ML20032B590
| ML20032B590 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 09/15/1981 |
| From: | Carroll R, Haddock D, Galen Smith, Jason White, Wojnas E AFFILIATION NOT ASSIGNED, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), TERA CORP. |
| To: | |
| Shared Package | |
| ML20032B580 | List: |
| References | |
| 50-309-81-01, 50-309-81-1, NUDOCS 8111050693 | |
| Download: ML20032B590 (77) | |
Text
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s J.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region ~I Report No.
50-309/61-01 Docket No.
50-309 License No.
DPR-36 Priority Category C
. Licensee:
. Maine Yankee Atomic Power Company Edison Drive Augusta, Maine 04578 Facility Name: Maine Yankee Nuclear Generating Station Inspection at: Maine Yankee Station, Wiscasset, Maine Inspection conducte J fuar 30 9
Inspectors:
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J/R. White, Radiation Sp5'cialist, USNRC
'date signed kAb4 I
Yl E. Wojnas, Radiati(n Spe i t,- SNRC
'date signed f
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R. J(rroll, Health Physicist,'4 ERA Advanced date signed Services Cor oration h
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D.p(ddock,Research cien t
date signed Approved by:
%e t Eu. N 9//6 G. H.- Smigh, DiYector, Division of Emergency da'te / signed Prep arepnes: and Operational Support i
i 550'2889 ogisgg, PDR E
1.0 Radiation Protection Organization 1.2 Description The radiation protection organizational structure that currently applies to the Maine Yankec Radiation Protection Program is depicted in Figure 1.
The organizati+?al charts from which Figure 1 was derived are the licensee's technical specifications and the Health Physics Organization Chart.
In this structure the Radiological Control Supervisor does not directiy report to tha Plant Manager, but rather through the Tech-nical Support Department Head. The Technical Support Department Head is aiso responsible for several other functions which are production oriented, such as Plant Engineering, Reactor Engineering, and Chemistry.
It is likely that the structure produces a conflict of interest since the Department Head is also responsible for Quality Assurance, Regulatory Compliance and Radiation Protection.
The appraiser noted that NUREG-0731, Guidelines For Utility Management Structure and Technical Resources and NUREG/CR-1280, Power Plant Staffing typify organizational structures having the Radiation Protection Manager reporting directly to the Plant Manager in order to implement the guidance of Regulatory Guide 8.8, "Information Relevant to Ensecing That Occupational Radiation Exposures at Nuclear Power Stations.4111 Be As Low As Is Reasonably Achievable", Section C.1.b.(3), wich states:
"The kadiation Protection Manager (RPM) (onsite) has a safety function and responsibility to both employees and management that can be best fulfilled if the individual is independent of station divisions, such as operations, maintenance, or technical support, whose prime responsibility is continuity or improvement of station operability. The RPM should have direct recourse to responsible management personnel in order to resolve questions related to the conduct of the radiation protection program."
(emphasis added)
From Figure 1 it can be see that the current organizational structure directly contradicts this guidance by incorporating the radiation protection program in the Technical Support Department.
1.2 Scope of Responsibilities The responsibilities assigned to the radiation protection organt-zation are described in the " Maine Yankee Radiation Protection Manual," January I, 1980. This document appears to adequately address the areas for which the program has responsibility. Collateral or supplementary responsibilities beyond those specified in the Radiation Protection Manual were not apparer.t.
a
2~
In regard to the actual job descriptions of the personnel imple-menting the radiation protection program, there is clear delineation of responsibility, however the description of commensurate authority is confusing.
For example, in both the job description for the Radiological Controls Foreman (also known as Health Pi.jsics Foreman) and the Radiological Controls Supervisor, the following is stated:
Radiological Controls Supervisor
-AUTHORITY:
1.
To function as the respresentative of plant management in all matters relating to the act.vities of the Health Physics Department.
2.
To terminate any Health Ph..rics Department activity which in his opinion-is not being carried out in accordance with applicable procedures, specifications, regulations, require-ments or accepted practice.
(emphasis added)-
3.
To re a.. mend the termination of any plant activity which jeopardizes personnel-safety or continued power generation.
4.
To determine needs, check availability and requisition any test equipment, tools and materials required for the efficient operation of r.he Health Physics Department.
Radiological Controls Foreman AUTHORITY:
1.
To terminate any plant activity which in his opinion is not being carried out in accordance with applicable Health Physics requirements, procedures or practices.
(emphasis added) 2.
To recommend the termination of any plant activity which jeopardizes personnel safety or continued power generation.
3.
Shall assume aethority, in the area of Health Physics, commensurate with the position of Radiologica' Controls Supervisor during periods of the supervisor's absence.
From the emphasized statements, it would appear that morc general authority is vested in the Radiological Centrols Foreman in regard to enforcing adherence to radiological control procedures and require-ments. However, interviews with the personnel 1,ivolved indicate that it was the intent to state that the Radiological Controls Supervisor was vested with at least the same degree of general authority to assure that the program for which he is directly respon-sible is implemented. To this end, the licensee indicated that the J
e e
3 applicable job descriptions will be revised to assure that the authority vested-in the Radiological Controls Eupervisor is adequately described.
In the current organizational structure the following fJnCtions are the direct resoonsibility of the Radiological Controls Supervisor:
Emergency Planning and Preparation Radioactive Waste Handling and Transport Plant Radiological-Controls Personnel Exposure Control Program ALARA Program Respiratory Protection Program Health Physics Technician Training Program Plant Health and Safety Some of these functions are delegated to the Radiological Controls Foreman who also provides direct management of the health physics.
technician staff. There was no other personnel resource dedicated to these functions, with the exception of Plait Health and Safety, for which a specialist was recently hired.
While these individuals (Radiological Controls Supervisor and Foreman)
.l.
are technically competent and have generally performed satisfactorily.
in the implementation and management of each of these functions, several aspects of these elements (as detailed in this report) rcquire improvement to achieve an acceptable program. However, in these cases, it appears that the deficiencies are not a result of the lack of ability but rather the attempt to manage and implement a d
wide range of program elements with marginal personnel resources to support the efforts. The efforts of the current staff are commendable but are not sufficient to assure that the radiation protection program will be sufficiently upgraded or even maintained sufficient to assure adequate radiciogical controls in both normal and off-normal situations.
Much of the general technical support for the site radiation protection program is provided on request from the licensee's subsidiary, Yankee Nuclear Services Division.
The division provides dosimetry processing as well as other specialized engineering support services i
that have enhanced the ability of the site organization.
ne staffing of the radiation protection section is as follows:
1
-)
4 Position No. of Personnel Radiological Controls 1
Supervisor (RPM)
Radiological Controls Foreman 1
Health and Safety 01 rector 1
Ad;11nistrative Aide 1
Chemistry / Health Physics 5
Technician Tester 1
Contracted Clerk 1
Contracted Technician 1
With this resource, the licensee provides generally one technician on eac!1 working back shift and two technicians on the day shift.
Such coverage is marginal support for a 2630 MWT reactor, even in nu..nal operating conditions. At the time of_this appraisal, staff openings had been authorized for one additional tester and_two addi-tional technicians.
In addition, the licensee indicated that a staff position for Radio-active Waste S;pervisor had been recently authorized.
Appraisal The generic cause for many of the deficiencies identified in this report appear to be related to lack of personnel onsite sufficient to adequately implement the radiation protection program. With only two supervisors, the RPM and foreman, it is unlikely that adequate management support can be sufficient for the range.of specialty functions that need to be addressed.
It is apparent that these supervisors themselves are the only technical specialists available and are making the best effort possible to maintain the program.
This lack of technical / supervisory personnel, as well as the similar lack in regard to the number of technicians available to maintain plant radiological controls, contribute significantly to the program deficiencies identified during this appraisal.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
J
5 The organizational structure is currently not in' accord with the recommendations of Regulatory Guide 8.8, NUREG-0731 and NUREG/CR-1280, in that the designated Radiation Protection Manager is not independent station divisions having responsi-bility for the continuity and improvement of station operability.
There are marginal personnel resources currently available in terms of supervisory, technical support and technician' personnel to support the continuity or improvement of the radiation pro-tection program.
2.0 Perso. il Selection, Qualification, and Training Program Documents Reviewed
" Maine Yankee Radiation Protection Manual," January 1, 1980.
Procedure No. 9.1.23, " Respiratory Protection Training Program,"
Revision No. 3, August, 1979.
Procedure No. 9.237, " Health Physics Department _ Training Program,"
Revision No. 0; March 31, 1980.
Administrative Procedure No. 0-00-6, " General Plant Training Pro-gram," Revision No. 3, December, 1979.
Program The duties of health physics were performed by each chemistry and health physics technician in the Health Physics Department (HPD).
In addition, the duties of radiochemistry were performed by the chemistry and health physics technicians on the midnight to eight a.m. shift. The licensee's personnel section, qualification, and training program for the HPD were developed to address both Health Physics and Radiochemistry.
Selection and Qualification Program The selection and qualification criteria for licensee chemistry and health physics technicians were outlined in the Position Posting.
It contained selection criteria, responsibilities, and daties of each technician grade.
The licensee technicians were divided into two grades; chemistry and health physics technician "S", and chemistry anf. health physics tester. The tester grade is equivalent to a junior technician (ANSI 18.1-1971) and the "S" grade is equivalent to a senior technician (ANSI 18.1-1971).
Formal procedures do not exist for outlining qualifications, duties, or responsibilities of contractor health physics technicians.
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6 The duties and' responsibilities for HPD Management are contained in the licensee's Job Description.
In addition, this document outlines the authority ascribed-to these positions and the minimim qualifications.
The Job Descriptions reviewed were:
Radiological Controls Supervisor, Radiological Controls Foremen, Administrative Aide, and Health and Safety Director.
Training Program The health physics training program consisted of five categories: go c il -
employee indoctrination training program (given initially to all pla.
personnel), respiratory protection training program, general plant re.441n-ing program, naw personnel training"for HPD personnel, and health physics retraining for HPD personnel.
The general employee indoctrination is-given by'the Training Department to all new plant employees. This training consists entirely of a video-tape-presentation based on the following site specific outline:
I.
Definitions II.
Sources of Radiation III.
Measuring Devices IV.
Exposure Limits V.
Biological Effects l,
VI.
Relative Risks-VII.
ALARA VIII.
Surveys / Posting IX.
Dosimetry X.
Time / Distance / Shielding XI.
Contamination XII.
Protective Clothing XIII.
Whole Body Counting The same format is used for licensee and contractor personnel with a course duration of approximately one-half day. This time period also includes security, safety, quality assurance, and respirator training if applicable..The training is followed by a fourteen question multiple choice test.
The respiratory protection training consisted of a video-tape presentation given by-the Training Department followed by a respiratory fit test. An exam applicable to respiratory protection did not exist. The exam given for the general indoctrination does not contain any questions relating'to respiratory protection.
The general plant retraining program was v..ainistered by the Training Department but instruction pertaining to health phy:ics is provided by HPD management. This training was provided every other Thursday, for one hour, throughout the year. As a minimum, health physics receives one and one-half hour per calendar quarter of this type instruction.
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7 Health Physics Training, for:new HPD employees, was provided solely by-the HPD..The major portion of the training program was conducted as an on-the-job type program. A check list ("new employee training check off sheet") was maintained with the date and initials of instructors when each item in the program was completed.
A' final check-off indicating proficiency in the item covered is made by the Radiological Controls Supervisor. This system is also used for con-tractor health physics technicians.
Health Physics Retraining, for HPD personnel, is performed as a minimum every two years by the Radiological Controls Supervisor or his designated alternate. A check list (" employee health physics retraining check off i
sheet") is used to record the date and instructor for each of the items covered in the retraining program.
Documentation of HPD health physics training is kept in the HPD Records Office and health physics training, performed by the training department, is documented and maintained in the training department offices.
Appraisal Selection and Qualification P-qram The appraiser evaluated the selection and qualification criteria in the hiring and advancement process by reviewing the personnel files (resumes) of all licensee and contractor HPD staff members.
It was observed that the selection and qualification criteria -for licensee Health Physics technicians were inaccordance with ANSI 18.1-1971, and the guidelines formally outlined in the Position Posting.
However, the appraiser observed that a formal procedure or document did not exist for the-review and selection of contractor health physics technicians. The Radiological Controls Foreman stated that all contractor resumes were reviewed and that the results of written tests and individual interviews were evaluated informally to verify that ANSI 18.1-1971 guidelines were met for con-tractor technicians. At the time of the appraisal, there was one con-tractor health physics technician employed by the licensee, and he was verified to be an ANSI 18.1-1971 qualified.
The selection and qualification criteria for HPD management as outlined in the formal " Job Description" was found to be consistent with ANSI 18.1-1971 and Regulatory Guide 1.8 as shown below.
Radiological Controls Supervisor B.A. in Education 1 year formal Health Physics school 5 years as a Health Physics technician 12 years as Health Physicist
8 Radiological Controls Foreman B.S. in Zoology M.S. in Zoology 10 years a Health Physicist Training Program The appraiser reviewed training records for all HPD and training depart-ment staff members plus selected records of maintenance, operations, and site management personnel.
In addition to the review, various members of the HPD-were interviewed to determine the adequacy of the licensee's Health Physics training program.
It was observed by the appraiser that the content, scope, frequency, and technical depth of the training performed by HPD management was adequate.
This includes health physics technician initial /regaalification training and the retraining'of all plant personnel.
However, the general employee indoctrination and respiratory protection training performed by the Training Department were found to be inadequate. This is based on the lack of student " hands-on" participation, instructor participation, the competence of the instructor, and student demonstration of attainment of standards.
Videotapes depicting various Health Physics practices such as frisking techniques, step-off pad (SOP) precedures, donning / removing protective clothing, and the proper wearing of respiratory protection were used in the general employee indoctrination and respiratory protection training.
However, the classroom instructor did not require the students to perform or demonstrate these functions. The appraiser judged this to be a deficiency in the training program because staff members are routinely required to perform these functions in the controlled areas. During. interviews with various staff members, it was noted that the licensee's training program policy was not to require demonstration of the above items, but to let the workers find out how to perform the needed functions in the field.
In view of the appraiser, the videotapes used in the geneneral employee indoctrination and respiratory protection training are of good content and scope, but are not effective without reinforcement by student participa-I tion.
The deficiency noted above has, as one of its causes, the use of video-tapes exclusively for both indoctrination and respiratory protection training.
Even though an instructor is provided for both types of training, he/she does not participate unless questions are asked about the content of the videotapes. This is not consistent with ANSI N13.1-1978 which recommends that systems such as videotapes should not comprise more than 50% of the lecture time.
In reviewing the videotapes, it was observed that the tapes were designed to have breaks for class discussion but that these breaks were not utilized, and the videotapes were used 100% of the lecture time.
=
9 In addition to the lack of " hands-ca" training and instructor participation, it was observed that the= present instructor is not qualified to cover the material-either in the indoctrination or respiratory protection training.
A stenographer in _the training department with no background in health -
physics has been performing this function from October,1980 until the time of the appraisal.
In interviews with this staff member, it was stated that-whenever a question came up in a training class, it was necessary for her to find an instructor that could answer it.
At the end of the general employee indoctrination, a fourteen question multiple choice test is given to judge the attainment of standards pre-sented in training.
In reviewing training records and interviewing
-training department staff members, it was observed by the appraiser that a guide does not exist for determining the adequacy of a test result.
It was stated by the training supervisor that tests were treated on a case-by-case basis and that if a question was missed, it might be reviewed with the student depending on which question it was.
This is seen to be a deficiency by the appraiser and does not allow the instructor to judge if the student received an adequate amount of knowledge or whether the student should retake the training until acceptable.
Conclusions Based on the above findings, the personnel selection and qualification programs appear to be acceptable, but improvements in the following areas are required to achieve an acceptable personnel training program for general employee indoctrination and respiratory protection:
" Hands-On" participation Instructor participation Instructor qualifications Evaluation of student comprehension 3.0 Exposure Control 3.1 External Exposure Control Program Documents Reviewed
" Maine Yankee Radiation Protection Manual", January 1, 1980.
Procedure ~No. 9.1.6, " Establishing and Posting Controlled Areas," Revision No. 4, March, 1979.
Procedure No. 9.1.12, "Use of Personnel Monitoring Devices,"
Revision No. 9, June, 1979.
Procedure No. 9.2.19, " Exposure to Noble Gas," Revision No. 7, August 1979.
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10 Procedure No. 9.2.10, " Calibration of the Eberline Neutron Detector PNR-4," Revision No. 5, July 6, 1979.
Procedure No. 9.2.16, " Pocket Dosimeter Calibration and Leak Testing," Revision No. 4, May 31, 1979.
Procedure No. 9.2.17, " Performance and Calibration Check of the Yankee TLD Service," Revision No. 3, June 6, 1980.
Program The external radiation exposure control program for the licensee consists of the dosimetry, exposure review, exposure limitations,.
and quality assurance programs as related to external radiation exposure.
External Dosimetry Program The dosimetry program maintains control of personnel exposures by using exposure measuring devices, timekeeping, and a records system for documenting these exposures. The whole body measuring device used is a thermoluminescent dosimeter (T!.D). supplied and processed by a licensee service group for all Yankee plants.
In addition, a vendor-supplied TLD finger ring is used for extremity measurement.
Pocket ionization chambers (pencils) are also used.
Neutron exposures are determined by using the TLD. Timekeeping calculations for neutron exposure are performed but are not considered part of the legal record.
Skin exposure is determined by the licensee from a combination of TLD results and noble gas calculations. The records systems included indivioual exposure history files, a continuously updated comouter file for all personnel assigned a TLD, daily exposure logs, and radiation work permits.
i The TLD used by the licensee is supplied and processed quarterly by the Yankee service group.
The'TLD is designed to measure gamma, x-ray, beta, and fast neutron radiation. The TLD specifications are:
Energy Response Gamma /X-ray 100 kev - 1.5 MeV (linear less than 100 kev (supralinear).
Beta Responds to greater than 400 kev.
Neutron (fast)
Neutron response is plant specific to the actual neutron spectrum; greater than.1 MeV.
Neutron (thermal)
Not available.
11 Minimum Detectable Dose Gamma /X-ray 10 mrem Beta 25' mrem Neutron (fast) 10 mrem The licensee's TLD consists of a clip on holder with four TLD chips.
' Two chips are used for gamma only; the other two being used for beta / gamma and neutron / gamma.
Self-reading pocket ionization chamber (pencil) dosimeters are used in conjunction with the TLD. Pencil dosimeters are required for entry into the controlled area.
If both TLDs and pencil dosimeters are used, the pencil is recorded in the person's_ exposure file until the TLD can be processed.
The responsibility of reading, rezeoring, and recording pencil dosimeter results is left up to the Health Physics Department (HPD) and the security personnel at the plant entrance.
Extremity exposures are measured with a finger ring dosimeter con-taining TLD chips. The licensee's policy for wearing of finger rings is left to the judgment of HPD personnel on a case-by-case basis.
Records of extremity exposure are included in each person's exposure file on an NRC-5 equivalent form.
Records of skin exposure
.from noble gases as per Procedure No. 9.1.19 are also recorded in each exposure file on a separate NRC-5 form.
Each staff member has their own exposure record file which is main-tained by the~ radiological controls administrative aide containing:
NRC-5 forms NRC-4 forms Whole body count results Noble gas exposure records Baseline count data Badge change reports Visitor TLD badge records Personnel decontamination reports Respirator fitting program log sheets External Exposure Review Program In addition to the exposure records in the above files, an exposure report is generated daily and reviewed by HPD management. This report, "ME-Yankee Daily Exposure Log," lists maximum permissable concentration (MPC) hours, pencil dosimeter results for that day, weekly / quarterly / yearly totals and allowed limits (this is a com-bination of TLD and pencil dosimeter data).
The TLD data for this report is supplied by the Yankee service gruup with pencil dosimeter results being updated daily from the RWPs and the pencil dosimeter a
12
-log sheets generated by.the security group at the plant entrance.
During outages, this daily report is also sent to the control point-
.and each department of the licensee.
-In addition to the daily report, a quarterly report is generated with gamma, beta, and neutron exposure totals which is reviewed by HPD management.
External Exposure Limitations Program The exposure limitations program consists of documents establishing the licensee's policy regarding external exposure guides and radio-logical posting.. The exposure guides as outlined in the " Maine Yankee Radiation Protection Manual" are:
300 mrem / calendar week 2000 mrem / calendar quarter Quality Assurance Program The licensee's quality assurance program for external exposure control consists of the calibration of portable survey instruments, counting room equipment, and reliability checks on-the Yankee TLD service.
The quality assurance checks on the TLD's consist of exposing several TLDs to various exposure levels from 0 to 2000 mr on a semi-annual frequency as a minimum. These exposed (spikes)
TLD's are then sent in with the rest of the staff membert TLD's to be processed by the Yankee service group..The results are then compared to the calculated values as determined by the licensee during the spiking process. The results of this comparison allow the licensee to either accept or require the Yankee service group to re-evaluate its data accordingly.
Appraisal External Dosimetry Program The exposure history of each individual is kept in the HPD records office and contains both external and internal exposure records.
The appraiser observed that the individual records were current and I
complete; and met the requirements of 10 CFR 20.401. The NRC-5 forms were filled out each quarter with a separate NRC-5 form used for whole body, skin, extremity, and neutron exposures.
In interviewing the radiological controls administrative aide and the contractor radiation records clerk, it was determined that they had adequate knowledge to perform their normal duties as well as to recognize unusual events that may require special interpretations or evaluations. There were several systems of cross-reference for individual external exposures which coupled with the appraiser's findings made the external exposure record system acceptable, a
13 The data collected by the HPD routinely on their survey forms and RWPs gives the licensee the capability to calculate skin, extremity, and neutron exposures. The actual calculations are not performed on a regular basis but the records reviewed by the appraiser indicate that this option is considered an important tool by the licensee and is used correctly when needed.
External Exposure Review Program The review of external exposure records by HPD management was found to be acceptable. However, the appraiser noted that exposure reports were not reviewed by foremen and licensee management directly responsible for the individual workers except during outages.
As of the time of completion of the appraisal, a commitment had been made by the licensee to distribute-exposure reports to the appropriate management every Friday during non-outage periods.
The licensee has the ability within the present exposure records system to follow exposure trends on individual jobs and groups of workers.
However, the appraiser noted that exposure trends were not followed routinely. This needs to be performed because individuals and groups can lose track of ALARA goals over a period of time.
This deficiency is discussed in more detail in the ALARA section of this document.
External Exposure Limitations Progrem The appraiser observed that a formal system was not in place for authorization to exceed the licensee's plant administrative control limits.
The only document observed to cover this subject is the
" Maine Yankee Radiation Control Manual" which outlines the limits and what approval is necessary to exceed these limits. A procedure outlining the action to be taken if the plant administrative control limits are exceeded without approval did not exist.
In addition an upper limit, which is not to be exceeded by licensee or contractor personnel, was not established.
The limits outlined in the " Maine Yankee Radiation Control Manual" are:
300 mrem calendar week.
2000 mre / calendar quarter.
This document states that, " Exposure in excess of either the weekly or quarterly control limits will require health physics approval."
In interviewing the radiological controls foreman, it was stated that approval to exceed control limits is treated on a case-by-case basis.
It was further stated that an informal upper limit of 2500 J
14 mrem / calendar quarter was usually used.
In reviewing exposure records and interviewing the radiological controls foreman and administrative aide,'it is the opinion of the appraiser that a formal procedure should be developed outlining the following:
Plant administrative control limits.
Method of exceeding the limits.
An upper limit not to be exceeded.
Approval should irclude plant management besides the HPD.
What actions are taken if limits are exceeded without approval.
Guidance criteria to determine if exceeding the limits by that individual is necessary.
As discussed in the' exposure review program of this document, the-deficiencies of the ALARA program also effect the exposure limita-tions program. This is primarily due to the lack of following exposure trends.
This deficiency is discussed in more detail in the ALARA section of this document.
Other aspects of.the exposure limitations program such as radio-logical posting, shielding, access control, etc., were found by the appraiser to be acceptable.
Quality Assurance Program The appraiser observed that the quality assurance portion of the external exposure control program was marginal based on the portable survey instrument calibrations and the counting room instrumentation calibrations. This is discussed in more detail in the calibration section under the surveillance section of this document.
The quality assurance program based on the reliability checks per-formed on the Yankee service TLD is acceptable. A spiking procedure does exist (Procedure No. 9.2.17) outlining procedural steps and equipment to be used. The appraiser noted in reviewing the records that the reliability checks have been performed routinely, however, the recording of data needs improvement. There is not a standardized data form used. Presently, a blank memorandum form is used and the data is not recorded consistently in the same format.
The data that is recorded is:
Badge number Calculated dose Actual dose Percent error Date performed Whether it was gamma / beta / neutron
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15 The data that is not recorded is:
Exposure rate of source Time on/off The isotopes involved Serial number or identification. number of condenser "R" chamber used Remarks concerning reason for magnitude of. percent error Name or signature of staff member performing spiking Overall, the external exposure.qua'ity assurance program was found to be acceptable.
Conclusions Based on the above findings, the external exposure dosimetry program, the external exposure review program, however, improvements.in the area of plant administrative control limits should be considered.
3.2 Internal Exposure Control Program Documents Reviewed
" Maine Yankee Radiation Protection Manual," January 1, 1980.
Procedure No. 9.1.2, " Respiratory Protection Program," Revision No.1; January,1980.
Procedure No. 9.1.25, " Bioassay Program," Revision No. 3, August, 1979.
Procedure-No. 9.1.22, "MPC Hour Accountability Program," Revision No. 4; April 1980.
Procedure No. 9.1.26, "Whole Body Counting," Revision No. 4, October, 1980.
Procedure No. 9.211, " Calibration of the Eberline PAC-45 ALPHA Counter," Revision No. 2, March 2,1979.
Procedure No. 9.234, " Calibration of the Whole Body Counter,"
Revision No. 1, September 11, 1979.
Program The licensee internal radiation exposure control program consists of the dosimetry, exposure rev'iew, exposure limitations, and quality assurance programs as related to internal exposure.
16 Internal Dosimetry Program The internal dosimetry program includes biosurveillance, timekeeping, and a records system. The biosurvellance methods used by the licensee are whole-body, lung, and thyroid counting. Timekeeping in con-junction with air sample results is used in calculating maximum permissible concentration (MPC) hours. The results of these calcu-lations are used in determining the need for whole-bcdy counting or other biosurveillance methods. The records system included individual exposure history files, whole-body / thyroid / lung computer printouts, air sample data, personnel decontamination surveys, and MPC hour accountability logs.
The whole-body / thyroid / lung counter used by the licensee consists.of a chair and detector management. A three-inch by three-inch NaI detector is used for whole-body and lung counting and a one and one-half inch by two-inch NaI detector ~is used for thyroid counting.
The subject to be counted is required to sit in the chair, with the appropriate detector and collimators being used, for a period of ten minutes.
The computer program used to analyze the data generated in this period has the capability of identifying the following isotopes:
Whole Body / Lung Thyroid-Cr-51 I-131 Mn-54 I-133 Fe-59 Ba-133 Co-58 Sn-113 Cc-60 Cs-137 Zn-65 Co-60 Zr-95 Ru-103 Sb-124 Ba-133 Cs-134 Cs-137 I-131 The whole-body / thyroid counting frequency for licensee staff members by Procedure 9.1.20 is:
Annual Counting:
" Personnel whose duties do not require e
.1 ng the plant radiation control area.
f Semi-annual Counting:
" Personnel whose duties require entry to the plant radiation area."
O 17-Contractors and visitors are counted at a frequency as deemed nect.ar y.
by the. radiological controls supervisor.
Lung counting is performe-when the whole-body count shows the presence of an insoluable Class Y nuclide.
An exposure-record file is maintained for each staff member, which contains external exposure data, the results of all whole-body, thyroid / lung counts; MPC-hour calculations. respiratory protection fit data; and personnel decontamination se vey forms.
In addition, if nasal smears, or fecal and urine samples are taken, the results of the analyses are included in this file, MPC hours are recorded both in a computer file, as discussed in the external exposure contral section of this document, and in a three-ring notebook by the name of the staff member. The log is based on a limit of 40 MPC hours for seven consecutive days.
Internal Exposure Review Program The internal exposure review program consists of the case-by-case analysis of data by Health Physics Department (HPD) management.
This is accomp1'shed by feedback from HPD technicians, surveys, air samples, and whole-body / thyroid / lung count data.
Internal Exposure Limitations Program The internal expostre limitations program consists of procedures establishing licensae policy to meet the concept of ALARA.
In addition, the use of posting and protective clothing (including respiratory protection) are used to insure that internal exposures are minimized.
Quality Assurance Program The licensee's quality assurance program for internal exposure control cc--ists of the calibration of portable survey instruments, counting - ' instrumentation, air-sampling equipment, and the whole-bod 3 roid/ lung counter.
In addition, the. analysis of respirator, cotection fit data and inspection of respirators allow for maximizing the effectiveness of this program for internal exposure control.
The calibration of the whole-body / thyroid / lung counter is performed by the licensee. This consists of a semi-annual electronic / radio-active source calibration and a daily source check with radioisotopic phantoms.
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~ Appraisal
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Internal Dosimetry Program
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The appraiser observed that the internal exposure records 7were typically up-to-date and complete in meeting the requirements of NRC Regulatory Guide 8.26 and ANSI N343-1978, " Internal Dosimetry for Mixed Fission and Activation Products." The one exception to this was the "MPC hour accountability-record" form from Procedure 9.1.22.
These forms, for all of 1980, were not filled out completely as
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required by Procedure 9.1.22, Step 4.3 which states:
" Complete form MY-HP-28-75 for each individual." The form requires the following information:
Name Social security number RWP number Company Date Time in Time out Total time Isotepe Activity Protection factor used Respirator type and cartridge used MPC hours The following information was consistently not filled in:
RWP number Time in Time out Total time Isotope Activity In discussing this with the radiological controls foreman and admin-istrative aide, it was stated that this missing information was needed and that the_ problem would be corrected.
In addition, it was observed by the appraiser that there was no organization ir. the individual record files.
The data collected routinely by the HPD from surveys, air samples, and whole-body / thyroid / lung counts is adequate to evaluate most uptakes and determine the critical organs involved. However, the appraiser observed two aspects of the internal dosimetry expos:.re program that need to be improved.
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'The first was that a formal procedure outlining calculational _ methods to be'used in determining uptakes and-critical organs did not exist.
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Secondly, procedures for sampling, handling, and analysis of fecal and urine for radioisotopic concentration also did not exist.
The Radiological Controls Foreman,.who is responsible for performing calculations of an internal exposure nature, was interviewed.
It was determined that he is competent ~to perform the calculations and is aware of and uses appropriate-ICRP guidelines. However, in the view of the appraiser, other members of the HPD are at a di.1-advantage to perform this function without a formal procedure.
HPD staff members stated that fecal and urine samples are not taken en a routine basis. However, Procedure No. 9.1.20 calls for urine sampling on an incident case basis. This presents a problem because a typical (or averaged) baseline has not'been determined for plant workers.
In addition, the lack of a formal procedure outlining the following aspects would make the possibility of performing.these samples, especially in~an incident situation, unrealistic:
I Sample collection including volume requirements, frequency, selection of personnel to be sampled.
Storage and transportation'of samples.
Isotopes of interest.
Action-levels.
Analysis techniques.
Calibration methodology.
Calculational methods and models.
Internal Exposure Review and Limitations Programs The internal exposure review rnd limitations programs were found by the appraiser to be acceptable and conforming to gotd ALARA practices.
Quality Assurance Program The overall quality assuranca program for internal exposure control was found by the appraiser to be acceptable.
In particular, the calibration program for the whole-body / thyroid / lung counter is very well documented and performed. Aspects that make the bioassay program highly acceptable are:
V 20 Performance of daily source checks on whole-body / thyroid / lung counter.
Performance of semi-annual electronic / radioisotopic calibrations.
Frequency of routine bioassay counting program.
Competence of staff member running the whole-body / thyroid / lung counter.
Analysis of bioassay data by HPD management.
Conclusions Based on the above findings, the internal exposure review program, and the internal exposure quality assurance program appears to be acceptable, however procedures for determining radiosotopic uptakes and procedures for the collection and analysis of fecal and urine procedures should be developed to improve the system for controlling and monitoring intertial personnel exposure.
3.3 Surveillance Program Documents Reviewed Procedure Rev.
Date Maine Yankee Radiation Protection Manual 1/1/80 9.1.1 Plant Radiologica' Surveys 3
1/80 9.1.3 Neutron Surveys 4
4/79 9.1.5 Radioactive Source Inventory 4
3/79 and Leak Test 9.1.6 Establishing and Posting 4
3/79 Controlled Areas 9.1.7 Area and Equipment 3
3/79 Decontamination 9.1.8 Monitoring for Personnel 3
3/79 Contamination 9.1.9 Personnel Decontamination 5
12/79 Procedure
I O
21 9.1.10 Radiation Work Permits 8
5/83 9.1.14 Receipt of. Radioactive Materisi 5
5/80 9.1.15 Shipment of Radioactive Material 7
1/81 9.1.17 Processins Radioactive Solid 5
2/80 Waste 9.201 General Calibration rocedure
'll 1/7/81 For All Laboratory & Portable Instruments 9.202 Calibration of the Eberline 1
5/25/79 Rad Owl R0-3 9.203 Calibration of the Laboratory 5
3/7/79 G.M. Counters 9.204 Operation and Calibration of 2
9/3/80 NMC Automatic Sample Changer 9.205 Calibration of the Eberline 1
10/26/79 Mini Pulser MP-1 9.206 Calibration of the EON Low 0
3/18/77 Range Survey Meter 9.207 Operation and Calibration of 5
5/4/79 the Eberline PIC-6A 9.208 Operation and Calibration 5
5/4/79 of the Eberline E-400 9.209 Operation of NMC Constant Air 2
2/16/79 Monitors 9.210 Calibration of the Eberline 5
7/6/79 Neutron Detector PNR-4 9.211 Calibration of the Eberline 2
3/2/79 PAC-4 G Alpha. Counter 9.212 Calibration of the Eberline 3
5/25/79 RAD OWL R0-1 9.213 Operation and Calibration of 6
9/3/80 the Eberline RM-14 Radiation Monitor
22 9.214 Operation and Calibration of 5
7/5/79 the Teletector Model 6112 9.215 Calibration of the Victoreen 3
5/25/79 Radacon II 9.218 Calibration of Air Samplers 5
7/1/80 9.219 Calibration of the Eberline 0
5/3/78 RM 16 9.220 Calibration of the Dosimeter 0
9/5/80 Corporation of America Area Alarm Monitor Model 3090 9.221 Operation and Calibration of 0
1/9/81 the Eberline SAM-2/RD-22 9.225 Calibration and Use of the 0
6/20/78 Technical Associates CP-MU 9.231 Calibration of the Canadian 0
6/28/78 Admiral Beta Dosimeter AEP5210 9.232 Operation and Calibration 3
5/4/79 of the Eberline E-140 9.233 Dupont Constant Flow Air 1
6/25/79 Sampler Operation 9.235 Calibration of the Victoreen 0
2/1/79 Panoramic Model 470A 2.205.8 Operation of the Nuclear 1
2/23/79 Measurements Corporation PCC-11TC Windowless Proportional 3-5.2.1.29 Source Calibration of the R.M.S.
1 3/19/80 3.7.1.1 Liquid 'adioactive Waste 6
12/30/80 Discharg?5 3.7.1.2 Gaseous Radioactive Waste 1
12/30/80.
Discharges 7.205.6 Operation of Canberra 8700 1
12/24/80 Multichannel Analyzer
23 7.205.6.1 Calibration of the Canberra 2
11/28/79 Germanium-Lithium Detector and Multichannel Analyzer 7.205.6.2 Detection Efficiency Calibration 2
11/28/79 of the Germanium Lithium Detector and Canberra 8100 and 8700 Multichannel Analyzers 7.205.8.1 Calibration of the Nuclear 1
12/31/80 Measurements Corporation PCC-11TC Windowless Proportional Counter 7.205.11 Operation of Canberra 8100 1
12/9/80 Multichannel Analyzer 3.3.1 Scope The licensee's surveillance program was overall found to be inadequate. The inadequacies given in this section of the report are basically symptoms of the problem. The basic problem was identified as the lack of personnel resources available to the Health Physics Group.
It was apparent to the Appraiser that licensee personnel had the capability to identify and correct the problems but they did not have adequate personnel resources available to institute actions.
The licensee's procedures were only general in nature.
The procedures did not contain sufficient information to describe the basis of the surveillance program. Many of the procedures were outdated and did not reflect current practices or equipment. The licensee maintained well established schedules for performing routine surveillance such as surveys, calibrations, etc. However, the procedures did not contain sufficient information on instrument selection and use, survey method, air sampling method, calibration techniques, protective clothing l
requirement, controlled access exit requirements, j
qualification or requirements for self-monitors and other related topics.
The necessity for additional procedural guidance was verified by the varying answers received from Health Physics Technicians and other plant personnel regarding Radiation Work Permit (RWP) requirements, undressing procedure, use of step off pads, the need for Health
o 24 Physics job coverage, etc. The techniques used for surveys, air samples, instrument. cr.libration, routine check of laboratory equipment ano specifying RWP require-ments -varied greatly from one technician to another.
The licensee's procedures required Radiation Work Permits (RWPs) for:
entry into 'High Radiation Areas or Airborne Radioactivity Areas; entry into the Reactor Containment; when handling reactor fuel; areas posted "No Entry Per-mitted-Radiation Work Permit Required"; maintenance or inspection of contaminated or radioactive equipment in 2
excess of "..10,000dpm/100cm removable contamination, 25 mR/hr general area radiation levels, or opening of systems-that could release radioactive material." Most RWP's were issued on a daily basis, but the Health Physics Supervisor had the authority to extend RWP's for any period of-time he deemed appropriate.
RWP_'s were reviewed and signed by the Shift Operating Supervisor before they were issued.
This assured that operations had an opportunity to note any proble'ms or plant conditions that may affect the work.
Health Physics had an opportunity to discuss special precautions and radiological conditions with the working party supervisor before work began in accord with the RWP.
Technical Specification 5.12.1 "High Radiation Area" requires the use of, "a.
A radiation monitoring device which continuously indicates the radiation dose rate in the area, b.
A radiation monitoring device which continuously integrates the radiation dose in the area and alarms-when a preset integrated dose is received; or, c.
A health physics qualified individual (i.e.,
qualified in radiation protection procedures) with a radiation dose rate monitoring device who is responsible for providing positive control...and who will perform periodic radiation surveillance at the frequency specified in the RWP."
Procedure 9.1.10, " Radiation Work Permits", specifies the frequency that Health Physics personnel must check the work area under the provision.of Technical Specification 5.12.1.c.
In this regard approximately 190 RWP's_were reviewed for the period of December 13, 1980 through January 26, 1981 and included an outage period in December 1980. With few exceptions, self mcnitoring with survey instruments was the method specified on the RWP's for fulfillment of-the Technical Specification requirement.
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25 This practice was used even for RWP's that indicated radiation levels greater.than 1,000 mrem /hr and' included RWP's for contractors and plant personnel from various groups. A licensee representative stated that the indication of 10 - 6,000 mR/hr general area on a RWP, such as RWP number 80-12-155, did not mean that personnel would be working in the 6,000 mR/hr but only that those areas were accessible at the work site, Several licensee personnel who were responsible for 4
issuing RWP's were asked how they determined if individuals were qualified to self monitor. One response was that they knew who was qualified and that the individuals were only allowed to use PIC-6A instruments.
Two other individuals stated that anyone that completed basic health physics indoctrination and was qualified to enter the controlled access area unescorted was qualified as a self monitor. There was no indication that the licensee has a formal system for training and qualifying personnel to be self-monitors.
Six RWP's, numbers 80-12-341 through'80-12-345, had been issued to cover the entire month of January.
The use of RWP's for extended periods is not in itself an unusual or necessarily improper practice. However, the protective clothing and equipment requirement on these particular RWP's were marked "as required." Neither the'RWP nor the licensee's procedures provided information on the protective clothing and equipment requirements for entering various types of radiologically controlled areas.
Personnel entering the controllei accees area on these RWP's had no formal guidance, thu. the licensee had no positive control over the protective clothing and equipment worn. The special instructions on the RWP's did require that personnel contact Health Physics for entry into High Radiation Areas, Airborne Radioactive Areas or any other areas.
Types of Surveillance Radiation and contamination surveys appeared to be per-formed in accordance with the frequency established by Health Physics supervision.
Sign off sheets were utilized to ensure that routine surveys were completed. Some smears were counted for alpha, particularly during outages.
Selected survey records were reviewed for the year 1980 and through January 25, 1981. The radiation and contamination surveys appeared to adequately represent the radiological status of the facility.
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26 One individual from Plant Services was assigned to Health Physics for routine decontamination in the controlled areas. Additional Plant Services personnel could be assigned to Health Physics for decontamination as needed.
When areas were located that required prompt decontamination the individual assigned to Health Physics was directed to decontaminate the area.
An air sample program had been established and numerous grab samples were taken. The licensee's procedures required that additional air samples be taken on jobs tha' required respiratory protection equipment. Based on the design of the low volume air samples normally used, conversations with licensee personnel and observation, the appraiser noted that some grab samples may not be representative of the breathing zone of workers.
In response a licensee representative stated that the low volume air samplers would be modified to make it easier to obtain breathing zone samples.
With the exception of the Reactor Containment Building, routine grab samples normally consisted of particulate samples plus some gaseous samples. The air sample records for December 1980 and January 1981 and did not indicate that any routine iodine or tritium air samples were taken, except in the Reactor Containment, and in the Spray Building during maintenance.
In evaluating the air sampling proced"res for the Reactor Containment, the appraiser noted that the reading on the Reactor Containment installed continuous particulate and gaseous monitor were used to determine the need for respirators prior to entering the Reactor Containment.
Additional samples were obtained in the Reactor Building when personnel enter d to verify the airborne activities.
The reliability of cata from the Reactor Containment continuous particulate monitor is questionable since there are several 90 bends in the sample line prior to the particulate filter. The appraiser also determined that for short duration Reactor Containment entries (usually less than 30 minutes) only gaseous samples are obtained during the entry. Thus some entries are made into the Reactor Containment without an accurate determination of the particulate, iodine or tritium activities present.
Such practice is not in accord with the requirements of 10 CFR 20.201 and 10 CFR 20.103(a)(3).
Lapel air samplers were on hand but were seldom used, and not in current calibration (calibration was only required prior to use). One reason for the limitad use of lapel J
27 samplers and failure to obtain particulate and iodine samples for short duration Reactor Containment entries was the relative long sample times required by the licensee's procedures.
The appraiser recommended re-evaluation of these procedures to include the use of high volume samplers ir r Jer to perform sampling under these conditions.
The licensee's records indicated that air samples taken for specific jobs are normally allowed to run continuously for several hours in the work area. The samples therefore average the activity over a long period of time which includes periods when work may not have been in progress.
The airborne activity actually generated while work is in progress cannot recjily be determined with this type of sampling.
Records Radiation and contamination surveys were documented on survey forms that contained drawings of the area surveyed.
The original copy of the survey form was routed for review and filing. Duplicate copies of current surveys were kept on clipboards at the Health Physics Control Point. These surveys were readily ava:lable to personnel issuing RWP's.
The survey forms were filed chronologically, by area of the facility. The filing method simplified retrieval and review of the records.
Copies of other records and forms such as air sample results and calibration data were readily accessible and retrievable. With the following three exceptions the " Air Sample Record" contained sufficient information.
1.
The initial and final air flow rate was not recorded; and the units used (cfm or 1pm), were not indicated.
2.
The factor, "7.075E3," used in the formula to determine the total volume sampled when using a High Volume Air Sampler may be in error and should be re-evaluated.
A 1 7/8 inch diameter circle is cut out of the high volume filter for counting. The appraiser measured the active area of the original filter to be approxi-mately 3 7/16 inches in diameter. Accounting for the conversion from cubic feet centimeters and the area of the filter counted the appraiser calculated the factor to be approximately 8.43E3. The filter measurements should be more accurately determined and
28 the factor recalculated.
Tests should also be conducted to verify that cutting out the center of the filter provides a rep'.esentative sample.
The apparent difference in the factor used could result in the licensee's high voltme air activities being approximately 19% low.
3.
The Air Sample Records did not indicate which of the instruments was used to count the air samples. The efficiencies given for counting particulate samples varied significantly depending on the instrument used to count the sample. The efficiencies listed on par-ticulate air samples counted on December 10, 1980 were 21.18%, 51.07%, 19.94%, 27.54% and 47.23%.
Five efficiencies were listed that date and only four scalers are normally available for counting air samples. Without reviewing the daily efficiency checks for all the instruments, it was not possible to determine if the efficiencies were recorded incorrectly or changed during the day. The licensee should compare the information recorded to the recommendations of ANSI N13.1, " Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities."
The isotope and activity used by Health Physics to cal-culate the counter efficiency were recorded on the form provided.
However, neither the records nor procedure indicated if the standard activity listed was the original activity marked on the standard or if the activity was decay corrected.
The appraiser determined that the same sources were not used by all the technicians for performing the daily efficiency chee' on the counter scalers. The January 1981 record of aaily efficiency checks for the NMC counter scaler indicated that a 27,210 dpm Sr-Y source was used to determine the efficiency. The appraiser recorded the counting data for the lowest and highest efficiencies for the month, 1/12/81 and 1/23/81, respectiveb.
The effi-ciencies calculated by the technician on those dates correspond to a standard actvity of 24,202 dpm vs. 27,210 dpm.
The 24,202 dpm corresponds to a different Sr-Y source which was also available for use. The appraiser noted that the procedure should require the same source each day for the daily checks, and the information recorded as recommended in ANSI N13.6, " Practice for Occupational Radiation Exposure Records Systems."
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29 The licensee's " Health Physics Instrumentation Repair Record" form MY-HP-88-75 provided complete information on instruments problems including the nature of the repair.
These records assisted the licensee in reviewing the service history on a particular instrument. The licensee also maintained an " Instrument Calibration Log" form MY-HP-115-80 that listed all portable Health Physics instruments by serial number and calibration due dates.
This form ensured that the specified calibration schedule was followed.
The records being used by Health Physics were generally complete and readily retrievable, but some of the forms need to be revised to contain additional or revised data.
Access Control, Posting and Labeling The normal access point for the controlled access area was through the hallway adjacent to the Health Physics Control Point. When coveralls were required for entry, section 3.8 of the Radiation Protection Manual required removing
" outer clothing and shoes" in the Clean Area Locker Room.
Personnel then proceeded to the Controlled Area Locker and dressed in, " coveralls, cotton gloves, head cover, and shoe covers."
Paragraph 3.8.2 of the Radiation Protection Manual states, "The normal sequence for removing protective clothing is as follows: tape, outer gloves, head cover, coveralls, shoe covers, and inner gloves." It further states, "When a shoe cover is removed place your foot down in the clean area." This was different than the procedure that was observed or the one taught in the Basic Health Physics Indoctrination Training.
In the indoctrination and in the practice the shoe covers were removed before the coveralls.
In fact, personnel did not seem to follow any specific undressing sequence. Some individuals removed their
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gloves before they removed their coveralls or shoe covers.
Most individuals observed removed the shoe covers prior to removing their coveralls. The licensee's procedures and indoctrination do not clearly define the use or removal of protective clothing.
is personnel exited the controlled access area near the Health Physics Control Point they were required to frisk themselves prior to exiting. Two friskers with adjustable alarms, and equipped with thin window, pancake type GM detectors were available for use in a low background area.
Personnel observed during the appraisal frisked themselves properly prior to exiting the controlled access area.
30 Procedure 9.1.8, " Monitoring for Personnel Contamination" states that when personnel are frisking themselves, "If alarm sounds, resurvey area.
If the alarm is repeated to not move from area, notify health physics personnel."
'However, the licensee's procedures did not address the setting of alarm points for the friskers. A licerdee representative stated that when the efficiencies are checked, during the quarterly calibration, the alarm po'nts were set 9r approximately 1,000 dpm which would be E 9 cpm above background. The alarm point for one of the friskers was set at 300 cpm above the background but the other was set for maximum which was 500 cpm. The active area of the detector is 15.5 cm2 which is 6.5 times less 2
than 100 cm. Thus, if 1,000 dpm is detected with the 2
frisker it would correspond to approximately 6,500 dpm/100cm which is also 6.5 times the licensee's limit for a clean area. Assuming a 33% efficiency, a count rate of 50 cpm 2
above background would correspond to 1,000 dpm/100cm.
(Note: When considering transfer factors, 1,000 dpm/100cm 2 smearable would be equivalent to a count rate between 50 cpm and 300 cpm on the frisker. The appraiser noted that the licensee should re-evaluate the method used to set alarm points for friskers.
As mentioned previously, RWP's were required for most entries into the Controlled Access Area. The licensee's procedures need to provide more detailed information for Health Physics personnel that fill out snd issue RWP's.
Additional specific guidance is pi.rticularly needed for determining:
a.
When air samples are required and the specific types required; b.
Which of the various control options for high radia-tion areas should be specified, and; c.
Which of the protective clothing and equipment " Require-ments" listed on the RWP should be specified.
Procedure 9.1.10, " Radiation Work Permits" required that if air sampling was required for a RWP that the activity be recorded on the RWP.
In numerous instances the specified air samples were taken but the results were not recorded on the RWP.
A review of the RWP's indicated that there may be inconsis-tencies in the requirements for air sampling and respiratory protection. Additional procedural guidance for respiratory
31 protection and air sampling based on contamination levels would help ensure better. consistency in RWP requirements.
When questioned by the appraiser several technicians responsible for issuing RWP's had varying opinions on when Health Physics coverage was required, what individuals were qualified as self monitors and when air sampling was required.
Between 12/13/80 and 12/15/80 RWP numbers 80-12-155, 159, 165, 166, 180, 181, 182, 183, and 185 were issued for Reactor Containment Building Entries. The RWP's indicated radiation levels 10 to 6,000 mR/hr and containment levels of 1,000 to 1,000,000 dpm/100cm. All but one of the 2
RWP's required air sampling. One RWP specified "HP Coverage as Required" even though the radiation levels on the RWP indicated 10-6,000 mR/hr. One RWP denoted containment 2
levels of 3,000 to 349,000 dpm/100cm but did not require double anti-clothing.
Possibly these are only apparent inconsistencies and are dua to radiation and containment levels being entered on the RWP for areas beyond the work area.
From the data stated on the RWP it was not possible to determine if this was the case.
For legal as well as protection purposcs the licensee should be capable of showing the protection specified for various areas and jobs based on the radielegical conditions present at the time.
Procedure 9.1.6, " Establishing and Posting Controlled Areas" indicates in paragraph 7.7.1 that the posting requirements included "Up-date the area Radiological Status Board." However, these Status Boards were no longer being used. Thus the radiological data listed on the RWP was one of the primary methods used to make workers aware of radiological conditions in their work area.
If Status Boards are no longer to be used then procedure 9.1.6 needs to be changed and +be licensee needs to ensure that the radiological survey do.
1 the RWP reflects the job site conditions.
The " Maine Yankee Radiation P-otection Manual" stated that smoking was, " permitted only in certain designated areas of the Radiation Controlled Area." Smoking was permitted in the Health Physics Control Point Office, the Controlled Area Locker Room and in the hallway between them.
No signs were posted indicating the boundaries of the smoking area.
It was uncertain to the appraiser and at least one licensee employee if smoking was permitted in the hallway beyond the Health Physics Control Point 'ffice and in the vicinity of the undressing area. A licensee representative
32 stated that smoking was not supposed to be permitted _ past the Health Physics Control Point Office.
Posting should be provided to clearly. indicate the boundaries past which smoking is not permitted and the licensee's procedures and training should clearly indicate these areas.
High radiation areas greater then 1,000 mrem /hr were locked and posted as required by the licensee's Technical Specifications. A "High Radiation Status Check Sheet" form MY-HP-95-78 had been prepared by Health Physics for use when checking the locked high radiation areas four times a week. The form had space provided to indicate whether the area was properly posted as well as the status of locked doors.
Except for keys permanently issued to selected supervisors the keys to these areas were controlled by the Shift Operating Supervisors. The Shift Operating Supervisor logged key issues and inventoried all keys weekly.
The licensee's radiological posting methods were generally adequate with few discrepancies.
Large signs were posted at entrances to areas and on walls at various points in the Controlled Access Area that indicated the general radiation and contamination level in the area.
Hot Spot stickers are used to alert personnel to higher radiation levels in the various areas. When touring the areas it was not apparent which Hot Spot stickers were current and which ones were no longer valid.
Several " Hot Spots" were checked and varied significantly from the dose rate indicated on the sticker. A licensee representative stated that some stickers indicate potential dose rates during outages or other special operations.
Since the use of Hot Spot stickers was one of the primary methods used to alert personnel to higher levels of radia-tion in the facility, the licensee should review the use of the stickers and dev61op methods to ensure the infor-mation provided is current and clearly indicates the radiation levels present.
The methods used by the licensee to label radioactive matettal appeared to be satisfactory.
3.3.2 Ijlstrument Suitability and Use The " Health Physics Facilities and Equipment" section of this report addresses the quantities of instruments normally available for use.
33 Portable Instruments The licensee had a variety of portable survey instruments available. The survey instrument most commonly used for gamma measurements was the Eberline PIC-6A. The licensee used a uranium slab to provide contact beta correction factors for the PIC-6A, Eberline Teletector and Victoreen Panoramic survey meters. The licensee's calibration data indicated that the Panoramic was the only one of the three instruments suitable for beta measurements. The licensee's procedures did nst provide a means for determining beta dose rates except for the contact correction factors just mentioned. Based on the calibration data the licensee should not use the PIC-6A or Teletector for beta measure-ments.
A source was available for checking portable survey instru-ments prior to use. The source was labeled to indicate that instruments should read from 10-30 mR/hr.
Not all of the survey instrument procedures regrired the use of a check source prior to using the instrument and then the procedure did not specify a particular source. The licensee should develop and implement procedures for operational source checks of portable survey instruments that will meet the requirements of paragraph 4.6 of ANSI N323.
Counting Instruments The responsibility for maintenance and operation of counting instruments was divided between Health Physics and Chemistry and are discussed separately.
a.
Health Physics Health Physics had developed and implemented procedures for monthly plateaus and daily efficiency checks for their counter scalers. The problems noted with the daily efficiency checks have been previously reported.
Commercially available check sources prepared by plating activity onto a metal disc were used to determine the counting efficiencies for air particulate filters and smears. These sources did not have the same characteristics as the samples being counted.
The use of sources with characteristics different than the sample to be counted is satisfactory provided the corrections for backscatter, geometry and other variables are known. These corrections were not being used at Maine Yankee.
For comparison a Chemistry air filter standard that had been prepared using an u
34 air filter and Cs-137 was counted on four of the Health Physics counter scalers by licensee personnel at the request of the appraiser.
The apparent activity of the Chemistry standard of 0.027 pCi, varied from this value as -7.4%, 26%, -20.3% and -25%, respectively.
This check would indicate that the licensee needs to re-evaluate the method used to determina counter efficiencies, especially for airborne activities.
This check did not establish that either of the standards used we e accurate (see below).
b.
Chemistry Chemistry had developed and implemented routine calibration and daily quality control checks of their counting equipment. The standards used were traceable to NBS and were prepared in geometries appropriate for the samples being counted. One exception was the alpha particulate standard and possibly the beta air particulate standard.
Both standards are prepared by pipetting a portion of a liquid standard on an untreated air filter.
In such circumstance a portion of the liquid penetrates the filter and is evaporated from the plachet. This causes more self absorption of the radia'. ion than would be encountered on an air sample.
This potential error is very critical for alpha counting.
Chemistry use; a liquid scintillation counter to count tritium samples for Health Physics and Chemistry use.
Routine tri'1um samples included the reactor coolant, stack, airborne grab samples and Turbine Building sump samp'ies. The reactor coolant was the only type of tritium sample that was normally distilled prior to counting. Chemistry did not make e,uench correction for any of the tritium samples counted. A licensee representative stated that quench corrections had been made previously but had been discontinued.
The licensee needs to re-establish a method of providing quench corrections for liquid scintillation samples since chemical or color quenching can severely alter the sample analysis.
Contamination Detection Instruments The licensee utilized AC/DC count rate meters with thin win:me pancake GM detectors for contamination monitoring o' ptrsonnel and equipment.
The licensee's calibration method required that the detectors be labeled to match the a
35 count rate meter serial number. This was required because the detector efficiency was recorded on the count rate meter rather thar the detector.
If a detector became damaged the count rate meter also had to be removed from service until the detector was replaced and the entire system recalibrated.
A portal monitor was installed in the Guard House for use by personnel exiting the facility.
Information was not available to indicate the sensitivity of the portal monitor in relation to the licensee's limits for contamination. A licensee representative did state that a one pCi source would cause the monitor to alarm. The licensee needs to ensure that the portal monitor is set for the minimum practical sensitivity.
Air Sampling Equipment The licensee had two continuous air monitors (CAM) with capabilities for sampling particulates, gas and iodine.
Neither CAM was in operation during the appraisal. One CAM, stored outside the personnel hatch, was for the Reactor Building during outages and the other CAM was assigned to the Technical Support Center for emergency use.
The licensee had high volume air samplers for particulate grab samples and low volume air samplers for particulates and iodine sampling.
The high volume air samplers had three interchangeable orfices, labeled A, B and C that could be used to change the flow rate. The flow meter had three ranges, one for each orfice. Whei the appraiser asked a technician to demonstrate the, ampler he read the C scale on the flow meter as 60 CFM.
Vhen asked how he knew which orfice was installed the technician replied that normally only C orfice was used.
Upon checking it was determined that the A orfice was installed so that the flow rate should have been read as opproximately 16 CFM.
The appraiser noted that licensee raeds to develop a method to ensure tt personnel read _the proper scale when using the high volume air samplers.
The licensee had installed a type of quick disconnect fitting on the low volume air samplers for ease in changing sample heads. However, the fittings used did not provide tight connections.
The appraiser with the assistance of a technician checked the adequacy of the fittings on several samplers by blocking the sample suction and repositioning the sample head.
(Because of the design of the fittings the sample head and piping could normally be rotated into various positions.)
J
36 One sampler that indicated 32 1pm with a filter in place varied from 9 to 22 1pm with the suction blocked and the sample head rotated through its normal positions. All three of the samples checked indicated leakage with the type of fitting used.
Subsequently a licensee repre-sentative stated that they would replace the quick disconnects presently being used.
The method used to obtain gas samples consisted of emptying a scintillation vial-which had previously been filled with water. This allowed a sample of air to replace the water in the vial. The sampla volume was 22 to 26 cc depending on the vial used. The vial was then capped and counted with the Chemistry gamma spectrometer. Chemistry personnel indicated that the minimum detectable activity (MDA) for this type of gas sample was approximately 5 x 10 ' pCi/cc for gross gamma.
Chemistry personnel indicated that if greater than MDA gross gamma was detected with the NaI detector, the sample would be counted longer for isotopic analysis on the GeLi detector. A licensee representative said that it was possible to routinely measure the gaseous activity in the Reactor Building with this method but that less than MDA was normally detected in the Auxiliary Building. The licensee should consider the use of a large volume gas sampling device for areas of lower gaseous concentration such as those in the Auxiliary Building.
The appraiser noted that methods are readily available to measure gaseous concentrations at lower activities.
Procedure 9.218, " Calibration or Air Samples" provides calibration procedures for one type of low volume air sampler, the high volume air samplers and the lapel air samplers. Health Physics calibrates the flow meters for the type of low volume air samplar referenced in procedure 9.218. The Instrument Group calibrates the flow indicating devices for the other type of low volume sampler plus the high volume and lapel samplers.
The Instrument Group had handwritten procedures for calibration of the lapel samplers that was used instead of procedure 9.218.
The Instrument Group used the manufacturer's literature for calibrating the other two types of air samplers. The methods used by Health Physics and the Instrument Group to calibrate the flow devices appeared to be adequate but the procedures need to be formalized and approved to assure consistency.
Calibration Program The licensee used a multi-source gamma calibration device and several smaller sources for instrument calibration. A second, higher range gamma calibration device was avail-able, but was not in use due to decay of the source. Use l
37 of the smaller sources for low range calibration 'ansisted of suspending the source from a ring stand. A meter stick-laying'on the surfr-- below the source was used to position the instruments being calibrated. While this method probably provided a clost approxirnation it did not ensure reproducibility. The calibration data for the' smaller sources was derived from original source data.
Initial or periodic calibration checks w *e not performed to determine the influence of scatter or other factors. The method used to calibrate instruments using the smaller sources did not meet the recommendations of ANSI N323. Other generic problems were noted in the licensee's calibration methods and procedures including:
Many of the procedures, including the installed area radiation monitors, did not require calibration at a sufficient number of points.on each scale as recommended in paragraph 4.2.2 of ANSI N323.
The licensee's procedures did not address orientation of survey instruments during use. The licensee's procedures should address the orientation of the various instruments when used for surveys.
If an instrument is calibrated with the detector orientated, relative to the source, different than the orientation normally used, correction factors mey need to be developed to account for directional dependence of the detector.
In accordance with paragraph 4.3.4 of ANSI N323.)
While jigs for positioning some instruments were l
available for the model 1000 B calibrator, the cali-bration procedures did not specify the jig to be used or method to be used to position each instrument during calibration.
The uniformity of the beam intensity should be verified over the area of the beam that strikes the sensitive volume of each detector.
Variations in beam uniformity may effect the methods used to determine the correct exposure rate for the instruments.
The jigs supplied with the model 1000 B calibrator are designed to fit on adjustable shelving in the calibrator to allow varying the source to detector distance. One individual using the source did not know where the points of reference were for determining i
source to detector distance. This needs to be defined in the procedures.
38 The calibration procedures lacked specific detail and the calibration records'showed that calibration techniques varied with the persons performing the calibrations.
The calibration procedures did not address the use of a specific source for either gamma or beta calibration.
The records indicated that different individuals used different beta and gamma sources.
The calibration procedures did not provide specific information for adjusting instruments during calibra-tion.
In several instances they would refer the user to the technical manual.
The calibration datt sheets did not provide "before" and "after" readings.
In some instances it was not possible to tell from the data sheet which range on the instrument had been calibrated.
The neutron survey instruments _were calibrated using a pulse generator and then checked with a neutron source suspended from a ring stand. The data for the neutron dose equivalent rates were derived from initial calibra-tion of the source in 1971. A better positioning device is needed for the calibration procedure.
Since ten years have elapsed since the initial calibration of the source neutron emission rate, the source emission rate needs to be reverified by a qualified facility.
The licensee had a Victoreen Condenser R-meter that had been calibrated on 7/24/80. The previous calibration had been 8/2/77. The Condenser R-meter was not used routinely in the licensee's calibration program. The ifcensee also had a Victoreen Radacon II. The Radacon II was calibrated annually by the licensee on site such that the calibration could not be considered traceable to NBS.
However, the Radacon II was not used as part of the licensee's cali-bration program.
Conclusion Based on the above findings, improvements in the folluwing areas are_ required to achieve an acceptable program:
The radiation protection manual and procedures need to be revised. The present procedures are general in nature, lack sufficient detail, do not adequately describe the basis for the program and many are
39 outdated.
Some of the specific subjects or areas needing improvement are:
instrument selection and use; survey methodology; instrument calibration; specifying the types of routine air samples (particulate, gaseous, tritium, and iodine as appropriate); the method of performing daily checks for Health Physics counting equipment; establishing the method of setting i
alarm points for friskers; clarify protective clothing requirements to include the use of company issued shoes, undressing sequence and the locations where clothing is to be removed; additional instruction and guidance for persons issuing RWP's, and; a qualification program for self monitors.
Methods for specifying protective clothing and equip-ment requirements for extended RWP's to ensure positive management control in this area are not adequately established.
Methods for ensuring that non plant or non-Health Physics personnel are qualified to issue RWP's also needs to be established.
The licensee needs to ensure v. hat adequate air samples are taken when personnel ente? the Reactor Building even for short duration entries. The practice of relying on the installed monitoring system is not considered adequate unless the licensee can demonstrate that the data obtained from that system accurately reflects the air activity.
The licensee needs to re-evaluate the air sampling program to include: the use of lapel samplers; guidance for sampling when jobs are in progress; the information recorded; conversion factors used; larger volume gas samples; air sampling methodology; equipment suitability, and use of the proper equipment such as orfices when sampling.
In the area of sample counting the licensee needs to:
develop a suitable method of determining efficiencies on the Health Physics counting equipment for smears and air samples; provide a method of correcting for quench for the liquid scintillation counter, and Chemistry needs to develop suitable standards for beta and alpha counting of air particulate filters.
Formal procedures need to be developed and implemented for the flow devices for all of the types of air sampling devices used by the licensee.
40 The calibration program and procedures for portable survey instruments and installed area monitors need to be revised to meet the recommendations of ANSI N323, " Radiation Protection Instrumentation Test and Calibration."
.The licensee needs to formally develop operational source checks for portable survey instruments as recommended in ANSI N323.
In addition, the following matters should be considered for impcovement of the progra.n:
The filing system used by Chemistry should be reviewed and modified as necessary to make information more readily retrievable.
The smoking areas in _the controlled access area need to be clearly defined and marked.
Radiological data, such as survey results, needs to be available to workers in such a manner as to ensure that they can clearly relate it to their job location.
Guidance should be provided on the requirements for air sampling'and respiratory protection equipment based on contamination levels in the work area.
Better control for the use of Hot Spot stickers needs to be implemented.
In addition to the " contact" correction factors for beta measurements, guidance is needed for other beta measure-ments that aren't " contact" readings.
The sensitivity of the portal monitor in relation to the licensee's clean area limits needs to be established.
4.0 Radioactive Waste Management System 4.1 Program Responsibility The Operations Group was responsible for the operation of the radio-active waste systems, associated equipment and for solidication of liquid waste.
Plant Services personnel were responsible for compacting low level dry waste.
The Radiological Controls Supervisor was responsible for storage, scheduling and shipping of radioactive waste. The Chemistry Group had responsibility for analyzing and issuing permits for liquid and gaseous effluent releases. The Operations Day Shift Supervisor and the Technical Assistant were
41 also involved in reviewing the overall waste processing problems, selecting vendors for solidification equipment, volume reduction, additional processing equipment, expanded storage facilities, etc.
It did not appear that any one individual or group was responsible-for overall coordination of radioactive waste management.
A licensee representative stated that a Rad Waste Supervisor position had been tentatively approved but was delayed because the duties for the position-had not been established. The only written responsi-bilities for radioactive waste management that the appraiser could locate were in the job description for the Radiological Controls (RC) Supervisor and a brief section in the Radiation Protection Manual.
In addition to maintaining, " Radioactive Waste Shipping Precedures" the job description stated that the RC Supervisor was responsible for, " Developing and implementing controls, methods, and practices as may be_necessary to insure radioactive waste releases and shipments are maintained within applicable federal, state and local limitations, and as low as reasonably achievable." The Radia-tion Protection Manual states in paragraph 7.2.la. that, "It is the responsibility of the Chemistry Supervisor to:
Insure that analyses are made and records kept of the radioactive content of all reactor plzot effluents to determine that discharges are in compliance with 10 CFR 20 and the provisions of the Technical Specifications."
The responsibility for radioactive waste management needs to be clearly defined and~ documented.
4.2 Waste Processing System The facility had a 25 gpm Boron Recovery Evaporator and a 6 gpm Rad Waste Evaporator. However, the maximum capacity that they had been able to achieve with the Rad Waste Evaporator was 2.5 to 3 gpm. The facility originally had a cement solidification system that consisted primarily of a drum roller for mixing the contents of 55 gallon drums with cement. At the time of the appraisal a UF solidification system had been installed and was used instead of the cement system.
Spent resin was being shipped dewatered.
The State of South Carolina, in a letter dated January 17, 1981 granted Maine Yankee an extension of the January 1, 1981 deadline for meeting the new free-standing water requirements for dewatered resin and solidification radwaste shipments to Barnwell. The extension was effective until June 30, 1981.
There were no records to indicate that operation of the radwaste systems had been reviewed to determine if they met desigr. criteria such as decontamination factors, radionuclide concentrations, capacities, etc. This was probably due to the fractionation of responsibilities for management of the radwaste program.
I m
F 42 The installation of the UF system had been a major addition to the radwaste system. The reviews required by 10 CFR 50.59 had been per-formed and were adequately documented.
The records of tests and analysis for ventilation HEPA' filters and charcoal adsorber systems were not readily available during the appraisal. However, these tests had been previously verified by NRC Inspectors.
Liquids containing oil were being stored on site for decay.
A-commercially available solution was used for deco.tamination and the waste water was treated with an anti-foaming agen. prior to processing with the evaporators.
It appeared that all potential release points for liquids including the Turbine Building Sump, Demineralized Water Storage Tank, Auxiliary Condensate Receivers, etc., were sampled periodically for radioactive concentrations.
The UF solidification system was installed in the Radiologically Controlled Activity (RCA) Storage Area.
The Spent Fuel Cask washdown area was being used for filling the liners. The LSA Box Compactor had also been installed in the RCA Storage Area. The RCA Storage Area was also used for storage of other miscellaneous equipment.
The RCA Storage Area no longer had any space available for storing radioactive waste which was being held for shipment. Several outside areas were used to store containers.of radioactive equipment and waste. Thirteen LSA Boxes, covered with plastic and banded, were stored on the north-west side of the Reactor Building pending ship-ment.
Located in the same general vicinity were three barricaded storage areas. One storage ' area was located between the Reactor Building and the RCA Storage Building.
Concrete clocks had been stacked approximately six feet high to provide an enclosure. A temporary, padlocked plywood gate provided access to the area.
Material stored in that area included 55 gallon drums of miscellaneous material and two liners that were being held indefinitely. The area i
I was exposed to the weather. The 55 gallon drums had water standing l
on the lids and a number of drums showed deterioration from rusting.
A second outside storage area was adjacent to the doors used to l
transfer casks and liners into the RCA Storage Area. The area was enclosed by a wall of stacked concrete blocks approximately eleven feet high. The only outside access to the area was by using ladders to go over the wall.
l
F 43 An underground storage bunker had been constructed for higher activity waste.
It was estimated that the bunker cc'ld hold up to six of the 322 cu. ft. liners being used by the licensee. A licensee representa-tive stated that they had been considering a larger bunker that could store up to 24 liners and another storage area for compacted waste storage. At the time of the appraisal firm commitments had not been made for additional solid waste storage capacity.
Solid waste storage is a recognized problem at Maine Yarkee.
Procedure 9.1.15, " Shipment of Radioactive Material" contains refer-ences to the current burial site criteria,. State of Maine notifica-tions, and other required notifications. However, the procedure did not incorporate current burial site criteria or the means to be used to calculate the activity in containers.
Ensuring compliance with regulations, verifying that the current burial site criteria are met and calculating activities is highly dependent upon the knowledge of the Health Physics supervision. A review of the records indicated that radwaste shipments complied with the regulations.
Because of the increasing quantity of and changes to regulations and burial site criteria the licensee's procedures need to be more detailed to ensure continued compliance. The method used to determine activities in containers of radioactive waste needs to be. formalized and docu-mented.
Check lists were provided in the procedure that covered notifications and many of the regulatory requirements. These check lists required the signatures of Quality Control personnel as well as Health Physics personnel for each shipment.
4.3 Effluent / Process Instrumentation Overall the calibration and management of the effluent / process and area monitors was found to be unsatisfactory. Many of the items had been noted by the licensee and corrective actions were being initiated on some of the items.
The Instrument and Controls Group calibrated the process and area monitors.
Procedure number 3-6.2.1.29, " Source Calibration of the Radiation Monitoring System" included the instructions for calibration of the process and area moni'. ors. Under " Prerequisites", paragraph 5.1 stated, "The initial electronic alignment of the channel has been performed.
It is necessary to realign the electronics unless P.C. Boards or their components are replaced.
It may be necessary to check or perform channel alignment if difficulty is experienced in source calibration, or scaler print out versus RMS meter differ-ences."
When asked about the " initial electronic alignment of the channel" referenced in the procedure a licensee representative stated that it referred to the pre-op or initial acceptance test that was performed
44 when the system was initially installed.
If it was determined that the electronic alignment needed to be checked, the technician would use the manufacturer's technical manual since a procedure did not exist for that check and alignment.
The data for these cheeks were not normally recorded. The calibration procedure consisted r placing a test jig containing a sealed source on each detector, adjusting
.the discriminator voltage to a specified value and then varying the detector high voltage until the desired count rate was indicated on
- a. timer-scaler used for calibration. A second source with a higher activity was then used to check another point on the scale. The acceptable count. rate range was obtained from the original manufac-turer's data, corrected for decay.
The same procedure was used for GM and scintillation detectors. The acceptance criteria for the calibration was that the count rate on the two sources was within + 10*4 of the required counts. The procedure also required the technician to, " Inform I & C Supervisor of any significant differences between time-scaler count rate print out and RMS meter read-out for the process monitors. Refer to the area monitor sensitivity curve to relate timer-scaler CPM read-out to the Mr/hr meter reading." However, the meter reading for the monitor being calibrated was not recorded. Only the count rate for the timer-scaler used for calibration was recorded. The record did not provide information that made it possible to verify that the meter reading for the monitor had been checked or that it was responding correctly.
The calibration program for these monitors needs to be revised. The guidance in ANSI N13.10, " Specification and Performance of On Site Instrumentation for Continuously Monitoring Radioactivity in Effluents" and ANSI N-323, " Radiation Protection Instrumentation Test and Calibration" should be used in revising the calibration procedures.
The area and process monitors had internal and external alarm set points. The external set points could be set by operations. The internal alarm set points were specified by Health Physics and set by the I & C Group. The alarm set points were not controlled by procedure. A memorandum dated January 20, 1981 file number 14.8.2-8,5.0 was attached to the read out panel in the Control Room and stated the internal alarm set points for each monitor. The file copy of the memorandum also contained the basis used to specify the internal set points. The only method of determining the artual setting of the internal alarm point was to have I & C check it.
Operations personnel had no method of verifying the actual internal set points. Through interviews with licensee personnel the appraiser determined that the internal set points listed on the 1/20/81 mero-randum were the set points that the monitors were going to be set to.
Some but not all of the internal set points had been changed by o
F 45 I&C to correspond to the new values. 14o one could readily determine which set points had been changed to the new values and which ones had not been changed.
Conversations with Operations personnel indicated.that they were under the impression that the alarm points given in the 1/20/81 memorandum were the actual internal alarm points.
A. licensee representative stated that the 1/20/81 memorandum-had been generated so I & C would have a document to sign off on that would list the new alarm points. The lack of control of the internal alarm points was apparent.
The licensee needs to develop and implement a procedure to set and periodically verify the value of the internal alarm points.
The 1/20/81 memorandum referenced above listed monitor RI-3101 as the " Reactor Coolant Letdown (Low)." However, the background around the RI-3101 detector had increased to the point that RI-3101 was no longer useful. Area Monitor RI-6111 had been used as the Reactor Coolant Letdown (Low) monitor for over a year (prior to 1/10/80).
The records and alarm point list needs to reflect the monitu s actually used. A licensee representative indicated that they were planning to return RI-3101 to service or relocate that monitor in a lower background area.
A number of problems were also noted with the process particulate and iodine monitors.
It appeared that the stack monitor was orig-inally installed correctly to minimized particulate and iodine losses in the sample lines. However, Engineering Change Request
- 39, documented in a memorandum dated March 22, 1972, file number 14.8.2-10.13-1, MYP55-72 provided for the installation of an air dryer to correct moisture problems in the system. The dryer was installed between the sample point and the particulate filter and iodine adsorber. More recently, as a result of TMI Lessons Learned, emergency monitoring capabilities were also added. These modifica-tions were also made between the stack sample point and installed filter and adsorber media. This modificatior f ntroduced a series of 90 bends in the sample line.
The particulate and iodine process monitor for the Reactor Building had a series of 90 bends between l
the sample point and the filter media.
Paragraph 6.1.20 of Procedure 3.7.1.2, " Gaseous Radioactive Waste Discharges" and paragraph 6.1.25 of Procedure 3.7.1.1, " Liquid Radioactive Waste Discharges" required that Operations enter the applicable process monitor reading on the Radioactive Release Permit.
On permit numbers 454, 493, 530, and 536 dated 1/12/80, 3/8/80, 12/14/80, and 12/29/80 this was not done. Upon further investigation the Appraiser found two memoranda, dated October 13, 1979, and the other April 24, 1980 (both were File Number 14.8.2-19.1) which called Operation's attention to this problem.
46
]
Conclusions Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
The responsibilities for the Radioactive Waste Management Program need to be established and provide for overall coordination of the program.
The licensee's procedures for handling and shipment of radioactive waste should contain additional detail on shipping regulations, burial site criteria and methods used to determine the activity in j
containers.
The calibration procedures for process and area monitors needs to be totally revised and needs to provide for el'ectronic calibration of-each channel. The licensee needs to incorporate methods for con-trolling the use and alarm set points of area and process monitors in their procedures.
The process monitors for particulate and iodine monitoring require review to determine the effect of line losses on the monitor results.
The licensee needs to ensure that the information required on their Radioactive Release Permits is properly recorded.
In addition, the following matters should be considered for improve-ment of the program:
A system should be established to provide for periodic checks of radwate processing systems to compare operational data to design values such as decontamination factors, radionuclide concentration, equipment capabilities, etc.
The records of tests and analysis on HEPA and charcoal absorbers i
need to be more readily available.
5.0 ALARA Program The ALARA program at Maine Yankee is generally described in the station Radiation Protection Manual approved by the Manager of Operations on January 1, 1980.
Section 1.0, " Radiation Exposure Policy" generally identifies the bases on which the "as low as is reasonably achievable" concept is maintained at the station. This document as well as interviews with the Radiological Controls Supervisor and the Radiological Controls Foreman supports the notion that the Maine Yankee ALARA program is pre-7 dominently undefined and not well formalized.
~
e 9
s s
47 While the obvious objective (to reduce personnel and environmental radiation exposures to the lowest levels commensurate with reasonable achievability) is implied; and,' some elements of the ALARA concept are embodied in the radiation protection program, there is no system established that provides specific and detailed criteria for achieving the ALARA objective, nor is there general guidance that sufficiently embodies the concepts and require-ments of ALARA. Additionally, there is no system applied to determine if ALARA is successfully accomplished.
The basic goals offered in the Radiation Protection Manual are that to:
1.
Control each individual's accumulated radiation exposure; 2.
Minimize individual exposure by distributing the exposure among plant personnel as evenly as is practicable; 3.
Maintain exposure to personnel ALARA; and 4.
Maintain exposure to the public and environment ALARA.
From observations, these goals are implemented predominently by control-ling the maximum dose to the individual, and by efforts to evenly dis-l tribute the amount of exposure received by the plant personnel. None of these goals offer any discrete, measurable characteristic that could be used to prove or attest that ALARA results have been achieved.
The capability to establish and implement a successful ALARA program exists with the combined abilities of the Supervisor and Foreman of the-Radiological Controls Section.
Failure to be more aggressive in this area appears to be due primarily to lack of sufficient manpower and time appropriated to this activity rather than any lack of technical skill or understanding of the concepts involved in program development.
Figure 2 depicts the average dose per worker trend since the facility was first licensed in 1972. This indication reveals that the facility has maintained the average dose to workers below the mean of all PWR facili-ties since operation commenced. However, it is also evident from the trend line analysis (the linear least square fit of data points) that Maine Yankee has continued to increase dose per worker, while the average dose to worker for all PWR facilities has decreased.
Figure 2 is derived from information appearing in the latest annual report, Occupational Radiation Exposure a_t Commerical Nuclear Power Reactors-1979, NUREG-0713, Volume 1.
As can be seen the trend lines predicted that Maine Yankee would exceed the average dose to workers for all PWRs in 1980.
Compilation of actual exposure data from 1980 (which will appear in the 1980 annual report, NUREG-0713) indicates the follow-ing:
48 Average Dose To Workers, 1980 All-PWR Facilities' O.52 Rems Maine Yankee 0.63 Rems While the coefficient of determination (r ) does not indicate significant 2
linear. correlation of the data points attributed to Maine Yankee, the trend analysis line did accurately predict within 13% (0.55 Rems predicted versus 0.63 Rems actually reported) the 1980 average dose,to workers.
The power curve described in Figure 2 suggests a better fit.(r 2
.19)
=
but essentially predicts the same linear trend, with a positive slope.
It appears evident that without increased management attention and systematic-use of controls, Maine Yankee will continue in the trend of increased personnel exposure.
Evaluation Based on the above findings, improvements in the following area is required 4
to achieve an acceptable program.
Discrete, measurable goals are not specified sufficiently to permit management to assess the performance of the ALARA program.
Formal management control systems are not established and maintained to monitor, control and measure the success of the licensee's efforts in ALARA.
Adequate personnel resources are not available to provide technical support to establish, maintain and implement an adequate ALARA program.
6.0 Health Physics Facilities and Equipment 6.1 Facilities Overall the licensee's facilities were found to be overcrowded and inadequate. Offices for the Radiological Controls Supervisor, Radiological Controls Foreman, Chemistry Supervisor, and records area are located near the entrance to the controlled areas. The records office was utilized by the Administrative Aide and a Clerk.
This area also houses many of the Health Physics records plus com-puter hardware for a portion of the records system. The licensee is i
planning to expand the computer equipment used for record keeping.
The present space allocated for records personnel, records and i
computer hardware is inadequate. When the new equipment is installed it will compc'<rd the problem.
I
k 49 A break room, respirator test' booth, whole body counter and addi-tional record storage was located across tne hall from.the office area described above. Based on facility drawings this area was originally designed as the First Aid Room.
Space for processing personnel for respiratory fit testing and whole body counting was extremely inadequate, especially during high traffic times such as outages..To further complicate matters a large quantity of records was stored in the area where the whole body counter was located.
A smaller space adjacent to the above area had been converted into a First Aid RAva.
The appraiser did not check the supplies and inven-tory of the First Aia Room to verify their adequacy.
A Clean Locker Room was conveniently located in relation to the controlled area. However, it only contained space for plant personnel.
Additional lockers were located in the Turbine Building hallway outside of the Clean Locker Room by the corridor leading to the controlled area.
-An RCA (Radiological Controlled Area) Locker Room was located across from the Health Physics Control Point Office, just inside the con-trolled access entrance area.
Restrooms, wash areas and six ne-c;nnel decon showers were located in the RCA Locker Room Area. The decon showers were located in a rear corner of the RCA Locker Room such that contaminated persons would have to traverse the locker change area to reach the decon showers. Of the six decon showers, three did not have hot water available and the handles for one shower had been removed. One of the two showers that was operable had a hot water supply, but the shower head was removed and a hose was connected to it.
Thus, only one of the six showers was actually ready for use.
It was determined that the drains for the hand wash fountains in the RCA Locker Room Area and the decon shower drains go to the-facility's sanitary Waste Treatment plant. A licensee representa-tive stated that periodic grab samples from the Waste Treatment Plant were analyzed for radioactive material.
The appraiser noted that procedural guidance is needed on the method for using the decon showers without contaminating the RCA Locker Room. At least two of the decon showers should be a.vailable for use at any time and instructions should be available on how to provide hot water to additional showers if needed.
Procedures for decon-taminating personnel need to include instructions to sample the Waste Treatment System and also to estimate the release of radio-active material via that system when those facilities are used.
The Health Physics Control Point Office was utilized for RWP issue, storage of survey instrumerts, checking of some contaminated items, a work area and counting was done on the two GM counter scalers located in the area. An adjoining room was utilized as a counting
50 room and storage room for supplies and equipment. The counting.
equipment being used in this area included two GM counter / scalers and a gas flow counter scaler with an automatic sample changer. The Health Physics Control Point.0ffice provided sufficient space for handling RWP's and storage of some instruments for use.
- However, there was not sufficient space to accommodate the number of tech-nicians that normally staff the plant nor the additional technicians.
needed for outages. Sufficient work space for technicians for routine and outage conditions is one of the items addressed in Regulatory Guide 8.8.
The adjoining room provided minimal space for counting equipment and associated supplies. Space for other supplies was limited to working level quantities of selected items. A pass through.was provided between the Health Physics counting area and the Chemistry counting area.
Additional computer hardware and two GeLi detectors were located in the Health Physics counting area near the pass through.
This equip-ment plus an alpha spectroscopy system had recently been purchased but were not operational during the appraisal. A determination had not been made regarding the location or responsibility for the new counting' systems.
There was_no. adequate space in either the Health Physics area or the Chemistry area for the new equipment.
It was readily apparent that additional space was needed.
A room adjacent to the Health Physics Control Point was being utilized for a calibration room, source storage, instrument storage, storage of some miscellaneous contaminated equipment plus other items.
According to the floor plans this room was orginally designed as
" linen" storage.
(There was no space available for bulk storage of clean anti-c clothing at the time of the appraisal.
Clean anti-c clothing was kept in drums and stored in various parts of the Primary Auxiliary Building.) Because of source and equipment storage in-the calibration room the background intr-ferred with calibration of low.
range instruments. The space in th s room was not sufficient for the activities being conducted there.
Sources should not be stored in a calibration area. As discussed under " Surveillance" the cali-bration facility was inadequate.
The licensee did not have an onsite laundry facility. Anti-contamination clothing was shipped offsite to a commercial contaminated laundry facility.
An Equipment Decontamination Room was located adjacent to the RCA Machine Shop. A larger set of doors opened up to the outside for accessing larger equipment. The only decontamination equipment in the room consisted of two deep sinks. The licensee needs to investigate the possibility of adc,tional decontamination equipment for use in this area and possible modification or expansion of the present facility to handle larger equipment.
-51 The Chemistry complex contained a small room for. lower level samples, a chemistry laboratory and a counting room / office area. The smaller room for. lower level samples contained an alpha / beta counting system and-other equipment..This area had sufficient' space fu the work.
beingdone there but any: additional. equipment would over burden ~ the a ro. The Chemistry laboratory was used for radicchemistry, secondary chemistry, oil analysis, records storage,'etc. With the addition of test equipment over the years, including oil testing apparatus, the counter tops afforded very little working space.
Lead bricks stacked on.a counter top and other temporar lead shielding in a corner of-l the room were used for both.long and short term storage of-radio-i active samples..These caused the general area radiation levels to be 3-to 4 mR/hr in parts of the lab. The licensee did not have a suitable storage area for higher activity samples. The file cabinets for chemistry records.were also located in the chemistry lab.
Licensee representatives did not know if air flow measurements had been made on these hoods. One'of the-inside panels.was missing on-one of the hoods which could effect air flow in'the hood. Both hoods were equipped with red "on" indicator lights but the "on" lights were not working. An atomic absorption unit at the end.of the lab was also vented. There was no local indication for this system to verify that that ventilation system was on.
Several licensee representatives, when asked, were not sure where these systems discharged to; if the exhaust was filtered, or; if the filter was periodically checked. An individual from operations checked the plant drawings to determine where the vent hoods-discharged to filter assembly #7.
This ventilation unit has a prefilter (FL-19) and an high efficiency filter (FL-18). The atomic absorption unit-l exhaust went to filter assembly #8.
It also had a prefilter'(FL-56) and high efficiency filter (FL-57)..Neither unit had charcoal filters for iodine collection. Upon checking the filter banks the appraiser found labels in each indicating that they had been D0P tested in-1972. Two of the DP gauges indicated that they were cali-brated in 1972 and the other two did not'have calibration stickers.
Three of the gauges indicated a DP greater than the marker setting and the fourth was off scale high. Apparently neither the filters, gauges, nor flows were periodically checked for these systems.
The Chemistry Counting Rocm, in addition to housing counting equip-ment, doubled as an office space for three chemists.
Equipment in the Counting Room included two computer based multichannel Analyzer systems, two GeLi detectors (15% and 29%), two NaI detectors, a gas flow proportional counter and a liquid scintillation counter. The Counting Room did not contain sufficient space for counting equipment and office space. The atmosphere created by the crowded conditions did not provide a good working environment. One of the multichannels is to be taken out of service and replaced with a new system that was located in the Health Physics area. The procurement of additional counting equipment was also under consideration.
However space was not readily available for additional equipment.
G2' 6.2 Protective Equipment' An inventory supplied by a' licensee representativeLindicated the following quantities of protective clothing.
Item Total Quantity Coveralls 3,000 pair Labcoats 300 Hoods 2,000 Hoods 2,000 Caps 1,000 Rubber Gloves 2,000 pair Cotton Gloves 5,000-10,000 pair Rubbers 1,000 pair These quantities might be sufficient for facilities with an onsite laundry. However, Maine Yankee ships all clothing off site to 'a commercial laundry facility.
Discussion with licensee personnel indicated that they had experienced laundry shortages.
The licensee needs to re-evaluate their protective clothing inventory and assure sufficient quantities are available for routine and outage usage.
The licensee also needs to ensure the availability of sufficient quantities of protective clothing for use under emergency conditions.
Storage area for protective clothing is also needed.
The licensee does not normally use containment tents for contamination control. When making entries ~into the primary side of a Steam Generator ventilation was connected to maintain a negative pressure in the Steam Generator. To date that method has proven satisfactory.
The licensee did have. material on hand to construct containment-enclosures if needed.
bree portable air filtration units were available. The licensee appeared to have sufficient working inven-tories of temporary shielding material, poly sleeving, canvas, bags and other supplies on hand.
The licensee had 28 survey instruments of various types on inventory that had upper ranges of 500 R/hr to 1,000 R/hr.
Fourteen of these instruments were shown as out of service and four were in Emergency.
Kits which left a total of ten higher range instruments in service.
.The licensee's inventory also included nine lower range survey instruments of various types. Of this quantity, one was out of service and four were in Emergency Kits which left only four avail-able for use.
In addition, the licensee had seven portable area monitors (five in service), one high range underwater survey instru-ment, one scintillation type alpha survey meter, one neutron rem meger, one beta survey meter,19 count rate meters (14 in service),
and two continuous air monitors (one available for use). One Portal Monitor was available and in use.
The abnormally high number of out
53
'of service higher range survey instruments was primarily due to a common defective component. The components failed on.a group of recently purchased instruments. The manufacturer had agreed to provide replacement parts when they were:available.
The adequacy of the portal monitor sensitivity was questionable. During the appraisal time delay was not used with the portal monitor. Personnel walked through the monitor without pausing.
If the sensitivity is deter-mined to be inadequate the use of a time delay for personnel passing through the monitor may help-increase the. sensitivity.
In that-event, ~ additional portal monitor (s) may need to' be considered for processing personnel.out of the plant.during high traffic times.
The licensee should consider the use of a hand and foot counter and a portal monitor at the exit from the controlled area in addition :o friskers.
Conclusion Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Improved and/or larger facilities are needed for: Health Physics office and work space;. instrument calibration; record storage and work area; respiratory fitting area; whole body counting; instru-ment, equipment and supply storage; laundry storage, Health Physics Counting Room; Chemistry Counting Room; Chemistry laboratory work area, and; Chemistry sample. storage.
Additionally, the following improvements should be considered:
The "on" indicator lights on the chemistry vent hood need to be replaced or repaired.
Periodic air flow measurements should be made of the vent hoods and atomic absorption exhaust.
The licensee needs to develop controls to ensure the exhaust equipment and filters for the chemistry vent hoods and atomic absorption exhausts are periodically checked for proper operation.
The licensee needs to have more than one neutron rem counter on hand.
In addition, the following matters should be considered for improve-ment of the program:
Develop procedures for, and train personnel in the use of the personnel decontamination shower area to prevent spread of decontamination.
The procedures also need to include provisions for sampling the Waste Treatment Facility and determining the amount of activity released during personnel decontamination.
At least two decontamination showers should be available for use uat all times.
Information to indicate how hot water can be provided to the other decontamination showers should be made available.
54 The-licensee needs to investigate the procurement of decontamination equipment for the Decon Room plus possible modifications to the room itself.
The area around the personnel equipment hatch needs to be cleaned up-and kept free of materials and equipment.
The inventory of protective clothing should be reviewed and increased'
-as necessary to ensure against shortages due to outages or delays at the commercial laundry facility. The licensee also needs to be sure that sufficient quantities of protective clothing can be made available in the evelt of an emergency.
Continuous air monitors should be considered for routine use in~the air sampling program.
The licensee should consider using a hand and foot counter (s) and possibly additional portal monitor (s) in addition to friskers.
7.0 Emergency Planning and Preparation 7.1 Administration of Emergency Planning The Radiological Controls Supervisor of the Maine Yankee site is informally assigned the overall responsibility for the Emergency Plan and Implementation Procedures and reports directly to the Plant Manager. Assistance is provided by the Health Physics Foreman. The emergency preparedness assignment is one of his five major areas of responsibility. As a result, the individual devotes a maximum of fifteen percent of his time to emergency planning functions.
The Director of Licensing at Maine Yankee Headquarters acts as the corporate counterpart to the Radiological Controls Supervisor in matters involving emergency preparedness.
He provides managerial and technical expertise and is' responsible for writing the Emergency Plan and Implementation Procedures. The members of the Radiological Controls Department as well as individuals in the corporate headquarters have been mainly involved in the upgrading of the Emergency Plan to comply with upgraded NRC guidelines and requirements.
Although the elements required for a satisfactory alministration of emergency planning are generally present, discrepancies found during the Health Physics Appraisal indicated a lack of a unified management approach. The diversity of the functions assigned to the Radiological i
Controls Supervisor and his further delegation of emergency planning responsibilities to others, appeared to have lowered the readiness posture.
1 l
l
55-d Based on the.above findings, this portion of the licensee's program appears.to be acceptable, but.the following area should.be considered i
for' improvement:
Assign a specific individual responsibility for'the coordination, i
review, and follow-un cf all emergency' planning and preparedness functions.
8.0 Emergency Organization i
8.1 Onsite Organization I
The auditor reviewed the licensee's' Emergency Plan and Implementation Procedures and held discussions with licensee personnel to evaluate the adequacy of the description of the onsite emergency organization, including assignment of emergency du'.ies and responsibilities.
Functional Area of Emergency Activity Personnel Assigned Director'of Site Emergency Operations Plant Manager Assistant Plant Manager 1-
. Technical Assistant Administrative Department Head Manager, Control Room Operations Shift Supervisor Operations Department Head Manager, Onsite Technical Support Technical-Support Department Head Manager, Radiological Consequence Radiological Controls Asse. ment Supervisor-Health Physics Foremen Chemistry Supervisor Nuclear Safety Advicor Manager, External Communications Public Affairs
' Training Department Personnel Manager, Onsite Resources Selected Department Supervisors Manager, Security Security Supervisors 4
In the event of an emergency during regular working hours, the Plant Manager. assumes the Emergency Coordinator position and directs all onsite emergency activities. During backshifts, the Shift-Supervisor assumes the position until relieved. Once relieved, he reports to~
the Manager, Control Room Operations as a Shift Supervisor..Thus, there are provisions for an onsite Emergency Coordinator at all a
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Such individuals had been qualified through appropriate training and did have the authority and responsibility, as reflected in the Emergency Implementation Procedures, to initiate any emergency actions within the provisions of the Emergency Plan, including the exchange of information with authorities responsible for coordinating offsite emergency measures.
The line of succession for energency management was specified in the Emergency Plan. At the time of the appraisal there were seven individuals qualified to assume the role of Emergency Coordinator in addition to the Shift Supervisors. The line of succession for the Emergency Coordinator included the Plant Manager, Radiological Control Supervisor, Technical Assistant, Assistant Plant Manager /
Technical Support Department Head, Administrative Departmect Head, Operations Department Head, and Chemistry Supervisor.
The structure of the emergency organization was generally well defined and the chain of command clearly established.
The total organization was not, however, described to the working level, and the relationships and interfacing between normal and emergency duties and organization were not specified.
The licensee's site Emergency Plan and Imp.ementation Procedurer specified authorities, responsibilities and assignment of persons in the following areas:
Plant Systems Operations Radiological Environmental Survey and Monitoring First Aid Search and Rescue Plant Security and Site Access Control Personnel Accountability Communications Personnel Decontamination Repair / Corrective Actions Personnel Monitoring and Radiation Protection The licensee's Emergency Plan and Implementing Procedures failed to address the following areas during emergency conditions:
Recordkeeping and Retention Plant Chemistry and Radiochemistry The variety and complexity of the different responsibilities and functions and the broad span of control of the Radiological Control Supervisor appear to be excessive with the limited amount of personnel resources allocated.
This situation could reduce his overall effective-ness forcing him to neglect one or more areas of emergency response.
~
l-e 57 Based on the~above findings,.Inis portion of.the. licensee's program appears to be' acceptable but the following area should be considered for improvement:
Clarify,.using' accepted management principles, the emergency.
organization.
' 9.0 Emergency Training / Retraining The licensee's~ program for training employees who are-assigned specific-duties during emergencies is described in Procedure No. 2.50.14 of.the Emergency Plan Implementing Procedures.
Initial and annual refresher training is required.
4 The auditor reviewed documents and records-related to training and held discussions with the site's Training Director, instructors and persons e
assigned to various. functional areas of emergency respense.
Training sessions and attendance were documented.
The inspector compared training records with individuals listed on the Emergency Call List and all but four of the listed personnel had been trained within the last twelve month period. Nine of the designated thirteen Emergency Coordinators-received training during the last quarter of 1980. 'AllLof the thirteen ~
personnel authorized to administer First-Aid received ^-aining in November 1980. Nine personnel assigned to Radiological' Accident Assessment received i
training during the last six months of 1980. Training was documented by the date of training and a roster of attendees.
In the Emergency Plan Implementing Procedures, training was broken down into five categories:
Emergency Coordinator Training, Emergency Assistance 1
Personnel Training, Emergenc! Plan Briefing, First Aid Training, and Off-Site Support Personnel (Fire and Medical).
The first catcgory (Emergency Coordinator) was given to selected members of the Plant staff who hold a senior reactor operators license and to members who are otherwise technically qualified to act as the Emergency Coordinator. The training included emergency plan. procedures, duties of the Emergency Coordinator, and use of meteorlogical~ overlays.
4 The Emergency Assistance Personnel training was given to selected Plant-I-
staff to make-up a pool of trained individuals capable of coping with plant emergencies. The training included plant emergency procedures, health physics portable instrumentation, air sampling and counting, use of dedicated emergency. kits, and use of. communications equipment.
i An. Emergency plan Briefing was given to all personnel who.had no specific duties to perform during plant emergencies.
Training described what dutte are required and will be performed in the event of a plant emergency.
e 4
58 First Aid training was given to selected members of the piant staff. The minimum qualification for First Aid training was the satisfactory completion of e standard 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, Red Cross First Aid personnel safety program.
Tra ning films and refresher courses were utilized to maintain qualification.
Off-Site Support Personnel (Fire and Medical) consisted of the Wiscasset, Maine Fire Department-(volunteer) and the Bath Memorial Hospital, both of which' receive training annually. Training included. lectures and-films on fire or medical emergencies, familiarization tours of the facility, and health physics instruction.
There were no provisions to evaluate the ability of each individual to perform their emergency duties once the training had been completed.
Training objectives were not clearly stated, including the conditions, tasks and standards of performance that would apply in making an evaluation and a determination that a particular individual was qualified to perform the assigned emergency function.
There were no provisions to train members of the emergency organization in changes to procedures and equipment which occurred in the period between the scheduled training / retraining sessions.
Based on the above findings, this portion of the licensee's program appears to be acceptable but the following areas should be considered for improvement:
Develop function specific lesson plans which address each of the emergency functions.
Develop a means for evaluating the ability of each individual to perform his/her assigned emergency duties through the use of training objectives which state conditions, tasks and standards of performance for qualifying personnel in their assigned emergency functions and against which post-training performance is evaluated.
10.0 Emergency Facilities and Equipment 10.1 Emergency Kits and Emergency Survey Instrumentation The licensee had pre positioned emergency supplies and survey instrumen-tation at various specified locations throughout the facility.
Emergency kits and equipment were found to be located as specified in the Emergency Plan Implementing Procedures.
Implementing Procedure No. 2.50.6, " Emergency Equipment Readiness Check", provided a listing of equipment to be found in each of the specified locations and established a frequency for inspcction. The inspector reviewed inventory records and performed independent inventories to verify that equipment stocks were as stated in the Implementing Procedures.
t 59
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Equipment to be used by teams re-entering the facility, or portions thereof, included provisions for extremity monitoring as well as for the detection and measurementLof radiation fields up to 1,000 R/hr.
The licensee had the capability to detect and measure radioiodine concentrations in air'with a sensitivity of at least 5 x 10'.uCi/cc
-for gross beta gamma determinations..The counting instrument used is the Eberline SAM II-with RD-22 detector. The licensee presently uses charcoal cartridges as the air sampling collection medium but had silver-loaded silica gel cartridges on order. The auditor noted that this instrument was stored and maintained in an operational condition in the Emergency Coordination Center with lead brick shielding around the probe.
The licensee had an on-site capability for refilling Self Contained Breathing Apparatus (SCBA) utilizing two compressors rated at 20 CFM with filtered air, located in the turbine building.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
10.2 Fixed Facilities and Instrumentation for Radiological Accident Assessment 10.2.1 Area and Process Radiation Monitors The auditor inspected readouts of area and process monitors located in the control "oom and noted that all monitors were available and operable. Monitors were determined to have sufficient operating characteristics to assess tie accident conditions for which the Emergency Plan was designed to' cope.
The licenoee had installed a high-range stack monitor to measure both gaseous and particulate effluent emissions.
Based on the above findings, this portion of the-licensee's program appears to be acceptable.
10.2.2 Meteorological Instrumentation The-licensee's meteorological instrumentation consisted of wind speed, wind direction and temperature indicators.
The units were located on a 200 foot meteorological tower and measurements were recorded from the 33 and 196 foot levels.
In addition, th, uapability existed to obtain the temperature difference (aij from the two elevations.
L
-60 Meteorological readouts'were located in the Control Room.
The; licensee had provisions'for vital or. redundant power.
- Provisions were made, in the event of power loss, for obtaining representative, real-time meteorological-informa-
. tion through the Wiscasset Airport, National Weather Service at Portland Airport, and the Brunswick Naval Air.
Station weather service. The auditor noted that existing dose' assessment' procedures made no reference to this.
backup provision. Meteorological instruments were on a continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> day analog recording device. Calibration and operability checks appeared to be adequate.
Inoperable instrumentation is promptly ret tered, 'as indicated by the licensee's operability and maiatenance reco-ds.
B m d on the above findings, this portion of the licensee's am appears to be acceptable.
10.3 Emergency Communications Equipment The licensee's' emergency communications equipment was configured and located as-specified in the Emercency Plan and. Implementing Procedures.
The licensee used a high pitched electronic alarm to indicate a radiological emergency and/or the need for evacuation of personnel, and the public address' system in_tha a a.s of fire.
The licensee did not have different alarms to indicate distinct events. The licensee had provisions for routinely checking the operability of-the site emergency alarm.
Communications links had backups. The site EOC had dedicated telephone lines to various key offsite_ agencies (State, local, and NRC) and regular telephone lines were available in the EOC.
Backup communica-tions links consisted of State Police and Wiscasset Police radios, microwave to corporate headquarters, telephones, and Gaitronics plant rsging system.
The auditor concluded that onsite and offsite communications appeared to be adequate to support the performance of vital functions in transmitting and receiving information throughout the course of an emergency.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
61 10.4 Emergency Operating Center The licensee had a principal Emergency Operation Center (EOC)'from which the direction, evaluation and coordination of all activities related to the emergency would be performed. The principal E0C was located in the.Information Center.
The Alternate EOC (AEOC) was located at Eaton House approximately 2,000 feet from the reactor.
The location of both EOCs appeared to be-adequate.
Both the E0C and AE0C had the equipment and supplies required to perform their missiun, including:
low and ~11gh range beta gamma survey meters;. air samplers with capability for particulate and radiciodine sampling; personnel. dosimetry devices; check sources; copies of-the site emergency plan and implementing procedures; State and.lo:al emergency plans and implementing procedures; site map (ll50S 7 1/2 minute map marked with cardinal polar coordinates and 22 1/2 degree sectors, with the first sector splitting North and covering W olume response emergency planni.ng zone); applicable sections of the FSAR and Environmental Report; isopleths; survey forms, to include some plant layouts; writing materials and note pads; a clock; and communications devices (e.g, telephones, portable trans--
ceivers,etc.).
Neither the EOC nor AEOC however, had emergency power or readouts of the station meteo, fio3y.
Based on the above findings, this portion of the licensee's pregram appears to be acceptabie, but the following areas should be considered for improvement:
Prov'+ emergency power for the EOC and AEOC.
Provision for readout of the Station Meteorology in the EOC and 3
AEOC.
10.5 Medical Treatment Facilities The licensee maintained onsite provisions -and facilities for the treatment of individuals who may be injured or contaminated. The first aid station was located on the first floor of-the service building which is normally staffed by a nurse during the day shift.
The facility was easily accessible to a stretcher being carried by two individuals and was equipped with first aid equipment and supplies.
A calibrated low range beta / gamma personnel contamination survey instrument was readily available. The facility was equipped to handle only minor injuries. More extensive treatment would be provided at the Rath Memorial Hospital. Decontamination would be performed usiro Implementing Procedure No. 9.1.9, " Personnel Decontam-ination Procedure", dated December 11, 1978. The procedure uses flushing with soap and water as the main decontaminant.
62 The nurse stated that if-an injured patient is not ambulatory, the First Aid personnel go to the patient ad determine whether to administer first aid or to forward the patient to the hospital.
If decontamination is required, it would be performed with the assistance of Health Physics Technicians at the Health Physics Control Point.
but only in the case of minor injuries.
For serious injuries, sae patient'would be transported and decontaminated and treated by the Maine Yankee Medical Director.
If the patient is ambulatory, he/she would be taken to the First Aid Station after showering and being decontaminated at the Health Physics Control Point located on the first floor af the Service Building.
There is a' telephone in the facility and a plant page in the adjoining room.
Based on the above findings, this portion of the licensee's p-' gram appears to be acceptable.
10.6 Decontamination Facilities There were provisions for personnel decontamination.
The decontamina-tion area was located on the first floor of the Service Building in close proximity to the Health Physics Conrol point and First Aid Station.
Liquid waste resulting from decontamination goes through normal sewer lines to an onsite sewerage treatment facility where solid waste is recovered and disposed of in a normal manner.
Facilities for personnel decontamination at the assembly / reassembly area were not available.
Bas.ed on the above findings, this portion of the licensee's program appears to be acceptable, but the following area should be considered for improvement:
The assembly / reassembly area have available adequate facilities and equipment for personnel decontamination.
-10.7 Protective Facilities and Equipment The Information Center was designated as the assembly area. All office personnel, visitors, contractors and non-essential plant personnel assemble in the Information Center and await instructions.
The above assembly area appeared to have sufficient space to accomodate the numbers of personnel expected,'but did not have adequate respiratory protection equipment and protective clothing.
Based on the above findings, this portion of the licensee's program appears to be acceptaole.
63
.10.8 Damage Control / Corrective Action and Maintenance Equipment Supplies The licensee did not maintain reserves of equipment for damage control, corrective actions, and/or emergency maintenance of equipment.-
Rather, the Emergency Plan relied upon the availability of routine stocks of instrumentation and equipment. This aspect is not addressed the licensee in their current planning effort.
-Based on the above findings, this portion of thi licensee's program
. appears to be acceptable, but the following matter should be considered for improvement:
Provisions for emergency maintenance equipment.
10.9 Reserve Emergency Supplies The licensea relied upon normal station inventory of supplies to support a majority of their emergency response activities.
In some cases, the licensee relied on corporate support and other Yankee System plants for additional emergency-survey instrumentation.
There were minimum stock levels established for expendables, such as protective clothing, polybags, etc., to ensure'their availability.
The licensee appeared to have maintained stock levels to ensure.
their availability. The licensee also appeared to be maintaining-adequate reserves of normal supplies to handle emergency situations.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
10.10 Expanded Support Facilities The auditor and licensee representatives discussed the work facilities required for the increase of personnel expected during emergencies.
This aspect was not addressed in the current planning effort and should be considered for improvement.
11.0 Emergency Implementing Procedures 11.1 General Content and Format The general content anJ format of the licensee's procedures for implementing the Emergency Plan were evaluated to determine general useability. At the time of the appraisal, the licensee had one Emergency Plan and twenty-one Implementing Procedures. Subsequent to, and as a result of the appraisal, the licensee added two new Implementing Procedures.
1
64 The licensee's procedures generally specified the individual and organizational elements having the authority and responsibility for performing tasks covered by the implementing procedures. Action steps were generally displayed in a sequential manner.
Implementing procedure steps which required other functions to be performed did not, however, always contain references to the interfacing implementing procedure. While implementing procedures generally. indicated when the user was expected to perform certain actions, they did not provide specific criteria in the form of quantities, levels, etc.,
when this was possible. There were sign off sheets, check lists and data sheets to document the actions taken.
Based on the above findings, this portion of the licensee's program l
appears to be acceptable, but the following area should be considered for improvement:
Procedural cross references should be more specific / clarified.
11.2 Emergency Operating Procedures The auditors reviewed a sampling of the licensee's Emergency Operating Procedures developed pursuant to Regulatory Guide 1.33 and noted that they contained a step in the immediate action section which required evaluation of the emergency conditions relative-to emergency action levels contained in the Emergency Plan and Implementing Instructions as well as instructions fcr classifying the situation and implementing the appropriate implementing instruction.
Based on the above findings. this portion of the licensee's program appears to be acceptable.
11.3 Implementing Instructions The licensee had a separate procedure for each class of emergency specified in the Emergency Plan. The classification system represented in these implementing procedures was graded.
Each implementing procedure specified the Emergency Action Levels (EALs) to be considered in implementing a response to each class of emergency. Generally, the Emergency Action Levels were based on installed Control Room instrumentation.
The Implementing Instructions were written to orchestrate the implementation of other more specific implementation procedures which had been developed to support the implementation of the Emergency Plan.
The auditor held discussions with variou: licensee representatives in the operations group (e.g. Shift Supervisors), thise individuals were well-versed and knowledgeable in their assigned duties.
65' Implementing Procecares were written from the: viewpoint of and for use by the Plant Emergency-Director. His duties, responsibilities and actions were clearly specified therein.
Based on the above findings, this portion of the plan' appears to be acceptable.
11.4 Implementing Procedures 11.4.1 Notifications The sequence of notifications to alert or mobilize the onsite emergency organization and_ supporting agencies was.
specified for each class of emergency.
Important notifica-tions that would be immediate in nature were incorporated into the "immediate action steps" of the implementing procedures.
The licensee utilized pre planned messages, announcements and alarms for initial notifications. The content and form of these notifications and a listing of persons and agencies to be notified were included in the relevant procedures. The means to be used to make notifica-tions were specified-and where telephone numbers would be r.. quired, they were specified. The auditor noted, however, t1at there was no authentication scheme for initial notifica-tion to offsite authorities.
Based on the above findings this portion of the licensee's program appears to be acceptable, but the following area should be considered for improvement:
Development of a means for authenticating initial notification to offsite agencies.
11.4.2 Offsite Radiological Surveys The methods and equipment to be used to perform emergency offsite radiological surveys were specified'in the implemen-ting procedures-governing the activities of the offsite radiological survey teams (Procedure No. 2.50.12).
The auditor noted, however, that the licensee had no specific pre planned survey points or routes.
The implementing procedure for offsite radiological surveys for airborne radioactive materials had provisions for recording the location, time, date, instruments used (by type / serial number), mode of instrument use, duration of l
sample counts and background radiation levels. ' Instructions were provided to ensure that each sample would be uniquely labeled for later identification and ie-analysis.
66 The auditor noted that there were no provisions to take whole body radiation measurements as part of response or any means to prevent'over-estimation of airborne radioiodine using an illegible log chart, Figure 2 of Implementing Procedure No. 2.50.12 as well as. log charts to Implementing Procedure No. 2.50.16.
The licensee had specified in a general way the means by which sample data would be provided to the organizational element responsible for emergency assessment functions.
The site Emergency Operations Center was designed as the central data collection point.
There was no central collection point designated for environmental samples collected by the offsite survey teams. Team communications and backup means were described in the procedures, but provisions for transportation were unclear although five company vehicles were available to support offsite monitoring operations.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following areas should be considered for improvement:
A means to measure whole body radiation offsite as part of the response.
Description of the means of transportation for offsite radiation monitoring teams.
11.4.3 Onsite (out-of plant) Radiological Surveys The auditor noted that provisions for onsite (out-of plant) radiological surveys were partially addressed in Implementing Procedure No. 2.50.11, " Entry and Recovery".
The stated purpose of the implementing procedure was to " establish a re-entry and recovery plan following a radiation emergency".
There was no other implementing procedure addressing onsite (out-of plant) surveys necessary to assess the radiological consequences and to provide further data for the evaluation of plant conditions. The aforementioned implementing procedure (2.50.11) did not provide guidance for personnel selection, hazards which may be encountered, how the surveys were to be conducted, which locations around or within the buildings should be surveyed or the type of surveys to be performed (e.g., airborne, direct radiation, contamination).
Further, the implementing procedure did not address when these surveys would take place, that is, whether they would be needed to contribute to the assessment of plant conditions, or to be performed after the plant has been evacuated and the situation is under control.
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67 Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Develop implementing procedures which describe the rationale, methods and equipment for onsite (out-of plant) radiological surveys.
11.4.4 Inplant Radiological Surveys The auditor noted that the licensee had a specific emergency implementing procedure for the performance of inplant radiological surveys (2.50.7). However, the Emergency Survey Forms found in the Emergency Kits during the audit showing designated survey routes was not part of the implementing procedure.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following area should be considered for improvement:
Incorporate existing inplant survey route forms in the Emergency Plan Implementing Procedure.
11.4.5 Personnel Monitoring and Decontamination The licensee had no specific personnel monitoring and decontamination procedure, but relied on the " Maine Yankee Radiation Protection Manual" dated January 1,1980 and Implementing Procedere No. 9.1.9, " Personnel Decontamination Procedure". Both the manual and procedure made no reference to the Emergency Plan Implementing Procedures, and in turn was not referenced by them. The approach appeared to be of a general, "ad hoc" nature. The implementing procedure did not clearly specify the provisions for monitoring all individuals in pre-determined emergency assembly areas (e.g., Information Center, Emergency Control Center, etc.,) sejregating those found to be contaminated or performing decontamination.
The existing implementing procedure (9.1.9) did provide a means for recording the names of individuals surveyed, the extent of any contamination found, the instrument used, and results of any decontamination efforts.
The contamination levels that will require decontamination were not defined in the implementing procedure.
There were no guidelines relating specific contamination levels to distinct procedures and there was no discussion of skin contamination with radiciodine. A general step
68 decontamination technique was described. Decontamination chemicals are provided and Health Physics personnel will supervise decontamination. The Maine Yankee Medical Director would, depending'upon the severity, decontaminate wounds.
Based on the' above findings, this. portion of the licensee's
_ program. appears to be' acceptable, but the following areas should be considered for improvement:
Integration of a personnel decontamination procedure into the Emergency Plan Implementing Procedures, defining its applicability in're'ation to personnel decontamination in/or leaving emergency assembly or control areas during emergency conditions.
Clarification of organizational responsibilities for decontamination during emergencies.
11.4.6 Evacuation of Onsite Areas The. classification of'an emergency as a Local, Site, or General Emergency, results in the sounding of an emergency alarm and an announcement on the plant paging system.
In this manner, the evacuation of personnel to the assembly area depends upon operational parameters and EALs used to classify the emergency. During a tour of the licensee's.
facility, the auditor noted that evacuation routes were-not marked.
The. licensee's emergency plan addressed only.one assembly area for evacuation purposes, the Information Center. The Information Center is also the Emergency Coordination Center. All nonessential station personnel, contractor personnel, and/or visitors protective actions for the various emergency conditions were described in specific terms such as:
"all office personnel, visitors and contrac--
tors assemble at the Information Center and await-further instructions".
The licensee had provisions for concise oral announcements over the facility public address system to describe-immediate actions for nonessential personnel.
Emergency Plan-Implemen-ting Procedures included' reference to personnel accountability.
Although the evacuation procedure addressed the monitoring of personnel for radioactive contamination it did not reference decontamination procedures or provide instructions on actions to be taken if personnel in the assembly area
.are found to be contaminated.
69 Based on the above findings. this portion'of the licensee's program: appears to be acceptable, but the following area
]
should be considered for improvement:
Evacuation routes be clearly defined and marked with conspicuously posted arrows.
11.4.7
-Personnel Accountability Personnel accountability actions were the responsibility of Department Supervisors during a Local emergency and the Security Force during Site and General emergencies. :Their responsibilities were incorporated within each of the procedures which deal with the different emergency classes.
Search and rescue was addressed in Implementing Procedures -
2.50.2 and 2.50.3.
Provisions for-continuous accountability were not addressed by the licensee's emergency procedures.
Based'on the above findings, this portion of the licensee's program appears to be acceptable, but the following area should be considered for improvement:
-Provide for continuous personnel accountability within the emergency procedures.
11.4.8 Assessment Actions The system for gathering information and data upon which to base decisions tc escalate, de-escalate, take corrective actions, or recommend protective actions onsite and offsite was based on: effluent monitor readings, area radiation monitor readings, offsite environmental surveys and other surveys performed by emergency personnel. Applicable procedures identified the sources of information available to calculate the source term of releases of radioactive material, the magnitudes of the release and any resulting contamination. Action levels and protective action guides were specified which would be used by assessment personnel as a basis for considering or initiating emergency measures to terminate or mitigate the actual or projected consequences determined by the assessment process.
Implementing procedures relied upon installed Control Room instrumentation for initial dose projections with initial results corroborated and refined by environmental surveys.
The auditor found no provisions for initially assessing 1
70 offsite radiological consequences in the event all plant effluent monitors were inoperable.
In addition, dose assessment implementing procedures made no reference to alternate means for obtaining meteorological information-should onsite instrumentation become inoperable.
Dose assessment calculations were the responsibility of the Radiological Controls Supervisor, using data provided by either control room instrumentation and/or offsite radiation monitor teams. At the completion of dose assessment, the Emergency Coordinator / Plant Manager is notified of the results. There were no clear provisions for trend analyses of assessment information to offsite agencies who would be responsible for implementing protective actions in behalf of the general population.
Implementing procedures relating to assessment of offsite-radiological consequences included provisions for environmental soil, vegetation and water sampling and analysis, but did not address the use of the data.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
11.4.9 Radiological and Environmental Monitoring Program The licensee had provisions for implementati'n of a radio-logical environmental monitoring program during emergericies.
The program included the assignment of duties for collection and evaluation of data relative to environmental TLDs, soil, vegetation, water, milk, and animal feed samples.
The above functions would be performed under the direction of the Vice President, Yankee Nuclear Services Division who forms part of the Yankee corporate emergency response organization. The licensee appeared to have a coordinated structure for emergency environmental monitoring.
Samples would be evaluated by the Yankee Westboro, Massachusetts environmental lab. The licensee appeared to have adequate TLD reading capability.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
11.4.10 Onsite First Aid / Rescue Implementing Procedure 2.50.8, " Medical Emergency P.an",
described pre planned response to in onsite First Aid or medical emergency.
The procedure described the actions for assisting personnel who have become injured, excessively
71 contaminated,-potentially over-exposed to_ internal / external radiation, or any combination of these conditions. The methods for receiving, recovering, transporting and handling persons and the interface and conditions for using offsite medical treatment facilities was described.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.4.11 Security During Emergencies The security measures to be placed in effect during emergen-cies were specified in Implementing Procedure No. 2.50,9,
" Security Force Radiation Emergency Plan" ar.
in various emergency procedures for each emergency category. Action steps in the security procedures provided a means for-security and accountability during emergencies.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
11.4.12 Radiation Protection During Emergencies The licensee's Emergency Plan and Implementing Procedures were found to contain little information.regarding radiation protection during emergencies.
Information was limited to the " Maine Yankee Radiation Protection Manutl", dated January 1,1980. Detailed organizational and procedural means was adequately developed to include the_following a eas: personnel dosimetry, exposure records, positive access controls, instructions to emergency workers, dose assessment, provisions for preventing re-exposure of individuals or limiting further exposure, ALARA, etc.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following area should be considered for improvement:
Integration of the Maine Yankee Radiation Protection Manual into the appropriate sections of the Implementing Procedures.
11.4.13 Recovery Implementing Procedure No. 2.50.11, " Plant Entry and Recovery Plan", provided guidelines for limiting personnel exposures during a re-entry and recovery following an emergency.
72 The organizational authority for declaring that a recovery phase is to be entered was not specified. There were no' provisions for evaluating plant operating conditions in
~
the procedure, however, out-of plant as well as in plant radiological condition evaluations were called for prior to assuming a recovery mode.
Based on'the above findings, this' portion of the licensee's program appears to be acceptable, but the following area should be considered for improvement:
Clarification of the organizational authority for declaring that a recovery phase has been entered.
11.4.14 Repair / Corrective Actions The auditor noted that the licensee had not considered and addressed repair / corrective actions which may be necessary or prudent as part of their emergency response. An'implemen-ting procedure that addresses repair / corrective actions should be an integral part of the Emergency Plan.
11.5 Supplementary Procedures 11.5.1 Inventory, Operational Check and Calibration of Emergency Eouipment, Facilities, and Supplies The licensee's inventory procedure for emergency supplies and equipment, Implementing Procedure.No. 2.50.6, " Emergency Equipment Readiness Check", provides an inventory of all equipment dedicated for use during emergencies and specified the frequency at which emergency equipment is to be inventoried and operationally checked. Operational check of the State Police radio is the only communication check.
Based on the above findings, this. portion of the licensee's program appears to be acceptable but the following area should be considered for improvement:
Provisions for testing emergency related communications equipment on a routine basis.
11.5.2 Drills According to the licensee's Emergency Plan (Imp 7ementing Procedure No. 2.50.5), " Annually, the Emergency Plan Coordinator in conjunction with senior plant management, will select a simulated accident which, were it to occur, would result in a general Emergency".
The Maine Yankee Radiation Emergency Drill was conducted on Thursday, December 4, 1980 at 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />.
73 Based on-the above findings, this portion of the licensee's program appears to be acceptable, but the following area should be considered for improvement:
Provision for_ drills and/or exercises during back
]
shifts / periods of_ minimum staffing.
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11.5.3 Review, Revision and Update The licensee's Emergency Plan called for a review and update of the Emergency Plan on an annual basis.
Implemen-tation procedures which; implement the Emergency Plan were reviewed-on a continuous basis in order to conform with-new requirements and guidelines.
In addition, the Plant-Operating Review Committce (PORC) reviews the Emergency Plan and recommends updating procedures as the need arises.
~
The auditor observed that the licensee was reviewing the updated implementing procedures, incorporating new instruments-and equipment, and other pertinent changes as the need was identified. Changes to implementing procedures were promptly approved and implemented and their distribution was verified to be appropriate.
Based on the above findings, this portion of the licensee's-
-program appears to be acceptable.
11.5.4 Audit The licensee had provisions for auditing the Emergency Plan and Implementing Procedures by corporate headquarters on a routine basis. The last Emergency Plan audit was conducted on November 24, 1980.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
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4 ANNEX A i
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Exit Meeting and ~ Licensee Commitraents-l 5
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The NRC Appraisal Team met with the licensee representatives (denoted in ANNEX
'd B) on January 30, 1981 to discuss the scope and findings of the appraisal.
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ANNEX B Persons _ Contacted
- E. Wood, Plant _ Manager.
- G. Cochrane, Radiological Controls Supervisor
- G. Pillsbury, Radiological Controls Foreman C.1 Young, Chemistry / Health Physics Technician C. Gentile,. Chemistry / Health Physics Technician
'l P.LStover,-Chemistry / Health Physics: Technician J.-Stevens, Chemistr's Supervisor
- 8. Kimball, Secondary System Chemist W. Lach, Primary System Chemist P. Radsky, General Chemist D. Sellers, Chemistry Technician L. Thornberg, Chemistry Technician R. Arsenault, Day Shift Sepervisor R. Hanley, Shift Operating Supervisor T.
S. Atwater, Shif t Operating Supervisor H. Stercks, Operator 1
R. Radash, I&C. Supervisor D. Lemieux, I&C Foreman R.'Wyckoff,' Senior Staff Engineer
- D. Pike, Ouality Control Manager R: Bowden, Contractor Health Physics Technician
- D.
Sturniolo, Technical' Assistant
- W. Lazarus, Senior Resident Inspector
- P. Swetland, Resident Inspector
- derotes those. individuals present at 'the Exit Meeting on January 30, 1981.
In addition,.several other members of the licensee'; staff were contacted, including technicians, operators and maic,cenance personnel.
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Figure 1 Maine Yankee f(tomic Power Organizational Structure, Company (MYAPC) 1 As it Relates to the l
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