ML20037D360
| ML20037D360 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/29/1981 |
| From: | Carroll R, Hadlock D, Galen Smith, Wajnas E, Jason White Battelle Memorial Institute, PACIFIC NORTHWEST NATION, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), TERA CORP. |
| To: | |
| Shared Package | |
| ML20037D359 | List: |
| References | |
| 50-244-80-16, NUDOCS 8107100121 | |
| Download: ML20037D360 (83) | |
Text
.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
80-16 Docket No.
50-244 License No.
DPR-18 Priority Category C
Licensee:
Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14604 Facility Name:
R. E. Ginna Nuclear Power Station Appraisal at:
Ontario, New York Appraisal conducted:
Decer er 7-J9 1980 7 7/
Inspectors:
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t Appraisal Summary'.
Appraisal on December 7-19, 1980 (Report No. 50-244/80-16)
Areas Inspected:
Special, announced appraisal of radiation protection program, including organization and management, training, quality assurance, procedures, internal and external exposure controls, surveys and access controls, instru-mentation, ALARA, radioactive waste, facilities and equipment, and accident response capabilities.
The appraisal involved about 330 hours0.00382 days <br />0.0917 hours <br />5.456349e-4 weeks <br />1.25565e-4 months <br /> onsite by four NRC appraisers.
Region I Form 12 (Rev. April 77) 8107100121 810615 PDR ADOCK 05000244 0
TABL5 0F CONTENTS 1.0 Radiation Protection Organization 1.1 Description 1.2 Scope of Responsibilities 1.3 Staffing 2.0 Personnel Selection, Qualification and Training Program 3.0 Exposure Control Program 3.1 External Exposure Control Program 3.2 Internal Exposure Control Program 3.2.1 Respiratory Protection Program 3.3 Surveillance Program 3.3.1 Scope 3.3.2 Instrument Suitability and Use 4.0 Radioactive Waste Management System 4.1 Program Responsibility 4.2 Waste Processing Systems 4.3 Effluent / Process Instrumentation 5.0 ALARA Program 5.1 Program Establishment 5.2 Program Implementation 6.0 Health Physics Facilities and Equipment 6.1 Facilities 6.2 Protective Equipment Annex A Exit Meeting
. Annex B Personnel Coatacted Figures 1 and 2 i
1.0 Radiation Protection Organization 1.1 Description Figure 1 depicts the corporate and station level organizations, as the structure applies to the radiation protection activity.
In this organization, it is seen that the Supervisor, Chemistry and Health Physics (the designated Radiation Protection Manager-RPM) reports to the Assistant Station Superintendent as opposed to the Station Superintendent. While such a reporting structure is less desirable than the RPM reporting directly to the Station Superintendent, there was no evidence in this Appraisal that the Radiation Protection aspects of station operation were recieving less than adequate management attention as a result of the organizational structure.
Figure 2 describes the RPM's concept of the Chemistry and Health Physics organization structure as of December 19, 1980.
However, up to this date, no accurate organization arrangement had been formalized, described or promulgated that depicted this structure and expected reporting chains. According to the RPM, the Administrative Procedure, A-201, "Ginna Station Administrative and Engineering Staff Responsibil-ities," Revision 9, dated August 1, 1980, will be revised to reflect the organizational structure described in Figure 2, and will ce amended to include functional descriptions of the principal staff personnel.
1.2 Scope of Responsibilities As of the date of this Appraisal, formalized positive descriptions and functional statements (responsibilities and authority) appeared only for the titles of Supervisor, Chemistry and Health Physics, Health Physicist, Secondary (Systems) Chemist and Radio-Chemist in Administrative Procedure A-201 and formalized Job Descriptions.
The licensee generally described the Job Description of Health Physicist
l 2
to apply to several of the positions shown in Figure 2, par.ticularly Rad Waste and Transportation Coordinator, ALARA and Respiratory Protection Coordinator, HP Records Specialists, and HP Foreman.
It was evident, however, that these current positions were significantly more specialized than was recognized by the Health Physicist Job Description.
In fact, the position of Health Physicist was no longer represented in the organizational structure, Figure 2.
The lack of definition and clarity with regard to the current structure was evidencedby the fact that the personnel involved, particularly first line supervision, were unsure of their reporting chain, positions within the organizations, and the discreet respensibilities and authorities assigned to their functions.
Accordingly, efforts were initiated by the licensee's management to provide formal and accurate descriptions and functional statements for the principal positions in the current organizational structure, including the responsibilities and authorities assigned to personnel.
With regard to the existing Job Descriptions, while responsibilities may be specified, it was not apparent that commensurate authority was provided in the existing documentation.
From interviews with various supervisors and technicians, it was apparent that some of the personnel 1
were unsure of the authority vested in their positions, particularly in regard to stopping work-in progress when radiological conditions compromised safety, or enforcing adherence to procedures.
This uncertainity seems to result from the lack of a definitive statement of authority posed in any policy or administrative document such as A-201, "Ginna Station Administrative and Engineering Staff Responsi-bilities," or A-1, " Radiation Control Manual."
3 1.3 Staffing Current normal staffing of the Chemistry and Health Physics Organization was as follows:
Position Personnel Assigned Supervisor, Chemistry & Health Physics 1
Environmental & Radiochemistry Supervisor 1
Rad Waste & Transportation Coordinator 1
Health Physics'0peration Supervisor 1
ALARA and Respiratory Protection Coordinator 1
Health Physics and Chemistry Foreman 1
Records Specialist 1
Secondary System Lead Chemist 1
Chemist 1
Chemistry Laboratory Aide 1
Chemistry Coop 1
Chemistry & Health Physics Technicians 9
Clerks 2
Contracted Technicians 3
While it appeared that this level of staffing was adequate for normal p
operations, and sufficient to provide continuous shift coverage, it was noted that the functions of Rad Waste and Transportation, and ALARA and Respiratory Protection were not adequately staffed commen-surate with the tasks assigned to these positions.
In both cases, the individuals in charge of these functions appeared highly motivated and able to manage the responsibilities but lacked the personnel
4 resources that would enable better performance in the area.
For example, it was observed that the ALARA and Respiratory Protection Coordination was entirely involved with the development and perform-ance of the ALARA Program to the point that none of his time was devoted to development and performance of the Respiratory Protection Program.
Similar circumstances, though not as acute, were observed for the Rad Waste and Transportation Coordinator.
Currently, both functions must rely on a pool of technicians that, while qualified, were not specifically trained in the particular attributes associated with these specialized functions.
The current organization appeared able to function adequately even though the structure provides for both the Radiation Protection and Chemistry specialties.
The area of Secondary System Chemistry was the most apparent production related activity in the organization, but its involvement with the Chemistry and Health Physics Department was predominently administrative in nature.
Technical direction and support for this activity was usually through the Rochester Gas and Electric (RG&E) Laboratory Director.
Technical and management support from the corporate office was provided by the RG&E Radiation Specialist (who as of this appraisal was designated as Corporate Health Physicist).
The individual provided direct technical assistance to the RPM, performed special projects and studies in support of the Radiation Protection activity, augmented the management of the Radiation Protection Program when necessary, and performed critical review of the performance of the activity.
The fact that this individual reported through a management structure that was independent of the station management would appear to increase the potential for the position to provide objective oversight of the Radiation Protection activity. However, since the position was relatively new, a descriptive functional statement had not yet been developed that represented the responsibilities and authorities of the position.
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5 Evaluation At the time of this appraisal, the organization was completing a revision in alignment and function, however, it appears that adequate support for the Radiation Protection activity was maintained. A clear structural definition, functional description and statements of responsibilities and authorities still need to be promulgated to complete the licensee's efforts in this area.
Based upon the above findings, improvements in the following area are required to achieve an acceptable program:
An accurate description of the Radiation Protection organization was not developed, established and maintained sufficient to define the organizational hierarchy, reporting chains, functional descriptions of the personnel involved (including responsibilities and authorities).
Administrative Procedures had not been revised to reflect the current arrangement of the Chemistry and Health Physics organization, nor had Job Descriptions been established that accurately represented the positions in the current organization, including that of Corporate Health Physicist.
Other portions of this area were acceptable but the following matter should be considered for program improvement:
Assignment of personnel to augment and support the functions of Respiratory Protection and ALARA, and Rad Waste and Transportation.
6 2.0 Personnel Selection, Qualification, and Training Program Documents Reviewed Procedure No. A-1, " Radiation Control Manual," Revision No. 19, October 27, 1980.
Procedure No. A-102.1, " Facility Staff Training Program, Ginna Station Personnel Training Program," Revision No. 2, January 10, 1980.
Procedure No. A-102.2, "R. E. Ginna Administrative Controls Training Program," Revision No. 4, October 10, 1980.
Procedure No. A-102.3, "R. E. Ginna Health Physics Orientation Program," Revision No. O, January 22, 1979.
Procedure No. A-102.6, "R. E. Ginna Systems Familiarization Program,"
Revision No. 2, April 3, 1980.
Procedure No. A-102.10, " Health Physics Technician Training and Responsibility Limits," Revision No. 3, November 13, 1980.
Procedure No. A-201, "Ginna Station Administrative and Engineering Staff Responsibilities," Revision No. 8, August 1, 1980.
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l Program Health physics and radiochemistry duties were jointly performed by each technician in the chemistry and health physics department (CHPD).
The licensee's personnel selection, qualification and training program for the CHPD were developed to address these two job functions.
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7 The selection and qualification criteria for licensee and contract health physics technicians were outlined in Procedure No. A-102.10.
The qualifica-tion criteria for CHPD management personnel were contained in Procedure No. A-201.
Procedure No. A-102.10 contained selection, advancement and training criteria along with the responsibilities of each technician grade. The technicians were divided into four grades (trainee, "B", "A" and Foreman) for licensee technicians and into two grades (junior and senior) for contract technicians, depending upon experience and company service time.
In these categories, the trainee grade was equivalent to a junior technician; and technicians B, C and foreman were equivalent to a senior technician in accord with ANSI N18.1 (1971).
Procedure No. A-201 contained a job function description and a listing of duties for various management positions in the CHPD. The positions outlined were Supervisor of Chemistry and Health Physics, Health Physicist, Radio-Chemist and Secondary (Systems) Chemist.
These job titles were those that existed prior to a reorganization that took place during the appraisal, as discussed in Section 1.0 of this appraisal report.
The training program for health physics consisted of three categories:
R. E. Ginna health physics orientation (with requalification annually for all plant personnel who were assigned film badges); R. E. Ginna systems.
familiarization (in which operations personnel spent an initial one week in the CHPD); and recurrent health physics training sessions for CHPD technician personnel (performed by Ginna management or outside contractors).
The health physics orientation was given by the training department to all personnel expected to enter a controlled area.
This training, in most circumstances, consisted of 75% contractor produced videotape and 25% lecture by the instructor.
The videotape portion was a general presentation based on the following outline:
8 I. What is nuclear radiation?
II. Types of radiation III. Biological effects IV. Radiation units V. Limits VI. Dosimetry VII. Time, distance, shielding VIII. Radiation Work Permit (RWP)
IX. Posting X. Contamination XI. Protective clothing XII. Worker's rights XIII. Prenatal considerations A lecturer provided site specific information and answered questions raised during the training sessions.
The course duration was approximately one day which included a forty-five question multiple choice test.
The same format was used for all initial and annual requalifications for licensee and contractor personnel.
Health physics technicians and operations department staff members also attended a systems familiarization course on a one time basis for a minimum period of three weeks. At the completion of this training, operations staff members were assigned to the CHPD for one week to familiar-ize themselves with the following areas that were discussed in Procedure No. A-102.6:
I. Dosimetry II. Film badge records III. Surveys and smears IV. Packaging and shipping rad was-.
9 Health physics training was provided at least quarterly by CHPD management personnel.
This was augmented in 1980 by the addition of a contractor-produced health physics course.
This course was composed of half-day sessions for one week per month for eight months; and successful completion provided equivalent college credit.
Documentation of this training was maintained in the training office for the current year, and in central records for previous years.
A training file was maintained for each staff member.
The file contained exam results, a list of training received, and education / experience records.
In addition, training schedules, instructor sign off sheets, and lesson plans were similiarly maintained.
Appraisal The appraiser evaluated the selection and qualification criteria used in the hiring and advancemdnt process by reviewing the personnel files, including resumes, of all licensee and contractor health physics staff members, and by interviewing various health physics tecFaicians.
It was observed that the selection and qualification criteria for licensee and contractor health physics technicians is in accord with ANSI N-18.1 1971 and the guidelines pro"ided in Procedure No. A-102.10.
However, selection and qualification criteria for the CHPD management positions, as required in Appendix A, Section 6.3.1 of the technical specifications, i.e.:
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l "Each member of the facility shall meet or cycaec the minimum qualifications of ANSI standard N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, as supplemented by Regulatory Guide 1.8, September 1975, for comparable positions..."
was not formally addressed in any of the licensee's documents.
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10 In view of this requirement, a formal procedure should be established that identifies measurable education and experience factors used in the hiring and advancement of health physics management personnel.
In reviewing the resumes and company experience records of the chemistry and health physics department, it was observed that, currently, a highly qualified health physics management team meeting ANSI N18.1 and Regulatory Guide 1.8 requirements did exist as shown below:
Supervisor, Chemistry and Health Physics B.S. in Chemistry 12 years as Radiochemist, 8 of which were as Supervisor, Chemistry and Health Physics Corporate Health Physicist B.S. in Environmental Sciences M.S. in Radiological Health Health Physics Operations Supervisor B.S. in Chemistry M.S. in Environmental Health 12 years as Health Physicist i
ALARA and Respiratory Protection Supervisor B.S. in Health Physics 2 years as ALARA coordinator at another utility 4 years as Health Physicist 1
11 Rad Waste and Transportation Supervisor B.A. in Biology M.S. in Reactor Health Physics 3 Years as Health Physicist The appraiser reviewed training records for all CHPD and training department staff members, as well as selected records of maintenance, operations and site management personnel.
In addition, various members of the CEPD were interviewed to determine the adequacy of the licensee's health physics training program.
It was noted that, while training was performed initially and on a routine basis for plant personnel by the training department and for the CHPD personnel by health physics management, the training program did not provide for physical demonstration of attainment of health physics skill s (i.e., " hands-on and "on-the-job" training).
General Employee Training During the health physics training given to personnel before they were allowed to enter controlled areas, the use of protective clothing, step-off pads (SOP), pencil dosimeters, and frisking techniques were discussed.
Videotapes showing various health physics practices were used for this training, (for example, a contractor was shown danning and removing protective clothing).
However, the classroom instructor did not require the students to perform or demonstrate these functions,and the appraiser noted this to be a deficiency in the training program since staff members qualified as radiation workers were routinely required to read and rezero l
their own pencil dosimeters, frisk (survey) themselves out of the controlled area, and properly don and remove anti-contamination clothing.
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12 During interviews with staff members, it was noted that the licensee's training program policy was not to require demonstration of the above itens but to let the workers find out how to perform the needed functions for themselves in the field.
In the view of the appraiser, the videotapes used in the health physics orientation were of good content and scope but were not effective without reinforcement by student participation.
The lecture time by the instructor (25% of the course) on site specific material should be increased to include actual student demonstration of certain health physics techniques.
This is consistent with ANSI N-3.1 (1978) which recommends that systems such as the videotapes should not comprise more than 50% of the lecture time.
With this exception, the health physics training course content, the competence of the instructors, and the evaluation of student performance objectives by written tests was acceptable.
HP Technician Training "On-the-job" training for health physics technicians did not formally exist for counting room equipment, portable survey instruments, survey techniques, and the whole body counter. All training of this type was based on classroom sessions, procedures, and assistance from other health physics technicians who were familiar with the equipment or techniques.
An "on-the-job" training checklist was used for contractor health physics technicians and each individual item (such as a survey instrument, smear technique, etc.) was signed off by a licensee health physics staff member when the contractor technician snowed his/her proficiency.
In interviewing the CHPD management it was stated that a similar checklist was used in the past for licensee health physics technicians but was stopped because the record was not kept current.
Evidence was available that the health
13 physics technicians were competent and were able to respond knowledgeably to normal or unusual conditions.
However, without a formalized " hands-on" and "on-the-job" training program, there was no demonstrated assurance that replacement health physics technicians were adequately prepared for normal or emergency conditions in the future.
It was observed by the appraiser that, with the exception of " hands-on" and "on-the-job" training, the content, scope, frequency, and technical depth of the training for health physics technicians appeared adequate.
Based on the above findings, the personnel selection and qualification program appeared to be acceptable; however, improvements in the following areas are required to achieve an acceptable personnel training program:
Student Demonstration of Attainment of Skills
" Hands-On" and "On-The-Job" Training I
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14 3.0 Exposure Control Program 3.1 External Exposure Control Program Documents Reviewed Procedure No. A-1, " Radiation Control Manual," Revision No. 19, October 27, 1980.
f Procedure No. HP-1.1, " Issuing Personnel Dosimeters," Revision No. 14, November 5, 1980.
Procedure No. HP-1.2, " External Exposare Limits," Revision No.
7, April 18, 1980.
Procedure No. HP-1.3, " External Exposure Records," Revision No.
8, November 11, 1980.
Procedure No. HP-1.4, " Noble Gas Exposure," Revision No. 4, March 31, 1980.
Procedure No. HP-1.5, " Dosimeter Discrepancy Evaluation,"
Revision No. O, August 31, 1978.
Procedure No. HP-1.6, " Neutron Exposure," Revision No. 5, November 8, 1980.
l Procedure No. HP-2.3, "TLD Reader Calibration," Revision No. 3, November 5, 1980.
Procedure No. HP-2.4, "TLD Readout," Revision No. 3, July 14, 1979.
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15 Procedure No. HP-3.1, " Exposure Reports to Individuals and the Nuclear Regulatory Commission," Revision No. 5, November 8, 1980.
Procedure No. HP-3.2, "In-Plant Reporting of Current Exposures,"
Revision No. 2, February 19, 1979.
Procedure No. HP-4.2, "Self Reading Dosimeter Use;," Revision No. 3, June 20, 1980.
Procedure No. HP-7.5, " Pocket Dosimeter / Accuracy and Leak Test," Revision No. 5, December 1, 1979.
Procedures The external exposure control program consisted of the dosimetry, exposure review, exposure limitations and quality assurance ;rogram.
The control of personnel external exposure within the dosimetry program was accomplished by the use of exposure measuring devices, timekeeping, and a records system for documenting these exposures.
The external exposure measuring devices used by the licensee were vendor processed film badges, 'icensee processed thermoluminescent dosimeters (TLD) for both whole body and extremity measurements, and pocket ionization chambers (pencil dosimeters).
In addition, the use of a portable neutron survey instrument plus time keeping were used to estimate neutron exposure.
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The system of records used to control personnel external exposure were individual exposure history files, a continuously updated computer file for all film badge wearers, daily exposure logs and special work permits (SWP) and TLD tape printouts.
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The film badge used by the licensee was supplied and processed by a vendor on a monthly frequency.
The film was designed to measure gamma, X-ray and beta radiation. An additional neutron-sensitive film package supplied by the vendor was used on an experimental basis but was not considered the legal record for this type of exposure.
The vendor specifications for the film badges used were:
Energy Range Gamma /X-ray 18 kev - 20 MeV Beta Greater than 1.5 MeV Neutron 1-10 MeV Minimum Detectable Dose Gamma /X-ray 10 mrem Hard Beta 40 mrem Fast Neutron 20 mrem Thermal Neutron 10 mrem The licensee's TLD device consisted of a clip on holder wi,th four positions for TLD chips (Li-7), one of which was an open window covered only by tape for beta measurements.
Two chips were used in each holder, one for gamma and one for beta plus gamma.
Processing and recording of TLD data were performed by the chemistry and health physics technicians.
The licensee's policy was to use the TLD as a backup device if the pencil dosimeter and film badge showed a discrep-ancy, otherwise the film badge was used as the legal record.
TLD's were required to be worn in high radiation areas or when personnel were expected to receive greater than 300 mrem / calendar quarter.
Self reading pocket (pencil) dosimeters were used in cenjunction with
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the film badge and TLD. The licensee's policy was to require the wearing of pencil dosimeters for entry into the controlled area.
If both TLD's and pencil dosimeters were used, measurements from the the pencil dosimeter was recorded in the person's exposure file until the film badge could be processed.
The responsibility for reading, rezeroing and recording pencil dosideter results was the responsibility of each staff member.
17 Extremity exposure measurement was by the use of finger rings contain-ing two TLD chips.
The licensee's policy for the wearing of finger rings was left to the judgement of CHPD personnel on a case by case basis.
Records of extremity exposure were included in each person's exposure file on an NRC-5 form.
Records of skin exposure from noble gases were also recorded in each exposure file on an NRC-5 form, in accordance with the licensee's Procedure No. HP-1.4.
Each staff member was assigned a exposure record file (which was maintained by the exposure record clerks) containing:
NRC-5 Forms NRC-4 Forms Exposure Evaluation for Damaged or Lost Badge Record of Exposure Requested By and From Other Organizations Dosimeter Discrepancy Evaluation Form Neutron Dose Calculation Sheet Whole Body Count Records l
l Skin Decontamination Records An exposure report was distributed every Monday (daily during outages) to approximately twenty-five foreman and management personnel for their review and dissemination to their staff.
This report listed the previous week's exposure total, the quarter to date total, and the previous thirteen week's total (as required by New York State) for each individual.
The film badge data for this report was supplied
18 every month by the vendor with pencil dosimeter results being updated daily from the RWP and SWP log sheets.
External exposure data was also recorded on individual " permanent personnel film badge record" cards in three ring notebooks for easy reference.
This card covered a period of one year and had whole body count data recorded on the back.
The exposure limitations program consisted of procedures establishing policy for the licensee's external exposures guides to meet the concept of ALARA. The external exposure guides outlined in Procedure No. HP-1.2 were:
100 mrem / day (200 mrem during outages) 300 mrem / week (500 mrem during outages) 2000 mrem / calendar quarter 3000 mrem /13 consecutive weeks (New York State guide)
To exceed 2000 mrem / calendar quarter the permission of health physics operations supervisor was required; and to exceed 2250 mrem / calendar quarter the plant superintendent's permission was needed.
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personnel were limited to 2500 mrem / calendar quarter.
The licensee's quality assurance program for external exposure control consisted of the calibration of portable survey instruments, counting room equipment, and reliability checks on the vendor's film badge and the licensee's TLD system.
The quality assurance checks on the vendor's film badge consisted of exposing film badges to various known gamma exposure levels (spiking) and then sending them to the vendor for processing with the rest of the licensee's monthly film badges.
The exposure results of these film badges as determined by the vendor were then compared to the values as determined by the licensee during spiking.
The conclusions of this comparison allowed
19 the licensee to either accept or reouire the vendor to reevaluate the data accordingly. The quality assurance checks on the licensee's TLD's was performed in a similiar manner to that of the vendor's film badge, except that the licensee evaluated its own data.
Appraisal The exposure history of each individual staff member was kept in the exposure records office and contained both external and internal exposure records.
The appraiser observed that the individual records were up to date, well organized and complete in meeting the requirements of 10 CFR 20.401.
The NRC-5 forms were filled out each quarter with the period of exposure further broken down into months with a separate NRC-5 form used for whole body, ' skin, extremity and neutron exposures.
In interviewing the three exposure records clerks, it was observed thac they had adequate knowledge to perform their normal duties as well as to recognize unusual events that may require special interpre-tations or evaluations. As mentioned previously there were several systems of cross reference for individual external exposures which, coupled with the above findings, made the record system acceptable.
The data collected by the CHPD routinely on their survey forms and SWPs gave the licensee the capability to calculate skin, extremity and neutron exposures.
The actual calculations were not performed on a regular Lisis, except for neutron, but the records reviewed by the appraiser indicate that this option was considered an important tool by the licensee and was used correctly when needed.
Fast neutron exposure, as discussed previously was determined by standard time-keeping method;.
At the time of the appraisal, the licensee was considering a TLD or film badga system to replace this method.
The external exposure dosimetry program, with the exception of a few suggestions, was acceptable overall.
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20 The review of external exposure, both CHPR management and the subject individual, was observed to be acceptable. Weekly exposure listings were reviewed by foreman and licensee management directly responsible for the individual workers and a well directed ALARA program was in use.
Exposure trends were followed on individual jobs, both by the j
ALARA coordinator and the licensee personnel in charge of the job i
(including the chemistry and health physics technicians).
As discussed earlier, a system was in effect as discussed earlier for authorization to exceed the licensee's radiation exposure guides with management approval.
However, the appraiser observed that a procedure did not exist for defining the action to be taken if a staff member exceeded these guides without the proper approval.
The only documentation found by the appraiser was in Procedure No.
HP-1.2, Se tion 6.7 which states:
" Notify the health physicst when any of the above limits are reached."
The other areas of the external exposure limitations program (including radiological posting, administrative limits, access control, surveil-lance program, and the use of remote handling devices) were observed by the appraiser to be acceptable.
Aspects of the quality assurance program relating to portable survey instrument calibration, counting room instrumentation calibration, TLD reader calibration, and reliability checks on TLO's and pencil dosimeters performed by the licensee were acceptable. However, quality assurance aspects pertaining te verdor supplied film badges was deficient.
It was observed that a written procedures for performing reliability checks (spiking) on the vendor's film badge did not exist.
The health physics operations supervisor stateo that he informed the chemistry and health physics technicians what was to be performed
I 21 i
In inter iews with the supervisor, for spiking each time it was done.
v he stated that spiking was not always done routinely but an effort was made to perform it monthly.
The appraiser observed on December 17, 1980 that spiking had been p9rformed on the following dates since June, 1980:
June 6, 1980 July 1, 1980 September 2, 1980 The data was collected on the SWP/RWP survey record attachment form, and contained the following information:
Date of exposure Time on Time off Source exposure rate Film badge number Total exposure Sc1rce number The signature of the CHPD technician performing the spiking and any acceptance criteria, such as percent variation between the licensee's and vendor data, was consistently lacking from these records.
l The method for spiking used by the licensee consisted of exposing one film badge each to two different exposure levels.
This was accomp'ished by placing the film badges in the licensee's gamma calibrator and then using time keeping with various gamma sources to get the required total exposure to the film badges as follows:
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22 June 6, 1980 Film Badge #474 490 mr Film Badge #475 2270 mr July 1, 1980 Film Badge #472 481 mr Film Badge #473 2508 mr September 2, 1980 Film Badge #477 5595 mr Film Badge #478 788 mr This was observed to be unacceptable since only one badge was used at each exposure level which is not statistically valid for a facility that uses several hundred film badges per month, and does not allow for the possibility of using a defective film badge by mistake.
In addition, only two exposure levels are done each time with a wide range between them which does not adequately cover the normal exposure spectrum of personnel film badges.
Another aspce:
f this process which was found to be unacceptable was the use of the gamma calibrator which only utilizes Cs-137 sources.
This system allowed only for varying the exposure levels and did not consider other' types of radiation (beta, neutron) or various energy values of the radiation emitted as outlined in ANSI N13.7-1972 and NRC Regulatory Guide 8.3.
The reliability checks (spiking) performed on tFi vendor's film badge by the licensee were unacceptable.
This was based on the number of badges spiked, the types of sources used (one gamma isotope, 4
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levels used, the non performance of routine spiking and the record-ing of spiking data.
Conclusions Based on the above findings, the external exposure dosimetry program, the external exposure review program, and the external exposure limitacions program appeared to be acceptable, however, improvements in the quality assurance program for film badges are required to ar.nieve an acceptable external exposure quality assurance program.
3.2 Internal Exposure Control Program Documents Reviewed Procedure No. HP-2.1, "Whole Body Counting Guide," Revision No.
3, November 8, 1980 Procedure No. HP-2.2, "Whole Body Count Operation," Revision No. 8, November 8, 1980 Procedure No. HP-2.5, "Whole Body Count Evaluation," Revision No. 2, March 31, 1980 Procedure No. HP-2.6, " Nose Smears," Revision No. 0, November 13, 1980 Program The internal exposure program for the licensee consisted of the dosimetry, exposure review, exposure limitations and quality assurance programs as related to internal exposure.
The control of personnel internal exposure within the dosimetry program was accomplished by
24 a
i i
the use of bio-surveillance, time keeping and a records system for documenting these exposures.
The bio-surveillance method used by the licensee for determining internal exposure was a whole body counter with analysis performed by a vendor.
Time keeping in conju...-
tion with air sample results was used to calculate maximum permissible concentration (MPC) hours for determining the need of whole body counting or other bio-surveillance metheds.
The system of records used to control personnel internal exposures included individual exposure history files, whole body teletype printouts, air sample data, contamination surveys and MPC hour logs.
The whole body counter used by the licensee consisted of a horizontal table with a one-time passover by a NaI detector.
It had the capability of detecting approximately twenty-eight isotopes, of which the 4
following five are printed out routinely for the licensee.
I-131 Co-58 Co-60 Cs-134 Cs-137 i
The counting data from the detector were transmitted to the vendor by telephone lines where it was analyzed and transmitted back to a i
l teletype at the licensee.
The normal counting frequency for plant staff members was as follows:
Semi-Annual Counting Health Physics Technicians i
Primary Side Operators i
l
25 Pipefitters Primary Side Maintenance Personnel Welders Annual Counting I&C Shop Personnel Electricians Mechanical Shop Personnel Maintenance Shop Personnel Operators Results and Test Personnel QC Inspectors Count Every Two Years 3
Administrative Staff Stockkeepers Contract personnel were counted at the frequency deemed necessary by the plant health physicist.
Each staff member was assigned a specific exposure record file which contained external exposure data plus the results of all whole body counts and any calculations to determine MPC hours for suspected ingestions or inhalations.
In addition, if nose smears or fecal and urine samples were taken, the results of the analyses were included in this file. As a backup, whole body count data were also recorded on individual " permanent personnel film badge record" cards in three ring notebooks.
This card covered a period of one year and had external exposure data on the reverse side.
MPC hour logs were kept by the chemistry and health physics department (CHPD) in the health physics counting room.
The log was based on a limit of 40 MPC hours for seven consecutive days with a whole body count being required to determine uptake if the 40.'iPC hour limit was exceeded.
I 26 The internal exposure review program rested solely with the CHP0 health physicists by feedback from CHPD technicians, surveys, air samples, and whole body count data.
The exposure limitations program consisted of procedures establishing licensee policy to meet the concept of ALARA.
In addition, posting and protective clothing (including respiratory protection) were utilized to insure that internal exposures were minimized.
The licensee's quality assurance program for internal exposure control consis ed of the calibration of portable survey instruments, counting room instrumentation, and air sampling equipment (both continuous air monitors - CAMS-and air sample pumps).
The calibration of the whole body counter was performed by the vendor.
This consisted (f a weekly electronic check and a periodic evaluation with a radio-1sotopic phantom.
Neither of these methods was managed by the licensee nor was the data evaluated by the licensee.
Aporaisal It was observed by the appraiser that the internal exposure records were up to date, well organized, and complete in meeting the require-ments of NRC Regulatory Guide 8.26 and ANSI Standard N343-1978. At the time of the appraisal, the licensee had performed whole body l
counts on plant personnel consistent with the frequency outlined in l
Procedure No. HP-2.1.
In reviewing the exposure records, it was observed that suspected incidents involving greater than 10*4 of a j
maximum permissible organ burden (MPOB) had occurred only twice in the past several years.
The calculations and models used to evaluate these suspected uptakes were acceptable and it was found by the licensee that the percentage of MP08 was actually less than 10%
since external contamination was found in both cases.
i I
27 The data collected routinely by the CHPD from surveys, air samples, and whole body counts was adequate to calculate most uptakes and i
determine the critical organs involved. However, the appraiser observed some aspects of the internal dosimetry exposure program that needed to be improved.
These were the lack of a formal proced-ure outlining calculational methods to be used in determining uptakes and critical organs, the lack of procedures for the sampling, handling and analysis of fecal / urine specimens, and the lack of a procedure for thyroid counting.
The only formal document in existence at the licensee for performing bio-surveillance calculations was Procedure No. HP-2.5, which stated in Section 6.5.1:
"If the exposure is due to inhalation or ingestion, determine the critical organ, effective half life, and the dose commitment r
using ICRP Publications 2, 10 and 10A."
In interviewing the health physics operations supervisor and reviewing
~
internal exposure records where calculations of the above type had been performed, it was determined that ICRP guidelines were used. -A hand-written outline to be used in these calculations was generated by the health physics operations supervisor for his own use and was very well thought out. However, for someone else in the CHPD to perform these calculations, it would be necessary to use the ICRPs or be aware of the outline noted above.
In the view of the appraiser, this hand written outline should be used as the basis of a formal procedure for determining the requirements of Section 6.5.1 of Procedure No. HP-2.5.
In interviewing CHPD staff members, it was stated that fecal and urine samples were not taken on a routine basis and as far as the appraiser could determine there was no indication that they had ever I
28 been taken. This was not observed to be a deficiency from a past routine sampling consideration since uptakes of greater than 10% of a MPOB have not occurred. However, Procedure No. HP-2.5 calls for urine and fecal samples to be taken if an uptake of greater than 10%
of MP0B occurs.
This presents a problem since a typical (or average) baseline has not been determined for plant workers.
In addition, the lack of formal procedure outlining the following aspects would make the possibility of performing these samples, especially in an emergency situation, unrealistic.
r Sample collection including volume requirements, frequency, selection of personnel to be sampled.
Storage and transporation of samples.
Analysis techniques either by vendor or licensee including 1
calibrations.
Calculational methods and models.
It was observed that suitable baseline evaluations and procedures had not been developed for thyroid counting.
Thus it has been determined by the appraiser that the lack of the following items makes the internal exposure dosimetry program unaccept-l able:
l Lack of a formal procedure outlining calculational. methods to be used in evaluating uptakes.
l Lack of a formal procedure for fecal and urine specimens.
Lack of a formal procedure for thyroid counting.
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29 The internal exposure review and limitations programs were found by the appraiser to be acceptable and conforming to good ALARA practices.
The appraiser observed that the quality assurance of the internal exposure control program was unacceptable based on the reliability checks performed on the vendors whole body counter.
The other aspects of the quality assurance program, such as the calibration of portable survey ins +.ruments, counting room instrumentation, and air sampling equipment by the licensee, were acceptable.
The two aspects found to be unacceptable for the reliability checks on the whole body counter were the non performance of routine radioactive source (phantom) checks by the licensee (discussed below) and the lack of written procedures covering reliability checks.
Procedure No. HP-2.2, "Whole Body Count Operation," Sect on 5.2 states:
"Run a test count weekly." This test was performed by CHPD management and the results were sent to the vendor.
A procedure did not exist for the performance of this test and the data was analyzed by the vendor with no evaluation performed by the licensee.
In addition, the vendor performed a phantom calibration onsite at their convenience.
In interviewing the health physics operations supervisor, it was stated that the licensee had never calibrated the whole body counter themselves, either electronically or with radioactive sources.
This needs to be accomplished since the internal exposure control program relies entirely on the whole body counter and not on other bio-surveillance techniques.
In order to make the program acceptable, a phantom should be acquired along with known concentrations of the radioisotopes of interest and frequent routine checks should be performed.
i l
30 Conclusions Based on the above findings, improvements in the following areas are required to achieve an acceptable internal exposure dosimetry program:
Procedures for determining uptakes.
Bioassay Procedures that address fecal and urine sampling and analysis, and thyroid counting and analysis procedure.
Based on the above findings, the internal exposure review program, and the internal exposure limitations program appears to be acceptable.
Based on the above findings, improvement in the following area is required to achive an acceptable internal exposure quality assurance program:
Routine Radioactive Source (phantom) checks on the vendor supplied whole body counter.
3.2.1 Respiratory Protection Program Program Establishment It was not apparent that a policy statement has been adequately promulgated by management in regard to the use of respiratory protection.
In response to an inquiry by the anpraiser, the licensee was able to produce a letter (undated) from the (now) Executive Vice President to all Ginna Station 9
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However, the appraiser did note that the existance of such a policy statement was unknown to many of the licensee's radiation protection personnel, including the Respiratory Protection and ALARA Coordinator (the individual charged with the responsibility for developing and maintaining the respiratory protection program).
Though the letter may have once been disseminated, the manner of promulgation i
was apparently not sufficient to assure that the statement was maintained as an active representation of management's policy in this area, such as by incorporation in a current administrative procedure or policy document.
The appraiser's review of the policy statement revealed that it generally provides a sufficient corporate commitment on which to develop, establish and maintain an adequate respiratory protection program.
In accordance with Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection," the licensee had assigned the overall responsibility for the program to the Chemistry and Health Physics Supervisor, who had delegated this specific function to the Respiratory Protection and ALARA Coordinator.
From interviews and reviews of experience and training, the appraiser noted that the individual was qualified to oversee and maintain the licensee's respiratory protection program, and had the ability to evaluate respiratory hazards, to recommend appropriate engineering controls, and specify appropriate respiratory protection.
- However, at the time of the appraisa', none of these responsibilities had been formally assigned to the individual (see Section 1.2).
m 32 The following procedures were developed by the licensee in support of the respiratory protection program.
Procedure No.
Title HP-12.1, Revision 6 Usage of Respirators November 8, 1980 HP-12.2, Revision 7 Medical Check, Fitting and April 18,-1980 Training of Personnel Using Respirators HP-12.3, Revision 2 Selection of Respirators September 26, 1978 HP-12.4, Revision 3 Fitting and Testing of September 29, 1978 Respirators HP-12.5, Revision 1 Maintenance of Respirators August 25, 1978 HP-12.6, Revision 11 Issuance, Proper Use and November 8, 1980 Return of Respirators HP-12.7, Revision c Constant Flow Breathing Air November 25, 1980 System Setup SC-3.16.11, Revision 2 Operating Instructions -
June 20, 1980 Self-Contained Breathing
" ro, acus SC-3.16.15, Revision 1 Charging of Air-Pack June 20, 1980 Cylinders - Compressor or Cascade Method While there are a few deficiencies in the procedures, the l
review of the procedures indicated that the use of respiratory equipment appeared to be adequately controlled and managed, however, the facility for the storage of the devices (a large locker) was deficient in that damage could be incurred when equipment was piled into the locker.
The attributes for such procedures, as identified in Regulatory Guide i
33 8.15, and NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials," appeared to be addressed and implemented but lacked detail.
Inclusion of more detail in revisions of these procedures is recommended to assure that personnel understand the attributes of the program and adequately perform associated activities.
While there were very few direct referet.es to procedures for air sampling and bioassay, such procedures did exist and were implemented in support of the respiratory protec-tion program.
The following were reviewed:
Procecure Title HP-1.4, Revision 4 Noble Gas Exposure March 31, 1980 HP-11.4, Revision 3 High Volume Air Sampling February 22, 1979 HP-11.10, Revision 2 Air Sampling With Siersat January 14, 1480 Low Volume Air Samplers HP-11.2, Revision 10 Iodine in Air Charcoal May 10, 1980 Cartridge Method Procedures pertaining to Whole Body Counting and Bioassay are discussed in Section 3.1 of this report.
i From discussions with the individuals involved in the respiratory program development (Corporate Health Physicist, Chemistry and Health Physics Suoervisor and Respiratory Protection and ALARA Engineer) and review of the records available that document the program's performance, it was l
apparent that sufficient information was generated on which i
to base the effectiveness of the program, and that the licensee does maintain the program in accordance with Regulatory I
Guide 8.15.
l
34 It was observed that while the licensee does not prohibit the use of sorbent cartridges, it was recognized in the procedures that a protection factor cannot be assigned.
Initial and routine medical surveillance was provided in the program and was implemented by knowledgeable medical personnel in accordance with approved procedures.
The appraiser verified certain of the licensee's efforts to establish engineering co.~trols in lieu of permitting the use of respiratory protection devices.
Such items as the use of temporary ventilation systems and containment systems had been provided when practicable, particularly for work involving steam generator eddy current testing or radwaste processing. Additionally, systematic decontamina-tion of particularly high contamination areas had been practiced in an effort to reduce the potential and degree of airborne radioactivity.
Training and Qualifications In the course of this review, the appraiser examined the contents of the training provided by the licensee for persons that may be required to wear respiratory protection equipment.
The majority of the lesson plan and course content was vendor supplied to the licensee. The course itself con-sisted of a videotape presentation of the general informa-tion that was essential to the understanding of respiratory protection.
In the course attended by the appraiser, the videotape presentation was relied on entirely with very e
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r 35 little involvement of the instructor whose main occupation appeared to be running the videotape equipment.
There was no performance evaluation of the trainee nor was there any physical demonstration performed by which personnel could actually acquaint themselves with the equipment and techniques discussed in the videotape.
In the case observed by the appraiser, personnel were deemed qualified to use self-contained air breathing equipment based only on the fact that certain information was announced.
No attempt was made to assure that the personnel were proficient in the use of the device.
Further information regarding training is discussed in Section 2.0 of this report.
Evaluation Based upon the above findings, improvements in the following area are required to achieve an acceptable program:
Personnel were not provided sufficient opportunity to physically acquaint themselves with certain types of respiratory protection devices, particularly self-contained creathing apparatus.
Inordinate reliance was placed upon ii: formation provided by videotape with little effort directed to assure that personnel were proficient in the use of the equipment.
Other portions of this area were acceptable but considera-tion should be given to establishing the written policy statement on respirator usage as a formal administrative procedure, in order to assure that it is maintained and recognized as management's current policy in this area.
36 Additionally, the storage of equipment should be reviewed to asaure that facepieces are not damaged or deformed while in lay-up, and more detail should be incorporated in the existing procedures to assure that the. :cessary attributes of a respiratory protection program are adequately identified.
3.3 Surveillance Program Documents Reviewed Procedure Title Revision Date A-1 Radiation Control Manual 19 10/27/80 A-1.1 Locked Radiation Areas 9
2/17/79 A-1.6.1 Documentation of "As low As Reasonably 2
2/26/80 Achievable (ALARA)" Program M-18.1 Handling, Loading, and Unloading of 2
4/18/80 CNSI Transport Cask CNS-8-120, Model Number LL-50-100 M-43.2 Initial Radiological Survey 7
2/5/80 M-52.3 Incore Thimble Cleaning 5
8/1/79 S-4.1.25 Checking Drums for Free Standing 0
10/6/80 Water HP-2.6 Nose Smears 0
11/13/80 i
HP-4.1 Controlled Area Entry 6
11/19/79 HP-4.2 Self Reading Dosimeter Use 3
6/20/80 i
HP-4.3 Work Permit Use 15 11/5/80 i
HP-5.1 Area Radiation Survey 6
3/31/80 HP-5.2 Posting of Radiation Areas and 2
6/14/79 Container Labeling
37 Procedure Title Revision Date HP-6.1 Contamination Surveys 10 11/5/80 HP-6.2 Posting of Contaminated and Airborne 3
1/30/80 Areas HP-6.3 Personnel Decontamination 2
3/27/80 HP-6.4 Contaminated Clothing Report Form 1
7/11/79 Use HP-6.5 Contaminated Laundry Operation 1
3/1/79 HP-7.3 Calibration of Alpha Survey Instruments 2
12/1/79 PAC-4S HP-7.4 Calibration of Neutron Survey Instruments 4
7/3/80 HP-7.5 Pocket Dosimetry / Accuracy and Leak Test 5
12/1/79 HP-7.6 Tagging of Instruments Requiring 4
11/25/80 Calibration or Maintenance HP-7.7 Calibration of Beta Survey Instrumers.s 2
11/8/80 HP-7.8 Alarming Dosimeter A curacy Test 2
10/6/80
-HP-7.9 10008 Gamma Calibrator Operation 1
11/13/79 HP-7.10 Area Monitor Calibration Emergency 0
10/23/79 Center HP-7.11 Teletector Operation and Calibration 1
10/23/80 HP-7.12 PIC-6A Operation and Calibration 1
5/2/80 HP-7.13 R0-1 (Rad Owl) Operation and 0
10/22/79 Calibration HP-7.14 R0-2A Operation and Calibration 0
10/23/79 HP-7.15 XETEX 302A High Level Probe Operation 0
10/23/79 and Calibration HP-7.16 XETEX 3028 High Level Probe Operation 0
10/23/79 and Calibration 1
38 Procedure Title Revision Date HP-7.17 GME-530 Survey Meter Operation and 0
11/20/79 Calibration HP-7.18 Auto Digimaster 305 A & B Operation and 0
11/20/79 Calibration HP-7.19 Jordan Rad Gun Operation and Calibration 0
11/20/79 HP-7.20 Digi / Master Survey Meter Operation and 0
11/20/79 Calibration HP-7.21 Jordan Radector III Oper~ation and 0
11/20/79 Calibration HP-7.22 High Range Survey Meter, CP-5-MU 0
11/20/79 Operation and Calibration HP-7.23 XETEX 501 A-2 Digital Area M itor 0
11/20/79 Operation and Calibration HP-7.24 Radiation Monitor Unit RM-3C Calibration 0
8/11/80 HP-7.25 Radiation Monitor Unit RM-14C Calibrstion 2
11/5/80 HP-G.1 Radioactive Source Use 1
7/11/79 HP-8.2 Leak Testing of Licensed Sources 6
10/13/80 HP-8.3 Calibration of Gamma Sealed Sources 2
1/31/79 HP-8.4 Radioactive Source Inventory 7
1/28/80 HP-10.1 Quality Control of Counting Systems 6
2/26/80 HP-10.2 Operational Test of Portal and Hand 3
9/22/80 and Foot Monitors HP-10.3 Flow Rate Calibration of Hi-Volume 2
9/22/80 Air Samplers i
HP-10.4 Calibration of Alpha and Beta Counters 1
T/8/79 HP-10.5 Efficiency Calibration of Gamma 1
1/31/79 Spectrometer >
HP-10.6 Calibration of Liquid Scintillation 1
12/18/78 Counter
39 Procedure Title Revision Date HP-10.7 Flow Calibration of Low Volume Air 2
11/5/80 Samplers HP-11.1 Iodine In-Plant Air Drying Tube Method 1
7/15/77 HP-11.2 Iodine In Air--Charcoal Cartridge 10 5/10/80 Method HP-11.3 Noble Gas Sampling and Analysis 3
10/13/80 Utilizing a Marinelli Beaker HP-11.4 High Volus._ Air Sampling' 3
2/22/79 HP-11.5.1 NMC Constant Air Monitor AM-30 3
10/3/80 Calibration HP-11.5.2 NMC Constant Air Monitor AM-21 2
10/3/80 Calibration
-HP-11.5.3 NMC Constant Air Monitor AM-221 2
10/3/80 Calibration HP-11.5.4 NMC Constant Air Monitor AM-21F 0
10/30/80 Calibration HP-11.5.5 NMC Constant Air Monitor AM-330F 0
10/30/80 Calibration HP-11.10 Air Sampling With Siersat Low Volume 2
1/14/80 Air Samplers RD-1.1 Containment Iodine & Particulate, 2/26/80 Sampling & Analysis RD-1.2 Containment Radiogas Sampling and 3
2/10/79 Analysis i
RD-1.3 Tritium In Containment Air Sampling 4
1/31/79 l
and Analysis RD-2 Containment Purge Release 7
11/28/80 l
RD-3 Plant Vent Iodine and Particulate 6
11/21/80 Releases Sampling and Analysis RD-4 Vent Radiogas Background and Factor 7
8/7/80 Determination
40 Procedure Title Revision Date RD-5 Ventilation System Releases 4
5/22/80 RD-6 Gas Decay Tank Releases 9
8/20/80 RD-7 Liquid Waste Release 15 11/5/80 RD-8 Liquid Radwaste Compositing and 6
10/11/79 Analysis RD-9.1 Preparing Radioactive Material For 1
6/9/80 Shipment to a Burial Site RD-10.1 RG&E Radioactive Material Shipment 1
8/11/80 Record Forms RD-10.2 Radwaste Shipping To CNSI At The 0
5/16/80 Barnwell, S.C. Site Type A Quantities RD-10.2.3 Check List For Type A Radwaste Shipments 0
11/5/80 To Barnwell, South Carolina RD-10.4 Radwaste Shipping to NECO at The Beatty, 0
4/9/80 Nevada Site RD-10.4.1 NECO Radioactive Shipment Record (RSR) 0 4/9/80 RD-10.4.2 NECO Certification Form 0
4/9/80 RD-10.4.3 State of Nevada Certification Form 0
4/9/80 RD-10.4.4 Check List for Radwaste Shipments to 0
4/9/80 Nevada RD-11 Receipt of Radioactive Materials 1
7/11/79 RD-12 Tritium in Air Sampling and Analysis 4
4/5/80 l
l PC-1.4 Operation of TN-11 Gamma Analyzer 2
1/28/80 PC-1.5 Operation of TN-4000 Gamma Analyzer 0
3/18/80 PC-23.2 Containment Atmosphere Sampling and 2
10/13/80 Analysis During Containment Isolation P-9 Precautions, Limitations and Setpoints 27 7/14/79 P-9 Radiation Monitoring System l
l
F 41 3.3.1 Scope The licensee's procedures provided the methods and frequen-cies to be used for Health Physics surveillance activities.
Updated copies of the procedures were maintained for use in the Chemistry and Health Physics work area.
The proced-ures did not provide guidance for instrument selection for surveys.
However, the technicians appeared to be knowledge-able in this area and Chemistry and Health Physics Technicians provided 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage to the plant.
Some individuals were allowed to perform self monitoring.
The individuals permitted to self monitor were personally approved on an individual basis by the plant's Health Physicist after assuring that they were adequately qualified.
Special Work Permits (SWP) were used for most activities in the Controlled Area.
SWP's were issued daily.
The final signature on the SWP was that of the Shift Supervisor.
This method assured that Operations had the opportunity to inform Chemistry and Health Physics of changing plant ctnditions.
During outages, daily planning meetings were also used to update Chemistry and Health Physics, Operations, and other groups that had input to outage planning.
The Appraiser did not note any problems in this area.
Considering the licensee's program, it was not felt that the lack of procedural guidance on survey instrument selection had been a problem but such guidance would be desirable considering the number of various types of instruments available.
42 Responsibility Work permits for radiologically controlled areas were issued by supervisors in the Chemistry and Health Physics Group.
Completed work permits, surveys, calibration records plus other records were reviewed by at least two supervisors in the group, including the plant Health Physicist. All supervisors in the group had to informally review surveys in order to !ssue work permits.
It appeared that records and data had bien thoroughly reviewed by the licensee.
Types of Surveillance Radiation and contamination surveys were performed in accordance with written procedures.
The procedures included methodology for conducting the survey as well as required minimum survey frequencies for all areas of the facility.
Sign-off sheets were utilized to er sure that periodic surveys were completed as scheduled.
Some routine smears were periodically counted for alpha activity.
Selected survey records were reviewed for the paried December 17, 1979 through December 9, 1980.
The surveys appeared to adequately represent the radiological status of the facility.
l The surveys showed that some beta anc neutron measurements were made. Areas requiring decontam' nation were reported to the Maintenance Group either verbtlly or by use of the "Ginna Station Maintenance Work Order and Trouble Report" form. A review of completed Trouble Reports available in the Chemistry and Health Physics work area files indicated that areas were generally decontaminated within one to two days of the time they were reported to maintenance.
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43 Periodic air samples were taken in the Controlled Area.
Additional breathing zone air samples were taken during jobs that required or could require the use of respiratory protection.
Lapel samplers were used on some jobs.
Continuous air monitors were in use in Controlled Areas.
The SWP form indicated if and when air samples were required and whether a "Hi'Vol," " Lapel" or " CAM" was to be used.
Results of air samples were recorded on the SWP form.
The filters and absorption media used by the licensee for air sampling were appropriate for the flow rates used.
Tools and equipment used in contaminated areas were bagged and taken to the Hot Shop for surveys and decontamination if needed.
Chemistry and Health Physics personnel surveyed and released equipment before it was removed from the Controlled Areas.
On December 9, 1980, the Appraiser noted a pair of rubbers in a dumpstEr near the Intake Building.
Chemistry and Health physics personnel recovered i
the rubbers and determined that they were contaminated.
l Additional surveys of the dumpster did not reveal any other contaminated material or equipment. An immediate investigation by the licensee determined that an individual l
working in the Intake Building had asked the laundry operator for a pair of rubbers.
(Rubbers were not routinely available for use and were only issued upon request).
The laundry operator assumed that the individual would use the rubbers in the Controlled Area and issued them. The individual used the rubbers to keep his feet warm while working in the Intake Building.
The individual had left the rubbers in the Intake Building after use.
A janitor later found the rubbers and threw them in the dumpster L
+
44 i
witn other trash.
Due to the levels of contamination on the rubbers, the incident did not result in significant area or personnel contamination. After further review and additional conversation, the Appraiser was convinced that this was an isolated incident and not indicative of a significant problem in the licensee's program.
The inci.ient did point out a need for additional training for workers, janitors and laundry personnel regarding the use of anti-c clothing outside of the Controlled Area.
Incidents of personnel contamination were documented and r
kept on file.
One incident on November 11, 1980 involving l
facial contamination on individuals working in the Steam Generator was reviewed.
Information in the individuals' files showed the location and extent of skin contamination, the results of nasal smears, effectiveness of decontamination, and results of repeated whole body counts. Whole body count data had been plotted to show the elimination rate of activity for the individuals.
Memoranda in the individuals' files documented the cause and corrective action associated with the incident.
MPC-hour calculations l
were made based on the whole body counts using the ICRP #2 lung model.
The highest internal activity involved was 83 nanocuries.
The incident was adequately assessed and documented.
~
Records Radiation and contamination survey results wera docemented on survey forms that contained drawings of the area surveyed.
One copy of routine surveys was maintained in a file l
cabinet in the Chemistry and Health Physics work area. A second copy was kept in a notebook on the desk where work permits were issued.
The original forms were routed for
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45 review and then turned over to the records group for permanent filing.
The survey forms w(-e filed chronologically by area of the facility.
The filing method simplified reviews to determine if conditions were changing and if surveys were being conducted at the specified frequency.
Copies of current survey data for the controlled area were posted at the entrance to the area for personnel to review.
Copies of other records and forms, such as air sample results and calibration data, were readily accessible and retrievable.
Forms and data sheets appeared to contain sufficient information.
The licensee's work permit system consisted of Special Work Permits (SWP) and Radiation Work Permits (RWP).
RWP's were used for routine functions such as surveys or tours by operations and were valid for one year.
Seventeen RWP's had been issued in 1980.
SWP's were used for specific tasks or jobs and were valid for one day.
RWP's and SWP's required signatures of a supervisor of the group performing the work, a Health Physicist and the Shift Supervisor.
RWP's also required the signature of the Plant Superintendent.
A management level Health Physicist completed and signed the RWP or SWP.
Information on the SWP included date, time, location of work, job description, special instructions, protective clothing, respiratory protection equipment, personnel dosimetry, and air sampling requirements.
The SWP form also indicated if an ALARA review was required and provided current radiological information on radiation and contamination levels in the work area.
The SWP provided sections to indicate the need for " Health Physics Monitoring."
46 Personnel using a RWP or SWP were requir;d to sign the reverse side of the form to indicate that they had read and uncerstood the requirements. An " Exposure Information" sheet was attached to each SWP and was used to record pocket dosimeter reading and dosos for that particular SWP.
The Appraiser reviewed the seventeen RWP's issued in 1980.
On December 10, 1980, the Appraiser observed as Health Physicists issued SWP's.
The Health Physicists issuing the SWP's had current surveys available and were familiar with them.
The jobs and Health Physics requirements were discussed with the individual requesting the SWP. The Appraiser reviesed about 84 SWP's that were issued between December 1 and December 5, 1980.
These SWP's covered work during the recent outage.
The SWP issue log showed that the licensee issued an average of three to ten SWP's per day during normal operation.
The review cf the SWP's indicated that the SWP's properly reflected the work conditions and specified adequate precautions and equipment for the work performea.
Access Control, Posting and Labeling The normal access point for the Controlled Area was adjacent to the Chemistry and Health Physics work area. A RWP or SWP and protective clothing were required for ali entries.
Dosimeter readings were recorded when personnel entered or exited the Controlled Area.
The doses recorded by pocket dosimeters were assigned to the specific RWP or SWP used for entry.
Locations within the Controlled Area that 2
exceed 10,000 dpm/100 cm were considered contaminated areas and were posted with step off pads and/or signs.
2 100 dpm/100 cm was the limit for removable contamination outside the Controlled Area.
47 Persons exiting from the Controlled Area removed their anti-c lothing and frisked themselves using thin window pancake GM detectors. A Hand and Foot counter was used by personnel exiting through the men's change area.
The Appraiser observed personnel exiting on several occasions and observed that personnel followed the established 4
procedure for undressing and frisking.
One item that concerned the appraiser was the method established for the removal of anti s clothing.
Two step off pads were set up at the exit area.
Personnel removed their shoe covers at the first step off pad and their coveralls at the second step off pad This method did have the advantage of causing personnel to be more careful when removing their coveralls to prevent contaminating their sNoes. However, the normally accepted method is to remove coveralls prior to removing the final set of shoe covers to prevent the coveralls from contaminating the individuals shoes.
One of the appraisers learned that this undressing procedure had caused concern and confusion among transient personnel.
A licensee representative stated that the procedure had been nece sitated when the exit area was previously in a.
state of change and the practice had been continued.
The licensee representative also stated that they had not experienced any additional problems with the spread of contamination or contaminated shoes.
The appraiser reviewed the contamination surveys for the exit area and locker room for the outage period and did not note any significant contamination problems.
Notwithstanding the apparent absence of problems with that method to date, the Appraisal Team recommends changing the undressing sequence, such that coveralls are removed prior to the final set of shoe covers.
It is felt that this sequence is more logical for preventing shoe contamination and will reduce concern and confusion among transient personnel.
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U 48 The appraise. asked a licensee representative how the licensee ensured that personnel complied with the self frisking procedure at the exit area during high traffic periods.
The licensee representative stated that during the previous outage they had periodically stationed a technician in the area at lunch time to ensure that personnel uncressed and frisked properly.
High radiation areas in which the radiation levels were greater than 1,000 mrem /hr were locked and posted as required by the licensee's Technical Specifications.
The licensee used two methods of providing information on radiatian levels to individuals entering rooms or cubicles posted as high radiation areas.
Unlocked or locked high radiation areas that did not have extremely high radiation levels had a copy of the latest survey attached to entrances to the room.
Radiation levels for locked areas, that were seldom entered and contained very high radiation lavels, were available in the Key Log in the Control Room. Whenever Chemistry and Hea'th Physics personnel detected radiation levels greater than 1,000 mrem /hr they would, by procedure (A-1.1), initiate a " Locked Area Change of Status Form."
The form provided the following information:
location; individual performing the survey; date; dose rate; signature of individual requesting the area to be locked; and signature of the Shift Surervisor.
This sheet was placed in the Key Log notebook in the Control Room with a form for checking out keys. The appraiser reviewed the Key Log in the Control Room and found that dose rate information was available for all locked areas. The Shift Super >isor controlled tne keys to high radiation areas.
r 49 The licensee's radiological posting methods were generally adequate.
There were some exceptions, however, which indicate the need for improvement in this area.
The following are examples of posting methods that need improve-ment.
The Chemical Drain Tank in the Basement of the Intermediate Building, South, had High Radiation Area Labels affixed to the sides of the tank.
There was no information to indicate the radiation levels presen,t or if the High Radiation Area was in the vicinity of the tank, inside the tank, etc.
The technician accompanying the appraiser stated that the High Radiation Area was usually under the tank.
The technician surveyed the tank and found the radiation level under the tank to be approximately 50 mr/hr.
The sub-basement of the Intermediate Building, south corner of the room, had been fenced off and locked.
One side of the fence was posted as a High Radiation Area.
The "High" on the High Radiation Area sign by the gate had been tape.d over to indicate a Radiation Area.
The technician removed the tape so that both sides of the fence would be posted as a High Radiation Area until the area could be resurveyed or current surveys checked.
It was later determined that the area was a radiation area and apparently the posting had only been changed on one of the two sides of the fence.
1he sign used to post the Reactor Coolant Filter Area as a contaminated area was an Airborne Area sign with pockets for inserts.
The " Airborne Area" wording on the sign had been taped over and a " Contaminated Area" card inserted into one of the pockets.
Temporary shielding had been installed around piping at the west end of the Sodium
50 Hydroxide Tank. A general use, pocket-type sign had been hung on the temporary shielding. The wording "High Radiation Area" had been written on the sign with a grease pencil.
Additional information was also written on the sign with a grease pencil such that the words "High Radiation Area" were not obvious or distinctly visible.
The other informa-tion on the sign stated "20 mr/hr. this side of lead-mR/hr on pipe." The dose rate data for the pipe had been marked over and could not be distinguished.
The method used to label radioactive material needs additional clarification.
In general, equipment and items not in use were wrapped in plastic and stored in various areas of the facility.
The items were marked with Radioactive Material labels but normally did not provide additional information on activity or contamination and radiation levels. A licensee representative stated that items so labeled were usually low activity and exempt from marking.
The licensee representative said that higher activity items were normally segregated and stored separately.
During the appraisal, some items wrapped in plastic were found stored near the New Fuel Storage Area in the Auxiliary Building.
These items were labeled as Radioactive Material.
The only additional information on the label was the notation "Do Not Remove Plastic Without HP Present." The note indicated that additional controls were needed to handle the material.
Hcwever, information could not be readily obtained to determine if high contamination levels or other radiological problems existed.
j 51 A large quantity of items in the facility had been marked with Radioactive Material labels.
Only a limited number of the labels provided additional information concerning the amount of material or radiation levels present.
3.3.2 Instrument Suitability and Use As noted in the " Health Physics Facilities and Equipment" section of this report, the licensee had an adequate compliment of survey instruments for normal operation.
Portable Instruments The licensee's procedures required tagging inoperable or out of calibration instruments with "Do Not Use" tags.
The appraiser checked a number of surveys instruments being used in the Controlled Area plus instruments stored in the Chemistry and Health Physics work area, Instrument and Controls Shop, Chemistry and Health Physics Storage Area, Calibration Facility and other locations.
The instruments in use had calibration stickers affixed, indicating that they were in current calibration.
Inoperable or out of cal 1bration instruments were properly tagged with "Do Not Use" tags.
The licensee's procedures did not contain a method for or l
requirement to operationally cl.__k portable radiation detection instruments as recom.aended in ANSI N323.
Some of the technicians did informal checks using known radiation levels in the plant, however, mandatory operational checks should be developed and implemented.
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52 A portable area monitor was located on the refueling bridge for the Spent Fuel Pool. A licensee representative stated that portable area monitors were normally installed in some high radiation areas in the Reactor Bui1 ding during outages. According to the licensee representative, periodic operational checks had not been developed for tnose monitors.
Operational checks need to be developed and implemented for portable area monitors that are in use. Guidance should also be formalized for setting the alarm points on these monitors.
Counting Instruments The licensee had developed and implemented procedures for daily quality control checks and calibration of the laborctory counting equipment. Check sources were counted daily and the results were plotted on a graph which indicated the acceptable statistical limits for the check source used.
With the exception of the pancake GM detectors used in the Counting Laboratory, individual efficiency checks were not made for thin window GM detectors utilized with count rate instruments.
The counting efficiencies wre assumed to be j
25% for all thin window GM detectors.
The detector for
(
the portable count rate meter located in the Auxiliary Building was used with a sample holder which was shielded by lead bricks.
This instrument was being used to count smears taken on 55 gallon drums being prepared for shipment.
The smears were checked to ensure that they were less than 2
l 1,000 dpm/100 cm.
The results were recorded as < 1,000 2
dpm/100 cm and specific readings were not recorded.
The background for the instrument was approximately 300 cpm and full scale on the x1 range was 500 cpm.
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53 efficiency of 25%, a count rate of full scale or 200 cpm above background (which would cause an alarm), would be 2
800 dpm/100 cm.
If the efficiency was actur iv only 20%
2 a count rate of 200 cpm would yield 1,000 dpm/100 cm,
Ten percent of the smears were taken to the Count Lab and recounted for beta and alpha.
Instruments used to count smears, especially for release of material such as the radioactive waste drums, should have an efficiency determined for the detector being used.
Daily quality control checks should also be performed and recorded for these instruments.
The count rate instruments being used were calibrated with a pulse generator and were in current calibration.
The Hand & Foot Counter and the Portal Monitors were calibrated annually and source checked monthly.
Check sources with known count rates had been prepared and secured in plastic holders that allowed repeatable position-ing for checking these instruments.
Procedure HP-10.2,
" Operational Test of Portal and Hand and Foot Monitors,"
required that the alarms be set at twice background but not higher than 500 cpm.
The appraiser used the check source and verified that the alarms on the Hand and Foot Counter were properly set.
Calibration Program The licensee purchased and began using a gamma calibrator for calibrating survey instruments in 1979.
They had previously calibrated their higher range instruments at another facility.
Procedures had been prepared for calibra-tion of survey instruments using the new gamma calibrator, with the exception of procedures for the Eberline models
54 E-500 and E-140 and the Victoreen " Vamp" Area monitors.
The licensee's portable instrument calibration procedures were approved in late 1979 or early 1980 and are relatively new procedures.
Generic problems were noted in the licensee's calibration methods and procedures.
Due to the number of procedures involved, the generic problems will be addressed rather than specific procedures.
Many of the procedures, including the installed area radiation monitors, do not require calibration at a sufficient number of points on each scale as recommended in paragraph 4.2.2 of ANSI N323.
The approximate dose rates for each calibration point selected were not specified in the procedure.
The only reference in the licensee's procedures to orientation of survey instruments during use was in Procedure HP-5.1, " Area Radiation Surveys." Paragraph 6.10 of Procedure HP-5.1 states:
" Hold the meter at waist level or above, with the barrel parallel to the floor." 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 l
from the orientation normally used, correction factors may need to be developed to account for directional dependence of the detector.
(Refer to Paragraph 4.3.4 of ANSI N323).
Jigs for positiening some instruments were available with the model 1000B calibrator.
The calibration procedures should specify the jig to be used or method to be used to position each instrument during calibration.
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55 The jigs supplied with the model 10008 calibrator were designed to fit on adjustable shelving in the calibrator to allow varying the source-to-detector distance.
Each jig was designed with a positioning mechanism for the various instruments to ensure reproducibility of the instrument position on the jig.
For example, one jig had four holes for the rubber pads of a certain type instrument. The calibra-tion points used by the licensee did not always correspond to a standard shelf position for this instrument, and in some cases cardboard shims were placed on the jig to elevate the instrument to the proper height.
This practice defeated the positioning device built into the jig.
In addition, the height of the detector ha-d to be measured with a rule when repositioning the instrument.
The method used to position instruments should ensure reproducibility o
even when different individuals perform the calibration.
The method developed should be clearly described in the calibration procedures.
For calibration of the lower ranges on survey instru-ments the calibration procedures reference the use of a lower activity source. The licensee's procedures did not specify the source to be used, procedures for using the source or procedures for calibration of the source.
Procedure HP-8.3, " Calibration of Gamma Sealed Sources," did provide general information for calibrating radiation instruments at various distances from smaller sources.
Ho.tever, the procedure was not specific enough to ensure adequate reproducibility for instrument calibration.
56 The licensee had two Condenser R-Meters that were used to calibrate gamma sources for instrument calibration. One Condenter R-Meter was calibrated each year by the vendor so that either instrument was calibrated once every two years.
Procedure HP-8.3 required that the R-Meter used must be calibrated annually.
Only three of the seven R-Chambers were calibrated with the R-Meter that was calibrated in 1980.
The licensee should e'ener nave both R-Meters and all R Chambers calibrated annually or take steps to ensure that the out of calibration R-Meter and R-Chambers aren't used by mistake.
The l'.censee's neutron instruments were calibrated by an outs,de facility.
The calibration frequency for the neu'.ron rem counter was annually.
The manufacturer's recommended calibration frquency for the instrument is quarterly.
The licensee should review the calibration frequency for that instrument to determine if their present calibration frequency is adequate.
Conclusion Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
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."
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57 The licensee needs to develop operational source checks for portable survey instruments and portable area monitors as recommer.ded in ANSI N323.
In addition, the following matters should be considered for improvement of the program:
Additional training should be provided to personnel regarding the use of anti-c clothing outside of the Controlled Area.
The undressing sequence for individuals exiting the Controlled Area should be reviewed and made consistent with industry practice.
The licensee should review the signs used to post radiological areas to ensure clarity and consistency.
The licensee should also review their methods of labeling radioactive material stored in the plant and provide additional information on the label.
Guidance for setting alarm points for portable area monitors should be formalized.
l Procedures for calibration and source checking GM detectors used for " field" counts of smears should be l
l developed.
l The Eberline models E-140 and E-500 survey instruments j
and Victoreen " Vamp" portable area monitors should not be used until calibration procedures are approved.
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58 4.0 Radioactive Waste Management System 4.1 Program Responsibility The Operation's Group was responsible for the operation of the radioactive waste systems and equipment. The Supervisor, Chemistry and Health Physics, was responsible for the other aspects of the Radioactive Waste Management Program.
A Health Physicist that reported to the Supervisor, Chemistry and Health Physics, had been given the responsibility for the day-to-day management of the program.
The baseline leakage rates were established early in the plant's operation. The Operation's Group stayed current on the sources and amounts of leakage into the radioactive waste systems.
Excessive leakage was found and reduced as it occurred.
Daily tank level sheets were reviewed by the Operations Supervisor, the Health Physicist responsible for radioactive waste, the plant's Health Physicist and the Supervisor, Chemistry and Health Physics.
The Maintenance Group supported operations such as compacting trash and handling containers.
No problems were noted with the organizational responsibilities as assigned.
4.2 Waste Processing Systems The facility had evaporators for baron recovery and for processing liquid waste. The solidification system utilized 55 gallon drums.
Cement and vermiculite were used as the solidification agents.
In addition, an ultra-filtration system was being tested at the licensee's facility.
Data were being collected to demonstrate system effective-ness with and without the ultra-filtration system in operation.
Previous work had been done to compare the system's output to design objectives. After the initial studies, demineralizers were added so that the system would meet the design specifications.
Preliminary data on the new tests indicate'd that the use of the ultra-filtration system would adequately meet the design specifications.
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59 The control panel for the ultra-filtration system was located adjacent to the filter media and near the Waste Hold Up Tank (WHUT). At the time of the appraisal, the general radiation level in the vicinity of the control panel was 40 mR/hr.
For extended or permanent use the location of the panel needs to be reviewed from an ALARA standpoint.
Consideration should be given to locating the panel in an area of lower radiation level outside of the WHUT cubicle.
The licensee, with the use of a 3 kw heater, had been able to operate the evaporator at a lower temperature, which had im=) roved the reliability and decreased maintenance.
The drum filling and solidification station was located adjacent to the drum storage area in the Auxiliary Building.
Five drum filling connections were available.
Shields were available for use in filling high activity druus.
An overhead electric hoist was used to move the filled drums into the drum storage area. A drum-lifting device that could automatically latch and release drums was attached to the hoist.
A shielded viewing window was installed in the shield wall between the fill station and the drum storage area.
During the appraisal the hoist operator would climb up on the shield from the storage area instead of using the viewing window.
Lower levels of radiation were present during the appraisal and the practice of not using the windows was not considered a problem. However, the licensee should periodically review that practice from an ALARA standpoint whenever higher activity material is involved.
In preparation for shipments, the drums were removed from the drum storage area with the same overhead hoist.
A scale suspended between the drum handling device and hoist he-k allowed the drums to be weighed as they were lifted. At the time of the appraisal, drums were being prepared for shipment. As the drums were removed from t
60 the storage area they were sashed down, weighed, surveyed and smeared.
Each drum had been numbered as it was filled by Operations.
The operators logged the drum number, contents, initial radiation level and other data.
Following the survey, the drums were moved through the overhead door and loaded onto a trailer.
The carrier normally left a trailer onsite until it was fully loaded and ready for shipment.
This allowed greater flexibility in scheduling the loading operstion.
The licensee did not have the capability for solidifying spent resin and they did not have provisions for shipping or disposing of resin after January 1981, when the South Carolina burial site would no longer accept dewatered resin.
The licensee had contracted with a consultant to review and recommend radwaste strategies.
The study was to include onsite storage capability, solidification of resin and evaporator bottoms, review of present systems, etc.
The study was estimated sc take 8 to 9 weeks starting in early January,1981.
The licensee had made arrangements to ship the balance of their resin prior to the January 1981 cutoff date.
The licensee needs to ensure that an acceptable method of preparing spent resin for shipment and burial is available before their spent resin storage tanks become full.
For redundancy, either of two evaporators could be used to process radioactive waste.
An alternate solidification method was not availaale onsite. A licensee representative stated that they would have a minimum of four weeks to bring in a portable unit, if needed.
A shielded transport cask was available for handling and transporting spent cartridge filters to the solidification area.
The cartridge filters were placed into 35 gallon drums.
The 35 gallon drums were then placed in 55 gallon drums which previously had had concrete poured in the bottom.
Concrete was then poured around and over the 35 gallon drum to provide shielJing.
The Health Physicist responsible for radwaste calculated the activity of the filters based on the g
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61 radiation levels.
The method used to calculate the activity or obtain the radiation levels appeared to be adequate but was not incorporated into procedures. While the Appraisal Team was still onsite, a licensee representative drafted a procedure to be used to determine the activity of spent filters.
The compactor used by the licensee compacted dry trash in 96 cu. ft.
rectangular metal boxes.
The compactor ram only traveled to a depth of 13 inches above the bottom of the container.
Noncompactable trash was placed in the bottom 13 inches of the containers prior to compacting trash.
An additional storage area had been constructed onsite for interim storage of waste.
The area was fenced and centained a concrete bunker, equipped with hatch covers, that was used for storing material below grade.
The bunker drained to a sump which could be sampled and pumped to the plant rad.oactive liquid waste system.
No material had been stored in the bunker at the time of the appraisal.
The drains from the Turbine Building were pipad to a retention tank.
Samples were taken prior to cischarge and releases were monitored by Radiation Process Monitor R-21.
All potential radioactive release points from the facility appeared to be monitored.
There were no outside tanks that contained radio-active liquids.
The licensee used condensate polishing demineralizers for 100% of the flow in the secondary system.
If these demineralizers become contaminated due to a primary or secondary leak, a licensee representa-tive stated that there was a line with an outside connection through which the rasin could be discharged to a container for disposal.
62 Procedure P-9, " Precautions, limitations and Setpoints, Radiation Monitoring System," provided setpoint information for the licensee's process and area monitors.
In addition, Control Room personnel maintained graphs to show trends on area monitors R-1 through R-9 and process monitors R-10 through R-20.
Each graph indicated the alarm points associated with the monitors. When more than one type of readout was available for a monitor (meter, graph, etc.), the various indications were plotted on the same graph for comparison.
Control Room personnel also graphed the Gas Decay Tank pressures, CVCS Hold Up Tank level and Boric Acid Storage Tank concentrations and levels.
The Shift Supervisor had a schedule that indicated when periodic tests or checks were due and performed on the area and process monitors.
A daily cneck sheet that was completed once per shift included the process and area monitor alarm points.
The correct alarm points were indicated on the graphs and check sheets.
Radioactive Material Shipping Records were reviewed for selected 1980 shipments.
The shipments reviewed included Large Quantity, Type B, Type A and LSA.
The appraiser did not note any problems with the shipping record.
Shipments were made in accordance with written procedures. Quality Control Inspections were made according to Procedure QC P-21, when required by 10 CFR 71.
Information j
required for the specific burial site was contained in the procedures and included with the shipping papers.
4.3 Effluent / Process Instrumentation The calibration records from 1972 through 1980 were reviewed for the plant's process monitors.
Process monitors are calibrated annually.
Quarterly, monthly and daily checks are also required.
Documentation was not available to demonstrate that the sources that were received from a certain vendor were qualified as Derived Standards in accordance
63 with ANSI N323, " Radiation Protection Instrumentation Test and Calibration." The vendor was contacted by telephone during the appraisal and assured the licensee that the sources were calibrated against national standards. The vendor was to send confirmation to the licensee.
The procedures used to calibrate process monitors also provided for maintenance and repair. When a monitor was repaired, the procedure automatically required recalibration to complete the procedure.
The appraiser noted problems with the sample lines for Monitors R-11 through R-14, which are gaseous and particulate monitors for the Containment Building, Containment Stack and Auxiliary Building Stack.
The sample lines appeared to be properly designed and installed up to the point where the lines approached the back of the monitors.
The sample lines beyond this point contained tee's or other 90 bends on the monitor inlet and evaluations and corrections for halogen plate-out and impaction of particulate matter had not been made.
The same problem was noted for grab sample points located near the process monitors.
In addition, there were several small unplugged holes in the ventilation stacks where samples had been previously taken.
The lice nsee initiated action to plug the additional holes during the appraisal.
Tests were performed annually to determine flow rates for the various fan combinations in the ventilation system.
Conclusion Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement of the program:
64 If the ultra-filtration system is to be made permanent or used
. for an extended period of time, the location of the control panel needs to be reviewed from an ALARA standpoint.
The licensee needs to determine how they will ship and dispose of spent resin after January 1981.
The procedure for calculating the activity of spent radioactive cartridge filters needs to be formalized.
Documentation is needed to demonstrate that the radioactive sources used to calibrate process monitors meet the requirements of ANSI N323.
The use of the fittings with 90 bends on the inlet to process monitors R-11 through R-14 needs to be reviewed to determine the effect on collection efficiencies for particulates and halogens.
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65 5.0 ALARA Program 5.1 Program Establishment On December 21, 1978, the Chief Executive Officer and Chairman of the Board of Rochester Gas and Electric Corporation issued a written management commitment to ALARA entitled " Rochester Gas and Electric Corporation ALARA Policy".
In this statement, all employees involved in the design, design review and operation of Ginna Station were directed tc ensure that occupational radiation exposures were maintained as low as reasonably achievable.
The Executive Vice President was charged with the responibility and authority to assure that this policy was carried out, and the statement specified that management would review the ALARA program at least annually to evaluate implemen-tation and effectiveness.
To establish the ALARA program, the following administrative procedures were developed and implemented:
A-1.5, "ALARA Occupational Exposure," dated February 21, 1978.
A-1.6, "ALARA Committee Operating Procedure," dated April 5, 1980.
A-1.6.1, " Documentation of 'As Low As Raasonably Achievable' i
(ALARA) Program," dated February 26, 1980.
In accordance with the procedures, the licensee established an ALARA committee which meet was required to at least quarterly (and more frequently during outages) in order to:
plan activities of personnel who must enter radiation areas; f
y 4
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66 evaluate.Se actions and procedures of personnel working in such areas; and conduct post operation debriefing on projects that resulted in substantial exposures.
The Chairman of the committee was (and is) the plant superintendent.
Members included representatives from Health Physics management, Operations, Maintenance, Health Physics technician staff, Technical Engineering and Quality Control. Additionally, the Superintendent, Nuclear Operations, was designated as a regular member of this committee.
The designated RPM (Supervisor, Chemistry and Health Physics) had general responsibilities to the ALARA program as specified in Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable (ALARA)." The specific responsibilities were delegated to the Respiratory Protection and ALARA Coordinator.
5.2 Program Implementation The appraiser noted that Procedures A-1.5, * -1.6 and A-1.6.1 had been implemented and were being used to perform ALARA planning and review.
Formal ALARA reports were being developed by the Respir-atory Protection and ALARA Coordinator to evaluate the ALARA aspects of completed activities.
Additionally, efforts had been initiated to develop a data base on which to reference the existing program.
However, there were no formally established goals or objectives in place that could be utilized to measure the effectiveness of the licensee's ALARA efforts, i.e., there was no apparent system established that would indicate whether implemented ALARA efforts were resulting in personnel exposure as low as reasonably achievable.
67 At the time of the appraisal it arpesred that the licensee had excelled in the establishment and implementation of an ALARA program, and that the formation of goals and objectives on which to measure the effectiveness of the program appeared to be the next logical step in the sequence of program development.
Based on the above findings, this portion of the licensee's program appears acceptable, however, the formation of goals and objectives on which to measure the effectiveness of the program should be considered for improvement in this area.
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68 6.J Health Physics Facilities and Equipment 6.1 Facilities The facilities were modified and expanded in April 1980. The expan-sion p"avided a locker room and change facilities for women plus addit, nal locker space for men and for health physics activities.
Separate dressing / undressing areas, decontan.ination sinks, showers and friskers were provided for men and women.
The men's undressing area had two friskers plus a Hand and Fact Monitor.
Since the women's facility was not equipped with a Hand and Foot Monitor, the d
licensee's procedures required women to wash their hands after exiting from'the Controlled Access Area. According to licensee 7[
representatives, the women's facilities received minimal usage during outages and nearly negligible use during routine operation, such that a Hand and Foot Monitor was not justified in that area.
The friskers in use were thin window pancake detectors connected to count rate meters equipped with aural devices.
The friskers were located in low background areas.
The count rate meters had an alarm capability but the alarms were all set at maximum (500 cpm).
The placement of the Step Off Pad at the entrance / exit from the women's change area was somewhat ambiguous.
This was discussed with a licensee representative and he took steps to have it corrected.
A plant phone was located near the women's exit point to provide communications.
The women's decontamination shower had bags of torn anti-c clothing stacked in it.
A sewing machine used to repair clothing was located near the decontamination shower.
A licensee representative stated that personnel periodically mended the torn cluthing in this area.
Since there were no women using the facility at the time of the appraisal, and since the bagged clothing could be i
removed from the shower with little effort, the use of the shower for temporary storage of torn clothing was not considered a prdlem.
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69 The laundry facility was conveniently located in relation to dressing /
undressing areas.
Two freon solvent dry cleaning units were normally used.
In addition, two washers and two dryers were located in the facility and could be used for backup if required. A count rate meter with a beta gamma sensitive GM detector was used in the laundry to monitor the clothing.
The Chemistry and Health Physics work areas were located adjacent to the Controlled Access Area and were interconnected.
This area consisted of an office area, general work area, Count Room, Radiochem-ist,y Laboratory and Chemistry Laboratory.
The First Aid Room, Whole Body Count Room, Dosimetry / Records Area, Supervisor's Office plus the Calibration / Storage Room were in the Administration Building and were all in close proximity to the Chemistry and Health Physics work area.
The Count Room contained four scalers and two gamma spectroscopy systems.
Three of the counter scalers utilized GM tubes and the fourth was a gas flow internal proportional counter. A TN-4000 system was used with a 8.2% GeLi detector for most gamma spectroscopy counting. A Canberra gamma spectroscopy system was available for -
use with a NaI detector. The Canberra system was not routinely used.
Formal procedures had not been developed for the Canberra system since it wasn't used for analysis of required samples.
The Environmental Laboratory was contained in a trailer located onsite.
The Environmental Laboratory contained a gamma spectroscopy system, scaler and liquid scintillation counter. A TN-11 system was connected to a 23.6% GeLi detector and could be used as a backup for the TN-4000 system. The counter scaler was a gas flow internal propor-tional counter with an automatic sample changer.
70 The primary sample stations were located in the Controlled Access Area on the other side of the Radiochemistry Laboratory wall. A pass box with an interlock system made it possible for samples to be readily transferred to the Radiochemistry Laboratory with short personnel handling times. The Radiochemistry Laboratory contained sufficient sample storage space and a hood for handling samples.
The Chemistry Laboratory also provided an adequately large work area and sample storage area for routine non-radioactive samples.
The First Aid Room was exceptionally well equipped.
It consisted of three rooms which included a restroom and separate area with a bed for patient care.
An examination table was equipped with a shield and lead glass viewing port for the attending physician's use if necessary. All of the cabinets werc clearly labeled to indicate their contents.
Other equipment in the First Aid Room included an Autoclave, Pulmonor-Waterless Spirometer, two sinks, a commercial sample kit for biological samples (with instructions) and a commercial personnel decontamination kit (with instructions). A nurse is available one day per week in the First Aid Room.
The door to the First Aid Room was accessed by the use of a card reader.
The Dosimetry System and records clerks were located in a large room with sufficient space. One corner of the room was enclosed and contained the vrale Body Counter.
A room across the hall from the supervisor's office was used as a Chemistry and Health Physics storage area and as a Calibration Room.
Calibration sources included a multisource, self contained, interlockei cabinet type gamma calibrator and several smaller sources for free air irradiation at lower dose rates.
The gamma calibrator used combinations of sources plus a variable distance for adjusting the dose rates, which could range from approximately 1 mR/hr to 600 R/hr.
A circular wooden jig was used with one of the smaller sources for irradiation and calibration of pocket dosimeters and personnel monitoring badges.
A uranium slab was used for beta calibration.
71 A Hot Shop was used for storage and decontamination of contaminated tools and equipment.
The Hot Shop contained a decontamination sink, ultrasonic cleaner and automatic dishwasher.
The Spent Fuel Cask decontamination pit in the Auxiliary Building was used for large equipment decontamination. A larger ultrasonic cleaner was located in this area. A licensee representative stated that a steam cleaner had been purchased but that it had not yet been installed.
Contaminated material and equipment were stored at various locations.
With the exception of radioactive waste, there did not appear to be any facilities specifically devoted to the storage of contaminated equipment. Two areas in the sub-basement of the Intermediate Building, South, were used for storage. One area was roped off and metal containers of various items were stored there.
Adjacent to that area a chain link enclosure had been erected for storage of Eddy Current test equipment. Material wrapped in plastic was also being stored on the Operating Floor of the Auxiliary Building near the New Fuel Storage enclosure.
The plant had just completed an outage prior to the appraisal and some of the material was being stored temporar'ily in that location.
Contaminated Crevice Clean Tools that were used on the secondary side of the Steam Generators were stcred in sealed plywood boxes in the Screen House.
The tools were contam-inated but survey of the equipment indicate that the total activity was below that requiring the area to be posted.
The storage methods were adequate.
Gates for locking high radiation areas generally were equipped with slide bolts that were locked with padlocks.
It is possible that someone, thinking the gates had been inadvertently left open, could lock personnel within the area.
10 CFR 20.203(c)(3) indicates that controls for high radiation areas shall be established in such a way that no individual will be prevented from leaving a high radiation area.
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72 For some gates, such as the Waste Holdup Tank Room and Waste Evaporator Room, the slide bolt cannot be operated from the inside.
Personnel could be locked in by merely closing the bolt.
Wordin5 on a sign posted by the hatch leading to the Auxiliary Building sub-basement stated that the hatch should not be secured unless a check was made to ensure that no one was in the area.
The potential that existed for locking someone inside a high radiation area does not meet the intent of '.0 CFR 20.203(c)(3).
This item should be corrected.
Connections were provicad on the Intermediate Floor of the Intermediate Building, North, for obtaining a grab sample of the Containment Building atmosphere.
The sample connections and location appeared to be adequate for normal operation.
6.2 Protective Equipment From observations made by the appraiser, there appeared to be an adequate supply on hand of anti-c clothing, lead blankets, s terial for constructing containment enclosures, pcrtable ventilation equipment with filters and consumable supplies.
Discussions with licensee employees did not indicate problems with shortages of any of these I
items.
Containment enclosures for major work, such as Steam Generator entries, were purchased as prefabricated items.
The licensee also had the capability and material to fabricate enclosures if needed.
Disposable paper coveralls were also available when needed.
The limit set for reuse of contaminated clothing, as stated in Procedure HP-6.5, was 5 mR/hr, except for rubbers and boots, which was 10 mR/hr.
The informal limit for clothing posted in the Laundry Room was 5,000 cpm. According to a licensee representative, that level j
corresponds to 2 to 3 mR/hr and was used to ensure the clothing was kept below the upper limit.
The 5 mR/hr and 10 mR/hr limits are higher than those normally used in industry.
It is recommended that the licensee re-evaluate their limits for anti-c clothing.
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r 73 The licensee had on inventory 26 survey instruments of various types that had upper ranges of 500 R/hr to 1,000 R/hr.
Seven of these instruments were shown as out of service for repair, which left a total of 19 operating higher range instruments. The licensee's inventory also indicated 15 lower range survey instruments of various types on hand. Of this number, one was shown to be out of service for repair.
In addition, tae licensee had 9 portable area monitors, I high range underwater survey instrument, I scintillation type alpha survey meter, 3 neutron rem meters, 1 fast / slow neutron meter, 24 count rate meters, 6 ccntinuous air monitors and 17 alarm dosimeters.
A Hand and Foot Monitor and 3 Portal Monitors were also in use.
Ten additional alarm dosimeters plus 6 lower range survey meters were on order.
Six area monitors had been added since the original installation.
These were R-23 through R-28 and were associated with the condensate demineralizer system. All six of these monitors indicated a failure alarm at the time af the appraisal.
A licensee representative stated that the problem was caused because the monitors were in low background areas and the monitors had fixed low level failure alar-points. A trouble ticket had been turned in but no solution had been proposed or implemented.
This problem needs to be resolved.
Even though the monitors had been verified to be functioning properly, the continued operation with the " failure" light on can cause personnel to tend to disregard the alarm condition.
The licensee had a mockup of the primary side of a Steam Generator for use in training.
Eddy Current testing, brazing and the use of explosive plugs (including detonation) were practiced in the mockup.
The same type of video equipment was used in the mockup that was used in actual work. Other smaller mockup devices were available in the room for use in discussing the details of various jobs prior to a dry run in the Steam Generator mockup.
74 In the course of the review, the appraiser examined the licensee's efforts in implementing the requirements specified in NUREG-0578, TMI-2 Lessons Learned Task Force Status Report And Short, Term Recommendations, as clarified by the letter TO ALL OPERATING NUCLEAR POWER PLANTS, from the Director, Nuclear Reactor Regulation, dated October 30, 1979 (Item 2.1.8.b, " Increased Range of Radiation Nenitors").
While it was evident that the licensea had mcde efforts to implement the requirements in a manner that was technically reasonable, the method was not well suited for the intended application.
The method involved the use of a portable instrument, minimally shielded, positioned approximately 20 feet perpendicularly from the plant vent header Procedures, calibration and a calculational system were developed to use this arrangement to meet the 2.1.8.b requirements.
However, the appraiser noted that in the configuration, there was no overlap between the installed noble gas monitoring system and this interim high range capability, i.e., in the post-accident condition, the installed instrumentation would be off scale by several orders of magnitude before the high range device would begin to measure radiation from the vent header. Also, it was noted that without sufficient shielding, there was no way to reliably estimate the effect of background radiation on the detectors and subsequently j
the release rate of noble gas activity.
In accordance with an Immediate Action Letter, dated December 19, 1980, the licensee committed to reinstall, by December 33, 1980 the instrumentation in closer proximity to the plant vent, to recalibrate as necessary, and to install sufficient lead shielding to mitigate i
the effect of background radiation on the detector. Additionally, Crom the Procedure PC-23.3, " Estimation of Noble Gas Release Rates Plant Vent During Accident Conditions," was to be revised to provide more specific user information for estimating noble gas release rates.
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75 Conclusion Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement of the program:
Steps need to be taken to assure that personnel cannot be inadvertently locked in high radiation areas.
The radiation limit for reusing anti-c clothing should be re-evaluated to determine if there is a sufficient basis for continuing with the current limit.
Corrective action needs to be taken in order that the failure alarms on area radiation monitors R-23 through R-28 fulfill their intended function.
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ANNEX _A Exit Meeting and Li:ensee Commitments e
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ANNEX A i
Exit Meeting and Licensee Commitments i
The appraiser met with the licensee representatives (denoted in Annex B) on 1
December 19, 1980, to discuss the scope and findings of this appraisal.
In the course of that meeting, the following particular areas were discussed:
a.
Licensee's actions relative to NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Rec,mmendations."
b.
Licensee actions relative to upgrading the emergency response capability.
In both these cases, the licensee agreed to perform corrective actions as identified in the Immediate Action Letter from B. H. Grier, Director, NRC Region I, to J. E. Maier, Vice President, Rochester Gas and Electric Company, dated December 19, 1980.
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ANNEX B Persons Contacted
ANNEX 8 Persons Contacted i
1 Mr. J. E. Maier, Vice President, Electric and Steam Production Mr. B. A. Snow, Plant Superintendent Mr L. S. Lang, Superintendent, Nuclear Production Mr. R. J. Watts, Corporate Health Physicist Mr. J. C. Noon, Assistant Plant Superintendent Mr. D. Filkins, Supervisor, Chemistry and Health Physics Mr. E. Demeritt, Emergency Planning Coordinator Mr. E. Gordon, ALARA/ Respiratory Protection Coordinator Mr. R. Marchanda, Assistant Training Coordinator Mr. W. Goodman, H2alth Physics Foreman Mr. R. Zimmerman, NRC Resident Inspector Mr. F. Mis, Radwaste/ Transportation Coordinator Mr. B. Quinn. Health Physics Operations Foreman Mr. R. Morrill, Training Coordinator Mr. R. Burt, Health Physics Technician Mr. D. Filion, Radiochemist denotes personnel attending the HP Appraisal exit meeting on December 19, 1980.
In addition, several other members of the licensee's staff were contacted including technicians, operators and maintenance personnel.
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CORPORATE AND GINNA STATION ORGANIZATION AS REGARDS RADIATION PROTECTION A
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