ML20039E544
| ML20039E544 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/22/1981 |
| From: | Bland J, Carroll R, Hadlock D, Neely D, Galen Smith Battelle Memorial Institute, PACIFIC NORTHWEST NATION, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), TERA CORP. |
| To: | |
| Shared Package | |
| ML20039E539 | List: |
| References | |
| 50-334-81-05, 50-334-81-5, NUDOCS 8201110014 | |
| Download: ML20039E544 (97) | |
Text
..
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION T Report No.
81-05 Docket No.
50-334 License No.
DPR-66 Priority Category C
Licensee:
Duquesne Light Company
)
435 Sixth Avenue Pittsburgh,. Pennsylvania 15219 Facility Name:
Beaver Valley Power Station, Unit 1 Appraisal At:
Shippingport, Pennsylvania Appraisal Conducted-Februaryj23 - March 6, 1981 h/
/2 /t/ //
Team Members:
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e'ely,~In'sp cti D5pe.cialist date g
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A J. /S.
land, Health Py cist, NRC HQ
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R.,_G.
- rroll, ni 7 ealth Physicist,
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(E dvance.
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[D P cif'fadlock, ite' search Scientist, Battelle ct D.
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date a
ic Northwest Lab atories (PNL)
/2.///f /
Approved by:
G. H.
m1@, DfreNor, Divi'ston of Emergency
/date Prepa edness and Operational Support 8201110014 811223 PDR ADOCK 05000334 G
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^
TABLE OF CONTENTS l
Page Summary..
y l
1.0 Organization, Responsibilities, Staffing and Management Oversight.
1 l
1.1 Documents Reviewed.......................
1 1.2 Organization Description...........
2 1.2.1 Beaver Valley Unit 1 Organization..........
2 j
1.2.2
.Duquesne Light Corporate' Organization........
3 1.3 Responsibilities.......................
3 1.3.1 Beaver Valley Station'Responsibilitias.......
3
-1.3.2 Duquesne Light Corporate Responsibilities.....
6 1.4 Staffing...........................
7 1.4.1 Beaver Valley Unit 1 Staffing...........
7 1.4.2 Duquesne Light Company Corporate Staffing.....
8 1.5 Management Oversight.
9 1.5.1 Review and Audit.
9 1.5.2 Communications...................
10 1.6 Conclusions.......
10 2.0 Personnel Selection and Qualification (Training)..........
11 2.1 Documents Reviewed.......................
11 2.2 General...........
11 i
~2.3 Selection and Qualification Criteria..............
12 2.4 Training Program.....
14 l
l 2.5 Conclusions..........................
16 i
i l
l
-Table of Contents-p Page 16 j
1 l
3.0 ' Exposure Controls.........................
i i
i I
3.1 External Exposure Control..................
'16 l
3.1.1 Documents Reviewed.................
15 I
l 3.1.2 General.......................
18
]
3.1.3-External' Dosimetry Program.
.18 3.1.4 Exposure Review....................
21 3.1.5 Exposure Limitation.
21 3.1.6 Quality Assurance Program.
22.
i 3.1.7 Conclusions..........
23 3.2 Internal Exposure Controls................... 23 3.2.1 Documents Reviewed..................
23-3.2.2 General.......................
24 3.2.3 Internal Dosimetry Program.
24 l
3.2.4 Internal Exposure Review..
26 l
(
3.2.5 Internal Exposure Limitations '...........
26 1
3.2.5.1 Administrative Controls.........
26 3.2.5.2 Respiratory Protection.
27 3.2.5.3 Engineering Controls..........
32 3.2.6 Quality Assurance..
33 3.2.7 Conclusions...................
33 3.3 Surveillance Program.
34 3.3.1 Documents Reviewed................
34 3.3.2 Surveillance Program Implementation........
40 3.3.3 Instrument Suitability and Use...........
49 11
Table of Contents L
Page 3.3.3.1 Portable Radiation Monitoring Instrument.
49 j
F 3.3.3.2 Analytical Instrumentation........
49 l
3.3.4 Conclusions.....................
55 4.0 Radioac'.ive Waste Management.
58 i
4.1 Documents Reviewed......................
58 l
4.2. Program Responsibilities...................
59 4.3 Waste Processing Systems..........
60 4.3.1 Li q u i d Wa s te Sy s tem s................
61 4.3.2 Solid Radioactive Waste System.
66 4.3.3 Gaseous Radioactive Waste System..........
67 4.4' Effluent / Process Instrumentation........
68 4.4.1 Liquid Monitoring System..
68 4.4.2 Gaseous Monitoring System...
70 4.4.3 Monitor Calibration...
71 4.5 Solid Waste Disposition.
72-4.5.1 Program Implementation.........
72 4.5.2 Quality Assurance Program...
73 e
4.6 Conclusions.........................
'4 7
5.0 A LA R A...............................
75 l
l 5.1 Documents Reviewed......................
75 5.2 Program Establishment.
75 5.3 Conclusions.........................
77 6.0 -Health Physics Facilities and Equipment.
78 6.1 Facilities.........................
78 111
(
A ~
.TableDof Contents;
-Page s
6.1.1 Radiation Protection...............
178 -
6.1.2 Chemistry......
81 h-6.2; Protective Equipment.
82 i
6.2.1 Anti-Contamination Clothing...........
82 6.2.2 Shielding....................
82 i
S 6.2.3 Containment Materials..............
82 6.2.4 Portable Ventilation Systems..........
82' 4
6.3 ' Conclusions........................
82 j
7.0 Exit Interview-...............
83
. ANNEX A Persons Contacted-l ANNEX B Organization Charts s
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SUMMARY
The Special Health Physics Appraisal was conducted during the period February 23 - March'6, 1981, to evaluate the overall adequacy and effectiveness of the Beaver Valley Power Station, Unit.1, radiation protection program. At the time of the appraisal, the Beaver Valley facility was shutdown for maintenance purposes.
The Appraisal Team consisted of one inspector from Region I, Office of Inspection and Enforcement, one inspector from Headquarters, I&E and two employees of Battelle Pacific Northwest Laboratories. The appraisal included observations of work practices, review of selected procedures and records, and interviews of Duquesne Light Company personnel. The scope of the appraisal included:
Radiation Protection Organization and Management Personnel Selection, Qualifications and Training Exposure Controls (Internal and External)
Radioactive Waste Management ALARA Program Facilities and Equipment Management Oversight Results of the special health physics appraisal indicated that significant weaknesses existed in the radiation protectien and radioactive waste management programs. Weaknesses were identified in the areas of organization and management (Section 10) personnel selection, qualifications and training (Section 2.0);
internal exposure control (Section 3.2), surveillance (Section 3.3); radioactive waste management (Section 4.0); and facilities and equipment (Section 6.0).
v
1.0 Organization, Responsibilities, Staffing and Management Oversight 1.1 Documents Reviewed a.
Letter dated January 19, 1981 from Stanley G. Shafer,- President, Duquesne Light Company to Boyce H. Grier, Director, Region I-NRC.
b.
Systematic Assessment of Licensee Performance - Beaver Valley Power Station - Region I Evaluation Board Meeting.
c.
Proposed change to Beaver Valley Technical Specifications, Appendix A and Appendix B, dated January 17, 1980.
d.
Beaver Valley Training Organization (Proposed), dated January 1981.
e.
Quality Assurance Procedure OP-3, Revision 5.
f.
Quality Assurance Department 1980 Audits:
BV-1-80-01, " Nuclear Services Quality Control," 4/7/80 BV-1-80-04, " Service Organizations," 2/19/80 BV-1-80-05, " Training," 2/19/80 BV-1-80-09, " Chemistry," 3/24/80 BV-1-80-19, " Solid Waste Program (Barnwel')", 6/5/80 BV-1-80-26, " Compliance to License Conditions (ORC)," 6/30/80 BV-1-80-29, "Offsite Review Committee," 8/12/80 BV-1-80-30, "Onsite Safety Committee," 9/22/80 BV-1-80-33, " Operations," 8/28/80 BV,-80-34, "RADCON" BV-1-80-35, "Nonconfornance Control," 8/25/80 BV-1-80-43, " Effluent Monitoring," 11/12/80 g.
Quality Assurance Procedure OP-2, Revision 4 h.
Station Administrative Procedure, Chapter 10, "0nsite Safety Committee,"
Revision 1 1.
Technical Specification 6.5.2, "Offsite Review Committee"
2 j.
Offsite Review Committee Audit Report 79-3-T, " Audit of Performance, Trr:ning and Qualifications," dated November 5, 1979.
i-k.
Offsite Review Committee (ORC) Audit Report 80-2-0, " Audit of Compli-ance to Technical Specifications," dated April 15, 1980.
L t
1.
Offsite Review Committee Audit Report 80-3-0, Audit of Fire Protection and Loss Prevention Program," dated April 8, 1980.
m.
Memorandum dated April 3,1980 to J. J. Carey, Chairman ORC, from R.
l J. Washabaugh,
Subject:
ORC Sponsored Audits.
l n.
Memorandum dated April 16, 1980 to J. J. Carey from J. D. Sieber, i
Subject:
Transfer of ORC Audit Activities to QA Department.
l o.
Minutes of Offsite Review Committee dated September 17, 1980.
p.
Minutes of RADCON Supervisers meeting dated May 10, 1980.
q.
Minutes of RADCON Staff meeting dated May 17 and June 4,1980.
r.
Memorandum dated January 20, 1980 from J. A. Kosmal to J. A. Werling,
Subject:
Status of RADCON Group Activities and Required Actions, s.
Memorandum dated December 11, 1980 from J. A. Kosmal to J. A. Werling,
Subject:
1980 Objectives Quarterly Status Report - Fourth Quarter -
RADCON.
1.2 Organization Description l
1.2.1 Beaver Valley Unit 1 Organization The Beaver Valley Unit 1 Radit. logical Controls Department Organiza-tional structure in place at the time of the appraisal is depicted.
in Annex B, Figure 1.
The auditors noted that the organization depicted in this chart is substantially different from that depicted in Figure 6.3 of the existing Unit 1 Technical Specifications. The auditors were informed by licensee representatives that a proposed change (Amendment Request No. 45) to the Technical Specifications reflecting the current offsite (corporate) and facility organizations was submitted to the Office of Nuclear Reactor Regulation on January 17, 1980. The auditors noted that the current onsite organization was consistent with the one depicted in the Beaver Valley Power Station Administative Procedure, Chapter 2, " Station Organization and General Instructions," Revision 0.
3 The major differences between the proposed organizatiorial structure and the one depicted in the existing Technical Specifications is that the Radiation Control Supervisor (Radiation Protection Manager:
defined in Regulatory Guide 1.8) reports directly to the Beaver Valley Station Superintendent. The auditors noted that this organiza-tional arrangement meets the recommendations specified in Regulatory Guide 8.8, Section c.l.b.c, which states, "The Radiation Protection Manager (RPM) (onsite) has a safety-related function and responsibility to both employees and mananagement that can best be fulfilled'if the individual is independent of station divisions, such as operations, maintenance, or technical support, whose prime responsibility is continuity or improvement of station operability."
The auditors consid.r the current reporting level for the RPM to be adequate to provide the direct access to the Station Superintendent and level of communication and authority comparable to operations and maintenance which is necessary for him to carry out his radio-logical control functions.
1.2.2 Duquesne Light Corporate Oroanization The Beaver Valley Station Radiological Controls Department receives health physics engineering support from the offsite organization depicted in Annex B, Figure 2.
The functional position of "Superin-tendent of Licensing and Compliance" is responsible for the supervision j
of the overall radiological control program for the Power Stations Department.
Specific program support responsibilities are discussed further in Section 1.3.2.
1.3 Responsibilities 1.3.1 Beaver Valley Unit 1 Organization The organization and responsibilities of key station personnel is set forth in Station Administrative Procedure, Chapter 2, " Station Organization and General Instructions," Revision 0.
Section IV.F of the procedure specifies that the Radiation Control Supervisor reports to the Superintendent Nuclear and is responsible for the implementa-tion of the station radiological control program to ensure that exposures to station personnel, contractors and visitors are maintained as low as reasonably achievable.
He is charged with responsibility for radioactive source control, the radiological aspects of nuclear shipments leaving the site and the calibration of radiological monitoring equipment. The Radiation Control Supervisor (Radiation Protection Manager) is also a member of the Onsite Safety Committee.
Station Administrative Procedure, Chapter 6, " Radiological Control Group Administration," Revision 2, sets forth the organization, responsibilities, and functions of the onsite Radiological Control Group, with the exception of the Radiation Control Supervisor and the Radiation Control Technicians.
I, i
4 f
Professional and supervisory staff functional reponsibilities were spectfled as follows:
l
_ Radiation Control Engineer (RCE) - The Radiation Control Engineer I
reports to the Radiation Control Supervisor; and, in the absence of the Supervisor, the Radiation Control Engineer is responsible for directing the Radiation Technician work force through the Radiation Control Foreman.
in the absence of the Foreman, the Radiation Control Engineer may supervise the work force.
In addition, he will review procedures concerning both upcoming i.
and completed work in radiation areas to ensure exposures are l
maintained ALARA. He will assist with the preparation of required reports and participate in the calibration of the Radiological Monitoring System. He will also assist the Radia-tion Control Supervisor in implementing the station Radiolog-ical Control Program.
Radiation Control Foreman (RCF) - The Radiation Control Foreman reports to the Radiation Control Supervisor and is reponsible for the direct supervision and coordination of the functions of l
the Radiological Control Group. He prepares work schedules and l
makes daily activity assignments and is responsible for ensuring that work is accomplished in accordance with the BVPS-RCM. The i
Radiation Control Foreman assists the Radiochemist in laboratory and counting room training of Radiation Technicians. As necessary, he administers general training and radiation safety programs to both personnel under his supervision and station personnel in general.
Associate Engineer (AE) - The Associate Engineer reports to the Radiation Control Supervisor. He may perform special studies l
related to radiation exposure, the Radiation Monitoring System, effluent releases, or similar subjects. He is responsible for ordering parts, and equipment for the Radiological Control Group and maintaining, in the proper station 1ocations, adequate forms and records for radiological control ' activities.
The authorities and responsibilities for the Radiation Control Technicians (RCT) are defined in the RADCON Manual, Appendix 1, l
"RADCON Administrative Guide," Issue 2.
The RCT responsibilities and authorities are specified as follows:
The Radiation Technicians are under supervision of the Radiation Control Foreman. While in the Radiochemistry Laboratory or Counting Room, they are also under the supervision of the Radiochemist. The Radiation Technicians are responsible for:
a.
Familiarity and compliance with the policies, procedures and limits of the Radiological Control Manual.
l 5
b.
Proper performance of routine and special radiological monitoring surveys, and calibrations and the appropriate neat recording and careful retention of this data.
c.
Preliminary evaluation of data and the reporting to appropriate supervision of unusual or above limit radiological conditions.
d.
Ensuring radiological safety by monitoring equipment and methods used by the radiation worker.
If necessary, the Radiation Technician is responsible for stopping work and evacuation of personnel to a safe area. They will notify Radcon Supervision and/or the Shift Supervisor immediately. The situation will be evaluated by Supervision.
e.
Training new station personnel in the standard radiological control orientation.
f.
Duties as described in the Duquesne Light Company job description J
for Radiation Technicians.
RADCON Procedure, Appendix 1 also addresses overall administrative rules of practice which include the following areas:
]
Interface with other station groups Control room conduct Communications with other plant' personnel Log entries, chart marking, rr 'ti and forms Conduct of maintenance Purchasing Shift responsibilities Procedure at shift change Field office responsibilities Laboratory chemistry Counting room Based on a review of the above documents and interviews with plant personnel the auditors determined that sufficient authority has been delegated to the RCT for "stop work" in the event that unexpected radiological conditions or violation of procedures are encountered.
k 6
Job descriptions provided by licensee representatives were reviewed for the staff members of the Radiological Control Group and compared to duties and responsibilities described in above mentioned procedures.
Also, job descriptions were compared to the functional positions in place at the time of the appraisal.
The following job descriptions were provided to the auditors for review:
Radiation Control Supervisor ALARA Specialist Radiation Control Foreman Radiation Control Engineer Radiation Technician The auditors identified the following descrepancies as a result of the review of job descriptions and the compatability with the current Radiological Control Group depicted in Annex B, Figure 1:
The functional position of Radiation Control Foreman was actually being implemented by four individuals who were assigned separate specific duties and responsibilities. The functional areas assigned included the following:
Foreman in charge of personnel dosimetry Foreman in charge of records and reports management Foreman in charge of instrument calibration and maintenance (portable and effluent monitors)
Foreman in charge of the operational health physics program (i.e. exposure control, surveillance, counting systems, radwsste shipping, etc.)
Based on interviews with station radiological personnel and contractor supplied health physics personnel it was determined that individual were functioning within their assigned areas even though formally documented job descriptions which accurately defined their duties and responsibilities did not exist.
i 1.3.2-Duquesne Light Corporate Responsibilities The authorities and responsibilities for the corporate element of the Duquesne Light Company Nuclear Power Stations Department is set forth in Section 2.3.2.4 of Quality Assurance Procedure OP-2, Revision 4, " Organization and Responsibilities." The Superintendent of
7 Licensing and Compliance functional position depicted in Annex B, Figure 2, has been delegated authority for supervision of the overall radiological control program for the Power Stations Department.
The proposed Technical Specification amendment No. 45 includes the Superintendent of Licensing and Compliance as part of the Offsite Review Committee.
In carrying out his responsibilities the Superintendent of Licensing and Compliance has a Health Physicist and on ALARA Specialist. ' Job dascriptions exist for both positions and appear to adequately address their duties and functions.
The Health Physicist is mainly charged with planning, analyzing, and performing evaluations' of the Duquesne Light Company Nuclear Power Stations health physics and environmental programs. He also provides technical assistance to the station radiological controls organization; serves on audit and review committaes of the nuclear power stations in the areas of health physics; evaluates the effectiveness of the station's ALARA program; and plans the h--Ith physics program and reviews changes to the nuclear power sta
.n's health physics manuals.
The ALARA Specialist plans, analyzes, and performs evaluations of the departmental ALARA program.
In doing so, participates in planning, development and inital preparation of the power stations ALARA program; participates in design reviews for facilities and equipment; assists the station in developing and implementing an exposure control program; reviews and provides input into training programs related to radiation areas or radioactive materials; assists in the preparation of station procedures to implement the power stations ALARA program; assists in integrating management philosophy and regulatory requirements, along with goals and objectives into the ALARA programs; and assists in developing effective methods of data and information collection for use in analysis and evaluation of ALARA practices.
1.4 Staffing 1.4.1 Beaver Valley / Unit 1 Staffing The Radiological Controls Group was staffed as follows:
Title Number of Individuals Radiation Control Supervisor (RCS) 1 Radiation Control Engineer (RCS) 2 (2)*
Radiation Control Foreman (RCF) 8 (4)*
Associate Engineer (AE) 4 (3)*
Radiation Control Technician (RT) 37 (31)*
Record Clerk 1 (Part Time)
- Filled by contractors
8 During normal operations the Radiological Controls Group provides continuous health physics coverage in support of plant operations, surveillance and maintenance.
This coverage is comprised of three alternating eight hour shifts. The back shifts consist of two contractor supplied RTs and one contractor supplied RCF. The day shift coverage consists of both contractor and station health physics personnel, the majority being contractor supplied personnel.
Senior level management in response to previous NRC concerns regarding the heavy reliance on contractor health physics personnel has committed to a long term plan for improvement in this area.
In a letter to Mr. B. H. Grier, Director, Region I, NRC from Mr. Stanley G. Shafer, President, Duquesne Light Company, dated January 19, 1981, initial action steps planned or already started to review and evaluate the necessary manpower levels for the Beaver Valley Station were described.
The licensee has already made an effort to decrease the number of contractor Radiation Control Technicians by implementing a program to train Duquense Light Company employees to be Radiation Control Technicians. There were approximately 14 individuals enrolled in the company training program at the time of the appraisal.
Licensee representative's plan to continue this training program until Duquesne Light Company personnel replace the contractor staff. The auditors noted that it would take at least two years before the present trainees would be qualified in accordance with current qualifications standards, but that these individuals could participate in the.
radiological controls program under strict supervision (on-the-job training) until such time as they became qualified.
The auditors noted that the turn over of contractor heal;h physics personnel during the last year or so was small in number due to the fact that the station management appeared to be selective in who they retained and that most of the contractor s lived locally. Also, the contractor staff was afforded the same training and re-training program that Duquense Light Company were receiving. The auditors did not, however, see an all out effort to obtain supervisory and professional type individuals.
1.4.2 Duquesne Light Company Corporate Staffing The corporate element staffing presently consists of one department manager, one health physicist and an ALARA Specialist. The auditors discussed future staffing plans with licensee representatives who indicated that plans were being made for combining the expertise of the station and corporate radiological controls groups. They indicated that it should be adequate to handle the technical and operational support functions of the Beaver Valley Station.
Planned staffing would consist of approximately 80-90 individuals.
I
9 1.5' Management Oversight 1.5.1 Review and Audit Radiation Control Supervisor Reviews The Radiation Control Supervisor maintains awareness of the radio-logical controls program by several means. He is directly involved in day-to-day implementation of the program.
He reviews on a daily basis, the following records:
Rad Con Deficiency Log Rad Con Foreman Daily Reports Personnel Monitoring Reports Radiation, contamination and airborne survey data.
The Radiation Control Supervisor is also a member of :.he Onsite Safety Committee and is routinely involved in reviewing procedures (revisions or ncw) involving an impact on radiological safety. The auditors noted that the Radiation Control Supervisor should remove himself from deep involvement in program details but should be able to standback and assess the overall implementation of the program.
By not being so the close to the program the Radiation Control Supervisor would be better able to identify and evaluate radiation 1
control problems and determine root causes of radiation protection incidents.
Quality Assurance Audits Early in 1980 the Duquesne Light Company Quality Assurance Department began performing audits required by Technical Specifications 6.5.2.8.
In the past this was done by the Offsite Review Committee. The Quality Assurance Department has been delegated to perform these required audits under the cognizance of the Offsite Review Committee.
The auditors reviewed the records of those audits referenced above in Section 1.1 and determined that the audits appeared to lack sufficient depth and only addressed specific procedural requirements.
Only one audit appeared to utilize personnel with health physics experience; Audit No. BV-1-8-43, " Effluent Monitoring".
Quality Assurance audits required by 10 CFR 71 with respect to the Radioactive Waste program was given little attention. Only one audit was done in 1980, No. BV-1-80-19, which was performed at the waste burial site in Barnwell, S.C. (This is discussed further in Section 4.5.2.)
-10 Corporate or Contract Audits-Formal audits of technical adequacy and program effectiveness by the corporate element are essentially non-existent. A formal audit program has not been established. A recent audit was done by a corporate radiological control staff member on a very informal basis, with no follow-up improvements required.
1.5.2 Communications Based on interviews with staff personnel it appears that communciation paths are adequate. This is achieved by frequent meetings between the Radiation Control Supervisor and members-of his staffs usually on a weekly basis. The Radiation Control Supervisor appears to have a clear communciation path between himself and the Superintendent, Nuclear. The Radiation Control Supervisor keeps the Superintendent, Nuclear informed of the Radiological Control Group's activities by submitting a " Weekly Goal" status report. Also, the Superintendent, Nuclear is provided a quarterly report describing the status of planned objectives.
1.6 Conclusions Based upon the above findings, improvements in the following areas are required to have an acceptable program:
1.
Management attention should be increased in making further efforts to become less reliant on contractor health physics personnel and actively recruit technical, supervisory and technicians to establish a more permanent staffing level.
2.
Job / Position descriptions currently in existance should be upgraded to reflect actual duties and responsibilities assigned to the Radio-logical Control Group staff members. Also, RADCON procedures describ-ing specific functional responsibilities should be compared to proposed or existing job descriptions for consistency.
3.
The Quality Assurance Department should re-evaluate their audit procedures / plans and assure themselves that audits are being accom-plished to identify programatic problems, in addition to satisfying regluatory requirements.
Other areas of the organizational and management aspects of the health physics function appear acceptable, however the following should be considered for improvement:
1.
Establish a biennial review by the ORC or the corporate radiological controls element, utilizing qualified health physics individuals, to perform a comprehensive evaluation of the radiation protection and radioactive waste program management and performance.
I
11 2.0 Personnel Selection and Qualification (Training) i 12. 1 Documents Reviewed I
a.
RADCON Manual, " Appendix 1, Part III - Organization and Responsibil-ities,". Revision No. 1.
b.
Beaver Valley Power Station Training Manual; Section 1.1, " Power Stations Indoctrination Training," Issue 1, January 2, 1975.
Section 1.2, " Station Orientation Training," Issue 1, January 2, 1975 Section 3.1, " Radiation Technician Training," Revision No. 3, January 29, 1981.
Section 3.2, "Requalification Training for Radiation Technician,"
Revision No. 3, January 29, 1981.
Section 3.3, " Radiation Worker Training," Revision No. 2, October 24, 1977.
Section 3.4, " Radiation Worker Training Continuing," Revision No. 2, October 24, 1977.
Section 3.5, " Radiation Technician Training - Beaver Valley,"
Revision No. 3, January 29, 1981.
Section 4.1, " Chemist's Training," Revision No. 1, July 20, 1977.
Section 4.2, " Chemical Analyst Training," Revision No. 1, July 20, 1977.
Section 10.1, " Respiratory Protection Program," Revision No. O, October 21, 1977.
c.
RADCON Procedure No. 11.3, " Radiation Worker Training," Issue 1, March 24, 1975.
2.2 General Health physics duties are performed jointly by licensee and contractor personnel in the RADCON Department (RCD). The licensee's personnel selection, qualification, and training program for the RCD was developed for these two groups.
12 2.3 Selection and Qualification Criteria The selection and qualification criteria for licensee RT's are outlined in a formal Duquesne Light Company job description. This document contains-duties and qualifications for senior technicians as recommended by ANSI-18.1 1971.
Formal job descriptions do not exist-for outlining duties and/or qualifications for contractor Radiation Control Technicians or licensee's Junior Radiation Control Technicians (ANSI-18.1 1971).
The duties and qualifications for selected RCD management and technical support personnel are contained in the licensee's job description. The positions outlined are:
Radiation Control Supervisor, Health Physicist, ALARA Specialist, Radiation Control Engineer, and Radiation Control Foreman. The positions of Radiation Control Associate Engineer and Dosimetry Records and Evaluation personnel (including management) are not formally addressed in this document.
The auditor evaluated the selection and qualification criteria in the hiring and advancement process by reviewing the personnel files (resumes) of all iicensee and contractor RCD staff members.
It was observed that the selection and qualification criteria for licensee Radiation Control Technicians were consistent with ANSI 18.1-1971. At the time of the appraisal, there were a total of six Duquesne Light Company Radiation Control Technicans, all of whom were qualified as Senior Level Technicians per ANSI-18.1-1971. However, the auditors noted that not all of these six technicians met the qualification criteria in the formal Job Descrip-tion which states:
"A Degree in Associate Engineering or equivalent from an accredited school or a minimum of two years of college level work at an accredited school in Engineering, Physics, or Chemistry."
In the view of the auditors, the licensee needs to either hire personnel who meet this requirement or modify the formal selection criteria (job descriptions).
In addition, the Radiation Technician job description does not discuss junior level (ANSI 18.1-1971) licensee technicians or contractor supplied technicians.
The RADCON Supervisor and the Training Supervisor stated that all contractor resumes were reviewed and that the results of written tests and individual interviews were evaluated to verify that ANSI 18.1-1971 guidelines were met for contractor radiation technicians. At the time of the appraisal there were thirty-one contractor Radiation Technicians employed by the licensee, and they were determined by the auditors to meet the experience requirements specified in ANSI 18.1-1971.
In the view of the auditors, a formal job description or procedure should be established, defining measurable education and exper-ience factors used in the selection of contractor and junior level licensee radiation technicians. This procedure should also outline conditions to be met for the advancement of a junior level technician to a senior level technician.
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13 The selection and qualification criteria used by the licensee for RCD management was found to be consistent with ANSI 18.1-1971 and Regulatory Guide 1.8 as shown below:
RADCON Supervisor 16 years health physics experience Six' years as Health Physicist
' Associate Degree in Quality Assurance Health Physicist 16 years health physics experience B.S. in physics RADCON Foreman Four years experience in health physics Associate degree in Electrical Engineering Four years experience in health physics 10 years experience in health physics Five years experience in health physics RADCON Engineer 16 years experience in health physics B. A. in chemistry M. A. in health physics However, the auditor noted that the formal job descriptions for these positions did not reflect the qualifications required and used by the licensee for health physics positions. As an example, the job description for the RADCON Engineer requires the following:
A bachelor of Science Degree in Mechanical or Civil Engineering Should have two years experience related to structural design engi-neering and/or sheet metal fabrication.
In the view of the auditors, the licensee needs to update the above job description to reflect current practice, specifically, as it relates to health physics requirements.
-14 The auditors noted that formal job descriptions did not exist for all positions. Associate Engineers are utilized within the RCD to perform various functions.
It was stated by the RADCON Supervisor that a formal-job description did not exist for the Associate Engineer position because their duties depended upon the needs of the licensee. The Exposure Records Clerk position also lacks a formal job description. This clerk is supplied from a secretarial pool, on an as needed basis.
In the view of the auditor, formal job descriptions should be established.for these positions and they should be staffed with permanently assigned personnel.
2.4 Training Program.
The Beaver Valley Power Station health physics training program consists of six categories:
station orientation training (given initially to all station personnel); radiation worker training; radiation worker requalif-ication training; initial radiation technician training; requalification training for radiation technicians (given by the training department and the RCD); and respiratory protection program training.
The station orientation training is given by the Training Department to all new station employees.
This training consists of a video tape supple-mented by lectures on radiological fundamentals, station security, emerg-ency plan, QA/QC, and other subjects that are site specific.
l The radiation worker training is given by the Training Department to all personnel expected to perform work within radiation areas. This training utilizes videotapes but relies mostly on classroom instruction and demon-stration according to the following site specific outline:
Definitions Sources / Types of Radiation ALARA Exposure Limits l
Pre-natal Exposure, Biological Effects Time / Distance / Shielding Radiation / Contamination Posting Dosimetry /Whole Body Counti1g Protective Clothing l
Respiratory Protection The same format is used for licensee and contractor personnel.
Course duration is one day. The morning consists of a classroom lecture followed by a thirty-seven question test.
In the afternocn session the students are required to perform hands-on demonstration of the subject matter covered in the morning session.
The radiation worker requalification training is administered by the Training Department. This training consists of one-half hour video tapes which are shown at regular intervals.
15 Health physics training for licensee and contractor radiation technicians is provided by the Training Department. This program consists of classroom /
practical training, equipment familiarization, review of the radiological control manual, and training in emergency procedures.
A check list is provided_for licensee and contractor technicians with the date each item in the program is completed.
In addition, the Training Department also administers a one year on-the-job training program in health physics for the purpose of qualifying individuals as junior level radiation technicians.
Requalification training for radiation technicians is conducted on a continuing basis for all qualified personnel over a two year period by d
the Training Department. An annual exam is used to determine the amount of training required.
In addtion, a continuing health physics training program is administered by the RCD for licensee and contractor Radiation Technicians.
The respiratory protection training consists of classroom lectures plus hands-on instruction followed by a respiratory fit test. An exam applicable to respiratory protection does not exist and the exam given for the radiation worker training does not contain any questions relating to respiratory protection.
This training is discussed in detail in Section 3.2.3.2.1. A, " Respiratory Protection Program" of this document.
Health physics training for selected members of the Chemistry and Operations Departments is providad by the Training Department. This training is based on the need of these personnel to perform self monitoring.
Training Program The auditors reviewed training records for all RCD staff members and Training Department Health Physics Instructors, plus selected records of maintenance, operations, chemistry, and site management personnel.
In addition to the review, various members of the RCD were interviewed to determine the adequacy of the licensee's Health Physics Training Program.
It was observed by the auditors that the content, scope, frequency, and technical depth of the training performed by the RCD and the Training Department was adequate. This includes the general employee, radiation worker, and radiation technician training.
The use of hands-on training for frisking techniques, step-off pad (SOP) procedures, donning / removing protective clothing, and the proper use and wearing of respiratory protection was very good. This training utilized mock-up radiation / contamination zones with each student performing the various functions under the instruc-tor's observation. During interviews with various staff members, it was noted that licensee policy was to require the demonstration of skills attained before using these skills in the field.
The exception to this involved deficiencies in the maintenance of respiratory protective equipment which is discussed in Section 3.2.3.2.1.A, " Respiratory Protection Program" of this document.
16 The auditors noted that even though the overall training program is good, the health physics training provided to selected members of the RCD needs improvement.
These positions include the RADCON Supervisor, Foremen, Engineers, Associate Engineers, and the Health Physicist.
The deficiencies were noted to be the content and technical depth of the training received.
Presently, these staff members do not receive any more training in health physics then is given to radiation workers.
In interviewing staff members and reviewing personnel folders it was noted that.the Health Physicist is the only RCD Management staff member to recently attend courses, seminars, or lectures on health physics related subjects. As an example the RADCON Foreman in charge of internal and external exposure evaluetion has never received any formal training in dosimetry or biosurveillance.
In discuss-ions with this foreman it was observed that he is competent but needs further training to evaluate non-routine data and situations. The training supervisor stated that future plans called for such training.
In the view of the auditor, a formal training program needs to be established for RCD Management with the utilization of outside courses, seminars, and lectures. This training should emphasize state-of-the-art technology and problems encountered in power reactor health physics.
2.5 Conclusions Based on the above findings, improvement in the following area are required to achieve an acceptable program:
Job / position descriptions need be established for all functional positions within the Radiological Controls Department.
Job / position descriptions need to contain selection and qualifi-cation criteria actually used in the hiring and promotion process, such as, including education, training, and experience factors related to health physics.
Other areas appear acceptrole, however, the following should be considered for improvement:
Formal training programs should be established for the professional staff of the Radiological Controls Department, utilizing outside courses, seminars, and lectures.
3.0 Exposure Controls 3.1 External Exposure Control 3.1.1 Documents Reviewed a.
RADCON Manual, " Chapter 1, Part II - Radiation Exposure Control and Monitoring," Issue 3.
4-17 b.
RADCON Manual - Chapter 3 RADCON Procedure No. 2.4, " Area Posting," Revision No. 1, May 29, 1980.
RADCON Procedure No. 2.6, " Neutron Monitoring," October 31, 1980.
RADCON Procedure No. 4.3, " Pocket Dosimeters - Reading and
-Charging," Revision No. 1, March 8, 1979 I
i RADCON Procedure No. 4.4, Issuing Pocket Dosimeters,"
I l
Revision No. 3, October 17, 1980.
l RADCON Procedure No. 4.5, Pocket Dosimeters - Controlling,"
Revision No. 3, March 27, 1979.
RADCON Procedure No. 4.6, " Pocket Dosimeters - Testing and Calibrating," Revision No. 3, October 3, 1980.
l RADCON Procedure No. 4.7, "Thermoluminescent Dosimeter (TLD) Response Check," Revision No. 4, July 3, 1979.
1 RADCON Procedure No. 4.8, "TLD Badges - Periodic TLD Card Exchange and Control," Revision No. 1, March 13, 1979.
RADCON Procedure No. 4.9, "TLD Badges - Description and Handling," Revision No. 3, October 17, 1979.
RADCON Procedure No. 4.10, "TLD Badges - TLD Card Processing,"
Revision No. 3, July 3, 1979.
RADCON Procedure No. 4.11, " Neutron Dosimetry," Issue No.
2, October 30, 1980.
RADCON Procedure No. 4.12, " Pocket Dosimeter Reset Record -
Information," Issue No. 1, August 31, 1979.
RADCON Procedure No. 4.13, "Thermoluminescent Dosimeter (TLD) Beta Correction Factor Calculation," Revision No. 1, March 8, 1979.
RADCON Procedure No. 4.14, " Transmittal of Radiation Exposure Records," Issue No. 1, October 17, 1979.
RADCON Procedure No. 5.1, " Exposure Authorization and Control," Revision No. 2, November 27, 1979.
RADCON Procedure No. 11.2, " Personnel RADCON Processing,"
'!evision No. 4, January 18, 1980.
s 18 RADCON Procedure No. 12.4, " Radiation Dosimetry Records and Reports," Revision No. 1, October 17, 1979.
RADCON Procedure No. 12.5, " Radiation Exposure Control Records," Issue No. 1, July 24, 1975.
c.
RADCON Manual - Chapter 4 RADCON Instrument Procedure No. 1.5, "Thermoluminescent Dosimeter (TLD)/ Dosimeter Calibration Exposure Procedure,"
Revision No. 1, October 3, 1980.
RADCON Instrument Prccedure No. 1.6, "TLD Beta Exposure,"
Issue No. 1, December 8, 1977.
RADCON Instrument Procedure No. 3.7, " Portable Neutron REM Counter - Model PNR-4/NRD-1 (Eberline Instrument)," Revision No. 4, June 24, 1980.
RADCON Instrument Procedure No. 3.8, " Fast-Slow Neutron j
Counter - PNC-4/NRD-1 (Eberline Instrument)," Revision No.
4, June 24, 1980.
RADCON Instrument Procedure No. 4.1, "Harshaw Model 2271 Automated TLD System Checks," Issue No. 1, April 14, 1975.
3.1.2 General The external radiation exposure control program consists of dosimetry, exposure record, review and limitations and a quality assurance program as related to external radiation exposure Control of personnel exposures is accomplished by using exposure measuring devices, timekeeping, and a records system for documenting these exposures. The external whole body dose measuring device used is a thermolu.ninescent dosimeter (TLD), supplied and processed by the licensee. The TLD is also used for extremity measurements.
Pocket Ionization Chambers (pencils) are used in conjunction with TLD's as a backup measuring device. Neutron exposures are determined by using portable survey instruments and timekeeping. A neutron film badge is presently used but is not considered part of the legal record. The records systems includes individual exposure history files, a computer file for all personnel assigned a TLD, daily exposure logs, and Radiation Work Permits.
3.1.3 External Dosimetry Program The TLD used by the Licensee is processed onsite by the RADCON Department (RCD) quarterly as a minimum or as administrative exposure guides are approached. The TLD is designed to measure gamma, x-ray, beta, and thermal neutron radiation.
The TLD specifications are:
C 3
19 Energy Response Gamma /X-ray 14 kev - 1.5 meV Beta / Neutron (Thermal)*
Data Not Available Minimum Oetectable Dose Gamma /X-ray 10 mrem i 50%
Beta 40 mrem 1 50%
Neutrcn (Thermal)*
5 mrem 1 50%
- The device is not utilized by the licensee for thermal neutrons.
Self-reading Pocket Ionization Chamber (Pencil) Dosmeters are used in conjunction with the TLD.
Pencil dosimeters are required for entry into the controlled area.
If both TLD's and pencil dosimeters are used. the exposure received by the pencil is recorded in the person's file until the TLD has been processed. The responsibility for reading, rezeroing and recording pencil dosimeter results is left up to RCD personnel.
An exposure record file for each staff member is maintained by the Exposure Records Clerk and reviewed by the RADCON Foreman in charge of external and internal exposure control.
These records files contain:
NRC-5 Forms NRC-4 Forms Whole Body Count Results Personnel Decontamination Reports Bioassay Exemption Forms Baseline Urinalysis Data TLD vs Pencil Discrepancy Forms Authorization to Exceed Administrative Exposure Guides Respiratory Protection Records The exposure history of each individual staff member is kept in the Central Records office. One year of exposure data is kept in the RCD Dosimetry Field Office and then forwarded to the Central Records
20 office to be maintained by the Exposure Records Clerk.
The auditor observed that the individual records were up-to-date, well organized, and complete in meeting the requirements.of 10 CFR 20.401.
In interviewing the RADCON Foreman in charge of dosimetry and the Exposure Records Clerk, it was determined that they had adequate knowledge to' perform their normal duties.
However, their lack of formal training in evaluating and interpreting dosimetry data for-non-routine situations in unacceptable in the view of the Appraiser.
This is discussed in Section 2.0, " Personnel Selection, Qualification, and Training" of this document.
In addition, the Exposure Records Clerk is not dedicated (permanently assigned) to the job of maintaining exposure record files, but works out of a secretarial pool and may be required to perform other duties as priorities demand.
In the view of the auditor, this job function should be solely under the direction of RCD Management.
Presently, the RCD Dosimetry Foreman has six Radiation Control Technicians assigned to him for the purpose of processing internal and external exposure data.
This presents a similar problem to that of the Exposure Records Clerk function, in that if demand dictates, these Technicians can be utilized for other functions. The auditor observed that presently the exposure data are kept up-to-date and are evaluated competently.
However, there is concern that without proper training and dedicated dosimetry staff members that this may not be the case in the future.
TLDs are presently stored and processed in the Dosimetry Field Office. The Appraiser noted that the radiation fields (.1 mrem /hr) in this office are significantly higher than background levels, due to a nearby source (tank).
This may amount to an additional exposure of several hundred mrem to the TLDs over the quarterly exchange period.
Presently there is no provision for shielding these TLDs from this source except to put them in a sheet metal box which has a negligible effect.
In discussing this problem with the RCD Dosimetry Foreman, it was stated that it would be investigated.
Future plans call for moving the Dosimetry Field Office to a new Technical Support Facility which will alleviate this problem.
At present the processing of the TLDs is accomplished solely by RCD personnel. The licensee system for processing consists of two TLD reader and cnnealing units. An agreement Ias not been made with the adjacent nuclear power plant site, the vencor from whom the TLDs were purchased, or any other group for assistance if the readers fail or an incident occurs.
This will be discussed in more detail in the Quality Assurance section for external ex,osure control.
Overall the external dosimetry program was found to be acceptable.
21 3.1.4 Exposure Review In-addition to the exposure records in the above specified files, worksheets utilized by the RCD staff are reviewed daily by RCD management. These records include daily pencil dosimeter readings, routine and non-routine TLD processing data, and alert list status.
During routine and outage operations a quarterly whole body exposure
. report.is generated. These. data are reviewed by RCD management and then disseminated to appropriate foremen and supervisors.
The review process for external exposure records by RCD Management ~
was found to be acceptable. However,-the auditor noted that exposure reports were not reviewed by foremen and licensee management directly i
-responsible for the individual workers except at the end of the calendar quarter when a report is issued by the RCO. This was found by the auditor to be the case both during routine and outage situations.
The auditor discussed this point with the RCD Foreman in charge of Dosimetry, who acknowledged the need to generate these exposure reports more frequently. At the. time of the appraisal, the quarterly report was generated to a great extent by hand because the RCD dosimetry computer system was not fully operational.
It was stated by the RCD foreman that when the system is functional, the frequency of reports will be increased, especially during outages.
3.1.5 Exposure Limitation The exposure limitations program consists of documents establishing the licensee's policy regarding external exposure guides and radio-logical posting. The exposure guides as outlined-in the RADCON Manual, Chapter 3, procedure No. 5.1 are:
Whole Body
- 2700 mrem / Calendar Quarter
- 4700 mrem / Calendar Year Skin
- 7 rem / Calendar Quarter 24 rem / Calendar Year Extremity d
- 15 rem / Calendar Quarter
- 65 rem / Calendar Quarter In order to meet these guides, an alert list system is established at the following level-
22 Whole Body-
- 1000 mrem / Calendar Quarter
- 3000 mrem / Calendar Year Skin / Extremity The levels are established on a case-by-case basis by the RADCON Supervisor.
The aspects of the exposure limitations program such as radiological posting, dose limits, shielding, and access control were found by the auditor to be acceptable. The content and use of procedures for exposure. limitations was also acceptable.
However, the procedures were not well organized and required too much cross reference with other documents and procedures. This is a general deficiency found with the present RADCON Manual Procedures and is discussed in more detail in the Superveillance section of this document.
3.1.6 Quality Assurance The licensee's Quality Assurance (QA) program for external exposure control consists of calibration of portable survey instruments and counting room equipment and reliability checks on the TLD system by the RCD. Quality Assurance checks by the licensee's QA/QC Department or an outside vendor is not performed on the TLD system.
The auditor concluded that the Quality Assurance portion of the external exposure control program was marginal, based on the portable survey instrument ;alibrations, the counting room instrumentation calibrations, and the reliability checks performed on the TLD system.
Portable survey instrument and counting room instrumentation calibra-tions are discussed in detail in the Section 3.3.3 of this appraisal report.
Quality Assurance, as performed by the RCD on the TLDs, was found by the auditors to be acceptable. At the time of the appraisal the licensee was exposing a batch of TLD cards to levels of 100 mr every quarter at TLD exchange time.
Prior to processing a batch of TLD's, several of these pre-exposed TLD's are processed to assure the reliability of the TLD readings.
However, it was observed that the exposure data from the TLDs is not reviewed by a group independent of the RCD.
In discussions with RCD management it was determined that this had been done in the past, but was discontinued.
In the view of the auditor this needs to be reinstituted and performed on a regular basis. This is important because TLD results are the legal dose record for the licensee and without a third party evaluation, there may be doubt as to the accuracy of the data.
.~
s f=
23-3.1. 7_
Conclusions Based on the above findings, the external exposure control-program appears to be acceptable, but the following matters should be con-sidered for improvement of the _ program:
Formal training of dosimetry staff members.
Permanently assigned dosimetry staff members.
Offsite capability for processing TLDs.
Frequency of exposure reports disseminated to selected licensee-management staff members should be increased.
Reinstitution of independent quality assurance testing of the TLD system.
3.2 Internal C<posure Controls 3.2.1 Documsats Reviewed a.
RADCON Manual - Chapter 1, Part II
" Radiation Exposure Control and Monitoring," Issue 3.
b.
RADCON Manual - Chapter 3 RADCON Procedure No. 4.2, " Body Count Requirements,"
Revision No. 4, October 17, 1979.
RADCON Procedure No. 5.2, "In-Vivo Activity Determination,"
Revision No. 4, October 17, 1979.
RADCON Procedure No. 5.3, " Bioassay Sampling," Revision No. 1, October 17, 1979.
c.
RADCON Manual - Chapter 4 RADCON Instrument Procedure No. 4.4, " Multi-char,el Analyzer for Invivo Counting," Revision No. 2, October 23, 1979.
RADCON Instrument Procedure No. 5.6, " Air / Particulate Sample Counter - [MS83, HP-210, SH-4 ]," Revision No. 4, June 24, 1980.
d.
RADCON Manual, Appendix 7
" Bioassay Program," Revision No. 3, l
January 23, 1976.
e.
RADCON Mar.ual, Chapter 1, Part III
" Airborne Radioactivity
[
Control Program," Issue 3.
l
?
c 24 f.
Beaver Valley Power Station Training Manual; Section 10.1,.
" Respiratory Protection Program," Revision No. O, October 21, 1977.
g.
RADCON Manual - Chapter 3 RADCON Procedure No.10.1, " Respiratory Equipment," Revision No. 4, August 25, 1980.
l RADCON Procedure No.10.2, " Respiratory Equipment: Training, Fitting, and Testing," Revision No. 2, July 13, 1978.
RADCON Procedure No. 10.3, "BVPS RADCON Respiratory Equipment -
l Chemox," Revision No. 1, July 13, 1978.
l l-RADCON Procedure No. 10.4, " Full Face Respirators - Inspection, Repair Storage," Revision No. 3, July 5,1978.
RADCON Procedure No. 10.5, " Air Supplied Hoods - Inspection, Repair, Storage," Revision No. 2, January 6, 1978.
RADCON Procedure No.10.6, " Sodium Chloride Test System,"
Revision No. 2, May 20, 1980.
RADCON Procedure No.10.7, "BVPS 35'r, Oxyaen Airline Equipment for use in Containment," issue No. 1 9
j-Revision No. 2, October 14, 1975.
h.
RACON Manual, Appendix 6 " Respiratory Protection Program,"
i.
Unit 1 Maintenance Manual, Chapter 1, Section Y, " Control and Maintenance of Respiratory Equipment," Revision No. 2, March l
18, 1980.
3.2.2 General The licensee's internal radiation exposure control program consists of dosimetry, exposure review, exposure limitations, and quality assurance programs.
3.2.3 Internal Dosimetry Program The internal dosimetry program includes biosurveillance, timekeeping and an exposure records system. The biosurveillanc! methods used by the licensee are lung / thyroid counting and urinalysis. Time:
motion studies in conjunction with air sample results are used in calculating maximum permissible concentration (MPC) hours. The results of these calculations are used in determining the need for additional biosurveillance.
The records system includes exposure history files, thyroid / lung counter printouts, air sample data, personnel decontamination suiveys, and MPC hour logs.
e
=
25 The lung counter used by the licensee consists of a stationary four-inch by five-inch NaI detector with the subject to be counted lying in a horizontal position beneath the detector. This detector may also be used on areas other than the lung (primarily the lower abdomen). The thyroid counter consists of a stationary three-inch by three-inch NaI Detector with the subject to be counted sitting in a chair.
Either detector may be utilized for wound counting. The normal count time for both detector arrangements is ten minutes.
A lung and thyroid count is performed on all radiation workers once a year in addition to the counts at the time of hiring and termination.
Individuals specified for lung / thyroid counting submit urine samples when deemed necessary by the RADCON Department (RCD). These require-ments apply to all contractor and visitor personnel unlass specifically exempted by the RCD.
The radionuclides of interest that are evaluated by the licensee are:
H-3 Mo-99 Cr-51 Ru-106 Mn-54 Sb-124 Co-58 I-131 Fe-59 Te-132 Co-60 I-133 Zn-65 Cs-134 Sr-89 Cs-137 Sr-90 Ba-140 Sr-95 Ce-144 An exposure record file is maintained for each staff member, which contains data as outlined in Section 3.1, " External Exposure Control Program," of this appraisal report.
The auditor observed that internal exposure records were up-to-date, well organized, and complete in meeting the requirements of NRC Regulatory Guide 8.26 and ANSI N343-1978, " Internal Dosimetry for Mixed Fission and Activation Products." At the time of the appraisal, the licensee had performed lung / thyroid counts and urinalysis consis-tent with the frequency outlined in RADCON Procedure No. 4.2.
In reviewing exposure records and from discussions with the RADCON Foreman in charge of internal and external exposure evaluation, it was noted that no individual had received greater than 10% of a maximum permissible organ burden.
The RADCON Foreman mentioned above was interviewed and was determined to be competent to perform this job function.
However, as discussed in Section 2.0 of this document, there was a lack of formal training as applied to this position.
It was stated by the foreman that his
I' 26 L
technical-knowledge was obtained on his own initiative. The use of ICRP Guidelines and data collected routinely by the RCD from surveys, air sr.mples and biosurveillance is adequate to evaluate most uptakes and determine the critical organs involved.
l 3.2.4 Internal Exposure Review The internal exposure review program consists of procedures establish-ing licensee policy to meet the concept of ALARA.
In addition, the use of posting and protective. clothing (including respiratory protectica) are utilized to insure that internal exposures are minimized. The internal exposure. review program was found, by the auditor to be acceptable and conforming to good ALARA practices.
3.2.5 Internal Exposure Limitations 3.2.5.1 Administrative Controls The aspects of the exposure limitations program such as posting, uptake limits, engineering controls, access controls, and protective i
clothing (excluding respiratory protection) were found by the auditors to be acceptable. The content and use of procedures for exposure I
limitations was also acceptable. However, the procedures were not well organized and required too much cross reference with other documents and procedures.
This is a generic deficiency found with the present RADCON Manual Procedures and is discussed in more detail in the Section 3.3.1 of this appraisal report.
The utilization of respiratory protection in the internal exposure 1
limitations program was found to be inadequate by the auditor. This is based on deficiencies in the respiratory protection program as j
follows:
l l
Air sampling Fitting l
Training Inspection / Testing / Repair This area is discussed in more detail in Section 3.2.5.2, " Respiratory Protection," of this appraisal report.
l f
e l'
+-
27
.3.2.5.2 Respiratory Protection Program Establishment The licensee's respiratory protection program consists of hazards evaluation, engineering controls, training / qualification, maintenance, and a quality assurance program as related to respiratory protection.
The respiratory protection program is formally establ.ished by licensee management t'1 rough the policy statement of RADCON Manual, Appendix 6~- Respiratory Protection.
The responsibility for respiratory protection is divided among the RADCON Department (RCD), the Maintenance Department, and the Training Department.
The Maintenance Department maintains and controls all l
respiratory equipment except MSA and Scott respirators and air-supplied hoods which are the responsibility of the RCD. The Training Department l
is responsible for performing and recording all respiratory protective equipment training as well as verification of medical and respiratory fit information.
Respiratory protective equipment utilized by the licensee is NIOSH approved and is of the full face design with seal about the face and i
neck.
In addition, air supplied hoods that completely enclose the-head and neck and are supplied with positive pressure breathing quality air are used. Allowance for respiratory prote,tive equipment is not applied unless the respiratory protective program has been implemented as required by Regulatory Guide 8.15.
The licensee's Safety Engineer is responsible to ensure that the respiratory protection equipment control and maintenance program is adhered to by all personnel.
In addition, he is responsible for overall implementation of the program.
In discussions with the Safety Engineer, it was determined that he delegates his authority to the RADCON Supervisor and the Station Maintenance Supervisor because he does not have sufficient experience.
In Chapter 12 of NUREG-0041, it states:
"Regardless of his organizational position, the responsible individual in charge of the respirator program must have the i
ability, training, and experience to, (1) evaluate the hazard i
and the job; (2) recommend engineering controls if appropriate; (3) specify respiratory protection if control cannot be otherwise obtained; and (4) forbid the use af respirators if conditions warrant.
The responsible person shoudl have, in addition to his other qualifications, at least 1 year's field experience in the use of respirators."
l '. --
28 Neither the Safety Engineer or the Maintenance Supervisor meet these criteria; however, the RADCON Supervisor and one of the RADCON Foreman do meet these criteria. Unitl the past several years the respiratory protection program was run exclusively by the RCD. As observed by the auditor, a qualified, person is not assigned respon-sibility for the ' respiratory. protection program.
The other aspects involved in the establishment of the respiratory protection program, such as management policy statement, selection of approved equipment, and requirements and limitations for respirator wearers was found by the appraiser to be acceptable.
Hazard Evaluation The hazard evaluation program is based on oxygen deficient conditions (in containment), maximum permissible concentrations (MPC), and the air sampling program.
Due to the subatmospheric environment within secondary containment, a 35*4 oxygen, pressure demand system is used.
This system consists of pressurized oxygen cylinders (240 cubic feet) in conjunction with either MSA or Scott respirators and pressure demand valves.
Presently, protection factors for respiratory protective devices are i
calculated for each licensee staff member based on respirator-fit data, not to exceed NIOSH recommendations.
However, at this time, protection factors are not utilized and thus the administrative l
control of 40 MPC hours per week is based solely on air sample data without taking credit for the use of respirators.
l The classification of hazards based on oxygen deficient conditions, toxic and nuisance atmospheres, and MPC-hour accounting procedures was found by the appraiser to be acceptable.
The licensee's an air sampling program utilizes Continuous Air Monitors (CAMS) and air samplers (both particulate and gaseous).
The air samples are drawn using either low or high flow rate air pumps and then are analyzed both by the RCD and the Chemistry Department, depending upon the isotope of interest. At the time of the appraisal, the air sampling program was found to be inadequate; the basis for this finding is contained in Section 3.3 of this appraisal report.
Training and Qualifications The respiratory training program consists of classroom instruction followed by hands on instruction. This training is performed by the Training Department and consists of the following elements:
29 Biological Hazards Construction, Operations / Limitations of Respirators Use and Maintenance Fitting Requirements Malfunction of Respirators Emergency Use In addition, training specific-to other departments for the maintenance and control of respiratory protective equipment is performed by each concerned department.
Fitting by the licensee for respiratory protective equipment consists of both qualitative and quantitative tests.
Full-faced filtered respirators, full-face constant flow air line respirators, and air supply hoods are qualitatively fitted by using isoamyl acetate.
Chemox, 35% oxygen, and Scott air pack respirator systems are quan-titatively fitted for each individual by using the licensee's sodium chloride test booth. The isoamyl acetate test is performed by the Training Department at the time of training and the sodium chloride test is performed by the RCD when needed.
The ability of an individual to wear respiratory protection is based on the results of training fitting, and medical status. The licensee's Medical Department reviews each respirator user's medical history annually and either approves or disapproves the use of respiratory protection by that individual. A computer printout is generated by the Training Department with the names of personnel qualified to wear respirators (training, medical) and the types of respirators for which they have been fitted.
The instructors utilized by the Training Department for respiratory protection were found by the auditor to be both competent and exper-fenced. They used classroom instruction plus hands-on training to meet their training objectives.
The hands-on training consisted of the students donning and removing respirators, the use of a smoke house to simulate emergency conditions, and the inspection and fitting of respirators by the students.
The smoke house was observed by the appraiser not to be utilized for MSA respirators and the air supplied hoods.
In discussions with the Training Supervisor and a Respirator Training Instructor, it was stated that field tests and drills are not performed for the MSA filtered respirator. Because this respirator is the primary device used in the field by radiation workers it is the opinion of the auditor that the Training Program is inadequate for this respirator.
NUREG-0041 Section 8.4, states:
30
" Training must include the use of the respirator under simulated conditions of exposure so that the wearer will develop a sense of confidence in his ability to use the device properly."
Training for other types of respirators meet this criterion and it is suggested that the staff members receive this type of training program on all respirators, including the MSA filtered respirator, before being considered qualified on them.
.The auditor determined that the respirator fitting program for the MSA filtered respirator was also unacceptable.
Presently the licensee performs qualitative fit tests on this respirator by using isoamyl acetate.' The potential wearers are required to turn their heads.
from side to side while inhaling isoamyl vapors from a bottle to determine if they can detect any leakage.
NUREG-0041, Section 8.5.2, states:
"When quantitative fitting test equipment is not available, some form of qualitative test is required.
It is preferable to use a chamber containing a challenge atmosphere, such as isoamyl acetate, in order to perform the exercised as described in Section 8.5.2.2" The licensee is using a sodium chloride test booth to perform quanti-tative tests on respirators. This system is available, but is not utilized for the filtered respirators. In addition, the qualitative tests presently performed on the filtered respirators do not require the use of exercises as stated above. In the view of the auditor, quantitative fit tests should be performed on all respirators in use due to the availability of the test equipment.
At the time of the appraisal, the licensee's Medical Department reviewed each respirator wearer's medical record on an annual basis with a medical physical examination being performed every three years. NUREG-0041, Section 7.4.3, states:
"A physical examination is required for each user before he wears any device and at least annually thereafter."
The present licensee policy does not meet this criterion. The medical record (evaluated by the licensee annually) consists of the number of days absent from work and any other medical facts supplied by the employee.
To meet the requirements of NUREG-0041, the licensee must require a medical exam annually for all respirator users.
The training program for the various types of respirators was found to be an initial one-time program.
Retraining was not performed unless the competence of the respirator wearer was in question.
NUREG-0041, Section 8.2, states:
5 31 "It is important, especially in establishments where respirators are used only occasionally, that periodic retraining be performed with sufficient frequency and at appropriate times so that a high degree of proficiency will be retained when respiratory equipment is actually
'used."
'The present training program with the correction of the above defic-iencies, would be sufficient to meet the retraining requirements if given at an adequate frequency.
Present industry practice suggests a maximum of two years between training sessions in an appropriate frequency.
The proficiency of students within the respirator protection is presently not evaluated as observed by the appraiser.
The test given.at the end of the radiation worker course does not address respiratory protection and a separate test is not given 'after the respiratory protection training.
In the view of the auditor, a proficiency test, with a predetermined passing grade, should be administered by the Training Department.
The respiratory protection training is generally adequate, but there is no tool to determine if the students have gained anything frcm the training to insure that they are qualified respirator users.
Maintenance The maintenance of the licensee's respiratory protection program consists of the inspection, testing, repair, storage, inventory, issuance, cleaning, and disinfection of most respirators by the Maintenance Department. The exception to this is that these functions are performed by the RCD for the MSA and Scott respirators and the air-supplied hoods. Before issuance, the respirators are surveyed by the RCD for loose and fixed contamination.
Upon completion of successful maintenance and radiological surveys, each respirator is bagged, sealed, and affixed with an inspection tag.
In addition to respirators, associated equipment, such as fittings, hoses, and gas cyclinders undergo a maintenance program with appropriate documentation.
The maintenance program for respiratory protective equipment is provided both by the RCD and the Maintenance Department. The job functions performed by the RCD were found to be acceptable by the appraiser and included (1) contamination surveys and decontamination of respirators, and (2) inspection and maintenance of the MSA and Scott full-face respirators and supplied air hoods.
The Building Maintenance Foreman is responsible for issuance, cleaning, proper storage, and monthly inspection of all routinely ud-i respira-tory protective equipment.
The auditor observed that these functions were performed adequately i
and that the Maintenance staff members performing these functions were provided with acceptable procedures and training for their job function.
32
-_The Mechanical Maintenance Foreman is responsible for assuring that the following respiratory equipment is properly inspected and main-tained:
Chemox MSA 401 Pressure Demand Self-Contained Breathing Apparatus Pressure Demand Supplied Air Breathing Apparatus Supplied Air constant flow Respirator Accessories for supplied air hoods It was observed that procedures were in place to perform the above duties but, that the Maintenance personnel in this group were not trained to perform these duties.
In discussions with a Mechanical Maintenance Foreman, and the Station Maintenance Supervisor, the auditor was informed that the Mechanical Maintenance staff members had enough mechanical experience that they did not need to be trained on these procedures. Maintenance Department policy was to give the mechanic the appropriate procedure and let him determine what had to be done to the respirator.
Section Y, Part 7.a.3, of the Maintenance Manual, states:
" Repair of any component of a respiratory protective device may be undertaken only by persons thoroughly familiar with the device who L
have been instructed in the type of repair to be performed.
No attempt shall be made to replace components or to make adjustments or repairs beyond the manufacturer's recommendations."
In the opinion of the auditor, a taining program needs to be estab-l lished for the Mechanical Maintenance staff members who are respon-sible for respiratory protective equipment repair.
The reliance on mechanical experience alone is not enough when health and safety is involved.
1 l
Quality Assurance The licensee does not have an active independent quality assurance program. The quality assurance that does exist is performed by each individual department based on their job function in the respiratory protection program.
3.2.5.3 Engir 3 ring Controls The engineering controls used by the licensee within the respiratory protection program consist of permanent and temporary ventilation systems, sample hoods, temporary containments such as glovebags, and continuous airborne sampling equipment with alarm functions. The engineering control used by the licensee for the respiratory protection program were found by the auditors--to be acceptable.
?
33 3.2.6 Quality Assurance Program The licensee's quality assurance program for internal exposure control consists of the calibration of portable survey instruments, l-counting room instrumentation, air-sampling equipment and the lung /
thyrcid counter.
The calibration of the lung / thyroid counter is performed by the RCD.
This consists of a semi-annual electronic / radioactive source calibra-tion and a daily source / background check with radionuclide phantoms.
The licensee perforn 4 calibrations cn the lung / thyroid counter located onsite. This calibration program is very well documented l
and adequately performed.
Strengths of this particular bioassay program are:
performance of Daily background / source checks.
performance of semi-annual electronic /radionuclide calibrations.
[
l i_
frequency of routine counting program.
1 Competence of staff members operating the counter.
analysis of data by RCD management.
However, it was observed that the reliability of this system's' data L
is not evaluated by an independent group outside the RCD.
In discuss-l ions with RCD Managment it was stated that if positive indications are obtained with the onsite lung / thyroid counter then the subject being counted is sent offsite to receive a lung / thyroid count.
l Evaluation of the reliability of of fsite lung / thyroid data however l
is not performed by the licensee.
In the view of the Appraiser, the l
reliability of both these systems needs to be evalcated on a regular basis. This is important because the lung / thyroid data can be related to the internal dose of the workers and without a third party evalua-tion there may be doubt as to the accuracy of the data.
1 The quality assurance of the internal exposure control program was unacceptable.(as described above) based on the reliability checks performed on the licensee's lung / thyroid counter and the offsite lung / thyroid counter services provided by a vendor.
It was also noted by the auditor that. calibrations of the portable survey instru-ments, counting room instruments, and air sampling equipment were marginal.. Calibrations are discussed in detail in Section 3.3 of-this report.
3.2.7 Conclusions Based on the above findings,. improvements in the following areas are required to achieve an acceptable internal exposure controls program:
U
-, -, - - ~ -,-
n 34 outside reliabili'.y checks on licensee lung / thyroid counter.
licensee reliability checks on vendor lung / thyroid counter.
improved air sampling program.
assignment of reponsibility for the respirator program to a qualified person.
Field test and drill training for full-face filtered respirator users.
Respirator fitting pregram for full-face filtered respirators.
annual medical examinations.
respirator retraining.
proficiency of respirator users.
training of maintenance staff members for inspection, testing, and repair of respiratory protective equipment.
3.3 Surveillance Program 3.3.1 Documents Reviewed a.
RADCON Manual, Chapter 1, " Standards and Requirements," Issue 3.
b.
RADCON Manual Appendicies:
Appendix 1, "Radeon Administrative Guide,"
Appendix 2, " Terms and Definitions,"
Appendix 3, " Signs. Tags, and Marking Materials,"
Appendix 4, " Frequency of Airborne, Radiation, and Contam-t ination Surveys,"
Appendix 9, " Safe Handling of Radioisotopes,"
Appendix 10, "Radcon Records and Forms,"
c.
RADCON Manual, Chapter 2, " Rad *ation Worker Practices," Issue 1, Revision 5.
1 p.-
35
.d.
RADCON Manual, Chapter 3, "Radcon Procedures" t
Radeon Procedure No. 1.1, " Radioactive Standard-Accounta-l bility Inventory (Initiation)," Issue 1, Revision 2, Radcon Procedure No. 1.2, " Radioactive Standards-Handling and Routine Accountability," Issue 1, Revision 2, Radcon Procedure 1.3, " Radioactive Standards Accountability-Routine Inspection &-Inv. Check," Issue 1, Revision 5, Radcon Procedure 1.4, " Radioactive Standards Accountability-(Termination)," Issue 1, Revision 2, Radcon Procedure 1.5, " Ordering Radioactive Standards,"
Issue 1, Revision 2, Radcon Procedure 1.6, " Accountability-Subdivision of Radioactive Standards," Revision 1, February 5,1976, Radeon Procedure No.1.7, " Accountability Control-Multiple Source Gamma Calibration," Revision 1, February 5,1976, Radcon Procedure No. 2.1, " Area Entry Requirements," Issue 1, Revision 6, Radeon Procedure No. 2.2, " Radiological Work Monitoring,"
Issue 1, Revision 1, Radeon Procedure No. 2.3, " Decontamination Control," Issue l
- 1. Revision 1, Radcon Procedure No. 2.4, " Posting," Issue 1, devision 1, Radcon Procedure No. 2.5, " Drumming of Solid Waste," Issue 1, Revision 3, Radcon Procedure No. 2.6, " Neutron Monitoring," Issue 2, Radcon Procedure No. 3.1, " Material Monitoring," Issue 2, Radcon Procedure No. 3.2, " Labeling and Packaging Radioactive and/or Contaminated Material," Issue 2, Radcon Procedure No. 3.3, " Receiving Radioactive Material,"
Issue 2, Radcon Procedure No. 3.4, " Handling Monitored Material Within the Controlled Area," Issue 2,
36 Radcon Procedure No. 3.5, " Handling Material-Removal from the Controlled Area,". Issue 2, Radcon Procedure No. 3.7, " Removal of Material from Contam-inated Area or Systems," Issue 1, Revision 2, Radeon Procedure No. 4.1, " Requirements for Setting up a Frisker Station, Issue 1, Revision 2, Radcon Procedure No. 7.1, " Area Contamination Survey,"
Issue 1, Revision 6, Radeon Procedure No. 7.2, " Airborne Radiation Survey,"
Issue 1, Revision 2, P. adcon Procedure No. 7.3, " Airborne Particulate Sampling,
" Issue 1, Revision 1, Radcon Procedure No. 7.4, " Airborne Radioiodine Sampling,"
Issue 1, Revision 5, Radcon Procedure No. 7.5, " Air Particulate Radioactivity Sample Assessment," Issue 1, March 10, 1975, Radeon Procedure No. 7.6, " Storage, Use, and Handling of Silver Zeolite Cartridges," Issue 1, Radcon Procedure No. 8.1, " Radiological Work Pernit,"
Issue 1, Revision 6, Radcon Procedure No. 8.2, " Radiation Clearance," Issue 1, Revision 2, Radeon Procedure No. 8.3, " Containment Radiation Barrier Key Control-Shutdown and Major Maintenance," Issue 1, Radcon Procedure No. 9.1, " Contaminated Area Control,"
Issue 1, Revision 7, Radcon Procedure No. 9.2, " Radiation Area Control, " Issue 1, Revision 2, Radcon Procedure No. 9.3, " Anti-Contamination Clothing-i Specification," Issue 1, Revision 3.
Radcon Procedure No. 9.4, " Anti-Contamination Clothing-Use,"
Issue 1, Revision 2, Radcon Procedure No. 9.5, " Anti-Contamination-Monitoring,"
Issue 1, Revision 3,
l 37 l
i Radcon Procedure No. 9.6, " Contamination Containment
)
Practices," Issue 1, Revision 1, March 8, 1976, Radcon Procedure No. 9.7, " Contamination Containment-Walk-in, Tent-type Enclosures," Issue 1, Revision 1, l
Radcon Procedure No. 9.8, " Shielding," Issue 1, Revision 1,
Radcon Procedure No. 12.1, " Accountability Logs," Issue 1, April 4, 1975, Radcon Procedure 12.2, " Instrument Maintenance (Check) and Calibration Records," Issue 1, Revision 2, Radcon Procedure 12.7, " Radiological Survey Records,"
Issue 1, April II, 1975, Radcon Procedure 12.8, " Radiological Clearances and Work Permits," Issue 1, July 15,1975, Radcon Procedure 12.9, " Radiation Logs, Deficiency and Incident Reports, Issue 1, Revision 1, Radcon Procedure 12.10, " Counting Room Equipment Records,"
Issue 1, Revision 3.
I e.
RADCON Manual-Chapter 4, "RADCON Instrument Procedures" l
Radcon Procedure No.1.1, " Multiple Source Gamma Calibrator,"
Issue 1, Revision 2, Radcon Procedure No.1.3, "Victoreen 570 Condenser R-Meter,"
Issue 1, Revision 1, Radcon Precedure No. 2.4, " Portable Area Monitors-Model RM-16 (Eberline Instrument), Issue 1, Revision 2, Radcon Procedure No. 2.5, " Portable Area Monitor High Range-Model RM-16/Rd-17A (Eberline Instrument)," Issue 1, Revision 1, Radcon Procedure 3.1, "GM Survey Meter-Model E140N/HP210 (Eberline Instrument)," Issue 1, Revision 5, Radcon Procedure 3.2, "GM Survey Meter-Model E530/HP240 (Eberline Instrument)," Issue 1, Revision 4, Radcon Procedure 3.3, "GM Survey Meter-Model E530N/.'P200-HP220A (Eberline Instrument)," Issue 1, Revision 5,
c.
38 Radcon Procedure 3.4, "GM Survey Meter-Model E400/HP240,"
Issue 1, Revision 5, Radcon Procedure 3.5, "Teletector 6112 Survey Meter (Total Instrument)," Issue 1, Revision 5 Radcon Procedure No. 3.6, " Portable Ion Chamber-Model-PIC-6A (Eberline Instrument)," Issue 1, Revision 3, Radcon Procedure No. 3.7, " Portable Neutron Rem Counter-Mode PNR-4/NRD-1 (Eberline Instrument)," Issue 1 Revision 4, g
Radcon Procedure No. 3.8," Fast-Slow Neutron Counter-PNC-4/
Np-2 (Eb9rline Instrument)," Issue 1, Revision 3,.
Radcon Procedure No. 3.9, " Gas Proportional Alpha Counter-Model PAC-4C/AC-21 (Eberline Instrument), Issue 1, Revision 3,
Radcon Procedure No. 3.10, " Ion Chamber Survey Meters-Models Cutie Pie 740 F, 740 G (Victoreen Instrument)," Issue 1, Revision 5, Radcon Procedure No. 3.11. " Survey Instrument Probes-HP-1778, HP-200, HP-210, HP-240, RD-17A, LEG-1, AC-21, NRD-1,"
Issue 1, Revision 1, Radcon Procedure No. 3.12, " Beta-Gamma Floor Monitor-Model FM-12," Issue 1, April 9, 1975, Radcon Procedure No. 3.13. " Logarithmic Survey Meter-Radgun,"
~
Issue 1, Revir. ion 2, Radcon Procedure No. 3.14 " Panoramic len Chamber Madel 470 A," Issue 1, Revision 1, Radeon Procedure No. 3.15. " Ion Chamber Survey Meters Models RO-2, R0-2A (Eberline Instruments)," Issue 1, Revision 1, Radcon Procedure No. 3.16, " Ion Chamber Survey Meter-Model CP-TP-10K (Technical Associates)," Issue 1, Radcon Procedure No. 4.2, "Eberline RM-14 Ratemeter/HP210 Probe," Issue 1, Revision 3, Radeon Procedure No. 4.3, "Eberline Portal Monitor (PMC-48 L
and PMP-4B/4C)," Issue 1, Revision 3, 1
Radcon Procedure No. 5.1, "NMC PC-4 Gas Proportional Counter," Issue 1, Revision 2,
t!
-39 Radcon Procedure No. 5.3, " Low Background Counter (Wide Beta II)," Issue 1, June 4, 1975, Radcon Procedure No. 5.4, " Liquid Scintillation Counting System," Issue 1, June 4,1975, Radcon Procedure No. 5.5, " Gamma Counting System-20 ml Well," Issue 1, Revision 2, Radcon Procedure No. 5.6, " Air Particulate Sample Counter (MS-3 Hp210 SH-4)," Issue 1, Revision 4, Radeon Procedure No. 5.7, " Counting Instrument Calibration and Maintenance, Issue 1, Revision-1, Radcon Procedure No. 5.8, " General Practice, Chi-square Test and Counter Control Checks," Issue 1, Revision 2, Radcon Procedure No. 5.9, " Counter Operation-Verification,"
Issue 1, Revision 2, Radcon Procedure No. 5.10, " Determination of Counter Minimum Detectable Activity (MLA)," Issue 1, Revision 1, Radcon Procedure No. 5.11, " Plateau Counts and Plateau Checks," Issue 1, Revision 1. July 28,1976, Radeon Procedure No. 5.12, "ND 4420 Counting System,"
Issue 1, Radcon Procedure No. 5.13, " SAM-2/RD-22 1-131 Counting System," Issue 1, Radcon Procedure No. 6.1, " Portable Air Particulate Detector-Eberline Model AMS-2," Issue 1, Revision 2, Radcon Procedure No. 6.2, " Continuous Air Monitors-AM-38,"
Issue 1, Revision 2, Radcon Procedure No. 6.4, " Portable High Volume Air Sampler,"
Issue 1, March 27, 1975, Radeon Procedure No. 6.5, "MSA:
Battery Operated Air Sampler," Issue 1.
f.
Procedure No. CP-112 MSA Granimetric Dust Sampler Flow Calibration.
g.
Procedure No. CP-2019 Air Sampler Air Flow Determination.
h.
" Report of Neutron Survey, Beaver Valley Station, Duquesne
-Light Company, Shippingport, PA. 15077, September 18-20, 1979,"
Issued February 15, 1980.
1.
40
~
1.
Memorandum Dated August 10,'1978 to Mr. Ed Schnell from Mr.
Eric Gergin of'Eberline Instrument Corp. regarding the response of some of the'Eberline Instruments to 6MeV gamma energies.
3.3.2 Surveillance program Implementation The Beaver Valley " Radiological Control Manual" consisted of 5 Chapters plus 10 Appendices.
(Chapter 5 covered emergency operations and is not addressed in this report. A summary of the chapters and appendices follows:
Chapter 1 " Standards and Requirements"
. contain "...the basic policies, standards, requirements and guidelines for radiological control" and was, " prepared for the use of supervisory and Radcon personnel."
Chapter 2 " Radiation Worker Practices"
"... prepared as a guide for Radiation Workers and provides practices and other pertinent information which must be followed to ensure compliance with the provisions of Chapter 1."
Chapter 3 "Radcon Procedures" - contains the detailed procedures (approximately 90) for general Radcon practices and information to be utilized by the Radcon Group to implement the Chapter 1 program.
Chapter 4 "Radcon Instrument Procedures" - contains the detailed p ocedures (approximately 50) to be used by the Radcon Group, "for the use, calibration, care, etc. of Radeon instruments."
In addition to the following, there are 10 appendices that
" provide supplemer.tary information to the Chapters."
Chapters 1 through 4 plus the 10 appendices fill four 2 inch binders.
The quantity of procedures, appendices, etc. makes assimilation of the procedure difficult and time consuming.
It also makes it difficult for individuals to determine if they are complying with the procedures since in may instances multiple procedures must be consulted prior.
I to performing one task. As an example the procedures pertaining to i
obtaining and analyzing an air sample for iodine and particulate are-as follows:
Procedure Title RP 7.3 Airborne Particulate Sampling i
RP 7.4 Airborne Radiciodine Sampling RP 7.5 Air Particulate Radioactivity
i l
41 l
i RP 7.6 Storage, Use, and Handling of Silver Zeolite Cartridges (if used)
RIP 5.6 Air Particulate Sample Counter RIP 5.12 ND4420 Counting System j
RIP 5.13 SAM-2/RD-22 1-131 Counting System l
l Appendix 10 Radcon Records and Forms i
l The procedures normally gave detailed information on the operation of instruments plus technical data and specifications from the l
manufacture's manual.
However, information for use, method of selecting the proper instrument, calculation methods, etc. were vague. Many procedures referenced obsolete instruments, inoperable instruments or instruments that were no longer routinely used.
I Examples of these problems can also be illustrated using the procedures referenced above.
Procedure RP7.3 " Airborne Particulate Sampling" provides information on obtaining " general area", " process samples" and " breathing zone" samples."
l In paragraph 3.2.6 the procedure required that air samplers be l
operated for sufficient time to obtain a representative air sample.
l The paragraph stated that five minutes was usually sufficient for high volume air samplers and, "a longer period may be required" for low volume samplers. No guidance was given on how to determine the proper minimum sample times.
Procedure 7.4 provides minimum sample volumes required for radioiodine using the rapid evaluator technique but not for routine samples.
Procedure 7.5, paragraph 3.3.4 pro-l vided minimum sample times in minutes for particulate samples when I
using a rapid evaluation method. Again, mininum times or volumes were not given for routine sample.
In addition the minimum sample times given in the procedure did not specify the related flow rate.
Faragraph 3.3.2 of Procedure 7.5 stated that a "staplex" or " annular inpactor" could be used to obtain particulate samples for use with the rapid evaluation method but that the " annular impactor" was prefered. However, eccording to a licensee representative the use of the annular impactors had been discontinued and high volume air samplers are only used in emergency kits.
The calculational methods were contained on the associated forms.
Procedure RIP 5.6, " Air Particulate Sample Cour'
' provided technica information plus the control functions used the counter scaler.
The procedures to be used for calibraticr-i source checks wre not specified.
Some calculations were contained on the forms located in Appendix 10 of the Radiological Controls Manual.
These are but examples of the many problems found with the licensees procedures.
Even though the procedures are unusually voluminous, in many casos they did not provide the required details. The fractionation of information needed among the various chapters, procedures and appendices resulted J
42 in procedures not being clear, concise and easy to use.
It may be desirable to have a procedure, such as air sampling, refer to another procedure for the actual counting of the sample. However, each of the procedures should contain the instructions and degree of detail necessary for the particular task to be performet. a qualified individual. ANSI N18.7, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" paragraph 5.3,
" Preparation of Instructions and Procedures" should be consulted for additional information.
Many procedures contained words such as "may", "as required", "at the discretion of", etc. such that the procedure did not give actual requirements but only suggestions.
In some instances this is justified but it was, too, prevelant in the licensee's procedures. A licensee representative stated that some of the permissive wording had been added to prevent problems during QA audits by licensee personnel.
It appeared that QA had a tendency to apply absolute literal interpre-tation to procedure wording even when it was obvious that this wan't the intent of the procedure.
For example, Chapter 1 Part III paragraph A.1.b of the Radiological Controls Manual states, "All contaminated areas may be posted with a magenta (a purple) on yellow sign...."
The Appraiser took that statement to mean contamination areas may be posted but that it wasn't required. A licensee representative stated that the "may" was intended to refer to the colors " magenta on yellow" since step off pads could also be used to post contarair,ated area.
Previous deficiencies noted on QA audits resulted in changing the wording in the manual. Another example had to do with the method of using yellow and magenta tape and rope to barricade contam-inated areas (procedure 9.1). The procedure wording had indicated that the rope would be above the tape used to deliniate the contam-inated area.
In practice the rope was over the tape or beyond the tape depending upon the availability of convenient tie points or stanchions. QA listed a deficiency because a rope wasn't vertically above the tape. Chapter 1 of ti.e Radiological Controls Manual stated that 005 (Out of Service) tags may be used for instruments.
Again, to the Appraiser this implied that out of service instruments did not have to be tagged. A licensee representative explained that the wording was intended to imply permission to use 00S tags in lieu of a different type of station tag.
The procedures need to clearly state the requirements that are to be implemented in positive terms.
If interpretation problems are experienced by QA, management may reed to review the QA audit guidance and the method used to express requirements in procedures, to resolve the problem.
Discussions with licensee representatives indicated that a policy was originally established such that the Beaver Valley and Shippingport Radcon procedures should be kept compatible.
The Appraisal Team felt that this was a primary contributor to many of the procedure problems. The Shippingport facility is not an NRC licensed facility; is not a similar design, and; is operated under a different basic
43 philosophy.
In some instances this has resulted in trying to make portions of the programs compatible that.by nature were incompatible.
The basis for some of the procedures and techniques " inherited" from Shippingport were not readily apparent or were vague to licensee personnel. A licensee representative, after considerable difficulty, was able to locate the basis for several items only because he had considerable previous experience at Shippingport. As an NRC licensee, Beaver Valley should develop their own radiation protection program, procedures and surveillance program based on regulatory requirements.
A second major contributor is a shortage of licensee personnel in the Radcon Group.
Licensee personnel have recognized many of _ the problems and have started revising or rewriting procedures, however, they do not have sufficient time to complete the job. Overall, the licensee's Radcon procedures are inadequate because:
they do'not contain sufficient detail; do not clearly define the basis for the surveillance program; are too cumbersome for practical use, and; many are outdated and/ur need revision to reflect the methods and techniques being used.
Additional specific procedure problems are addressed in other portions of this section.
Radiation Work Permits (RWP)
The RWP program was one of the areas where the methods in use at the plant at the time of the appraisal did not correspond to the current procedures. According to Procedure RP2.1. " Area Entry Requirements" a RWP was required "for all construction or maintenance in areas where the radiation levels exceed 2.5 mR/hr and/or the transferable contamination level exceeds 450 pCi/100 cm. Procedure RP8.1, 2
" Radiological Work Permit" stated that: A RWP was required for all High Radiation Areas; may be required for any work by persons other than Operations or Radiological Ccntrols; "is required for any work task or system testing within the controlled area _if either radiation or contamination is present or is likely to result during the perform-ance of the task and/or test," and; that "Requirea.ents for a RWP are specified in BVPS-RCM, Chapter 1, Article II.F.4" Beaver Valley Power Station, Radiological Control Manual (8VP-RCM), Chapter 1.
Article II.F.4 stated that, " Radiological Work Permits are required f 3r any maintenance repair work or system testing within a controlled area if either radiation or contamination is present or is likely to result during the work performance.
BVPS-RCM, Chapter 2, which was written for radiation workers use stated that, " Maintenance work in controlled areas exclusive of the Service Building, normally requires initiation of a RWP in accordance with the BVPS-RCM, Chapter 3."
The requirements given in the various procedures or even within the same procedure (i.e. RP 8.1) were not clear or consistent. The requirements in effect during the appraisal were that all entries into controlled areas of the plant required a RWP.
The licensee's procedures, such as RP 8.1 made provisions for a D: sular RWP, Blanket RWP or Extended RWP. According to RP 8.1 Regular RWP's were for specific jobs, Blanket RWP's were primarily for long term maintenance tasks and Extended RWP's were issued to authorize routine entries.
Extended RWP's could be issued for High Radiation Areas.
i 44 t
_During the appraisal the majority of the RWP's issued were Blanket or Extended RWP's. A licensee representative stated that Routine RWP's are only used infrequently for short jobs performed by a few people.
Some of the re::uired entries on RWP's according to Procedure 8.1 under paragraph 3.3, "RWP Entries Required" included the following:
" Work Area" (description of); " Entry Authorization" (for High Radiation l
or Operating Exclusion Areas); " Work Steps" (description of work);
I
" Work Category"; " Radiological conditions of the work area" (radiation and contamination status); recording activity in uCi/ml if water was l'
present; " Anti-Contamination Clothing Requirements"; " Respiratory Protection Requirements"; " Work Party Dosimetry Information", and;
" Radiological Control Requirements to Perform Specified Work." The required information listed under " Radiological Control Requirements l
to Perform Specified Work" paragraph 3.3.6 included the following:
"the type of radiological monitoring required"; "the need for contin-l uous monitoring"; "the need for periodic air samples"; "the need for containment to perform stated work description," and; "if additional or special dosimtry is required." Twenty-eight active RWP's were reviewed (dated 1/6/81 through 3/1/81). Under " Radiological Conditions of Work Area" the majority stated "see attached survey." Surveys were not attached but were posted on the Field Office wall. Under
" Radiological Control Requirements to Perform Specified work" and
" Anti-Contamination Clothing Requirements" items are checked but the i
check was often followed by "Per RCF", "Per RCT" or "Per RCF/RCT" (Radcon Foreman or Radcon Technician.) All but two of the 28 RWP's listed some type of respiratory protection equipment under " Respiratory Protection Requirements". On 20 of the 26 RWP's listing respiratory requirements the phrase "precuationary measure" followed the requirement and 17 also stated "per RCF", "per RCT" or "per RCF/RCT".
Therefore, the RWP's were not being completed as required by procedure and I
workers could not refer to RWP's to determine the requirements for their job. In nearly all cases it was necessary for individuals to contact a Radeon Technician for requirements for each entry.
Licensee representatives stated that they had been in the process of and would revise the RWP procedure sucn that precautions and requirements would be clearly stated on the RWP. The other sections of the RWP form appeared to be completed as required. The " Work Steps" section was filled out by the Radcon Group. The " Work Step" sections were usually quite detailed which indicated that the Radcon Group was exceptionally well versed on the details of the job to be performed.
According to procedure RP 8.1 RWP's are to be terminated upon completion of the task, if the task is to be inactive for three days or if the
" work party leader" is assigned to another task requiring a RWP that will last more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The procedure also stated that Extended RWP's "are normally issued, to the last day of the calendar month, but may be changed as conditions require," A licensee representative stated that in practice RWP's were being issued for the following periods:
Extended-90 days; Blanket-30 days; and; Regular-7 days.
Through discussions and observations it appeared that the licensee had difficulty with RWP's not being cancelled upon completion of jobs and field copies of RWP's being posted in controlled areas long after the RWP was terminated.
45 l
ksponsibilities Procedure RP_8.1 stated that the Radcon Foreman (RCF) would determine i
if a RWP was required for a specific work request. The procedure also stated that a Radcon Technician would issue the RWP. Work party leaders were required by procedure to sign Regular RWP's to
" acknowledge the RWP provisions." For Extended or Blanket RWP's paragraph 3.1.3.6 of Procedure 8.1 required work party leaders signatures on the RWP to signify that they were " aware of the require-ments" and to " assure that all those he/she authorizes to enter the RWP will comply with the requirements." During the appraisal most RWP's were issued by a RCF. Many of the " Work Party Acceptance" signatures were department supervisors instead of " Work Party Leaders",
especially on Extended RWP's.
Extended RWP's issued for " Inspection
& Surveillance" of various areas of the plant were used by individuals from groups other than the group under the control of the supervisor signing the " Work Party Acceptance,"
It was not possible, in those cases, for the individual signing for " Work Party Acceptance" to-I fulfill the requirements of paragraph 3.1.3.6 of procedure RP 8.1 as stated above, since that individual had no control over who used the RWP.
Types of Surveillance Appendix 4 of the Radiological Control Manual lists required frequen-cies for airborne, radiation and contamination surveys.
Chapter 1 of the Radiological Control Manual also contains information on surveys frequencies. Appendix 4 requires radiation and contamination surveys daily in and around the Change Room /Restrooms, Lunch Room, Training Room, etc. Weekly radiation and contamination surveys are i
specified for controlled area shops, First Aid Room, Control Room and other selected clean area shops. The frequency specified for radiation and contamination surveys in the major portion of the controlled area was monthly according to Appendix 4 and guidance given in Chapter 1.
The majority of the areas beyond the controlled area, such as the Turbine Building, required annual radiation and -
l contamination surveys. The licensee needs to reevaluate the required survey frequencies.
In some instances the Appendix 4 schedule required more frequent surveys in areas where there was less potential for radiation and contamination than in areas where the potential wa, greater. Areas outside of controlled areas, especially at potential exit points should be surveyed more frequently.
Radiation and contamination surveys were conducted at a greater frequency than required. Appendix 4 indicates that a schedule was established for air sampling ir ide controlled areas but the frequency was not specified.
To the Appraisers knowledge the licensee's surveillance program did not specify a routine airborne sampling frequency although numerous air samples were taken. The licensee also had a number of continuous airborne particulate monitors in operation at various locations in the controlled area.
.w
.a 46 Airborne particulate and iodine samples are first counted in the Field Office to determine if they indicate above or below MPC values.
~ (As noted in section 3.3.3.2 the counting method.was found to be unsati sfactory. ) Samples approaching or above MPC were recounted in the Chemistry Dept. on their GeLi detector system. The use of the only available GeLi system by both Radcon and Chemistry created a back log of samples waiting to be counted.
On 2/27/81 at 3 p.m. a total of 38 air samples that had been collected over a three day period from 2/24 through 2/27/81 were waiting to be counted for particulate and/or iodine. An outage was in progress during the appraisal which resulted in additional' air sampling. The inability to rapidly count and evaluate air samples, especially during an outage, is unsatisfactory.
When protective clothing was returned from the offsite facility it was monitored with a GM count rate meter prior to use. The licensee's acceptance limits for laundered clothing was less than 0.1 mR/hr or 1,000 cpm abuve background.
Tools and equipment being removed from the controlled area were checked for contamination by Radcon personnel. The licensee's pro-cedures allowed personnel to frisk their own " personal" items such as pencils, paper, etc. when leaving the controlled area. When asked which items were or weren't checked by Radcon a licensee's representative said that Radcon checked all items such as pencils and papers prior to release.
The procedures should be amended to clarify this inconsistency.
Records The results of Radiation and contamination surveys were documented on survey forms that contained drawings of the areas surveyed.
A copy of each survey was given to a Radcon Foreman and a copy of each survey was also placed in the applicable RWP file in the Field Office.
The RWP files contained copies of all surveys, air sampling forms, notes, etc. that effected that RWP.
Copies of routine surveys were also posted at the entrance to the controlled area.
During the appraisal the surveys posted for the Reactor Building were dated from 11/15/80 to 12/19/80 greater than 60 days old.
The practice of leaving old Reactor Building surveys posted following an outage can be misleading and could result in exposures of personnel.
The unit used by the licensee for loose surface contamination was pCi/su.
"Su" is an abbreviation for Smear Unit and "5mear Unit" is defined as:
" generally equivalent to an area of 100cm (approximately 2
four square inches), but may represent an area smaller than 100 cm 2 4
1.e., the ' clean' smear results of a pencil or nail would be stated
<450 pci/su."
+
w m-
47 Access Control, Posting and Labeling Separate locker facilities and change areas are provided for. men and women. The normal access to the controlled area was through the hallway adjacent to the Field Office. During the appraisal much of the licersee's controlled area, with the exception of the Reactor Building was accessible without the use of anti-contamination clothing.
Contaminated cubicals and areas were posted individually and required anti-c for entry. All high radiation areas of greater than 1,000 mrem /hr and most other high radiation areas were locked. The keys were administratively controlled by the Shift Supervisor. During outages the licensee's. procedure allowed some keys to be checked out-of Radcon.
The following observations made by the appraiser on March 3, 1981 were indicative of some access control and procedural problems. An Operator entered a pump cubicle for surveillance under Extended RWP number B007368.
That RWP was for entry into High Radiation Areas on all elevations of the "PAB, Safeguards, Fuel /Decon Bldg." RWP B007368 required continuous coverage. Other items, including a full face respirator, anti-c clothing, etc. were marked on the RWP form but were followed by the notation "per RCF/RCT".
Licensed Operators i
L are allowed to self-monitor and the Operator used a survey meter for the entry. The Operator wore a full face respirator, full set of anti-c clothing and two pair of shoe covers.
The Operator wore j-personal clothing under the anti-c clothing and did not tape the l
anti-c openings.
Two step off pads were located inside the locked barrier to the cubicle. Although the step off pads had been installed in reverse order, requiring the removal of the inner pair of shoe covers prior to the removal of the outer set of shoe covers, the Operator removed the shoe covers in the proper sequence. After crossing the final step off pad into the clean area the Operator l
removed the respirator, hood, ccveralls and gloves. During the above sequence the Operator did not violate licensee procedures.
The licensee's precedures do not exclude the use of personal clothing under anti-c clothing. A licensee representative stated that they discourage this practice and some Radcon Technicians were under the impression that it was a requirement. Taping of openings is not always required by procedure. The licensee's normal proteoure did not require or provide guidance on removing anti-c clothing, except shoe covers and rubber gloves prior to crossing the final step off pad. A licensee representative stated that personnel are often allowed to go through clean areas from one contaminated area to another by simply removing their shoe covers and outer gloves but not their other anti-c clothing.
The wearing of personal clothing under anti-c coveralls and allowing anti-c clothing to be worn from contaminated areas into clean areas is not accepted health physics practice. Neither the licensee's procedure nor the RWP gave clear guidance or requirerients in these areas.
48 Two Operators were also-observed in another high radiation area.
Neither individual possessed a' radiation survey meter which violates the licensee's procedures and RWP.. A licensee representative stated -
that although they had passed thorugh the locked barrier that was posted as a "High Radiation Area" they had not actually entered the portion of the room where high radiation was present. The fact is that they did enter an area that the licensee had designated as a High Radiation Area without meeting the requirements set forth for such entries.
The methods specified by the licensee's procedures for posting were in accordance with the requirements of 10 CFR 20.
In addition the posting of rooms or cubicles included requirements for radiation zones 1 though 5, contamination zones A, B, or C, plus the minimum clothing requirements for entry into these zones.
Radiation zones 1 through 5 were 0-2.5, 2.5-15, 15-50, 50-100 and >100 mrem /hr, respec-tively. Contamination zones A, B and C were less than 450, 450-50,000 2
and greater than 50,000 pC1/100cm respectively.
Many individuals had problems remembering what raaiation levels corresponded to the various zones. The use of three zones for contamination levels accompanied by the minimum clothing requirements appeared to work well.
In general the Itcensee's posting was very good.
The following are examples of some posting practices that could be improved. On March 3, 1981 a yellow and magenta rope had been placed around the Safeguards Building Trench on elevation 722.
Caution, Airborne Radioactive Material Areas signs were attached to the ropes but the signs had been covered with yellow muslin bearing the wording "Only When Working".
Signs should be posted when needed and removed when not applicable. A number of smaller areas in the controlled area were posted as contaminated areas due to local leakage.
The additional information on these signs was not consistent and did not normally contain the information found on posting for cubicals or larger s
areas.
Numerous frisking stations were provided throughout the controlled area. A final frisking station was provided at the exit from the controlled area that lead back to the locker room.
From observation, review of prcblems noted in the licensee files and interviews with licensee personnel the Appraiser had reason to believe that Operations personnel need additional guidance and motivation if they are to continue to provide their own health physics coverage in High Radiation Areas.
The licensee's procedures i
and RWP's should De expaned to provide clearer Guidance on these requirements. Operations personnel and others then need to be trained in these requirements.
Management also needs to assure that all personnel are fully aware of managements commitment to following and enforcing procedures.
i
=
49 3.3.3 Instrument Suitability and Use 3.3.3.1 Portable Radiation Monitoring Instruments
~
The licensee uses a variety of portable survey instruinents.
The licensee had 52 high range survey instruments on inventory. Of these 14 were in emergency kits, 24 were inoperable, 3 were in storage and I was unaccounted for leaving only 10 high range instruments available for use. Of the 64 low range instruments on inventory, 23 were in emergency kits, 16 were inoperable, and 7 were unaccounted for leaving only 18 instruments available.
From reviews of the licensee's records including the Radcon records, out of service instruments is a chronic problem. Some instruments are returned repeatedly for repair and others had been out of service for as long as 8 months. When instruments were repaired no records _were maintained of what repairs had been made.
Thus the licensee could not determine if trends or generic problems existed with the instruments. The licensee needs to review the records for, and priority associated with, the repair of Radcon instruments.
3.3.3.2 Analytical Instrumentation Smears are normally counted on the friskers available at various points in the facility. The friskers consist of count rate meters equipped with thin window, pancake GM detectors.
A standard conversion factor was used to convert cpm to pC1 when using the frisker.
The source check values shown in procedure RIP 4.2 for the frisker indicate that the ef feciencies for the friskers range from 6.6*4 on the I range te 13.2's on the 100 range. This is not consistent with the practice of using one conversion factor for smear counting on the friskers. Paragraph 2.7 of RP 7.1, " Area Contamination Survey" stated that friskers weren't to be used to count smears if the background was greater that 0.5mR/hr but paragraph 3.4.2 said 0.05 mR/hr. The friskers were source checked daily and if appropriate, a check mark is placed on Form 2.13 indicating satisfactory response.
However, actual response data are not recorded on the form. If the friskers are to be used to count smears they should be afforded the same daily backgrcund and efficiency checks as the counter scalers which are used for this purpose.
Airborne particulate samples were counted in the Field Office using counter scalers with thin window, pancake, GM detectors.
Some lead bricks had been placeo around the sample holder to reduce the background.
The da'ly check of this counting system consisted of counting a j
source for a preset time and comparing the count to an acceptable range. The license?'s procedures did not specify the source to be used or the accertance criteria. When asked who determined the source to be used and the method for determination the acceptable range of the counts a licensee representative stated that this was up to the Radcon Foreman. The Appraiser was unable to determine the basis for-the specified range. Another licensee representative
50 stated that initially some work had been done to determine the ranges but records were not available. He said that the numbers listed in the procedures may contain typographical errors. The records for the MS-3 scaler serial number 337 indicated an acceptable range of 3,377 to 4,912 counts in 5 minutes.
The counts for the period from 2/1 through 2/22/81 ranged from 3,802 to 4,075 with a 4
maximum of 4,537. The a'verage count for the acceptable range specified was 4,144. Using the 4,144 average count the acceptable range was approximately + 18%. The source used to determine the efficiency for counting airborne particulate filters was plated onto a steel backing.
Correction factors were not applied to account for differences in backscatter or other factors resulting from the differences between the source and the sample. A counter correction factor and MDA were also determined daily. The licensee had detailed procedures for determing plateaus chi square, etc. for counter scalers; however, the MS-3's used for counting air samples were exempt from these tests. The procedures applied to equipment that was no. longer used or was out of service.
The Radcon group also used a portable dual channel analyzer for counting iodine cartridges in the Field Office to determine if the iodine activity was above MPC values.
Procedure RIP 5.13 was developed for field counting of iodine and was based on work done by the licensee. A calibration procedure had not been developed. At.the time of the appraisal the data collected by the licensee did not demonstrate that this technic accurately and consistently identified levels of iodine. A licensee representative stated that the system was to be used for gross indication of iodine levels and not for absolute values of iodine.
The licensee repertedly started to use the system prematurely because of the time delay in receiving results from the Chemistry Celi system.
Radcon personnel used the Chemistry GeLi detector and multi-channel analyzer on an as available basis for counting particulate filters and iodine cartridges.
The Radcon group had a Nal well detector and single channel analyzer for counting miscelianeous water samples. Two manual internal proportional counters were located in the Field Office for alpha counting but these instruments were inoperable at the time of the j
appraisal and they had a history of inoperability.
Operable counting equipment in the Chemistry Counting Laboratory included a GeLi with a computer based multi-channel analyzer; a liquid scintillation counting system; two NaI well detectors coupled
- to single charnel analyzers; a counter scaler coupled to a thin window GM detector; and; a gas flow proportional counter equipped with an automatic sample changer. Other gamma spectroscopy equipment was on site but was not being used.
.e 51 A standard is counted daily whenever the liquid scintillation counter is used. A new quench curve is developed annually or for each new batch of scintillation cocktail, which ever occurs first. A licensee representative stated that they normally tr'y to check the linearity on the GeLi system weekly or more often if they notice a channel shift.
Reportedly it is sometimes necessary to do hourly checks because of the effects of temperature changes in the room. The licensee has an informal quality control check where weekly GeLi source checks are plotted against a two sigma error band. The licensee calibrates the GeLi annually using a standard for one of the 8 geometries normally used. A licensee representative stated that if "the calibration for that geometry didn't change, the other geometries were assumed to be unchanged also." Efficiencies were determined annually for the gas flow proportional counter and GM counter scaler. Unless the efficiency factor changed significantly from year to year the efficiency used for calculations was not changed. Counting instruments should be source checked daily when in use to ensure proper operability.and effeciency.
The licensee needs procedures for the checks, calibration and use of counting l
equipment. ANSI N42.14, " Calibration and Usage of Germanuim Detector for Measurement of Gamma-ray Emission of Radionuclides" and ANSI l
N323, " Radiation Protection Instrumentation Test and Calibration" may be found useful in this regard.
Air Sampling Equipment The licensee's procedures for air sampling when using low volume air samplers with adjustable flow rates specified a fins rate of 4CFM for airborne particulate sampling and 2CFM for iodine sampling on charcoal cartridges. Two technicians westioned stated that they used 2CFM for airborne particulate filters and charcoal cartridges and another technician said he used 4CFM for either collection media.
The licensee must ensure that the technicians know which flow rate to use. The licensee's procedures for air sampling assume 100*J collection ef feciencies for the Whatman-41 filter paper for low volume air samplers and 99.9*J for high volume air samplers.
Based on the data in ANSI N13.1, " Guide to Air Sampling Airborne Radioactive Materials in Nuclear Facilities." the Whatmar.-41 collection effeciencies should be: 81?; at 2CFM; 9P; at 4CFM; and; 9&J at 28CFM, The licensee must determine the appropriate collectior, cf ficiencies for all sample media used in their air sampling program.
Procedure RP 7.5 lists a ca rection factor of 3 to be applied when counting a two inch diameter circle taken from a four inch diameter high volume air sample filter. When comparing the area of the two diameters the correction should be approximatey 4 vice 3; this requires reevaluation by the licensee.
Some technicians marked an X on airborne particulate filters with a pen to distinguish the direction of the air flow. This practice can damage the filter and cause the sample to be inaccurate.
52 The licensee's procedures required a four hour decay for airborne particulate samples, between collection and ccanting, whenever possible. The licensee should measure the short lived activity and compare it to the limits listed for short lived isotopes, in 10 CFR 20, Appendix B.
The Appraiser could not determine if a routine tritium air sampling program has been established.
Sampling for airborne tritium was done by Chemistry when requested by Radcon.
Chemistry required a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> delay between sample preparation and analysis. This presents a problem when trying to determine airborne tritium concentrations prior to entering an area. The delay may assure greater accuracy but methods are available that allow for sufficiently accurate results in a much shorter time.
Calibration Program Chapter 1 of the Radiological Control Manual stated that the normal calibration frequency for Radcon instruments was every six months.
Some of the individual procedures for calibration and.use of the instruments specified a calibration frequency and some did not.
The calibration frequency given for the gamma instrument calibrator was "at a frequency determined by the RCF and/or the RCS."
Portable survey instruments should normally be calibrated at least quarterly unless the equipment's history can justify a longer cal-ibration interval. The accuracy of gamma calibration sources should normally be verified at least annually.
Other 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.
The procedures did not require calibration at a sufficient number of points on each scale as recommended in paragraph ~
4.2.2 of ANSI N323.
In some instances the procedure did not require calibration of all ranges.
The calibrat'on procedures did not provide adequate instructions for adjusting the instrument being calibrated.
Many of the procedures did not contain acceptance criteria.
The requirement for recording "as found" and "as left" readings was inconsistent. Both sets of data should be recorded.
The licensee's procedures should address the orientation of the various instruments when used for surveys and during calibration.
If an instrument is calibrated with the detector orientated,
i 53 l
relative to the source, different than the orientation normally-used for surveys, correction factors may need to be developed to account for the directional dependence of the detector.
(Refer to paragraph 4.3.4 of ANSI N323).
Jigs for positioning some instruments were available with the model 10008 calibrator and others were being made. The cali-bration procedures should specify the jig to be' used or method to be used to position each instrument during calibration.
The uniformity of the beam intensity should be verf fied over the portion of the beam that strikes the sensitive volume of each detector.
Variations in beam uniformity may effect the methods used to determine the correct exposure rate for the instruments.
The licensee did not have a suitable method of calibrating the lower ranges on survey instruments.
Lower activity sources had been inserted into metal tubes for handling and were hand held next to the detector of the instrument being calibrated. This method does not provide sufficient calibration points or repro-ducable positioning.
Instruments that required electronic calibration were sent to the Instrument Group. The instrument group did not have proce-dures or data sheets for their portion of the calibration.
According to a licensee representative the Instrument Group just calibrated the instruments according to the technical l
manual.
A licensee representative stated that a calibration facility with "well" type sources was being designed into Unit 2 which was under construction. However, a suitable calibration facility is necded in this interim.
Some count rate instruments such as the RM-14 were electroncially calibrated with a pulser and then source checked by Radcon. During the source check procedure the calibration pots were adjusted to give the desired resdhg.
This technique invalidates the electronic cal!bration.
The itcensee possesses a Condenser R-Meter with ten R-Chambers. The R-Meter and five R-Chambers were calibrated on April 7, 1980 by the manufacturer. The licensee was not sure when the other chambers had bean calibrated, or when the R-Meter had been last calibrated prior to,\\pril 1980. A licensee repre sentative thought that the previous calibration had possibly been do,e in 1977.
Reportedly, a graduate student had performed initial calibration work on the gamma calibrator using the R-Chambers.
That work was done through the licensee's corporate group. When asked about that calibration data a licensee representative stated that it was stored
[-
l l
l 54 somewhere and was not available. There appeared to be a problem with information flow between the Corporate Health Physics Group and the Plant Health Physics Group.
The licensee had recently begun calibration checks on the gamma calibrator. The gamma calibrator contains cesium 137 sources. None of the R-Chambers being used had been calibrated for cesium 137.
In fact three of the chambers used were not designed for use with cesium 137 energy gammas. A licensee representative stated that the plant originated purchase. order for the Condensor and chamber R-Meter had specified cesium 137 calibration but that this was deleted from the final purchase order which was sent to the manufacturer. The licensee was utilizing energy response curves contained in the technical manual to determine the cesium 137 gamma energy correction factors for the R-Chambers based on the calibration data for other energies. The adequacy of the method for use and calibration of the Condensor R-Meter and chambers should be evaluated.
Procedure RIP 3.7, " Portable Neutron Rem Counter Model PNR-4/NRD-1" requires both electronic calibration and calibration to a known neutron flux.
Both calibrations were to be performed annually. A licensee representative stated that both the electronic and source calibration were being performed by the manufacturer. During September 18-20, 1979 the manufacturer of the PNR-4 neutron rem counter made neutron spectra measurements in the Beaver Valley Containment Building.
The results of that study were issued in a report to Beaver Valley dated February 15, 1980. The introduction of the report stated that not all desired data was collected due to an outage 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after dosimeter placement.
The introduction went on to state, "However, this report will attempt to present all data collected, to provide an interpretation of this data and to recommend a preferred method for neutron dosimetry." The report stated that the Beaver Valley PNR-4 over responded to the neutron flux probably as a result of the instrument being responsive to gamma radiation.
The " Conclusion and Recommendation" section of the report stated that the vendors dose rate measurements were significantly lower" than those estimated by Duquesne instrumentation" referring to both gamma and neutron instrument readings This section went on to state, "The calibration factors derived and used throughout this report are as accurate as we could define given time and financial constraints. You may apply any degree of conservativeness to these factors at your discretion."
The or.iy basic conclud on crawn or recommendations were in regard to the use to TLD dosimeters and the adequacy of the vendors TLD system.
The report did not address changing the calibration factor for the FNR-4 instrument.
The standard PNR-4 supplied by the manufacturer is calibrated for 50 cpm / mrem /hr. Following the study the licensee's instruments have been calibrated for 109 cpm / mrem /hr. A licensee representative said this was done based on the results of the study. Due to several problems encountered during the study, plus the lack of a specific 1
d
55-written recommendation by the manufacturer to change the PNR-4 calibration factor, the appraiser had concerns regarding the validity of that decision.- Before continued use of a cal.ibration techniques that results in approximately a 50% reduction in measured dose equivalent rates the licensee should have a specific written recom-mendation from the manufacturer or have the report reviewed by an
' independent expert to verify the assumptions. It may well be that the new calibration factor is valid but verification is needed.
The licensee's Field Calibration Procedures CP-2019 " Air Sampler Air Flow Determination" and CP-112, "MSA Gravimetric Dust Sampler Flow Calibration" provided for air flow calibration of the Radeco and MSA samplers.' respectively. These procedures did not specify the cal-ibration frequency for the calibration apparatus. Procedures were not available for the other types of air samplers used by the licensee.
For variable speed samplers, procedure CP-2019, specified acceptance criteria for the 2CFM flow rate but did not give acceptance criteria for the other air flow rates.
l Summary i
A number of problems are presented in this section of the report.
j It should be pointed out that Radcon personnal for the mast part appeared to be providing radiological protection for personnel that was adequate for the plant conditions at the time of the appraisal.
This was attributed to the knowledge and efforts of Radcon personnel; the amount of work coverage given by Radcon; plus, the fact that the primary system activity was still relatively low. Tne Radeon Supervisor, Foreman and most technicians were well versed on the radiological conditions of the plant. However, as the primary system activity, contamination, airborne and radiation levels increase the present program cannot continue to provide adequate controls. The Beaver l
Valley Station had just completed its first refueling.
Experience at other facilities has shown that activities in plant systems will continue to increase and may even take significant step changes.
Given the facilities, equipment and manpcwer available the Radeon-l efforts to date are commendable.
The deficiencies noted require l
prompt attention to assure continuad effectiveness of the program.
l 3.3.4 C_onclusions Based on the above findings, improvements in the follcwing areas are required to achieve an acceptable program:
l.
1.
The Radiological Controls Manual which includes the Radcon Procedures needs to be revised.
The present procedures are cumbersome, lack sufficient details, do not adequately describe the basis for the program and many are outdated. The procedures should be based on the needs of the Beaver Valley Facility not the Shippingport Facility.
l:
i 56
'2.
Some of the specific subjects or areas needing improvement are:
instrument selection and use; survey frequencies; instrument calibration; air sampler calibration; the methods for performing checks and calibration of Radcan and Chemistry counting equipment; RWP's and;_use of protective clothing.
In addition, wording in many procedures caused them to be recommendations versus positive guidance or requirements. The problems that appeared.to exist between the wording of procedures and-QA's interpretation needs to be resolved.
3.
The RWP program is in need of a complete reevaluation. The Radcon procedures and RWP's need to define protective measures and equipment requirements.
The procedures need to be followed.
The frequency for radtological surveys, (radiation, contamination, and ' airborne including tritium) need to be reevaluated.
4.
Additional emphasis needs to be placed on procedure training and adherence to procedures for Operations personnel allowed to self monitor as well as other plant supervisors.
Managements commitment to procedure adherence needs to be reinforced.
5.
Records need to be maintained on the repairs made to Radcon instruments. The reason for the large quantity of instruments being out of service needs to be determined and corrected.
6.
More information on the source to be used and expected reading associated with the licensee's daily source check of survey instruments needs to be documented.
The licensee should consult the methods used to ANSI N323, " Radiation Protection Instrumen-tation Test and Calibration."
7.
If friskers are to continue to be used for counting smears better methods for determining the efficiency, calibration and daily source checks are needed.
8.
The methods for counting air samples was unsatisfactory. The quality control checks and calibration of the GM counters, dual channel Nal system and GeLi system were inadequate. Samples could not be counted within a reasonable time on the GeLi system or for tritium.
Concentration of short lived isotopes need be evaluated.
9.
Collection efficiencies for air sampling media need to be determined and incorporated into procedures.
- 10. Quality control of chemistry counting equipment needs to be reviewed and documented.
1
57
- 11. The calibration program and procedures for portable survey instruments needs to be reviewed to meet the recommendations of ANSI N323.
- 12. Additional justification is needed to support changing the calibration factor for the licensee's neutron rem counters from 50 to 109 cpm / mrem /hr.
- 13. Calibration procedures for. air flow devices are needed for all types of air sampling equipment used by the licensee.
Other areas of the surveillance program appear acceptable, but the following areas need to be improved:
1.
Clarification is needed concerning what personal items leaving controlled access can be frisked by the individual versus Radeon personnel.
2.
Surveys for the Reactor Building should be removed from the current surveys posting area followir.g an outage.
3.
An indication of the radiation levels present in high radiation areas should be available at the entrance to those areas.
4.
Radcon technicians need clearer guidance on current requirements such as the use of anti-c clothing (use of personal cloching under coveralls, taping openings, etc.).
The revision of procedures should aleviate many of these problems.
5.
Clear guidance needs to be established on the requirements for wearing anti-c clothing through clean areas.
6.
Establish uniform method for posting information for " temporary" contaminated areas that are not defined by existing barriers.
Develop methods to track these areas to ensure repair of leaks, decontamination, etc.
7.
Ensure that signs used to post radiciogical areas are removed when not required and that they are not just tempcrarily covered.
8.
The cor. ction factor associated with counting 2 inch diameter sections of the high voleme air sampler filter needs to be revit.wed.
9.
The licensee needs to correct the practice of placing an "X" on the surface of particulate air filters.
- 10. The licensee needs to review the use of the Condenser R-Meter and Chambers. More detailed guidance is needed for use and calibration of this instrument.
58 11 '. Data collected during the set up of calibration procedure and instrument checks needs to be filed so that it is readily retrievable.
- 12. The flow of technical information from the Corporate Health Physics Group to the Plant Health Physics Group should be increased.
- 13. The licensee necds to provide controls to ensure that technical changes to purchase orders for Radeon equipment, calibration, supplies, etc. are not changed without prior consultation with the Radcon Supervisor.
- 14. Acceptance criteria needs to be provided for all calibration procedures for air samplers.
4.0 Radioactive Waste Management 4.1 Documents Reviewed a.
Maintenance Surveillance Procedure No. 43.0782, " Radiation Log Rotemeter and Process monitor Eighteen Month Calibration (Radiological)."
b.
Maintenance Surveillance Procedure No. 43.18R, Revision 1, " Radiation Process Monitor RM-LW 104, Liquid Waste Effluent Filter Discharge-Liquid Activity".
c.
Station Administrative Procedure, Chapter 6, " Radiological Control Group Administration," Revision 2, dated November 4, 1980.
d.
RADCON Manual, Chapter 1, Part III, Section F, "Use of Temporary Hoses / Piping," Issue 3, Revision 1.
Temporary Operating Procedure (TOP), " Operation of Temporary Liquid e.
Waste Deminerlaizer",
f.
Temporary Operating Procedures (TOP) 80-22, "Hi-Hi Setpoint Calculation for LW104".
g.
RADCON Manual, Appendix 10, Section F, R.C.M. Form No. 6.1, " Radioactive Waste Discharge Authorization-Liquid".
h.
Radiation Work Permit No. 6309, " Guidelines for Monitoring Trash".
i.
Control Room Log L3-11 Instrucions, Waste Handling Systems-7 day Running Inventory.
J.
RADCON Manual-Chapter 3:
Radcon Procedure No. 3.9, " Monitoring Vehicles," Issue 2.
l
59 Radcon Procedure No. 3.11. " Shipping Solid Radioactive Waste for Burial-Drums", Issue 1, March 29, 1975.
Radcon Procedure No. 3.12, " Shipping Solid Radioactive Waste for Burial-Liners," Issue Revision 2.
Radcon Procedure No. 3.13, " Requirements Checklist for Shipping Greater than Type A Quantities of Radioactive Material," Issue 1, Revision 1.
Radcon Procedure No. 12.3, " Radioactive Shipment Records,"
Issue 1, Revision 2.
k.
Station Administrative Procedure, Chapter 2, " Station Organization and General Instructions," Revision 0, September 1, 1980.
1.
Station Administrative Procedure, Chapter 4, " Plant Operations Group," Revi sion 3, February 1,1981.
m.
Memorandum dated November 23, 1979 from J.A. Kosmal to J.A. Werling.
Subject:
Campaign to Reduce Non-contaminated Compacted Waste.
n.
Beaver Valley Station Operations Quality Assurance Program (Manual).
o.
Memorandum dated December 17, 1980 from J.S. Kosmal to J.A. Verling.
Subject:
1981 Objective-Radcon p.
Memorandum dated December 11, 1980 from J. A. Kosmal to J.A. Werling.
Subject:
1980 Objectives Quarterly Status Report-Fourth Quarter.
4.2 Program Responsibilities The responsibility for the operation of the radioactive waste system lies with the Plant Operations Group. Within this organization, no clear lines of responsibility exist and no formal, documented job descriptions have been developed. However, these responsibilities have been assumed by individuals, partially on their own initiative, with one individual being responsible for each of the major areas of solid, liquid, and gaseous radioactive waste.
The Chemistry Department serves as an advisory group to the Plant Operations Group for the processing of liquid radioactive waste.
The Chemistry Department will determine processing efficiencies (e.g., decontamination factors for demineralizers and evaporators) and will evaluate special problems upon request f rom the nat Operations Group. No formal program exists for evaluating system performance.
The Radiation Control Supervisor is responsible for radicactive source control, and the radiological aspects of waste shipments leaving the site.
60 4.3 Waste Processing Systems 4.3.1 Liquid Waste Systems The original liquid radioactive waste system was designed to segregate the low level liquid waste (less than 10
- uCi/cc) from the higher level liquid waste (greater than 10 ' uC1/cc).
The low level wastes were to be filtered and the filtrate discharged to the environment.
The high level wastes were to be evaporated and either released to the environment or recycled back into the plant.
Due to inadequate design and operational problems, the segregation and processing systems have never functioned as intended.
From the outset, the.
systems were incapable of handling the volumes of waste encountered.
The liquid waste processing components consisted of filters and a single 6 gpm evaporator with a polishing demineralizer. The initial liquid storage capacity consisted of the following:
2-2,000 gallon low level waste drain tanks 2-5,000 gallon high level waste drain tanks 2-1,300 gallon laundry and contaminated shower drain tanks 2-3,000 gallon evapotator test tanks With this initial design the major problems encountered were: (1) the operating efficiency and reliability of the evaporator and (2) the unavailability of alternate processing paths, and (3) the small tankage capacity. These problems have been exaggerated by the liquid waste inputs to the system being greater than anticipated and more than the system could properly handle.
The process system evaporator has experienced typical corossion problems and has nevar operated at design capacity. The evaporator currently operates at about a 2 gpm throughput.
Because of these operational problems, the condensate polishing demitieralizer, LW-I-1, has been used to process more highly contaminated water than it was designed to process.
The location of the demineralizer is in an open space on the 735 ft. elevation of the PAB and its use as a process demineralizers has increased the radiation levels in this area. Temporary shielding (lead blankets) has been used to reduce the levels. However, the general area radiation levels remain higher than desirable. At the time of the appraisal, the radiation levels on contact with the wire cage erected around the demineralizer were 20-25 mrads/hr and radiation levels in the general area were approximately 5 mrads/ hr.
A process radiation monitor (RM-RW-101) for the river water system is located in this general area. This monitor is to provide indication of-leakage from the Component Cooling Water Heat Exchanger to the river water system. The radiation levels in the general area have resulted in an increased background on this monitor, approaching the alarm setpoint. The effectiveness of this monitor to identify small amounts of radioactive contamination leakage into the river watar system is questionable.
This subject is discussed more in section 4.4.1.
61 An additional problem area that has affected liquid radwaste processing is the input of laundry solutions into the system.
They have caused foaming and carry over into the evaporator and deplete the demineralizer
. beds thus reducing their efficiency and useful lifetime.
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Several actions which have been taken to help alleviate these problems follow:
Prefilters are being installed on the PAB sumps to help increase the efficiency of the evaporator and demineralizer.
A replacement reboiler for the evaporato-has been ordered which will increase evaporator efficiency.
Chemistry control is being examined in an' attempt to increase evaporator efficiency.
Laundry solutions are now controlled on a batch bases. Anti-foaming agents are added to reduce foaming and increase evaporator efficiency.
The major action taken to correct the inadequate design capacity is the use of a temporary demineralizer system. This system constitutes an alternate processing capability. However, this system is not available at all times but it is installed on an "as needed" bases. The use of this temporary system is discussed later.
To help alleviate the water storage problems, the licensee has used other storage capacity as available. The main operational modification was the use of the steam generator tanks (LW-TK 7A and 7B) for low level waste storage. This option became available because of the pre-operational change from a phosphate to an-all volatile chemistry treatment for the Steam Generator water.
With an all volatile chemistry treatment, tF1 steam generator drain tanks did not provide a useful hold-up/ discharge capacity because of the volumes involved.
The licensee recycles the steam generator blowdown as make-up instead of discharging it to the river. These tanks are located outside and are of cement construction with capacities of 34,000 gallons each. A local high level alarm is available but no alarm exist in the control room. The tanks communicate with each other through a high level overflow.
The high, high overflow is to the yard.
Prior to modification (high density rack installation), the spent fuel pool had been used tc store low level waste. This occurred during 1977 and 1978.
It was at this time that the temporary demineralizer was first used to aid in the processing of liquid waste.
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a 62 At the time of the appraisal, one of the two reactor coolant drain tanks (part of the boron ecovery system) was being used to store ~ low level. liquid waste..The other tank was available for reactor. operations, if needed. This waste water (approximately 60,000 gallons) had been in the tank for several months awaiting processing by the temporary demineralizer system.
The water inventory problems experienced at Beaver Valley can be exemplifed by the volumes discharged during the first two years of operation.
In the last 6 months of 1976 (which are essentially the first 6 months of operation), 3.6 million gallons of liquid waste were discharged. During 1977, the volume was 3.1 million gallons.
It was in 1978 that actions Sere taken to try to reduce these volumes by reducing the irputs.
In 1978, the volume decreased to 2.1 million and in 1979 a further reduction to 1.4 million gallons was achieved.
A goal of 60,000 gallons per month was set by the Plant Operations Group. This goal was achieved during the first 8 months of 1980. The last 4 months exceeded the goal due to excessive water from the refueling outage and the draining of the reactor coolant drain tanks for weld repairs.
However, as a whole, for the calendar year 1980, the average monthly discharge was 59,000 gallons which is a marked improvement over the 300,00 gallons typical of the first two years of operation.
As stated above, it was in 1978 that a concerted effort was undertaken to reduce unnecessary input into the liquid waste system. This was initiated because of the discovery that unidentifiable leakage into the PAB sumps was a major cause of the water inventory problems. Much of this input was found to be from normally nonradioactive systems.
These previously clean inputs were becoming contaminated from the PAB drain system and had to be processed thru the liquid waste system.
By rerouting the inputs from the drain system to clean areas er the river water system (a non-contaminated system) major reductions in waste inputs were achieved. The river water (RW) system provides a convenient receiver for these inputs because the system operators at a negative pressure thereby providing a suction on gravity drains.
The RW system is also monitored thereby capable of providing indication of any unexpected radioactivity inputs.
The design changes initiated consist of the following:
The charging pumps were used to backflush the river water system filters with the backflush water being added to the raowaste system. A modification was made whereby the flush water is returned to the river water system. The previous backflushing flow path not only added excessive uncontaminated water to the liquid radwaste but also introducted silt into the system.
The silt was adversely affecting the process systems.(demineralizers, filters, and evaporator) operability and efficiency.
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t 63-The cooling coils for the supply air system to the PAB ventilation were adding approximately 1-3 gpm from'the cor.densation drains to the radwaste system. The cooling coil draining has been rerouted to a clean area ~ for discharge as non-contaminated waste water.
For determining conductivity in the steam generator, a constant letdown flow is maintained through a cation demineralizer column located in the PAB.
The waste iss being added to liquid waste. A valving change was initiated-to reroute this flow to the river water system. Should a steam generator tube leak occur, procedures require that this flow be switched back to radwaste.
Condensation from the main steam room ventilation system has been rerouted from re.dwaste to the river water system.
This ventilation system is isolated if a steam generator tube leak occurs to prevent inadvertent, undetected releases.
The auxiliary feed pump flange leakage provided an input of 1-2 gpm per pump to radwaste.
The seals have since been repacked and the catch basins of the pumps were rerouted to the river water system.
The plant filtered water system is used for cooling water for the deaerator vacuum pump on the boron recovery system.
This cooling water added 1/4-1/2 gpm to liquid waste. The drain has been rerouted to a building roof top.
A design change has been initiated to route the auxiliary feed pump room floor drains from liquid radwaste to a clean area. Completion of the change is awaiting install-ation of a radiation monitor on the drain line.
Other corrective actions taken within the last several months to help identify leakage in systems adding unexpected inputs to the liquid radwaste system include:
(1) the addition of a control room alarm when the PAB sump pumps are actuated on high level; and (2) the initiation of a control room seven day running log of the waste inventories.
The seven day log provides for better accountability and control over the identification of small increases in tank levels which were unidentifiable by the previous logging scheme. At the time of the appraisal the liquid waste inventory was between 40,000 and 50,000 gallons (not including the 60,000 gallons in the Reactor Coolant Drain Tank).
This 40,000 to 50,000 gallons inventory represents about 1/2 of the total liquid radwaste storage capacity at the facility. When the 60,000 gallons from the RCDT is added, the designed liquid storage capacity is exceeded.
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64 With the current inventories and storage capacity available, the facility fails to meet the design capacity for PWR liquid radwaste systems as addressed in ANSI /ANS 55.6-1979. This standard calls for tank sizing to accommodate maximum waste inputs that can occur when prccessing is not available with an additional 20% safety factor and 10*l, freeboard allowance. A major factor compounding the under designed storage capacity is the unavailability of redundant processing components. The importance of this redundancy has been previously discussed.
In the past, the licensee has relied on a temporary deminerlaizer system to provide back-up processing capability.
This type system has been used predominantly for processing when the liquid waste evaporator is inoperable and when the inventory of liquid radwaste becomes excessive.
The first use of a temporary demineralizer was approximately two years ago to process a back log of liquid radwaste that was being stored in the spent fuel pool.
(No fuel was in storage during this period). The temporary system is located in the decontamination building and is connected to the liquid waste system via PCB piping.
Since its initial use in 1978, this system has been installed and operated on as "as needed" basis whenever the accumulation of a large inventory of liquid waste has resulted in a storage problem. The temporary system currently in use consists of a pre-filter, a charcoal filter and an open (atmospheric) bed demineralizer suppled by Chem Nuclear. The design flow capacity is around 20 gpa with a total throughput capacity of between 200,000 and 300,000 gallons.
Temporary shielding has been placed around the demin bed and the charcoal filter is located inside a shield well.
Even though consicered temporary, this type system has been used periodically for the past two years. The system still has the appearance of a make shift set-up. The PCB (and some iron) piping is supported by ropes tied to cable trays and upper platform structures. A local high level alarm (local) has been installed but a remote high level or a high radiation alarm is not available. The pre-filter must be periodically changed-out at the expense of unnecessary exposure to radiation. A change-out on 3/5/81 involved the manual removal of a cartridge reading approximately 1 R/hr, which had to be hand carried several hundred feet to be placed in a shielded container. This changeout was necessary after the precessing of approximately 20,000 gallons of water.
A radiation monitor (RM-16 with GM probe) is located in the decon building.
The probe is adjacent to the pre-filter.
However, the monitor read-out is located on a platfe.m above the system. The operator must leave his immediate work area in order to read the radiation levels on the prefilter housing.
65 The current operation involves recycling liquid waste through the demineralizer from the steam generator drain tank (LW-TK-78).
This recycle mode of operation, instead of once-through to a
> receiving tank, is a less effective and more time consuming method of processing liquid waste.
Being temporary, the current set-up lacks the necessary system and radiological design of a permanent processing system, e.g.,
location, piping, shielding, remcte indicators, and remote operators.
The corrective actions taken by the licensee have accommodated the water inventory and process system problems without adversely affecting plant operation and safety.
The licensee has been able to maintain radioactivity releases well within the facility's design ~ objectives. However as the plant gets older and experiences crud build-up and minor fuel degradation, operational problems can be anticipated. Continued reliance on a temporary.demineral-ization system is unacceptable.
4.3.2 Solid Radioactive Waste System The solid radwaste processing system is an ATCOR cement system. The major components consist of:
(1) a resin waste tank which receives the spent resins from the liquid radwaste system, the CVCS, and the spent fuel pool clean-up system, (2) an evaporator bottoms hold tank, which receives the bottoms from the liquid waste evaporator and the two boron recovery evaporators; and (3) a cement silo with associated mixer feeder which feeds the cement and provides mixing with the spent resins or evaporator buttons prior to discharge into 65 cubic foot solid waste liners. The normal system output is about 5 liners per month.
Even though the system provides an acceptable solid waste product, the system suffers from an original design that did not adequately consider keeping occupational exposures ALARA and routine maintenance.
Two examples of this shortcoming are:
(1) the transfer and metering pumps are not shielded from the tanks; and, (2) tanks are located in cubicles whicn afford little space for maintenance.
Major maintenance outages on this system recently highlighted these following design problems:
About six months ago, the metering pump on the resin tank became inoperable. At the time, the tank contained resins yeilding a radiation dose of 150 R/hr. Because the pump is not shielded from the resin tank, the resins had to be removed before the removal and replacement of'the pump. This was achieved by the use of a portable air operated pump.
The resins were transferred to a liner and subsequently shipped dewatered. By removal of the resins the cump repair was 4
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66 performed without major radiation exposure. A total of 1.3 man-rem was expended to complete the pump repair.
At the time of the appraisal, heat tracing on the evaporator bottoms hold tank had been lost, which resulted in the bottoms solidifying due to the boric acid concentration and the degrad-ation of the pump seals on the transfer pumps.
The radiation levels associated with this maintenance were around 700 mrads/hr in the general area; 5 rads /hr at contact with the pump; and, 1-3 rads /hr, in the general area under the tank where personnel had to remove the pump. At the time of the appraisal, a total of 6 man-rem had been expended on this maintenance activity. A major exposure job ef replacing the insulation on the new pump remained to be performed.
As the system experiences additional operational wear and crud accumulation, more occupational exposure problems can be expected for both routine operation and maintenance.
To assure the acceptability of the solidified product (i.e., no free standing water), an extra amount (3-4 inches) of cement is added to the top of the product.
This addition is achieved by continuing to run the cement fuel pump for a fixed period of time after the metering pump is secured.
Prior to shipment, each liner is visually examined to assure the absence of water on the top of the product. Tests were performed to assure that the cement / product mixture would solidify under varying boric acid concentrations.
Test batches were mixed with 10%, 12%, and 16% boric acid.
All batches solidified at varying times depending on the boric acid concentration. The 16%
batch required around 6 days to completely solidify.
Comp _ actable Trash The contaminated trash at Beaver Valley is compacted, if compactable, in 55 gallon drums by a hydrualic compressor. Non compactable piping and hardware are stored and will be decontaminated and disposed of as nonradioactive trash.
During 1980 in an attempt to reduce the volume of compacted trash, the licensee established a trash sorting program.
Under this program, trash is monitored piece by piece for segregation of the noncontaminated from the contaminated trash.
This monitoring is performed on a designated table equipped with a dedicated ventilation system.
This local ventilation system provides a 200 fpm flow over the work area to prevent worker exposure to any airborne activi'v and the spread of activity resulting from the sorting operation.
This process has reduced the compacted trash generation to about one drum per day.
To assure detection of low level contamination, each piece of trash is separately monitored.
The detection limits are less than 100 cpm with an Eberline RM14 monitor which is equipped with an HP 210 probe
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or less than 450 pCi/100cm 2 of removable contamination. These limits are consistent with Regulatory Guide 1.86 and are considered acceptable for establishing a contamination control program.
Solid Waste Storage The original plant design did not provide adequate storage capability l
for solid waste. A total of 6 liners can be stored in the waste processing' area.
To provide added capacity, 12 additional liners can be stored in the decon building.
For the compacted waste (55 gallon drums), an area adjacent to fuel receiving is used for temporary storage. A total of 365 drums, triple stacked, can be stored in this area.
If the licensee were to experience problems in-l disposing of the waste (e.g., burial site restrictions), the limited storage capacity could pose a problem. Additional temporary storage would have to be sought and would most likely not provide the isolation and shielding that the current temporary facilities provide. This fact could result in increased radiation levels in undesirable locations.
The licensee is currently examining the construction of a new storage facility with a capacity equivalent to two years solid waste generation.
An additional problem confronting the licensee is the= storage of laundry and contaminated equipment. This area is discussed further in Section 6, Facilities and Equipment.
4.3.3 Gaseous Radioactive Waste System l
The original gaseous waste delay system included a charcoal subsystem l
designed to delay xenons for about 30 days and kryptons for about 2 l
days. An overhead gas compressor was to take suction on this subsystem and direct the gases to a surge tank.
From the surge tank the gases were to be recycled as cover gas to the volume control tank (VCT) in the CBCS or directed to one of three waste gas decay tanks (WGDT).
Due to moisture problems (carry over) in the CBCS degassifier, the charcoal delay beds have never been used.
Consequently, the gases are not recycled as cover gas to the VCT.
This forced change in the operation of the gas hold-up system has resulted in the actual hold-up decay times for the radioactive gases being less than the designea hold-up decay times.
For example, during the first 2 months in 1981, a total of 15 batch releases were made from the WGDis. The average hold-up time was about 12 days. This period included a plant shutdown which resulted in several tanks being released with only a 1 day delay.
Currently, this decreased hold-up capability is not an operational problem in maintaining gaseous releases within the ALARA guidelines.
During the last refueling outage a major maintenance / system modifi-cation on the charcoal subsystem was completed. The modification included the addition of a chiller on the degassifier to remove excess moisture.
If the changes are effective, the licensee should l
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68 be able to place the charcoal subsystem into operation. This fe'ature will be a major factor for assuring that future releases are maintained ALARA.
The ventilation system in the PAB was recenity rebalanced in an attempt to alleviate flow distribution problems. Localized accumulation of radioactivity in the PAB and incorrect directional flow (high activity areas to low) have been experienced with increasing frequency over the past several years. At the time of the appraisal, the licensee had not been able to verify the effectiveness of this rebalancing.
The operability of the various ventilation filtration systems was examined by observing the pressure differential across the filters as measured by a AP gauge. All systems examined indic.ated differential pressures typical of normal operation (i.e., no excessive loading of filters was indicated based on the observed AP).
The change-out of the HEPA and charcoal filters in the process vent system was discussed with the licensee. This system is not an ESF system.
Consequently, the operability and performance of this system are not addressed in the Technical Specifications. The licensee stated that no procedures exist for routine, periodic maintenance (filter examination, change-out, and testing) for this system. However, it has been past practice to frequently examine system differential pressure and change-out filters as needed. The HEPA filters were last changed in April 1978 and the charcoal filter in February 1978. Also, the system is not subjected to any leak or penetration testing to verify efficiency.
Due to these two facts, (1) the change-out of the filters is not covered by proceduras and (2) no efficiency testing is performed, the actual performance of this filtration system within the designed operation conditions is questionable. This is not a major factor because under abnormal conditions flow is diverted from this system to the main vent system, which is an ESF, Technical Specification System. However, this system is the major filtration system for the WGDT discharges, and being so is a major contributor to maintaining routine releases ALARA. Realizing that the system design does not include provisions for effeciency testing, the licensee should subject this system to other means available for assuring system acceptability.
For example, the filter change-out should be addressed by approved procedures which may include independent verification of installation.
4.4 Effluent / Process Instrumentation 4.4.1 Liquid Monitoring System The number and location of the liquid effluent and process radiation monitors appeared adequate. However, increasing background radiation levels has affected the capability of several of these montiors to
69 perform their. intended function. Two of these monitors.are discussed below:
1.
The liquid effluent monitor, RM-LW 104, has been plagued with increasing background levels due to crud accumulation and location. This monitor is-located in the same cubicle with a prefilter for the liquid waste demineralizer, LW I-1.
The
. radiation level on contact with the filter housing was about 50 mRads/hr with a general area level of 3 mrads/hr in the vicinity of the monitor. These two radiation contributors (crud accumu-lation and LW I-1 pre-filter) have increased the background levels on RM LW 104 to the point that a special Temporary Operating Procedure, TOP 80-22, had to be developed for estab-lishing interim alarm setpoints. This procedure was implemented on 7/28/80 and is to be effective until the background problem is corrected.
The TOP implements a more detailed method of correlating the nuclide concentration of the tank to be discharged with the monitor sensitivity (i.e., cpm /uCi/cc for each nuclide identified).
The 111 Hi alarm set point is established at one-tenth of the corresponding MPC concentration. This method allows for the discharge of liquid waste which would have been impossible with the current background levels and the previous method of estab-lishing alarm setpoints. The current use of this monitor does not pose a health and safety problem; however, on occassion it has posed an operational problem.
The increased background and alarm set points have hindered or delayed the timely releases of liquid radwaste to the environment.
2.
The purpose of liquid process monitor, RM-RW-101, is to warn of contamination leakage into the river water system, predominately from the component cooling water heat exchangers. This monitor is located in the open space of the 735 ft. elevation of the PAB. Also located in this area is the liquid waste demineralizer, LW-I-L.
Due to the increased radiation levels caused by the deminalizer, the background on this monitor is approaching the hl clarm setpoint. At the time of the HP Appraisal, the background levels on RM-RW 101 were around 400 cpm.
The high alarm was set at 500 cpm and the high, high alarm at 830 cpm.
The con-version factor for this monitor is 1.3 x 10 ' uCi/cc/ cpm.
The detection of minor leakage from the component cooling water heat exchanger to the river water system could be jeopardized by the high background level. Currently, this is not a problem because of the relatively low alarm setpoints. Also, a back-up monitor, RM-RW 100, is located on the river water system effluent.
This effluent monitor would warn of a contaminated system; however, its ability to detect minor leakage from the component
70 cooling water heat exchange is questionable because.of the l
dilution involved.
If background continue to increase forcing the readjustment of. the alarm setpoints on RM-RW 101, the usefulness of this monitor to-perform its intended function will become questionable.
Neither of the potential. problem areas discussed above represent a current public health and safety problem.
However, they do indicate potential operational problems, that if left uncorrected i
could impact on plant operations.
4.4.2 Gaseous Monitoring System The number and location of the gaseous samplers appeared adequate.
Also, the samplers and monitoring equipment appear well maintained, except for the multi sampler, RM-217, which collects a sequential sample from 12 locations in the PAB and control room, which has been out of service since August 1980. Two potential problem areas were noted in the sampling system arrangement.
1.
The typical flow rate thourgh the samplers which include charcoal l
cartridges for radiciodine analysis was around 7-9 cfm. This high flow rate decreases the absorption efficiency of the charcoal for the iodine because of the reduced residence time.
Based on this f act a collection efficiency of 60?? is assumed for the cartridges.
The actual collection efficiency of charcoal cartridges depends on many factors; relative humidity, residence time, impregnation, particle size distribution, and iodine species. For example, for one charcoal cartridge currenity being marketed, the retention efficiency for methyl iodine (CH I) drops from about 90*s retention 3
at 1-2 cfm sample flow to around 50?; retention at 4 cfm flow.
Other iodine species (elemental and HOI) have a higher retention L
efficiency than the methyl iodine. Typically for PWRs auxiliary l
buildings, the methyl iodine comprises over 50?; of the available i
It follows that, the actual efficiency of the collection media varies with species and flow rate. The variability is
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much less at low flow rates (1-2 cfm) irregardless of species.
2.
The exhaust from the PAB ventilation sampler is not piped back to the ventilation system but dur.ps directly into the area where the sampler is located. This arrangement has the potential for increasing the airborne activity levels in the cree of the sampler. Consideration should be given to rerouting the sampler exhaust back to the PAB ventilation system.
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~4.4.3 Monitor Calibration The initial calibration of the monitors at Beaver Valley was performed by Radiation-Management Corporation (RMC). According to the RMC study, at least one of each' type of detector / sampler geometry was calibrated in place or with a mock-up containing a known concentration of a specific radionuclide. All;other monitors were calibrated using prepared sources in a-lead calibration jig.
Each monitor was.
calibrator with from 6 to 8 calibration sources and a corresponding 2
sensitivity (cpm per uC1) was' determined for each source.
From this
' data two factors for each monitor were determined:
(1) instrument response (cpm /uC1). and (2) a calibration factor (cpm /uCi/cc).
The licensee uses this RMC initial calibration study as the basis for the periodic re-calibration of the monitors. The calibration-is broken into two parts, electronic calibration performed by the-
- instrument department and radiation calibration performed by a Radiation Technician. One -potential shortcoming of the calibration procedures was identified.
Under the radiological calibration, the instrument is calibrated normally with two of the calibration sources used during the initial calibration..These two sources result in instrument response which typically fall within the same decade on the scaler. ANSI N323 sets calibration standards which specify fer readout instruments, a calibration performed at a minimum of one point near the midpoint of each decade.
In order to assure the linearity of the monitor over the entire range, the monitors should be subjected to a radiological calibration consistent with the ANSI standard. As a minimum, each monitor should be calibrated at several points within each decade.
Accident Instrumentation (NUREG 0578)
In complying with the requirements for increased capability for i
effluent monitoring, that resulted from the lessons learned froa TMI NUREG (0578 and 0737), the licensee insta' led new intermediate atd high range gaseous monitoring systems on ti = process vent (GW 108\\,
the ventilation vent (VS 101), and the elevated vent (VS 107). Eati.
system consists of an intermediate range noble gas monitor (GM detector), a high range noble gas monitor (GM detector), a particulate filter, iodine sampler (charcoal or silver zeolite), and an ambient radiation monitor for background subtraction.
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The upper concentration range of these monitors for Xe-133 is 105 uCi/cc, which meets the requirements for increased detection capability. The effluent range of the monitors for Xe-133 are as follows:
Monitor Intermediate Range High Range
-3 2
I 6
VS 101 10 to 10 Ci/sec 4 x 10 to 3 x 10 Ci/sec VS 107 5 x 10 to 5 x 10 Ci/sec 2 x id to 2 x 106
-4 1
Ci/sec
-5
-1 4
GW 108 2 x 10 to 2 x 10 Ci/sec 7 x 10 to 7 x 10 Ci/sec Two potential probelm areas were identified upon exam-ination of the monitors.
Prior to the gaseous sample stream entering the particulate filter and charcoal cartridge, a 1800 bend with a radius of around 2 inches occurs in the sample line. Such a severe bend will result in particulate loss by impaction on the wall of the sample line.
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The second potential problem concerns the physical lo-cation of the monitors.
VS-101 is situated approximately 4 feet from the vent stack, VS-107 is about 15 feet below a 4 x 4 foot ventilation duct, and GW 108 is also close to the duct being monitored. While this close proximity l
gives added assurance that the sample in representative, the background radiation resulting from the sources during an accident could have a swamping effect on the monitors leading to false indications. This is an item that the appraisal team was unable to fully evaluate but it deserves licensee consideration and follow-up as appropriate.
4.5 Solid Waste Disposition 4.5.1 Program Implementation Radioactive shipment records were reviewed for three shipments, numbers B 0299 (4/28/80), B 0393 (12/8/80) and B 0410 (3/3/81). These shipments represented a solidified resin shipment, solidified evaporator bottoms and a dewatered shipment, respectively. No significant probelms with the shipping papers were noted.
In addition to the required information a vehicle inspection record, individual surveys of linc s or casks, curie content calculations, a check list for Greater Than Type A Quantities, plus other additional information was included with the shipping papers. The licensee requires the burial site to acknowledge receipt of each shipment.
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-The licensee's procedures for shipping radwaste were generally adequate.
Procedure RP 3.13 provided the check list for greater than
' Type A quantities.
The procedures stated that the Radcon Supervisor, Radcon Foreman or other designated individual was responsible for filling out the check list. At the time of the appraisal the Radcon Supervisor completed this check list and did the final review on all shipping papers.
Due to the Radcon Supervisors knowledge and understanding of the regulations the checklists and forms were properly completed. Additional procedural guidance would be needed for other personnel.
The licensee had a copy of the burial site license and criteria plus certificates of compliance for the casks used.
4.5.2 Quality Assurance Program The auditors reviewed the licensee's shipping program for compliance with 10 CFR 71, Appendix E, " Quality Assurance Criteria for Shipping Packages for Radioactive Material.
Based on interviews with Quality Assurance Department Representatives it was established that the only involvement of this department was in the follow-up audit to IE Bulletin 79-19, " Packaging of Low Level Radioactive Waste for Transport" in 1979 and an audit of the burial site at Barnwell, S.C. in 1980 (Audit Report No. BV-1-80-19). The auditor brought to the attention of licensee represent-atives that the quality assurance activities related to packaging and transportation apply to such areas as, container design, purchasing, fabrication, handling, shipping, storing, cleaning, assembling, inspecting, testing, operating, maintaining, repairing and modifications.
The auditors interviewed operational quality control personnel assigned to the Beaver Valley Station and were informed that quality control personnel are involved in the loading and shipping of greater than Type A quantities of radioactive material. Their involvement includes verification of certain hold points in the loading and closing and securing of the containers. This is documented on established check lists.
l Based on interviews with the Radiation Control Supervisor and review of RADCON procedures the auditors determined that the overall quality assurance being performed was i
done by the Radiological Control Group without any independent verification from outside groups.
The auditors noted that
74 the success of the program so far has'been attributed to the exceptional attention given to the program by the Radiological-Control Group.
- 4.6 Conclusions Based on the above findings, improvements.in the following areas are required to achieve an acceptable program:
1.
Formal, documented job descriptions should be developed for the managerial and oversight responsibilities in the areas of solid, liquid,-and gaseous radwaste system.
2.
A permanent, liquid radwaste processing capability (such as the temporary demineralizer) should be engineered and installed to provide continuously available back-up processing capability to the present liquid radwaste system (evaporator and polishing demineralizer).
The system should be designed taking into consideration the ALARA practices of Regulatory Guide 8.8 and the design guidance of Regul: tory Guide 1.143.
3.
An alarm should be installed in the control room for high level indication in the steam generator drain tanks.
The-following items should be considered for improvement of the radioactive waste management program:
1.
The demineralizer LW-I-1 should be permanently shielded to reduce radiation levels in the PAB and increase effectiveness of the radiation process monitor, RM-RW-101.
2.
The process vent filtration system should be subjected to a routine demonstration of operability and maintenance.
3.
The filter change-out for the process vent should be contained in approved procedures which include independent verification of proper installation.
4.
A formal program should be developed for evaluating radwaste system operation and performance.
5.
RM-LW 104 should be appropriately decontaminated and shielded or moved to a low background area in order to assure the effectiveness of the monitor.
6.
RM-RW-101 shouh e appropriately shielded or the demineralizer, LIW-I-1, be permanently shielded in order to assure the effectiveness of the monitor.
c 75 7.
'The sample flow rates through the charcoal canisters for radiofodine sampling should be reduced to aiound 1-2 cfm:so as to improve sampling efficiency.
8.
The PAB ventilation sample exhaust should be piped back'to the ventilation system or some other suitable receptor.-
.9.
The radioactive effluent and process monitors should be sub-
'jected to a-radiological calibration which includes a radiation source calibration on each range.
- 10. The piping configuration for the accident effluent monitors (VS 101, VS 107, and GS.108) should be re-aligned to eliminate sharp, severe bends.
11.
The Duquesne Light Company Quality Assurance Department should participate more-actively in activities relating to radioactive waste packaging and shipping.
5.0 ALARA j
5.1 Documents Reviewed a.
RADCON Procedure No. 8.1, " Radiological Work Permit," Issue 1 Revision 6.
l b.
RADCON Dose Reduction Check List.
I c.
Form, " Request for ALARA Review".
d.
Form, " Radiation Work Permit Request".
e.
Station Administrative Procedure, Chapter 6, " Radiological Control Group Administration," Revision 2, dated November 4,~1980.
f.
RADCON Manual, Chapter 1, " Standards and Requirements," Issue 3.
g.
RADCON Manual, Chapter, " Radiation Worker Practices," Issue 1, Revision 5.
h.
RADCON Manual, Appendix 10. "RADCON Records and forms," Issue 1, dated February 12, 1976.
5.2 Program Establishment j
The auditors reviewed the licensee's adminstrative policies and implemen-tation of measures for maintaining occupational radiation exposures as low as reasonably achievable (^LARA).
Chapter 1 of the Station RADCON Manual,_" Standards and Requirements," contains the written management commitment / policy to maintain an ALARA program consistant with Regulatory Guide 8.8 and 8.10 and also provides the basis for implementation of the ALARA program.
76 Based on a review of Chapter 1 the auditors noted that the ALARA commitment addressed internal exposure controls as well as external exposure control.
The' procedure includes'the.-following program policies and objectives:
External ~ Radiation Exposure Criteria Internal Radiation Exposure Criteria Emergency Dose Criteria i
Personnel Radiation Exposure Monitoring Dose Control Administrative Exposure Control.
Other Exposure Controls.
Prior Planning and Rehearsal Shielding and Decontamination Special Tools Reduction of Sources by Discharging, Flushing, etc.
Radiation Surveys Work Practices Radiological Training and briefings Investigation of Exposures.
Radiography.
Area Radiation Monitoring.
Contamination limits and controls, decontamination, airborne radioactivity control, and use of temporary hoses / piping are also included in Chapter 1 of the RADCON' Manual.
General rules and requirements for radiation workers to be aware of and adhere to for maintaining exposures ALARA are described in Chapter 2 of RADCON Manual, " Radiation Worker Practices." Chapter 2 was prepared as a guide for radiation workers and provides practices and other pertinent information that must be fol' owed. Specific radiological control practices for radiation workers are detailed to the extent considered necessary in the implementation of the radiological controls program.
C'
6 x
77 Based on interviews, observations, and record review it appears that ALARA practices and concepts are being applied. The licensee has. compiled exposure data for many jobs and has illustrated that a significant man-rem reduction has resulted due to ALARA concepts being implemented. The development of'ALARA~ job studies and shielding placement guidelines has resulted in' reduced exposures to station personnel.
The estimated exposure reduction for jobs where a documented ALARA reviews were maintained was 795 man-rem during 1980.
The auditors noted that improvements could be made in the ongoing review of ALARA recommendations made for high exposure jobs of long duration.
The auditors noted that ALARA reviews which had been performed on certain jobs were not adequately tracked because the records system at the plant was extremely cumbersome, i.e., survey records and cancelled Radiation Work Permits were unavailable to the ALARA' Engineer for determining if ALARA recommendations were effective. The auditors review of this area indicated that the ALARA progran at Beaver Valley appears to be adequately implemented and effective in reducing exposure but lacks sufficient documentation on the results of techniques being employed.
- However, elements of the program such as shielding, decontamination, job specific personnel training, and innovations to reduce direct personnel exposure have resulted in measurable exposure decreases.
The auditor interviewed staff members associated with the corporate element of the radiological controls program, specifically, addressing the ALARA program. _ Based on these interviews, the auditors determined that the corporate element was working towards establishing ALARA baselines and dose tracking programs.
It did not appear that the corporate element was directly involved with the implementation of the ALARA program at the Beaver Valley Station. Closer coordination between the Beaver Valley Station ALARA personnel and the corporate ALARA staff should be encouraged.
The program appears to sufficiently meet the guidance provided in Regulatory Guide 8.8. "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Reasonably Achievable (ALARA)," and Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As low As Reasonably Achievable, "with the exception of better documentation of program effectiveness and formal-ization of the program into implemented procedures.
2 5.3 Conclusions Based on the above findings, this portion of the licensee's prcgram appears to be acceptable, however, the following should be considered for program improvement:
1.
Improve the management of survey records, exposure records and completed Radiation Work Permits so that the effectiveness of ALARA recommendations made for job specific tasks caa be evaluated.
78 2 '.
' Develop administrative procedures'in order to enhance the interaction of the ALARA program at the station and corporate levels.
6.0 Health Physics Facilities and Equipment 6.1 Facilities 6.1.1 Radiation Protection Health Physics Field Office (Access Con _ troy The health physics field office is utilized for RWP issue, portable instrument storage and check out, portable instrument calibration, general work area and as the health physics counting room. The area is undersized to accommodate these activities.
The room was located adjacent to the access corridor for the Primary Auxiliary Building.
The_ shielding for the room was not adequate to prevent significant fluctuation in the laboratory counting instrument backgrounds when radioactive material was transported through the adjacent corridor.
Counting equipment in the field office consisted of a portable single channel analyzer with a NaI well detector, two gas flow proportional counters and three mini-scalers equipped with thin window pancake GM detectors in unshielded sample holders.
Some lead.
bricks had been placed around the GM sample holders for shielding.
The two gas flow proportional counters were inoperable and had a history of failure caused by temperature flucuation and dust in the environment.
Dosimetry Office The equipment for dosimetry issue and evaluation was found, by the auditor, to be acceptable.
The space available for this equipment
.rd the personnel needed to operate it were also found to be acceptable.
However, future needs could not be accomodated within the available space.
In discussions with the Dosimetry Foreman of the RADCON Department (RCD), it was learned that this facility was going to be relocated in a building which is presently under construction.
Portable Radiation Monitoring Instrument Calibration The radioactive source for high range calibration of portable radiation monitoring instruments was located in the field office in a multiple use area. Small hand held sources were used for low range calibration.
These sources were held against the side of the detector because the licensee does not have a facility for calibrating the~ lower ranges on survey instruments. The instrument calibration facility was inadequate.
(Additional deficiencies concerning the instrument calibration program are given in Section 3.0 " Surveillance".) Check sources were stored in a locked fire resistant file cabinet in a
79 room near the field office. One of the drawers contained lead shielding to reduce the external radiation levels in the vicinity.
The extra weight of the lead made it necessary to use a tool to pry the drawer cpen. A more-suitable source storage area is needed.
Whole Body Counter The equipment used for the lung / thyroid counter by the licensee is discussed in the Internal Exposure control Section of this document.
It was found by the Appraiser to be acceptable.
Training Facilities The licensee's training facilities consisted of classrooms, mockup areas, and instructor office space. The space available was acceptable l
and the utilization of the space appeared to be appropriate. The equipment available to the instructors for the various training sessions was judged to be acceptable by the auditors.
Respiratory Protection Facilities The licensee utilized the station laundry room for respirator cleaning, inspection, storage, and issue. A washer and dryer had been installed in the room but were inaccessiiele because of shelving for respirator storage.
Respirators were frisked by a Health Physics Technician using a thin l
window GM detector attached to a count rate meter.
Respiratbrs that were contaminated to levels greater than 100 cpm as measured by the frisker were sent off-site to a commercial laundry facility for decontamination. Uncontaminated respirators were cleaned and disinfected i
by maintenance personnel. The respirator cleaning facility consisted of two deep sinks, one of which was used for rinsing the respirators.
The licensee had modified a steel storage cabinet into a drying unit for the respirators. After being dried the respirators were inspected, bagged and stored on shelves.
l The space available for respirator cleaning, inspection, storage and issue was congested. During periods of accelerated respirator usage two shifts were needed to keep up with respirator cleaning and issue. As the plant gets older and airborne levels increase the cleaning facilities will probably not be adeqaute.
At the time of the appraisal, the Respirator Fit Chamber was in the process of becoming operational after a long shutdown period. The sensitivity and capability of the chamber were found to be adequate.
However, the proper utilization of this facility was inadequate.
This is discussed in detail in the Section 3.3 of this appriasal
(
report.
'O-0-
80 Contaminated Equipment Storage The facilities for the storage of anti-contamination clothing and contaminated equipment are inadequate. The use of any available
.open space for the storage of anti-contamination clothing isuan example of this problem. The PCA machine shop contained about 100-55 gallon drums filled with anti-contamination clothing. An additional 40 drums of clothing and other contaminated and non-contaminated equipment were stored on the PCA mezzanine. About 20 drums of clean anti-contamination clothing were stored in the corridor outside the HP. field office.
The equipment decon room is located within the PCA machine shop.
The condition of this area typified the inadequate storage as well as indicating poor housekeeping practices.
The decon room contained an electropolishing unit that was not in service during the period of the appraisal. An accumulation of non-compactable trash,. hoses, piping, and oil, was outside of the decon room. Also, located within the decon room was a pile of contaminated equipment in an unorganized clutter that included 4 ladders and assorted piping.
The electrical shop which is located within the PCA machine shop, was used as the storage area for some radioactively contaminated equipment; this resulted in this area being controlled by a' locked gate for radiological purposes. Contaminateo equipment located throughout a typically nonradiological uncontrolled area can lead to a spread of contamination or personnel contamination.
Personnel Decontamination A dedicated decontamination room located adjacent to the HP access control point is available for personnel decontamination. The room is kept locked to prevent unauthorized use.
Inlcuded within the room are 3 showers, 2 wash basins, and 2 toilets.
The toilets are not to be used because the effluent is not controlled as potentially contaminated. A modest inventory supply is kept in the room, including anti-contamination clothing, soap, and potassium permanganate. The potassium permanganate is to be used only under the direct supervision of the HP Supervisor.
A stretcher is available for the removal and transport of injured, contaminated individuals out of radiologically controlled areas and if necessary off-site for medical assistance. The plant has agreements with two local medical facilities ( Aliquippa and Beaver County) for the treatment of contaminated, injured individuals.
Change Room Separate men's and women's change rooms were available. The men's i
change room appeared adequate and well maintained and it was equipped with lockers, showers, wash basins, and toilets.
One potential 1
l 4
81 problem is the availability of adequate facilities for contractor employees since they are banned from the use of these permanent facilities. During outages, trailers are supplied for the use of contractors and to facilitate _ radiological control of contractor employees. The wo' men's change' room consisted of a clean side with a sink and shower.and a contaminated side with a. disconnected sink, toilet, and shower. Anti-contamination clothing had to be obtained from the men's facilities. A portal monitor and frisker were provided for radiological contamination control.
6.1.2 Chemistry The Chemistry room lacked. adequate space for storage and processing of samples awaiting analysis. At the time of the appraisal, a several day back log of samples was stored on a counter shelf outside the court room. There was little appearance of organization and inventory control over these samples.
The hot lab fume hoods in the chemistry lab showed obvious signs of dust loading. These hoods and associated ventilation systems are designed to prevent the spread of airborne radioactive contamination.
The hoods are not included in a routine maintenance program and are not checked to assure proper ventilation flows.
Upon checking the hoods, the appraiser measured the air flow velocity across the surface face of the hot lab hood at 50 feet per minute with the door wide open. The air flow across the face of the low level hood was around 75 feet per minute with the door 3/4 closed.
Both of the velocities are below the industry accepted standard of 125 fpm. The Chemistry Count Room was designed to be a vault and provided some atmospheric control. Additional air conditioning capacity has been ordered for this area.
The room appeared to be filled to capacity.
The Chemistry Count Room contained the following equipment: a liquid scintillation counter; computer based gamma spectroscopy system with two shielded sample caves (only one detector was in use); a hard wired multichannel analyzer (not in use); an intrinsic detector (for use with the system not yet installed); two NaI well detectors, each with a single channel analyzer; a counter scaler with an end window GM detector in a shield, and, a gas flow proportional counter with an automatic sample changer. A second intrinsic detector and a 3 x 3 Nal detector were stored elsewhere.
A new computer based gamma spectroscopy system was in the Chemistry Office but had not been placed in service.
If the additional air conditioning capacity is installed the Chemistry Count Room would probably be adequate for the equipment installed during the appraisal. However, it did not appear that the room could accommodate the'new gamma spectroscopy system.
. 1 82 6.2 Protective Equipment 6.2.1-Anti-Contamination Clothing An adequate supply of protective equipment was available for use including anti-contamination clothing and respirators.
6.2.2 Shielding Temporary shielding which including sheet lead and encapsulated lead -
shot blankets was available.
6.2.3 Containment Materials An adequate supply of plastic containments (glove boxes) were available in the warehouse for use. Also'available for the construction of' containment barriers was an ample supply of plastic sheeting and tubing.
6.2.4 Portable Ventilation Systems Three portable air. handlers were.available for cont-olling localized airborn contamination problems.
Each unit included a blower, HEPA and charcoal filter and a flexible duct for directional suction.
These systems are used to control airborne activity and reduc?
worker exposure for jobs where there is a potential for high airborne radioactivity levels.
6.3 Conclusions Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
The health physics counting room requires additional space and shielding.
The chemistry counting room requires added space to facilitate use of existing equipment and for adequate storage and processing of samples.
The calibration facility requires a dedicated area with adequate space and shielding is. required for portable instrument calibration.
The storage of anti-contamination clothing and contaminated equipment
-requires a dedicated area with increased capacity.
Other health physics and chemistry facilities and equipment appear adequate, however, the following areas should be considered for improvement:
The respiratory protection equipment cleaning and storage areas
- should be upgraded to relieve congestion and assure' adequate availability.
of respirators.
i 4
83' The chemistry fume hoods should'be properly maintained to assure adequate hood face. flow to prevent. airborne _ contamination.
7.0 Exit Interview The appraisal team members met with licensee representatives (denoted in Annex A) at.the conclusion of the health physics appraisal on March 6,-
1981, to summarize the scope and major findings of the appraisal.
The findings were-classified into two categories:
a.
Significant appraisal findings are described in Appendix A of the tr nsmittal letter forwarding this report and are summarized at the conclusion of each applicable section of this report. Written-responses to these significant findings.will be required, and corrective actions will be reviewed during subsequent inspections.
b.
-Findings of lesser significance but which are considered important by the appraisal team are summarized at the end of each-report
.. secti o n.
No written response to these findings required, however, it is expected that these finuings will be used by the licensee in formulating a radiation protection plan.
Requirements for the radiation protection plan will be specified by the NRC in the future.
Progress and improvements in these areas will also be reviewed during subsequent inspections.
b e
ANNEX A PERSONS CONTACTED
c-i:
~,.
' Annex A to Report 50-334/81-05 PERSONS CONTACTED DUQUESNE LIGHT COMPANY
- J.A. K0SMAL, RADCON Supervisor
- J.C. Allingham, Health Physicist W.J. Brady, Foreman A.E. Castagnacci, RADCON Foreman A.T. Lonnett, RADCON Foreman E.A. Schnell, RADCON Foreman N..Vasguez,-Exposure Records Clerk
- J.V. Vassello, Training Supervisor D. Arnold, Health Physics Instructor C.R. Haney, Health Physics Instructor B. Grubbs, Training Records Clerk M. Hopple, Training Records Clerk
- R.L. Hansen, Station Maintenance Supervisor
,A.C. Fawcett, Mechanical Maintenance Foreman W.I. Sarvey, Building Maintenance Foreman
- V. Linnenbom, Radiochemist
- J. Wenkhous, Reactor Control Chemist
_A. Matijak, MCR Foreman i
! c.,
,1 R. Clear, Mechanic-0.-Evans, Shift Chemist J. Sieber, Superintendent, Licensing'and Compliance
- J. Werlir.g, Station Superintendent -
- H.-Williams, Chief Engineer.
- J. Carey,: Director of-Nuclear Operations
- G.L._Beatty, QA Engineer
- R.M.;Vento, ALARA Specialist K. Grabs, Operations Department L. Schad, Operations Department H. Jenkins, Operations Department D. Schultz, Operations Department RAD' SERVICES PERSONNEL'(Contractor)
C. Vergari, Project Supervisor J. Orr, Assistant Project Supervisor R. Greenwood, Radcon Engineer R. Beamer, Radcon Technician T.-Mobley, Radcon Tuhnician T. Angelo, Radcon Technician D. Kotarski, Radeon Technician R. Griffith, Radcon Technician S. Burris, Radcon Technician
- s;
?
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- d C..Terwilliger,'Radcon Technician T. Duberville, Radcon Technician
~J. 0 liver, Radcon Technician V.. Taylor,tRadcon Technician
' P. ;Gianutsos, Health Physics Instructor -
- R.' Greenwood, Radeon Engineer ENERGY CONSULTANT PERSONNEL-(Contractor)
D. Blair,'Radcon Engineer I
NRC PERSONNEL AT EXIT INTERVIEW (Other than team members) j O.A.- Beckman, Senior Resident Inspector 1-i
- denotes those present at the preliminary exit interview conducted at the j
Beaver Valley Power Station on March 6, 1981.
i The auditors also held discussions with and interviewed other licensee and contractor employees. They included engineering, operations,' quality.
assurance / control, training, maintenance and radiological controls personnel.
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