED IN RP202 AND !$ SATISFACTORY. SEE I
SECTION 7.4.8.
38 CID&B2233 DISSDt!NATING RADIOLOGICAL PLEASE DEVELOP AND PROCD URALIZE CLOSED. RPM 4 IIESPONDS TO M EED CONDITIONS MET EDS FOR PREPARIN6 AND FOR PREPARIN6 AND DISIENINATINS DISSDt!NATING RAD!! LOGICAL RADIOLOGICAL CO @TT!0NS TO CONDITIONS TO SLPCWISION SLFERVISION.
39 CID882234 RADIAT!DN PROTECT!DN MNUAL REWRITE RADIATION PROTECTION CLOSED. REVISED RADIATION PROTEC-REWRITE WDilRL AS RADitLD61 CAL PROCDURES TKH PLAN ISS E 7/26/89 AND ALL IN O M R SECTIONS OF M RP P M DURES REVISED AND ISS O OPERATING NIDifflL 9/1/89. l l
_ _ _ L
p6 '
l 1
WWG PLE.!C POER DISTRICT C30llTIOff TRACKils SYSTDI l l
CONCERNE les E W O EES !
l ITDI I CWCElBi 0 SLBJECT TASK EWOGE 60 C!DMi237 C3filpilMTION PLEAE PRtNIE A LEVIS!91 TO M CLDED. EIS!WI PIEN!DED FOR LETTER 1987 OPPD IDORTIIS (F SKIN AIS DATD 4/26/04 FOR K.J. MARIS TO P.II.
Q.0THINB C3ffigilNATlW E TO 1100 l'
IEA R (19901. IIIPORT!W IETIEELNY IS CselSTDff WITH ligl5TW IIS 1190 SilISAIDS.
41 CID842239 CGfilul! NATION PLEAE CSFLETE M PROE3UE CLDED. INITIAL EBOSE 105 IP-18 PIRIBUES DDEES lERASilG TE lEPORT!W OF (Vil+1tl, PERR30EL SECgmgilmilmi, > I PDEBSEL CGrilBI!NAT!WI IICIENTS EV. 7,10/09. MbEVER, 5807 IIS !
AESTATD IP903 Mbi llEXilpONITE A (IBFLETE i EWOeE. )
1 4 CIDa&2E41 AC%lLDLLATED EIPOMS PLEAE PEIFOSI A LEV!D10F 1988 CLDED. MR. B!LAU PEIFDIOED !VILIA- 1 DORES ABAllET 100 Dit lus ADJUET T10N FOR PERIOD 10/47 TO 3/84 (5 SKIN I i ACCIMLATD EXPOSUES ActXIllD!lELY AND 25 CLOTHING CGITipilMTISE). i LETTER SDff 70 1190. I l
43 CID642243 HLI BODY COWTS PLEAE EXE TilAO(ING fps Q.01ED. REV!DED IMIWO lue IMITRO l TIEND!lE THESMLD FDR POSITIVE B10RIBAY P e % 19650, 1914, j MLi 90DY (%DfiS TO MTCH INSilMENTATION PERIBUES IIS DIS- 4 IISUSTRY PMCTIE CLINED WITH DOE!IETW DEIEBAEL.
TE BEW amma WC WILL E IN (FERL AT!!N BY DS OF YEAR fue WILL P1WVIE A WlER RANE F0ll DIASEETICS. PID- i SIWWI IEETS IISUETRY SiluSARDS. l
{ !
64 CID882245 FC DESSING PRACTICES PLEASE EVD.0P AND PROCDUMLl!E CLOSED. 1ESPON9E INCLUDES IIP 201 l
STANDARDl!D PROTECTM CLOTHING (ATTAC K WT !), PP204 SECTION 7.7.!!
DRESSIN6 AND LNDRESSING PRACTIES AND RP904 FOR LISTD MINIILN Pil0TEC-T!VE CLOTHING AND DIESSIIS AND LN-DRESSIN6 CRITERIA.
l 45 CID682247 RADIOLOGICAL PRACTICES PLEASE REC 0mDS A ETHOD FOR CLOSED. TCPIC COVEED IN 8/26/88 ,
REC 0ppelDATIONS ASSURIN6 SLFERVISORY ALAllA Cum!TTEE lEETilE. 110903,
]
ACCOLNTABILITY OF THEIR W0llKERS' RADIOLOGICAL OCCURIENES IDORTING l RADIOLOGICAL PRACTICES TO TE APS TRENDING, PROVIES IETM00 LOGY. !
l ALAM CumlTTEE 66 CID682249 RADIOLOGICAL PRACTIES FOLICY ftEASE DEVELOP AND llFLDENT A CLOSED, REVIEWED RP904, SECTION 2.2. ,
FINAL PCLICY FOR ASSURING SATISFACTORY RESPGEE FOR ASSURDE
, SLFERVISORY ACCOUMi4BIL!iY OF SLFERVISORY ACCOLNTABILITY OF
- TEIR W0ilHERS' RADIOLOGICAL WORKERS' RADIOLOGICAL PRACTIES.
j PRACTIES 47 CIDB&2250 PERFORMNCE STANDARDS CDPFLETE PROGRAM REGARDING CLOSD. PERFORMANCE INDICATORS AE PERFORMANE STANDARDS DEVELOPD DESCRIBED IN RPP, SECTION !!.8 AND .
IN TE REWRITE OF RAD PROTECT!DN ARE VISUALLY DISPLAYED FOR GDERAL MAltlAL, PROEDUES FOR EASURING If0RMAT10N. TESE INDICATORS ARE ACHIEVDENT PCIFORMAP(I REVIDED BY MNAGDENT AND AfE
p, y '
l (NMR MLIC MhER DISTRICT ComuTIENT TRAD(ING SYSTD C3Elp6 fue ERWES ;
i
- m. C .. S-C1 . ., E l TANDI ER100E.Y. SimeRSE ET IEET
)
BOES PMCTICES IN M llRETRY.'
I 44 CIDM2252 AIR SluplES D UIP M CWRITE M PROCEDUMLIZATION OF Q.DE. EVIDED AIR 955415 I AIR $4R.ES IEPIEENTIE INEAlWlm PREDUE me m EptmTORV I 23ES T4EN lHIN EpillRiolE AIE PRODRM AND ERitMSff. PIRIIMES i WOW #9 M ACIlulSITION OF ADERlRTELY COVER BERTHis ! GEL DR!lPIENT TO R590RT I 49 CID642254 IHLE 9tBY CIDlTING PLEAK IIRDENT A PROGMM TO CLDED. IEVIDED STSSIS PROBRM PEIFOSI RSSSI 60GI DISY (IDITING OMER 89-!!-lp, WWD-J00, se ISS !
i 7 PEROW9EL PEIFTilpil5 6105( IN Ft-IP 422-49 (9/5/091 IIMITOOfE.
I RAD!!LIBIClLLY CWTillLIID AIEAS M THAT 10ll 7 TW IElWIS RFDPIRATORS AIE lac'D.
j S0 CID642257 TLD SYSTEM MNGE DETIE TLD D0$MTRY SYSTD AND CLOSED. E,4fl6Y STISY CSRITED AND i l
M lilNE OF EXPECTED llADIATIONS TLD SYSTEM OlHilTE. l 158 DELE!ES IN M PUINT SO flNY l- DEV:ATIONS CAN E IDENTIFID II@
)'
l ADDESSED 51 CID682259 TLD PROCESSOR PLEAE PURDIRE Als llRDOff A OPDi. WILL E CLIED tilth FILL (ptMTilBI EW TLD PROESSOR CAPARLE OF OF PANA6mi!C TLD SYSTDL PNfellC PROVIDIN6 TLDS OF APPfl0PRIATE TLD SYSTD IS OHITE, INUP IEVIDI Dell 6Y RESPON9E AS STATED ColplETE AND IS fillRITIE ERTIFICATION. ,
WILL M FRLY (FUIRT!WfL i I
$Y END OF YEAR.
52 010882262 PC DRESSING SIGNS CLEASE HAVE SiONS IN PLACE CLOSED. EVALUATIONTEAMOBSERVED PROVIDING REMINDERS OF FROPER SIGNS TMT PROV!K REM 12ERS OF l
DRESSING AND LNDRESSING OF PROPER DRESSING AND INDIESS!!G OF PROTECTIVE CLOTHING POSTD PROTECTIVE CLOTHilE. Pil061111M IETS IN APPRCPRIATE AREAS !NDUSTRY STANDARDS.
53 CID882265 WORKER 6UIDANCS - P G ASE DEVELOP, PROCEDURAlllE CLOSD. PROCDUES, TRAINING, AIS q CONTAMINATION AND DISSDl!MTE SPECIFIC WORKER AWMENESS (VIA S!BNB) HAVE KU l GUIDANCE RELAT D TO SPREAD OF llFLDENTED. I CONTAMINATION AND SELF I CONTAMINATION AS STATD 54 CID882266 CNTAMIMT10NFRISKING PG ASE C M NGE PROCEDURES TO CLOSED. FRISKING MS BEEN ADDilESSED ADDRESS CONTAMINAT!DN FRISKING ON )Y PROCEDURE, If0lplAT10N SIGNS, EXIT FROM A CONTAMINATION AREA AND TRAIN!NG. FRISKIN6 Whis OBEINED BY EVALUATION TEAM AND WA6 SATIS-FACTORY.
l 55 CIDB&2269 PROTECTIVE CLOTHING PLEASE CMNBE PROCDURES TO CLOSED. COVERED BY R@ PR02 DURE.
IN CONTROLLED AREAS PROHlBli USE OF PROTECTIVE CONSISTENT WITH INDUSTRY STANDARDS. I CLOTHING IN TE CLEAN (%)NTR1 LED AREA EICEPT AS PERMITTED BY
. .-. - - - - . -~ _ --
Pena 8 '
p OWlHA PLE.lt poler &lSTRICT COMITIENT TMCKING SYSTDI n
l :
CNEIMS AND E50EES ITER 4 CODE 111N 0 SLBJECT TA9K IE50EE MDIATim M Kitt!T l
56 CID482273 EPA FILTER PROEDUES PLEAE PRnrmam !!E CNTIEL OF CLOD. REVIE S It000, 701, 702, ,
M VACLAsl CLSDERS M PORTAILI 705, 706, A @ 000. PERI 3 LIES AE M AIR FILTER We EEUIE CtBSISTDR WITH IWWTR SYNOME.
LatXIE L0tX, M CONTIEL OF j
LMITS DY EALTH PHYSICS TEC 57 C 0882274 IP M PRRCTIES panrmaal IZE PRt5lER llADIAT!!N Q.ED. 190 QMISS MIM PRDTECTION M PMCTIES AS INDIATION PROTECT!W WE PETIES BTATED NIWE BEDI INtIlWGNITG 1100 3 GLY l
LEVIED We APPWG PIEEIBUES.
PROEDUES AD01EE IIIB M PNC- i TIES We IEET lleWTW ST40M38. ,
58 CID882276 QlNTMIMTEC MTERIAL PLEASE DEVELIP PROCDUES CLOSED. RW300, 501, 503, 505, $06, PROCDURES EGMDING SEAL!ss Als TRMFER OF Ale 507 REVIDED FOR ABERNEY NS POTDGIALLY CENTMINATG MTERIAL CtBS!STENCY. PIREW FOR TilluGTR i
FRG1 CtWTMINAfD M AEAS (F POTENTIALLY CtBRWilWTG NATERIALS FROM Q;rillteTD M AIEAS MEETS IleWTRf STNONES.
C9 CID882278 TD F0llARY CURBS PLIAE INSTALL TDFORMY CURBS CLOSED. IN T/88, WTER 6518 DETECTD AS APPROPRIATE AROL40 AEAS F1.0 WINS FROM A CIBRigilWTG NEA TO AS STATED. PLEASE DOCLBENT A CLEAN AEA. TE lATER 6518 QBills YOUR ACT!DNS A2 SUBMIT A COPY Fil0M A MABK WAGER. 4555G0 TO LICENSING PIP!NG REPA!RS EIE lulDE We TE NED FOR CURBS WAS EVALURTG. SEE FC-C-664-68 IDATD 12/13/88 B!LAU TO 9001@.
60 CIDB822B1 MONITORING CLEANING MASE 1RDOT A FROGRM CLOSED. NEW PRnrmer, RADIAT!W DEVICES FOR MONITORING CLEAN!N6 Als UNTMINATION RJilVEYS, liplDENT DEVICES SUCH AS MASSELIN CLOTHS A PROGRM FOR M(Na,0RIE CLEAN!E CONTMINATION AS STATED. DEVICES.
DOCL8 0 T AND SUBMIT A COPY TO LICENSING 61 CID882300 PERS30E. PROTECTIVE EVALUATE A MET WD FOR SURVE!LLANCE CLOSED. REVIEW BY NRC 121CATD SWE l EQUIPMENT PERIODIC OF PERS010EL PROTECTIVE EQUIPMENT POOR RP PRACTICES Als AVAILABILITY EVALUATIONS NECESSARY FOR RESPONDING TO 0F ONE STEM Sulf FOR MINTORCE.
RAD 10 LOGICAL ENERGENCIES LETTER FROM OPPD 10 NRC DATO 8/24/
I 68 5iATG ADDITIONAL EDU! PENT PUR-CHASES AND RESPONSE TO RP PRACTICES.
RESPONSE IS Sif71CIENT.
62 CID882431 '
ENGINEERING CONTROLS PROCQ URALIZE TE USE OF CLOSED. REVISED RESpillATORY PRO-ADDIT!DNAL ENINEERING CONTROLS TECTION PROCEDURES A 2 EXPERIENCE OF TO REDUCE RELIANCE ON RESPIRATORS TE SUPERVISOR - RADIAT!W PROTECTION AS STFiTED HAVE LED TO A RESpillATORY PROTECT!W
o ,-
I I
l OMMA RELIC POER DISTRICT Com!TIENT TRADCIE SYSTD C(BERNB fue EWWES ITD e CSEM i SLBJECT TADC EWOE PRNRAM TNAT IETS Ilgl5TRY 8789455.
63 CIDbt2491 IIRDIAT!!N PROTECT!DN ESTAIL19100ES Ale OBJEITMS Q.0ED. Grits D e n S H N P, 00RLS FOR RADIATION PRDTECT!DN GRO@ SJECTMS AS IWLS, As ISS W.
[ FOR 1999 IlplDENTATION FC-IP-153-49 DATO 3/16/89 (NWL 70 ' 3 ALL IP PERIBSELI 40 PIEBIT 1989 j ERLS lEIE EV!BEB. ATTENT!W 18 {
PAID TO ADDIERSIs NES 3 ERLAR ;
BRSil. DLRIM EVElflTiSt, A MBEST FOR IgumEIBfPS Mas me IRECT!WES lEIE 91LICITD DV RSRIVWIF4DIAT!W PROTECTilBI IN OMG 10 FIEPRE FOR 1990. - 90RLS AS BJECT!WES NO PEFONWWE 19101755 NE (IBEllTDif WITH GOOD lleUSTRY PARCTIES.
64 CID682494 RADIATION PROTECTION liplDENT M llADIATimi PROTECT!DN CLDED. - 1989 8018.8 Ale BJECT M S . l GDRL PROBilRN 615P 00RLS Ale OBJECTMS AS HlWE EDI liplDENTD 20 INE TilRDO. i STATED PDIFOIDIRIE IWICATOM HlWE ME't
]
DEVELOPO IDS E T15108.
65 CID882498 RADIATION PROTECTION TilWWFO R M GORL Ale OBJECTIVES CLDED. KilF0mug G l elCATORS A E '
l PEFOWIMCE INDICATORS ESTRILIDG FOR RP INTO RF00 gun EIE TlWICHED. ALL IP PEMBBEL 20 i INDICATORS Ale IOllTOR M OMRS AIE MADE fuglE F TNlt PER- '
EFFECTIVDOS OF M llP 6110LP Als FDD12G. DATA WILL E M D FOR ITS PER9010EL EVALURTION OF 19 PRWWII AT De F 1989. PREPAllRT!!BI F 1990 00lt.S AND OBJECTIVES WILL E PIEWAIED AFTER RECE!VIIe llelREIENT 119UT.
]
66 CID862501 IMPLDENT 60ALS, DBJECTMS, -
RADIATION PROTECT!DN CLOSED. MRS010EL EVALURT!!NS AND )
PERFORMANCE INDICATORS I KRFORMAN E INDICATORS AND PLANS POSITION DESCRIPTIO$ BOTH INCORP-SERVE AS M BASIS FOR INDIVIDUAL ORATE Tif INDIVIDUAL'S 'PART' IN .
AS WELL AS BROLP KRF0llilRNE BEETIN6 60ALS AND OBJECTIVES. 00RLS I'
EVALURT!DNS AND OBJLCTIVES AIE TRHEN OBE STEP 1 I
FURMR FROM TE S@ERVISOR TO TE TO M INDIVIDL51LS.
l 67 CID882521 RADIAT!D4 PROTECT!DN PRESENT A YEARLY REVIEW OF PAST (PEN. THE PRESENTAT!310F TE ' i TERFORMANCE HISTORY YEARS PERFORMAN E TO PLANT YEARS' PAST KRF081mG WILL E l MANRGDENT AND DISalSS 00ALS, DEVELOPED AT THE END OF KFDDIANE q OBJECT M S AND PERF0DtANCE FROM KRIOD. THIS DELAY WAS A59 ROVED 1 PAST AND FUTURE PERSPECT!VES TO PROVIDE ADEQUATE TIE TO TRACK !
TE FIRST YEARS' 60ALS AND l OBJECTMS. REPORT DLE 3/1/90.
l 68 CIDB82522 RADIATION PROTECTION UPGRADE RADIATION PROTECTION (NDER LICENSING REVIEW TO CLOSE. <
MANUAL UPGRADE l@LEENTINS PROCEDURES AND l RADIATION PROTECTION AS STATED
)
69 CID882550 TEDNICAL ALEQURCY REVIEW / REVISE PROCEDURE SCIPE, CLOSED. Em FC-RP-143-89 (BOBBA TO l
1
_. , , _ _ _ _ ~-
r t
L Pege 10 :
l OlulNR PLAILIC POER DISTRICT C30llTIDif TRACK!E SYSTDI
{
1 CD ERNSAW E50RES ITEM 4 COGRN I SLBJECT TAE ESpesE i
)
ETHritim risy, IEalllDENTS, FIS! CARD) AND M 451ATim PROTEC- )
PIECAlfil0E, LIMITATIONS Als T1131 MlutlRL (SECT 131 10) FOR PR> !
MPTIIE CRITERIA FOR CDUES EE E!DED. 5.0. > 73, l TEDellCAL ADEGURCY PillIIBUE WRITERS EllE, PIRWlES
' M IEDEIRIBY FOR LIMITATISS IDS I ACIIPflIE CRITERIA FOR TEDtilDL l ADDNRCY. i i
70 CID642551 TED0llCAL ADEQURCY VERIFY PIREDUES WILL E CLDED. IEVIDED 5.0. 6-73 FOR WLIDATO DY APPIRPRIATE LIE TilAIN!E IIMLVDelf. IEVIDED l 9tFEWISIONS 70 DEVEL!P TARINIE PROEDUE FO ' IICOWORRTIE TilRIN!E lEGUllDENTS DIRIRES. PilDEN IFFEARS SAT! FACTORY. !
71 CID642553 BID 0(!AL REVIEW OF PLEASE INC0lFORATE ON G0ING CLOSED. M $100i!RL lEVIDI IEfallE- ,
PR0(DUES MRINTDIANE OF TE PROCDUES MENT DF PROCDUES IS INCLISEl' IN -
INTO M BIDellAL OF $T85812 ORER 6-36. ALL IF PROCDUES' ;
PROCDUES AS STATO ERE REVISD Ale IEDUE EFFECTIVE 9/1/89. A 90EDLLE FOR E !EW TO E DEVEL W D SY M SUEW190R-ARDIATISI PROTECT!S6 t 72 CID882554 REVIS10N PROESS CINILETE M SHDRT TERM ACTION Q.0KD. PROESS WAS Il51LDeffD SY TilRD(llE SYSTEM PLAN FOR A Pil0CDUIE TilACKilE HYDAD-NUCLEAR DURM IF PREDUIE SYSTEM TO MONITOR TE REVISION REVISIONPR0611AM. PROEDUIES HRVE PROCESS E EN ISSE D.
73 C!D&82773 RADIATION PROTECTION AUDIT HAVE DEMSTON REPEAT AND LR ATE SUPERSDED. OTHERS EE INVOLVED i M AUDIT TO ASSURE THAT ONGOING IN AUDITS AND DEVEL5ENT OF EFFECT!VDESS IN TE PROGRAM WAS CORRECTIVE ACT!DN FOR RP PR06flAM.
COMilNUING ,
74 CIDB82851 BlMONT)LY UPDATE !!! SUBMIT A blMONT)LY UPDATE OF T)E CLOSD. MS. LONDA HARELL TRAEKS M ,
RADIATION PROTECTION ACT10N ITEMS OUTSTANDIN6 COMMITIDITS FOR M RP SECTION. CLOSE COORDINATION IS MAIN-TAllED WITH LICEN616 IN THIS MATTER. -
TE RP SECTION HAS CONTRQ. OF DATES AND MILESTONES FOR THIS EFFORT.
75 CID683172 WVLAP-DOSIMEThY ONSITE RESOLVE TE DEFICIDCIES CLOSED. THIS WAS AN OPPD ASSESSMENT FORM IDENTIFIED IN THE TLD PROGRAM CORPORATE AUDIT. RESPONSE TO TE ,
AUDIT AS STATED CONCERNS WERE PROVIDED 8/23/89.
MEMDFC-RP-373-89.
I T6 CID883204 CONTINUOUS HP COVERAGE SLPERSEDED. TO BE C;NERED BY CID-RESPOND TO (PDTENTIAL) VI(LATION RESARDING LACK OF COMilWOUS 890153/01.
HP COVERAGE FOR ENTRY INTO A VHRA 77 CIDBB3207 RADIAT!DN HDT SPOT ISSUE REVISION OF PROC D URE CLOSED. VOLUME Vl! NO LONBER EIISTS. ,
VERIFICATION PROC D URE Vll-9-25 TO INCLUDE INSTRUCTIONS THE ALARA SECT!DN MS EVALWTD TE REVISION ON HOW TO POST HDT SDOTS StANT FOR HDT SPOTS AND IS DEVELOP-
- ^ ^ _. _ . - _ _ _ . . ----
y
'
- Pege 11' f
i (NHL PUR.!C PSER DISTRICT C0041TIENT TlWRX16 SYSTDI C M Elg6 AS REW O K S ITDL 4 CNEID( 4 i SLBJEC1 TagK E50E
!NS A PR06lWIM TO EDLEE TE 188ER OF NOT SPOTS. MET!W F IST WUTS IS COVEED BY IG PIERIELNIEE. i 78 CIDt43228 OLfTAE ABEISTANCE VISIT LEV!EW ECONeeRTIONE, ECT!DN H, OPDt. ESPONE DLE 11/31/M. .
Mmm88T10E EOMDIE INTElpmL [IPOIUE C3filEL FOR P00$!ILE ACT!WE 4 -
ESCRIK Puti F ACT191 i 79 CID883247 ESP!lunTORY PROTECTION LEV!EW OBENYAflWI ESMDING CLOSD. INOPECTitBI NRB PIEWNIO DY EQUIPIENT (IFE) INBPECT!DN PERIDGEL NOT IIs(CTIE TE TYPE OF BABS LAG FOR STOWE. LE CWS!T!31 F IE5)!IIRTORY OF CLEAR PUISTIC Elt.ED RMB fullb5 ;
PROTECT!!BI EDU!PIENT FOR VISURL INDECT!!BI F IE581RATORE.
(IFD AT POINT OF 19EE
!~ ,
60 CID883249 BIMONTM.Y UPDATE IV SLEpili A $1MONT4.Y LPDATE OF TE I CLDED. SEE ITDI NO. 73.
RADIATION PROTECTICM ACTION ITDtB ,
81 CID883264 SOER 85-3 COMPLITE ACT!DNS FOR SOER 85-3 CLOSED. REV!DED FC-lp-00849, DilTD '
IECONeeAT!DN NO. 5 REC 0pBENDATION NO. t REGARDING 1/3/89 (MATTIE TO 3RIA) MDI i EIES$1VE PEllB30EL RADIATION ESPONDED TO SER 8543, UEES!YE :
DOE PERSG0EL RADIAT!!BI EXPMIE. IElBT OF THIS IE 0llMRT!WI DID IST APPLY
- TOFCS.
82 CID8832T2 RADIAT!DN !MPROVDGT PROVIDE AN ASSESSENT AND AUDIT CLOSED. DURDEI IS PROVID19612 lomi -
PROGRAM ASSESSENT (SALP) FlMCT!DN TO ENSURE PROPER REVIEW OF TE RP DHNIIGT PR06 RAM.
- IMPLDENTATION AND EFFECT!VD4ESS OF THE RIP AS li IS PHASED IN DURING NEIT 12 MONTHS 83 CID883162 RADIATION PROTECT!DN CO@LETE STAFFING FOR TE CLOSD. RADIATION Pil0TECT10N STAFT!NG (SALP) RADIAT!DN PROTECTION ORGAN!!ATION SECT!DN HRS A CO E ETE STAFT AS STATED COMPLDENT AS TE FINAL POSITION, PADWASTE Sl.PERVISOR. WR6 FILLED 1
DURING THIS EVALURil0N. ,
84 CID883283 RADIATION PROTECTION LONG CD@LETE LONG TERM PROGRAM CLOSED.1. STAFFING CSFLITD.
TERM l@ROVDENTS (SALP) !@ROVEENTS SY SEPT.1,1988 2. TROCEDUREF KV! SED. 3. EDU!PIENT/
AS STATD RESOURE S ORDEF D AND IN PflEPARATION '
FOR OPEFATION. 4. RECORDS ARE BE!NGLFDATET.
85 C!tS83426 RADICLOGICAL PROTECTION REVIEW RECDP9 G DAT10NS FOR I CLOSED. TH'.S SH M.D NOT BE TRACHED ASSISTANCE VISIT POSSIBLE ACT!DNS AND PROVIDE AS AN ACT!Did ITEM AS TASHS AllE
- RECOP90DAT!DNS DOCU O TATION DESCRIBING PLAN INCLUDED AS PART OF EHNCDENT OF ACT!DN PROGRAM. SEE !@0-88-0228.
86 CID883429 EIPOSURE RECORDS REVIEW COMPLETE REVIEW AND l0 GRADING CLOSED. REVIEED STATUS OF ACTIVE CF EIPOSURE RECORDS FOR AND INRCTIVE RECDRDS AND Elt) FC-
Tage!! '
WHi PA!C iMR DISTRICT C39t!TElfi TRADWEi SYSTDI CONCERNS AND ESPONES ITDL 4 COGM e SUBJECT TASK EEPONE INDIVIDUALS AB E00!IED RP-342-89 (BOMA As PETURBI TO FIS! CARD). CURENT STAfl218 FILL!bEs ,
- 1. ACTIVE EC00 6 - TO E (IB R ITD l BY lt/15/M, 2. IWCTIE 1E1358 -
MILLED FOR CSRET!WI WY 9/30/90. ;
WITH PIEEENT NW5GER, TWIS LDEL (F :
ETFORTISDBTAINRILE. l 87 CID643460 (LAlt!FICATION OF STATION ABRNE FIELS IDENTIFICATIBI BY @ WlED. IP903, RSitLIBitX. IIIMI- ;
IEPORTIE PRREDUES PERS010EL OF A 107R20.402(B) IEIGS R90RTIE IIS TIBBilS -
IEPORTAILE INCIDDif WITH ATTA00ENT I - IEPORTIEE DDift PROEDUML AND TMININ3 PROV!KS DIE-HOUR, FtMHEMI,
!NITIATIVES OF RIP PROBilm inENTV3OUR NOUR Ale 30 DAY HDTIFICATION REQUllEIBlil.
BB CID683464 PING MONITOR ALARMS PROV!K A SPECIFIC ACTION PLAN TO 10 SED. TE PING IS FOR '!2! CAT!3d' ADDESS PING MONITORS FALSELY PURPOBES - RP IS TEN TO VERIFY Cth- l ALAMING AS STATED 10 NRC DITION. AN ACCEPTAR.E ACT!!BI PUIN INSPECTORS NAS KEN DEVELOPED M R FC-IP 165-89 DATG 3/23/89, 80BBA TO FISICAIEl.
89 CID683472 SHIPIENT OF CONTMINATED REVIEW SLBJECT NOT!E FOR (10KD. REVIDED IWW FC-IP 196 49 EDU!P9ENT BETWEEN NUCLEAR APPLICABILITY TO FCS DATD 4/12/89 (BILAU TO ISBR) E-POWER STATIONS SARDIN6 NRC IWOMATilBI R11ETIN '88-101 DHIPENT F CGITipilWTD EQUIPMENT KTWEEN 14X1EAlt IOER STATIONS. FROCEDURES AT FCS ARE ADEDUATE IN THIS REGARD. '
N CID683483 LIFETIE RADIATION EXPOSURE REVIEW !$0'S TOSITION ON CLOSG. RP-AD-600, DOS!ETRY PRO-REVIEW MINIM!!!NG FERS0 $EL L1FETIME GMM. AND RP601, EITERNRL DOS! ETRY RADIATION EIPOSUPE PROGRAM, ADDRESS MINIM!!!NB LIFE-T!E RADIATION EIP09Ulf AEDUATELY.
91 CIDBB3993 NRC INSPECTOR'S CONCERNS REVIEW INSPECTOR'S CONCERNS CLOSED. CONCERN WAS FOR TED9d!CIAN REGARDING FUEL PJNDLES REGARDING SURVEY!N6 EW REL USING A LIST TO REVIEW BY A@ NOT BY BLNDLES PROCEDURE. SURVEYING F EW REL ,
IGIDLES WILL BE D0'E BY PROCOURE.
32 CICB90085 POTENTIAL VIOLAT!DN RESPOND TO POTENTIAL VIOLATION CLOSED. TERE HAS MEN DIFFIClLTY, REBARDING IMCCURATE RESARDING SUle!TTAL OF INACCURATE AS EXPERIENCED BY OTE R SITES WITH
!W ORMATION - IER 87-04 INFORMATION REGARDING EIII LHOLE GETTING SOME EXITING PERS0lML TO EI!T MEETING BODY COUNTS OBTAIN tie REDUlRED Elli WBC.
FRESENTLY, A LETTER IS SDi1 TO TE i
INDIVIDUAL'S M3ST RECEKi ADDESS OR
( COMPANY REQUESTING Tmi A WBC E DOE i l AT FCS OR AT ANOTER SITE. CONSIDER- 1 ATIONS SHOLLD LE SIVDi TO A MORE AGGRESSIVE ETHDD, l.E.,1. REQUIRE A PENALTY BE PA!D BY C(NTRACTOR FOR l
i
(,-
'D Pege'13' r
OMRHR PLULIC POWER DISTRICT C0m!TNDIT TRACKING SYSTEM !
CONCERNB AND KSPOWES i ITER I CulCERN 8 SLELIECT TASK RElpolEE l
THOE NOT DETTINS AN Elli WC OR, 2.
!$1CATE THAT TE !$1VilluRL fulf WT ,
E 6ELC01E AT FCS 18LESS EIIT MC IS ,
(IISLETD.
93 CID890006 FAILUE TO ADEE TO RE500 TO POTDff!AL VIMTION 9@EREDED BY CID-890161/01. i l PEEDUE 50R C0lfTROL OF IEGARD12 FAILUE TO ADEE TO VERY HISI RSIATION AEAS . penrmart FOR TE CCDITR(L (F VHAR
!ER 8944 EXIT EETINS 94 CID890rJ95 PERS30EL RAD 10LD61 CAL WORK MONITOR STAT!!Di PERIDGEL S@ ERE D G BY CID-490Et!. '
PRACTIES RADIMSICAL WDE PRRCTIES FOR TE EFFECT!VEESS OF CORIECTIVE ACT10MB 95 CID8900?7 14N10PER 6E)RK PRACTIES BY llCREASE TE USE OF ON TE SPOT S@ERSDED BY CID-890221.
EALTH PHYSICS CORCHINS A2 CORNECTION OF IIPROPER WDE PRACTIES SY EALH PHYSICS TEO911CIfplS AND SLFERVISORY PERS018EL 96 CID890160 PROCDURfL GUIDANE FOR PROVIDE PROCDURALIIG EDANE CLOSED. SEE RPM 3.2.2.2. IEFEIENE FLASHINS LIGHTS IN HIGH AND LIMITATIONS FOR ll@LDENTAT!DN FC-RP-225-89. 5/8/89.
RADIATION AREAS OF 1)E PROVISIONS OF TECH SPECS
- 5. !!. 2 97 CID890162 PERS016EL QUARTERLY REVIEW INSPECTOR'S REMARKS OPEN. WILL BE CLOSED WEN RECORDS EXPOSURE - OPDi ITEM REGARDING VERIFICATION OF ARE UP-TO-DATE. PROJECT FOR THE REVIEW 8904/3 PERSul#EL GUARTERLY EIPOSURE - 0F ACT!VE FILES IS ON SCHEDLLE. IN-ACT!.
NRC FORM 4 WEN RECEIVED FILES WILL F(LLOW WITH A PROJECTG COIFLET!DN DATE OF 9/90.
l I
98 CID890163 RADIAT!DN PROTECTION RESPOND TO VIOLATION REGARDING SUPERSED G SY CID-890518.
PROCEDURES - VIOLATION FAILURE TO COMPLY WITH RP 6904 4 1 PROCGURES (CRAFTSMEN ENTERED INTO HIGH RADIATION AREA).
99 CID890154 FAILURE TO PERFORM E40LE RESPOND TO VIOLATION REGARDING SUPERSEDED BY CID-890518.
BODY COUNTS ON TERMINATIN3 FAILURE TO PERFORM WHOLE BODY WORKERS - VIOLATION 8904 4 4 COLNTS ON TERMINATINO WORKERS PER HP-1
- 00 CID890105 410LI BODY COUNT INACCURATE RESPOND TO VIOLATION REGARDING SUPERSEt{D BY CID-890518.
INFORM TION - VIOLATION SUBMITTING INACCURATE INFORMATION 8904-02 TO THE NRC IN REFERENE TO TERMINATING PERSOP4EL NOT RECEIVING WHOLE LODY COLNTS 101 CID890224 POTENTIAL Ml!G WASTES DETERMI T THE POTENTIAL MlIED CLOSED. MIIED WASTES AT FCS HAVE WASTES TO MAKE TIELY BEEN IDENTIFIED IN MEMD FC-RP-149-89
l- . . I Page 14 i l
l OMRHR MLIC POER DISTRICT Cum!TIDfi TRAD(!E SYSTEM ,
i CONERNS AND E90NES
.! TEM i C3ERN 0 S3 JECT TASK ESPO W NOTIFICAT!36/PEDIT APPLICATim DAfD 4/12/89 (BILAl TO IMR). M TO M DEC F0ll MlIG WASTE dBTES EE OBEAe Age PIEptILY ,
ACTIVITIES '
PGAED AND $70G. AT THIS TIE ME !$ 2 MY TO D190E IF MIIG l WSTES AIS TEY 185T E STOB. ;
102 CID890273 IEDUCIIS TE NLIIER OF C35ETE M EVALURTION TO EDLE Q.0ED. IG E FR31 I W A TO GATES, HIDI AlelATitBI AIEM M 14fER (F HIDI MDIATimi AEJE FC407-89, ADDEMS !WLBelTATitBI 0F A HOT-SPOT 1904. PAWRE. !
APPADIlllATELY 40 IST-DOTS ME BEEN IDENTIFIG NS EFFORTS TO '
ELIMINATE 04 REDLEE TIM leT-SPOTS IS IN PROCESS.
103 CID890501 POTENTIAL PROBEMS WITH REVIEW SUBJECT NOTICE FOR CLOSED. THIS ITEM IS CDElBED WITH f WOlBi DR DIST0RT G HOSE APPLICABILITY TO TE FCS NRC BLt.LETIN 89-47, POTENTIAL !
CLAWS ON SELF CONTA!ED PADILEMS WITH WOWI OR DISTORfD HOEE .
i '
BREATHING APPA MTUS Q.AWS OR SELF-CONTAIED SIEATHIE t
APPAMTUS. AT FCS, MlgtFACTUERS' EC3000AT10NS FOR IWECTICBl N '
EIN6 F(LLDED tlEE IP507). FC-IP-205-89, DAT G 6/12/ M (IEIR TO LICENS!N6) PROV!ES IIFOMAT!!BI AB TO TE CURIENT EVALURT!!BI PEIFOIDED.
i 104 CID890503 INCIDENT REPORT (!R) 880537 REISSLE PP-RCC-1 AS A RADWASTE OPEN PROCEDURE IS WRITTEN AND REGARDINS REISSUING MP-RCC-1 PROCDURE. DEVELOP & IMPLEENT A WILL GO TO PRC EFDE JAltlARY, 1990.
REACTOR CAVITY CLEANING PROEDURE, RW-515, AS STATED 1
l .05 CID890518 !ER 89-04 VIOLATIONS RESPOND TO IER 99-04 VIOLATIONS CLOS
G. PROCEDURE
TO ALLOW TRANSli REBARDING RADIOLOGICAL WORK REGARDING RAD 10LODICAL PRACTICES THIRJGH A VHRA BY QUALIFID RP TECH PRACTICES AS STAT D WITH APPROPRIATE MONITORING EQUIPENT j WAS LP FOR PRC REVIEW AND APPROVAL DURING EVALUAT!@i. PROCDUML l
CHANGE WOULD LEAD TO RESOLUTION OF THIS ITEM.
- 06 CID890580 TRANSIT THROUGH A VERY HIGH REVISE PROC GURAL REQUIREMENT TO UNDER LICENSING REVIEW TO CLOSE.
RADIAT!DN AREA - IER 89-04 ALLOW TRANSIT THROUGH A VHRA, BY RP-104 IS REVISED.
RESPONSE QUALIFIG RAD PROTECTION TEDI, WITH APPROPRIATE MONITORING EQUIPMENT, WITHOUT SECOND PERSON 107 CID890581 RADIATION PROTECT!DN C0plETE TE RADIATION PROTECTION CLOSG. TE RP ENCHAPCEENT PROGRAM DNANCDENT PROGRAM E)HANCEMENT PROGRM BY 9/30/89 MILESTONES ARE MING MET AND ARE CD@LET!DN - IER 89-04 WDER CONTROL BY TE RP SECTICN.
RESPONSE
108 CID890723 RADIOLOGICAL DCEURRENCES DEVELOP Q RADIOLOGICAL DCCURRENCES CLOSED. RP903, RADIOLOGICAL
. - . _ - . .- . . . . . .~
'Page 15 OMNR PWLIC POKR DISTRICT COMITH TRA(XIE SYSTDL
= = =ES,-S l
ITm e cicEM i SLs.TECT Tm uSP0mE EPORT (ROR) 1 Fl@lN6 REPORT (Il0R) SYSTDI TO BRIDE GAP QCCURIDEIS lEPORTIE 150 TIBSilE, D. 9-1 KTM M WomER PRACTICES MS ISSLED 9/1/89. PEEDUE AS ;
PROSilllM fue STATION INCIDDIT IEPORT ITS !@LDENTATI(Bi WILL CSKITF ;
109 C10090724 IFOMATIM POSTERS - POST IWDMATION POSTEltS, CNERIE CLOBED. SEVElWL OF TM POSTERS I
FINPils 19.9-1 VARIOUS RADIAT!!BI PROEIM AIEAS EllE DBERVED IN TE Pugif M ISA.
SUDI AS LDeellTOED SYSTEM 91EADES, A PLAN TO DEVE!D A SDER11 FOR IN VARIOLE I.0 CATI (DE WITHIN M RCA IW0ltfli!ON POSTER IS Ele EVILuRTD. i i 110 CID490726 PERSIDGEL CONTAMINATION VERIFY A IGl IECORDS NRNRIGENT CLOGG. M EVIS.lsnittBI TUpl IEVIDED EPORT - Fl@lNB RP 9-1 SYSTDI 36 EVALUATED FOR A STUDY OF A IECOMB IIIfEGIT
!@LDelTATitDi EGAllDING SYSTDI Tmi COLD RESIST IN M INBLFFICIENT D0230' TAT 10N (F EVALUAT!DN fue DOC 18ElffAT!!BI OF stRS30EL CCNTAMINATION REPORTS PERS0KL CONTAM!lfli!!E IEPORTS.
A RECORDS MANRWl9ff SYSTDI IS EEDED FOR TE RP SECT!!Bi IN ORER 70 MIN 1AIN TE RECORDS AW DIX 23Elffs Ale PEIF0lgt CERTAIN ANALYSES.
!!! CID890726 PiRSO N L CONTAMINATION !@LDENT Pil51DUIES TO EME CLOSED. RP903, RADI(LOGIClL EPORT - Fl@!N6 RP.9-1 REVIEW OF PERSONL CONTAMINATION OC(2)RIENCES REPORT 12 fue TIEISils, REPORTS BY SUPERVISOR-RAD. WILL SATISFY THIS TA R.
PROTECT!DN OPS As ASS 190ENT TO 3
!!! CID890726 PERSO N L CONTAMINATION PURCHASE A EW RECORDS MANA6 DENT CLOSED. SEE ITEM NO. 109.
REPORT - FINDING RP.9-1 SYSTDI FOR IMPLEMENTAT!DN REGARDING INSUFTICIENT DOCLMENTAT!DN OF PERSO N L CONTAMINATION REPORTS.
!!3 CID890728 WHOLI LODY CONTAMINATION l@LDIENT REVISED PROCEDURES TO UNDER LICENSING REVIEW TO CLOSE.
I' MON!TDRS - FINDING RP.9-1 INCORPORATE TE leilTOR NEW FROCEDURES WILL E l@LDENTED MODIFICAT!DNS INTO TE CALIBMTION FOR THE UPGRADE FENDING INSTALLATION.
TR06 RAM AS STATED L !!4 CID890728 WHOLE BODY CONTAMINATION PURCHASE UPGRADE PACKAGES TET LNDER LICENSING REVIEW TO CLOSE.
I MONITORS - FINDING RP 9-1 WILL DNANCE TE SDEITIVITY OF THE THE UPGRADE PACKAKS FOR TE PERSOHL WHOLE EDDY CONTAMimTION MONITORS CONTAMINATION MONITORS (PCM-1) HAVE AS STATED LEEN PURCHASED AND ARE SCEDLLED FORINSTALLAT10N.
!!5 CIDB907E9 PORTABLE NEUTRON DOSE RATE ADD TWO NEUTRON DOSE RATE METERS AT CLOSED. NEUTRON DOSE RATE ETERS - FINDING RP.6-1 THE SITE AS STATED METERS hAVE LEEN ORDERO.
!!6 CICB90731 TELISCOPING BETA GMA DOSE ADD 10 TELESCOPING BETA GAM m DOSE CLOSED. ;0 TELESCOETN6 RATE INSTRUMENTS - FINDING RATE INSTRLMENTS AS STATED LETA/SAMMA DOSE RATE INSTRLMENTS RP.6-1 HAVE BEEN ORDERED.
117 CID890731 TELESCOPING BETA GAP 9tA DOSE PROCURE 10 ADDITIONAL TELESCOPING UNDER LICENSING REVIEW TO CLOSE.
Pa9e 16 OMlHn PLE.!C MBER DISTRICT C0iptlTENT TRA(XIN6 SYSTEM i
CONCERNS AND RESPO WES ,
- . C M. Su.xC1 1. .S, j llATE INSiluENTS - FINDING DOSE MTE INSTRIOTS IN 1990 10 ADDIT!0NAL TELE 9CtP!W DOE MTE 1P. 6-1 IETEBENTS HAE IGN IREMETO FOR 1990.
116 CIDt90732 DEDICATO CllDi TO IEPAIR VERIFY A DEDICATD CD TO IIEPAIR Q. DIED. RP NAS lE5GS181LITY FOR AS CALISMTE PORTABLI As CAL!BARTE PORTABLE MDIATIIBl IDAIR A2 CILibHRT!W F PORTIEE 1151AT1(31 follTOR!lE MONITOR!lE EEllPIENT WAS F015ED SulNEY ETERS. PIEENTLY TWO BEDICflTD I EEllPIENT - FINDINS RP.6-1 AS AS$1BIED CIBITRRCTORS A. PEFOMIN THis ENVIE.
IT IS OBVIOUS TET MRIUSILITY F llSTRBENTS HRE liplENED.
119 CID890736 PORTABLE RADIAT!(BiIOilTOR- WRIFY A REFUllB!SHING A2 20 SED. MielR S(MEZ LED TO DILitiglTE Ils EQUIPIENT Pil0CDUES - VERIFICATI(k 0F fppD'S POR'ABLE MDIATitBI1RBitTOR!W ERl!PIENT FlWING RP.6-1 RADI(LOGl'AL INSTRBOT HkS KEN lik*AJP9190 lIS lEERIFIG BY T CALIBMTION SalRCE WAS MNHCTURER.
CJPLETED
.20 CID890726 PORTABLE RADIATION MONITOR- IIMDEXI PROCDullES FOR CLOSED. fil0CDulES ISPLIED 9/1/69. [
IDE EQUIPIENT Pil(EEDullES - CAlliiRATION AND REPA!R OF PORTABLE FidlN6 RP.6-1 RADIATION MONITORIN6 EQUIPIENT 121 CID890736 PORTABLE RADIATION MONITOR- IIFLDENT PROCDUML REQUllEIENTS Q.0 SED. RP-402,
- CAL 18AAT!!BI AIS TEST IN6 EQUIPENT PROCDURES - SPECIFYllE COIBION INDUSTRY PRACTICES REQUlllDOTS FOR MDIAT!!BI PROTECTION FINDIN6 RP.6-1 FOR INSTRBENT CALIBRATION AND EQUIPMDiT,' ISSLED 9/1/89 ADERInTELY CALIBMTION SOURCE VERIFICATION ADDRESSG C0le10N llSLETRY PilRCTIES FilEDUENCIES FOR INSTRulOT CAL 1911ATI(Bi AND SIMICE REVERIFICATION FREOLEEIES.
122' CIDB90738 HOT SPOT REDUCTION PROGRAM - MVE THE HDT SPOT REDUCTION OPEN PENDING LICENSING REVIEW TO CLOSE.
FINDING RP.4-1 PROGRAM OPEMT!DNAL LY OCTCER TROGRAM IS GEERATIONRL. TE ALARA GROUP 1589 MS LOCATED APPR0!!MTELY 46 HOT-SPOTS AND IS PRESENTLY ADDRESS!!E TE METHODOLOGY TO ELIMINATE OR ROUCE TE LEVELS FROM THE HOT-SPOTS. LICENSING WILL SUBMIT TO INPO.
123 CID890739 FORMLIZED PROGRAM IMPLDOT A FORMAL!!ED PROGRAM CLOSED. RP901, RADIATION EFFECT!VDESS REPORTING EFFECTIVDESS REPORTING SYSTEM TO PROTECT!DN TROGRAM EFFECIIVDESS SYSTDi - FINDING RP.1-1 PROVIDE MNAGOOT WITH CONCISE REPORT, WAS ISSL D 9/1/89. Fil06MM IWORMAT!DN FOR RADIATION WILL SATISFY REQUIRDIEN! 0F PROVIDIN6 PROTECTION PROGRAM MMGDOT WITH CONCISE IWORMTION REGARDINS RP PROGRAM.
124 CID890739 FORMALIZED PROGRAM CLOSED, ALL RP PROCD URES UPGRAX PROCEDURES TO PROVltC EFFECTIVEESS REPORTING BETTER GUIDANCE TO THE RADIATICN HAVE LEEN REVISED AND ISSUED ON SYSTEM - FINDING RP.1-1 PROTECT!DN TEDNICIANS ON 9/1/89. RP TECHNICIANS REVIEE D MONITORING REQUIREENTS FOR ;ROCEDURES TRIOR TO TEM BEING RADIOLOGICAL WORK FINALIZED.
125 CID890739 FORMALIZED PROGRAM MVE OPERAT!DNAL A RWD CLOSED. RP308 HAS KEN ISSLED.
EFFECTIVDESS REPORTING SURVEILLANCE PROGRAM TO FURTHER
_ ,, _ _ _ . _ _ _ _ _ _ _ ._ - - - ~- -- - -
Pegt 17 ..
WWDtA PLELIC POER DISTRICT CDOIITIOff TRACKl'3 SYSTEM C(MIINS AND EBOEES
- 4. 4 CDEERN6 SLBJECT TASK RESPONSE SYSTEM - Fl@ll6 IIP.1-1 DHANE PERF0lIWBdCE IN THIS AREA BY F0lflAL EVALUAT!QN OF RADi(LOGICAL JOB FLNCT!DNS AND WORK 126 CID890751 !@0 OUTAE IWueAIEIENT EVIEW !@0'S SIGNIFICANT llEIDOIDi- OPEN.
ABSISil8EE VISITS IECDOEN- DATIONS A2 STIEETHS FROM OUTAE DATIONS IWINASDENT AS$1STNCE VISITS FOR flPPLICABILITYTOFCS.
127 CID090752 POTENTIAL lEANIESS IN ADDESS POTDITIAL lEAMIESES IN l8SER LICDIS!N6 REVIEW TO CLOSE.
IIADI(LOGICAL (Dfill0L RADl! LOGICAL C(NTil0L PilACTICES RP HA6 Pfl0V!DED !@lli TO LICENSIN6 PilRCTICES DIERG DURIN6 TE 1989 ApetillL IN ESPONE TO C0lEIllNS IDENTIFIED EERCISE AT SLBOER lil0RAAL DRILL.
128 CID890766 STOMGE AEA ECDOOSATION REVIEW INSPECTOR'S RECDOENDRTIONS LNDER LICENSilvG REVIEW TO CLOSE.
REGARD 12 ST0llAGE AREAS }WlVING BASS PILG IN A Mp0 DER THAT ,
INTERFERED WITH PLANT DPEllATIONS j 129 CID090794 POTENTIAL EITIEMITY OVER- IEVIEW !@0 ER FOR OPEN.
EXP(AllE DURIIS STEAM 15'PLICABILITY TO FCS GDEllRTl!N Q.0SEOUT lidiPECTION - 14 ELE 4R ETeiDilk l 130 CID890912 RAD 10RCTIVE MTERIAL SHIPPING REVIEW FEERAL E61 STER RE6ARDING LDGER LICENSING REVIEW TO CLOSE.
10(TR49 PARTS 171,172, AND 173 AEGARDING SHIPPl>Ei 0F RAD 10RCTIVE MTERIALS 131 'CID890912 RAD 10 ACTIVE MTERIAL SHIPPING REVISE RW-219 BY IPCORP0llATIE OPEN. ISSLED !!/9/89. CHA>EiED NEW CRITERIA FOR "REPORTABLI PROCEDURE SENT TO LICENSING.
QUANTITIES' AND ALL SHIPIENTS AFFECTED BY OVINGE MUST BE HALTD 1
~ _ _ _- ,- . - _ , -
.. . . - . . . - . - - - - . . - . .. .... ._ .~ - -
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8 Ah1ATION PROTECTION ENHANCEi ,,,ux PRtvmans ACTION PTAM ACTION ITEMS I
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. - . . , _ _ . _ - _-. -. .. _ _._.m,_.~. .___, . .., _ .-.- _..
i !
PDRT CAlal0UN STATION l RADIATION PROTECTION ENHANCDENT PROGRAN Mort Category 1 - Organization and Staffing NOTE: the response categorizes each item (1, 2, 3. or s) as defined in the Commitments portion of section 3.0 1
l' Item N A r 1 l-Reorganize Radiation Protection, Radioactive Waste and Chamistry. ,
(lLiP 0, iDis 1-1, iGic 265/ss05-07)
Response Number 1 .
l The RP Organization was reorganized and is presently in place at a full staffing level. Chemistry is not currently assigned to the RP organization. 2 ,
l t Jten Number 2 l
- i. Improve selection, training and qualification of petisonnel.
(RIP 0, HNS 12)
Eeunonne Egnbar 2 Job descriptions have been vritten, training program han been 1NPO certified and qualified personnel have filled the new positions. 1 ,
Item Number 3 Improve interfaces between corporate and station dosimetry.
(RIP 0, HNS 1-3)
Resoonse Nu=her 3 There exists only station dosimetry in the new organization. 2 Iten Numher 4 l
I Clearly define the responsibilities of the Radiation Protection and IEC groups in regards to the acquisition and maintenance of portable health physics instrumentation.
(RIP 0, HNS 1-4) '
i
!- Response Nn=her 4 The RP Section performs calibration and repair of survey instruments in the new organization. In-line and process instrumentation is serviced by I&C.
1b1 .
Item Number 5 Investigate pathways for improving communications between the radiation protection group and other plant groups such as maintenance.
(RIP 0, HNS 1-5)
F047/1 1- 11/89
9 4 j
i l
i l
- Rannonge leumber 5 l
1 The policy of the Supervisor-Radiation Protection was reviewed; good effort initiated on all Coordinator levels; the new Radwaste Supervisor is '
pursuing these enhanced communications. 1 Item % = L e 6 j
Combine Special Services Respiratory Protection, and A1 ARA function into one group called Radiological Health and Engineering.
Ramponaa 10 umber 6 Radiological Health and Engineering Group formed in new organization 1 Item N==Lr 7 Increase the staffing of professional and supervisory personnel by three professional health physicists in the Radiologir.al Health and Engineering group, i
(RIP 0, HNS 1-7)
L 1 Beanonse E-M Additional professionatu he.ve been selected and hired to fill the completa organization chart requirr.mont.s.1 ,
f Item Number 8 Establish a foreman position for radiclogical operations and a foreman for surveillance and instrumentation in tne Radiation Operations group.
(RIP 0, IDiS 1-8)
! l I
Renconse Number 8 A l Item Number 9 l
Keep contractor technicians to a minimum and fill authorized complement of OPPD technicians. Develop a staffing plan to achieve this objective. ,
i (RIP 0, IDiS 1 9) i Response Number 9 '
I i
Staffing has been completed. Contractor technicians fill needed positions and are used for outages. Efforts to minimize use of contractor !
technicians is in place. 1 1 4
F047/1 2- 11/89 l
i .
)
f
- l. Item Number 10 I
l Increase staffing of the corporate group, Radiological and Environmental Monitoring Services, to provide additional espertise for support of plaot radiation and protection and chemistry programs. !
(RIP 0, HMS 1-10) .
1 Rammonne Numbar 10 Corporate grog is under development with charter to be completed in l mid-1990, 1 and &
l l Itan Numbar 11 Add three professional specialties to the Radioactive Waste group - one {
I health physicist for overall packaging and shipping program support, and 1 two radwasta engineers for Dry Active Waste, Process Control Program, and operatfanal technical support. I (RIP 0, hNS 1 11) 1 l Rennense N
- r 11 1'
l New RV organizattoi, addrs.stes the needs for additional profesrioral l- support. Radiological Engineering positiotu attahliched to address th.ts .
! issus. 1 and &
L hN 1-J Re-evaluate the supervisory and tschnician staffing levels. structure, and responsibilities within the radiation prctaccion organization.
(R;P 1, Cheeston II-7)
Resnonse Nii=her 12 New RP organization addresses this item. 1 '
frem Nii=her 13 l
Change the existing Technician assignment to allow all technicians to be a part of the shift rotation.
(RIP 2, Chomston II-7)
Response Number 13 As technicians complete shift technician training, they will be considered for shift rotation. As of this date, two technicians assigned to other groups within the RP department are completing the shift technician training. s Item Number 14 Provide a full time clerk to the dosimetry group.
(RIP 3. Cheaston II-8)
F047/1 3- 11/89
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l Ramaansa V r 14 Additional staff has buen added to dosimetry in new organization.1 t
Iw u r is I Radiological protection standards must be integrated into the operation and :
maintenance of the station by all personnel. !
(RIP 7 OPPD 16) i Raapense lhamber 15 l
L initiation of new procedures, organization with a position management style and resources will set the stage for ' setting the sameple" for the development of practices / standards to a satisfactory level. 1 Item Ni= L e 16 Identify areas where radiation protection support resources hacone strained
!. or overicaded. Provida additional rew urces e evaluate the load ;
! dictrilution among the prestint resources. !
(RR' 13, OWO 2)
Etsaarue Numhey,,1$
- Eeveral audhs have been completed that address this concern. Primarily, the Hydro Nuclear Audit addressed this concern and corrective action has '
j been taken with Added staff ano rer.nuncen.1 & J i
11em N mher 17 Identity present resources strengths and weaknessos. Correct weaknesses.
Develop thren year program to prevent problem recurrence.
Resconne Ni=her 17 Again, audits and evaluations have identified strengths and weaknesses.
Corrective action has been made thru the enhancement program with a target '
for completion of approximately one year.1 & 2 Item Nimher 18 Add additional depth to organization structure such that there is a supervisor of health physics between the CRP supervisor and the plant health physicist.
Resoonse Nimher 18 New organization includes Supervisor. Radiation Protection (RPM), with three disciplines reporting to the position. Chemistry is a separate function.
162 F047/1 4 11/89
t Itan ihmber 19 Review current position descriptions and include scope and limits of authority for each position.
1 Ramnenan llumbar 19 i i
Position description has been reviewed with scope and in t of authority defined. I 1 Itan ihmbar 20 Identify all responsible positions within the organisetion and provide written, approved descriptions of these positions so that all supporting Groups clearly understand the roles and purposes of the position.
Resoonse Number 20 Has been accomplished with RPM, new organization and position descriptions.
1 i
i Iten Wtmeek' 21 1 1 I
Publish an orgnnizational chart of functional positions in the Radiation Protection Manual. 1 (RIP 18, OPPD 0) !
ggggonne N=har 21 '
Accomplished with new organization in RPP. J. !
Item Number 22 Clearly define corporate radiological protection responsibilities, organizational structures and interface / authority with the station radiological protection management.
{
Resoonse Number 22 This task is scheduled for completion in mid.1990, 1 Item Number 23 Develop one corporate staff that handles long term projects and is a s resource to the plant, but not responsible for supporting daily operation I directly.
Resnonse Number 23 1
Scheduled for completion in mid.1990 1 F047/1 .$. 11/89 1
- _ _ .________.._____.______________.I
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Item Mushar 24 One corporate radiological protections staff should be developed to address f technical imamos related to radioactive waste, health physics, A1APA, ;
internal and eaternal dosissetry, and respiratory protection policies. :
(RIP 21, OPPD 118) 1 Ramponaa ahambar 24 Specific areas have been discusand with the Supervisor, Radiation Protection. Scheduled for completion in mid.1990 1 Itan 1hambar 25 >
Establish a corporate staff that h==dles long term proj ects and is a resource to the plant, but not responsible for supporting daily operation directly. ;
(RIP 22, 0 PPD 118)
Resoonse Number 'd Scheduled for completion mid-1990 1 ;
Iten Numbe'- 26 Determine by talking to plant health physics pe9ple what aross in tha health !
physics area the ec,rporate group could help with.
(R7,P 25, OPPD 121) '
Esaponm Eunber M ifas been reviewed wit.h Supervisor Radiation Protection.1 Item Number 77 Evaluate the structure of the corporate support group for radiation protection.
Resoonse Nn=her 77 Scheduled for mid 1990 1 & 2 Item Number 28 Place the responsibility of RPM at the level of supervisor health physics in order that the RPM can provide direction on a timely basis without the weight of responsibility for the station chemistry.
Resoonse Number 28 Completed with new organization.1 F047/1 6 11/89
i Itam _M M r 29 i Develop a corporate radiation protection staff vith resources to fully I evaluate radiological trends, recommend effective corrective actions and ,.
provide senior annagemmat comprehensive summary analysis of all major i radiation protection activities. !
(RIP 28, OFFD 123) !
Ramponaa theber 29 Scheduled for completion mid-1990,1 & 1 Itaa Number 30 Add destastry records clerk to the staff. Use junior type technicians to ,
suppleanne this activity during outages. The constant turnover of people and low level of staffing results in loss of time in processing the workers.
(RIP 64 Chomston IV-5) -
Resoonse Number 30 Domimetry staff has been supplemented. Additionel contractor staff has 6
been assigned to bring active and inactive records up to-date. 1 1
i Item Nuehg d l
\' ;
Of?D chould consider assignimg heelth physics workers to six shifts in order to improve creamunication with other groups.
(KII>231 SUEC 4.9.4) l l=
Resp,nnre.NunttI,Al "
1 .
l /resently six shifts are implemented. 1 and 4 i
Item Number 32 Functional job descriptions should be developed before the new organization is implemented.
Resoonse Nn=her 32 Completed and approved job descriptions have be:en developed for all positions. 1 Item Number 33 OPPD needs to increase staffing.
Resoonse Nn=her 33 Staffing has been expanded and appears adequate for the present program. A F047/1 7 11/89
r FORT CAIBOUN STATI0lt l
RADIATION PROTECTION ENHANCEMENT PROGRAN I Nort Category 2 - Surveillance IteELAREbEL.36 I
Provide management overview assistance for reviewing routine survey natters [
and RUPs and for overseeing coverage of work in progress.
(RIP 0, HMS 2-1) '
Rannonna thambar M Included in new procedure 1 '
Itan Mumber 35 Rewrite routine survey progran, including implementing procedures.
(RIP 0. HNS 2-2, NRC 285/8805 08) ;
Reasonne N==k=r 35 '
i survey prograa has been ' rewritten und reviewed by evaluatien team.1 Ltaa.jbahtr M !
Identify r- nothod fnt- addirg and dels ting areas from the routiss an 4 tempoesry or pennanent basis.
(RIP 0, HNS 2-3).
i Ex m ase Nt
- I.lf l
Mechodology has been developed by procedure ,1 Item Ni=her 37 ,
Develop detailed guidance on tho writing of RVPs. '
(RIP 0, HNS 2-4)
Resoonse Ni=her 37 New RUP procedure provides detailed guidance.1 Item Ni=her 38 Develop a short training program on the writing of RUPs.
(RIP 0, 2-5)
Resnonne Ni=her 38 Training has been provided. 1 '
F047/1 8- 11/89
I ,- ,
Itan Mumbar.39 Do not allow phrases such as directed by MP to be entered into the requirement section of the RWP.
(RIP 0, nets 2 7)
Rampensa thspher 39 New procedures and directions have eliminated such phrases. 1 Itaa thamber 40 Enter more detailed survey information onto the RWP.
(RIP 0, 158 2 4)
Raspanna Mumher 40 Completed. New RWP procedure. 1 Itan N==har 41 Dovelop a mechanism by which routino and periodic surveillance data are reviewed to identify trends and poseihin additioul action and incorporate
!' 'inco pu cadores.
(RIP 0, V.N3 2 9)
L- Reinonse lhaqbar 41 Completed. N#N procedure. 1 l 14E.flMahRL3Z Amend the RWF approval process so that the more routite RWP4 are approved i at a forr man or supervisory lavel and RVPs wich higher man-rem commitment or greater radiological hazard are referenced to the Supetvisor Radiation Protectf.on.
(RlP 0, HNS 2-10)
Resnonse di=her 42 l RWP procedure has been rewritten and incorporates the new approval process.
1 Iten Ni=her 43 Provide instrumentation training for the technicians highlighting such areas as uses and limitations for each instrur.ent.
(RIP 0,1 Dis 2-10)
Resnonse Ni=her 43 Some training has been initiated. Additional training is scheduled. 1 F047/1 9- 11/89
4 0 f
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Item madpar 44 Develop procedural guidance on correcting for source size. !
Rannonne mannar 44 Procedures have been rewritten to incorporate correcting for source sise.1 ,
Item maahar 65 I
i Develop operational procedures for eact. instrument in use. '
) (RIP 0,1888 2-13) t Rampensa ilumber 45 '
Completed. New procedures. 1 Item N a -r 46 l Develop a procedure defining and describing surveys to h3 sade utneva >
(.' providing job covsrage. '
- (RIP 0, Miss 2 14) lL :
{ Et3RRhpe. M L f. 4 l
Completed. New pr;ocedures. 1 1 1%E E2Mh1 i=
Chan6e the WP 4 t,taa to make it more meaniugiul by est kblir.hir.g ths l
- e m eute t.on*, rate ar.d teequiramer.ts en the RWP.
(R*/# Go, Cho u cou vil) 7) i gescome Ntater 47 Completed. New Procedures 1 Item'Nin=her 48 Provide more standattiization in radiological protection requirements and
- - work practices.
(RIP 72, OPPD 30) i Response N'=her 48 See new procedure RP 904, Radioloeical Vork Practices Procram 1, 1 l- Item Ni=her 49 Develop a !!ot Particle Program.
(RIP 73, Cheaston VIII-8)
F047/1 -10 11/89
o l o. . l 1
c Raanoman Number 49 1
- Hot particle program has been written, reviewed by PRC and implemented.1 Itan Number 50 consider the followias recommendations een revising the controls for entry 1 to Very High Radiation Areas. (Short ard long term) i (RIP 74 Cheaeton VIII.8)
Rannonsa Number 50 Addressed individually below. ;
r Item M A r 51 Old hot spot stickers she' 4d be removed and hot spots should be identified {
with a more readily replaceable posting label, i l
i BAJDonne Number 51 Cogleted and obsarved by evaluation tems.1 ,
trem N A r 52 f 5
- Provide specific guidanco rsgr.rdlug fragtr.ncy and duration of intermittent l job coverage by radiacion protectica personoel. ,
(RIP 78, OPPD 33) j- Resnonce N3 =ker 52 l i in new procederos. 1 Item Ni=her 53 '
Procedures will be changed to prohibit the use of protective clothing in
-clean controlled area except as permitted by Radiation Work Permit.
Resnonne Ni=her 53 In new RVP procedures. 1 Item Number 54 For the workers, establish personnel and tool decontamination criteria in cpm and not dpm.
I (RIP 96, Cheaston V-5)
Resoonse Number 54 In new procedures.1 F047/1 11 11/89
- , - , - - , . - - . , - --, - -- e ,- - ,
o .
Itaa thumhar 55 consider elimination of lab coats or restricting une to bench-top contamination operations. ;
(RIP 94, hton V 6)
Raananaa thamhar 55 b ,
Itan thunbar.56 l Initista standard method for setting up and maintaining contaminated area control points for HP technicians se the personnel can be ~ instructed in the standard method of disposal into plainly labeled receptacles.
Ramnenae M A r 56 Radwaste procedures have been revised to improve contamination control. 1 i
Iten Ni ar $2 i RE evaluate containment entrie.a until the results of the witius air sempting acelysis are known.
(RIP 114, Cheaston VI 3) s 1eznor.no N A r__$1 ,
hcommendstion folbred.1 !
l ltRE.SSAtLil i< Restrict the use of plastic suits for tritium protective practices.
L (RIP 116, Cheaston VI-4)
Resoonse Nn=her 58 Completed. 1, 1 Item Nu=her 59 Revise and consolidote the documents relating to the air sampling program so there is a set of operational instructions for collecting an air sample, a set of operational instructions for analyzing an air sample and a set of action levels.
Response Nn=her 59 Completed. 1, 2 F047/1 12 11/89
l i
c I
l Itan Mumher 60 i Eliminate the use of the CANS for quantifying airborne activity levels. In addition, limit the sampling line length and change to a material where i particulata deposition is less likely.
(RIP 125, Cheaston VII-3) ;
Rannonna Mumhar 60 New procedure. 1 '
Itan Mumhar 61 Re. evaluate the containment air saryling entry program. Consider the use of air sampling for long (greater than 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) entries and the need to determine the tritium concentrations prior to entry. '
(RIP 127, Cheaston VII-3)
Resoonse Na=her 61 New procedure. 1 I
( >
L l
ltaaJsehar.62 -
3 l_ Ectablish .an air suspling qustity cratrol program ttu t includes L r'niew/analysta of date.. . determinacion of existing equipment / materials, and p- effectivaness .u.d trending analysis of alpha and high energy bete !
centaminants.
(RIP ll28, Cheaston VII-4) 3ciL9).04S IiWehAK. 62.
New procedure. 1 '
t i ten Nn=he r 63 '
A method _ for rapid field assessment of air samples should be developed. 4 This method abould allow for qualitative assessment of particulate air l filters and radiciodine cartridges.
(RIP 129, Cheaston VII-4)
Resoonse Nu=her 63 New procedure. 1 Item Number 64 Set limiting parameters for flow rate drop on air samples so instead of '
always averaging the start and end flow rates, the technician is directed whenever large drops occur to either take a new sample or use the end flow rate to calculate the activity.
(RIP 130, Cheaston VII 4) 4 ro47/1 13- 11/89
'NnnXh n
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- , )p ~$%7 3 93 my y,W Raanonna Nunhar 64
, 'New procedure. 1 I
i/ ,- +-
Itam %
- r 65- I
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. Develop : , a written policy statement in accordance with NUREG 0041 requirements, (RIP 131, Cheaston IX-4)
Rannonna Na=h-r 65 t
E Completed,1-g:. Item Nn=har 66-Detailed guidance will - be developed and proceduralized for air sampling methods and frequen::y by October 1991.
(RIP 148 --INPO 88 page 13)
Ramnonne Nn=har'66 Completed with new procedures. 1 Item Nn=hEr 67 i
Detailed guidance will be develope. . proceduralized for the frequency I'
and, type of -radiation and conte . ion surveys to be taken during L- radiological work by October 1991.
.Renconse Nu=her 67 Completed with-new procedures, 1 Item Nn=her 68 Signs providing reminders of proper protective clothing dressout will be
. posted at primary dressout areas. Signs providing reminders of proper undressing procedures will be posted at primary undressing areas.
Resoonse Nn=her 68 ccepleted and observed. 1 Item Number 69 s
Specific worker guidance related to self contamination such as wiping sweat and touching glasses will be developed, proceduralized and disseminated by September 1988.
F047/1 11/89 sa
Raanonna Number 69 .
New procedure. 1 i l
- Item N==ker 70 Guidance be on worker provided-as in RP.cont 9-lb.==ination of areas outside contamination zones will I. (RIP 156, INPO 88 page 19)
Rannonna Ni ar 70 i
New procedure. 1 Item Ni=her 71 ,
Procedures will be changed to address frisking upon exiting- from contamination areas.
Rannonne Nin=her 71 i
. Procedures have been changed. 1 Item Nie=her 72 Establish written procedures for use of step-off pads and removal of anti-contamination clothing to support this criterion and post at exit boundaries of contaminated areas. '
Resoonse Ne=her 72 New procedure 1
-Item Number 73 Use whole body friskers when exiting the RCA.
(RIP 180, Cheaston-X-17)
Resoonse Number 73 Completed and observed. 1 Item Ni=her 74 All 1987 skin and clothin6 contamination reports will be reviewed against INPO reporting criteria. A revision to the 1987 OPPD reporting of skin and clothing contaminations will be sent to INPC by August 1988.
Resconse Number 74 1987' cone ==ination reports were reviewed against INPO criteria. Revision has been provided to INPO. 1 & 1 F047/1 11/89
1 I
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Item N==k-r 7 5 4 l
Increase management and supervisory monitoring of radiological work in l.
progress to identify and make on-the-spot corrections of improper work l
)
practices.
i Restenan N==kar 75 Completed and observed 1 & 2 I Item N==k-r 76 Strengthen radiological survey requirements to ensure that surveys .
. accurately assess the radiokgical conditions encountered by workers prior to and during radioactive work.
Remoonse Ni=kar 76 Completed by new procedures. 1 Item Ni=har 77 Increase monitoring of radiological work in progress to identify and j , correct improper worker practices.
Resoonse Ni=her 77 Completed and observed. 1
~
Ites Number 78 Personnel contamination monitoring equipment should be _ placed to allow personnel to survey themselves when exit.ing contaminated areas.
(RIP 222. INPO 86 page 40) i Response Ni=her 78 Completed and observed. 1 I
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FORT CA1210UN STATION RADIATION PROTECTION EEHANCEMENT PROGRAM
.Nort Category 3 - Personnel Selection, Training and Qualification i
- Item N==har ' 79 Establish managerial and technical training programs for first time ,
supervisors. '
(RIP 0,1.His 3-1).
Response Number 79 Pull . training program is being evaluated. Tr=ining programs will be established. 1 Item Number 80 l
.- i i
Insure personnel selected for positions are fully qualified. !
(RIP 0, HNS 3-2)
Resoonse N==har 80 t l ;
New organization, new staff, new position descriptions ensure this. L 1 !
Item N==har 81 '
Establish. required management training course for the Supervisor -
Radiation Protection.
-(RIP 0, HNS 3-3)
Resoonse Ni-her 81 Training has' been established. Some courses have been e.ompleted with a satisfactory schedule for additional training.1 Item Ni=har 82 Establish entry level tests for technicians and technical persons to assess -:
their capabilities for the radiation protection field.
(RIP 0, HNS 3-4)
< Resoonse Number 82 True for contractor technicians. Do not yet have for "in-house" people.1 Item Number 83 Establish testing process to determine which personnel from the technician and technical fields are most suitable for management training and management positions.
(RIP 0, HNS 3-5) l F047/1 17- 11/89
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i- _ Ramnaa.e 2 ' r 83 l
l Some effort has ' been made in this area.- However, trsining is looking further.at this. 1 Item E==k-e 84 1
Develop ' specialized training for personnel- in areas such as dosimetry processing, radwaste, and respiratory protection.
(RIP 0, Hits 3-6) n..none. m.=k-r 84 ,
1 F
This activity is on-going for all areas; personnel have attended several I courses and seminars. 1 '
Item Nin-k-r 85 Develop and implement a formal review process that requires approval by the j Supervisor-Radiation Protection for all training lesson plans and materials l to radiation protection.
(RIP 32, Cheaston 111-3)-
Resoonne *==her 85 l
Supervisor-Radiation Protection reviews training material and periodically l i
monitors courses. Formal review process is not in place. 1 Item Nin=her 86 Develop a system for incorporating both plant and industry experience into the training material.
(RIP 33, Cheaston III-4) i Response Number 86 RP personnel have attended EPRI annual seminar for RW experience; this-should continue. Industry practices / events are included in technician (
training and requalification training. 1 '
Item Number 87 Consider the establishment of an AIARA training course for engineers and supervisors.
(RIP 35, Cheaston III-4) )
i Response Number 87 l This topic is under review. 1 I
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F047/1 -18 11/89 1
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Iten Ni= 6 r 88-Add a training shif t to the radiation protection complement and - include supervision in some of this training.
(RIP 36, Chomston III-4)
Rasnonne N==Le 88 Presently there are six shifts. Extensive training is e=Hnr place at all levels. 1 & (g l
Item Ni=Lr 89 1
Develop a formal self-monitoring program.
(RIP 371 Cheaston III-4)
Resoonce N==ker 89 Not developed at this time.1, 4 Item Ni=her 90 .
Develop a training lesson for non-radiation protection managers and supervisors on fulfilling their responsibilities in radiological areas.
Resoonse Ni=her 90 Training- department is reviewing appropriate lesson plans for non-radiation workers. Present CET also addresses these issues. 1 Item Number 91 Continue aggressive approach to training health physics people to reduce contractor usage and establish an in-house staff that will further program effectiveness.
Resoonse Number 41 Close attention is paid to this as contractors are used only in areas for which expertise has not been fully developed in house.1 Item Numher 92 Determine specialized tasks that are not covered within the existing curriculum.
Resoonse Number 92 On-going process. Training program under development to better address RPT and RPTT needs. 1 F047/1 -19 11/89
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Itam DAr 93 I l
Complete lesson plan review so that technical training can start.
Reasonna D A r 93 i Closed. Training has been reviewed and is an on-going process. 1 l Itan !
E=kar 94 j
Evalusta what resources and man-power will be required to meet the 1987 INPO Cuidelines for training.
Resoonse E=her 94 Training has received INPO certification and manpower needs have been evaluated. 1 Item *=her 95 Determine how frequently continuing training can be supported by the techs and senior people and still support day to day operations, )
Resnonne Ni=her 95 New or5anization provides staff that can support continuing training needs.
i 1
I l Item Number 96 Continue technician training. Include system training.
Response Number 96 Training of technicians is continuing. Systems training has been incorporated into technician training. 1 Item Ni=her 97 Ensure that all technicians have signed off training sheets and train senior technicians.
Response Number 97 j
Program in place. 1 l
F047/1 11/89
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lt;ag Number 98 l Establish a- detailed program for requalification and specify frequency of required requalification for specific tasks.
Roanonsa Na=har 98 Completed 1 Itam _mer 99 Designate, within the radiation protection group, a single point of contact (CNE) to provide radiation protection changes as input to training department. j (RIP 49, OPPD 28) '
1 Renconne Nn=her 99 Completed 1 Item Nn=har 100 l
Bud6 et item requests for attemi== e at professional meetings, conferences. l and workshops, (i.e., HPS, EEI, EPRI, and INPO) need high priority in order to reap the benefits of District membership in these organizations.
Resoonse Nn=her 100 RP budget includes meeting attendance at appropriate professional groups.
RP has attended EPRI and other meetings as needed to maintain technical i awareness, l' Item Number 101 Health Physics continuing training must be addressed for personnel assigned long term to the Radwaste group. '
Resconse Nn=her 101 L
This is being reviewed by Supervisor-Radiation Protection. Training department is developing new technician training program for RPTs and RFITs. 1 & 4 Item Number 102 1 L
Changes to the procedures will be factored into the health physics I technician Training Program Master Plan. !
I 1
F047/1 21 11/89
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i l- Training is aware and new procedures are being reviewed for incorporation into training. This a a major project.1 Item Ni=kar 103 Consider changing the tim technician annual requalification program such that various operational situations are presented and must be resolved.
Response Number 103 This item is under review. 1 l- Item Ni=har 1G4 Additional attention needs to be given succession planning for key employees.
- l. Resnonne Nii=her 104 1
Succession planning is in progress. 1 & 4 Iten Ni=her 105 OPPD must develop programs -to improve the skills of ==nagement and
- supervisory personnel.
Resnonse Number 105 i
Management training is in progress, coordinated by Organization and' Development group located downtown. 1 F047/1 22 11/89
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l-FDRT CAIR00N STATION RADIATION PROTECTION ENHANCEMENT PROGRAM Mort Category 4 -- Radioactive Waste Management Item Ni=har 106 In preparation for the outage, draft a strong policy. statement emphasizing.
the need to control the generation of radioactive waste.
l (RIP.O. NHS _4-1)
Rannonaa E =kar 106 This is resolved in the OPPD Nuclear Policy Manual and Standing Order C-63, 1
Item Ni-kar 107 Identify and develop the missing elements of the PCP in addition to those '
elements which require revision.
(RIP 0, HNS 4-3)
Reanonne N==har 107 %
Procedure RW-200 addresses the PCP; a review reveals that the PCP has been substantially revised; additional review and " tweaking" is desirable and is currently underway; the issue of mixed waste and hazardous wasta needs further attention 1
. Item Ni=kar~108 1
l Define a schedule for PCP Program development and implementation.
(RIP 0, HNS 4-3) i l Resoonse Number 108 l
This was addressed in the overall efforts to date and the 9/1/89 issuing of l: new RW procedures. 1 Item Number 109 Perform an in-depth QA/QC audit of the Process Control Program to be used as a baseline for program improvement.
Resnonse Number 109 The program has been improved. 1 & 4_
i' Item Number 110 Revise the Process Control Program based upon revisions made to the overall Radioactive Waste Management Program.
(RIP 0, IINS 4-6)
F047/1 -23 11/89
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-l Rannonna W=bar 110 1
This has been done with issuance of RW-AD-100 'and RW-200 1- 1 Item E=ker 111 i I
Submit ' the revised Process Control Program to the NRC for review and approval.
(RIP 0,1915 4 Rannonna E =kar ill The PCP will require submittal with the next Semi-annual Report. after
.9/1/89 1 1
Item >=har 112 1 Restrict waste shipments to burial site until PCP has been revised and
_ implemented.
(RIP 0, IDiS 4-7)
Resnonne Ni=her 112 l
Shipeents were restricted and PCP is revised and implemented.1 l
Item E=her 113 l
Relocate the contaminated to an environmentally oil stored in a trailer located in the back lot safe area.
-(RIP 0, IDiS 4-8)
Resnonne Nt=her 113 Storage and handling of the contaminated oil . will be re-examined in l
conjunction with an overall evaluation of low-1cvel contaminated wastes.1 1 Item Ni=her 114 Evaluate requirements for enclosures to protect materials stored outside.
(RIP 0, IDIS 4-9)
Response Number 114 This . is addressed with new RW program and procedures; hazardous vaste l; storage requires closer scrutiny. 1 l l l Item Number 115 L Stop hand frisking trash using current techniques.
l (RIP 0,194S 4-12) ;
l l Resnonse Number 115 l-New procedures are implemented.1 F047/1 24- 11/89
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-Itan B -kar 116 Start-up the automated wasta sorting table.
(RIP 0, HNS 4-11)
Rannonne D =k=r 116 Don't have an automated . wasta sorting table. Need a ' sort and release pagram first.1 Item B -k-r 117 Develop. a stringent policy for control of material going into the '
controlled area to be implemented prior to the outage.
(RIP 0, HNS 4-12)
Reanonne B =har 117 New program and procedures are implemented by Conramination Control -
Coordinator. 1 Item Ni=har 118 Develop a poster campaign for waste reduction. !
(RIP 0, HNS 4-13)
I Resnonne Ni=her 118 !
Contamination Control Coordinator is initiatin6 development of this poster campaign. 1 & 4 Item Ni=her 119 Develop procedures for use of the waste sorting table.
(RIP 0,~HNS 4-15)
Resnonne Ni=har 119 Procedures have been developed. 1 Item Number 120 Develop procedures for control of material going into the RCA.
(RIP 0, HNS 4-16)
Resoonse Number 120 New procedures developed. 1 Item Number 121 Develop a corporate policy defining Radioactive Waste Management responsibilities and authority.
(RIP 0, HNS 4-17)
F047/1 -25 11/89
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n..na==e N -k-r 121-Addressed in RW-AD-100 and FCS Radiation Protection Manual.1 Item N A r 192 Review qualify and document the waste classification program.
(RIP 0, HNS 4-18).
Rannonne Number 122 New procedures developed. 1 l' Item Ni=h-r 123 Initiate a program for- the development and implementation of a Radioactive Waste Management and tracking program.
(RIP 0, HNS 4-19) ,
Resoonse N =her 123 1 A revised' program with implementing procedures is in place; however, a need continues to have a computerized system to assist in waste classification, i
L paperwork development and tracking. 1 l
Item Ni-her 124 '
l.'
Involve QA/QC in a more formal way in the inspection and review of -l processes and data.
(RIP 0, HNS 4-20) l Resoonse Ni=her 124-This is included in the new procedure. 1 Item Number 125 !
l l
Review and revise procedures to provide uniformity and continuity. '
(RIP 0, HNS 4-21)
Response Number 125 i
This is resolved in the new procedure. 1 Item Number 126 Review the use of methods and equipment for handling radioactive waste for inclusion of ALARA techniques.
(RIP 0, HNS 4-23)-
Response Number 126 AIARA review was included in the recent procedure development process.1 F047/1 11/89
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Item Ni=har 12Z Develop an overall plant itadioactive Waste Minimization Program.
(RIP 0, HNS 4-24)
Reanonne Ni=kar 127 '
1 This is- addressed by RW-500 and supplemented by efforts by the Contamination Control Coordinator. OPPD has ' Radiological Wasta t Minimization Policy", dated March 31, 1989, issued by W.C. Jones in the OPPD Nuclame Poliev Nmemm1 1 Itam B -kar 128 l Develop a training module for GET and GET addressing Radioactive Waste h
Minimization.
(RIP 0, HNS 4-25)
ResDonse N==her 128 l-The current training modules will be reviewed by the Contamination Control Coordinator to ensure the FCS program is adequately addressed. 1 Item N==her 129 -
i ._
'~ Develop a program for limiting clean material entering controlled areas. l 1
l (RIP 0, HNS 4-26)
Reanonse Ni=her 129 Included in RW-505 and efforts of the Contamination Control Coordinator.1 Item Number 130 1 1
Increase awareness in other training programs -
maintenance, chemistry, ,
etc. - of the need to reduce the quantity of radioactive material. I l
i Resconse Number 130 1
This is an on-going activity and is part of the Contamination Control Coordinator's plans for further implementation of the vaste minimization ,
program. 1 Item Number 131 1
Move all decon operations under radwaste.
(RIP 0, HNS 4-28) 1 Response Number 131 1 j
Completed 1 l F047/1 -27 11/89
I Item D =k-r 132 Develop release criteria for clean waste.
(RIP 0,1018 4-30)
'Rannonna E =har 132-l This effort is temporarily- suspended pending review of OPPD's plans and '
approach toward release criteria, BRC and waste minimination.1 l' Item %=k=r 133 Develop a long term program for processing DAW.
Resnonse B =har 133 The Radwaste Supervisor is planning a review of the overall program relating to waste minimization, BRC, release criteria as well as DAW and
- other waste disposal practices. Earlier plans appear appropriate for consideration during this effort. 1 L Item E=her 134 Review and provide input to the training department for assuring that current and proposed changes are covered in' the Radioactive Waste training i program.
(RIP 0,19tS 4-31)
ERsoonse Ne-her 134 This is adequately covered by the program and procedures. 1 .
Item Number 135 Provide specialized training and periodic retraining in DOT, NRC, Burial
- Site and station requirements for radioactive waste personnel.
(RIP 0, leis 4-32)
Resoonse Number 135 Such training has been provided in the past and expected in the future.1 Item Number 136 Review and revise all radioactive vaste proceduros.
(RIP 0, IINS 4-33)
Resoonse Number 136 Completed September, 1989 1 F047/1 -28 11/89
4 '4 Item % =k-e 137
': Quality control personnel should attend training and workshop as offered on site to stay current on applicable regulations for preparation and shipment of radioactive materials.
Remnan.. u. w ,137 FCS radmasta procedures provide QC points as appropriate; QC should attend RW training as appropriate. 1 ll Item Number 138 '
[ Ceneral instructions need to be provided by OPPD to the contract driver L
' transporting radioactive materials to handle various incidents.
, Reanonne N== h-r'138 l
FCS radwasta and transportation procedures have been revised to reflect industry practices and regulatory requirements. 1 Item Ni-har 139 Complete the operation and calibration procedure for the tool monitor and trash sorter.
(RIP 99, Chamston page V-6)
Resoonse N==har 139 Appropriate procedures have been prepared. 1 Item Number 140-A clean trash barrel should be set up at every step-off pad where personnel may place objects or protective clothing they believe is potentially clean, i '(RIP 100, OPPD page 73)
V Resoonse Number 140 This has been partially implemented but is being suspended pending review of release criteria, etc. 1 Item Ni=her 141 Standing Order C-63 needs to be modified to give the Radwaste Coordinator responsibility for determining which materials can be taken into radiologically controlled areas.
Resoonse Number 141 This order appears redundant to RW-AD-100 and implementing procedures. 1 &
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b Item Ai-k-r 142
.i l In addition, during outages a material control watch should be posted at
,.. the auxiliary building entrance by the locker-rooms with specific e guidelines (provide by Radweste Coordinator).
L Baananze Number 142
- p. This- practice is currently being implemented by the Cone ==ination Control '
Coordinator. 1 Item Na=har 143 ,
Develop a program for total station involvement in the control of all !
elementa of radioactive waste generation.
'-.r
, Reasonne Ni=har 143 L
L- This is being fully implemented at present.1 1
Item Nin=her 144 Launderable protective clothing, such as booties need to be investigated.
L (RIP 105, OPPD page 76) l' l
Reunonne Ni=har 144 This has been investigated by the radwaste organization. 1 Item Number 145 Work with EPRI on BRC petition.
Resoonse Number 145 The Radwaste Supervisor will monitor BRC activities. 1 & 11 Item Nii=her 146 '
Completion of Radwaste Processing Facility (1990) will provide dedicated room to properly sort /se6regate.
Resoonse Number 146 The Radwaste Processing Facility will be carefully evaluated to ensure the facility is fully utilized. 1 Item Ni=her 147 Pursue a program / limit for the release of low-level trash.
, F047/1 30 11/89
.- ', )
Ramnonna N==k=r 147 I This will be considered as part of the - overall program evaluation of release criteria, BRC, etc., which will be under control of the Radwasta Supervisor. 1-1 Item Number 148 l Supercompaction will be evaluated as an alternative option as work on a ,
release limit progresses. '
Response Number 148
(
This will be considered as part of the overall program evaluation of )
release criteria, BRC, etc. , which will be under control of the Radwaste Supervisor. 1 & 6 Item N==her 149 1
1 Determine an alternate method of verifying scaling factors for filters and )
DAW.
Resoonse Number 149 The current plana for the scaling factor have been revised.1 Item Ni=her 150 Analyze resin shipments on an individual basis because of the infrequency I of the shipment.
l
Resconse Number 15Q I l 1 This item is not necessary if the overall scaling factors are consistent with industry practiens. 1 & 4 Item Ni=her 151
)
Investigate a plan to verify scaling factors.
Resoonse Number 151 Current plans and procedures provide this capability.1 L ' Item Number 152 l
Revise procedure for determining isotopic fractions in liquid waste.
F047/1 -31 11/89
I llammonne *=k-r 152 Procedures have been revised as appropriate. 1 !
Item Ni=k-r 153 s
Change the entrance TLD issue forms to ask if the individual has worked in a uranium of fuel processing type facility and refer all yes answers to supervision for follow-up.
(RIP 117, Cheaston page VI-4)
R===a B-k-r 153 Completed 1 Iten Na=h-r 154 A program for monitorieg cleaning devices such as masslynn cloths for contamination will be developed, proceduralized and. implemented by April 1989. Documentation methods for these surveys will be included. -
Resnonse Ni=ker 154 This is handled by Procedure RU-503. The need for formal documentation is questionable. 1, 2, & 4 Item Ni=her 155 A standard method for posting, taping, controlling, and receiving waste should be proceduralized so that such areas are uniform in operation and appearance as well as boundaries clearly defined.
Resnonse Number 155 Current radwaste proced'ures appear to adequately address this recommendation. 1
)
Item Number 156 l
Complete a review of unrestricted release of all materials in order to determine whether different materials or all materials should have identical release limits.
Response Number 156 This will be addressed by plans of the Radwaste Supervisor.1 j i
\
Item Number 157 l
[
Continue to improve cavity decontamination.
F047/1 32 11/89 I
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Reanonna E=h-r 157 i
The Contamination Control Coordinator is evaluating several alternatives including robotics and other new techniques.1 l, Item E =k=r 158 Continue to investigate the most effective methods to decontaminate sources such as the SUIRT and spent fuel area now that the fuel integrity has been improved.
(RIP 177, OPPD page 16) i Rannonna E =k-r 158 Several alternative are being investigated including recently developed I robotic filtration systems. 1 Item N==h-r 159
, Develop an acceptable sorting / segregation program with sophisticated
- l. sorting equipment to release low-level trash.
Resoonse Ni=ker 159 The Radwaste Supervisor will be evaluating the overall program. 1 Item Ni=her 160 t
. Cet sorting table operational.
_s Resoonse Nt=her 160 Procedures have been developed. 1 Item Ni=her 161 Investigate sorting / segregation programs at other utilities and develop a.
program at Fort Calhoun which would be acceptable to the NRC.
Resoonse Number 161 The Radwaste Supervisor will review overall industry practices as part of his program evaluation. 1 Item Number 162 The radwaste processing facility (expected completion 1990) will provide the needed space to properly decon and store waste prior to shipment.
F047/1 11/89
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Reasonne Ntamber 162 7 67 ,
i This will be included in the overall plans for 1990 activities relating to '
the Radwasta= Processing Facility. 1 1 ,
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F047/1 l
-34 11/89 i
FORT CAlll00N STATION RADIATION PROTECTION ENHANCEMENT PROGRAM Mort Category 5 - General ~ Employee Training
!. Item Ni-h-r 163 l
o L
Perform an internal audit after the revised CET program is complete to assure the continued presentation of training necessary to meet the criteria.
Ramnonne N==kar 163 l
The Supervisor-Radiation Protection or a member of the staff audits CET on an annual basis (resulting in 4 audita per year). 1 Item N==k=r 164 '
A program of continuing training must be implemented in order for general employees to perform at the expected level in regard to radiation protection requirement, (RIP 50, OPPD 28)
Resnonse Ni=har 164 Annual CET review is provided. 1 l'
Item Ni=her 165 Training in CET would need to be implemented to give guidance on what is potentially clean and stress that objects are not necessarily radwaste just L because it is brought into the radiologically controlled area.
(RIP 56, OPPD 73) l l Resoonse Number 165 l
[ The training module has been upgraded and will be re-evaluated by the Contamination Control Coordinator to ensure adequacy 1 l
Item Number 166 Incorporate procedure developed for item 174 into CET training.
L (RIP 175, OPPD 111) 1 Response Number 166 Complete 1 Item Number 167 Emphasize to workers the importance of adhering to radiological protection l
requirements.
L (RIP 211, INPO 86 page 33) l l
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Resonnaa Shamber 167 ll ,
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' Grr[. annual-update,supervisorsandcontinuedcurveillancebyRPemphasizes' RF-requirsaants.- ROR is issued in cases where neglect or lack of attention ,
to details is present. 1 k
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F047/1 11/89
l FURT CAlllOUN RADIATION PROTECTICif ENHANCEMENT PROCRAM Mort Category 6 - AIARA
, Item Ni=har 168 l
Clearly define the AIARA policy in a central document, either the Radiation Protection Mm==1 or an AIARA Nanual. ,'
(RIP.0, HNS 6-1, NRC 285/8805-Pil)
Rannonne N==k-r 168 AIARA policy statement has been issued.1 Item Ni=har 169 l
Further develop the program and implementing procedures.
(RIP 0, HNS 6-2)
Resnonse Ni=her 169 i
I- AIARA procedures completed September,1989 and comprehensive.1 Item Nii=her 170 Perform a detailed walkdown of the plant to determine cost-benefit for
- removal and/or shieldin6 of hot spots.
(RIP 0, HNS 6-3)
Resoonse Nii=her 170 l
AIARA section has performed the initial phase of identification.
Engineering review is in process. 1 Ites Number 171 Consider use of cameras for surveillance of high radiation area monitoring during high exposure jobs such as steam generator testing and repair.
(RIP 0, HNS 6-7)
Resnonse Nin=her 171 Concept is being reviewed by ALARA section. (t Item Number 172 Establish AIARA goals based on projected plant operations and maintenance for the year.
(RIP 0, HNS 6-8)
Resoonse Number 172 AIARA goals are in the process of development by the various sections with operations and maintenance in mind. 1 F047/1 37 11/89
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Item Ni=k-r 173 Establish and present an AIARA training program tailored to the various support groups such as engineering, plant supervision, and the ALARA technicians.
(RIP 0, HNS 6 9) '
Reznonna N==har 173 AIAEA awareness training program is presently under review.1 I Item N==b-r 174 7 l
Change the AIARA comunittee composition so there are a smaller number of members, a higher level of orPanhation participation and a reduction in scope so that the committee only performs program effectiveness
,_ assessments.
! (RIP 67, Cheaston page VIII-6)
- l. Resnonse Ni=her 174 AIARA committee has been re-evaluated and changed.1 Item Nn=har 175 AIARA efforts need to be more proactive with greater effort on analyzing high dose / dose race jobs to determine effective dose reduction techr.iques.
(RIP 68, Chamston page VIII-7)
Resnonse Ni-her 175 New procedures and AIARA program does proactively consider high dose / dose rate jobs.1 l
Item Number 176 Change the AIARA review system so it addresses the goals of AIARA which is maintaining exposures as low as reasonably achievable.
(RIP 70, Chematon page VIII-7)
Resnonse Number 176 New procedures address and include AIARA goals.1 Item Number 177 A review of high dose / dose rate tasks should be performed and either a radiological control procedure developed for the task or the radiological controls integrated into the work procedure.
(RIP 71, Cheaston page VIII-8)
Resnonse Number 177 New procedure satisfies requirement. 1 F047/1 -38 11/89
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I Item N==k-r 178 Broader participation of craft workers is needed in AIARA information meetings. ,
(RIP 75)
Renaa=== N= =k- r 178 l :
A1 ARA . section - is seeking methods to involve craft workers to a higher r
- degree. AIARA suggestion program has been initiated.1 Item n=k-r 179 '
The AIARA Committee should review and study more aggressive programs which seek to limit lifetime exposure of long term station employees as a~ goal for 1988.
Resnonse Ni=her 179 i 1'
Covered by procedure.'l Item Ni-har 180 Identify . the standard parameters for which collective exposure -goals should be formulated in both outage and non-outage years.
Resnonse N =her 180 Parameters have been identified. 1 l Item Number 181 Establish a formal exposure goals program to administer and monitor against established goals with appropriate. accountability.
Resnonse Number 181 Covered by procedures RP-304, RP-AD-300, and the RPP.1 Ites Number 182 Develop a program which identifies positions or personnel to fulfill the role of project manager with the responsibility and authority to satisfy the stated goal (criteria).
Resnonse Number 182 In process. 1 F047/1 11/89
,1 .,
Item Numbqr 183 s
Implement the required actions of INPO criteria 4a. Then provide a program to break down station work requirements by department or work group.
Ramoonae Number 183 In process. 1 l, Item Humber 184 i
L Identify the se==tard parameters or work requirements for emeh department against which collective . exposure goals can be formulated in both outage and non-outage years.
Resoonse Ni=her 184 Standard parameters have been identified. 1 Item N==her 185 l
Assign personnel identified in required actions for INPO criteria 4b to monitor actual collective exposure for the department or work group so that timely corrective action is taken to achieve the goal.
Resoonse Ni=her 185 In process, 1 Item Ni=her 186 All work requirements used to formulate the initial goals must be L identified so that subsequent work requirements that impact on the goals can be evaluated and adjusten as necessary, j (RIP 88, OPPD page 45)
Resoonse Ni=her 186 Will follow initial effort. 1 Item Number 187 1
Temporary or permanent curbs and dans will be installed as appropriate around areas where contaminated water could contaminate nearby clean controlled areas or areas of much lower contamination. Temporary curbs will be installed by December 1988.
Resoonse Number 187 Completed 1, 2 F047/1 -40 11/89
cf, .
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(. ,
Item Number 188 Impron jM.., pation in the AIARA program.
(RIP 215 INPO 86 page 37) et Rannonna Number 188 Efforts are being made to improve participation in the AIARA program.1 Itam Number 189 Place a high priority on AIARA recommendations that can result in significant dose reductions.
Rennonsa Number 189 I Reorganized AIARA Committee and created an Executive AIARA Committee.1 i
Item N==har 190 Consider developing incentives to encourage participation by workers.
Resnonse Number 190 Not fully implemented, however, being considered by FCS management.1. !i Item N M er 191 Encourage work Group participation in establishing challenging but l achievable goals based on projected annual work requirements. '
(RIP 218, INPO 86 page 37) l Resoonse Number 191-RP-304, " Radiological Coals Program " has been implemented. The AIARA Committee is responsible for reviewing and recommending goals and improvement plans and for tracking progress against the goals. 1 Item Number 192 Identify and correct leakage from radioactive systems in a timely manner.
Resoonse Number 192 Radwaste procedure RW-508 addresses this item. 1 Item Number 193 Provide containment devices on radioactive leaks to limit the spread of contamination until corrective maintenance is completed.
F047/1 41- 11/89
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Ramannaa Mumbar 193 RU contamination control personnel perform this function. Procedures are in place. 1 2
F047/1 42 11/89 I i
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i IDRT CAlBOUN i RADIATION PROTECTION ENHANCDENT PROGRAN Nort Category 7 - External Exposure Control I ta= _" r 194 Develop procedores for dosimetry issuance, dosimetry records, routine and termination dose reports, dose assessesats, lost / damaged desinators, and ,
T12/ Pencil discrepancies. ,
Rennema + " r 194 By new procedures. 1 '
i Itan N==kar 195 Develop job descriptions and qualifications for the dosimetry office staff. l (RIP 0, HMS 7 2)
Reanonna N==*ker 19S !
All positions have a completed job description.1 !
Itan N =kar 196 Develop controls that allow only qualified personnel to issue dosimetry in accordance with specific procedures.
(RIP 0, HNS 7 3) '
i Reanonna Na=her 196 Controls are in place. 1 Item Nin=her 197 Develop specific guidance for calculating and recording exposures. extremity (RIP 0. HNS 7-4)
Resnonne Nii=her 197 i New procedures. 1 Item Nii=her 198 Develop definition and enforcement of proper locations and methods for wearing personnel TIIs and pencil dosimeters.
(RIP 0, HNS 7-5)
Resoonse Number 198 New procedures. 1 r
F047/1 43 11/89
~
Itaa thambar 199 Develop a low background storage area for all in use Tia and pencil dosimeters.
(RIP 0, HNS 7 6)
Rannonaa Nuntpar 199 Imv background area selected. 1 Itaa Numbar 200 Develop a method of controlling all peroonnal that have had an exposure limit imposed by the plant or by the individual (Reg. Guide 8.13)
(RIP 0, HWS 7 7) k annnan Munhar.200 The current administrative dose control procedures and manual access control system provide adequate control. This control will be enhanced with the implementation of a computerized access control syntam which is under consideration.1 Item N -kar 201 Add a senior technical health physicist that haa emperience in running a dosimetry office and is capable of detailed dose calculations and evaluations.
(RIP 0, HNS 7 9)
Reanonne Nia=her 201 Complete with new organization. 1 Item Ni=her 202 Purchase a new dosimetry system that is capable of monitoring all types of radiation present at Fort Calhoun, and consists of various types of holders (e.g. ring and wrist).
(RIP 0, HNS 7 10, NRC 8830/01)
Reasonne Nin=her 202 Panasonic system has been purchased. NAVIAP certification in in process.1 Item Ni=her 203 Nove the dosimetry office from corporate to the site where it can receive the technical support necessary and where it can be integrated into the total dosimetry system.
(RII 0, HNS 7 11) ;
Remnonne Nin=her 203 Moves completed. 1 & 3, F047/1 44 11/89
p Itan Mumbar 204 Nove the domiastry calibration source to a scatter free environment where l proper security can be enforced.
l (RIP 0, ) Dis 7 12) 1
( Raamonae Number 204 l
A new dosimetry calibration source for the Panasonic TIA System has been purchased and placed into service.1, 2 I
Itan Mumher 205 Determine the beta and neutron spectra at Fort Calhoun and provide the proper correction factors to the dosimetry office.
(RIP 0, ) Dis 7 13)
Remna==a N -k-r 205 1
i Plans are to measure the spectra during the next year 1 Item Nu=har 206 Improve the TLD calibration jig and purchase a new beta calibration source.
(RIP 0, ) Dis 7 14)
I Reanonne N==her 206 l
Complete 1 Item N==her 207 1
I Develop procedural guidance on the evaluation of dosimetry data to establish exposure trends and enhance the recognition of resulting implications.
(RIP 0 HNS 7 15) jtesnonne N==her 207 By new procedure. 1 Item N==her 208 Improve procedural controls on receiving increasing levels of exposure.
(RIP 0. HNS 7 16)
Response Nn=her 208 By new procedure. 1 IV47/1 -45 11/89
==--. _ _ _ _ _ _ _ - _ _ _ _ _ _ ,
+ o j 1
1 i
Itan M ahar 2D9 Provide off-sita dosimetry training for the corporate dosimetry technician l at one of th numerous training gograms offered by vendors or by the major i universities.
(RIP 0, Wls 717 l j
1 Rammensa thapbar 209 I The corporate group is no longer responsible for the dosimetry program. !
Radiation processing of Panasonic Ttas have attended vender training. 1 1 1
Item W r $10 Improve the esisting guidance in RFit 2.10 by ' developing a specific 1 procedure for evaluating lost badges, exposure without badges, off scale '
dosimeters and significant discrepancies between TIDs and DRDs.
(RIP 58 Cheaston Page IV-4)
Resnonna N==k=r 210 A .
New procedure. 1 '
Item Number.211 >
Change the T12 vs DkD comparison categories to reduce the number of categories from three to two. Also add a provision for evaluating a dose assignment for personnel with minimal TIA reading but large DRD readings.
(RIP 59, Chomston Page IV-4) ,
Response Nn=her 211 Complete. 1 Item P Ser 212 Proceduralize the documentation of changes in raw dosimetry readouts at the Corporate T!m processing center. 3 I
(RIP 60, Cheaston Page IV-4) '
Resnonne Nn=her 212 Dosimetry moved to site. Procedures have been issued. 1 Item Number 213 L Develop a criteria and a protocol for determining changes in neutron spectra and calibration factors.
(RIP 61, Chenston Page IV-5)
Resoonse Nn=her 213 FCS plans to measure the neutron spectrum at a future date.1 F047/1 46- 11/89
j o i Item N + r 214 Evaluate the existing Za-133 skin dose equation and determine the adequacy of the model, the recent January 1988 article in RPM magaaine may be used as a reference.
(RIP 62, Cheaston Page IV-5)
Reasonne Number 214 Model evaluated and is adequate. Other models also available. 1 Itaim B A r 215 Consider the une of a mechanical system such as notes or markers affiaod to T1D badges to aid in determining terminated workers.
(RIP 65, Cheaston Page IV-6)
Reanonae N =her 215 Methodology is being evaluated. 1
/
Iten N==her_216 A review of 198 doses determined against 100 sq cm instead of I sq cm will be performed by September 1,1988.
Reasonas N==ker 216 Complete. 1 & 2 Item Ni=her 217 The TID dosimetry system and the range of expected radiations and energies in the plant will be clearly defined so that any deviations can be identified and addressed.
Resnonse Nii=her 217 Under evaluation with new TLD system.1 Item Number 218 A new TID processor capable of providing TIDs of appropriate energy response, radiation differentiations and formats such as finger rings will be purchased and implemented or contracted in 1989.
Response Number 218 on schedule. 1 F047/1 47 11/89
o ..
Ie== u. *- r 219 Develop a more consistent set of limits and include action criteria.
(RIP 94, Cheaston Page V 6) n..===== x.=k-r 219 New procedure. 1 Itaa Ahanhar 210 Change the skin dose calculation action levela so that the level is in terms of cpm and time on the skin is considered when performing the dose calculation.
(RIP 98, Cheaston Page V 6)
Reasonne N==h-r 220 New procedure. 1 Itan N==kar 221 Improve station check out system for all personnel that are terminating their assignment employment, or visit at the station, to ensure that these individuals notify HP in order that all requirements for VBC and exposure reporting can be completed.
Rennense Nin=her 221 All in. coming personnel are required to sign a sheet explaining the procedure for terminating their employment (i.e.: exit whole body count, return dosimetry, etc.) 1 Item Niimber 222 Change the background check plot program so it only records isotopic activities greater than MARL.
(RIP 184 Cheaston Page A16)
Resoonse Number 222 Completed. 1 Item Number 223 Implement improved algorithms which have been developed and tested for evaluation of TIS data and are ready for implementation.
Resoonse Number 223 In process with new TLD system. 1 F047/1 48 11/89
o .
i Ita= + ' r 224 Begin algorithm development' and testing for the mixed gausa/ neutron l category of esposure.
Em ==== * ' r 224 Neutron spectra needs to be measured. This is being evaluated and scheduled for 1990, 1 ,
Igen thanhar 225 Study / evaluate possible upgrade to new 112 reading equipment.
(RIP 199, OPPD Page 87) l Remnonne B-A-r 225 New system selected. 1, 2 l l
Item Ni=har 226 Establish an OPPD action level lower than ANSI N13.11-1083 acceptance '
l criteria limit for the monthly QA testing.
Reanonne Ni-her 226 '
Will be' accomplished with new system. 1 Iten Ni=her 227 Decrease the acceptance criteria for calibration and calibration checks of the T13 reading equipment.
Resoonse Ni=her 227 New procedures. 1 Iten Ni=her 228 '
. Record glow curves (plot of heating temperature versus light emitted by the
' TLD element.) for documentation of individual TLD element performance.
Response Number 228 New procedures with new system. 1 F047/1 49 11/89
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Item + " r 229 i Strengthen procedural requirements for the position of dosimetry devices during radiological work.
Resoonse Number 229 Incorporated in new procedures. 1 l
Item N= A r 230 Investigate improvements to radiation monitoring of the hands. Various TID '
products that can be worn on a finger are available in the industry.
Reasonne N= A r 230 ,
i Extremity monitoring is addressed in procedures and finger rings will be provided by an off-site vendor. Consideration is being given to acquiring on site capability. 1 Item Ni=her 231 Evaluate the need to move the TLD processing activity to the site.
Resnonse Ni=her 231 Move has been completed to the site, 1 & 4 Iten Number 232 Develop guidance for actions to be taken when PIC - TLD discrepancies are significant, and what degree of difference is significant.
Resconse Ni=her 232 Completed with new procedures,1 l
F047/1 50 11/89
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i PORT CAIROUN STATION RADIATION PROTECTION ENHANCDONT PROGRAM Nort Category 8 Facilities and Equipment Ita= B
- r 233 Rewrite all instrument operating procedures.
(RIP 0, HNS 4 1)
Ramponaa Number 233 2
New procedurea issued 9/1/89 1 & 2 Itan Number 234 l
Review and rewrite calibration procedures. '
(RIP 0, HNS 8 2)
Reasonna Nie-her 234 New procedures issued 9/1/89 1 & 2 l Item N==her 235 Develop accountability procedures.
(RIP 0, HNS 8 3)
Response Nin=her 235 New procedures issued 9/1/89, 1 l- Item Ni=her 236 Develop a memorandum of understanding between I&C and health physics regarding the responsibilities of each group. ,
RIP 0, HNS 8 4)
Resnonne Ni=her 236 RP now calibrates and repairs survey instruments. I&C calibrates and repairs in-line process monitors and area radiation monitors 1 Item Number 237 Evaluate the instrument inventory and develop and improvements plan.
(RIP 0, HNS 8-5)
Response Number 23_7 Inventory completed. Improvement plan is under evaluation.1
- F047/1 51 11/89
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Item Ma ar 238 '
Place friskers at strategic locations throughout the plant.
(RIP 0. HNS 8 6) !
Ramannas Nisahar. 238 !
Observed on all levels with instruction for frisking. 1 ;
Itam Number.239 Provide health physics technicians with a training course in instrument theory and operation.
(RIP 0, HNS 8 7)
Resnonne Ni-k-r 239 Training has been evaluated and will incorporate this need into the RP tech training program. 1 Item N =k-r 240 Develop proper beta calibration techniques and assign proper correction factors.
(RIP 0, HNS 8 8)
Resoonne N==her 240 Completed with new procedures. 1 Item Number 241 Jointly share instrument calibration program between I&C and health physics.
(RIP 0, IDis 8-9)
Resoonse Ni=her 241 See iten 236 1, ft Item Number 242 Add a senior engineer familiar with instrumentation to the group to take responsibility for developing an instrument program.
Resoonse Number 242 Senior engineer has been added.1 F047/1 52 11/89
i Ita= m ' r 243 ,
Designate an instrument storage area and assign responsibility to the radiation protection group.
Ramponaa Number 243 Storage area has been assigned and responsibility assigned.1 I*== m ' r 264 Establish a dosimetry office outside of the gate and combine the whole body -
counting operation, the dosimetry office currently located downtown, and the records program.
- Reasonne N==her 244 l'
Completed. 1 l
Item Ni=her 245 Clean up the personnel decon area and restrict access to authorired personnel.
(RIP 0, IMS 8-13) 1 Resnonne N==her 245 Complete. 1 '
l Item Nii=her 246 Delay the purchase of the new automated dosimetry system pendin6 a more thorough evaluation.
Resnonse Number 246 V
! System has been evaluated and purchased. 1 Item Number 247
' Perform a thorough review of the construction plans for the new radiation l protection facilities and integrate with existing facilities for maximum use and function.
Resnonse Number 247 Reviewed new " layout" and found the space allocations acceptable. 1 F047/1 53 11/89
4' 4 i
I Itan W ' r 248 1 Ensure procedures are developed in a timely manner for new instrumentation.
(RIP 179, Cheaston X 17)
Resu ma M* ' r 248 Procedures issued 9/1/89 1 re=. r 24, Change procedure CP HP 22-12: Determining function check point. Change ;
posted source activities from the single one minute activity values to the average of ten five minute source peak activities.
(RIP 187, Cheaston A16)
Reasonna N===ker 249 New procedure. 1 Itan Ni ar 250 Provide an uninterruptable power source and operate the whole body counter off the power. ;
(RIP 189, Cheaston A17)
Resoonse Ni>=her 250 i
1, New AccuScan unit will have uninterruptable power source. 1 Item Nii=her 251 l
A program is suggested which reduces the time an instrument is out of service for calibration and keeps more calibrated instruments available for field use.
Response Nii=her 251 Recent responsibility change has improved availability of instruments. /
Additional instruments have been budgeted. 1 I ten Ni>=he r 2 5 2 1
A minimum number of available instruments should be specified by type of instrument and reported and tracked as a performance indicator.
Response Number 252 New procedure. 1 I
i F047/1 54 11/89 1
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I Iram N A r 253 l
Upgrade equipment environmental conditions to appropriate levels, particularly for counting room equipment. '
Ramponaa ihmber 253 !
Under evaluation. Sose improvements have been made.1 Item lhahar 254 Consolidata the oquipment QC program during the revision of the Radiation Protection Manual. .
Rannonna N=Ar 254 Complete. 1 I t l .
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I F047/1 55 11/89 l
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l MMtT CAIROUN l
RADIATION PROTECTION ENHANCDGMT PROGRAM Mort Category 9 - External Exposure Control l
Ita= N= A r 255 Develop a urinalysis prcgram to meet the recosumendations of industry {
standards, l
(RIP 0, HNS 9-1) l I
Rmananna N===kar 255 f
i Complete. 1 l Item N= ==k-r 2 56 l Develop a complete set of procedures that address, as a minimuss, the j requirements and recommendations of ANSI N343, INPO 85 010, and ANSI 1 k b. HNS 9-2) l l Resoonse Nin=her 256 Complete. 1 Item Nin=her 257 Develop procedures for the records program. 1 (RIP 0. HNS 9-3) l Lesconse Number 257 Complete. 1 Item Nii=her 258 Change the training programs and the operating mode to ensure only qualified personnel are working in the dosimetry office. ;
(RIP 0, HNS 9 4) i Estsoonse Nin=her 258 l
1
-Dosimetry personnel are trained. 1 Itce Number 259 I
Carefully control access to the personnel exposure files and allow only qualified personnel to enter or retrieve data. I (RIP 0, HNS 9-5) l Resnonse Nin=her 259
)
Access control to files and enter or retrieval of data are controlled. 1 l
1 F047/1 56 11/89 l
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Itan lhambar 260 l i
l Develop a qualifications and training program for personnel in internal !
dosimetry.
i (RIP 0, }ms 9-6)
Ramponse thaaber 260 '
l In process with planned training programs 1 Item Number 261 Establish a syntam for controlling samples taken for bioassays.
(RIP 0, mis 9 7)
Response Nsaber 261 Protocol has been developed. 1 Iten Number 262 Evaluate suitable backup facilities for whole body counting.
(RIP 0, }OIS 9 8)
Rannonam N d er 262 AccuScan will be operational shortly. 1 ;
Item N= W r 263 Establish good dose records keeping system.
(RIP 0. HNS 9-9)
Response Number 263 Established Radiological llealth group with records expertise. Active records are presently being updated (completion 12/89). Inactive updates will follow. 1 & 2 Item Ni=her 264 Improve capabilities for internal dose calculations.
(RIP 0, HNS 9-10)
Response Number 264 The establishment of the Radiological Health and Engineerin6 group provides the improved capability for internal dose calculations.1 Iten Ntaber 265 Develop an exposure and contamination review policy.
(RIP 0, HNS 9-11)
F047/1 57 11/89
tr . y
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l, Rannonna thaahar 265
[
New Procedures. 1 1
Itam Numbar 266
{
Improve administrative dose control procedures.
(RIP 0, WIS 9 12)
Rampenna thumber 266 i_
New Procedures. 1 '
Itan Mumbar 267 .
Establish a quality control and assurance program for internal l l dosimetry. -
(RIP 0,19t5 913) '
Reasonne u.=kar 267 f
New Procedures. 1 !
Item Number 268 i
Integrate accepted and INPO recommended industry standards into the
. program.
(RIP 0, HNS 9 14) -
Reanonne N==har 268 Complete. New Procedures. 1 Item Ni-her 269 Develop minimas qualifications for the whole body counter operator and i include as a part of the job description. "
(RIP 0, HNS 9 15) t Resnonne Ni=her 269 A specific performance evaluation checklist (PEC) for the operation of the whole body counter has been developed and is used to qualify operators. 1 ,
Item Ni=her 270 The tracking and trending threshold for positive whole body counts will be revised to match industry practice by September 1, 1988.
Resoonse Ni=her 270 Complete. 1 .
F047/1 58 11/89
s ,
Item N= " r 271 Provide urinalysis for personnel entering containment at power routinely.
(ElP 115. Cheaston Page VI 4) ,
Ra m ema.. ns. ' r 271 New Procedure. 1 ,
Ita= " ^ r 272 Review the whole body count evaluation procedure to provide action level '
criteria bened upon MPC hrs and not MP88 or MPOS.
(RIP 120, Cheaston Page VI-5)
Reanonna N==bar 272 Complete. 1 Item N -ker 273 Provida a format and instructions for investigating intakes in excess of
! 40 MPC hrs. This can be done by revising an already existing incident
- i. evaluation procedure.
I. (RIP 123, Cheaston Page VI-5)
Reanonne N===ker 273 .
Complete. 1 lten Niamher 274 A program to perform random whole body counting of personnel performing work in radiologically controlled areas will be implemented by September 1, 1988.
Resnonne Number 274 l
Complete and observed. Every tenth person using a respirator is WBC'ed. 1
&}
Item Number 275 Evaluate and upgrade of the whole body counting system to incorporate high resolution Ce - 1.1 detectors which would effectively lower the threshold of detectable activity.
Response Niamher R New AccuScan WBC has been purchased and is scheduled for operation by the end of the year. 1 F047/1 59 11/89
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Item Migsbar.276
, Evalusta a - program for in vitro methods of bioassay in order to monitor i for internal deposition of radionuclides that cannet be detected using l whole body counting equipment, such as tritium, j l
(RIP 163, OFFD Page 54) !
i 1 Egamenam Mumbar 276 j
Rvaluation is complete. 1 l
IJ:an Number 177 i Install a gain stabilizer on the Fastscan.
) (RIP 181, Cheaston Page A12)
Rannonne N== L r 277 l
The FASTSCAN has been moved to a more controlled envircrament (Training I Center) making the gain stabilizer unneessary. 1 i
Item Number 278 i
Revise procedure HP 1. !
l (RIP 182 Cheaston Page A12) 1 l l Reanonne N==her 278 Procedure issued 9/1/89 1 -
l Item N==Lr 279 1
-Purchase and operate a second whole body counter system, preferably a scanning, germanium detector system. 1 & ft (RIP 183, Chomston Page A14)
Resnonne Nember 279 '
New system purchased and scheduled for operation by end of year.1 Item Ni=her 2{Q Make changes to the Calibration Check Plot and the background check plot program on the Fastscan Whole Body counter. 1 (RIP 185, Cheaston Page A16)
Response Number 280 Complete. 1 1
F047/1 60 11/89
1 i
I Ita= *
- r 281 Make the QC source with more activity or count it longer to achieve the i minimum 10.000 not counts for the three reference photopeaks recommended '
l in AS'Dt and Aust standards.
l (RIP 186, th=aton Page A16)
{
Rannonaa ilumbar 281 Complete. 1 Item ilumbar 282 l
Check using the mixed isotopic source in the lower C.I. position of the phantos. Modify the library and calibration entries to QC in the same way it is done for the thyroid sensitivity check.
i- ,
i (RIP 188, Chomston Page A17)
Reanonne N===ker 782
! Complete 1 Item N===ker 283 Consider relocating or rearranging whole-body. friskers to ensure that, '
once personnel are determined to be uncontaminated, they :lo not traverse potentially contaminated areas of the radiologically controlled area prior to exiting.
Response Ni-her 283 Evaluated and changes made 1 Item Nu=her 284 Evaluate an upgrade to the whole body countin6 system to incorporate high resolution ce-Li detectors, j (RIP 224, OPPD Page 59) l Resoonse Ni=her 284 New system purchased. 1 L
l F047/1 61 11/89 i
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-Roanonna S =ker 372 New organization is addressing this concern.
Item D =k-r M Additional efforts must be taken to improve comunications between the different groups.
(RIP 235, SURC sect 3.3.2)
Rannonna E k-r 373 Supervisor Radiation Protection and the three recently hired supervisors have improvement of communications as a top priority.1 Item E=ker 374 ,
OPPD Project needs 1991. improvement in root cause analysis beyond that envisioned in l '
l Resnonne h>=her 374 l This evaluation secommended that root.cause-analysis training be given to coordinators and supervisors.it
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F047/1 81 11/89
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IVRT CAIROUN RADIATION PROTECTION ENHANCDENT PROGRAM Mort Category 10 - Procedures !
Iten Number 285 Rewrite the Radiation Protection Manual using NUREC 0761 and INFO 88-010 i for guidance.
Ramoonse Numpher 285 '
The RPM was split into the RP Plan and RP Procedures.1 Item N a ber 286 [
Remove praa-airal steps from the Radiation Protection Manual and state in implementing procedures.
(RIP 0,1985 10-2, NRC 285/8805 08)
Reanonne N==har 286 r
Procedural steps have been removed. 1 & 6 Item N==har 287 Procedures which contain actions which groups other than t.he radiation protection group are responsible for performing should not be written as radiation protection procedures but rather as standing orders.
(RIP 0, HNS 10-3)
Resoonse Nin=her 287 Standing orders have been and will continue to be issued as required.1 Item Number 288 Implementing procedures should be rewritten in a consistent format which agrees with ANSI N18.7. See meno.
(RIP 0, IDis 10-4)
Response Nin=her 288 New procedures meet ANSI requirements.1 Item Number 289 A job enk analysis should be performed for the tasks performed by the radiation protection group as an aid in writing the new procedures.
(RIP 0, IDIS 10-4)
F047/1 62- 11/89 v:-- --
@ d i
i Rennenne Ma=k-r 289 i New procedures issued 9/1/89.- A period of time will be required to
- de-bug
- the procedures. 1 & 6 l
l Item N A r 293 Verify new procedures by field test prior to implementation.
I (RIP 0,198810 6)
Rmano=== Ni-kar 290 Verification and validation was completed for all new procedures. 1 Iten Number 291
- Develop instrument use procedures.
(RIP 0, }MS 10-7)
Resconne N'=her 291 New instrument use procedures developed. 1 l
Item Ni=har 292 -
Develop procedures describing routine survey basis and implementation.
Resoonse Ni=her 292 Included in newly revised survey procedure. 1 Item Number 293 1
Develop procedures for respirator control, return and maintenance.
(RIP 0, IMS 10 9) 1 Resoonse Number 293 Completed with procedure revisions issued 9/1/89 1 Item Number 294 Divide procedures into two groups; those required by RegCuide 1.33 and needing PRC approval, and those procedures which may be approved by the department head.
Resoonse Number 294 ^
F047/1 63 11/89
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Item N==k-r 295 1 ,
l Create a section in the Radiation Protection Manual that delineates the responsibilities for radiation protection of all groups within OPPD. )
State specific areas of authority. '
,e (RIP 4. Chomston Page II-8) 1 1
Ramnonne u. A r 295 1
1 Included in revised RPP-(7/89). 1 Item N==k-r 296 J i
l 1 l
Reduce or eliminate the number of Radiation Protection instructions issued as standing orders, policies, or menos.
(RIP 5, Cheaston Page 11-9) {
Reasonna N==her 296 Some se="ing orders are considered advisable. Most functions have been proceduralized. 2 Item Ni=her 297 Revise the radiation protection plan and procedure system so the plan is i
' a guidance document on what the program is to accomplish and the procedures explain how the program elements are accomplished.
(RIP 6. Cheaston Page II-9) -
Resoonae Ni=her 297 Accomplished with revised RPP (7/89) and revised procedure (9/1/89). 1 1
Item Number 298 Eliminate the use of ambiguous phrases in written radiation documents.
(RIP 8, Cheaston Page II-9) l Response Number 298 Procedure preparation guide helps eliminate ambiguous phrases. 1 Item Ni=her 299 Make forms and changes to the forms part of the radiation protection procedures.
(RIP 9, Cheaston 11-9)
Resoonce Number 299 New procedures include revised and consistent forms. 1 F047/1 64 11/89
.. , i i
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Ie.= p. 'r 300 The Radiological Protection Marman1 and radiological procedures in other 1 sections of the Operations Manual will be written by October 1991. )
Rammonam Na-kar 300 i
RPP revised and issued 7/89, procedures revised and issued 9/1/89.
Reference responsa number 285 1 ;
1 1
Itan Na=kar 301 l 1
As performance s e arwimrds are developed in the rewrite of the Radiation 1' Protection Manual procedures for measuring the achievement of the
- t. performance standards will be concurrently developed.
Resoonae Ni=har 301
)
Performance standards and measurement are included in RPP. 1 l
Item Nn=her 302 l
l Health physics procedures and policies are under review by outside i
' consultants with the objective being to upgrade or totally rewrite the j Radiation Protection Manual in order to separate and clarify policies '
and procedures.
(RIP 39, OPPD Page 12, NRC 285/8805 08)
Renconne Na=her 302 RPP revised 7/89 1 Item Number 303 Provide procedural and RUP guidance on re-zeroing and stay times for high dose jobs.
(RIP 63, Cheaston Page IV 5)
Response Ni=her 303 Included in new procedures.1 Item Number 304 A review of radiation protection procedures and increased emphasis on compliance with these procedures has been initiated.
(RIP 76, OPPD Page 31) i Response Number 304 Procedures revised and issued 9/1/89. Management has emphasized the followin5 of procedure. 1 PO47/1 65 11/89
. c Item N A r 305 i
Incorporate into the maintenance procedures that valves removed from the secondary sida of the plant be surveyed by an HP technician.
(RIP 95 Cheaston Page V-5)
Rannonam N=" r 305 '
i Item under evaluation. 1 & 2 Iram N -ker 306 Complete a major revision of the Radiation Protection Manual which will provide a clear plan supported by coordinated procedures. .j (RIP 166, OPPD Page 55) '
l Resnonne Number 306 Revised RPP issued July, 1989, followed by revised procedures issued 9/1/89 1 & 2 Item Ni=her 307 Assure that the future rewrite of the Radiation Protection Manual and procedures will provide a clearer description !
of the radioactive contamination controls program.
(RIP 170, OPPD Page 101, NRC 285/8805-12)
Resnonne Ni=her 307
'Ihis has been incorporated. 1 Item Ni=her 308 Revise and consolidate the instrumentation procedures so there is a clear set of operational and calibration instructions that are unique to each instrument.
(RIP 178, Chematon PaBe X 17)
Rer:nonse Number 308 All instruments have upgraded procedures as of 9/1/89 1 & 2 Item Number 309 The upgrade of the Radiation Protection procedures should be given a high priority by OPPD. '
(RIP 132, SVEC Sect. 4.9.4, NRC 285/8805 08)
Response Number 309 Upgrade completed 9/1/89, 1 & 2 F047/1 66 11/89
FDRT CA12100N RADIATION PROTECTION ENHANCDENT PROGRAM Mort Category 11 - Respiratory Protection Program Item N. A r 110 ,
Do not take protection factors until missing program elements havs been developed.
(RIP 0, HNS 11 1, NRC 285/8805-13)
Rasnonna u ' r 310 Comply. 1 Item N A r 311 Determine NPC hours for using all entries respiratory protection equipment in accordance with 10CFR20.103.
(RIP 0, HNS 11 2) l l Resoonse Nimber 311 Comply. 1
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Item Ni=har 312 Bring a qualified individual on site to oversee the development of the elements of an acceptable program, i- (RIP 0, HNS 11 3, NRC 285/8805-13)
Response Nimher 312 Complete (Respiratory Protection Coordinator). 1 Iten Ni=her 313 Develop procedures governing maintenance of the various types of equipment.
(RIP 0, HNS 11-4, NRC 285/880513)
Response Ni=har 313 Procedures have been issued. 1 Item Number 314 Develop and implement a program to verify the effectiveness of respiratory protection controls.
(RIP 0, HNS 11 5, NRC 285/8805-13)
Response Number 314 !
Included in new procedures 1 F047/1 67- 11/89
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Ieam Ni-kar 315 f t
Present and document training to persons maintaining respiratory protection equipment.
(RIP 0,1985 11-6)
Raanonse Number 315 Training program has been scheduled and will be documented. 1 f Itan u.=kar 316 Develop an issue system. *
(RIP 0,198811-7, NRC 285/8805-13)
Reasonna Nia-kar 316 New procedures include issue system. 1 -
Item N==kar 317 l
Apply for NRC approval to use the radio iodine sorbent canisters.
(RIP 118, Chematon Page VI-4) '
Remoonsa N==her 317 i
The initial evaluation concluded that the requirements necessary to meet ;
NRC approval of radio iodine sorbent canisters are very restrictive and not cost effective. The canisters are available and will be used when ,
applicable with no protection factors applied. 1 ~
r Item Nimber 318 Evaluate and develop en61 neering and operational chan6es to reduce the quality of unfiltered air from leaving the spent fuel pool work area and ,
reaching adjacent work areas.
(RIP 119, Cheaston Page VI-5)
Resoonse Ni=her 318 Evaluation in process, 1 ,
Iten Number 319 Change the requirement for wearing respiratory protection at 20,000 -
dpm/100 sq cm to a higher value.
(RIP 121, Cheaston Page VI-5, NRC 285/8805 12)
Response Number 319 lias been accomplished. 1 F047/1' 68 11/89
' Item N= r 320 F ,
Change the systea ~of accumulating NPC hrs so it can be does promptly; --
use ofs the ' new computerized exposure tracking cystem -is one suggested method.
(RIP 122, Cheaston VI 5)
, Epsponse Number 320 New respiratory program .ud procedures include changes.1 le== N==h-r 321 Reintroduce the use of lapel samplers.
- (RIP 126, Cheaston D.t.u VII-3)
Raggonne Na-k-r 321 hr _ f,1 Item Nn=har 322 Develop. an. organizational 2. atrix and responsibilities' for the
- respiratory protection program. Try to limit the number of individuals /
groups who have' direct responsibility for implementing the program.
. (RIP 132, Cheaston Page IX-4)
' Remnonne Ni=har 322 New organization corrects the previous problem and provides specific responsibility. 1
-1 Item Number 323
' Evaluatez the existiny, station gas systosa to ensure the supply I i
r connections are not compatible with respirator air supply equipment.
(RIP 133. Cheaston Page IX-5)
Resnonse Nn=her 323 Evaluation completed. 1 Item Nn=her 324 Evaluate the station service air system to determine if the potential for - contamination of the air system exists and, if it does, impicment the . appropriate measures to prevent occurrence. See IE Notice 79-08 and 85-06 for additional details.
(RIP 134. Cheaston Page IX-5)
Resoonse NumLtr 324 Han been evaluated and corrective action taken. 1
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Item Ni-ker 32S_
Change the locations of the air sampling for the breathing ' air system within the RCA. Select the locations - randomly and include sampling for -
radioactive contaminants.
(RIP 135, Chomston Page 11-5)
Reasonae Number 325 Imcations have been evaluated and some changes made.1 k
Item N==har 326
]
' Unique or different hose connector fittings should be applied to all \
station compressed air outlets so that hoses cannot be inadvertently connected to the wrong systeo. ;
J Resnonne N==her 326 Completed. 1 Item Ni=her 327 !
Develop procedural instruction on respirator selection for the HP technician.
(RIP 137, Cheaston Page IX-5, NRC 285/8805-13) l Resoonse Ni-her 327 New respiratory protection procedures contain the necessary guidance. 1 Item Number 328 Develop formal training and experience requirements for personnel performing program implementation function.
(RIP 138, Cheaston Page IX-5)
Response Number 328 Requirements have been incorporated.-1
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Item Number 329-
' Move the respirator cleaning facility to an enclosed, ventilated area and reconfigure the process flow so the high level contamination work is furthest from the exit.
(RIP 139, Cheaston Page IX-5)
Response Number 329 Facilities have been upgraded and meet industry good practices. 1 5
F047/1 11/89
Item Ni=her 330 l
t Review the issue system so a positive control system is implemented.
(RIP 140, Cheaston Page IX-5)
Resnonne N==her 330 Positive control system has been implemented. 1 Item Niar 331 Maintain an inventory / code number for each respirator so a maintenance history can be maintained for each respirator.
(RIP 141, Chomston Page 11-6, NRC 285/8805-13)
EgJoonse N==her 331 Requirement is a part of new procedure. 1 Item Number 332 Change the respirator cleaning procedure to include instructions for retrieval, prewash monitoring, washing, sanitizing, drying, and surveys.
Eliminate any other procedure providing these instructions. Add a limit for fixed contamination.
(RIP 142, Cheaston Page IX-6, NRC 285/8805-13)
Resnonse Ni=her 332 These changes have been included in new respiratory protection precedures. 1 Item Number 333 Clarify the qualification criteria and process for obtaining approval to wear a respirator. Include designating who has approval authority, and the methods to be used in notifying the wearer and wearer's supervisor when requalification is required.
(RIP 143, Cheaston Page IX-6, NRC 285/8805-13)
Response Number 333 Included in new respiratory protection procedures.1 Ites Number 334 Evaluate the usefulness of applying to the NRC for approval of twelve (12) PF credit for sorbent canisters (See Farley write-up as an example).
(RIP 144, Chematon Page IX-6)
ResDonse Number 334 Has been evaluated. See response to s317 1 F047/1 71- 11/89 1
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1 Item N==bar 335 Develop .a separate training course for respiratory protection qualification. Include in the training the NUREC 0041 guidelines.
(RIP 145, Cheaston Page IX-6, NRC 285/8805-13)
Reasonne Nia-h-r 335 CET level III. Is included as a separate training course and includes l NUREC-0041 guidelines. 1 Item N==k-r 336 Do not perform initial fit testing until medical approval to wear a respirator has been obtained.
(RIP 146, Cheaston II-6)
Reanonne Ni=h-r 336 Requirement has been included.1 Item Nii=her 337 Expedite development of an operating procedure for the mask / fitter testing unit. Ensure that each mask is tested annually for leakage j (preferably the month before a refuelin6 outage). I (RIP 147, Chematon IX-7)
Resnonse Nin=her 337 Completed as a part of new procedures 1 Item Number 338 Air samples will be taken that represent the breathing zone of each worker whenever respirators are worn. The proceduralization of this approach and the acquisition of equipment to support it will be accomplished by June 1,1989.
(RIP 151, INPO 88 PaSe 16) l Resnonse Number 338 4
New procedures were issued 9/1/89, 1 Item Number 339 A reevaluation of the level of smearable surface contamination on floors and equipment above which respirators must be worn was performed and station procedures changed from a value of 20,000 dpm/100 sq cm to a higher level.
F047/1 -72 11/89
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Ramaa=== m A-r 339 r
RP-501
- Description and Selection of Respiratory Protection Equipment". 1 Itan N==k-r 340 Develop a clear and well organized respiratory protection program with procedures that address and implement all requirements of the regulatory guidance (NOREC-0041) and this criteria.
(RIP 164, OPPD 54) llennonaa Ni-k=r 340 Completed with new respiratory protection plan, procedures and personnel. 1-Item Ni=her 341 Define responsibility for respiratory protection program implementation at a level in the organization that provides close supervision of the application of respiratory protection in field activities.
- Reanonna N==h-r 341 New organization defines responsibility at a significant reporting level.1 l
Item N==her 342 '
The respiratory protection program should be described in separate distinct sections of both plan and procedures, (RIP 167, OPPD 55) i Eggponse Number 342 The RPP, procedures and standing orders provide acceptable distinct sections. 1 & ft Iten Number 343 The program element for use of self-contained breathin6 apparatus (SCBA) must be upgraded to industry standard, especially in the testing, maintenance, training qualification, and approval process.
Resnonse Number 343 Completed with new procedures and equipment. 1 F047/1 73 11/89
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FORT CA1210UN STATION RADIATION PROTECTION ENHANCEMENT PROGRAM j Nort Category 12 - Radioactive Materials Control Igg;n N==k-r-345 Review and revise existing radioactive material (byproduct) procedures for uniformity and continuity.
Rampensa Number 345 f,
'Ibe radwasta procedures have been revised and upgraded. -
.Itaa N =k-r 346 Establish a database for the control and accountability of byproduct source material.
(RIP 0, HNS 12-2)
Resoonaa Ni-har 346 -
i J
. The selection of a dgtabase management system will assist in accountability of byproduct source material.1 & (t :
Item N==her 347 1 Control of HEPA vacuum cleaners and portable HEPA air filters will be proceduralized and will require locking and control of units by technicians.
Resoonse Ni-her 347 The various plant vacuum cleaners and HEPA filter operations have been formally procedurized. '
Iten Ni=her 348 Procedures will be developed for sealing and transfer of potentially contaminated material from contaminated work areas.
Resoonse Number 348 This has been included in the revised procedures.
F047/1 11/89
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- FURT CAulOUN STATION RADIATION PROTECTION ENHANCEMENT PROGRAM Nort Category 13 - Nanagement Overview Item Ni= Le 349 Establish realistic goals for the radiation - protection program based on planned work activities to bring the program up to acceptable industry
' standards.
(RIP 0, HNS 13-1) i Rannonne Number 349 1989 goals wore' a first step. The 1990 goals will be based upon experience and will be mor.itored closely by management.1 Item Ni-her 350 Expand the goal setting process to facilitate the improvement program. !
(RIP 0, HNS 13-2)
Resnonse Ni=her 350 The 1990 goals will include those major tasks in the improvement program.1 -
Item Ni=her-351 Expand goals and-performance indicators beyond the basic INPO guidance.
(RIP 0, HNS 13-3)
Resnonse Ni=her 351 Coals and performance indicators include INPO guidance and go further to meet the needs of FCS. 1 Item Ni=her 352 :
Establish an environment conducive to creating personnel motivation.
(RIP 0, HNS 13-4)
Resoonse Ni=her 352 The enhancement program is designed to provide an RP program that one can feel a part of. This program is establishing the " roots" for a positive environment. 1 Item Number 353 Create programs for developing the potential of personnel.
(RIP 0, HNS 13-5)
F047/1 11/89
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Rasoonse Nimdper 353 i
l This need is recognized and management is reviewing best methods to develop personnel'. 1 Item N==k-r 354
- Develop and = implement a health ' physics - deficiency reporting and tr=*M ag program, l
q (RIP 0, HRS 13-6, NRC 285/8805-09)
Rannonse Number 354 ll ROR procedure issued 9/1/89 satisfies this item. 1 Item N==har 355 .
~ Develop and implement training for audit personnel.
(RIP 0. HNS 13-7, NRC 285/8805-09)
Resoonse Ni-har 355 Training of audit personnel is scheduled. 1 Item N==har 356 l
Develop an open items system and checklists to ensure routine activities and
- periodic record / field work reviews are performed by radiation protection supervision.
(RIP 10, Cheaston II-10)
Resoonse Ni=her 356 1
Commitment Tracking - System List satisfies current need for upgrading RP program.. A database management system has been evaluated and will provide further tracking methods.1 & 2 Item Ni-her 357 l
Determine OPPD's commitments to the NRC and establish a computerized database and corresponding procedures to allow the commitments to be listed in the reference section.
(RIP 11, Cheaston Page II-10) l Resnonne Ni=her 357 L
Commitment Tracking Syst.sm List satisfies this requirement. 1 l~ Item Ni=her 358 L Implement a program or worker evaluation in radiation controlled areas to L identify improper application of defined procedural requirements and j
provide prompt corrective actions.
l- F047/1 77- 11/89 l
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Ramaa==e N A r 358 Program is in place. to evalusta on-the-spot problems or procedure violations. The new ROR procedure is the reporting process for violations.
1 Item Number 359 Track and identify trends in radiation protection incidents with root causa determination.
Rasconne Number 359 New procedure tracks incidents and provides trending methodology.1 I Item Number 360 Corporate radiation protections staff should be utilized to provide more intimate trending of radiation protection parameters that otherwise left unaddressed can lead to violations and inspector concerns.
Remnonne N===har 360 Corporate staff will finalize plans by mid-1990 1 Item Ni-ker 361 Methods for preparing and dissaminating radiological conditions t.o supervision will be developed and proceduralized by December 1991.
Eggponse Nin=her 361 Performance indicators and information regarding daily radiological-conditions are reported to management. Methodology for proceduralized reporting is under evaluation. 1 Item Number 362 An audit plan for QA or some other internal assessment group should be developed that ensures monitoring the effectiveness of training in radiological activities.
(RIP 34. Chematon Page III-4, NRC 285/8805-09)
Resoonse Number 362 Corporate RP support will complete a plan by mid-1990 1 F047/1 11/89
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R I*== u ^ r 163-Implementation of a': strict retraining policy for individuals violating the proper procedure for work in a radiation controlled area.
Raanonae Nu4er 363 See ROR procedure. 1_
O Item Number 364
. Modify- Standing Order G-50's scope to require . individual
' sections / departments to develop their own exposure goals.
-(RIP 66, Chematon-Page VIII-6) ,
Reanonne n==her 364 This is-in process currently. 1 l
Item Ni-kar 365 1 Define parameters that need to be identified against which radiation- i
^
exposure goals can be better formulated and monitored.
Rean'onne Ni-Lar 365 Parameters have been identified in RPP. 1_ .
Item Ni=har 366
)
The. reporting of personnel contamination incidents will be improved by i changing the reporting form and supporting guidance to require information i
needed for investigation and analysis.
(RIP 150, INPO 88 Page 13) i Resnonse Ni=her 366 See new ROR procedure. 1 Item Ni=her 367 Increase management and supervisory monitoring of radiological work in progress to identify and make on-the-spot corrections of improper work practices.
.(RIP 212, INP 86 Page 33, NRC 285/8805-09)
Resnonse Ni=her 367 On-the-spot ' evaluations and immediate corrective actions is in progress under the AIARA groups. 1 F047/1 -79 11/89
.+ o Item N==kar 368-Improve the implementation of the radiological deficiency reporting system - ~
by documenting, trending, and analyzing all noted radiological deficiencies.
Use the results of the - trends and analyses to identify root causes of radiological problems.
(RIP 214, INPO 86 Page 36, NRC 285/8805-09)
Rannonna Nuoher 36B !
See ROR procedure 1 Item Number 369 Tack the RPPCC with the responsibility for providing corrective action for RP problems identified through the incident report program.
Reanonne Ni-her 369 See ROR procedure. 1 & !t Item Ni=har 370 Management must closely monitor the performance of the health physics group.
Kannonne Ni=her 370 The RP Enhancement Program and the selection of key supervisory personnel are ixu11cative of management overview of RP. Performance indicators are provided to management. 1 Item Ni=her 371 The C/RP Supervisor should be responsible for determining the root cause of j poor performance in radiation protection practices and determining the 1 appropriate corrective action.
Resoonse Ni=her 371 The Supervisor-Radiation Protection has this responsibility with the aid of the ROR procedure. 1 Item Number 372 Problems are not being resolved in a timely manner due to the lack of effective planning specifically in setting of priorities, the integration of the schedule, and the depth of the planning process.
F047/1 -80 11/89
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Ramoonaa E =k-r 372 New organisation is addressing this concern.
Itam E =kar 373 Additional efforta asust be taken to improve - consuunications between the I different groups.
(RIP 235, SUBC sect 3.3.2)
Ramponse lhamber 373 Supervisor amatation Protection and the three recently hired supervisors have improvement of connamications am a top priority.1 i Itan E=k-r 374 OPPD needs improvement in root cause analysis beyond that envisioned in Project 1991.
(RIP 236, SUBC Sect 3.4.1)
Resnonna E =kar 374 This evaluation rec-= dad that root-cause-analysis training be ,given to coordinators and supervisors.6 "
F047/1 11/89 m