ML20040B299
| ML20040B299 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/22/1981 |
| From: | Essig T, Neely D, Galen Smith, Terc N, Wadman W AFFILIATION NOT ASSIGNED, Battelle Memorial Institute, PACIFIC NORTHWEST NATION, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), WADMAN & ASSOCIATES |
| To: | |
| Shared Package | |
| ML20040B296 | List: |
| References | |
| 50-029-81-01, 50-29-81-1, NUDOCS 8201250370 | |
| Download: ML20040B299 (47) | |
Text
,
i U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-29/81-01 Docket No.
50-29 License No.
DPR-3 Priority Category C
Licensee:
Yankee Atomic Electric Company 1671 Worcester Road Framingham,_ Massachusetts 01701 Facility Name: Yankee Nuclear Power Station _ Qankee Rowe)
Appraisal at:
Rowe, Massachusetts Appraisal conducted:
anuary 5 ';,
981
_fa///_ s/
Team Members:
D. R.
jeel inspection Specialist (Team dat6 / signed e der), NRC RI/
I'r/r.'fhl yy w
1.'b N. M.
ferc( Ra'diation pecialist, NRC:RI date' signed L
p..
,5
/ tha/ E)
/m T. HT E/sig, Re's M cI, Scientist, Battelle date signed 1
Pycific North e,st Caborat ries (PNL)
' 3<yc; -l sW*W4
/ 7 f7% $\\
- f. c W.
Tadman,Ya'ian dA ociates date signed
't
/
_/2./
h Approved by:
c gn G.H,-[S th, irector, Division of Emergency dAt signed
, Preparedness and Operational Support l
Region 1 Form 12 l
(Rev. April 77) 1 8201250370 820108 PDR ADOCK 05000029 G
TABLE OF CONTENTS Page Summary...........
V 1.0 Organization, Responsibilities, Staf fing and Management Oversight......
I 1.1 Documents Reviewed......
I 1.2 Organization Description......
2 1.2.1 Yankee Rowe Station Organization...........
2 1.2.2 Yankee Atomic Corporate Organization....
2 1.3 Responsibilities.........
3 1.3.1 Yankee Rowe Station Responsibilities.....
3 1.3.2 Yankee Atomic Corporate Responsibilities..
3 1.4 Staffing.
4 1.4.1 Yankee Rowe Station Staffing.
4 1.4.2 Yankee Atomic Corporate Staffing..
4 1.5 Conclusions.
4 2.0 Personnel Selection, Qualification and Training...
5 2.1 Documents Reviewed.....
5 2.2 Selection Criteria.....
5 2.3 Qualification Criteria.
6 2.4 Training Criteria...
6 2.5 Conclusions.....
7 i
1 Table of Contents Page i
3.0 Exposure Controls....
8 3.1 External Exposure Control............................
8 3.1.1 Documents Reviewed.
8 3.1.c External Dosimetry Program..
9 3.1.3 Exposure Limitation.
10 3.1.4 Quality Assurance Program.........
11 3.1.5 Conclusions...........
11 3.2 Internal Exposure Controls.
11 3.2.1 Documents Reviewed..
11 3.2.2 Internal Desimetry Program...
12 3.2.3 Internal Exposure Review.
16 3.2.4 Internal Exposure Limitations..
17 3.2.4.1 Administrative Controls..
17 3.2.4.2 Respiratory Protection..
19 3.2.5 Quality Assurance.
22 3.2.6 Conclusions.
22 3.3 Surveillance Program...
24 3.3.1 Documents Reviewed.
24 3.3.2 Surveillance Program Implementation.......
26 3.3.3 Instrument Suitability and Use..
30 3.3.4 Conclusions..
34 1
4.0 Facilities and Equipment 35 4.1 Documents Reviewed.
35 11
Table of Contents Page 4.2 Fac111 ties..................................
35 4.3 Protection Equipment...........
37 l
4.4 Conclusions.........................................
37 l
5.0 Exit Interview...........................................
38 Annex A Persons Contacted Annex B Organization Charts iii
l A
SUMMARY
The Special Health Physics Appraisal was conducted during the period January 5-16, 1981, to evaluate the overall adequacy and effectiveness of the Yankee Nuclear Power Station (Yankee Rowe) radiation protection program. At the time of the appraisal, the Yankee Rowe facility was operating at approximately 75%
power level.
The Appraisal Team consisted of two inspectors from the NRC Region I, Office of Inspection and Enforcement and two individuals provided by Battelle Pacific Northwest Laboratories. The appraisal included observations of work practices, review of selected procedures and records, together with interviews with Yankee Atomic Electric Compant (YAEC) personnel.
The scope of the appraisal included:
)
Radiation Protection Organization and Management Personnel Selection, Qualifications and Training Exposure Controls (Internal and External)
?
Facilities and Equipment I
Results of the special health physics appraisal indicated that significant weaknesses existed in the radiation protection and radioactive waste management programs. Weaknesses were identified in the areas of personnel selection, qualifications and training (Section 2.0), internal exposure control (Section 3.2) surveillance program (Section 3.3).
i r
l r
I V
o i
)
l l
1.0 Organization, Responsibilities, Staffing and Management Oversight 1.1 Documents Reviewed a.
Yankee Rowe Technical Specifications 6.2.
b.
American National Standard (ANS) 3.2, " Administrative Controls i
and Quality Assurance for the Operational Phase of Nuclear Power Plants," dated 1976.
c.
American National Standard Institute (ANSI) N18-1-1971, " Selection and Training of Nuclear Power Plant Personnel."
d.
Regulatory Guide 1.8, " Personnel Selection and Training."
l e.
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As-Low-As-Is-Reasonably-Achievable," ALARA.
f.
Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Exposures As-Low-As-Is-Reasonably-Achievable (Nuclear Power Plants)."
g.
Administrative Procedure (AP) No. 0226, " Qualification and Training of Personnel," Revision (Original).
h.
Administrative Procedure No. 2001, " Responsibilities and Authorities of Operations Department Personnel," Revision 10.
i.
Administrative Procedure No. 0228, " Quality Assurance Program,"
l Revision 1.
j.
Administrative Procedure No. 0208, "In-Plant Audits," Revision 6.
k.
Administrative Procedure No. 8001, " Health Physics Department Organization and Training," Revision 1.
Administrative Procedure No. 9000, " Qualifications and Training of Chemistry and Health Physics Personnel," Revision 3.
m.
Yankee Rowe Radiation Protection Manual, dated April 30, 1980.
n.
Yankee Operational Quality Assurance Program, YOQAP-1-A.
o.
Yankee Nuclear Power Station Final Safety Analysis Report.
t Quality Assurance Audit Report No. YR-80-3, dated September 2, p.
1980; Area Audited
" Health Physics."
2 q.
Quality Assurance Audit Report No. YR-80-5, dated September 12, 1980; Area Audited
" Training."
r.
Quality Assurance Audit Report No. YR-80-11, dated May 30, 1980; Area Audited
" Control of Measuring and Test Equipment."
s.
Quality Assurance Audit Report No. YR-80-13, dated March 31, 1980; Area Audited
" Document Control."
t.
Quality Assurance Audit Report No. 79-14, dated December 20, 1979; Area Audited
" Emergency Planning."
u.
Nuclear Safety and Audit Review Committee (NSARC) Meeting Minutes dated November 9, 1979; May 16 and November 14, 1980.
1.2 Organization Description 1.2.1 Yankee Rowe Station Organization The Radiation Protection organization as defined in the three administrative documents, AP 0226, 8001 and 9000, did not clearly describe the organizational responsibilities.
The Health Physics Department (HPD) did not contain a reporting chain with the single exception that all personnel reported directly to the Radiation Protection Manager (RPM).
There was no clear assignment of duties, authorities and responsibilities within the documents specified for the HPD.
It was not possible to ascertain the number and assignment of the staff within the HPD.
The appraiser were told that the lack of clarity was the result of some delicate management-labor negotiations.
The job descriptions for the HPD personnel were relatively vague and did not clearly outline the exact performance requirements expected for the job title.
However, it appeared that when a task was verbally assigned to an individual that the individual understood what their assigned duties were.
1.2.2 Yankee Atomic Corporate Organization The corporate structure was clearly defined through an organization chart, written assignment of duties, authorities and responsibilities.
The job descriptions were adequately defined and were understood by those individuals filling the positions.
The responsibilities of the corporate staff were basically multi-disciplinary in nature.
=.
3 1.3 Responsibilities 1.3.1 Yankee Rowe Station Responsibilities The responsibilities assigned in the areas of personnel monitoring, radiation work permit issuance, counting room, instrument maintenance and calibration, chemistry, radiation 1
surveys, and job coverage were considered adequate by the appraisal team.
Although their job responsibilities were not formally documented, the technicians seemed to have no question concerning their day to day responsibilities in the organiza-1 tion and appeared to carry out their assigned duties effectively.
The responsibilities for the Respiratory Protection Program l
were assigned to a person who did not meet Regulatory l
Guide 8.15 or NUREG 0041 requirements.
The ALARA review and ALARA engineering functions were assigned to an individual who had neither the ANSI N18.1 qualifications nor nuclear power plant experiente which would have prepared him for the duties as an ALARA coordinator or ALARA engineer.
.)
Although the responsibility for the HPD training was assigned to a person with an adequate academic and technical background, the scope of responsibilities for his position was not documented which caused the program to appear fragmented.
The HPD program management responsibility was assigned to the RPM.
There appeared to be no formal structure beneath him.
The technical expertise was evident; however, the lack of freedon to assign intermediate levels of responsibility and supervisory responsibility prevented effective management of the program.
1.3.2 Yankee Atomic Corporate Responsibilities At the corporate level, the following areas were observed:
personnel monitoring, counting room operations at the Environmental Lab, job coverage, ALARA review, training and program management. Of the areas reviewed, it appeared that the ALARA review process could be made more effective by closer coordination and interaction between the plant personnel and corporate staff.
No formal training program was established for corporate professional personnel.
It was recommended that a corporate professional staff training program be established.
l i
o 4
1.4 Staffing 1.4.1 Yankee Rowe Station Staffing No backup to the Radiation Protection Manager (RPM) had been designated.
It appeared that none of the subordinate staff were RPM qualified.
The backup for the RPM needed a formal designation.
Further, a line of responsibility might be appropriate so that personnel onsite and from outside agences would know whom to contact.
The facility appeared to have adequate numbers of technicians, and adequate technical support for the program.
The clerical support to the Health Physics Department appeared competent and efficient.
Because of their diverse duties, it would appear that a reassignment of work to other personnel within the department might be appropriate at times to provide timely handling and transferring of data.
Both would be particularly important during outages.
p Supervisory staff was non-existent.
This was seen as a particularly difficult position to be tolerated within a department where responsibilities were diverse and tasks could be complex.
Close supervision by a single individual was impossible.
Because of the unusual structure and lack of supervisory assgnments, the staff was considered not properly managed.
Further considerations for the modification of the departmental structure was recommended by this appraiser.
1.4.2 Yankee Atomic Corporate Staffing It appeared that one person within the corporate Radiation Protection Organization was qualified to serve as the RPM at the site in an emergency.
The technical support from the corporate organization to the site appeared to be at a high technical level and was adequate.
The number of supervisory personnel appeared to be adequate and they appeared to have smooth running programs.
1.5 Conclusions Based upon the above findings, improvements in the following areas are required to achieve an acceptable program:
l l
l
5 Establishment of a clearly defined station radiation protection organization which includes each major position / function in the Radiation Protection Department.
Establishment of clear assignment of duties, authorities and responsibilities and specific functional position descriptions.
The scope of responsibilities and the division of duties within the ALARA, respiratory protection, and health physics technical training programs would benefit from a thorough review and formalization of assignments.
Other areas of the organizational and management aspects of the radiation protection program appear to be acceptable, however, the following item should be considered for improvement:
Development and implementation of a corporate professional staff training program (NUREG 0731).
1 Consideration should also be given to providing RPM backup capability, additional ANSI N18-1 qualified supervisory staff r
and additional clerical support during outages.
2.0 Personnel Selection, Qualification and Training l
2.1 Documents Reviewed a.
Administrative Procedure No. 9000, " Qualifications and Training of Chemistry and Health Physics Personnel," Revision 3.
b.
Administrative Procedure No. 0226, " Qualification and Training i
of Personnel," Revision (Original).
c.
Administrative Procedure No. 2003, " Initial and Review Qualifica-tion of Auxiliary Operators," Revision 6.
d.
Administrative Procedure No. 8001, " Health Physics Department Organization and Training," Revision e.
Administrative Procdure No. 0501, " General Plant Training Program," Revision 7.
L 2.2 Selection Criteria The Yankee Rowe Atomic Electric Company's selection criteria was reviewed to determine the adequacy and effectiveness of the program.
Regulatory Guide 1.8 and ANSI N18.1 were used in this review.
It was determined that there was no documentation for positions such as managers, supervisors, health physics technicians, contractor health physicists, contractor health physics technicians, instructors, Rad Waste operators, or specialists.
In a review of the organization in
6 documents AP 9000, AP 8001 and AP 0226, the appraiser found ambigious definitions as well as definitions which could not be identified from document to document as being the same selection criteria.
For those positions with documented selection criteria, the job descrip-tions tended to be indicative of the qualities that would be used in a selection.
For those positions with selection criteria defined, the requirements of formal education and/or training and the minimum required experience were usually indicated.
The criteria, however, were not used during the hiring of the Health Physics assistants or engineering assistants.
This lack ;f properly defined selection criteria has produced a staff that does not meet the ANSI N18.1 i
requirements for supervisory personnel in all cases.
2.3 Qualification Criteria The qualification criteria for the Radiation Protection Organization were reviewed against Regulatory Guide 1.8 and ANSI N18.1 as they pertained to the positions listed in AP 8001.
It was determined that the documentation of the qualification criteria was not clear.
However, where qualifications were specified, they frequently were of a general nature, which allowed flexibility in judging qualifica-tions.
The qualifications, when stated, were found to contain the criteria specified in Regulatory Guide 1.8 and ANSI N18.1, including the experience requirements.
However, the criteria did not seem to be judiciously used during the hiring process.
2.4 Training The Health Physics technical training was performed within the department. The documentation of the training program was not complete.
It rarely listed the frequency that initial training or qualification training should be given; the scope or content of the training; the objectives of the training; performance objectives and scheduled, formalized lesson plans.
Further, the documentation on retraining was not complete because it lacked:
the elements of the initial training qualifications; the verification of a student demonstration of attainment of the standards; and the completions of the performance objectives of the retraining.
Modifications to the existing training program were in progress to upgrade the scope of training and the level of thoroughness of the documentation.
i Because the Health Physics Organization's technical training was under revision, the plant and contract Health Physics technicians appeared to be receiving the majority of the training that was being conducted. The general employee training, basic respiratory protection training, plant orientation and emergency evacuation training appeared l
to be adequate.
The Rad Waste operators and auxiliary operators were given advanced Health Physics training by the Health Physics Organization; the program was well documented.
There appeared to be no training program on advanced and current health physics topics for supervisory, managerial and professional health physics personnel.
7 It appeared that the tra:ning program of the Health Physics Organization should be reorganized and should specify the personnel to be trained and the level of training necessary.
The training program of the Health Physics Department personnel was reviewed for content and subject matter.
The training material for the technicians and auxiliary operators was job specific and stressed proper job performance. General duties were convered but the exact responsibilities were vague.
The training did not define departmental authority or reporting chains.
The training was primarily a lecture with visual aids.
" Hands on" training was not included in the classroom lectures.
It is recommended that consideration be given to including both " hands on" and supervised on-the-job training.
The lecture series given to technicians was found to be too technical and theoretical.
The classroom instructor stated that many modifications to that particular lecture series were needed to make material more pertinent.
2.5 Conclusions Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Selection criteria should be documented for all positions within the organization.
Selection criteria should reflect job descriptions and should be used in the hiring of station as well as contractor personnel.
To the extent possible, selection criteria should be applied to the promotion process.
Qualification criteria should be documented for all positions.
Qualification criteria should be considered in the hiring process to acquire the highest level of trained personnel.
In the cases where the personnel hired may not meet the qualification criteria, a training and upgrading program should be instituted to ensure that the person is fully qualified within a specified period of time.
Documents AP 9000, AP 8001, and AP 0226 should be reviewed for consistency of definitions of both pay title levels and functional levels within the organization.
The training program should be reviewed, revised as necessary, and formalized to conform to the requirements of Regulatory Guide 1.8 and ANSI N18.1-1971.
The program should include the frequency, scope, content, objectives, performance objectives, schedules and lesson plans, and demonstrations by the students.
Retraining should be scheduled for all technical level personnel.
8 3.0 Exposure Controls 3.1 External Exposure Control 3.1.1 Documents Reviewed a.
Administrative Procedure No. 8001, " Health Physics Department Organization and Training," Revision b.
Administrative Procedure No. 8100, " Establishing and Posting Controlled Areas," Revision 5.
c.
Operating Procedure No. 8403, " Personnel, Monitoring,"
Revision 3.
d.
Yankee Rowe Radiation Protection Manual, dated April 30, 1980.
e.
Administrative Procedure No. 8004, " Manual Self-Peading Dosimeter Records," Revision 3, dated March 1980.
f.
Administrative Procedure No. 8010, "High Radiation Area Control," Revision 3.
g.
Department Procedure No. 8407, " Dosimeter Rezero Slips," Revision 3.
h.
Department Procedure No. 8408, " Dosimeter Off Scale Reports," Revision 4.
l i.
Department Procedure No. 8550, " Leak Test and Calibration Check of Pocket Dosimeter," Revision 4.
j.
Operating Procedure No. 2475, " Vapor Container Access,"
Revision 6.
k.
Operating Procedure No. $107, " Neutron Surveys Using the PNR + Rem Counter," Revision 2.
1.
Operating Procedure No. 8302, " Health Physics Release of Equipment and Material," Revision 3.
m.
Department Procedure No. 8404, "Dositetry Service Quality Control Program," Revision 4.
n.
Operating Procedure No. 8415, " Radiation Work Permits,"
Revision 7.
?
9 o.
Department Procedure No. 8416, " Radiation Exposures By Duty Function," Revision 3.
p.
Department Procedure No. 8418, " Calculation of Dose Due to Noble Gases, Neutrons, and Beta Radiation,"
Revision 3.
q.
Operating Procedure No. 8409, " Lost or Damaged TLD,"
Revision 2.
3.1.2 External Dosimetry Program The routine dosimetry program at the site consists of self reading pocket dosimeters and Thermoluminescent Dosimeters.
The Self Reading Dosimeter (SRD) was appropriate for the measurement of medium to high energy gamma radiation.
It was used as a daily indicator of integrated radiation exposure and met the criteria of Regulatory Guide 8.4.
l The thermoluminescent dosimeters (TLD) were used to measure the integrated exposure to ionizing radiation.
TLDs were processed offsite at the Yankee Atomic Electric Company, i
Environmental Laboratory (EL).
The assessment of the EL dosimetry program was documented in the Vermont Yankee Health Physics Appraisal: Report No. 50-271/80-14.
The dosimeters were routinely read quarterly or whenever the cumulative total reading of the SRD reached 500 mR.
Although the TLDs were not used as beta dosimeters, the personnel processing the TLDs indicated that beta and neutron exposure information could be obtained from the existing dosimetry system.
Non-routine and special exposure measurements were performed at the site. A review of extremity exposure dosimetry indicated several aspects which were questionable.
A licensee representative indicated that in some instances, an SRD had been attached to the backs of hands or wrists to evaluate extremity dose. On Dccasion, a TLD may have been utilized in the same position.
However, no calculations were made to correct for the difference in dose from the wrist to the fingertips, nor were beta exposures evaluated in the cases where the hands may have been extended inside s
of primary system containment structures, such as valve i
bodies or pipes.
Extremity dosimetry procedures were not written to cover these areas.
The EL indicated that skin exposures could be calculated from the current TLDs, but that the station has not requested beta exposure information from them.
10 Neutron exposures were calculated using rem-meter instrument readings and stay-time calculations.
No problems were observed in this area.
The TLD calibration program was reviewed. No problems were noted.
Dosimetry exposure records were provided by the EL and maintained onsite in the Health Physics Office.
The dosimetry section of the EL kept the original copy of the exposure records.
The appropriate dosimetry information was well documented and audit records verifying any changes of the information contained in the documents were available through the EL. Current personnel exposure history was provided to each department for use in job assignments.
Exposure records appeared to contain the information outlined in Regulatory Guide 8.2 and 8.8.
The Health Physics Office clerical staff maintained up to date records and dosimetry information to be used for planning work assignments and HP job coverage.
Records of accumulated exposure based on SRD data plus the latest TLD exposures were maintained.
The dissemination of information appeared to be adequate.
However, the clerical staff indicated that under outage conditions, they had difficulty maintaining a timely dissemination of information because of the workload.
3.1.3 Exposure Lititations Exposure 1:mitations were administered through the implemen-tation of proceiures and posting of radiation areas.
Procedures AP 8001, " Health Physics Department Organization and Training," AP 8100, " Establishing and Posting Controlled Areas," and OP 8403, " Personnel Monitoring," described the radiation exposure limits and appeared to be adequate.
The radiation area posting requirements met the regulatory standards contained in 10 CFR 20.
The posting of radiation areas appeared to be adequate with only minor discrepancies of posting observed.
No radiation doses were noted to be in excess of the limits contained in 10 CFR 20.
Radiation exposures were reduced and maintained through the use of shielding, access control and special tools.
Access control and use of special tools for remote handling appeared to be adequate.
No problem was found in the manner in which shielding was employed and it appeared to be utilized in several areas around the plant.
It was recommended that criteria for the use of shielding be developed.
]
11 3.1.4 Quality Assurance Program The quality assurance activities supporting the EL dosimetry program were reported in Vermont Yankee Health Physics Appraisal; Report No. 50-271/80-14.
The corporate quality assurance program included procedural audits of the external exposure controls at Yankee Rowe.
In addition, the Health Physics Department conducted periodic reviews of various aspects of its program.
The corporate level quality assurance group had the technical capability to perfore an in-depth audit of health physics.
It is recommended that technical audits be made in addition to the present proced-ural audits.
3.1.5 Conclusions Based upon the above findings, this portion of the licensee's program appears to be acceptable.
3.2 Internal Exposure Control 3.2.1 Documents Reviewed a.
" Yankee Rowe Radiation Protection Manual," April 30, 1980.
b.
Procedure No. DP-8007, " Calculation of Internal Dose for a Single Uptake of Solube Radionuclides," Revision 2, April 1979.
c.
Procedure No. DP-8008, " Dose Estimate to GI Track and/or Lungs for a Single Uptake of Insolube Radio-nuclides by Comparison with MPC's," Revision 2, April 1979.
d.
Procedure No. AP-8015, "MPC-br Accountability,"
Revision 3, July 1980.
e.
Procedure No. DP-8400, "Use of Protective Clothing,"
Revision 4, November 1979.
f.
Procedure No. OP-8401, " Respiratory Selection and Use," Revision 3, October 1978.
i
12 1
g.
Procedure No. OP-8405, " Bioassay Program," Revision 4, September 1980.
h.
Procedure No. DP-8563, " Calibration of the Invivo Bioassay System," Revision 1, Februar, 1979.
i.
Selected whole-body counting results for the period of November-December 1978, September-November 1979 and January 1980-January 1981.
j.
Selected Urinalysis data for the period from January 1974 through February 1975.
k.
Procedure No. OP-2603, " Operation of the Breathing Air Compressors," Revision 2, dated February 2,1981.
1.
Procedure No. OP-8419, " Cleaning, Disinfection, Decontamination and Storage of Respirators," Revision 3.
m.
Procedure No. OP-8421, " Respiratory Protection Equipment Inspection and Maintenance," Revision 2.
l n.
Procedure No. AP-8422, " Respirator Fitting," Revision 1, dated March 1981.
3.2.2 Internal Dosimetry Program The only bicassay program used by the licensee was whole-body counting. According to a licensee representative, other bioassay techniques, e.g., excreta analysis, have not been performed since 1975 on the basis that whole-body counting was more reliable than excreta analysis for gamma-emitting radionuclides.
For those nuclides not detectable by whole-body counting, e.g., H-3, Sr-90, the licensee represen-tative stated that airborne monitoring for these radionuclides had shown them not to be a problem.
The licensee had not documented the basis for the lack of a routine urine and/or fecal analysis program, however, and the appraiser recommended that such documentation be accomplished.
The whole body counter (WBC) consisted of a chair, a detector and an analyzer.
The WBC was located inplant in the Health Physics Supervisor's office.
The WBC, which had been in use since 1975, used a 3" x 3" Nal crystal for counting the trunk region and a 1-1/4" x 1-1/4" Nal crystal for counting the thyroid.
The detectors were connected to a 1024 channel analyzer.
The WBC power supply was not i
connected to a source of regulated voltage.
Although this point was discovered after completion of the onsite phase
13 of the appraisal, it was briefly discussed with a licensee representative via telephone. A regulated voltage supply should be considered as a long term need for the WBC.
Output data available to the operator directly from the analyzer consisted of a CRT display of the gamma spectrum and a printout of countrate data by channel number. A computer program (GAMANL-II) was readily available via telephone line to the licensee's corporate office to process gamma spectra and compute organ burdens.
(
l The licensee's bioassay program, which was essentially limited to whole-body counting, was described in Procedure OP-8405. This procedure was limited to statements of frequencies for routine whole-body counting and of non routine exposure situations that warranted whole-body counting.
Procedure DP-8563 was essentially limited to the step-by-step requirements for the performance of an annual primary calibration of the WBC. After reviewing the collective activities addressed by these two procedures, it appears that the following items have been partially or incompletely addressed:
The specific sources to be used for the daily energy and efficiency calibration check and the annual calibration were not sufficiently identified.
No mention was made of room temperature impacts on equipment operation.
(Mention is made of establishing a comfortable room temperature {72o F}, but this appears to be required for the operator only).
Whole-body counts should be triggered by an exposure in excess of 40 MPC-br as specified in 10 CFR 20.103.
With respect to termination whole-body counts, Procedure OP-8405 noted that, "If an individual refuses to be counted, the refusal will be noted on his record."
The appraiser questioned whether such a statement was suf ficient to ensure that terminating employees comply with the procedural requirement to obtain a whole-body count.
Procedure OP-8405 did not require the issuance of termination exposure reports (10 CFR 19.13); however, such reports were routinely issued.
14 Procedure OP-8405 also did not provide for contingency program for urine / fecal analyses including sample handling and shipping to be implemented as an alterna-tive to WBC and/or as additional followup capability when elevated bady burdens are detected by the WBC.
Procedure OP-8405 required whole-body counts annually for plant personnel whose duties do not require entry into the plant controlled area, semi-annually for plant personnel whose duties require frequent entry into the controlled area, entrance / exit counts for non plant personnel, and termination counts for plant personnel. Additional whole-body counting was performed if protection factors for respiratory protection devices were used and at the discre-tion of a health physics supervisor.
The appraiser performed a selective review of whole-body counts performed during the periods of November-December 1978, September-November 1979, and January 1980-January 1981.
Of the approximately 600 counts examined by the appraiser, none was in excess of the minimum detectable activity (MDA) of 50 nCi for Co-60 (the principal radionuclide encountered).
The MDA correspond to 4% of the Maximum Permissible Organ Burden (MP0B) with the lung as the organ of reference.
The MDA of 50 nCi for Co-60 was based on a 1000 second count. This sensitivity, when reviewed in terms of %
MP08, was judged by the licensee to be adequate.
- However, MPOBs are equilibrium burdens, and most exposure situations encountered were transient in nature.
Therefore, the burden corresponding to the 40 MPC-hr control measure in 10 CFR 20.103 should be considered and included in WBC operator training.
This point is further illustrated as follows:
Exposure Situation Co-60 Lung Burden, nCi Short term exposure to 40 MPC-hr 54 Short term exposure to 520 MPC-hr 650 Long term exposure at MOC (equilibrium) 1200 Minimum detectable activity with licensee's WBC 50
~
15 The chair counting arrangement marginally enabled the licensee to detect an organ burden corresponding to a 40 MPC-br exposure.
The MDA for the WBC was discussed in some detail with licensee representatives.
It was agreed that the Co-60 background in the building was the cause of the high MDA.
Because the licensee's ability to detect Co-60 organ burdens to a 40 MPC-br exposure was rather marginal, the appraiser stated that the Co-60 background would need to be reduced so that the whole-body counting data could be properly correlated with MPC-hr exposure data determined by other means (e.g., air sample results).
It was noted that this background reduction would either require a relocation of the WBC or additional shielding of the chair or a combination of both.
Operation of the Whole-Body Counter The WBC was operated by one of the Health Physics Department's clerical personnel.
The Health Physics Department Supervisor stated that the clerk was being utilized on a trial basis as a WBC operator and that the individual was being used primarily to perform a mechanical function and not to interpret data.
Three professional staff members from the HP Department maintained cognizance over WBC activities, performing interpretations of the data and the annual primary calibration.
The appraiser noted no apparent problems with this system of data generation and review.
Routine operation of the WBC included the following opera-tional and quality control checks:
A daily 1000 second background count (on days during which counts are scheduled).
This count was processed through the GAMANL-II computer program for subsequent use in processing of individual spectra.
A daily 100 second count of a CS-137 button source.
The total counts under the photo peak for this count were entered on a control chart. Acceptance criterion was + 3I of the expected value.
A daily 1000 second count of the same sources used for the annual primary calibr ation.
This count was also processed through the GAMANL-II computer program.
An annual calibration using the following sources in lucite chest and neck plantoms:
Cs-137, 370 nCi; Co-60, 66 nCi; and Ba-133, 320 nCi (all as of 12/31/80).
The appraiser noted that a letter from the vendor (dated August 18, 1975) stating the activity of the sources was on file; however, documentation of the
1 16 l
l l
NBS traceability of these sources was not available.
l In general, no problems were noted with the primary calibration; however, the appraiser noted that it was not in conformance with that recommended by ANSI N343, " Internal Dosimetry for Mixed Fission Products."
Specifically, the licensee was calibrating the WBC with a single activity level for a given nuclide, rather than over a range of activity from 60 - 20,000 nCi as recommended by the standard.
i, The library, contained in the GAMANL-II program, included the prominent gamma rays from eighteen radionuclides.
While this library generally included those radionuclides considered important by ANSI N343 in power reactor dosimetry programs, a few of the important nuclides were not included.
Those were:
Ru-Rh-106, Ba-La-140 ar.d Ce-Pr-144.
3.2.3 Internal Expo:ure Review Management review of the bioassay program (whole-bouy counting) data was virtually a continuous process, with either an Engineering Assistant (Health Physics) or the Assistant Planc Health Physicist reviewing each whole-body count performed.
Procedure OP-8405 required the plant health physicist to evaluate, on a case-by-case basis, any measured body burdens in excess of 10% MPOB.
Procedures j
AP-8007 and DP-8008 described the dosimetric models to be i
used in evaluating uptakes of soluble and insoluble radio-I nuclides, respectively; however, cross-referencing between OP-8405 and the two dose calculation procedures appeared to be nonexistent.
l l
The performance of organ dose calculations vs. estimation l
of MPC-hr exposures was discussed with licensee radiation protection management.
The appraiser pointed out that although organ dose calculations are consistent with ICRP and NCRP practices, the performance of MPC-hr exposure estimates is necessary to be responsive to 10 CFR 20.103 requirements. Whole-body counter generated MPC-hr data can also be used to judge the effectiveness of respiratory protection and air monitoring programs. MPC-hr data were generated by the licensee from air sample results pursuant to Procedure AP-8015; however, because whole-body counting data were not evaluated in terms of MPC-br exposures, a comparison between the two data bases could not be made.
Investigations of personnel exposures to high levels of airborne redicactivity or contact with high levels of surface contamination were triggered by high air sample
17 results, positive nasal swabs, or skin contamination monitoring results.
Licensee action fellowing these events appeared to be timely and complete, including several followup whole-body counts and, when appropriate, urine and fecal analyses.
Documentation of these events appeared adequate.
3.2.4 Internal Exposure Limitations 3.2.4.1 Administrative Controls The licensee's method for limiting internal exposure consisted of a combination of procedural controls and physical controls, such as protective clothing, respiratory protection, and engineering controls.
The Yankee Rowe Radiation Protection Manual contained guidelines for the control of surface and equipment contamination levels, as well as the use of protective clothing and respiratory protective eqs1pment.
The Manual provided quantitiative definitions of the various types of exposure control areas used by the licensee, vis., radiation area, high radiation area, high radiation exclusion area, airborne radioactivity area, radioactive materials areas, clean area, contaminated area, and controlled area. The Manual, together with Procedures DP-8400 and OP-8401, provided instructions relative to the use of protective clothing and respiratory protective equipment; situations which warranted more or less clothing than the standard coveralls, shoe covers, gloves and head cover were considered on a case-by-case basis by health physics personnel.
The appraiser noted the use of job-specific procedural controls relative to the use of prctective clothing and respiratory protective equipment in place thoroughout the plant in the form of Radiation Work Permits (RWPs).
The protecitve clothing and respiratory protective equipment specified in the RWPs appeared to be appropriate for various jobs observed by the appraiser during tours of the facility. With respect to airborne exposure controls, however, RWPs generally appeared deficient in the following areas:
(a) the type of respiratory protection required was frequently not specified on the RWP; and (b) no space was provided to record any MPC-hr limitations for particular individuals or specific tasks.
18 Procedure AP-; J15, which defines the MPC-hr accounting techniques used by the licensee, failed to address the 40 MPC-hr control measure contained in 10 CFR 20.103. Although the procedure called for MPC-br accounting for an individual when exposures of 2 MPC-br/ day or 10 MPC-hr/7 days occurred (more restrictive than the 40 MPC-br/7 days contained in 10 CFR 20), no mention was made of corrective actions to be taken when 40 MPC-br was exceeded.
The types of protective clothing in use by the licensee appeared appropriate to cover a reasonably broad spectrum of work activities and surface / air-borne contamination levels.
Procedures for donning of such clothing appeared adequate.
Posting of radiation and contamination areas was also observed during tours of the facility. No problems were noted with posting as required by 10 CFR 20.
Based on discussions with licensee representatives, l
the limitation of exposures to airborne radioactive materials through the use of engineering controls (e.g., auxiliary ventilation systems) appeared to be understood by the licensee and such systems used when practicable.
For example, a 1000 cfm HEPA/ charcoal filter train had been used to exhaust steam generators during tubing plugging operations; high airborne radioactivity loads in l
the Vapor Container (reactor containment) which normally followed such work were virtually eliminated.
Reporting to terminating employees of exposures to internal emitters was performed routinely.
Such reports, which were required by 10 CFR 19.13, reported "no significant gammas in the spectrum" for organ burdens less than the MDA.
l An improvement in the minimum detectable activity l
for the whole-body counter (such as that mentioned earlier) would enable the licensee to report information more meaningful to the exposed individual (such as the number of MPC-hr corres-ponding to the measured burden and a comparison with the 520 MPC-hr quarterly limit).
The current method of reporting did not appear to be consistent with the intent of 10 CFR 19 and 10 j
CFR 20.
19 3.2.4.2 Respiratory Protection Program Establishment The station had committed to a Respiratory Protection Program as indicated in the Technical Administrative Guides. A policy statement for the Respiratory Protection Program was included.
The RPM was assigned the responsibility for the Respiratory Protection Program.
The RPM did not appear to have the training and qualifications to qualify as a direct line supervisor for the Respiratory Protection Program.
The person assigned the functional responsibility for Respiratory Protection did not appear to have the training qualifications, or experience for that responsibility.
The Respiratory Protection Program included an extensive procedural system which closely paralleled the guidance given in NUREG 0041. However, the Respiratory Protection Manual was outdated and needed to be reviewed and revised as necessary to comply with Reg. Guides 8.15 and NUREG 0041 requirements.
Formal evaluations of the Respiratory Protection Program effectiveness had not been conducted.
The site did not have listings of internal depositions with which to perform trend analyses or comparisons of air sample results and whole-body-count data.
The facility had committed to the selection and use of approved or accepted equipment for the Respiratory Protection Program.
However, one piece of unapproved equipment was found in the storage area where Respiratory Protection equipment could be obtained by the workers (it was removed from use during the course of the appraisal).
The Health Physics Department could not document where unapproved equipment had been used.
Consequently, an assessment of potential internal exposure from the use of unapproved equipment could not be made.
l l
i W
i 20 4
i Hazard Evaluation The Health Physics Organization had the capability to classify hazards as they pertained to particulate airborne radioactivity and to deficiencies in oxygen content.
However, the air sampling program was not adequate to determine iodine concentrations in air.
The Respiratory Protection Program did not provide for evaluation of personnel exposure to radioiodine.
This was considered a deficiency.
Engineering Controls Health Physics Procedure No. DR-8200 illustrated i
the various containments which could be used to i
localize airborne contamination.
The document did not indicate where these containments were located.
It would be appropriate if the various procedures indicated where personnel could obtain containments and instructions for their use.
1 Ventilation systems for removing and filtering contaminated air were available.
None were in use at the time of the appraisal.
The facility had two Continuous Air Monitors t
(CAM).
It appeared that additional CAMS would be appropriate for use as trend monitors in J
j areas such as the spent fuel pit.
Training and_ Qualifications The qualifications of personnel providing the Respiratory Protection Training appeared to be deficient.
Direct training by factory personnel in the use of specific equipment could not be documented with the exception of one technician i
who had been partially trained in the use of the j
respirator fitting booth.
Training of respirator users appeared to be minimal.
e The contents of the training program needed to be expanded to include the requirements of NUREG
}.
0041.
In addition, because the Respiratory Protection Manual was out of date, references to it in the Respiratory Protection training and
)
j uther procedures should be deleted until the manual is brought up-to-date.
1 i
i 1
21 The respiratory equipment fit program was deficient.
Personnel conducting the fit tests were inadequately qualified.
Individuals operating the fit test a
equipment were not required to demonstrate their knowledge of its use or proficiency in its i
operation.
t i
The requirements for authorization to wear respiratory protective equipment appeared to be i
adequate.
A random check of respirator users j
was conducted to verify that qualifications were met.
No discrepancies were noted.
The medical requirements as outlined in NUREG 0041 appeared to be satisfied.
j It appeared that no emergency SCBA training was given except to the fire brigade and emergency J
response teams.
J Maintenance Program Inspection, testing and repair of the respiratory protective equipment was deemed to be unacceptable.
4 Af ter major repairs of the respiratory protection masks, inspection for leakage was not performed.
Equipment to test for leakage after repais was I
not available onsite.
The SCBA and supplied air respirators were only given negative pressure tests in the field.
In addition, no formal training program was in place for personnel performing respiratory equipment repair.
4 j
The storage, inventory, control, issuance, j
contamination surveys and cleaning processes i
appeared to be adequate.
4 The maintenance of breathing air supplies was inadequate. Although the Hansen fittings were q
unique to the supplied air system, the air j
compressor's outputs were not tested as required to assure meeting the specifications of Grade "D" breathing air.
The compressors did not have l
a method for purification of intake air and would be unusable in the event that airborr.e radioactivity was released into the compressor intake area. Breathing air inside reactor containment was supplied from semi portable banks of compressed air cylinders.
1 22 l
3.2.5 Quality Assurance The appraiser reviewed the QA activities conducted in support of the internal exposure control program and noted l
that such activities were conducted both by the plant HP Department staff and from the corporate office. No inconsis-tencies were noted relative to the program recommended by ANSI N343.
It appeared that the respiratory protection program had no quality assurance audits.
3.2.6 Conclusions Based on the above findings, improvements in the following areas are required to achiese an acceptable program:
The annual primary calibration methodology used for the whole-body counter needs to be expanded to include a range of activities for each nuclide as recommended l
by ANSI N343.
The lack of a formal internal dosimetry program for non gamma emitting nuclides, e.g.,
H-3, Sr-90, and alpha emitters, should be justified.
Procedure AP-8015 should reference the 40 MPC-hr control measure contained in 10 CFR 20.103(b)(2) as a point at which certain evaluations and corrective actions are required.
The individual assigned responsibility for the respira-tory protection program should have the qualifications outlined in Regulatory Guide 8.15 and NUREG 0041.
Alarm systems for the 1 jication of increasing airborne radioactivity should be ?mployed in areas where the potential for significant variation in the airborne radioactivity levels exist.
l The training and qualifications of respiratory equipment l
training personnel should be upgraded to comply with i
Regulatory Guide 8.15 and NUREG 0041.
l Respiratory protective equipment fitting should be performed by a qualified person.
l Emergency use training for respiratory protective equipment should be included in the overall training program.
23 The maintenance program, including the inspection, testing and repair of the respiratory protective equipment, should be reviewed and revised as needed to comply with Regulatory Guide 8.15.
Tests for contamination of breathing air should be conducted to assure that it meets the requirements of American National Standards ANSI Z 86.1-1973, " Commodity Specification for Air."
Other areas of the internal exposure control program appear to be acceptable, however, the following items should be considered for improvement:
Gamma-ray spectra for Ru-Rh-106, Ba-La-140, and Ce-Pr-144, nuclides considered significant by ANSI N343, should be added to the GAMANL-II library.
A procedure for a contingency program for excreta analysis should be developed for use when needed (e.g., if the whole-body counter fails to operate or if additional followup is indicated because of a high whole-body count).
f The RWP form needs to be improved to permit specifica-tion of the type of respiratory protection to be-used. Also, it is recommended that space be made available on the form to list any MPC-hr limitations which may be necessary.
Termination exposure reports issued pursuant to 10 CFR 19.13 should be more definitive than "no significant gammas in the spectrum" (i.e., a correlation with MPC-hrs of exposure should be included).
The background Co-60 radiation in the vicinity of the whole-body counter needs to be reduced so that inhala-tion exposures well below 40 MPC-br can be assessed.
Only MSGA/NIOSH approved respiratory protective equipment should be selected and used.
Procedures for engineering controls should include adequate description of available containments and their appropriate usage.
The extent of respirator training for users should be expanded to include all aspects of the regulatory requirements.
24 A quality assurance program designed to determine the overall adequacy of the Respiratory Protection Program should be developed and implemented.
3.3 Surveillance Program 3.3.1 Documents Reviewed a.
" Yankee Rowe Radiation Protection Manual," April 30, 1980.
b.
Procedure No. AP-8001, " Health Physics Department Organization and Training," Revision 0, December 1980.
c.
Procedure No. AP-8015, "MPC Hour Accountability,"
Revision 3, July 1980.
d.
Procedure No. OP-8100, " Establishing and Posting Controlled Areas," Revision 5, April 1980.
e.
Procedure No. OP-8101, " Plant Radiological Surveys,"
Revision 5, August 1979.
f.
Procedure No. OP-8105, " Breathing Zone Air Samples,"
Revision 4, September 1980.
g.
Procedure No. OP-8107, " Neutron Surveys Using the PNR-4 Rem-Counter," Revision 2, April 1980.
h.
Procedure No. DP-8200, " Contamination Containment Areas," Revision 2, April 1979.
i.
Procedure No. OP-8302, " Health Physics Release of Equipment and Material," Revision 3, June 1979.
j.
Procedure No. OP-8415, " Radiation Work Permits,"
Revision 7, March 1979.
L.
Procedure No. DP-8502, " Operation of Eberline Models E-500B, E-520," Revision 4, October 1980.
1.
Procedure No. DP-8506, " Operation of the NMC Automatic Counting System," Revision 2, April 1980.
Procedure No. DP-8508, " Operation of the Nuclear-Chicago m.
2650 Portable Radiation Survey Instrument," Revision 3, October 1980.
n.
Procedure No. OP-8509, " Operation of the Victoreen 470A Panoramic Survey Meter," Revision 1, April 1979.
,e,
l 25 o.
Procedure No. DP-8520, " Operation of the Victoreen Radector III Portable Radiation Survey Instrument,"
Revision 3, October 1980.
p.
Procedure No. DP-8551, " Calibration of the Jordan Radgun," Revision 4, July 1980.
s q.
Procedure No. DP-8552, " Calibration of the Eberline E-500B or E-520," Revision 3, November 1978.
r.
Procedure No. DP-8553, " Air Sample Pump Calibration,"
Revision 1, April 1979.
s.
Procedure No. DP-8554, " Calibration of the Radector II and III," Revision 2, April 1980.
t.
Procedure No. DP-8555, " Calibration of the Eberline PIC-6A," Revision 2, April 1980.
u.
Procedure No. DP-8556, " Calibration Check of the Eberline RM-16," Revision 2, April 1980.
v.
Procedure No. DP-8557, " Calibration of the Eberline PNR-4 Rem Counter," Revision 1, April 1980.
w.
Procedure No. DP-8558, " Operation and Sources Check of the Eberline Rm-14 Equipped with a HP-210 Probe,"
Revision 2, October 1980.
x.
Procedure No. DP-8559, " Calibration and Source Check of Gas Flow Proportional Counters," Revision 2, November 1980.
y.
Procedure No. DP-8560, " Calibration of the Nuclear-Chicago 2650 Portable Radiation Survey Instrument," Revision 1, October 1980.
z.
Procedure No. DP-8561, " Calibration and Source Check of a Geiger-Mueller Detector and Scaler Output System,"
Revision 1, November 1978.
aa.
Procedure No. DP-8564, " Operation and Functional Check of the Eberline Pm-2A Portal Monitor," Revision 1, November 1978.
j bb.
Procedure No. DP-8567, " Calibration of the Victoreen 470A Panoramic Survey Meter," Revision 1, April 1979.
26 1
cc.
Procedure No. OP-8568, " Calibration of the Nuclear Associated Mammonitor II," Revision 1, November 1979.
dd. Procedure No. DP-8569, " Calibration of the Auto Digimaster," Revision 0, April 1980.
ee.
Procedure No. DP-8570, " Calibration of the Xetex 302A High Level Probe," Revision 0, June 1980.
ff.
Procedure No. DP-8572, " Calibration of the Telector Model 6112," Revision 0, October 1980.
gg.
" Surface Contamination and Radiation Survey Sheets,"
July 1980 - January 1981.
hh.
" Air Sample Log," March - April and September 1979; July 1980 - January 1981.
11.
"RWP Log," October 1980 - January 1981.
jj. Calibration Records for Digimaster (S/N 355, 459, 460); E-520 (S/N 209, 835, 842, 844, 1704, 1891);
PIC-6A (S/N 909, 910, 911, 912,1378,1767,1885);
RM-14 (S/N 499, 855, 856, 857, 886, 975, 980, 982, 984, 1429, 1673, 1624, 1626, 1627, 2656, 2659, 2690, 2691, 2706); R0-2 (S/N 4473, 4474, 4475, 4476, 4477);
and R0-2A (S/N 4467, 4468, 4469, 4470, 4471) for January 1980 - January 1981.
l 3.3.2 Surveillance Program Implementation
)
The routine radiation surveillance program was documented l
primarily in Procedure OP-8101.
This procedure addressed i
routine surveys for 17 or more locations during normal plant operation and for 30 or more locations during periods of extended plant shutdown.
Based on a review of CY-1980 survey records, it became apparent to the appraiser that 85-90% of the licensee's surveillance efforts appeared to be devoted to routine surveys. The remaining 10-15% was devoted to special surveys and to those performed in support of RWP issuance. Although on many occasions routine survey information could be used in support of RWP issuance, RWP-specific surveys did not appear to be performed on a sufficiently frequent basis.
Discussions with licensee representatives indicated a general feeling of complacency in this area; many job-specific surveys were judged unnecessary because of extreme familiarity with the radiation protection aspects of the work (i.e., because of the age of the facility, many maintenance tasks had been performed a large number of times). The approach taken by the licensee
27 1
l with respect to job-specific surveys resulted in a certain lack of specificity with regard to radiation protection requirements on RWPs.
For example, RWP No. 2563 (dated 12/31/80) was issued for rebuilding and welding of drive shafts and dash pots, the latter having a radiation level up to 10 R/hr at contact.
The RWP did not specify contamina-tion levels or require extremity dosimetry. Although this task only resulted in external exposures of from 40 and 90 i
mR and an inhalation exposure of 0.066 MPC-hr, it appeared i
based on the nature of the task and the radiation level at contact with the dash pots (10 R/hr) that the extremity i
f exposures could have been significantly greater.
Extremity exposures were not very well defined because of the lack j
of surveys and dosimetry.
I A second example of non-specificity with regard to radiation conditions on RWPs involved RWP No. 0029, issued January 14, 1981, for repacking the No. 1 Charging Pump.
The radiation conditions listed for this job were based on a survey performed one month earlier, according to the individual signing the RWP for the Health Physics Department.
This task, which involved opening of components that had been exposed to primary coolant, was observed in part by the appraiser.
The RWP did not require Health Physics coverage during opening of the components; however, approxi-mately one hour after the job began, an HP technician checked on the progress of the job.
He took a smear survey and collected an air sample (in addition to the lapel sampler,<orn by two of the individuals performing the work) at that stage of the work.
One smear indicated a significant contamination level (200K dpm/100 cm ); the 2
air sample result was 2 x 10 ' pCi/cc (gross beta).
Although this task did not result in a significant exposure to the individuals performing the task, it would have been prudent, in the appraiser's judgment, for the licensee to have provided health physics coverage during the opening of the pump.
i Responsibilities for various facets of the surveillance program were defined, primarily in general terms, in Procedure AP-8001 (Personnel assignments and responsibilities are discussed in more detail in Section 1.3 of this report).
Surveillance activities were performed by nine Yankee Rowe technicians (2 Technicians and 7 Testers) and four contract technicians.
The Testers (Junior Technicians) performed most of the routine surveillance tasks.
The two Technicians reviewed RWPs prior to issuance and signed them for the HP Department, as well as performed more complex surveillance sasks, and assisted with other surveillance activities.
28 Technical procedural guidance for the performance of surveys (as opposed to guidance relative to operating an instrument) appeared to be generally lacking.
Although the licensee had written several procedures related to the operation of portable radiation survey instruments and air samplers, instructions neither indicated any limitations on the use of the particular instrument nor how to use it to perform a survey.
Records of surveys appeared, in general, to be adequate, although certain improvements in documentation of survey results in support of RWP issuance (noted earlier) could be made.
The appraiser noted that the Survey Log maintained at the HP control point consisted primarily of only the most recent surveys for a given area, copies of which were posted on a status board. A survey package was assembled on a daily basis by the HP technicians and forwarded to the HP Department management staff for review. Although such review is encouraged, it should not be done in a manner which tends to deprive the HP technicians of histor-ical surveillance data for trend analysis purposes.
Surveys should also, in the judgment of the appraiser, be numbered for future reference and filed chronologically by building location, the latter encouraging trend analysis.
Types of_ Surveys The types of surveys performed by the licensee for both routine and non-routine situations included direct radiation, airborne radioactive materials, and surface contamination measurements.
Ai1 surveys were performed either by licensee personnel or by contractor HP technicians.
According to a licensee representative, alpha measurements were made of selected smear surveys and air samples.
The bulk of these measurements appeared to the appraiser to be i
assoc'ated with the receipt and handling of new fuel.
Based on the appraiser's review of the surveillance data, it appeared that additional alpha measurements (air samples and/or smears) should be made, particularly in the radwaste handling / area, e.g.,
in the evaporator cubicle and other areas having potential for accumulation of alpha-emitting radionuclides.
Direct beta radiation surveys were performed using source l
correction factors which were based on a calibration of the instrument against a uranium slab source.
The only apparent major drawback with the licensee's program in this area was that beta surveys were not always performed, or at least recorded, when warranted, i.e., instances involving work on components having a high level of internal contamination.
It appears that increased attention is neeued in this area.
29 Gamma radiation surveys were made with the same ion chambers that were used for beta radiation measurements. No signifi-cant problems were noted in this area.
Neutron surveys were performed with a commercially available rem-meter. A deficiency in the licensee's program in this area was that neutron surveys were not clways performed when warranted, e.g., containment entries at power.
Because the survey meter also functioned as the primary l
dosimeter, such measurements take on additional importance.
l The appraiser noted that the licensee only had one rem-meter; l
backup capability consisted of borrowing a similar instrument i
from the Vermont Yankee station.
The appraiser recommended i
that the licensee purchase an additional instrument to l
improve this situation. Another problem noted in the neutron surveillance area was the licensee's calibration source and associated crocedure.
During a review of the most recent calibration of this instrument, the appraiser 2
l noted that the maximum neutron fluence, 815 n/cm -sec at 15 cm was insufficient to effectively calibrate the instru-ment; a maximum dose rate of only 4 mrem /hr was available at contact with the source.
The relevant procedure (DP-8557) l merely instructs the individual performing the calibration to " expose the instrument to a known field of neutrons" after having the I&C Department perform a linearity check.
The procedure did not reflect the recommendations of ANSI N323.
The appraiser concluded that a larger neutron source was needed in addition to improving Procedure DP-8557.
Airborne radioactive materials were collected both from an individual's breathing zone as well as from a few general locations around the facility. Only airborne particulate sampling was included in the breathing zone sampling program, i.e., radiciodine sampling was not included.
Low flow rate (1 cfm) samplers were occasionally used to determine ambient airborne radiciodine levels.
The appraiser discussed this lack of airborne iodine monitoring with licensee representatives who indicated that the fuel cladding integrity observed during the past two years had been good, hence, airborne radiciodine levels have been quite low. While surveillance data reviewed by the appraiser appeared to support this conclusion, it was emphasized to the licensee that a sound radiation protection program must include the ability to measure airborne radiciodine levels. Additional air sampling capability was available in the form af continuous air monitors (CAMS), which monitored airborne particulate radioactivity only. This l
program is further discussed in Section 3.3.3.
l l
i 1
l>
30 Surface contamination measurements (smear surveys) were performed with a two-inch diameter, commercially-available cloth medium having an adhesive backing.
Smears were counted on a thin window proportional counter which was typically operated in the automatic sample change mode.
Although smear surveys observed by the appraiser appeared to be performed in a satisfactory manner, a bias toward a routine program and away from RWP-issuance was apparent.
The appraiser also noted that alpha counting appeared to seldom, if ever, occur.
3 3.3 Instrument Suitability and Use Portable Radiation Monitoring Instruments Direct Radiation The licensee appeared to' have a sufficient number and appropriate types of instruments available for performing measurements of beta and gamma radiation levels during maintenance / refueling operations. One model of portable GM counter and one model of ion chamber were used for most of the measurements made as part of the routine program.
Other models of GM counters and ion chambers were held in reserve - either ccmmitted to emergency kits or to a storage locker to serve as backup to routinely used instru-ments. High range (up to 1000 R/hr) instruments having a telescoping probe were also in the licensee's inventory.
The licensee's procedure for tagging inoperative instruments and initiating a work request appeared satisfactory.
Calibrations of the above instruments were performed quarterly with a commercially available calibrator containing a 50 C1 Cs-137 source and several smaller sources.
The appraiser tested the licensee's ability to properly use the instrument calibrator containing the 50 Ci source by requesting the licensee to expose the appraiser's instrument (an ion chamber which had previously been calibrated with an NBS-traceable source) to several specific exposure rates.
For calculated exposure rates of 200 and 3400 mR/hr, the appraiser's instrument read 200 and 3200 mR/hr, respectively.
The appraiser noted that the calibration method used for low exposure rates consisted of positioning 1
one of the above-mentioned smaller sources on a laboratory bench having a slate top, with the bench being adjacent to a concrete wall.
This calibration setup was discussed with a licensee representative, who agreed that the potential for photon scattering could be significant and that an alternative arrangement would be examined.
l 31 An operational check source for gamma survey instruments was located at the HP control point, however, its strength (8 pC1) only resulted in an exposure rate of a few mR/hr at best.
Such a small scale deflection was not, in the appraiser's judgment, a sufficient operational check.
Alpha monitoring discussed earlier from the aspect of air sample smear counting, should be supplemented by a direct measuring alpha survey meter.
The licensee currently does not own such an instrument.
The Appraisal Team recommended that consideration be given to purchasing such an instrument.
With respect to area monitoring instrumentation, the appraiser noted that the licensee employed both a fixed system (original equipment having si.x monitoring points and an upper limit of 1000 R/hr) and several semi-fixed monitors.
The licensee's original fixed system was in the process of being upgraded both in range and number of detectors in order to be responsive to the recommendations of NUREG-0578 (TMI Lessons Learned) and to ANSI N320-1979,
" Performance Specifications for Reactor Emergency Radiological Monitoring Instrumentation." The upgraded system is to have 23 monitoring points with a maximum range of 10' R/hr.
It is recommended that this area be re-examined during a future inspection.
The licensee had three semi-fixed monitors, however, none was in use as a portable area radiation monitor. Although two of the three instruments were committed to other uses, the third instrument could, in the appraiser's judgment, have been used as a valuable supplement to the licensee's surveillance program.
Airborne Radioactivity _
Ambient airborne radioactivity levels were determined with the use of continuous air monitors (CAMS) and low flow rate (1 cfm) air samplers.
The CAMS intended for surveil-lance during normal operation were the two units which sampled the Vapor Container (VC), one of which was located inside and the other located outside (but sampling inside) the VC.
Both CAMS had beta scintillator detectors with the discriminator adjusted such t'nat primarily only high energy beta radiation, e.g., Rb-88, was monitored, permitting the CAMS to serve as primary coolant leak detectors.
During outages, the discriminator on these CAMS was readjusted to permit a wider range of beta energies to be detected, thus allowing them to be used as personnel monitors.
Based on a review of facility layout and operations having
32 a likelihood for generating airborne radioactivity, the Appraisal Team concluded that a CAM (including iodine sampling capability) should be located in the Primary Auxiliary Building as a personnel monitor for the operator stationed there.
Low flow rate (1 cfm) air samplers, represented the licensee's sole capability for radiciodine sampling. At tFa time of the appraisal, only three of the 5-6 units on hand were in use, with the remainder being on standby. Additional attention by the licensee appeared warranted in this area.
Breathing zone air samples were collected through the use of lapel-mounted units (flow rate of 0.07 cfm) and high flow rate units (20 cfm).
The lapel air samplers appeared to be the mainstay of the licensee's air sampling program.
The high flow -ate units served as a supplement to the program.
Neither type sampler, however, had the capability for sampling radiciodine--a point which was judged by the Appraisal Team to represent a significant deficiency in the licensee's surveillance program.
Because of the paucity of airborne radioiodine data which has been generated by the licensee's routine program (low flow rate air samplers), the potential for generation of radiciodine concentrations, and ALARA considerations, the licensee should consider the addition of airborne radioiodine sampling capability to the existing lapel sampling program and to other programs, as appropriate.
The program for monitoring airborne particulate radioactivity was generally of high quality for beta gamma emitting radionuclides.
Sample analyses included a beta gamma count, with an occasional alpha count and GeLi analyses when the gross beta gamma concentration exceeded 3 x 10 '
pCi/cc.
Two areas of this program, however, appear to warrant further attention by the licensee.
First, the type of filter paper (glass fiber) used by the licensee was conducive to the tunneling o' particulate materials into the filter mat via impaction - a condition which had a high potential for significant self-absorption of alpha activity.
Because self-absorption could mask the small quantity of aloha activity expected to be present on a filter, a better sampling medium (e.g., a millipore-type filter) should be examined by the licensee.
The second area which should be examined by the licensee is related to the operation of lapel samplers while a particular type of respiratory protection (air hoods) are worn.
The licensee's practice was to collect the air sample under the hood. While this practice provides a
33 1
direct measure of the radionuclide concentrations inhaled by an individual, it does not provide a measurement of the airborne concentration that the individual is working in as required by 10 CFR 20.103.
Licensee representatives indicated that they would review this area with the intent I
of either using a flow splitting arrangement (i.e., collec-ting samples simultaneously inside and outside the hood) or simply relocating the sampler to a position outside the hood. No other problems were identified in the licensees air monitoring program.
Contamination l
The licensee's program for personnel contamination monitoring was dependent on friskers.
Whole-body frisking can require a relatively long time to perform, and unless required and enforced by a health physics organization, is seldom properly performed.
In the absence of a required whole-body frisking program, a personnel contamination monitoring program should employ a combination of the usual monitoring devices (i.e. friskers, hand and shoe counters, and portal monitors).
The licensee did not have any hand and shoe counters and the portal monitor, although operating, was not very sensitive.
Specifically, during a calibration of this monitor performed on January 14, 1981, the appraiser noted that a 288,000 dpm source was required to produce an alarm in the monitor.
The source produced a response of 400-600 cpm (approximately 10 times background) on each of the seven body detectors compared to the alarm set point of 400 cpm. The four foot detectors requested a response of 400 cpm to the same source as compared to an alarm setpoint of 600 cpm.
The alarm for the foot detectors apparently could not be adjusted, i.e., the set screw mechanism had worn because of its age.
The above problems with the portal monitor, the lack of hand and shoe counting capability, and the lack of whole-body frisking were discussed with the licensee and the need for improvements in this area emphasized.
Licensee representa-tives indicated that improvements in portal monitoring capability were being investigated.
In the area of contamination monitoring, the Yankee Rowe Radiation Protection Manual discusses reuse of protective l
clothing if the contamination level is less than 2000 cpm I
at 1/2 inch (levels in excess of this require laundering I
or disposal).
The appraisers did not observe protective l
clothing being surveyed prior to storage in an individuals locker for reuse.
Increased attention by licensee management appears warranted in this area.
l
\\
,.m
34 3.3.4 Conclusions Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
The air sampling program should be upgraded to include radioiodine.
l l
The frequency of surveys for alpha, beta, and neutron radiation should be increased.
Other areas of the surveillance program appear to be acceptable, however, the following items should be considered for improvement:
Radiation surveys performed in support of RWP issuance need to be more comprehensive and better documented.
Survey records need to be better organized so as to be more amenable to trend analysis / review at the HP control point (the area where RWPs aru issued).
Portable alpha survey meters and an additional neutron rem-meter need to be added to the licensee's inventory.
Existing semi-fixed area monitoring capability should be utilized for routine monitoring situations.
An additional continuous air monitor with radioiodine sampling capability is needed in the Primary Auxiliary Building.
The filter medium (glass fiber) used for the routine air sampling program needs to be evaluated to determine whether it is adequate for alpha counting.
The procedure for survey and reuse of protective clothing should be examind to determine whether it is adequate.
The location of lapel samplerr inside of air hoods needs to be re-examined.
I l
j 1
35 4.0 Facilities and Equipment i
4.1 Documents Reviewed 1
a.
Procedure No. AP-8006, " Control of Health Physics Masuring and Testing Equipment," Revision 2, January 1979.
b.
Procedure No. DP-8559, " Calibration and Source Check of Gas Flow Proportional Counters," Revision 2, November 1980.
l c.
Procedure No. AP-8005, " Dose Rate Calculations for Calibration i
Sources," Revision 4, September 1980.
d.
Procedure No. DP-8200, " Contamination Containment Areas,"
Revision 2, April 1979.
4.2 Facilities 2
The licensee performed general sample counting in two areas - the hct chemistry laboratory (HCL) and the HP control point.
The counting room of the HCL contained a GeLi detector and a 3" x 3" NaI crystal, both of which were coupled to a multichannel analyzer.
These counting facilities were used primarily for analysis of samples associated with the chemistry program, however, selected samples, charcoal i
cartridges, vapor container air samplers, other air samples having j
concentrations > 3 x 10 ' pCi/cc, were counted on either the GeLi or the NaI system.
i The auditor reviewed the calibration of the chemistry laboratory counting equipment and noted that except for three Co-60 sources, NBS-traceability could be demonstrated for each counting standard.
A licensee representative stated that the three Co-60 sources would not be used for future calibrations.
Calibrations existed for seven counting geometries on the GeLi detector and for five geometries on the Nal detector; however, each appeared to be for only one source-to-detector distance.
Calibration at several distances (particularly large distances) is advisable, in the appraiser's judgement, for those high level samples which cannot readily be dilted or an aliquot
- taken, e.g., post accident charcoal cartridges.
The survey instrument calibration facility was located in one section of the Cold Chemistry Laboratory. As noted earlier in Section 3.3.3, the low level calibration sources were operated in an environ-ment having high potential to produce photon scattering.
This facility does not appear to meet the recommendations of ANSI N323-1978,
" Radiation Protection Instrumentation Test and Calibration."
Facilities for decontamination for small and large equipment were located in the North and South Decontamination Rooms.
These facilities appeared to be adequate.
i 4
36 Personnel decontamination facilities consisted primarily of a shower located adjacent to the HP control point. A sink located at the HP control point, although primarily earmarked for respiratory equipment decontamination, could probably be used for occasional minor personnel j
decontamination tasks.
The respiratory protective equipment decontamination sink mentioned above could impact on other uses of the room in which it was located.
Other uses of the room included air sample counting, smear counting and survey instrument storage.
The Appraisal Team concluded that such routine decontamination activities should be conducted in an area where background-dependent activities, such as sample counting, were not being conducted.
Respiratory protective equipment fitting and testing was performed in a vendor-supplied test booth which employed Nacl as the test atmosphere.
Although no major prob!cns were noted with the booth itself, the lack of an adequate ser.tilation system to reduce ambient concentrations of NaC1, resulting wten an individual exits the booth, was judged unsatisfactory.
Such ambient levels could impact on the baseline for the next individual's fitting.
Change room areas appeared adequate both in terms of size and location.
i Clean and potentially contaminated change areas were located in proximity to both the HP control point and the decontamination shower. One area requiring attention was the apparent lack of surveys of protective clothing prior to reuse. The Appraisal Team did not observe such surveys being performed during walk throughs of the change room area.
The HP Control point, located between the clean and potentially contaminated change rooms, appeared adequate both in terms of size i
and location.
The only problem noted with this area was that respira-tory equipment was decontaminated in the sample counting room portion of the HP Control Point area.
Survey instruments used for the routine surveillance program were stored at this location. Additional storage space for survey instruments was in the " goodie locker," a storage closet adjacent to the change room.
Office space for the HP Department Staff was marginally adequate.
The HP Department Supervisor's accomodations appeared to warrant improvement - both in terms of size and location.
Specifically, the Supervisor's accom.odations were limited to a single desk in a large room which was shared with two clerical personnel, a whole-body counter, with associated data processing equipment, and a computer terminal.
The Supervisor's desk was adjacent to the traffic flow into a subordinate's office, the respiratory protective equipment fitting booth and a records storage area.
The Appraisal Team concluded that better accomodations were needed for this individual both from the standpoint of activities / noise reduced and the need for an area private where private discussions could be held with subordinates.
37 In addition to the chemistry counting room mentioned earlier in this section, the appraiser also toured sampling areas for primary coolant, containment, and airborne effluents.
The sample sink from which primary coolant samples were obtained was located in a hood in a room in the Upper Primary Auxiliary Building.
The air velocity into the hood was adequate (measured by the appraiser to be 150 ft/ min with the door half open); however, the sample lines leading to the hood appeared to be those originally installed with the facility, i.e.,
they were unshielded.
Because of this lack of shielding, this system may not meet short-term recommendation 2.1.6 in NUREG-0578.
Containment sampling capability also appeared to have been in place for a number of years and appeared to warrant upgrading in terms of consideration of post accident radiation levels and in terms of iodine sampling capability (the latter was not provided for).
No other problems were noted with sampling areas.
4.3 Protection Equipment The appraiser reviewed the licensee's stock of protective clothing, temporary shielding, containment materials, and portable ventilation systems, with particular emphasis placed on whether adequate supplies were available for major outages. No problems were noted with any of this equipment.
With respect to portable ventilation equipment, the licensee had a verdor-supplied, 1000 cfm HEPA-filtered exhaust system.
This system was used successfully to contain airborne activity levels which normally would have been present in the Vapor Container during steam generatcr tube plugging operations.
Additional small, 100 cfm, HEPA-filtered units have also been used as engineering controls pursuant to 10 CFR 20.103, according to a licensee representative.
Containment materials were discussed extensively in procedure DP-8200.
This procedure described numerous methods for constructing enclosures around valves, pipes, and other components.
These enclosures were quite elaborate, having glove ports, HEPA filters, drain valve arrangements, etc., and would appear rather effective in containing contamination. According to HP Department management, however, these devices had not been used in at least five years simply because most situations did not warrant them.
The appraiser did not note any major problems ct% ed by discontinued use of these devices.
4.4 Conclusions Based on the above findings, this portion of the licensee's program appears acceptable, but the following matters should be considered for improvement of the program:
38 Consider an alternate location (to the HP Control Point) for mask decontamination.
Consider an alternate location (preferably one with a low l
photon-scattering potential) for small calibration source operation.
l Consider additional ventilation exhaust for the area around the l
respiratory protection equipment fitting booth.
Upgrade the primary coolant and containment sampling capability to be consistent with current recommendations / requirements.
In addition to the above recommendations, the Appraisal Team noted that because of the age of the facility (20 yr.) that, in general, facility and equipment design features did not consider ALARA. All future facility modifications should address this point.
5.0 Exit Interview The appraisal team members met with licensee representatives (denoted in Annex A) at the conclusion of the health physics appraisal on January 16, 1981 to summarize the scope and major findings of the appraisal.
The findings were classified as follows:
Significant appraisal findings are described in Appendix A of the transmittal letter forwarding this report and are summarized at the conclusion of each applicable section of this report.
The licensee is required to submit written responses to these significant findings.
Actions taken on these findings will be reviewed during subsequent inspections.
Findings of lesser significance but which are considered important by the appraisal team are also summarized at the end of each report section.
No written response to these findings will be required, however, it is expected that these findings will be used by the licensee to formulate a radiation protection plan.
Progress and improvements in these areas will also be reviewed in subsequent inspections.
-1 Am--L
+-L gm.,
a.-m-m..-,A m..m A4s.
s a
_A._._%
- 4
___6_m...,
E
--4a a-~.
4
_----..~
4 m
.-4 J
f 1
3 1
I k
i k
I I.
I 4
!I l
ANNEX A Persons Contacted l
i 1
4 i
.I e
j i
i i
)
1 i
i
)
I 4
i f
l 1
...-.r.--
-r, n,,
Annex A to Report 50-29/61-01 h
Persons Contacted I
- D. Moody, Manager Operations, YAEC
- H. Autio, Plant Superintendent
- N. St. Laurent, Assistant Plant Superintendent
- J. Staub, Technical Assistant to Plant Superintendent
- F. Hicks, Training Supervisor
- F. McVilliams, Health Physics Engineering Assistant
- D. Pike, Manager, 00AD, Yankee Nuclear Services Division (YNSD) - Framingham Office
~
- N. Panzarino, Radiation Protection Group - YNSD
- J. Trejo, Health Physics Supervisor
- M. Vandale, Health Physics Engineering Assistant
- L. Reed, Quality Assurance Coordinator - YNSD D. O'Donnell, Assistant Plant Health Physicist M. Thissell, Technical Assistant (Chemistry)
NRC Personnel at Exit Interview (Other Than Appraisal Team Members)
T. Foley, NRC Region I Resident Inspector W. Raymond, NRC Region I Senior Resident Inspecto-
- denotes those present at the exit interview on January 16, 1981.
The auditors also held discussions with and interviewed other licensee and contractor employees.
They included members of the operations, health physics, chemistry, quality assurance and emergency planning groups.
e I
l e
I L
4
)
I i
i i
ANNEX B Organization Charts I
i s
t t
?
i l
~ _ _ _ _ _,
__..__. _ m _ _. _
I I
l l
l l
g r
l l
i t
4 Plant
,S_upe r. lat e.n.d e. n.t
~ Assist'nt~
QCA a
Plant Cui
- perintenJent Su_-y-
_ _ a 1
I I
_.. F i
i 1
Adataletrative
% 8 a t enanc e Operatisca N.=ctor Instrument &
e Tethancel Chestetty &
Supervisor supurvisor Su S*6a't l*** f l
..J h~pervisor Controle Aselegant to the llealth rhyelse Lee i -
ri-* s r'....
t 5. - i s-I Anstatant Operettone j
L%o l
5mpervisor 7Jetatstrative rtatatenance
( Shift Reactor Instrumentatten technetal Plant lOrganlaattan Organisation l$=cerviser Engtavering
& Controle Asetetant 46e a l th l.5,Rp,,]
L.....l_Phyaletet Assistante Organtration L-_
...J
(
I......
....Cheeletry & g Control Soom TAPS operatere Organisesson Health Plvn&ge, C*3 Uf $*.".!'?l8.d.'S Analliary Opusators
- flRE PRO 1ICT!0N PROGPM RE5P045tBILITY r
Figure 1 A FACILITY ORGANIZATION
~
__n