ML20054A590

Health Physics Appraisal Program

ML20054A590
Person / Time
Issue date:	03/31/1982
From:	Liza Cunningham, Flack E, Wigginton J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
References
NUREG-0855, NUREG-855, NUDOCS 8204150578
Download: ML20054A590 (108)

Text

NUREG-0855 lealth Physics Appraisal Program l.S. Nuclear Regulatory

ommission ffice of Inspection and Enforcement J. Cunningham, J. E. Wigginton, E. D. Flack p e "cauq,

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NOTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:

1, The NRC Public Document Room,1717 H Street, N.W.

Washington, DC 20555

2. The NRC/GPO Sales Program, U.S. Nuclear Regulatory Commission, Washington, DC 20555

3. The National Technical Information Service, Springfield, VA 22161 Although the listing that follows represents the majority of document 5 cited in NRC publications, it is not intended to be exhaustive.

Referenced documents available for inspection and copying for a fee from the NRC Public Docu-ment Room include NRC correspondence and internal NRC memoranda; NRC Office of Inspection and Enforcement bulletins, circulars, information notices, inspection and investigation notices; Licensee Event Reports; vendor reports and correspondence; Commission papers; and applicant and licensee documents and correspondence.

The following documents in the NUREG series are available for purchase from the NRC/GPO Sales Program: formal NRC staff and contractor reports, NRC-sponsored conference proceedings, and NRC booktets and brochures. Also available are Regulatory Guides, NRC regulations in the Code of Federal Regulations, and Nuclear Regulatory Commission issuances.

Documents avai able from the National Technical Information Service include NUREG series reports and technical reports prepared by other federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.

Documents available from public and special technical libraries include all open literature items, such as books, journal and periodical articles, and transactions. Federal Register notices, federa, and,

state legislation, and congressional reports can usually be obtamed from these libraries.

Documents such as theses, dissertations, foreign reports and translations,and non-NRC conference proceedings are available for purchase from the organization sponsoring the publication cited.

Single copies of NRC draft reports are availabic free upon written request to the Division of Tech-nical Information and Document Control, U.S. Nuclear Regulatory Commission, Washington, DC' 20555.

Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland, and are available

there for reference use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, from the American National Standards institute,1430 Broadway, New York, NY 10018.

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L GPO Printed (.opy price:

$5.50

NUREG-0855 lealth Physics Appraisal Program inuscript Completed: December 1981 to Pi'blished: March 1982 J. Cunningham, J. E. Wigginton, E. D. Flack ffico of Inspection and Enforcement S. Nuclsar Regulatory Commission Ishington, D.C. 20555 9

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ABSTP/CT The accident at Three Mile Island in fiarch 1979 and subseouent investicetions identified, among other items, serious concerns involving several aspects of the radiation protection program.

Significantly, sone concerns involved areas not addressed by regulations or facility technical specifications.

This in turn led to initiation of a major effort to evaluate the adequacy and effective-ness of radiation protection programs at all currently operating nuclear power facilities during calendar year 1980 by the Office of Inspection and Enforcenent (IE), t'uclear Regulatory Commission.

This inspection effort was termed an appreisal since it was structured to facilitate an integrated look at the total radiation protection program, delve into matters for which explicit regulatory requirements did not exist, and emphasized evaluation of capability and per-formance rather than compliance with regulations. This report discusses the results of the 48 appraisals and the anticipated regulatory actions that may be taken to further address the concerns.

iii

C0flTEf4TS Page Abstract............................................................

iii i ' Preface.............................................................

vii l~

-Abbreviations.......................................................

ix Introduction........................................................

1 Program Purpose.....................................................

1 Program t1ethodology.................................................

2 P rog ra n I mpl eme n ta t i o n..............................................

3 Program Findings....................................................

4 Radiation Protection Organization and Management...............

5 Personnel Selection, Qualification, and Training...............

7 External Exposure Control......................................

10 Internal Exposure Contro1......................................

12 Surveillance...................................................

15 Radioactive-Vaste Management...................................

17 AL A R A P ro g ra m..................................................

18 Facilities and Equipment.......................................

21 Conclusions.........................................................

22 Suggested Actions for Improving a Health Physics Program............

24 Benefi ts and future Di rection of Regulatory Programs................

25

' References..........................................................

27 Appendix A: Heal th Physics Appraisal Program.......................

A-1 Appendix B:

Health Physics Appraisal Reports.......................

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l' PREFACE NUREG-0855 documents the results of the power reactor Health Physics Appraisal Program (HPAP) initiated by the NRC's Office of Inspection and Enforcement during 1980. The HPAP findings, both generic weaknesses and selected examples of above-standard performances, are presented. These findings reflect conditions that existed at the time of the appraisals.

Current conditions are likely improved since most licensees initiated immediate corrective actions for weak-nesses easily corrected and committed to positive actions for the correction of weaknesses requiring longer-term actions. Although it was not possible to cite each and every instance, the above-standard plant performers noted in the various health physics (HP) programmatic areas appraised should provide a useful source of information for other facilities interested in improving their HP programs.

Generally, NRC HPA personnel noted a cooperative licensee spirit and a positive attitude during the onsite appraisals and subseouent licensee followup actions taken to improve and upgrade HP programs.

Such cooperative response from the licensees is and continues to be encouraging.

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ABBREVIATIONS ALARA as low as reasonably achievable ANSI American National Standards Institute anti-c anticontamination (clothing)

BWR boiling-water reactor CCTV closed-circuit television 00T Department of Transportation ECCS emergency core cooling system ECS Emergency Control Station FSAR final Safety Analysis Report HEPA high efficiency particulate air HP health physics HPAP Health Physics Appriasal Program ICRP International Commission on Radiological Protection ICRU International Commission on Radiation Units and Measurements IE Office of Inspection and Enforcement JSA job safety analysis MPC-br maximum permissible concentration-hours NIOSH National Institute for Occupational Safety and Health

-NRC Nuclear Regulatory Commission NRRPI National Registry of Radiation Protection Technologists PWR pressurized-water reactor QA quality assurance RWP radiation work permit TLD thermoluminescent dosimeter TMI Three Mile Island TS Technical Specifications ix

HEALTH PHYSICS APPRAISAL PROGRAM INTRODUCTION l On !! arch 28,1979, Unit 2 of the Three Mile Island (TMI) Nuclear Power Plant experienced the most. severe accident in the operating history of commercial nuclear power plants in the United States.

Preparation for such an event hy the station staff and the radiation protection group was deficient in several respects that led to a less-than-satisfactory response to a real radiological emergency situation (NUREG-0600).

At approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> into the accident, a radition monitor responded to increased radiation levels caused by fuel-cladding failure. A fhw of this hiohly contaminated reactor coolant was maintained through the makeup and purification system for several days and was the principal pathway of release of radioactivity to the auxiliary and fuel-handling buildings and the environ-ment.

Levels in the vicinity of some makeup and purification systems com-ponents exceeded 1000 R/hr, which was the limit of the existing measurement capability.

Several effluent monitors went off scale because of the noble gas I

releases.

A number of actions and events indicated lack of adequate training and super-vision.

For example, early in the accident, dose rates were calculated to be 10 rem /hr at an.offsite location whereas, in fact, the actual dose rates were less than 0.001 rem /hr.

A sample of reactor coolant was collected without the knowledge of the Emergency Control Station (ECS) Director. When airborne radioactivity was released c'uring the collection of this sample, the-ECS had to be relocated. The high levels of radioactivity disabled a countino room that contained the only instrument on site capable of performing gamma isotopic

,; analyses.

Containers of coolant sample were handled directly without the use of remote tools or shielding, and extremity dosimeters were not used.

Several entries into areas of high airborne activity and whole-hody exposure rates in

. excess of 100 R/hr were made without the knowledge of the Supervisor, Radiation

~

Protection and Chemistry.

In at least one instance, survey instruments were not used. At least twice, individuals tailed to leave the area when survey instruments failed or deflected full scale. During the collection of a second sample of coolant, remote valve operating and sample-handling tools were not used although the sample valve measured 400 R/hr at 1 ft.

During the first few days af ter the accident, some technicians, against good industry practice, processed their own thermoluminescent dosimeter (TLD) badges.

During another period, a technician who had not operated the TLD reader system in more than a year processed badges without observing established procedures.

PROGRAM PURPOSE As a result of-the Three itile Islard accident and the resultant problems identified in the radiation protection program, the Nuclear Pegulatory Commission (NRC) undertook a major effort to-analyze the radiation protection programs at 48 commercially operated nuclear power plants. This effort, called the. Health Physics Appraisal Program (HPAP), was initiated to determine 1

i i

whether the nuclear power plants had adequate radiation protection programs and whether they had incorporated the lessons learned from the TMI accident in the r

area of radiation protection. A second objective was to identify eeneric radiation protection problems in order to make improvements in NPC regulationst requirements, and guidance.

The concept in developing the Health Physics Appraisal Program was te institutG a means for performing a comprehensive evaluation of the overall adequacy and effectiveness of power reactor licensees' total health physics programs.

1.

Whereas the previous inspection program was nore compliance oriented and led te the inspection of health physics programs by discrete subject areas, the appraisal program was structured to facilitate an integrated look at the total program.

The criteria for evaluating the licensees' program elements were taken from technical specifications, NRC rules and regulations, and NRC regulatory guides, as well as ANSI

• standards and ICRP/ICRU** recommendations, and in some cases where no published guidance was availa' ole, the professional judgment of the appraisal team members.

PROGRAM METHODOLOGY The HPAP was structured using a systematic methodology that consisted of analy-tical trees with applicable questions for each tree.

The analytical trees provided a graphic depiction that aided in the deductive analysis of a total system and provided a logic display of interrelationships.

The questions were i

designed to define the scope of the appraisal and to ensure consideration of the essential elements of a radiation protection program.

The questions were not an all-inclusive listing of significant items.

Thus the HPAP teans were expected to use professional judgment and be flexible, as the need arose, in the application of the guidance and use of the analytical trees.

For purposes of the appraisal the seven major parts of the health physics program were considered to be:

radiation protection organization, and management; personnel selection, qualification and training;

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exposure control, external and internal; surveillance; l

radioactive-waste management; ALARA program; and facilities and equipment.

One or more analytical trees with corresponding questions were developed for cach of these major parts.

Examples of analytical trees and corresponding l

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• American National Standards Institute ~

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• • InternationalCommissiononRadiologicalProtection/ International _Commissionj j

on Radiation Units and Measurements 2

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! questions are provided in Appendix A, pp. A-10 through A-22 and A-23 through A-59, respectively.

jThe analytical trees start with a single desirable condition and systematically l proceed through lower levels or tiers until all important factors, which 4 produce the major conditions, are specified.

The original program (which

} included emergency preparedness) consisted of 18 separate trees, 2 of which

interfaced with each of the remaining 16 trees.

L^ The interfaces between areas are important in the evaluation process. To j properly evaluate areas where transfers are noted, data collected from one area

must be " transferred" to another and considered in the evaluation of both areas. The result is that, in a systematic way, one can assess the true impact j of a particular event, and provide greater assurance that a given area is, in fact, adequate or inadequate.

Two interface areas that had to be considered and " transferred" to each of the major areas of the progran were Management Oversight and Procedure (s) OcVelopment.

l These two areas obviously are critical to the proper and effective implemen-tation of each of the major areas.

One area not included in the HPAP, but which is definitely a part of a total 1

l health physics program, was environnental monitoring and surveillance. This area was not included in the HPAP because the scope of the program was already so broad that completion would be difficult and because it would have extended

' the inspections to offsite areas.

Since a great deal of attention is directed

,to independent neasurements by the NRC end State and local environmental moni-toring, the plant environmental monitoring program was not included in the HPA.

Licensee's emergency response capability was examined during the HPAP.

! However, because of previous NRC regional inspection schedule variations in the cmergency planning area', the breadth and depth of appraisals in the area varied

. considerably among the regions.

In any case, the HPAP was structured to r

i appraise existing emergency response capabilities, prior to the recent

, emergency preparedness rulemaking.

In mid-1980, the NRC initiated and is l currently conducting a separate. nationwide evaluation program examining

' licensees' proposals.

In order to eliminate the possibility of duplication or confusion regarding emergency response capability findings between the HPAP and the ongoing emergency preparedness appraisal, the HPAP findings are not

, included in this document.

However, these findings were provided as input for

' the ongoing emergency preparedness appraisals.

PROGRAM IMPLEMENTATION To inplement the HPAP, eight appraisal teams were formed. The basic team was 4 composed of three to five professional health physicists, including a senior i NRC health physics inspector as a tean leader and two contractor health physicsts.

On some of the appraisals, other NRC health physicists served as l~ additional members.

The inclusion of a contractor health physicist added an extra dimension of perspective and proved beneficial.

l A team approach was selected for several reasons.

Because of the broad scope of the program, it.would have taken too long for a single individual to perform 1

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the inspection and complete the appraisal schedule.

Furthermore, the inter-l action between members was particularly desirable because many evaluations were.

necessarily based on professional judgments. Also, the interchange of concerns.

among team nembers and discussion of apparent weaknesses often helped clarify the real problem area or cause of the symptomatic deficiency.

Each appraisal was scheduled to be conducted over a 6-week period.

The first 2 weeks were spent reviewing the site's past inspection reports, radiation protection procedures, technical specifications, Final Safety Analysis Report i

(F5AR), and other pertinent information to help the team become familiar with the onsite inspections. The 2-week visit to the reactor site included discus-sions with plant personnel, review and observation of work practices, review of -

the licensee's radiation protection procedures, and review of records (exposure, incidents, and such).

In the appraisal process using the Management Oversight and Risk Tree described in Appendix A, it was necessary to determine whether each major part of the total plant program was adequate or inadequate.

It was also important that the documentation of the appraisal specify these conclusions.

To accomplish this, each team was directed to structure reports to specify for each of the i

seven major parts of the radiation protection program whether it was (1) acceptable, (2) acceptable but certain matters should be considered for improveo j

ment,or(3)notacceptable. Likewise, the total program was rated as accept-able, adequate for present operations but having significant weaknesses, or not acceptable.

Deficiencies or weaknesses were considered significant when the finding had a direct effect on the level of protection provided or was a critical element

}i that was required for judging whether that portion of the program was accept-able.

Isolated instances and minor items were not judged as representing a significant finding. Powever, if a number of deficiencies were found within a particular phase of the program, then a significant finding may have been warranted for that phase.

In instances where the deficiency or weakness required intrediate attention, the problem was. discussed with licensee I

management, definitive corrective actions were agreed upon, and specific dates were committed for completing the actions.

NRC then documented the corrective actions and dates in an Immediate Action Letter to the licensee.

Problems of less immediate concern were documented in the official appraisal report which was issued some weeks later.

Implementation of the Health Physics Appraisal Program involved a contract with Battelle Pacific Northwest Laboratory for providing professional health physics personnel to support the establishment of eight appraisal teams. A total of-24 contractor health physicists, 36 regional inspectors, and 8 NRC Feadquarters health physicists participated in one or more of the 48 team appraisals.

In all, 68 professional health physicists wre involved in the program and spent more than 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of onsite inspection time at licensee facilities.

i PROGRAM FINDINGS The HPAP inspections indicated that a number of. weaknesses in the radiation protection programs, similar to those identified at THI, did exist at-many of the currently operating nuclear power facilities. Summaries of the'most 4

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'~ significant and most frequently identified weaknesses are discussed in the following sections along with examples of nuteworthy performances.

Each section heading is identical to the seven major program areas used in the

' ~ appraisal program.

Radiation protection Organization and Management Significant weaknesses in the area of radiation protection organization and 3; management were identified at approximately a third of the facilities in-

.spected. The most significant of these weaknesses involved:

lack of management support, inadequate staffing, poorly defined assignments and authority, and failure to audit performar;e.

i Lack of Management Support The lack of management support of radiation protection programs was reflected in several ways. At some fccilities the Radiation Protection Hanager's (RPMs) reporting chain was such that the RPM must conpete with others within the same group to bring radiological problems and concerns before the station manager.

At other facilities, the lack of management support was best exemplified by the small staff allowed for the radiation protection department.

At some facilities, the quality of radiation protection was found to be signi-ficantly less where the RPM was not reporting directly to the station manager.

1 It was noted in these organizations that health physics was more of a routine, i

service organization than a radiation protection support function, integrated into the fabric of all plant operations.

It was noted that personnel within these organizations generally lacked incentive and a depth of technical knowl-edge.

At sone facilities, inadequate management support was demonstrated by a failure to take timely corrective actions upon notification of radiological problems.

As one example, disciplinary action for serious violations of radiological procedures was very rare.

Perhaps the nost telling fact was the attitude of many managers, that the radiation protection department was solely responsible to ensure good radiological work practices of all station personnel.

For these cases,-a similar attitude tended to prevail. throughout all levels of the i

organization. Upper management often failed to demonstrate its support by requiring and ensuring that radiological safety and good radiological work practices are the responsibility of all supervisors ard expected of all employees.

For example, past experiences have shown that some supervisory and other nonradiation protection staff personnel. failed to give appropriate

. consideration.to radiological concerns when entries were made into reactor

' cavities with in-core thinble chambers withdrawn.

In such cases,_the personnel making the entries apparently did not feel a responsibility to ensure that good radiological work practices were implemented. Such entries have;resulted in several-overexposures in the past few years.at other plants.

5

Inadequate Staffing The radiation protection group was inadequately staffed at about one out of every three facilities.

There were personnel shortages in the technician, forenan.and supervisory groups. Many facilities rely rather. heavily on con-tractor-HPs for their technician staffing.

In some facilities up to 80% of the routine radiation protection technician staff are contractor personnel. This heavy reliance on contractor technicians was considered a weakness because the turnover rate was generally quite high, and therefore, the level of familiarity 4

with station design, plant-specific characteristics, and local procedures was generally low.

Even at those facilities that did not rely heavily on contractor personnel, only enough radiation protection staff had been hired to meet minimum needs for routine operations; little provision had been made for outages.and other anomalous conditions that significantly increase the work 4

load.

Frequently, the technician staff was inadequate to accomplish all routine duties in a timely manner.

Furthermore, many facilities did not have radiation protection technicians on all shifts.

Instead, this coverage was often provided by other personnel on a n rt-time basis.

Many plant technical specifications allow for backshif t coverage by persons trained in radiation protection procedures.

Commonly, however, these personnel were poorly traincd

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and often unprepared to perform many of the routine functions required to i-evaluate radiological conditiens.

Generally, there were only a minimal number of foremen and supervisors in the r

i radiation protection department.

These personnel, frequently overburdened with l

administrative and clerical duties, could not supervise the technicians ade-quately.

Such inadequate supervision often meant that adverse inplant trends I

went unrecognized and nonroutine operations were incompletely e"aluated.

In addition, most of the facilities did not have a qualified backup for the RPH.

The need for providing a qualified backup has been demonstrated in the past; when the RPM became ill cr left the organization,- the quality of the radiation protection program decreased substantially.

Poorly Defined Assigninents and Authority At many of the facilities assignment of responsibility and authority was not 4

i clear within the radiation protection department.

At several. facilities, personnel within the radiation protection department could not identify their immediate supervisor. Specific duties, such as feedback of analytical data and 6

discovery analysis of ancmalous conditions (trend analysis), were not clearly i

defined.

At some facilities the authority to immediately stop work was not i

clearly established and in at least one case there were opposing opinions as to' whether or not this action was authorized.

J j

Failure To Audit Performance Another weakness observed in the organization and management of radiation protection programs:

performance of the radiation protection personnel,was.not audited.

Although functional audits were performed, those audits determined-only that specific functions were being performed, not the quality of that~

performance. Usually performance audits were seldom conducted because the audit personnel were not qualified to judge acceptable cuality. Another.

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l apparent reason was the shortage of qualified health physicists on the facility's staff that could provide technical program support such as per-forming audits and other assessments of the plant's radiation protection program.

I Exanples of Good Radiation Protection flanagement At some facilities (for example Trojan which is operated by Portland General Electric Company (PGE)), the management has made a strong, well-documented commitment to radiation protection even though PGE has only a single nuclear unit.

Concern for radiation protection at PGE is evidenced by the active participation at the vice-presidential level.

A formal charter has established a corporate radiation protection committee whose members are four vice presidents and a certified health physicist.

This committee meets regularly to consider policy matters and review or investigate unusual occurrences.

PGE has a strong, well-qualified corporate radiation protection staff which attends to licensing functions and long-term plant concerns.

This staff also supports plant activities with special expertise as the need arises.

PGE manaoement supports professional level training programs in the engineering disciplines by making university level courses available at PGE facilities.

Farley, which is operated by the Alabama Power Company, has a strong, well-managed r1diation protection program with strong support and active involvement of senior corporate officials who are committed to an excellent program.

Personnel Selection, Qualification, and Training Sigr.ificant weaknesses in the area of personnel selection, qualification and training were identified at about half of the facilities. The most significant of these weaknesses involved lack of development and use of selection criteria, poorly defined qualification criteria, and inadequate training proarams.

Inadequate Selection and Qualification Criteria Selection criteria were seldom established for specific positions within the radiation protection programs.

Positions were most frequently filled by seniority and availability rather than by seeking the most qualified person for the position. This often meant that personnel who were not best qualified and knowledgeable about the position got the job.

It was also common practice to accept contractor technicians "on faith" and to perform only cursory reviews of their qualifications.

In many cases where qualification criteria were iden-tified, they were defined too poorly or too generally to ensure adequate com-petcrcy.

One frequent mistake was interpreting ANSI-18.1 criteria as requiring 2 years of experience for technicians without paying attention to the functions 7

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The app,' al tear ru>ted <ther e l co 'en t c that demonstrated the inadeauacy of cornuter procrans for obtaining traloinq prngrarc A heavy reliance n'

anai,tical rotults n.ea n t thct a c orput er failure or pcwer loss would result in ihe i I t,'I 1 l!is t ()

idFntity dn( glia Ci i fV nuclides.

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Ii Wac t3rquei,t1v ob:crved tha+ technicianc failed to ttita;n1/P a pc tcntjg] ptoblrr inyplvinq alpha and bo+a radia* ion dnd ConSe-d 1d not pert DN appnll' elate surveVs to evaluate ihP Conditions.

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Iec hr it 1ans d i d rlC + ' DF PG n i ?f' siiuatiCn" Where extrerity monitoring should have Mer pe t + n rint)d.

!t was alsu nOiPd that POstPPPraiiDn bfiPfin45 WPre noI roli t i no l ', schedult'd followind rhl f o f Pl.+at;t's or (1r c;'p Ptior o# unusual ('pe ra -

t i on.

Thi' +vpe o+ contina i r c: t rainiro was on.it ted bs ranv f acilit ies.

The radiclogital centrolc raining tar general prploveo/ raciation workers was found te be defic!crt at rans t' a c i l i t i e s.

Marv procrars cid not provide the h as proper friskino +echnioues and donnina/

t ra it ee wi t h hards-on training w rerm inc prot ec t ive clothinc, or handling, novina, and working with contarinated materials.

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Eurples of bood belertion ana fualif ta+ ion r rittria Seve ra l ilonts werr noted to have devol g r4 a nd irrpl oren t ed so l er t i rn a nd cp.a l i f 1 r a t i r,n triteria The Farley and B rowns Ferry plants h u' documen ted select 1% and qual i f ic at ion criteria for en h position i r, their r a r' i a t i o n protfrfInn orgorilla t j ons.

Thpqp (p3tprje rplatpd t<,

l(d, desc ri pt ipn s, included formei training arm experience factors, ard were uwd as stardards for hiring and prca,tions The faunswick plant user 4 i nb descriptions +ne nach position c a t erf r/ Wi t h i f' the fddid'iCn Pfqani /d' 0

T hp s,> c' esc ri pt ion s were deta iled aftd orprohPT.C TVo dild prf!\\ided an PXff' pe r f o rr a n f f eVdlualinn as

'I bd s 1 -

r r

We qgjrip]jppc f g;p }gh ppqu i rpnpni( D '( rff 'IoVei 1 c t

f., <u p l m of Q <,d Training Sinco *he rot + f requently observe,1 woakne'< wds f ailur r tr provide adcquate tr,ining for india + ion prot ec t ion techniciam,

nunber of m arpl es o f clood appro,n he", in +rainiro are niver t' e l ow. J t #>w u+1l1i if$s haVP FL1de 1 "Uhttdetial c o r'r i f r,e n t +(> traininQ. Nd th 4 ph ,i + ec hr i c ian traininc for f e rH 'ra Power and l i aht i< h ohly f o rr,a l i zed j' (' o n ' i, r,( t i t if) w 1 t I' ?hD utili* SUc l t'a r.rd'n1Fn Ic i(In OLdit' EOdf

Paleigh,

( Technician' cre removed ' i nr the inh F r' s surr s ard provided an l. r e Hi and l d h t a r a t.1 r b wC rh enVir('n"efi, staffed by well-unint1t ,{it#sd i r 3 qualifled pr1. +e>,1onal dura +nr< Th< re appea n d to ho a close liaison he+ ween the << r; rite tr, "1"ot op t r e and

t. h e irnividual pl !r+

t ra i n i n-croun ' ', / ' techn1<al fra ning cent ir fN le Choa' Tlabama c. f # r t c a well-planned n_,<.nF

• rainir<

.u rse ter up +ochnic r nt R ecw" Fort' Th. course <<o ,in+' + i s!r e trit v t r a l i, ' r o' with ouui vent s ifn" l ir+e +ha+ UceC at the t l plani i 1 ['l,i r t t Ir tetj' i'Ir' l' >Vsien' l d 8 'il i f i I I. I l f I n, faCIEIiCD bC icv ry t b,.p g ? j t

-) r [ l pr' i l,1 ! y, and (p oral heal'h phl/siFs ins # ruCtiIn.

'1 1 t ht; ugh 'mth kru 's t i o n 'a l re t ra i n;nu program wac not imp'oronted, cnd taq uren at jpp j w( j ',T wetp n t i t o r*, the plant had ai, esc <'l rrt p roa r s r' for deve '1T i ng wili ',< ired >n oualifik heal +h phyci c, +erhn1ri m. Establishea in,1anuo r y lhM, th prnurar Ersigned i r: tale an irdis1cual with little or ni hea l i l-phs < ir +r ining arc (isolop thrruch an eicht-s+ry 4s eat p ro g ra rt, a c w. cuilit led t ,1 neicinn Pe+nce tbe tyainee cdt Frnaress + r. tho nowt hiaber p') h#' ri j ( ri u t l v s' .+ i: t I E + a f i OrV F) 'it'rt o

• ar i id#iCP feCu aOd aClf Ob e

+ ( Individualt are norn lly brouf* 4 nto the deselopment superv:wr conral' proera, at -top a: wever, tc<f"iciam w'+h c u++ir<<n+ ox pe rir "ce +n meet the ESI I!,l-}u/I ?e-1.1 r emo " * ' f f;t Pr

• ht' (h\\'elODron# p rl'GI aF aI Si PI peat h ! < i + t or '

' ems 1ve, + < 4 rr a l + ra ning prograr, ; tarts wi+h ;+s en t rt - l evel 4 radiatii'r p ro t !' t.r t e c h n i t. 'ans. Hiuh schcoxl gradua+rs, with b?cLaround ir ma+hematics and <ciencec wa r placo: Al-renth + ra i n i nt. croura" The pt'n(lral' "'iTdule i t, l ' d F' d c'a + N 'l l t I t' R JPI phVsical s r i r "'l e, b bS I)C CO M ef rem for t et hwil nqv, ecdlatinn prn+0c+ ion, and choris+r Rome 'f thr rodules i n( luded apprm ir a ti 'v 50 inplant ana 50 c l, < c enor' t i re is t the cornle'ior ot each FOdule, tho sturer' M ' rP refulred t( p< d CDNPFfh ive exar Ibo o pe a c h ik

• t or er-the,ob traini % trenrar wac irT lenented h a +rair iec ranual; the nanual had sk,Il e.quirerert-ard cua'4+

i% m or Pl art c vs ter s 2 t i a i n i ni; wa' di50 linIV I ed Q

/ [ j l d n t, s [ht' I. i r.n d [l a r.' I'fP-I '* \\ l b, If b 'tir' 'f ,rco of H+ loost i WO e L ', ' di' r a t i no rserrho '. e c t i p rc i d o c. c / c. ? trs t rainire rn < r a 3 r br(u } pr' b a <, j ' r n f' (1+ a i p rY I' r def i f' F Ibf OIklI1dUS* T ! ~ had ' t (,' "rubiclo t rc i n i na' +0r 4+c HP tech- , s ' t o r c. t ra i r ir n ir +he

r,tleted

inq Vehlt 16 war FOdh'Efi ?ed ift n,<ianc ore + r, s ce n. The ,; g c_ i f, ( .r+ a re '+<r re f un ! i nc; floor) wh ro the stur9nt learned r. r e s p o n c i b i l i t i v e.

1. r i i:,th, as ttt a f f oc t es n t r-i.,,

4"rn t i c r o e 4 t hrise' { la rit a r e.1 'or rarwn + o Pur l t i po i 5tility [:i m 't ir ! ( C P '[, cpora+c' (; Larcho 91r, cupporM a, t r ore terhniciar u; g rade pr wrar l r a d i m: t r. MPPT* r_ r r t i f i c a t i o n. SW!D has woi1ied c no r .e N terial< and <tuds + a t l l i t i rn a f t e r r n"e l

v. o r k hour c, ard p.,

the t ro rn1r ian< f(.r t ir e sor t + i ii p re pa r i to; for +hr + IL F T. x arli n a t i on. At c the preson t ne 6 t m hr i r j a r.

u' of a staff of M a,p tor +i' od and 3 are in t h, applit at inn un a ess.

Ihr ip ofit a l pmp l ' / t > t-ra d l d ' '(. V. F r k t ' '

• eclf iny AI If9\\PI d

V'b d u U # d YlU C 'Cld iPd WiIh ct a g s >d p r o q ere desinned tr. i r. u rl wo r k f r' of thD h"' h,e f l i n t, radiom +ive "ater,els. In addi+ior to lm'ur+< sidee presenta-t1(t< wt,rL er( wDre requ1rrd ?- phVsirJ' ', deU On s t F<' O F f' c ^Fr i (! F u5dGe, riskir<, donr inu anc tonnivo l 'f P rn + nc + 1 % e c l o th i nc; ctepr+' pad procedurr< + ,th. L' o Lup and sir u o' ed c on t ar.i na t i on a rr woo. sed to effect l and c c- + mre and retentlen sn T wri+*en +o<+ wa< adiinistered tc. evaluatt o,+ l

c. a

! rp(;r +. : n t ia( it ,ainin(. wa rii rec tpd b' wf 'l-<,, '+'td instructor 5. ur e fontr(il I.+t tUal [ > p()t lanificant wea t r es c er in +lr area of oxternal exp( sure con t rol v'ere identi f ied c+ a pp ni.1 r a t e' v one-f r,u rt h o+ the ecilitiec. The nost siGnificant o these d f weakne'so i ntlude i nader;tia t e d()s(' Vf'fii i f a t iDP, pn< 1 r <!1 s i.ep;i na t i c n iit current dose statuc, tail ure in pt f a lde

r. x t r e r' i +, nonitot irq and f a ! ' ( ? t' t0 + ()) I t % e c t ? h l i . h t d P rf'f edu rt'C I n.1 ( j(it '11,i i ti

['li s e \\' t ' f i i i ( d i i n tl tafilii' i+ was obserend that the stster, for r:r c e n' eupher wa' E.ty afJt'VDl\\ I reliupr t l y filr rr [ reddin() Wece nOI y e>ri t ir ati i tn,ared wi+F recLot A <1reter en d i ncs. Fven ir those ta w where c orTa r i son s t vt e Pude i t i.neiv 'N'te worr otter no accer+anty critrela rr a levo' at w h 1( h + e l l i sv. u p a t tion w'< required. 'r situatiorc whero unefpectediy hioh orred er where ver i+itatint c laran expec um was a r t i c.a b l e, osposure- ,1 Technoloclicts rO t t'C i i t

• Na t i.t a i LeQ1s

(># hadia t it t 10 L

thoro war ofton a reluctancf +c "no to +he trouble" of verif v ing the doses and, ir soro iasos, the nood +o ovaluato and docurent dosos for ofher than whole body n/[r suro Wa< nr ref ogniled. At a nunbot of facilities, pocket doc imoto wero sent o f ' c. i t F for Cdlihra tion 4 anr t ut into serviro di rec t l w upon receip+ without ary acceptar ( e tests. This bI'nd err opt anto 4 n vendor work without ao, independent qualit, cnntrol check reprev nt< a failure,if some li<ensees t: rocognizt the i responsibility to r ensure that vend < r service and supplio atisfactrrily meet licensee's needs. h or his;oninatinn of Current hoso Status C oro <J the ta( 11itles did no+ have system in place to preside tinelv o dir wmina t ion of current dose status o individucl s who were approachir q rerpil a

• c.r y or adr ii n,- t ra t ive limits.

Althcunh current dose status was i aintained at all futilities, the fineliness of feedback tn appropriate groups for ef t c( +ive centrol of exposurec was sometimes poor In Erst cacos, this was exhibited by systens that relied on manual processinc, of data. These f,o ilitiot using tomputer s v< t oms sel don, had a proolen, unless the con puter S ri)k D down Iallur. T h cvide fi t rer i t y Monitorino o Th failure 'r provide ndequat< extrenity cor,itoring has been identified in several other sortion< cf this repcrt hut deserves further discussion The inl, lor appear < t) relate +o the for' that at reac t ors whole-body e<pocuros are t' y far 'hs' creatent t ur.c o rn for nest of the opera t ions perf orn ed. It becomes s,. tiutino tha' <c m ideration o' othrt types at e>pesuro is forgotten. Typical ,1 ! ua t !or s wher" " < posu re to t hr Frad or har.d< r a y provide the 1imiting doses 1rc lude stear none ra t r r repairs, whero the head is closet to +ho tube cheet i than the t r unk of the whrile body, and r.a i nt emnce er incore detectors, where t he hands ras re c e i ve t he linitino exposures. hin1deratior nust alse be oiven to hota e<po<ure an;*ine the p r i na n cysten is cpon for na4 rtonance work. All 't o otten radiat ion pret tction technicians fe 4'ed to recoc,rize the neer for <perial nonitoring. Failure To follow I4 'ab'it hed Procedures failure to follov < t ab l i shed pr o< odu rec wa one at th" most # recur ntly r (d:st r\\ed faul (>t radia t lor protof t i(ir technit iarc and workees. Most ia( l l i i it Ilad {lrof edt;n s which we're adequate +o prevent incdvertont and t.rn#'t t's s a t i e x [n1R u r+ ' HoWDVer, DVst exposure oVents were CausPd, at least in par + ht t' a i l u i t ' ti fe' nW tho eC f <h!Ishoo precodures. This probler, was i oh t e t V#id ai n(, i f di'ili+it s. ) { s apy l o( '+ fa a > d { s t e r t al I s po t l1 re c i.n t f(ll [tfect1se u' e if c:1 pu+cr17ed ilose rrenrdkoppinG was ne'rd at soveral stationR. The cornute-wat o'ed esten f

e< a u l a t o r' dr<, ile een rnethl. ?r da+< hec-r- vailable, personnel 4 {. recul+c err o prograt c11rulating Il/ pocket filo< .tr updated +o rc + 1 s" e or u t r n /r alet t ir slonalr- 'rt "ach ratic outside a dr ' ir et er ratin predo'orrinoc 11r d + faidit,rm PWP d0co recc re c ctt wdlusic< based nn each d r m rat', ' hic e vs t m i< used t o renera tr daily dose individual' I! {'/ do' i me <'c'u< r o p, alert 1:<t< terr' +1on repr>r*r t e + rarl PWF person-ror-c rurul,*1r e ; and t, v ne ra + + +Fo na*eria' 'or requ i r o r1 annual rrports. The l' a r, r' t-be relative', simple tn use. s r t er appo'>sd to f unr + i nt. Wo 'm Fm:' t o has co ol rmod whe + , oars +a ho the bac' 'nr a pa rt i c ul a rl y v o f t :, t,ve, compu'or-based. pf rsonnol-<eposure PUP s, stem. Althruch not <<rpletola debuqqed and larLinq flr,1bility in certain areas, the syster rnit< ' '., o time ort,/ cf expos, roc repor+inq by shiftr r f exposures f or work

r

ups,,isual yevirw of rm eds by cathode-rav +ute (LRT) terminal and prop-t ra ' 1 m if hard t opv Fo rsom.

tile recordc and terr i ra t ion letters. This c.te, al v provides the plant mara m ont a dai's for hv shif+' statistical repot t posures dut inq the perc edinq M hcurs by variouc sorts, includina ,in r L g r<,u p-( r task Thr s y s t er; intiudes a rnrpu+er-based PWP syster which po rr i t < rultiple entry-exit point control pcsitive control of authorized individualc, and review of t ra ining and respirator protectior cualifications h e t<o s. .+t tv. The sy sten aut ora t icall s relects indi,iduals proposing entr en an WWP wN do not satist the trainina recu i ren ert s for the specific conditions ct wurL s t,, ' M r n the PWP a securi' cuard a+ t he ( Ontrolled crea access point. 'everai n ,nt< pos i t i c.n 'he nu m t offi;ient use o' +4 quarc war m t ed at Pra i rie Island where the cuard mn i t < 1r-tFr redundant plant security televacion syster, retains incividual ( 1m L pun ( h ravd t iir persors enterinC the cont rolled a rea, ensures tha t the i@ and d<>s!nter dose is entered on the cards, ensures that individuals are we i t im; proper dnsinetry, ard oversee < a f r i s k i n c;, 4+ [ntt'rt al {*{HisulT I (in t r(il signititc et wea L nos ws in the area of internal exposurr control were identi+ied at app ><. Imately one f i.urt h of the faciliti e. The mcct significant of these c weaf m ' w I nt ludod ( l Pidrina + ilsr s op t c(31, ['t'rstlnt't'l Ji' t '!'a dt'qu a t e ( ill i h t'a t i(: T p ' t q r d r c. 1 fia i i e! i en tl-stir # al t' coniap!TPiion a t't'd s, d flO T s p i l'a t (i f V pr(ti eft inD P rnC t'ans. Iillltit3' t (1 i UliV I Fp l t Weili It Wea k ne 1sc ir Personnel fUntarinat1( t fop +ro personnel i [t t a [)(T u ' pr e ' (Tu t-t h (i t t his facilitic<, serious weaknesses n ( Un t ami n.t + i on 'ont)ol we,ye obser',rd 'h i s we s one Of the njc t CeRFnn weakne se' idertified across the i n r' u s + r Very efter the +ype o' monitorira equiprert provided at exits tc. (urface c on t ar:i na t i er areas was inappropria?P tm detm ting significant levels of certanination er persornel The use of large-area "pancak e" end-window Geiger-Muller detec tors ( the preferred ins tru-AL.

mentation) was too infrequent. The placement of the frisker was frequently in high-background areas where only gross levels of contamination could be detected and calibrations were often inadequate. Shielding was not utilized to the best advantage. Personnel exiting surface contamination areas often monitored them-selves too fast, too little, or not at all. flany programs did not include provisions for recording instances of significant contamination for evaluation and tracking as an indicator of inproper work practices. In many instances, facilities did not realize the extert of their contamination control problems until they began employing sensitive detection techniques, such as whole-body frisking with a pancake probe. fiany facilities did not have a procedure for estimating maximun permissible cencentration-hours (MPC-hr) exposures from whole-body-counting data. Because 10 CFR 20.103 expresses standards for internal emitters in term of time-integrated concentrations (MPC-hr) and intakes rather than permissible body burdens or doses (such as has been done by the International Cormiission on Radiological Protection), two areas become very important: (1) that all licensees maintain a comprehensive breathing-zone air-sampling program; and (2) that all licensees be in a position to compare whole-body or organ burden data with the data generated by the air-sampling program. To accorrplish this, each licensee must have a method for interpreting whole-body-counting data in terms of MPC-br of exposure needed to produce the measured burden. Another reason for relating the whole-body-counting data base to the air-sampling data base is to determine the effectiveness of the respiratory-protection program. Many licensees failed to established a procedure for estimating MPC-hr exposures frem whole-body-counting data and were, therefore, not in an optimum position for determining the effectiveness of the air-sampling and respiratory-protection programs. Contanination control appeared to be e good measure of health physics (HP) prooram effectiveness. Good programs did it well, poor programs not so well. Employees were more productive when they were able to nove around the plant without being excessively burdened by pretective clething, and their attitudes toward the HP program were generally better. Good programs stressed worker training in proper contamination control work technioues and prompt correction and cleanup when contamination was found; poor programs provided minimal training in radiological work practices and merely delineated contaminated areas to prevent further spread. At the latter plants, decontamination was usually c collateral responsibility of a group other than HP, and the emphasis and skill applied to it was not as great as when controlled by HP. Good con-tamination control programs also reflected stability (low persornel turnover) in the decontamination group. An exception was at Point Beach where the non-professional entry level position is as "HP helper" (including decontamination work) for several months before selecting a permanent plant position. Failure To fully Implement Respiratory Protection Programs Approximately 25 of the facilities had respiratory-protection procrams which did not meet the reouirements of 10 CFR 20.103 or Regulatory Guide 8.15 nor the guidance criteria of NUREG-0041. In some cases, it appeared that the total program was not implemented because of the effort and expense that would be required. In most instances, deficiencies were noted in the areas of fit testing, assuring breathing-air quality, and maintenance of equipment. 13

'e{inus

1 i t i ru tFat did

,t

• u "Dl 'vuv ' the p n ;r, r there wae

/+ ' hose f at 6 d 6

• a t j rt f y r#

1. ff' [J r0 IL

( Ff( i> r f t i () r tPF(' e i ',IICV U b f' tie < could m + take ataMace n in +he or'mram Art n i t l u n a l 13 twe f f a, ion devlter ,.u t ho r 1/ed p ro + er tion f at t r:r < +or ** ve r. c an respi v+ rv rou +ri t and 'herefore, vo rkers would b ' 'ir cr+]v lit-+rd ir +he rmount of t im la, pend in ;irhorne-r<diraf+:V1I er"aE 4 I ' f 'i f

• i(*

ff* l"A P the - s bera n e ct the ne or< in<reased ( pt (.p i e inads;uat. ( a l ilo "t it r Perop m < Ihe calibratinn n '~ f r,sk ers and wh le-bed / n>urter< wa rr.ted ac a weakness at c a number t.t 4 srilitim In e <cm, r alibrat ion was r ot pe rf errred on ,, < h rs o r th ininimum levr 1 t de t m ' 1 m had r# heer establiched. At 4 <..eral f a< 111 t a m it wa '<.und + hat ( o ' i h ra t i nr n' whole-bod., counterr v.a s attenp?ed usinq one r, e r'o re umcco" of unkriwr art ivity er C without a phanton tablish prger geometru to e {, a mp l v < ..t N md 'nternal [. pc c.re C o n + r c,1 The i a l lto r + inn and ut il i zat ing, n' the whole-body /thvinid/lunn ccl.nter at the f'a i re YanLe. %c l ea r P4,we r 5tatinn wcs tound to be r>ceptinnal. This findinc i< hased 4 a 'h followino el emen t < c the licentee's in vivo count ing program: 4

e r ' o rma n, 6 r+

dai1y barkground and r adinisiit opic source rhecks on the wh< 3 ] # - hi,1 v / t h y rc ' ti,' l u nt; cbur.+ e r ; pv> rf c rr a tice, of a seri-aenual e}ectronic! , ad t elsot rq 1r ( alibratint er the coun t er ; frequercy of the r< >u t i ne in v1vr < ciu r t i: q Lir oqr an ; < orpet eer e ti' the heaiih ; hvsics depa rt ment sta'f member of in vivo data by the Health Physics per c1rn i ng in vivn countinn; anc anal4 d c i e <[nt t'i ne'n t !"O F l' p 'MJ'n i A a re ult (if pre,iously ident, ind contanination prrqram weaknesses, and re ultan+ pi '. i t a s r, responci & i mp ro v er.e n t s, the Prunswick Unitr i F. ? site's, jin nli ale (*n su r lf.', adequate }M'rsfinnel ( (m t ami na t 1()N surVevs WAR found eXCep-t j rina l Pf' t s t'r a l s ll r V e ills i f uIN'I i \\ f l S k P f WN Cd bfd tunttion?lly checLed at least daily and i< ally W to a radiatire sourm, ar a u w lly rait .hltt. FrisLet stations were located at e3its f ron t he radiation iontrol c rer and at wler ted places inside. Survey areac were shielded, if reco1 red, to r e dui e backornund radiatlun levels. Fa( h trisker station was con-finutiusly i.anned hv a " f ri ske r wa t cher' whr was ins t ruc ted to observe each individ'al surseying t. ersure that each i1ne perturned an adreuate survey and that hand-,arried < kin t_s were either surveyed or had a valid healt physics turvm release f t.rm The + rid er wat.chers were t rained in apprepria te survey techniqacs su1 na t i on nt survey data ar o ' ant conditions, ma r q i v <upply of instrumen, and i na dociu o t e alihratinn. e [ a i ' ta r f' [f) I'f i (' er O d('Qlj d

• t - [urVeVs The 4 r-n anpl i r.o prnoru< at a numbor nt the facilities did not provide a r u, a t e data for evaluating pntential irhalation problems. This was due tc a frequert t allur r + c. obtain air sar ples tha+ wr ro rop re sr-n ta t i ve o' the air brinq broa*h d bs werk er<

failure in <nnsider a currents and dilutior and turbulence rauwd by wc r L activities worn the most common reasons representa-t is-air s a mp l e < woro not obtained. Other ennnrr deficiencies noted ir the a i r-sarl ' 1 eq prno rm wore a s sur pt i on tha+ a ll filter media are 100 rfficient uMer all < r.r d i t i on <, countino officirrmios based upon standards placed on me'sl ta c L i nu' (that i< high backscat.ter\\; procedurr:s which did not take inte .u m u r + +h, evalunt;o-o' short-lived patticulate acti vity ir the presonce of natural radi, rtivit filter papor brinq cut down in size be'oro courting, w i + h, m t p t c pe, procodutal <nntrni-onsure tb sraller s ar plo is representa-tive, inar equa t e s arp ' i n, volumes ann tilter rfdia f or ai rborne al pha reasure-i ner+< ar# iradeoua!0 quality contrrl wasuros in the counting facility. In r :a n y c' the plant' appraised, per sonnel vsit ing radialecically controlled .i n used the per*al monitnr as the prime monitr,inc device for detectinr cf ion'ar nation. The e po rt a l unnitors measure gamma radiat ion onl v; they cannct persimpel < nn t a r ina t inn with the sencit4 vity needed and contanination dete ran bo n < w ed into an,, , +ricted areas and oftsi+r Post of the cortal mor iters were t oee t n aiain only when several rit racurit< were placed in close cortect with t'af b rio + ef f (if M(it e-sen s i i i Ve frisher-TypP i fl s ruPPnIdtiOI Wds usud Y 4I,t h l t' l'.i f [ie!SFrnDl W P r t' ' n()I f t' Qui red IO usD ii. aVc Alpha aw eta suru.s were pm +ormed info cuen+1s and, typically, with instru- ",ei! de' ',$d iln l y 'Pr ' t t ' r t i n r.

f'd!.ti* for Fahirg quantitd tivP Pe a C ll e, t.iil5.

Alsi) th n edure at many fac1 ties did not specify what correction factors i to use 1" iant i f Vino a l pha r easuremen t s or determinina beta demo rates with Q M h i i a l1!'t att'd 5utseV l n s i rurP'li 5. bPDlhPr COnLm wa s t ha t ihe portable curses ins t runrn t s used

• o conduct surve/s were tspitally not calibrated l

aq iir t l ' + t ' il' t 'l 8' ness Was n' 'e di a nu 1e r Of d( 1 1'f'eS--the de erminatin of the 6 ' oui rer M. e ouuisalent Var!ruc nou + ror -ron i t o ri r devicec wo. ebserved in u sti

• tue i nt l u Ot'd

'l -SN', -N, b l beC IbE, b l I OCC DOuIf0N siarve in 'rimeri< pr7ncipa'l' +he f h e r l ' 'S ' PW d I)piCalls, the aFpraisPrs l'

( ( . r r t e rrR r1 the nui+.h 'its et t he rmr. i to ri ng i nou t rre-o r,r ro v r,pm t r< in orcor +c er 'e tr uw n n r4 the apprrpr,ete tactorc to use for >+. err. iring the neutron dosp p r i; j k d l f ' n i.. i f s,( [ i " (('r'l i !' r : t II)n ni b u f V I '/ bdId 'flf I'l W 1 ed f' 9 P1aO+ rOrdi i <'n s t in rura nus in<tances, +he di<ser l +irm and uso o' survev resu ts were poorlv ( < M rd i rht fed, d n ff there Was a di' 'l t ldFk fr# r PIVun i c a t l( n s be t wpor rperations .md the red!ation prrto t. ion qr( n; c onco rri r a port i nor.* plant artitities and t..r i n i ng i < a l rondiflom

Pfton, curr or + ra d ir;lf ei ca l ca#e+s data woro not di nomiro+ed in a t i r a ! v r:a n no r 5.r i r,c l u s i e n nn work po rr i t ' or for updatinq ra d 1(> l oq i u a l <tatut tu m t r There wet al w a failure to maintair a good flow o

'i i j rn h ttjrr [3, > t y p p n P[f rai 'ns d r'(t +hr> ra ri at On protec on group renteming 4 4 1 plant ovciuti< m t im t c o u l d s i o n i t i r.n r. t l c hance radiole ;ical ccmdi t ions; for r ..unple, wi+hdran 1 o' W.L inu re de t oc t o rt io.d essocia*ed nauipr+nt during m'uelinu i;erations wi+hout tirel, r c: t i ' a c a t i e r of the radiat ion prntec tion t,, f t Paruinci E.rpl, of Int'runent< t 'tt' i; p[) l; rat fit) ilth [J h V 's i( i n s

• i lilf ? n t d i i o n dl r anY 'a 'l i l i ies Wd5 U qOd O c

[4 ! t rU i n d l l k .ii( ('[ la h l f ' t (! r r tiu t i rP nperation( a nd i na dPol.m tp f or ar accident ht> i,iij ri i i la do i'4 IIII (i t grDd: t ' i' 'nadequate ( a l ih ra t irt a l i b ra t iit a nd ma i n t il a nc e pn ib l er s we re ( nrrnn Calibration of bete and > >li i t I > n 1 fis t t umf ni ' WdE l'a ri i( l'l d rl V UoP t' NidOSPFPRd Use Ci fdIi008 ,' apt otds t (i r i a l i hr a t i orl pre t ticos did nri exist. Iho use Of PUne ralibration i teihnique +or perser r + 1 t ri ske> < and portal nenitors 0+ ten lod facilities to

• he talse a -unption that these instruments were performinq a function which tualls in( spahle of doina.

Not all facilities recognized the the, werr ac I mitation s portal monitrrs and sorr i r"p ro pe r l y relied on those i n s t rutren ts tio pe rw rm e l f ontar" nation conten' nonrral it was noted that ouality a'surance o r o g rari for health physics i ns t rur en t a t i on needed signi#icant i mp n n errn ' ( =,) r'[' l e < ) + [ir i'I Stj t V e i l l dII( e 0 h i(lh-(luit i 1 t V i n s i rurPnia I ioD [*' r f n Na nt e prgqran wa c ?oted at F ru r sWi c k ljnits } g.c ]n ihat a iliIll t i()fid I iheik (1t alI IGriahle iPEIFUFPU #C WdS dOnP ds d ' online n d e d by ONSI Nl[3-}O E' f d f. h no$d l W('r b i nq dd v drd within La hours re n pe+ ore use et portable i ns t rwen t s no+ routi nely used, each instrurent was i turned to tN calibration facility. It was visually inspected, a battery ch<L wa< rade and it wa< response tested at points en each rance using a s-ll' well sou rt e A checklict, used to recnrd data, presided the acceptable e response range Th w ins t rur en t s not rec oondino as recuired were removea from s, > \\ I f t' uPt1l t'r['a i red d elG/ Pr fi'f d l i b f a ted. 16

Radioactive-Waste Management Significant weaknesses in the area of radioactive-waste management were iden-tified at about one-fourth of the facilities. The most significant of these weaknesses included: failure to perform adequate reveiws of modified liquid-waste-processing

systems, failure to provide adequate facilities for storing packaged wastes, failure to meet burial grcund and DOT requirements, and failure to provide adequate maintenance on ventilation exhaust filter systems.

Failure To Perform Adequate Reviews of Modified Liquid-Waste-Processing Systems Several facilities did not perform adequate reviews of modified liquid-waste-processing systems, including the use of nobile process systems, to ensure the new systems provided the same degree of safety as installed systems. In particular, these new system interfaces with existing systems were frequently not tested before actual use. Operational procedures were not provided for these new systems. Failuce To Provide Adequate Facilities for Storing Packaged Wastes Because tewer commercial burial grounds are available and because limitations are being placed on quantities of waste accepted from a facility, the volume of packaged wastes stored onsite has increased. Provisions have generally not been provided for the temporary storage of a great deal of waste, therefore, unforeseen problens have developed. in a number of cases, the increased volume of packaged waste has overcrowded areas and has resulted in an increased potential for unncessary exposures. Failure To Meet Burial Ground and DOT Requirements The increased surveillance perforned on materials arriving at burial grounds has highlighted failures on the part of reactor facilities to ensure that no free-standing liquid exists within packages and that contaminatior, and radia-tion levels are within the 00T limits. Failure To Provide Adequate Maintenance on Ventilation Exhaust Filter Systems Several facilities had not established prograns to routinely inspect, test, and maintain those variou, ventilation exhaust filter systems, not subject to tech-nical specification requirements. Filter systems being operated without adequate surveillance prograns included high-efficiency particulate air (HEPA) filter trains serving radwaste buildings, auxiliary buildings, BWR offgas systems, and chemistry laboratories. On one pressurized-water reactor (PWR), 17

y l -_= fie'd ob ervations of the rporating r e a c. + o r conta nrent building e>haust i r rmqh ing filter s t om revealed + hat the arne ra.iori+y n+ + il ta c had 'eparated frnr their hr:l d i ng trare Ibecauw of o v e r l c, a c' i n a ). m !,ar plus rif Go.d Pad 1 oar +4 ve-Waste Merareren+ 1 w At rany statira p l a ri s hu boen mado t< > cons t ruc t far il i + ies f or t he intorim ~ s+nrage of solidified radwaste. Th. >inna i lant had torstructed a sheltered, f e n r,"i area onsite The area c ont a ' red a conc rete bunk er eauipped with hatch rev-that allowec for below-orado storne The ounkor drained to a sump = wh ic h nould be vmpled and rurped to the plant radinacti ve liquid waste system. No material had been stored in this drea at the time of t he appraisal. M Ar ac tr e nt f ac ilit ies had in<+1+uted programs to roduce the volume of solid radwa 'e genera +rd. Effort' were being rade t o bett er identity ard cegregate = 1renh, and n in ir tile the acounts of materials (like packaqirq l taken inte radiological rnntrolled aree New wasto-solidificatier systenc more m "++m tive oa.partors, and awarenes< + ra ininc about volume reduction were in plarned. The Drescien facility had installed a new waste-solidifi-j [ lat o or ( atinn syn +er in late 1979, with a resultant volure reduc t i r.n savings ranging C fror. hal+ f( a t ourt h. Additionally, an e s t i r'a t ed 7 ' recirtion of acsociated l had rosulted. e,p,suro of radwr to personne r, c,. c f4( Pi! e f r'()(l r'd f -m . )#fE' ( !I f 4 vdD <j rIf ' 'sf'( Il / 9 (k 5 (lW ds t 't 'a O n el V aChiFVable) ['rr n rarls We re d 4 th' fncilities. The nore clgnificant !<h'n!ifif at a pprow illa + el y One-fDurth 0 4 + 1hese we Lr..sses irnlu ed H ( ( t,, i l u r> t i, i n + etirg t,. A[ ARO pri:r:rar s t a t i ct:wi de = m lt h t,t h ()rFa b! bNb b rf,4 r dI" t at i11tir< no tornal id A P A p en g r r rr had boor developed and i rrp l e-f+ a nunhoe i rectation o' M "I n pi i.u i p l( wac rin,r m i the lack c writter coa'itments end 4 c a c onr'o n de',( lonry. Writter corri tFent s and iDple-Imp l t rvr t i n<' p rso eqiu r et wa w fl APA prone, help orsure uni f nrr, continued program ne*1ro prc o rm e' in t ' i' Iin i hf' dfSence of 'orritments dnd proCedUFes) s bst ini's( $ ARO e + ,uppir u i we n noted at plerts that had

• cono, we ll-motivated rdivirV 's in key positions.

= he lo <f +he o kr, T ru11 s i dua ' <, howo.or, could co ml+ in a significant loss <a o<tinfiver,< of the N fJ A e + f o r t s. t 0 { ibilli'e had lP' h i f' l ht'' 't)?r ' n 4

• i I ls # ed, n res Ct

I'f i, t u h i ht ! i ( s been det'pt ch 'm t i s m we re ;i lear, arr ?he rp+hode l +c hP used te i ii i, orderc+- H S onpr 'ailure i.,p ! cm r - the M?

c1'n ini.<

v, ret clo ,iornert t re' en ibil lts te a i r :le ccur withou+ +he 't'w v % ed wa s +h + m 6 i .iim i.

k. 4 emphasis that the entire station must actively implement the principles. Many 4 radiation protection organizations were attempting to perform the principal .' ?. - 4 ALARA functions with minimal input, feedback, and f.upport from other organiza-tional groups within the plant. It was generally noted that non-health physics, ~ first-line supervisors lacked specific commitments and responsibility for ALARA implementation. + Other ALARA Deficiencies At many plants. Y There were no apparent measurable goals set for the ALARA effort; there was no management system developed that would indicate the degree of success of ALARA effort undertaken, that is, if the goal has been ? achieved. e-There was no data base effectively derived from previous operational history nor did the current system (radiation surveys and dosimetry 7 records) lend itself to being readily useful and meaningful for ascertaining the goals and direction of the ALARA effort. ~ There was no engineering support; and appropriate ALARA involvement in maintenance and operations procedure reviews and prework planning were not a. adequate. At some facilities, even though adequate ALARA programs had been formulated, implementation efforts were seriously hampered by a lack of l ' trained health physics professionals and technicians to supervise the ~ program on a continuing basis. Examples of Good ALARA Efforts ^ A basic element in an effective ALARA program is the capability to collect and ) sort radiation exposure data in order to evaluate the status of on going jobs and provide a readily retrievable historical exposure file (by job function) for planning future work. .I i Several plants had developed ef fective, computer-based, exposure-tracking sy3tems as was mentioned in the external exposure control section of this document. Some facilities successfully solicited worker input and practical suggestions for dose reductions through " worker suggestion boxes," "ALARA problem reports," ~ i. and other plantwide participation schemes. The ALARA programs at Browns Ferry and Farley have directly benefited from such input, at the same time fostering employee involvement in the plant's ALARA efforts. ALARA committees offered another effective mechanism for invclving the various departments within the plant's organizations. In accordance with written procedures, the Ginna plant established an ALARA committee which was required to meet (at least quarterly, and more frequently during outages) in order to 19 ^ i'..

plan,ic t i v i t. i e, of pe sonnei who must enter rad ation at eas, evaluate the actions and pr oc edures of personnel working in such areas, and Londuc t postoperation debt ietinq on projects that resulted in s ut) s ta n t i a l exposures the chairman of the committee or the plant superintendent and the other memto r< int!uded representativ, trom health physics management, operations, ma i nt enan( e heaIth physits te %it lan statt, technical engineering, and qua l i t y c ont ro l. Additionall the supe intendent, Nuclear Operations was y, regular member of thi< committee. designated as .i Through e t t m t i ve AL ARA out age planning, the Browns ferry site has managed to provide a net decrease in total exposures over the course of seven outages. Other not ewort hy AI ARA dose r educ t ion schemes included sustained efforts to maintain fuel cladding inteqt ity and thoroughly reviewing maintenance pro-(edure Although improvement < should be made in documenting ALARA efforts, efforts at Indiin Point ? of adding -hielding, decontaminiting, and job-specific training hue provided ob',ervable eeposure reductions. Substantial person rem savings were made during the 19/9 ietuelinq outage for job activities such as steam genera t or,ludge latu inq, refueling operat ions, and reactor coolant pump mtintenante Ihe Now.iunee plant'> Ai ARA at t i v i t ies tor inservice inspections deserve ,pm ia l note A Quali t y Assur ante Auditor and a health physics technician visited each jot ite to e,tablish dose levels and to esaluate shielding ano s equipment requirements, they used this information tur scheduling and improving lub planning to minimize doses. A postmonitoring job evaluation torm is used routinely at Big Rock Point to dutument radiat ion protec t ion review of jobs where direct HP technician ( overage is urovided. This form tequests technicians to suggest methods to reduce e=posure on future similar jobs. Although deticiencies in the imple-mentatinn wer e noted, such toedback is a good AlARA tool ! t iet t ive s imulation training tur radiation workers using realistic equipment mo( Lup can provide for substant;al personnel dose reductions. i~he Ginna plant had est optinnal morkups of steam generators and reactor coolant pumps. The st eam generat m mockup int luded det ect ive tubes for eddy-current testing, and a tube sheet tot tube pluqqing and welding practice Video taping was also used et f m t iveis in the mo( Lup training. several plant ALARA effort-hate been enhanted Lr. the ettective use of audio-sisual t ec hn iques. C losed-c i rc u i t television (CCTV) was used to maintain visual contatt with workers, and aided in " dose-timekeeping" during sparger work in the drywell. CCTV was also used in remote radwaste areas to reduce the number of operator entries and, hence, exposure. Photographs have not only been used to document Al ARA techn igues, but also have been incorporated into t raining progr.im mat erial s and lesson plans for workers. 20

W e t ? + L=.* 4k . ()u ( } f )E (/ v f *! k f r f r)I! a ! fi k '(J l Prairie s 1 a nd 's /U APT p rreirar :ppe: red etrt,ve The plant'< ra di e t i or, duses s a jea r uve r +ho lest 2 ,oors. The natoly 60 pormn-rer < have a vi r a cjed epprr i ~ na'innal PWP a,e r arp wa a pp r(o ima t ol, h pe rs >n ~ rons for th c7s_1ggg '2 s t roru; ra vagenPn t. r<,t ' tre"t tr +he A' A P T E t, r.c e p t, a n ri *N p e r t r ' r' T he re wa' a t + 1 t uce< <>f plant work ers and HP stat' + < < o rd r i t. ir i z 1 nc; exm sua s woro e/rellent Irdividual and i t ;h - s p e c ' ' ' eo nure i n + o rr e t ; < + wat readilv N a v a i ; :!,l e c r ri routiroly uwd in p < n n i n r: + n e vs. r k attivitier 1 (k h k ) e l ( l f h ) ( A' M A p r< na rar "hore ori ip undor va t ti stop a d('re s i ne / ! [. F f. a s a sepa ra t e p r uq r at : r c' > a + he i

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tnphasize ir r r r pr ra! T rc O APA In+r the overa', radiatior p n > t er t i < 'n pt, gram. I r.p i men t a t i c'r an/ opa t +iro facili+' requires that AL /W [. p,io i; : r < te i nr o epm a t en i n +,, crerv dal l, ,o tivit.y a< well a intr special or lift ifiut> )( I l t 11 lt'< Ihn jirl f ( iples Di A'APA arD i nst ied ? ahl P f r'Ur kannd health irt er en + a t ir r % pond crimarily cr the l phnit pratt1<o ad + heir ,u< i es s f u ! ph i 1(m ;4t. / and att4 t uti. n+ rora'pnent a n e* y,,, L e t s, 4 h lh I. PI WfiihT+ (- 1 ri id( li l( a ' (l r (;!i i pl'lo n + Wf'f) ](jeni)$l( r ?t a f)O! j t b l n ]'l I * '{ 1 t th, + 3( il'+1ec TN nt+ c, i g n, t

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\\ The facilities for the decontamination of equipment and anti-c clothing at mos% plants were marginal at best. At many facilities decontamination of equipment, was done at temporary controlled work areas. Although appropriate area restrictions and contamination controls were normally initially instituted by means of plastic sheets and rope barricades, after long use these controls had broken down, presenting increased opportunity for the spread of contamination and for unnecessary exposure. Also these temporary work areas usually had inadequate air-flow control and lacked adequate storage. The amount of contaminated couipment present at many plants exceeded the storage designed for this purpose and consequently led to storage in areas not designed for contaminated equipment. This overflow storage compromised ALARA concepts on numerous occasions. This problem is caused by an apparent philosophy change which appeared since the plants were built. Health physics and engineering seem to concur that less waste is generated and less personnel exposure occurs if the routinely used equipment, which becomes contaminated in use, is just wrapped and stored in that condition pending future use. The logic is valid, but facilities must be provided to safely store this equipment without additional personnel exposure during normal operations. The equipment should also be protected from the elements to preclude spread of contamination. In many plants the linear air-flow velocities at the face of the hoods in which radioactive materials were handled were below recommended values. This lack of' concern for proper ventilatioc was evident as well in the decontamination work areas and in the waste compaction area. Limited Supplies of Special Equipment 1 i Shortages in supplies of special equipment were also noted. Types of special i equipment in short supply were typically portable ventilation units equipped with high-efficiency filters,

mmunication devices for use in contamination containment structures, and temporary shielding materials which are readily transportable and adaptable to various configurations.

Good Facilities and Equipment i ~ From discussions with licensee personnel at many facilities NRC staff learned that plans are being made or are under way to improve the health physics faci-lities. In some plants major modifications were in prooress. These included new or remodeled changing areas and rooms, decontamination facilities, and respiratory maintenance facilities. In addition to facility changes, funds for purchasing needed equipment were becoming available. CONCLUSIONS The redirected approach of the Health Physics _ Appraisal program provided the opportunity to focus attention on areas not specifically covered by regulations and permitted inspectors to delve into the areas where weaknesses were known or suspected to exist. In general, the health physics personnel at the facilities welcomed the type of appraisals performed during this program because it constituted an evaluation of their total program and frequently the findings 22

supported concerns and requests the facility health physicists had already identified to upper management. Based on the findings from the health physics appraisal of 48 operating nuclear _ power sites, several conclusions may be drawn. All of the radiation protection programs were judged to be at least acceptable for continued operations while significant findings were being corrected. Although there were no instances identified where the immediate health and safety of workers or the public were threatened, few of the programs were considred to meet the high standards of excellence expected of nuclear power f acilities. There was particular concern that the introduction of great stress on the program, such as would be the case in the event of an accident, could lead to a real decrease in the level of protection afforded. in some instances, lesser events such as loss of key pesonnel could also result in a seriously degraded capability to provide adequate radiological protection. The single greatest cause for weaknesses in the radiation protection programs can probably be traced back to the general attitude toward radiological safety. Management often considered the radiation protection group more of a routine service organization than a radiation support function integrated into the fabric of overall plant operations. Conse-quently, funding, staffing, and management backing was frequently provided at the minimum level. Also, foremen and supervisors in other departments tended to have an attitude that the burden for assuring radiological safety rested almost entirely on the radiation protection group rather than understanding that such responsibility was properly that of all line management. Their failure to demonstrate a continuing concern for proper radiological work practices results in the workers adopting a similar attitude. The weakness most frequently observed at facilities was the inadequate e.ualification and training provided for radiation protection technicians. Within this area, the lack of depth of technical training and understand-irg was most common, along with a lack of knowledge and understanding of plant systems and operations. This weakness in qualification and training was particularly evident among contractor technicians. There was general concern that some routine monitoring duties were not being performed and a serious concern that of tnormal and unusual conditions were not being recognized and evaluated thoroughly at some facilities. Although the list of specific weaknesses identified during the appraisal program included many that could jeopardize the adequacy of the radiation protection programs, it must be borne in mind that the acceptable per-formance standards were very stringent. The findings that areas were in need of ' improvement reflected concerns that programs and performance were not up to the standards of excellence expected and required of the nuclear industry. It must also be emphasized that.many aspects of the radiation protection programs were excellent and a large number of knowledgeable anc dedicated health physics personnel were performing their functions in an outstanding manner. Additionally, most licensees initiated immediate corrective actions for weaknesses easily corrected and committed to posi-tive actions for correcting weaknesses that required longer term actions. 23

i i i SUGGESTED' ACTIONS FOR IMPROVING A HEALTH PHYSICS PROGRAM Most of the weaknesses and deficiencies found during the HPAP involved aspects l of'the program that required management attention for correction. However, i there are a number of actions the individual health physicist can take and l policies he or she can actively support that could have a major impact on improving the most commonly identified areas of weakness in the radiation protection programs. Some suggested actions are discussed below. l l Plant personnel should not be satisfied with a program that merely meets the f formal regulatory requirements. Just meeting the regulatory requirements does not ensure that a program will be effective and efficient. The question to ask i is, does the program provide a satisfactory level of protection and does it work when applied to real situation? One precaution, avoid overemphasis on I paperwork and administrative details. A program that overemphasizes minute details tends to lose the respect of workers and consequently their coopera tion. Additional time spent on explaining the bases and reasons for certain requirements often reaps generous payoffs in the attitude and cooperation of workers. Don't forget, this is just as true for personnel outside the radiation protection department. When something goes wrong and a problem surfaces, be sure to search for the cause. It is remiss to just address the immediate act or event which may only be the visible sign of a more serious problem. A problem should not be dis-regarded as an inevitable slip or monentary loss of concentration on the part of a wnrker. For example, the problem may be a failure to follow radiation protection procedures. This deficiency could be caused by an inadequate training program, failure of the organization to stress adherence to pro-cedures, or an unclear or poorly worded procedure. However, the inquiry and evaluation of what caused the problem should not stop there. The next line of inquiry should be to question why an adequate training program is not provided, why compliance with procedures is not stressed, or what caused the procedures to be written in an unclear manner. The goal should be to determine the basic cause of the problem and to correct the cause of the problem, not just to alleviate the more obvious signs, i Take the time and effort to ensure that radiation protection personnel are assigned specific duties for routine operations and during emergency situa-tions. Furthermore, ensure that each individual knows his or her assignment and understands what is expected. Often the station procedures or Radiation Protection Plan will designate duties or functions to a generic class of i I personnel, for example, radiation protection technician. When this is the l-case, a procedure or formal assignment list should link names with the assigned-duties. Assignment of duties to the Radiation Protection Manager presents another problem,'one further aggravated by the requirements in the NRC.'s . Regulatory Guide 8.8. Everyone appears to want the RPM to be both a program manager and the technical expert;-however, adequate staff or support is rot provided to the RPM so that all the assigned responsibilities can be accomp-lished. In the area of training, it is important for the professional.HP staff to development a depth of knowledge and understanding of radiological protection principles and practices. This depth of knowledge is needed to perform . functions effectively, such as conducting performance appraisals and responding 24

to emergency situations. For the technician staff, training should include not only the technical and administrative aspects but also the application of the I l knowledge. Written and oral testing should be supplemented with hands-on ! performance. Although on-the-job training provides for necessary hands-on applications, it generally lacks the stress or pressure which is brought to bear by a test performance. Since most emergency situations would impose l increased levels of stress, preconditioning personnel to this situation is i often beneficial. One of the most frequent omissions in audit programs is performance audits. Most programs include functional audits which determine whether selected activities are performed and whether they are performed at the proper frequency. Performance audits are more difficult to conduct and consequently, are of ten lef t out of the audit program. These audits are crucial, however, because they determine whether the activities being performed are done properly and are technically correct. When conducting any type of audit, records and paperwork generally must be reviewed. One tipoff to a potential problem is the recurring use of a value which should normally be a variable groundcount. For example, the consistent use of the same value for a backgrcund count should alert the auditor that further investigation is needed. Likewise, the inclusion of the same radiation levels on rumerous radiation work permits even though they are for work in different areas of the plant should raise doubts in an auditor's mind as to the validity of the values. However, the auditor should not rely entirely on a paperwork review for conducting an audit. First-hand observation, independent measurements, and direct discussions with the people actually per-forming the activities are essential elements of a good audit program. The last suggestion deals with the very critical element of communication. Effective corraunication is an absolute necessity for an efficient and effective organization. This need exists not only within the department but also outside the department. Too often the communications and relaying of pertinent information between the reactor operations group and the radiation protection group are less than satisfactory. Even within the radiation protection group, orders or instructions are often given to technicians without any explanation of the reasons or bases for the direction. Another common mistake made by many of tha younger professicnals is to treat the technicians as lowly subordinates. This attitude can be very costly for the young professional and can be ' disastrous to the program. Cooperation is built on trust and respect; it does not come automatically with academic degrees and positions. DFNEFITS M:D FUTURE DIRECTION OF PFCULATORY PROGRAMS There have been several benefits from the Health Physics Appraisal Program. First, the radiation protection programs at all operating nuclear power facilities have been evaluated for their effectiveness in providing radio-legical safety. The weaknesses that were found have been identified to licensees and, in most cases, licensees respended with a very positive attitude and initiated aggressive actions to correct the deficiencies. Additional benefit from the program was the attention received from upper managment in the licenses' organizations. In the past, health physics inspection were perforned by one or two inspectors and their scope of review was necessarily limited to only a few parts of the total radiation protection 25

program'during each site visit. However, the Health Physics Appraisal Program involved a team of inspectors and their scope of review was the entire radiation protection program. This coupled with the new approach of extending the review beyond mere compliance created more attention from upper management. For example, findings from routine health physics inspections are discussed at an exit meeting with station management. For the Health Physics Appraisal Program exit meetings, a specific request was made that an appropriate corporate-level manager or vice president attend. In almost all cases, these ~ . representatives of upper management did attend the meetings. This provided the - opportunity to bring radiation protection problems to the immediate attention of upper management who are in a position to ensure that furding and support will be provided to upgrade the radiation protection programs. There are a number of followup actions under way to wind up the Health Physics Appraisal Program and to determine the future direction of the inspection program. One task was to conduct followup inspections to_ ensure that the major findings were being addressed and corrected by licensees. This effort was initiated after the inspections were completed, and most were completed by the end of calendar year 1981. The future direction of the inspection program has been affected by both the TMI accident and the Health Physics Appraisal Program. One proposal-which is currently being pursued is the imposition of a requirement on all power reactor licensees to develop and implement a radiation protection plan. Draft NUREG-076 -has been developed by the NRC to provide guidance for the development of radi-ation protection plans. The findings from the Health Physics Appraisal Program were considered in the development of this guidance document and many suggestion were incorporated which would correct deficiencies or upgrade areas of weakness that were identified. Current thoughts within the Office of Inspection and Enforcement are that the nature and structure of the inspection program will change significantly over the next year or so. There will probably be an increased use of team inspec-tions rather than one-man inspections. It is highly probable that the frequency of inspections and the scope of inspections will be adjusted on a case-by-case basis. Those facilities which do not appear to be operating effectively will be candidates for more frequent and broader scoped inspections. And finally, the areas of emphasis for inspections may be varied from year to year as opposed to the past practice of establishing set frequencies and standardized subject material for routine inspections. L } 4 26

J REFERENCES l r NUREG-0041 U.S. Nuclear Regulatory Comission, " Manual of Respiratory Protection Against Airborne Radioactive Materials," September 1976 :

NUREG-0600 U.S. Nuclear Regulatory Comission, " Investigation Into the' March 28, 1979 Three Mile Island Accident by Office of Inspection and Enforcement," Investigative Report No.

4 50-320/79-10, July 1979 NUREG-0761 U.S. Nuclear Regulatory Comission, " Radiation Protection 4. Plans for Nuclear Power Reactor Licensees," Draft Report 4 _for Coment, March 1981 _ REGULATORY U.S. Nuclear Regulatory Commission, "Information Relevant

GUIDE 8.8 to Ensuring That Occupational Radiation ~ Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable" REGULATORY U.S. Nuclear Regulatory Comission, " Acceptable Program for

_ GUIDE 8.15 Respiratory Protection" l f U 1 a 27

l l l l } APPENDIX A HEALTH PHYSICS APPRAISAL PROGRAM

t l l l l CONTENTS OF APPENDIX A Page l-l I. INTRODUCTION................................................... A-5 II. PROGRAM DESCRIPTION AND USE.................................... A-7 t General........................................................ A-7 Emergency Operations........................................... A-7 Hanagement 0versight........................................... A-8 . III. ANALYTICAL TREES............................................... A-9 Adequate and _Ef fective Radiation Protection Program............ A-10 Radiation Protection Organization.............................. A-11 ' Personnel Selection, Qualification, and Training............... A-12 Exposure Control............................................... A-13 External Exposure Contro1...................................... A-14 Internal Exposure Contro1...................................... A-15 - Res pi ra tory Pro tec t i on Prog ram................................. A-16 Surveillance Program........................................... A-17 Radioactive-Waste Management................................... A-18 ALARA Program.................................................. A-19 Facilities and Equipment....................................... A-20 Management 0versight........................................... A-21 Procedure Development.......................................... A-22 I IV. QUESTIONS...................................................... A-23 1.0 Radiation Protection Organization......................... A-23~ 2.0 Personnel Selection, Qualification, and Training.......... A-25 3.0 Exposure Contro1.......................................... A-28 3.1 External Exposure Control................................. A-28 3.2 I nternal Exposu re Control s................................ A-31 3.~ 3 Su rve i l l ance P rogran...................................... A-41 4.0 Radioactive-Waste Management System....................... A-46 5.0 ALARA Program............................................. A 6.0 Health Physics Facilities and Equipment................... A-51 7.0 Management 0versight...................................... A-54 8.01 General' Procedures' Development............................ AL58 -ATTACHMENT..................................................... A-61 i 4 A -

I. INTRODUCTION .The program contained in this document, developed to satisfy the need for a clearly defined method of appraising licensee performance in the health physics program, will be subjected to further scrutiny and subsequent improvement. A-5

.II. PROGRAM DESCRIPTION AND USE G neral This program consists of analytic trees (Section III), questions applicable . to each tree'(Section IV), and an Attachment. The analytic trees provide a graphical depiction that aids.in the deductive analysis of a system. The questions are designed as guidance to the appraiser for direction into areas-pertinent to a comprehensive evaluation of the various aspects of a health physics program. The Attachment to this Appendix (pp. A-61 to A-70) provides . a discussion of the functions of management and the manager and is provided as background information for the appraisers. i Although this methodology, i.e., analytic trees, is to be utilized by all teams', the team leaders are permitted a certain latitude in application. Whether the analytic trees are presented and discussed with the licensee is , optional. Also, the questions are not an all-inclusive listing of significant items. They are intended as an aid in providing an overview of the areas of ~ interest and as directive. guidance in conducting the appraisal. The analytic trees provide both a clear picture of the basic elements of a 1 system or program and a logic display of interrelationships. The trees start with a single desirable condition and systematically proceed through lower levels or tiers _until all important factors which produce the major conditions are,specified. The trees presented in this document provide a description of-the ideal elements of.a radiation protection program. Their use can help in the prevention or detection and corr.ection of oversights and omissions. Each of-the trees has some degree of interface with the others. Important interfaces are highlighted by transfer functions (triangles with arrows and a letter or number). Two of the trees (Management Oversight (p. A-21) and General Procedures Development (p. A-22) interface with each of the remaining trees. The questions accompanying each tree (7.0, Management Oversight and 8.0, General Procedures Development, pp. A-53 and A-57, respectively) are carefully structured to avoid duplicative effort in the interface areas. The interfaces between areas are important in the evaluation process. To properly. evaluate areas where transfers are noted, data collected from one area must be " transferred"~to another and considered in the evaluation of both areas. '.The end result is that, in a systematic way, we~can assess the true impact'of a particular event, and provide greater assurance that a given area is,'in fact adequate or inadequate. Emergency Operations The basic program incorporates only those aspects,of emergency response.capa-bilities that relate directly to the health physics program. If it is necessary or desirable to perform an in-depth review of all major aspects of a. A-7

licensee's emergency planning program, the trees and questions contained in " Emergency Operations," a subpart of the program provided for optional use by the NRC Regions, should be used. When that program is used, the questions in the basic program which are denoted with an asterisk (*) should be omitted since they are covered in the " Emergency Operations" package. (NOTE: The " Emergency Operations " subprogram was omitted for purposes of this NUREG, since it provided' inspection guidance developed prior to recent rulemaking in emergency preparedness.) Management Oversight In. reviewing the adequacy' of any of the elements of the health physics program, an informed evaluation of management's oversight is critical. Frequently the cause of problems in a program is attributed to a " lack of management control.". This view fails to recognize the control is only one of several management functions.which, if performed ineffectively, can result in program deficiencies. It also fails to recognize-that an individual manager or worker may be the causal agent. Therefore, to fully evaluate a program, the degree to which'the management team, the individual managers, and individual workers fulfill their functions must be considered. The attachment, " Functions of Management and the Manager" (pp.-A-61 to A-70), is provided as information and guidance. e 1 3 'l 4 A-8

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.-= i IV. QUESTIONS L0 RADIATION PROTECTION ORGANIZATION 1 1.1 Description a. Is there an organizat'ional chart depicting the site and corporate radiation protection organization? b. Does the chart clearly show that the Radiation Protection Manager (RPM) had a direct reporting chain to the Plant Manager?

• c.

Are the persons who may be assigned to.the following functional i areas of emergency activity specified by position or title: radiological environmental survey and monitoring, personnel monitoring, 4 recordkeeping and retention, radiation protection, and, plant chemistry. i

• d.

Are there corporate personnel specified who will augment the plant emergency staff in the following areas? I environs monitoring, 1 logistics support (e.g., equipment and supplies procurement),

• c.

Are there contractor and private organizations who may be requested to provide technical assistance to and augmentation of the emergency organization specified? 1.2 Scope of Responsiblities a.. Are the responsibilities assigned to the radiation protection- ~ organization-described? b. Are there collateral or supplementary responsibilities performed by the radiation protection organization that are not reflected in the formal assignment of responsibilities? c.. Is' there a clear assignment of. authorities and responsibility within the radiation protection organization? A-23

d. Does the radiation protection organization have adequate authority to ensure that the radiation protection program is implemented (e.g., enforce adherence to procedures, stop work, etc.)? e. Is there documentation of actual responsibilities, authorities and reporting chains in the job descriptions of radiation pro-tection personnel? f. Are job descriptions (e.g., responsibilities, authorities and reporting chains) understood by the individuals to whom they apply and by other personnel in the site organization (e.g., operations and maintenance)?

• g.

Are there any other individuals in the radiation protection organization assigned responsibilities for maintaining an emergency response capability? If so, what are the responsi-bilities?

• h.

Do the individuals in the radiation protection organization charged with responsibilities for maintaining emergency prepared-ness have adequate authority to ensure program implementation?

• i.

Are the emergency authorities and responsibilities of key i individuals in the radiation protection organization delineated?

• j.

Are the interfaces between and among the onsite funcitonal areas of emergency activity clearly understood?

• k.

Are there provisions for continuous (24-hour) operations for an indefinite period (e.g., are there provisions for manpower plan-ning to permit such continuous operation with the individual in the emergency organization who will be responsible for imple-menting the manpower planning considerations specified)? 1.3 Staffing a. Is there adequate staffing (numbers) of managers and supervisors for at-power operation and outages? b. Is there adequate staffing cf managers and supervisors (per site /per unit) for day and backshift operations? t c. Is there overall staffing level of radiation protection tech-nicians adequate to perform assigned responsibilities with the workload existing during normal and outage conditions? d. _Does staffing level provide for adequate numbers of specialists-for such jobs as' dosimetry, respiratory protection, ALARA review, etc.)? Is there adequate administrative support to relieve technical e. i personnel from clerical duties? A-24

f. Is there sufficient technical support at the corporate level?

• g.

Are adequate radiation protection resources (e.g., time, man-power, and money) devoted to the emergency preparedness program?

• h.

Does the licensee have plar.s for supplementing the HP staff beyond 24 hours under accident conditions?

• i.

Are the interfaces between the onsite funcitonal areas of emergency activities and the augmentation groups clearly understood by both parties? 2.0 PERSONNEL SELECTION, OUALIFICATION, AND TRAINING 'T 2.1 Selection Criteria a. Are there formal selection criteria for all positions in the radiation protection organization (permanent personnel; technical and management /centractor staff)? b. Do the criteria relate to the job (job description) which the individual is expected to perform? c. Do the criteria include measurable formal education and experience factors? d. Are the criteria actually used in the contracting, hiring, and promotion process? e. Are personnel aware of the selection criteria, methods, and requirements for promotion? 2.2 Qualification Criteria a. Are there qualification requirements for each position in the radiation protection organization? b. Are there qualification requirements for persons not in the licensee's radiation protection organization, but who may provide contract support to it or who may require access to the site (e.g., general employees and radiation workers) to perform non-radiation-protection jobs? c. Do individuals in the radiation protection program (licensee and contractor) meet qualification requirements? 2.3 Training Program a. Are the qualification criteria used as a basis for the develop-ment of the qualification training program? A-25 j

b. Do the training and retraining programs include: I frequency? scope / content? student performance objective (qualification requirements)? schedules and lesson plans? student demonstration of attainment of standards? I record maintenance? l qualification of instructors? i c. Are appropriate personnel required to undertake training / 1 qualification, such as: managers? 1 supervisors? i 1 HP/cher techs (contractor and licensee)? i radiation workers? general employees? ) 4 technical support? i self-monitoring personnel? radwaste operators? d. Is the scope _of the training provided to each category adequate-in content, nature, and length? -i e. Does the training include an appropriate level of knowledge of plant systems? f. Are adequate instructions provided on procedures including reasons and bases for the procedures? 9 Is instruction provided on the capabilities and limitations of-instrumentation (fixed and portable) (e.g., duct monitors and field gradients)? h._ Is training provided for special or unique activities (e.g... special maintenance)? A-26

1. Does;the training program encompass the minimum following cor. Cent: 1 general duties? responsibilities vs. job? i reporting / communication chain? authorities, site, local and regional? theory and practicum? f site specific or job specific? 4 job-related systems? related industrial and rad safety? i specific related procedures? i .special protection (i.e., respiratory, anti-c)? i ALARA? j. Are the operators of the various counting and analysis systems properly and adequately trained in their use, and qualified to 1 operate them? k. Is there an adequate operator training and qualification course for radioactive waste facility operators? 1. .Is formal on-the-job training available at appropriate intervals i for all individuals? f Is there a retraining, requalification, and training up to the m. L state of the art for on-board personnel in new instrumentation and its full' range of capabilities?- n. _ Are special surveys, unusual conditions, uncomonly encountered [ radiations, and non-routine survey locations adequately covered in training? i o. Is there a retraining ~ program for all, aspects of the use of fixed and semi-fixed instrumentation? i

• p.

Does the licensee have a documented emergency' plan training ( program?

• q.

Does the training include information on what might be expected under unusual plant conditions.(e.g., components and areas with high radiation levels, magnitudes of radiation increases, changed nuclide composition, etc.)? .A >

L

• r.

Is there adequate training of personnel in surveillance under accident conditions, including use of equipment, interpretation of.results, personnel access control, and special precautions?

• s.

Are initial training and periodic retraining programs provided to each of the following categories of emergency personnel? personnel responsible for radiological assessment, i radiological environmental survey and monitoring teams, radiation protection, chemistry (contamination and exposure control for " hot" ~ samples),- repair / corrective action teams.

• t.

Does training of the onsite emergency organization include practical exercises and/or tests in which each individual demonstrates his ability to perform his assigned emergency function (e.g., meet the student performance objective set forth in the lesson plan), and where.on-the-spot correction of erroneous performance is made through additional training and a demonstration of the proper performance by the instructor? i

• u.

Are there provisions to evaluate the ability of the individual to perform his emergency duties, including a description of the conditions, tasks, and standards of performance that will apply in making this evaluation? 4 l

• v.

Are there approved, formal lesson plans for each category of training as a supplement to the procedure?

• w.

Are the individual (s) who will be responsible'for conducting each category of emergency training specified by position or title?

• x.

Are the instructors qualified? j

• y.

Are there provisions to train members of the. emergency organi-l zation in changes to procedures and equipment which occur in the period between the scheduled training sessions? l l 3.0 EXPOSURE CONTROL I l-3.1 External Exposure Control 3.1.1 Dosimetry Program a. Is there an external radiation dosimetry system suitable for the radiation exposure types and levels L A-28

i I l l anticipated during routine or non-routine work operations? b. Are there adequate facilities for reading, precessing, storing, and calibrating all types of dosineters in use? c. Do the personnel available to perform the required dosimetry function have adequate knowledge to perform the normal duties as well as recognize unusual events that may require special interpretations or evaluations? d. Are adequate equipment and facilities available to perform non-routine dosimetry and exposure control functions? e. Are there suitable devices or exposure models and data base to reasure or calculate extremity exposures? f. Is there capability to determine skin exposure by measurement or modeling? g. Are there suitable techniques to measure neutron exposures? h. Are there suitable techniques to measure photon energies of creater than 3 tiev and less than 80 kev? i. Is there a system as backup or are there alternate offsite facilities if needed? j. Are devices of acceptable quality and sensitivity available for short-duration usage by personnel or visitors to areas requiring dosimetry? k. Is there a dedicated exposure records clerk? 1. Are exposure records kept up to date? m. Is information dissemination timely and accurate? n. Is there a dedicated exposure records system? 3.1.2 Exposure Review a. Are reviews of exposure data performed routinely by management? b. Are exposure trends plotted and reviewed for feedback in exposure control? c. Are exposure discrepancies reviewed by management (i.e., pocket chamber versus film badge or TLD)? A-29

4 d. Are exposure rates and integrated exposures evaluated against 10 CFR 20 and ALARA as a routine review? ) 3.1.3 Exposure Limitations 3.1.3.1 Administrative t a. Are there procedures which clearly establish and convey required actions and action a levels? (e.g., administrative exposure limits)? b. Do procedures clearly reflect the existing regulations and recognize the ALARA concept? i c. Are procedures written and disseminated for use and application by appropriate personnel regarding posting of various hazardous or-4 potentially hazardous areas in accordance 4 with 10 CFR 20? i 4 d. When access controls are employed,.are they adequate to prevent unnecessary exposure, inadvertent contamination, or unauthorized entry? e. Is there a surveillance program to demon- [ strate that the external exposure control J program is effective? f. Is there an effective program employing con-1 trol / action levels?. 4 j g. Are well-defined procedures followed to ensure that all personnel are logged out, nonitored, and equipment and tool inventories complete before leaving a worksite? h. Are areas accurately identified, posted..and controlled? 3.1.3.2 Physical a. For alarmed access areas, are periodic tests performed for assurance of operation and - function? -b. Are remote-operating and remote-handling devices available and maintained? r c. Are physical barriers for exposure control reviewed ~ on a regular basis? p i =A-30

. ~.- - t 3.1.4 Quality Assurance a. Is an active quality assurance element present? b. Is it managed and reviewed at an appropriate frequency and level? c. Is onsite calibration of instruments, devices, and processes a-part of or reviewed by the person charged with quality assurance? d. Are calibration functions performed.offsite reviewed 1 by QA? e. Is quality assurance extended to the review of procedures? f. Are quality assurance reviews extended into work 1, recently performed? g. Are there suitable feedback' procedures to suitable levels of nanagement? 3.E Internal Exposure Controls 3. 2.1 - Dosimetry program a. Are there sufficient types of biosurveillance tech-niques and counting facilities to make a reasonable assessment of internal bioburdens of radionuclides? j b. Are models or calibration capabilities availablesto ensure accuracy and reproducibility of measured findings? . hat biosurveillance capabilities are on site? W c. i Off site? whole-body counting? thyroid counting? urinalysis? I fecal-analysis? blood activity? others?

d.

'What radiation types are detectable by each system?- e. ~Are sensitivities adequate to assess maximum permissible concentrations (MPCs)? l A-31 I e ~ v e ,~ 4 ..n- ,m,--... .~ e-me-

f. Does equipment have adequate energy or radiation-type discrimination capability? g. Are procedures adequate to reduce or control against cross-contamination of samples or of counting facilities? h. Are dose estinations or dose factor calculations maintained as a matter of record? i. Are records maintained up to date end with suitable cross-reference? 3.2.2 Exposure Review i a. Are radiation exposure dose limits for rautine.and ] non-routine events maintained ALARA? b. Are survey and internal exposure data on an individual adequately compared? c. Are incidents of personnel contamination documented and followed up with a causal evaluation? d. Are the records reviewed for possible exposure investigation? e. Are the investigation records complete and maintained? 3.2.3 Exposure Limitations 3.2.3.1 Administrative a. Are uptake limits considered in the estab-lishment of administrative and physical barrier controls? b. Are nethods and calculations for results using uptake limits documented? c. Are procedures well defined for determining need for protective clothing and equipment? d. When need for respiratory protection _ is indicated, what procedures ensure that only qualified personnel employ respiratory equipment? e. Are-procedures well defined to control or-prevent cross-contamination of both facilities and personnel? .A-32

f. Do adequate procedures exist to establish authorized personnel in a controlled area? g. Are procedures defined for posting areas where controlled access, airborne, or other contamination are known to exist? h. Do the procedures clearly specify the need for exposure review relative to the specifi-cation of dosinetry and/or barriers? 1. Are suitable and proper measures taken to-minimize leakage, control local releases, and cican up contaminated areas in the con-trolled area? ? j. Are tests of engineering controls conducted at reasonable intervals and documented?

• k.

Are there adequate plans for expanding the respiratory protection program in the event of an accident (e.g., expanded supply of i respirators, provisions for expanded decon facilities, provisions for promptly refilling air bottles)? j 3.2.3.2 Physical 3.2.3.2.1 Protective Clothing and Equipment A. Respiratory Protection Program 1. Program Establishment i a. Policy Statement is there a written policy statement on respiratory usage issued i from a high management level (beyond station-i management)? Does the policy discuss the program objectives? Dces the policy discuss the application of engi-neering controls (i.e., containment, ventilation)? Are topics such as routine, non-routine, l emergency situations A-33

addressed? Are work periods discussed? b. Responsible Person Assigned is the responsibility for the program assigned to a respon-sible individual? Does that person have the ability, training, and experience to do t the following? i Evaluate total hazard? i Recommend engi-neering controls? Specify appro-priate respiratory j protection? 4 Forbid use of equipment when conditions warrant? c. Procedures and Standards Are written procedures prepared for descrip-3 j tions of equipment; issuance, maintenance, selection,'use, return i of equipment; and train-i ing and qualification of personnel? Are air-sampling and bioassay procedures included or referenced? i ~ d. Evaluation of Program Effectiveness Are sufficient records maintained to evaluate program effectiveness? IS there a system to feed back_information on program effectiveness?- A-34

.=. _..- i Are attributes such as comfort, visibility, I ability to communicate, ability to perform j tasks, confidence, and l wearer acceptance l evaluated? l Is there an adequate method to correlate i air-sampling results and bioassay results? Are positive indications of exposure while wearing equipment immediately investigated? e. Selection of Approved or Accepted Equipment 3 Is only NIOSH-approved equipment used? Is the filter equipment certified for protection against radionuclides, radon daughters? Are there provisions for using only the particular types of equipment specified by the certification (such as hose types, j fittings, regulator types,etc.)? Is there a provision against the use of sorbent cartridges or canisters for protection against radio-i active gases or vapors? f. Wearer Requirements and l Limitations Are visual and com-- munication problems. effectively handled? Are breathing resistance and air supply adequate?- A-35

Are there provisions to ensure proper fit of the equipment? I Are there provisions to prohibit facial hair that may interfere with the seal; for facial abnormalities? Are there provisions for routine medical evaluation of all potential users of the equipment to include a medical approval form? Are the medical provi-sions implemented by a certified medical 4 practitioner? Is there adequate guidance given to the medical practitioner sufficient to adequately evaluate wearer's ability l to use the equipment? 1 2. Hazards Evaluations a. Are there provisions to ensure i that oxygen-deficient condi-l tions are recogn.ized and effectively controlled? b. Are there provisions for recognizing and effectively controlling toxic and nuisance atmospheres? c. Are there provisions that relate the MPC to the mode of exposure (i.e.,.sub-mersion dose due_to. argon, krypton, xenon, and tritium)? .d. Are there provisions to ensure.that the air concen-tration does not exceed the multiple of the protection factors afforded by the t equipment? l. A-36 I

i ),

• e.

During emergency conditions, is there a capability for fillino self-contained l breathing devices, and would this equipment be usable under conditions in which the internal areas of the plant have high airborne / direct levels of radiation? I 3. Engineering Controls l' j a. ' Designated Ventilation System Are air flows from low to high airborne radio-activity areas? Are hood face velocities {i adequate? Are temporary ventila-tion systens used wherc practicable? i b. Containments Are containment systems ] (gloveboxes, hoods, tents, etc.) used where practicable? c. Alarn Systems Are alarm systems employed at 1-strategic locations? 4. Training and Qualifications a. Cualification of Training Personnel Do instructors have training .c 'and experience in the appli-cation of respiratory pro-tection devices? b. C'ontents of the Training Program - Are there provisions in the training program fcr instructing both the worker and his _ supervisor? i A-37l

Is there a retraining provision? g Are the following elements covered? airborne contaminants? construction, operation and limitation of the device? engineering con-trols; why respirators are used? procedures? fitting? e use and maintenance? ^ applicaticns of car-tridgesatldcanisters? emergency actions in the event of malfunction?\\ radiation and con-tamination hazards? classroom and field training? special. training as needed? r use during energencies? c. Drills Are there provisions for simu, lated use of equipment? d. Respiratory Equipment Fitting Are there qualitative .and quantitative testing requirements? A-38

Are simulated work cond-itions used during the fit test? Are the instruments adequate? Do operating personnel have adequate profi-ciency with the test equipment? e. Wearer Qualification is there a system that piertifies that the wearer is trained, experienced, and qualified on the equipment he uses? 5. Maintenance Program a. Inspection, Testing and Pepair Is there a periodic equipment testing and inspection pro-gram implenented? Are records kept? Are air and oxygen cylinders inspected menthly to ascer-

== tain charges? Is equipment (regulators, 2: warning devices, etc.) tested periodically? -2 Is repair accomplished by qualified, trained personnel? Are replacement parts certi-fied for the equipment repaired? Are there provisions for verifying that new equipment is acceptable? MM A-39 = um i

3. i b. Storage Is equipment stored so as to-prevent damage by adjacent equipment? Are there provisions to con-sider heat, cold, sunlight, moisture, etc. in the storage of equipment? c. Inventory and Control Is there an inventory system in effect to account for the stock level of all equipnent? d. Issuance of Respirators Are there procedures developed an6 implemented for issuance and' return of equipment? e. Contamination Survey / Decontamination Are there provisions for surveyinc equipment prior to cleaning and disinfecting?. Are there radiological lin'its' established for reuse of equipment? Are there provisions for decontamination of equipment? f. Cleaning and Disinfection Are accepted cleaning = procedures used?' Is adequate care.taken not to damage equipment? 1 g. Maintenance of Air or Oxygen. Supplies Are adequate procedures-provided? F r -A-40

_. - ~ l . Are fittings and com-ponents standardized to prevent inadvertent introduction of other gases? Are compressed gas cylinders labeled. Are specially. designed breathing air con-pressors used? Are compressors adequately monitored for CO, oil vapors, and other contaminants?' Is air quality routinely determined to-be at least Grade D or better?. 6. Quality Assurance ) a. Are there Ouality Assurance Procedures for qualifying results of internal dosimetry assessments? b. Are the calibration frequen-cies and QA reviews appro-priate for the usage factor l 'of each dosimetry system or dose assessment technique? l l-3.3 Surveillance Program i 3.3.1 Scope 3.3.1.1 Procedures and Basis a. Is there a clear' definition and basis of the sur- -veillance activities? l b. Are procedures for performing routine and i periodic surveys and surveillance well defined?- l c. .Do the procedures for performance adequately l reflect instrument selection and approved usage i. by back. shift monitors? f-l I N 'A, a n ~ w

d. Do procedures exist for keeping the HP responsible' for an RWP informed of plant conditions and change. that might impact'on the RWP work scope? e. If self-monitorinipractices are used, are procedures adequate? 3.3.1.2 Responsibility a. Are there any special surveillance or unusually complex surveillance tasks performed by an offsite team or consultant? If so, are they well . described and defined? i- = b. Are surveillance routines reviewed with regard to both necessity and frequency consistent with good health physics practices and regulatory i-requirements? a. c. Are routine and periodic surveillance data reviewed by the health physics staff.and/or RPM for overview or possible additional' actions? 3.3.1.3 Types a. Does the surveillance progran include provisions for radiation, airborne, and contamination surveys? b. Are the various types consistent with the hazards and work ~cendition as specified in the procedures and progran basis? c. Are all materials / tools monitored out of a work area and tagged as appropriate? d. Is there a routine comprehersive air-sampling progran implemented? ~ ~ e. Are air samples (particulate and gases) representative of workers' breathing zone? f. Are air-sempling data related to actual radiation . exposure and to bioassay result? 3.3.1.4 Records a. .Are surveys and surveillance activities documented?

b.

Are documented surveys clearly written and is trace- '- ability suitably' indicated as to instrument, person performing measurement, locations, date, time, and. other' pertinent conditions? A-42

c. Do radiation work permits correctly reflect job and work conditions (e.g., Are surveys, routine or special, adequate for the RWPs)? d. Is there timely and adequate feedback of analytical results to user groups?

• e.

Are arrangements adequate to ensure exchange of HP and operational data during emergencies? 3.3.2 Instrument Suitability and Use a. Is there an adequate complement of instrumentation for the performance of the HP surveillance program to minimum standards required by the regulations and license specifications? b. Are. portable instruments of sufficient number, type, range, and. sensitivity for the scope of routine and non-routine HP activities? c. Are instrumentation, supplies, forms, and support equipment adequate for the progran size and requirements? d. Are calibrations up to date and supplies replenished to complement or renove out-of-date material? e. Is various san.pling equipment of sufficient number, sampling range, type (grab air, breathing zone) for the scope of routine and non-routine HP activities? f. Have operational checks been developed and adopted for field use? g. Is there an adequate complement of semi-fixed and fixed (dedicated) instrumentation? h. Are thorough HP reviews of need and evaluation for l best location performed before installing semi-fixed l instrumentation? - 1. Is semi-fixed equipment accorded the same opera-tional check, calibrations, and maintenance.as fixed l (dedicated) instrumentation? r J. Are. instruments dedicated to analysis properly and l adequately maintained? k. Are calibration checks and calibration procedures adequate? 1. Are calibrations traceable to a recognized standard? A 43

l l m. Arc inoperative-irstruments properly marked, stored, and repaired?

• n.

Does the licensee pre-position emergency supplies and survey instrumentation at specified locations or in kits? o. Were kits and equipment located as specified in the plan / procedures?

• p.

Were inventories of major items or emergency equipment-correct (e.g., survey instruments, protective gear)? i

• q.

Was the emergency kit equipment operable? i

• r.

Does equipment to be used for team re-entering the facility or portions thereof include provisions for l extremity monitoring and detection and measurement of radiation fields up to 1,000 R/hr?

• s.

Is there a capability to detect and measure radiciodine concentrations in air of at least 5 x 10-8 mci /cc under field conditions in any kind of weather without the presence of noble gases and background radiation decreasing the stated minimum detectable limits? t. Is there an adequate in-plant capability for detecting airborne iodine in the presence of noble gases? \\

• u.

Are the numbers and locations of the area monitors adequate to assess accident conditions? (e.g.,could-they be affected by elevated background radiation or be inaccessible'during a serious emergency)? l

• v.

Are there procedures for using area radiation monitor readings under accident conditions? Are they located where workers may need to be (e.g., emergency-decontamination center, sampling areas, ECCS equipment areas,etc.)?

• w.

Are readings from these instruments readily available to those in the energency organization who would use the information to assess the accident?

• x.

Are these methods adequate? l ^3.3.6 Offsite Emergency Radiological Surveys

• a.

Are the methods and equipment to be us'ed to perform emergency offsi(e radiologi. cal surveys and pre-planned survey points.or routes specified?

• b.

Is there a means for team members to record: l' - A-44

the date and time of each survey? the location of each survey? the name(s) of the individual (s) who performed the survey? .the instrument used, by type and serial number? the mode in which the instrument was used, i.e., window open or window closed? the duration of the meter reading? air sampler flow rates? background radiation levels at the time of air sample counting? sample count time?

• c.

Is each environmental sample collected uniquely labeled for later identification? d. Is the means specified by which collected data to 3 include the original data sheets, are prcvided to the organizational element responsible for emergency asse,ssment functions?

• 3.3.7 Onsite (Out-of-Plant) Emergency Radiological Surveys (3.3)

The same as described in "b" above.

• 3.3.8 In-Plant Emergency Radiological Surveys The same'as described in "b" above,
• 3.3.9 Emergency Personnel Monitoring and Decontamination-i
• a.

Do procedures provide for monitoring all individuals j leaving restricted areas or other areas known or suspected to be contaminated?

• b.

Are the contamination levels that require decontami-nation actions specified to include or reference decontamination procedures for various' levels and types of contamination including skin contamination with radioiodine?

• c.

Are action levels specified that will require further assessment to include designation of the elements of the emergency organization responsible for performing the followup assessment? ~ A-45

• 3.3.10 Radiation Protection During Emergencies
• a.

Do radiation protection procedures clearly reflect their applicability during emergencies?

• b.

Are the following areas included: personnel dosimetry? exposure records? positive access controls? instructions to emergency workers (licensee as well as contractor or other persons / agencies augmenting the onsite emergency organization) regarding radiological conditions? dose assessment? provisions for preventing re-exposure of indi-viduals or limiting further exposure? d.0 RADI0 ACTIVE-WASTE-MANAGEMENT SYSTEf1 4.1 Program Responsibility Is the responsibility for radioactive waste management assigned? a. b. Is the responsibility assigned at a sufficiently high level? Is there proper attention, review, and management oversight? c. 4.2 Waste Processing Systems 4.2.1 General a. Is there verification that each system meets design objectives (e.g., FSAR, Appendix I, and Regulatory Guide 1.143)? b. Are standby or alternate processing systems available? c. Are the standby systems properly maintained and operable? d. Do process systens operate within experienced / expected decontamination factors, radionuclide concentrations, and equipment specifications? d e. Are the above factors verified on a periodic basis? A-46

9 f. If there have been any changes or additions to the waste systen, what considerations went into the 10 CFR 50.59 safety. evaluation? g. Are 10 CFR 50.59 evaluations documented? 4.2.2 Liquid and Gaseous a. Are checks, tests, and laboratory analysis performed on HEPA filters and charcoal adsorber systems? b. Are checks, tests, and laboratory analysis performed on installed air-cleanina systems not specifically listed in the Technical Specifications? c. Are plant operations / maintenance reviewed and con-ducted so as to minimize waste sources and effluent releases? d. Have any additions to the waste systems (i.e., new storage capacity, portable treatment systems, etc.) been designed and evaluated with current criteria documents (Standard Review Plan Sections 11 and 15 and i Regulatory Guide 1.143)? e. Are there specific waste-handling capabilities such as processing of contaminated oil, organics, and decon-tamination solutions? f. Do procedures exist for moving and discharging liquid and gaseous effluents? I g. Do the procedures address: release rates, alarm set-points, laboratory analysis results, compliance with Technical Specification (TS) limits, total activity release, total volume released, valve i line-up, and appropriate review and approvals? i h. Do procedures specify types of samples to be collected, the analysis performed on each sample, and appropriate sampling and analysis schedules? 1. Are the sample collection media and the delivery -systems adequate regarding constant gaseous monitors? j. Are the sample collection points: easily accessible, properly shielded, and properly ventilated? k. Are the samples representative? 1. Are the liquid and gaseous sample collection systems adequate for obtaining routine grab samples? A-47 l

m. When the plant is operating, are remote systems used to collect containment and drywell samples? n. Are all potential radioactive effluent release pathways monitored and/or sampled? o. Is the liquid and gascous radwaste equipment adequately maintained and operated? p. Are plant operations such that liquid and gaseous releases are alnimized to as to satisfy ALARA recommendations? q. Is there adequate storage available for safely holding and monitoring liquid and gaseous materials? 4.2.3 Solid Waste Processing Disposition a. Do processed waste packages conform to D0T regulations for shipment? b. What steps have been taken to comply with new burial . site requirements? c. Have there been changes or additions to solid-waste-processing facilities and what safety evaluations were completed prior to these changes (i.e., 10 CFR 50.59, SRP Sections 11 and 15, Regulatory Guide 1.143)? d. Does a volume-reduction program exist at the facility? If so, has it been effective? e. Is there a QA program for packaging and transportation of solid waste that meets 10 CFR 71 criteria? f. Is the radwaste equipment properly maintained and operated? g. Is solid waste processed, packaged, and shipped in a timely manner so as to avoid the unnecessary build-up i of on-site waste materials? h. If mobile solidification units are utilized,-have-10 CFR 50.59 safety evaluations been performed? 1. What on-site storage / storing exists and what provisions have been made'for safety, occupation dose control, and eventual disposition? 4.3 -Effluent / Process Instrumentation a. Are the monitors of sufficient quality and do they have operat' ng i characteristics to adequately measure the type of radiation and levels involved? A-48

.= b. Is there an established, routine calibration program for all instrumentation? c. . Are' there written procedures for each type of calibration? d. Are calibrations adequate for the need? e. 'Is there a QA program for packaging and transporting solid waste that meets-1-0 CFR 71 criteria? -f. Is the radwaste' equipment properly maintained and operated? g. Is solid waste processed, packaged, and shipped in a timely manner so as to avoid the unnecessary build-up of on-site waste materials? h. If mobile solidification units are utilized, have 10 CFR 50.59 safety evaluations been performed? i. What on-site storage / storing exists and what provisions have been made for safety, occupation dose control, and eventual disposition? 4.3 Effluent / Process Instrumentation a. Are the_ monitors of sufficient quality and do they have operating characteristics to adequately measure the type of radiation and levels involved? b. Is there an established, routine calibration program for all instrumentation? Are there written procedures for each type of calibration? c. d. Are calibrations adequate for the reed? 4 l e. Are the installed monitors adequate to address normal and anticipated occurrences? [ f. Are the monitors properly maintained? g. ' Are operability checks performed routinely on all monitors? Are - they adequate? h. Were setpoints on the monitors properly noted?. f i. Are alarm systens and process-monitoring control points installed and operable?- -*j. Are the number and locations of process monitors adequate to assess accident conditions?

• k.

Arc-there procedures for using process radiation monitor readings l under accident conditions? 1 -A-49

• l.

Are readings from these monitors readily available to those in the emergency organization who would need the information?

• m.

Does the licensee have interim methods (e.g., use of portable instrumentation or calculational methods) for estimating high-level releases? 5.0 ALARA PROGRAM 5.1 Program Establishment a. Is there a written management policy or commitment to ALARA? b. Are there written administrative procedures to implement the ALARA policy? c. Do facility equipment and design features incorporate ALARA concerns?' d. Are the responsibility and authority assigned to an individual in upper management? Does the RPM have responsibilities to the ALAPA program as .e. described in Regulatory Guide 8.8? 5.2 Facility / Equipment Design Features, Is there an adequate system established to avoid unnecessary.or a. inadvertent personnel exposures as described in Regulatory Guide 8.8? b. Is shielding / geometry designed: for servicing equipment? to provide distance when possible? to reduce streaming? to provide easy access to equipment and rapid removal? c. Are reach rods utilized? d. Are remote readouts utilized? e. Are ventilation systems adequate? f. 'Are flow rates adequate? g. Is surface contamination controlled adequately?- h. Is the production of crud adequately controlled by chemistry measures?~ A-50 u e o m.-

1. Are decontamination methods effective? t 5.3 Integration With Radiation Protection Program Is there adequate preparation and planning incorporated in a. work activities? b. Are health physicists involved in the planning of work activities? Is cleanup of leakage / spillage and material which is contami-c. nated given thorough decon treatment to reduce further spread of contamination? d. Are formal / informal post-operational briefings held? Is the information used to increase job performance in regard to i e. ALARA? f6.0'HEALTHPHYSICSFACILITIESANDEQUIPMENT 6.1 Facilities 6.1.1 Radiation Protection a. Are suitable areas available at appropriate locations 4 for: counting room? calibration? 3 personnel decontaninating? access control? offices? equipment decontamination? j instrument storage? external dosimetry? internal dosimetry? l respiratory protection - fitting /testino/ cleaning? training facilities? contaminated equipment storage? laundry? A-51 1

I e l' b. Do the design features acknowledge the need to practice ALARA philosophy? c. Does the facility maintain adequate change rooms, equipped with sufficient lockers and reasonably close to decontaminating area and control points? d. Does the licensee have an adequate personnel-decon-taminating area, (e.g., cole-use area with dedicated showers, basins, and installed "frisker" equipment)? e. Does the licensee have provisions for offsite decon-tamination of personnel? f. Do adequate calibration facilities exist for the portable equipment? g. Is the medical facility adequately equipped to handle contaminated workers? 6.1.2 Chemistry a. Do the physical facilities for the chemistry functions meet the design criteria? b. Are the facilities adequate for the present scope of operations? c. Are suitable areas available at appropriate locations for: analysis? sampling storage? d. Are sampling areas'available for safe and efficient collection of: primary coolant? airborne effluent? containment atmosphere? secondary systems? e. Can grab samples be taken of containment atmosphere? f. Are the sampling lines adequately. shielded? g. Does the licensee have and maintain an adequate chemistry laboratory, (e.g., fume hoods, hot drains, . shielding, location, etc.)? A-52

t l6.2' Protective Equipment 6.2.1 Respiratory Protection Devices i a. Are the quantities and types adequate for normal operations? For anticipated abnormal operations?

• b.

.Have actions been planned for rapid procurement of extra supplies in the_ event of an emergency? t

• c.

Pave actions been planned for expanded decontamination and repair services in the event of an emergency? 6.2.2 Anti-Contamination Clothing a. Are the quantities and types adequate for normal operations? For anticipated abnormal operations? b. Is special clothing, such as disposable paper and . plastic suits, available? J c. Are contamination limits established for reusable clothing? 6.2.3 Temporary Shielding a. Are various types of temporary lead shielding (e.g., bricks, blankets, lead shot, sheets) available? b. Are the supplies readily available and are the health physicists knowledgeable of the types and method of procurement? c. Are the contaminated supplies controlled adequately? 6.2.4 Containment Materials a. _Are adequate supplies of containment materials, (e.g.,. heavy-gauge plastic sheeting, plastic windows, non-skid floor coverings) maintained? b. Have_the materials been evaluated for compatibility _ with the' plant systems (e.g., chloride content, etc.)? c. Are there specific' instructions available for the con-struction of containment-structures? 6.2.5 Portable Ventilation Systems a. Are portable ventilation systems available for use? L b. Are the portable systems adequately filtered? l's {- A-53

c. Are the contaminated systens properly controlled? 6.2.6 Communications a. Are temporary communications systems available? b. Are the systems used to minimize the number of persons required in highly contaminated areas (e.g., steam generator repair work, etc.)? -7.0 MANAGEMENT OVERSIGHT 7.1 Management Adequacy 7.1.1 Planning a. Are plans completed before being implemented? b. Does planning consider radiation protection aspects? c. Are objectives to be accomplished clearly stated? d. Is forecasting used in the planning process? Are the forecasts based on realistic assumptions? e. f. Are the resources needed to implement plans clearly defined? g. Are policies outlined and procedures and guidelines established as part of the planning process? i h. Are milestones and check points established? i. Do plans include time phasing of radiation protection aspects? "1 j. Are plans adequately explained to and understood by- -the people responsible for implementing them? k. Is worker input included in the planning process? 1. Have provisions been made for modification of plans once implementation begins? 7.1.2 Organizing a. Is workload adequately planned? b. Are priorities set? c. Is the method for setting priorities. adequate?. i 'A-54

d.- Is the organization production oriented, functionally ' oriented, or both? e. What is the span of control at the first-line super-vision level? Second, etc.? 7.1.3 Directing Are there policy statements and/or guidance documents issued for plans and prograns to the individuals having responsibility for program implementation? 7.1.4 Coordinatiqq-a. Do various departments and managers coordinate their activities with the radiation protection organization and vice versa? b. Does the site management coordinate with non-site personnel including contractors? 7.1.5 Controlling i a. Are standards of performance established, documented, and communicated to those responsible-for meeting the standards? b. Are individual, group, and site performance regarding inplementation of the rediation protection aspects of plans and prngrams evaluated in' comparison with standards? l c. Is substandard performance promptly corrected? d. Is the corrective action adequate to ensure long-term resolution rather than symptomatic relief? e. Is -the controlling function performed on a routine basis? f. Is there a formal audit program? g. Are there self-audits and independent audits?. h. Is-there adequate followup on audit findings? i. Is there adequate control of contracted services? _ j. Is.there adequate direct contact and oversight of HP staff?- p . A-55 i- -Tv-rv w r w

q 7.2 Manager Effectiveness 7.7.1 Establishing Goals a. Are relevant program goals established? b. Are these goals: stated in measurable terms? attainable by the individual or group to whom they pertain? accepted by the individuals or group responsible for attaining them? c. Are goals short and long term in nature? d. Are the goals consistent with other goals which are related? 7.2.2 Motivating a. Are workers aware of what is expected of them, (e.g., standards of performance)? b. Do workers participate in the planning and decision-making process? c. Are workers provided with incentives or recognition for meeting program goals or meeting standards of performance? d. Is below-standard performance corrected? e. Do workers and managers appear well motivated? 7.2.3 Communicating ~ a. Are channels of communication clearly defined? b. Are the channels respected? c. Are methods of communication clearly defined (routine as well as non-routine) (e.g., staff meetings, open door,etc.)? d. Is it easy or. difficult to communicate?' e. Is information effectively disseminated to the HP staff? f. Is' the HP-staff made aware of~ plant status, planned maintenance, HP prcblem areas, environmental reports, Bulletins, Circulars, etc.?' A -..

I g. Is pertinent operational information conveyed to the I HP group? h. Is pertinent HP information conveyed to other plant groups? l' i. Is there timely and appropriate HP input for planned maintenance? f L j. 'Are arrangements adequate to ensure exchange of HP and [ operational data during emergencies?' 7.2.4 Maintaining Cooperation a. What is the manager's attitude regarding: the company? his position? 2 his program? his perfornance? his workers? 1-. b. Does the manager foster and encourage communication? c. Does the manager attempt to. broaden his staff's understanding of its mission? How? d. Do all managers have a unity of aims in relation to the radiation protection program? e. Does the manager promptly and adequately communicate problems and complete staff work? 7.2.5 Innovating a. Is there an. expression of a desire for constructive change? 6 l b. Is the manager able to overcome resistance to change. (his own and his staff's)? c. Is there a suggestion program or other means to com-municate innovating ideas? 7.2.6 ' Decision Making a. .Are decisions made in a group or individual manner? b. -Is timing adequate? A.

c. Are decisions clearly and promptly announced? d. Are decisions made based on a selection of alter-natives or are decisions made based on the first " alternative"? e. Does the manager make (permit) decisions? 7.2.7 Developing Subordinates' Potential a. Does the manager have a program for developing his people in the area? b. Does he coach, suggest special reading, or assign special tasks related to the field? c. Is there a personnel appraisal program? d. Are radiation protection instructors, managers, and supervisors encouraged and/or provided with the opportunity to upgrade their skills? e. Are individuals provided the opportunity to partici-pate in professional meetings and "short courses"? f. Are individuals encouraged to seek certification wher( such certification is available? 8.0 GENERAL PROCEDURES DEVELOPMENT 8.1 Format and Amendment Process a. Is procedure format as described by ANSI N18.7? b. Is the amendment process implemented in accordance with TS 6.8?- 8.2 Job Safety Analysis a. Is there an established priority in which jobs'are to be analyzc b. Is the job safety analysis (JSA) method adequate? Is a group discussion method used? or Is a direct observation method used? c. Is the job broken down into elements or individual steps? d. Are all of the contact possibilities (conditions in which personnel exposure could occur) identified? ' e. Are the contact possibilities adequately reduced or eliminated by such things as engineering controls, ventilation, contain-ment, protective clothing, etc.? A-58

8.3 Procedural Requirements Established a. Do the procedures for each task meet selection and training criteria and the applicable operating criteria? Are the pro-cedures responsive to supervisory problems? b. Do engineers and designers recognize their limitations in writing procedures for operating personnel, and of the need for selection and training criteria for operators, and of super-visory probleras? c. Are there sufficient check points in written procedures to ensure that steps are being done correctly? d. Are procedures revised, as necessary, to agree with changes in plant or equipment? e. Does the writing style of the procedures give consideration to variations in reading skills and intelligence of intended users? Are procedures sufficiently sceped and detailed to adequately cover all steps of a task? f. Do procedures give users clear instructions for all anticipated emergency conditions? Are instructions easy to follow in the stress of an emergency? g. Are dynamic and static warnings used when appropriate? Are they located at point of operation as well as in procedures? Is their meaning unambiguous? h. Are procedures written in such a way as to ensure that the step is in an order-of-logic sequence? i. Are lockouts and procedures used where hazardous situations are enceuntered or created? l l .i. Do the procedures adequately convey their intended message? If procedures call for coordination between users and other indi-viduals, are these interfaces clear? l k. Is the process of accomplishing the JSA program adequately c'efined and stoffed? Is work level employee participation requested in preparing JSAs? 8.4 Worker Participation Is consideration of employec-developed suggesticrs and inputs adequate? 8.5 Feedback System Is information on deficient procedures fed back to the procedure uriters ar.d responsible management? A-59

8.6 Verify by Field Test Are procedures valic'ated with applicable criteria and tested for correctness under " dry run" operating ccnditions? r A-60

1 4 i i ATTACHMENT: FUNCTIONS OF MANAGEMENT AND THE MANAGER Management _is the process of getting things done through the efforts of others. { Managers are people who make the management process work. Management (the l collective group cf managers) has five functions it must perform and each manager, has seven functions. The following discussion of these functions is provided to ! assist.intheapplicationofthemanagementoversighttreeandquestionstothe

sub-elements of the health physics appraisal.

I,

FUNCTIONSOfMANAGEMENT lPlannin_g i Planning is the development of a method or scheme of action to carry out a

! purpose. It provides an orderly transition from cne situation to another. It

recognizes where the organization is, specifies where it should go, how and lwhen it should arrive, and the price to be paid, iAn integral part of planning is forecasting - taking a reasoned look-into the

future to censider the possibilities based en a projection of current activities jand trends.

It is partly accomplished by experience and is not exact. l All levels of utility management should consider and clearly include radiation ! protection aspects in their planning activities. In preparing a plan, for an outage as an example, an analysis of the existing land expected radiological conditions should be made for the entire course of

the outage plant implementation. Will backgrourd radiation levels rise, will (they peek and then fall off, what areas of the plant will be affected and

'when? i 1 nce-the radiological aspects of a particular plan have been scoped (analyzed) 0 {the resources can be defined. The management team should outline policies.and iprocedures to ensure that events occur in accordance with the plan. Short-and

intermediate-range goals or check points should be established. With regard

to the radiation protection input-to the plan, dose limits, man-rems, or waste-l generation goals allocated to each task and the total plan should be established.

!The total; radiation protection program aspects of plans must be given considera- ~ ! tion and the goals should be explained to the workers.

Finally, as actual work proceeds, plans should be modified to account for un-jforeseencircumstancesorabroadeningofscope, n

ilarge jobs or programs.shculd include appropriate sequencing and milestone ~ jevents-that can be releted to the radiation protection program._ The inclusion ^

07 radiation' protection resources, tasks, and censideratiens must be an integral

!part 'of the planning process, regardlers of the complexity of planning being

done nr_the type of. plan being developed.

Radiation protection planning A-61

considerations are important in plans for reorganization, procedure develop-ment, training, budgets, work scheduling, maintenance, procurement, and much else. Often management breakdcwns are rooted in an ineffective planning process. Consequently, in looking at any radiation protection program, review the management team's planning process as it relates to the area of concern. Organizing Organization relates to the establishment of an intentional structure of roles by which people can know what their tasks and objectives are, how these fit with those of others, and how much discretion they and others have in making decisions to accomplish desired results. Utilities have traditionally been end-result oriented. Since it is difficult to structure an organization that totally reflects the end-result approach, structures that mix both functional and product results have emerged. Such an example is the organizational structure in which radiation protection or oth: " functional" areas are included within the operations area. Such structures usually exhibit instances of dual command with resulting elements of confusion and lack of responsibilities. An. offshoot effect of organizational aspects involves misconceptions of the line and staff authority relationships. This misunderstanding can lead to friction and inefficiency. Confusion with regard to functional authority relationships can be troublesome. Functional authority exists when one depart-ment is given authority over other departments not reporting to it. This is the case in which operations has authority over radiation protection or vice ve In organizing personnel resources, the management team should carefully conside span of control. Managers should be able to reduce their overload of less important daily duties giving themselves time for thought and personal contacts within their organizations. Spans of control guidelines are not rigid rules-designed to be applied to all situations, but rather to be used as a diagnostic tool when organizational weaknesses exist. The question to be answered is "How many persons should a manager or supervisor have reporting to him?" Narrow spans of control produce long lines of communication, decrease initia-tive and morale, cost more, delay decisions, decrease opportunities for self-improvement, and cause overmanagement. Too wide a span can overburden the manager so that he is unable to arrive at and communicate decisions. He has too little time to select, appraise, and teach his subordinates. With too little time to plan and check to see that plans do succeed, additional problems' result. Generally, no manager should supervise any more than five to six subordinates whose work interlocks. If, however, the work of subordinates is not closely interrelated and managerial coordination is not required, or where the manager ; is well supported by his staff or where close and frequent face-to-face communi-cation between the manager and his subordinates is not necessary, wider spans of control nay be appropriate. A-62

Rt higher levels, a span of control of from 3-8 subordinates and a span up to 80 people at lower levels are within range. 31recting $1recting is the function of propelling the organization toward accomplishment

@f plans and their objectives.

The management team must clearly direct, through golicy statements and procedural outlines, that its plans be implemented. If management develops plans but fails to provide clear direction regarding implementation,: managers find it difficult to make it a priority and devote resources to effective implementation. Qithout clear direction, plans can never get to first base. !@oordinating $oordinating involves the process of ensuring that needed resources, e.g., time, material, and people, are available at the right time and in the proper sequence. (than that the management team must coordinate itself and its plans. It melds things together and makes things go. Little more need be said other l { Controlling l '@ontrolling is making sure plans succeed. It is the measuring and correcting @f activities. Effective controlling-implies more than measuring and places emphasis on effective correction. Correction may require revised planning, additional organizing, better coordination or direction. As such, the con-trolling function closes the loop of the management process. The controlling process consists of establishing standards against which [serformance can be measured, measuring performance, and correcting deviations from'the standards or plans. Planning is the basis for controlling, and action by people with authority is its essence. JUNCTIONS OF A PANAGER A manager has seven general functions in relation to his subordinates: L establishing goals 3 motivating 3. communicating innovating-4 5. maintaining cooperation 6. developing a subordinate's potential 7. -decision making Each of. these functions should be performed by example and direction in such a ~ way that the manager gains the' confidence and respect of his-subordinates. This is leadership. It involves personality, vision, knowledge, courage, judgment, mental. flexibility, and integrity. Frequently, managers may become too involved in the technical aspects 'of their areas, leaving management to chance. A-63

Establishing Goals A goal is an end to be achieved or a purpose to be fulfilled. Establishing goals sets specific targets to direct the overall actions of people and con-tributes directly and vitally to their performance. This contribution will be good, bad, or indifferent in direct proportion tc how well the manager applic himself to this vital and continuing task. The Need for Establishing Goals A radiation protection staff exists to perform one major task - to limit / prevent exposures. The staff is composed of individuals, including the manager, who accomplish this task. If supervisors and technicians _are to make their best contribution, goals must be set and the staff must know and understand the goals. If they do not, or if this knowledge is clouded and con-fused, they'will be working for the sake of working and not for the sake of accomplishing anything. Therefore, establishing goals for a radiation pro-tection staff must receive continuing attention. The Nature of Goals Here are seme characteristics that goals should have: 1. They must be attainable. P. They must be stated in measurable terms (how much, how many, etc.). 3. They should contribute to the goals of the company. 4. They should be stated in a way that the individual's contribution can be directly related to them. 5. They are short range and long range. 6. Short-range goals should contribute progress toward accomplishment of the ultimate (long-range)-goal of the organization. 7. The goals must be accepted by those responsible for their accomplishment; in this case, by every member of the station. Acceptance'of Goals There is ovenshel' ming evidence that acceptance of a goal by the individuals who must reach them is a ' vital prerequisite to their successful accomplishment. Time permitting, the managers should do all they can to ensure acceptance ~of rad _iation protection goals by the station staff. Americans believe in the dignity of the individual and feel a need to know why'they should do what.they. do and why their organization does what it does. The radiation protection and operating staffs are no exception. The degree to which they know these things will affect their contributions as members of the station staff in meeting radiation protection goals. Understanding the purpose ~of the radiation pro-tection staff; is a prerequisite to acceptance of the radiation protection staff goals! When a worker understands, he will more likely become committed - to the goals. A-64 =

~ j Motivating L Hotivation 'is an artery which runs through all of a manager's tasks. The most successful manager is the one who gets his staff to work with him. To the successful manager, people are not just " resources." They are vital, creative beings.with hopes, aspirations, and needs. The success of a manager is measured in large part by the extent t0 which he can tap the potential in each of his workers. Motivation is the process of developing (within an indivual or group) the willing desire to accomplish results, and may be classified as primary and secondary. Primary motivation has its wellspring within the individual; secondary motivation comes from without - from the manager. Elements of Motivation Among many other factors, motivation includes: 1. Appreciating and integrating staff and personal needs. 2. Providing the opportunity for workers to participate in establishing goals 4 and standards of performance. Such participation fosters acceptance of goals and stimulates workers through identification of their personal interests with the aims of the staff and company. $3. The manager setting a personal example of optiumum performance. 4. The manager's decisive and fair public recognition and rewarding of good performance and correction of substandard performance. , Group Motivation Educational opportunities, promotions, and incentives help people to be pro-ductive and encourage self-motivation, but alone, they are not enough. They will not provide all the motivation which people need to be effective. The manager must provide the rest by constructive attitude and behavior. Results are obtained from people in six ways: satisfaction, reward, persuasion, auth- ' oritye fear, and force. -Individual Motivation 4 Every individual reacts differently to various things. People are like the ( fractions, 1/8, 3/8, 5/8 - basically the same, but all different upstairs. 1. When dealing with-subordinates, the manager should recognize that their emotions are facts! Needs which effect them must be considered in his relations with them. The fulfillment of their needs, not his, is what motivates them. Money,

for example, if only one motivating factor.

l-Another. principle to be considered is that needs and wants are arranged in a hierarchy of importance. As soon as needs on a lower level are fulfilled, those on a higher level emerge.and demand satisfaction. This hierarchy is arranged -in.a pyramid of five levels, from basic physiological drives at the bottom to the desire ~for self-realization at the top. A-65

A brief word of explanation of each of the five levels of needs is as follows: 1. Physiological needs - oxygen, food, water, shelter, rest, etc. These needs dominate so long as they are not filled. Once satisfied, however, they cease to be.important motivating forces. 2. Safety needs protection from physical and economic dangers, i.e., attack, war, fire, accidents, criminal assault, old-age risks, etc. Among the healthy adults of our society, these needs afford a minimal satisfaction. Consequently, their motivating force is a diminished one. 3. Social needs - love, affection, togetherness, belonging, etc. Unlike physiological and safety needs, social needs are not readily satisfied in our society. They have consequently become a dominant motivating-force. 4. Esteem needs personal worth, dignity, achievement, recognition, status, prestige, reputation, etc. These needs are obviously important determin-ants of behavior. They can give satisfaction. 5. Self-realization needs. This is the ultimate in the hierarcy of needs. It entails the fulfillment of one's highest potential. It requires making maximum use of all one has, becoming everything that one is cap-able of becoming. As more people have their lower needs n. ore and more satisfied, a greater number will work toward fulfilling their self-reali-zation needs. The Manager's Responsibility The manager must be able to translate each person's needs into a tangible effort: and create a unity of purpose. Awareness of the way needs influence people ~ will help in all areas. In general, appraisal and recognition of performance are essential. It is a manager's responsibility to make such appraisals and give the appropriate recognition. Communicating Communicating is anything that results in an exchange of information or under-standing. It creates mutual understanding and'is one of the most difficult and important areas of a manager's responsibilities. The effective manager will recognize and accept the fact that adequate communication is necessary. Elements of Communication Communication is more than "saying what you mean." It includes: 1. anticipating the reactions of the recipients, l 2. .using language that is understood. ' 3. stimulating. recipients to want to receive and. understand the information J transmitted, 4. encouraging interaction and personal contact, A-66

l 5. being an attentive listen _er and evidencing a willingness to act on what is said, 6. realizing the impacts of attitude and behavior on effectively conveying intent and motivation. Without effective communication every element of the staff is affected; there can be no cooperative action. flethods of Communication Communication may be either verbal or nonverbal, written or oral. The need for written communication is obvious, but exclusive reliance upon it can retard perfo rmance. Oral messages are frequently more effective because they are timely and abet mutual understanding. t!cnverbal conmunication is more difficult to understand or to discuss since it involves " implications" transmitted through attitude and behavior, i.e., a frown, a smile, tone of voice, etc. Nonverbal communication supports and affects the verbal message. Channels of Communicatior An adequate communication system consists of three channels - down, up, and across. The down channel is obvious. The up channel is the channel through which reports are made and through which the workers make ideas, wants, and needs known to management. The across channel enables workers and managers to coordinate their performance with others. The across channel enables the manager to coordinate his staff's activities with other managers. If the across channel is used well, it will reduce parochialism, foster teamwork, and ensure unified effort. In every organization, there always exists an informal channel of communica-tion called the grapevine. The grapevine transnits speculative and hearsay information, without relation to a specific line or channel. The wise manager, instead of trying to ignore or eliminate it, feeds it with accurate and complete information, thereby putting it to work for him. If left alone and permitted to breed on false rumors and half-truths, the grapevine can become a demoraliz-ing and disruptive influence. The flanager's P.esponsibility for Adequate Communication it is the manager's responsibility to keep his people and his supervisors informed. It is not enough to make reports and expect that they will be read and understood exactly as visualized in the orginator's mind. To be effective, the nanager must realize that reports alcne will not satisfy everyone's need for information, just as reports from workers do not totally satisfy the manager's need for infornation about work in progress. Written means of communication must be supplemented with direct contact via telephone calls, neetings, briefings, and conferences. In this way, managers can inforn as well as be informed. The type, frequency, and nature of communications that are necessary to ade-quately keep everyone informed should be defined. A lack of guidance regarding A-67

m = what is to be communicated and how and when it should be communicated must not be used as an alibi or excuse for failing to keep people informed. Quite often, fear of being criticized, a failure to meet goals, or simple laziness are the underlying reasons for a failure to communicate. Innovating Innovating is doing things differently for the purpose of improvement. All variations of the word have a ccnnotation of the new and different; all involvc elements of change. Importar.ce of Improvement It is unlikely that a manager will ever have enough time to do all he would like to do and knows is necessary. Therefore, he must constantly evaluate what he and his staff members do and how to get the job done making better use of time, still getting the same, or hopefully better, results. In managing, he should seek and find new and more economical ways of accomplishing all that he has to do. Irnovation boils down to one thing, creativity. If something is not working, or making one work too hard, a new and better way of doing it should be developed. Maintaining Cooperation A manager should strive to create an atmosphere in which workers believe that their individual contributions or efforts are important and worthwhile. It should be an environment in which each worker believes that he is a member / of an aggressive and progressive organization and that his manager is receptive to new ideas and to creative thinking. In brief, the manager's personal phil-osophy of his role, his staff, and his company is a hidden force which will per-meate the staff and mold its character. Elements of Maintaining Cooperation This function is intimately associated with motivating, communicating, and developing a subordinate's potential. It creates and continually strengthens unity of purpose by keeping the needs of the entire staff and the needs of the individual in balance. It includes: 1. fostering unity of aims and freedom of communication, 2. broadening the worker's understanding of the staff and the company, 3. integrating the needs of the staff and the company with the interests and capabilities of the staff and the dignity of the individual. Cooperation With Control In establishing and maintaining a cooperative staff, the manager should estab-lish realistic, attainable performance standards. In many cases, some of these standards are set by regulation or technical specification. A manager should, however, develop additional standards to apply to his staff. These standards should not be set arbitrarily, but, whenever appropriate, with the A-68

workers actively participating. If the workers participate in establishing standards of performance, the standards being set will frequently be higher than those the manager might develop on his own. Standards should be revised when appropriate, with the workers participating in the revision. Such revi-sions, however, should not penalize good performance but should provide for improved methods and procedures. Developing a Subordinate's Potential Developing a subordinate's potential is providing him with the opportunity to improve his capabiiities and realize this goal. The whole subject is closely interwoven with all the other functions of the manager. It is closely affi-liated with motivating, communicating, and maintaining cooperation and will thrive in an environment where those functions are performed properly. Developing a subordinate's potential is basically a training process. Ensuring that a worker is properly trained from the very beginning is critical to his further development. In helping develop a worker's potential, ask the following questions to determine what is important. 1. What does the job require that a particular worker doesn't know or is not able to do? 2 How can he be helped to learn quickly and easily? 3. How can one determine if he has learned what has been taught? Although these questions relate to teaching a specific skill such as surveying, they are also useful in analyzing all workers and formulating a general plan for the development of the entire staff. Techniques for Developing a Subordinate's Potential Coaching - a cooperative attack with the worker on specific problem areas. When coaching, workers are provided with suggestions of alternative ways to accomplish the same end. Special Assignments - a worker who prepares a presentation cr a particular subject will broeden his knowledge of the subject. Developmental Reading - The manager may suggest appropriate study or reading material, for the worker to review. It may be helpful to have a library of pertinent books. Academic Instruction - formal training. This type of instruction, coupled with experience, produces the nost rapid development for some individuals. Workers will develop more rapidly and learn more effectively under a manager who practices leadership principles rather than under one who is a driver. Recognize and be familiar with the characteristics of a so-called driver. The following comparison of the driver and che leader is provided for that purpose. A-69

_he Leader T The Driver Depends on authority Depends on good will Inspires fear Inspires enthusiasm Says "I" Says "we" Fixes the blane for a breakdown Fixes the breakdown Knews how it's done Shows how it's done Makes work drudgery Makes work a contest and satisfyino Decision liaking Decision making is selecting a course of action from among alternative courses to achieve a prescribed goal. Decisions may be made by an individual or by a group of individuals. One widely accepted method of decision making is for a group of individuals to be involved. The group studies the impacts of the alternatives and makes recommendations, in order of desirability, to the manager. The manager, however, makes the final decision. Having consulted with the group and kept it informed, the manager will have created an atmos-phere in which an unpopular decision is more acceptable to everyone. Timing is an important element of decision making. Occasionally, a manager may have to make an early decision without complete information. Too many decisions are made without complete information, but all desirable informa-tion will rarely be available in time. If a manager waits too long, events may overtake him generating a greater and more complex problem. His most difficult decision nay be to decide when to decide. The urgent will always take priority over the important. Frequently, the manager must decide what is urgent, what is important, and what is routine. Once a decision is made, the manager must be sure it is stated in terms that will be understood. Here, lessons in communicating come into play. Good conmunication should speak the language of the listeners, write the language of the readers, and avoid the haze of ambiguity. Indecision is infectious and epidemic. Workers properly expect managers to make positive decisions; they dct not expect them to let nature take its course. One reason for indecision and a lack of desire to make decisions is fear of I conflict. If a problem involves conflict, the tendency is to put off the decision. To avoid being indecisive, a manager should develop as much comfort 3 with conflict as he can endure. A-70

l l APPENDIX B HEALTH PHYSICS APPRAISAL REPORTS J o 9

Name of Plant-Report Number (s) Transmittal Letter Arkansas 50-313/80-20, 50-368/80-20 February 23, 1981 . Beaver Valley 50-334/81-05 December 23, 1981 BigtRock Point 50-155/80-04 June 13, 1980 Browns Ferry 50-259/80-36, 50-260/80-30, February 25, 2982 50-296/80-30 Brunswick. 50-325/80-45, 50-324/80-43 April 27, 1981 Calvert Cliffs 50-317/80-09, 50-318/80-07 December 11, 1980 Cook-50-315/80-23, 50-316/80-19 hay 26,-1981 Cooper 50-298/80-07 September 8, 1980 Crystal River 50-302/80-25 September 8, 1980 Davis-Besse 50-346/81-11 September 2, 1981 Dresden 50-237/80-13, 50-249/80-17 September 12, 1980 Duane Arnold 50-331/80-21 February 2,1981 Farley 50-348/80-41, 50-364/80-52 March 13, 1981 FitzPatrick 50-333/80-20 January 20, 1982 Fort Calhoun 50-285/80-16 December 27, 1980 Fort St.Vrain 50-267/80-13 October 8, 1980 Ginna 50-244/80-16 June 15, 1981 Haddam Neck 50-213/80-12 December 29, 1980 Hatch 50-321/80-27, 50-366/80-27 September 12, 1980 Indian Point 2 50-247/80-02 August 7, 1980 Indian Point 3 50-286/80-03 In preparation Kewaunee' 50-305/80-26 January 13, 1981 Lacrosse 50-409/80-10 March 3, 1981 Maine Yankee 50-309/81-01 October 7, 1981 Millstone 50-245/80-12, 50-336/80-11 March 19, 1981 Monticello 50-263/80-11 August 7, 1980 North Anna 50-338/80-21, 50-339/80-22 September 15, 1980 Nine Mile Point 50-220/80-11 March 2, 1981 Oconee 50-269/80-31, 50-270/80-27, January 20, 1981 50-287/80-24 Oyster Creek 50-219/80-17 In preparation Palisades 50-255/80-14 November 28, 1980 Peach Bottom 50-277/80-18,.50-278/80-10 April 2, 1981 Pilgrim 50-293/80-05 July 22, 1980 Point Beach 50-266/80-16, 50-301/80-16 November 14, 1980 Prairie Island 50-282/80-08, 50-306/80-09 August 12, 1980 Quad Cities 50-254/80-20, 50-265/80-22 October 21, 1980 . Rancho Seco 50-312/80-32 January 16, 1981 Robinson 50-261/81-07 June 26, 1981 St.Lucie 50-335/80-06 June 24, 2980 Salem 50-272/80-03. June 12, 1980 San Onofre 50-206/80-17 . August 15, 1980 Surry 50-280/80-29, 50-281/80-33 December 18, 1980 Three Mile Island 50-289/80-22 November 26, 2980-Trojan 50-344/80-16 October 31, 1980 ~ Turkey Point 50-250/80-17, 50-251/80-15 August 28, 1980 Vermont Yankee 50-271/80-14 In preparation Yankee Rowe 50-29/81-01 December 24,'1981 Zion ~ 50-295/80-05, 50-304/80-04 June 27, 1980 B-3.

"" 33; U S. NUCLEAR REGUL ATORY COMlW"SSION BIBLIOGRAPHIC DATA SHEET NUREG-0855 I LE AND SUBTIT LE (Add Voturne No., er appropr,are) 2 Ileave blan*1 Health Physics Appraisal Prooram ~

3. RECIPIENT'S ACCESSION NO.

kUTHOR(S)

5. D ATE REPORT COMPLE TED

. J. Cunningham, J. E. Wigginton, E. D. Flack l1981 mon m vE^n Decerter fE RFORMtNG ORGANIZATION N AME AND MAILING ADDRESS (laciude I,o CodeJ DATE HEPORT ISSUED Iffice of Inspection and Enforcement .S. Nuclear Regulatory Commission March l1982 vos m vE^a shington, D.C. 20555 6 't ** e o'*a * > 8 ILeave blanni SPONSOHING OHGANIZ ATION NAME AND MAILING ADDRESS (Include l<p Codel 10 PROJE CT!T ASK/ WORK UNIT NO ame as 9. above

11. CONT R ACT NO.

T YPE OF REPOR T PE RIOD COV E DE D (/nclusive dates / echnical Report SUPPLEMEN TARY NOTES 14 (L N D'8"* / ABSTH ACT (200 wmds or lessJ The accident at Three Mile Island in March 1979 and subsequent investigations identified, among other items, serious concerns involving several aspects of the radiation protection program. Significantly, some concerns involved areas not addressed by regulations or facility technical specifications. This in turn led to initiation of a major effort to evaluate the adequacy and effectiveness of radiation protection programs at all currently operating nuclear power facilities during calendar year 1980 by the Office of Inspection and Enforcement (IE), Nuclear Regulatory Commission. This inspection effort was termed an appraisal since it was structured to facilitate an integrated look at the total radiation protection program, delve into matters for which explicit regulatory requirements did not exist, and emphasized evaluation of capability and perfonnance rather than compliance with regulations. This report discusses the results of the 48 appraisals and the anticipated regulatory actions that may be taken to further address the concerns. I K E Y WOR DS AND DOCUVE NT AN ALYSIS 17a DE SC H iP T O RS 'n IDE N Til IE HS OFE N L N DE D TE RYS Tv g j gsiiTd AV Att ABILIT Y ST ATE VE NT 13 Unlimited availability YNIN $c, onv J3s. ' 7 n

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