ML20054D035
| ML20054D035 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/31/1982 |
| From: | Essig T, Knapp P, Galen Smith, Wadman W Battelle Memorial Institute, PACIFIC NORTHWEST NATION, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), WADMAN & ASSOCIATES |
| To: | |
| Shared Package | |
| ML20054D023 | List: |
| References | |
| 50-271-80-14, NUDOCS 8204220263 | |
| Download: ML20054D035 (33) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
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Report.No.
50-271/80-14 Docket No.
50-271 License No. DPR-28 Priority Category C
Licensee:
Vermont Yankee Nuclear Power Corporation
'1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: -Vermont Yankee Nuclear power Station
-Appraisal at:
Framingham, Massachusetts i
Appraisal-CondaEtedi7epteqber 22 - October 3,1980 b
Team IP D-
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J.J1Knapp,iI'Sec 'on (Team Leader) NRCChief,FacilityRaydlogical date signed 4
Protectio n-Q gy 3
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T.H. Essig._R search Scienti's', Ba6telle date signed t
G ific Northwes aboratories(PNL)
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W.W. Wadman, III, Nadman an5?Associhtes, da'te signed Inc. (Contracted to Battelle Pacific Northwest) 3' /
r Approved by:
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/ [L G.H.Srifth',jKreitor,DivisionofEmergency date signed
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Prepa ednyss and Operational Support 4
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c TABLE OF CONTENTS Summary 1.0 Radiation Protection Organization 2.0 Personnel Selection, Training and Qualification 2.1 Documents Reviewed 2.2 Position Descriptions, Selections and Qualification i
2.3 Training l
2.4 Conclusion 3.0 Exposure Controls 3.1 External Exposure Control 3.1.1 Documents Reviewed 3.1.2 General 3.1. 3 External Dosimetry Program 3.1. 4 Exposure Review 3.1. 5 Exposure Limitation 3.1. 6 Quality Assurance 1
3.2 Internal Exposure Controls 3.2.la Internal Dosimetry 3.2.lb Operation of the Whole Body Counter 3.2.2 Conclusion - Internal Dosimetry 3.2.3 Respiratory Protection Program
- 3. 2. 3.1 General 1
3.2.3.2 Training, Fitting and Qualification 3.2.3.3 Maintenance 3.2.3.4 Quality Assurance 3.2.3.5 Conclusion i
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2 3.3 Surveillance Program 3.3.1 Documents Reviewed 3.3.5 Scope 3.3.3 Instruments 3.3.4 Quality Assurance 3.3.5 Records 3.3.6 Conclusion 4.0 Radioactive Waste Management 4.1 Documents Reviewed 4.2 General 4.3 Gaseous Waste 4.4 Liquid Waste 4.5 Solid Waste 4.6 Process and Effluent Monitoring Instrumentation 4.7 Conclusion 5.0 ALARA 5.1 Documents Reviewed 5.2 Plant ALARA Program 5.3 Conclusion 6.0 Facilities and Equipment 6.1 Radiation Protection Facilities 6.2 Radiation Survey Equipment 6.3 Protective Equipment 6.4 Conclusion 7.0 Exit Interview Attachment A - Persons Contacted
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i Summary A special health physics appraisal was conducted during the period September 22 -
October 3, 1980, to evaluate the overall adequacy and effectiveness of the implementation of the Vermont Yankee radiation protection program. The i
appraisal team consisted of one member of the NRC Region I Office of Inspection and Enforcement and two contractor individuals.
The appraisal included observations of work practices, reviews of facilities, programs, procedures and records, and interviews with licensee personnel.
The areas included in the appraisal were:
Radiation Protection Organization and Management Personnel Section, Qualification and Training Internal and External Exposure Controls Radioactive Waste Management ALARA 4
Facilities and Equipment 1
Results of the health physics appraisal indicated a program that was well 4
above average but that a few significant weaknesses existed. These weaknesses i
are identified in the report and summarized in Appendix A, Significant Appraisal Findings, enclosed with the letter transmitting this report.
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1.0 Radiation' Protection Organization
-The radiation protection organization, called the Chemistry and Health Physics Department, is shown in Figure 1.
Individuals in the major
.line positions (Chemistry and Health Physics Supervisor, Health. Physicist and Chemist) all hold batchelor's degrees in a scientific field and i
have held professional supervisory positions at nuclear power plants for at'least seven years. The Health Physicist is the radiation 4
protection manager and meets the qualifications for this position.
outlined in Regulatory Guide 1.8.
The position designated Chemistry and Health Physics Assistant is the Vermont Yankee equivalent of j
foreman. Table 1 summarizes the relavent training and experience of the non professional level members of the Chemistry and Health Physics l
Department.
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Plant Superintendent Administration Training Assistant Plant Superintendent
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I Ope ations Maintenance Instrumentation Reactor Eng'ineering and Controls and Computer Engineering i
Support I
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Chemistry and Health Physics Supervisor ChemkcalEngineer RecordsC5erk(2)
Radiation and Environmental Technical assistants (2) i i
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Health Physicist Chemist l
j Chemistry and Health Physics j
Assistants (5) l Chemistry and Health Physics Technicians (9) i j
Figure 1 Organization for Health Physics During Normal Operations 1
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i TABLE 1 Training and Experience of Non-Professional Level Members of
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the Chemistry and Health Physics Department i
Years as Years as College Vermont Vermont Level Yankee Yankee Individual Training Assistant Technician Comment Tech. Asst.
10 Certified HP (Rad and Eny) I
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Tech. Asst.
BS 6
(Rad and Env) II Whole Body Counting Asst. A 10 Respirator Fit Training l
Asst. B 7
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Asst. C
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2 Radioactive Waste Asst. D BA 0.5 4
j Asst. E 0.5 10 I
Tech. A 1.5 Years 7
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Tech' B BS 1.5 l
Tech. C 0.5 6 Years Health i
. Physics Tech.
Experience Elsewhere Tech. D BS 0.5 l
Tech. E BS (HP) 0.5 1.5 Years Health Physics Tech.
l Experience Elsewhere 1
Tech. F 4 Months 0.5 1.5 Years Health 1
Physics Tech.
Experience Elsewhere Tech. G BS 0.1 l
Tech. H 0.1 Navy ELT Tech. I 0.1 Navy ELT i
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6 Until the refueling outage, which began on September 27, 1980, non-day shift radiation protection coverage required by Technical Specification 6.1.d.1 was provided by operators (rather than radiation protection personnel) who had received specialized training.
Records of this training were verified during spot checks of the training records. During the outage, radiation protection areas are covered on all shifts by a much more extensive organization which is outlined in Figure 2.
Licensee Management stated that after the outage, radiation protection personnel will be at the site during every shif t to meet the technical specification requirements.
i Chemistry and Health Physics Supervisor i
(0600 - 1530)
Chemist Chem and HP Assistant (1)
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Chem and HP Technician (1)
Health Physicist (0830 - 180d) i Radiation and Environmental Technical Assistant i
(0000 - 0930 hrs')
(0600 - 1530 hrs)
(1500-0030 hrs)
VY Chem and HP VY Chem and HP VY Chem & HP
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Assistant Assistant Assistant l
Contractor Tech (5)
Contractor Tech (8)
Contractor Tech (8)
Contractor Helper (1)
Contractor Helper (2)
, Contractor Helper (2)_
i Re ords Whole Body Counting i
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and Respirator Fit t
b Figure 2 - Organization for Health Physics During Outage Operations I
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The component functions of the radiation protection program, such as operational job coverage, personnel dosimetry, instrument calibration, RWP issue and chemistry, were supervised by the Chemistry and Health Physics Assistants.
The Assistants were required to rotate through these positions. The maximum time allowed in any one functional area was one month. Two exceptions were the Assistants who were assigned to whole body counting and radioactive waste operations. These individuals spent full time in these areas.
Thermoluminescent dosimeters employed for personnel monitoring were supplied and evaluated by an offsite organization, Yankee Nuclear Services. The dosimeters were issued and collected by site personnel. Computer reports of dosimeter evaluation were supplied by Yankee Nuclear Services.
The appraiser determined that the responsibilities, duties and authorities of each position were well defined and clearly understood. Job descriptions were adequate.
The scope of assigned responsibilities were adequately defined to assure effective performance with one exception, there was no clear statement of assignment of responsibilities for an ALARA position.
This is further discussed in Section 5.
Appraiser review established that staffing of the Radiation Protection Manager, Supervisor, Foreman and Technician positions was adequate and sufficient back-up personnel were available.
2.0 Personnel Selection, Qualification and Training 2.1 Documents Reviewed Documents titled " Job Description" covering the following:
Chemistry and Health Physics Supervisor, dated February 25, 1978; Plant Chemist, dated November 15, 1978; and Chemical Engineer, Plant Health Physicist, Technical Assistant Radiological / Environmental, Chemistry and Health Physics Technician, and Chemistry and Health Physics Assistant, all dated September 11, 1980.
Procedure AP 0004, " Plant Staff Training," Revision 2, dated December 6, 1979.
Procedure AP 0720, " Employment Processing," Revision 9, dated August 24, 1980.
Procedure DP 0160, "Non-Licensed Operator Training Program",
Revision 3, dated February 28, 1979.
Procedure DP 0632, " Chemistry and Health Physics Department Training Program," Revision 4, dated February 26, 1980 and Revision 5, undated.
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9 2.2 Position Descriptions, Selection and Qualiffcation The appraiser reviewed the " job descriptions" listed in Section 2.1. Each document contained ttie following:
A statement of the education and experience necessary to qualify for the position.
j' A statement of what position the incumbent reports to.
r A statement of the responsibilities of the position.
A statement of the authorities of the position.
Each description was dated and showed the signature of the Plant Manager in an " approval" block.
From a review of the " job descriptions" and records, and interviews with plant personnel, the appraiser determined that selection criteria and qualification criteria were appropriate for each position. The appraiser also determined that the criteria were applied in every case.
2.3 Training i
Training was divided into general plant training and departmental j
training. Under general plant training, that which is related to radiation protection matters was titled, "New Personnel Indoctrination, Emergency Plan and General Health Physics." These courses were developed by the Plant Training Coordinator and the Chemistry and Health Physics Supervisor.
Indoctrination was provided to all new personnel.
Emergency Plan training was provided to prescribed individuals and General Health Physics training was provided in j
such a way that approximately 100% of the plant personnel receive it once every two years.
Departmental training was developed by the Chemistry and Health Physics Supervisor and the Plant Training Coordinator. As a minimum, it consisted of on-the-job training, in-house or con-ntractor-supplied training, an annual departmental procedure review, a review of related technical documents, a department procedure change review and a review of applicable licensee event reports.
Licensed and unlicensed operators received radiation monitoring training and retraining provided by the Chemistry and Health i
Physics Department.
Records of all training were maintained on prescribed forms by.
the Plant Training Coordinator.
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I Details on-the Chemistry and Health Physics Department Training Program are presented in DP 0632.
This procedure provides for training of new employees and retraining of all departmental personnel. The procedure, in its latest form also prescribes the training to be provided to temporary technicians, such as those that are brought in to cover outage work.
The procedure provides i
i for documentation of all completed training.
Procedure AP 0720 provides, in substantial detail the training to be provided to in coming new employees including temporary employees.
It prescribes the subjects covered and the form of the training and includes the methods of verification of satisfactory completion.
It establishes the records which must be maintained.
2.4 Conclusion From a review of the procedures and records and contact with appropriate licensee personnel, the appraiser determined that the training was adequate in content, nature and length, that appropriate i
persons were included and that the appropriate records were maintained.
I 3.2 Internal Exposure Controls 3.2.la Internal Dosimetry I
i The only internal dosimetry program used by the licensee was whole body counting. According to a licensee representative, I
other bioassay techniques (e.g., excreta analyses) have not been performed because whole body counting was more reliable than excreta analyses for gamma - emitting radionuclides.
For those nuclides not detectable by whole body counting (e.g., H-3, Sr-90), the licensee representative stated that airborne monitoring for these nuclides had shown them not to be a problem.
The whole body counter (WBC) system consisted of two chair-type counters. A new chair had recently been installed and was being calibrated and set up for counting during the appraisal. The new chair was equipped with two large (4" x 4" and 4" x 5") NaI crystal detectors for trunk counting (GI tract and chest) and a small (1-1/2" x 2") NaI crystal detector for thyroid counting. All three detectors were coupled to a 4096-channel analyzer.
The old WBC chair, which had been in use since mid-1976, was equipped with a 3;" x 3" NaI crystal detector for counting the trunk region and a 1-1/4d x 1[-1/4" NaI crystal detector for counting the thyroid.
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11 Output data available to the operator directly from the WBC analyzer consisted of a CRT display of the gamma spectrum and a printout of count rate data by channel number. A computer program (GAMANL-11) was readily available via telephone line to the licensee's corporate office to process the gamma spectra and compute organ burdens.
The licensee's WBC program was described in Procedure DP 0533, " Body Burden Counting." Revision 2, dated February 26, 1980.
This procedure addressed special and routine circumstances which warranted whole body counting, described the performance of energy calibration checks and background counts and contained a detailed listing of all steps necessary to collect and compute body burden data.
Procedure DP 0533 was deficient, however, in the following areas:
The procedure did not specify the frequency of the energy calibration check or the background count.
According to the Chemistry and Health Physics Assistant (Chem and HP Assistant) who operated the whole body counter, background checks and energy calibration checks were typically performed on a daily basis.
Records examined for the period from August 18 -
September 24, 1980 indicated that such checks were performed on 10 occasions during the approximately 20 days of operation during the period.
The procedure did not specify the performance of routine source counts to determine whether the counter was properly quantifying known sources.
The procedure did not contain a procedure for a primary calibration of the WBC using sources which were traceable to the National Bureau of Standards. A discussion with the operator and a review of WBC records revealed that such a calibration was made annually, althouth not in total accord with ANSI N343, " Internal Dosimetry for Mixed Fission Products."
The procedure did not contain a body burden set point above which management was to be made aware of the results. A discussion with the operator and his supervisor, the Plant Health Physicist, indicated that body or organ burdens greater than 10% of the permissable burden would be investigated in detail, but this level had never been reached.
Procedure DP 0533 required whole body counts when exposures in excess of 10 CFR 20.103 limits occured or were suspected, or in the event of any special situation where whole body
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12 counting was deemed appropriate by the Plant Health Physicist.
The procedure recommended whole body counts semi-annually for Vermont Yankee (VY) employees, and entrance / exit counts for VY employees and contractors.
The appraiser performed a selective review of the approximately 1300 whole body counts performed between September 25 -
i December 31, 1979 and August 18 - September 24, 1980.
Of the 1300 counts performed, only 1 - 2% revealed activity r
greater than the lower limit of detection (approximately 50 nCi for Co-60 in the lung). Of those, three individuals were noted to have counts suggesting organ burdens in excess l
of 10% of the Maximum Permissible Organ Burden (MP08).
The three individuals, having apparent organ burdens ranging from 20 - 25% MP0B, were subsequently found to be externally contaminated. After decontamination, recounts revealed that the indications of organ burdens were gone.
r The appraiser noted that the lower limit of detection for a lung burden of Co-60 (the principal radionuclide encounted) was about 50 nCi (4% MP08) for a ten-minute count on the old WBC. This sensitivity, when viewed in terms of % MPOB, was judged by the licensee to be adequate.
However, the appraiser noted that MP0Bs are equilibrium burdens, and most exposure situations encountered were transient in nature. The appraiser stated that the burden corresponding to the 40 MPC-hr control measure in 10 CFR 20.103 should be considered and included in WBC operator training. This point is further illustrated as follows:
Exposure Situation Co-60 Lung Burden, nCi Short term exposure to 40 MPC-hr 54 i
Short term exposure to 520 MPC-hr 650 Long term exposure at MPC (equilibrium) 1200 Minimum detectable activity with 50 licensee's old chair ~
The old chair counting arrangement marginally enabled the licensee to detect an organ burden corresponding to a 40 MPC-hr exposure. After reviewing preliminary calibration data for the new chair, the appraiser noted that its effeciency was about a factor of 20 better than the old chair.
The increased efficiency of the new chair with the present counting time will allow the implementation of a more effective ALARA program. The new system will detect a much smaller organ burden than that corresponsing to 40 MPC-hr exposure.
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13 The GAMANL-II computer program reported organ burdens below the WBC lower limit of detection as "no significant gammas in the spectrum". Such a statement was also contained in the 10 CFR 19.13 termination exposure report when appropriate.
More sensitive whole body counting technique, such as that mentioned in the previous paragraph, would enable the licensee to report information more meaningful to the exposed individual (such as the number of MPC-hr corresponding to the measured burden). The current method of reporting did not appear to be consistent with the intent of 10 CFR 19 and 10 CFR 20.
3.2.lb Operation of the Whole Body Counter The WBC was operated by a Chem and HP Assistant.
The technician who operates the respiratory protection fitting booth located in the WBC trailer was being cross trained in WBC operation to serve as a backup.
The Chem and HP Assistant presently operating the WBC had done so since its installation in mid-1976. Aside from an initial indoctrination by the WBC vendor, and occasional consultations with representatives of the licensee's corporate office, the Chem and HP Assistant was self-instructed in the operation and calibration of the old unit. He had been given training by the vendor supplying the new unit. There was no retraining program for operating the WBC equipment.
It was noted by the appraiser that little management oversight either by the plant staff or the corporate office had been exercised over the WBC operation. The corporate radiation protection organization assisted with the annual QA audit of i
the VY health physics program.
The corporate HP staff appeared to have the expertise necessary to provide operator training and retraining and to lend technical assistance in the interpretation of complex gamma spectra and in situations where external contamination was suspected. According to corporate office representatives, no requests for such assistance had ever been received from the plant staff. The appraiser noted that it would be prudent to provide technical assistance and training for the WBC operator on a regular basis.
The WBC had been relocated on September 8, 1980.
Previously, tho unit had been located in the plant. After the move, the background (sum of 256 channels) decreased from about 5000 counts /10 min to about 3500 counts /10 min. Although the new quarters represented an improvement in radiation background, they have presented problems with respect to temperature control. According to the WBC operator, temperatures occasionally exceeded 80 degrees F, a point at which analyzer gain shifts began to occur, due to the lack of adequate air conditioning
o 14 for the trailer.
The operator had no recourse other than to discontinue counting when the temperature increased above 80 degrees F.
The licensee installed a thermometer in the trailer after the appraiser noted that the operator's personal ability to sense temperatures in the vicinity of 80' degrees F was the principal temperature monitoring mechanism.
According to a licensee representative, this problem was expected to be solved prior to the summer of 1981, by which time the WBC would be located in new permanent quarters.
Routine operation of the old chair included the following operational and quality control checks:
A ten minute background count.
This count, which was normally performed on a daily basis, was processed through the GAMANL-II computer program for subsequent use in processing of individual spectra.
A ten minute count of a 150 nCi liquid Cs-137 source.
This count was performed daily if the workload permitted to ensure that the Cs-137 photopeak fell within 1 to 2 channels of its expected location.
The acceptance criterion contained in Procedure DP 0533 was 4 channels.
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A ten minute count of two 20 liter polyethylene jugs containing Ba-133, 680 nCi; Cs-137, 680 nCi; and C0-60, 250 nC1. This count was only performed occasionally.
The appraiser noted that it was performed only once during the 20 counting days between August 18 and September 24, 1980.
The purpose of this count was to determine whether the analyzer was properly quantifying-activity.
This source count was not addressed in Procedure DP 0533.
An annual calibration using the foilowing sources:
Cr-j 51, 532 nCi; Sr-85, 732 nCi; Cs-137, 1014 nCi; Mn-54,
'928 nCi and Zn-65, 825 nCi. The appraiser reviewed the vendor's certification for the standards and noted that it was traceable to the National Bureau of Standards.
Although no problems were noted with the calibration that was conducted, the appraiser noted that it was not in conformance with that recommended by ANSI N343, 3
" Internal Dosimetry for Mixed Fission Products."
l Specifically, the licensee was calibrating the WBC with a single activity level for a given nuclide, rather i
than over a range of activity from 60 - 20,000 r.Ci as recommended by the standard.
The library contained in the GAMANL-II program included the prominent gamma rays from eighteen radionuclides. While
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this library included those nuclides considered important by L
ANSI N343 in power reactor dosimetry programs, a few of the important nuclides were not included. Those were:
Ru-Rh-106, Ba-La-140, and Ce-Pr-144.
3.2.2 Conclusion - Internal Dosimetry.
The licensee had the necessary equipment and capabilities for an adequate internal dosimetry program. However, based on the above findings, improvement in the following areas is required to achieve an acceptable program:
Calibration of the whole body counter at several activity levels ranging from 60 - 20,000 nC1.
Increased emphasis on management oversight and WBC operator training and retraining.
The relationship of organ burdens to airborne exposures based on air sample analyses should be included in the training.
Termination exposure reports issued pursuant to 10 CFR 19.13 should be more definitive than "no significant gammas in the spectrum,"
i.e., a correlation with minimum detectable intake should be included.
Gamma ray spectra for Ru-Rh-106, Ba-La-140, and Ce-Pr-144, nuclides considered significant by ANSI N343, should be added to the GAMANL-II library.
The lack of a formal internal dosimetry program for non gamma-emitting nuclides (e.g., H-3, Sr-90, and alpha emitters) should be corrected.
For example, specific tasks, such as diving operations in the fuel pool, should be reviewed to determine the need for tritium bioassay.
(50-271/80-14-01) 3.2.3 Respiratory Protection Program 3.2.3.1 General The appraiser evaluated the licensee's Respiratory Protection Program, including air sampling, engineering controls, MPC-hour controls, medical qualifications, training, and equipment maintenance and issuance. This was accomplished through review of records, and through observations and discussions with licensee representatives.
16 The licensee used respiratory protective equipment to limit the inhalation of airborne radioactive materials.
Licensee representatives stated during ' initial interviews that the respiratory protection program had received NRC approval and was covered by the licensee's Technical Specification, Section 6.5.B.
The Vermont Yankee Plant had manifoi, for the distribution of compressed air from the station air supply.
Self contained breathing apparatus (SCBA) were utilized for oxygen deficient atmospheres. Both types af supplied l
ai" units were used where high protection factors were required.
Two types of air filtration canisters were L
also used by the licensee. Credit was taken for protection factors provided by the various types of respiratory protection equipment in accordance with NUREG-0041.
The respiratory protection program was defined in procedures AP 0505, " Respiratory Protection," Revision 7, dated July 11, 1980 and DP 4533, " Airborne Radiation, Contamination, Determination," Revision 4, dated August 14, 1980.
These procedures adequately addressed wearer comfort, iodine environments, breathing resistance problems, wear times, age dating of charcoal canisters, and protection factors provided by respiratory protection equipment.
The procedures included instructions for the calculation of protection factors and actions to be taken in case of an emergency while wearing respiratory protection equipment.
The Plant Health Physicist indicated that although it was not covered in procedures, a person was assigned to stand by with a SCBA on while personnel were using supplied air or SCBA devices in oxygen deficient environments.
The person assigned the chief responsibility for the i
respiratory protection program was the Plant Health Physicist. The procedures which described that assignment were very general and did not describe the Plant Health Physicist's responsibilities in detail.
The Plant Health Physicist had sole responsibility for the selection of approved respiratory protection equipment.
Procedure AP 0505 stated that only approved equipment would be used in the program.
l The station procedures adequately described the requirements for an individual to be qualified to wear respiratory protective equipment and contained limitations to be-imposed on those individuals using respiratory protection equipment. The statements were in accordance with
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The evaluation of hazards requiring respiratory protective equipment of the air filtration type was generally left to the Health Physics Assistants. More serious problems, including those having a potential for an oxygen deficient atmosphere or exposure to chemically toxic or noxious vapors, were evaluated by the Plant Health Physicist, the Fire Brigade Team Leader, or the Station Medical Service Supervisor, as appropriate.
3.2.3.2 Training, Fitting and Qualification Respirator training included videotaped lectures to instruct new personnel and retrain station personnel with regard to the proper use and care of equipment.
The fitting process itself represented the only hands-on experience provided to the student.
No provision was made in the training program to provide the trainee to gain hands-on experience in examining, donning and fit testing the respirators.
Special training was conducted for personnel who would be expected to utilize SCBA and oxygen rebreathing respirators.
The fitting was performed in a facility adjacent to the training building.
The licensee used a Nacl mist test booth. The appraiser observed several fitting operations.
Individuals qualified by the fitting booth testing program were issued a sticker to be attached to their security badge for identification by health physics personnel at check points where respirators were issued.
Through an interview with the supervisor of the Medical Services Office, the appraiser learned that the station was in the process of developing a stricter medical review policy to ensure that the considerations involved in granting medical approvals closely adhere to the recommendations of NUREG-0041.
3.2.3.3 Maintenance Equipment testing, maintenance and repair were performed by Technicians in accordance with Procedure AP 0505.
The procedure required monitoring for contamination prior to decontamination and sterilization of respiratory protective equipment.
During the observation of this process, the appraiser noted that the required monitoring for contamination was not performed.
The appraiser
18 noted that failure to conduct the required monitoring could result in an unexpected transfer of radioactive contamination from a contaminated face piece to the water used for decontamination / sterilization.
Respirators ready for re-use were stored at the Health Physics Control Point and other locations where control points were established during outages.
The storage was generally adequate.
Respirators were issued pursuant to the requirements of an RWP. A Health Physics Technician checks for the current approval card attached to the individual's security badge. This card also includes the type of respirator for which the person had received appropriate training and fitting.
3.2.3.4 Quality Assurance Based on the appraiser's review of records, and discussions with licensee representatives, it was found that there had been no determinations that the station compressed air and SCBA refill air met the Grade D breathing air requirements of the Compressed Gas Association Commodity Specifications G-7.1-1966, " Commodity Specification for Ai r. "
The quality assurance program for respiratory protection at the station was not formally organized.
The program lacked some of the elements needed to prevent the use of defective or faulty devices which were newly acquired.
For example, the air purifying devices purchased were not formally tested upon initial receipt to assure that they were functioning correctly, as specified in NUREG-0041. The masks and face pieces were required to meet Station specifications and the licensee performed superficial examinations of these devices upon receipt.
The self-contained breathing devices were tested on station personnel prior to being approved for use in the field. However, filtered manifolds received no downstream air testing when they were newly put into service or after repair. The recirculating, oxygen-supplied re-breathers were undergoing tests and had not been released for use by the various emergency team members, nor had personnel been trained in their appropriate and proper use.
No procedures existed to specify the steps to be taken in the investigation of an incident involving failure of respiratory protection. The licensee representative
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indicated, however, that there was an unofficial form which indicated the results cf any reviews performed by him or his staff, regardless of the cause or nature.
A review of the training and fitting results was performed.
Fitting booth data obtained during the period from September 1979 through March 1980 were examined.
The appraiser noted that, on several instances, indications of leakage greater than 10% were observed during-testing on subjects within the booth.
It did not appear that suitable review of these tests had been performed in order to declare these tests failures. Subsequent analysis of fitting booth testing data did not indicate j
that these personnel were re-tested.
3.2.3.5 Conclusion Based on the above findings, improvement in the following areas is required to achieve an acceptable program:
Supervisory review of respirator fit tests must be utilized to ensure that the indicated protection factor is valid before an individual is authorized to use a specified device.
Respirator training must include hands-on training i
in order to give a prospective respirator. wearer an opportunity to become more familiar with the apparatus, its proper handling, donning, and removal.
(50-27 /80-14-02) d Based on the above findings, the following program improvements should be considered:
4 A program for_the evaluation of respiratory protection effectiveness by correlating assigned MPC-hour exposures with whole body counting and other bioassay data should be formally defined.
1 Respirators should be monitored for contamination prior to decontamination / sterilization.
3.3 Surveillance Program 3.3.1 Documents Reviewed Procedure AP 0502, " Radiation Work Permits," Revision 9, dated June 30, 1980.
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Procedure AP 0503, " Establishing and Posting Controlled Areas," Revision 5, dated January 7, 1980.
Procedure DP 0530, " Health Physics Data and Information Logging," Revision 5, dated April 16, 1980.
Procedure OP 0532, " Chemistry and Health Physics Department Key Control," Revision 1, dated April 12, 1979.
Procedure AP 1500, " Health Physics Activities During New Fuel Receipt and Inspection," Revision 9, dated March 15, 1979.
Procedure DP 4530, " Dose Rate Radiation Surveys,"
Revision 6, dated March 21, 1979.
Procedure DP 4531, " Radioactive Contamination Surveys,"
Revision 4, dated March 21, 1979.
3.3.2 Scope The licensee had developed procedures which gave a clear 4
definition and basis for the radiation surveillance activities at the facility. Various procedures described.the method for performing routine and periodic surveys and surveillance in various areas around the plant. The appraiser reviewed selected records of radiation, contamination, and airborne radioactivity surveys performed between March and October-1980.
Data posted from current surveys were reviewed and discussed with licensee representatives. The appraiser observed technicians performing various surveys in several areas around the plant.
It appeared that the detail and frequency of the surveys performed by the licensee were adequate.
4 The person assigned responsibility.for the overall surveillance program at the plant was the Plant Health Physicist.~
From discussions with this individual, the appraiser determined that the surveillance process appeared to be adequate for the reporting of usual and abnormal events and that there was suitable delegation of authority for technicians in the field to be able to establish safe and immediate action levels on an ad hoc basis.
Suitable types of radiation surveys were performed for the various ionizing radiations, neutrons, airborne radioactivity, removable surface contamination, and fixed. surface contamination.
There were suitable programs for the determination of the various radioisotopes found in airborne contamination surveys,
i 21 as well as computerized assessment programs to relate airborne activity data to maximum permissible values.
4 The survey records reviewed by the appraiser adequately indicated the data considered to be pertinent as described in ANSI N13. 6-1972, " Practice for Occupational Radiation Exposure Record Systems," ANSI N13.2-1969, " Guide for Administrative Practices and Radiation Monitoring," and 10 CFR 20.
3.3.3 Instruments The appraiser reviewed various records and made several plant tours to identify and locate various radiation detection instrumentation such as area radiation monitors; continuous air monitors and portable air samplers for the determination of airborne radioactivity; portal monitors, hand and foot monitors and friskers for the identification of loose and potentially contaminated personnel and articles.
Portable radiation detection equipment for the detection of alpha, beta, gamma and neutron radiation were located, and inventories of those instruments were reviewed by the appraiser.
It appeared that suitable numbers of the instruments with appropriate ranges for normal operations were found in the portable equipment inventory of the Health Physics Department.
The Health Physics Department had a facility for the calibration of.he various portable instruments. A portable calibration unit was available for the use with area radiation monitors.
The appraiser determined that the continuous air monitors (CAM) utilized by the plant were for trend indications. A licensee representative stated that CAMS were not felt to be adequate for establishing breathing zone concentrations of 1
airborne radioactive material to which personnel were exposed.
The appraiser determined that there were suitable numbers of portable air samplers.
Portable air samplers were equipped with filter cartridge extensions in order to permit them to be placed to obtain representative breathing zone samples.
An example of such usage was observed by an appraiser and found to be an appropriate method for obtaining a breathing zone sample.
The station had recently obtained three new portal monitors for the purpose of expediting personnel frisking for contamination.
Portal monitor response is discussed in Section 6.2 of this report. A hand and foot monitor was also maintained at the Health Physics checkpoint area in order to be a back up to a recently installed new portal monitor.
RM14/210 friskers were utilized at check points around the facility where portal monitors were not practical.
The friskers were found to exist in adequate quantities and to be in appropriate
22 locations where radiation background permitted.
They were in calibration.
3.3.4 Quality Assurance Instrumentation checked out from the Health Physics Control Point could be operationally checked with a 1 uCi Cs-137 check source prior to use.
The instruments were calibrated monthly. Quality assurance was found to be adequate.
3.3.5 Records Records older than six months were microfilmed and kept in document control. A review of the various radiation survey records was made for current data kept in the Chemistry and Health Physics office and for data which had been microfilmed and was kept in the document control section.
Documents were kept in chronological order by survey area.
The data were easily reviewed and no irregularities were found by the appraiser.
Survey records were compared against various procedures in order to establish the adequacy of the records as well as the requirements of the program.
3.3.6 Conclusion The surveillance portion of the licensee's prograin was found to be of high quality and adequate to deal with the demands placed on it.
4.0 Radioactive Waste Management System 4.1 Documents Reviewed Procedure AP 0504, " Shipment and Receipt of Radioactive Materials," Revision 5, dated October 26, 1979.
Procedure DP 0640, " Chemistry and HP Department Scheduling,"
Revision 11, dated June 30, 1980.
Procedure OP 2117, " Standby Gas Treatment," Revision 6, dated July 24, 1979.
Procedure OP 2137, " Process Radiation Monitor Systems,"
Revision 5, dated December 1, 1978.
Procedure OP 2150, " Advanced Off Gas System and Air Evacuation Equipment," Revision 8, dated January 23, 1979, as amended by DI-79-55 dated November 16, 1979.
23 Procedure OP 2151, " Liquid Radwaste," Revision 6, dated March 15, 1979.
Procedure OP 2153, " Solid Radwaste," Revision 5, dated April 16, 1980.
Procedure OP 2511, "Radwaste Cask, Drum, and Box Handling,"
Revision 6, dated January 7, 1980, as amended by DI-80-9 dated April 30, 1980.
1 Procedure OP 2610, " Liquid Waste Disposal," Revision 6, dated March 28, 1978.
Procedure OP 2611, " Gaseous Radwaste," Revision 7, dated November 7, 1978.
Procedure OP 4381, "A0G Radiation Monitor Functional / Calibration,"
Revision 3, dated July 13, 1978.
Procedure OP 4383, " Stack Radiation Monitoring Calibration,"
Revision 9, dated August 23, 1979.
Procedure OP 4386, " Liquid Process Radiation Monitoring System Calibration," Revision 7, dated April 16, 1980.
Procedure OP 4388, "AE06 Radiation Monitoring System Calibration,"
Revision 6, dated April 16, 1980.
Procedure OP 4610, " Filter Testing," Revision 7, dated November 26, 1979.
[" Chemistry Log," August 20 - November 23, 1979; November 26, 1979 - March 11, 1980; March 12, 1980 - present.
4.2 General Several tours were made by the appraiser of the radwaste facility, the advanced off gas (A0G) system, and tne standby gas treatment system (SGTS). With the exception of the AnG system, all systems were noted to be the original radwaste systems present when the plant went into commercial operation in late 1972.
The Operations Supervisor had the overall responsibility for radwaste system operation. Auxiliary Operators were utilized for day-to-day operation of the system.
Chemistry and Health Physics personnel provided advice, analyzed samples of gaseous, liquid, and solid wastes, and performed necessary radiation measurements to support the radwaste program.
l 24 4.3 Gaseous Wastes The A0G system had resulted in a factor of approximately 50 reduction in noble gas release rates.
Noble gas release rates at i
the stack in the period preceeding the appraisal had typically been less than 100 uCi/sec (less than 3000 Ci/yr). The licensee 3
routinely sampled noble gases at the air ejector and at one of several points in the A0G system, depending on off gas release rates. Noble gas samples collected at the stack in a Marinelli beaker had typically not contained.any detectable activity. All sampling appeared to be in accordance with the Technical Spec-ifications.
Required filter and charcoal efficiency testing for SGTS was examined for conformance with Regulatory Guide 1.52.
Cold 00P test results (February 28,1980) indicated greater than 99%
efficiency for both A and B trains.
Other tests conducted on the SGTS, including methyl iodine collection efficiency (March 17, 1980), met the Technical Specification requirements.
Non-SGTS HEPA filters (off gas, advanced off gas, and radwaste facility) were DOP tested following filter changeout.
Filters were changed when the pressure drop became excessive (AP greater than 2").
Radwaste system filters were checked quarterly for pressure drop and annually for flow rate in accordance with OP 4610, " Filter Testing."
3 4.4 Liquid Wastes The licensee had operated the plant essentially as a "zero release" facility. That is, releases had been the exception rather than the rule. Between January 1979 and the date of the appraisal, the only liquid releases made by the licensee were 16 radwaste batches, totaling 128,000 gallons, having a fission and activation product total inventory of less than 1 mci. All of these batches were-released between August 14 and September 11, 1979, in preparation for work to be performed during the annual refueling outage. All releases were within Technical Specification limits.
4.5 Solid Waste Solid wastes were generally one of three forms: dewatered resins, compacted waste, and uncompacted waste. Dewatered resins were loaded into either an 80 cu ft liner (reactor cleanup system demineralizer resins) or a 170 cu ft liner (all other filter /
demineralizer resins), which had been pre positioned inside HN-200 or HN-100 casks, respectively.
The appraiser reviewed the licensee's copy of NRC-issued Certificates of Compliance for these casks and noted that they were current.
Vermont Yankee was listed as an authorized user.
o.
25 l
The appraiser noted from discussion with licensee representatives l
that the licensee was looking into the various solidification methods currently available, as well as non-selidification (i.e.,
the use of high integrity containers). This review of alternate methods was being conducted to enable the licensee to ship spent resins to the Barnwell, S.C., burial site after June 30, 1981.
More restrictive controls will be placed on materials received at Barnwell for burial af ter that date.
The appraiser selectively reviewed records of shipments from January 1 through September 5, 1980 for conformance with Procedure AP 0504.
In the documentation associated with shipment No. 80-48 (July 28, 1980), the appraiser noted that the total isotopic activity in the resin sample (1.42 uCi/g as determined by GeLi spectroscopy) was listed as the activity shipped (1.42 Ci) rather than the correct value of 2.73 C1.
Both values (1.42 uCi/g and 2.73 C1) appeared on the isotopic analysis printout sheet. The
(
appraiser recommended that a suitable modification (e.g., a notation of the sample concentration in uCi/g in addition to the total activity of the shipment in mci) be made on VYAPF 0504.04 to help preclude recurrence of this error.
4.6 Process and Effluent Monitoring Instrumentation The licensee's process monitoring system consisted of five liquid i
monitors (RBCCW, radwaste discharge, service water, plant discharge, and house heating boiler) and three gaseous monitoring systems (air ejector, A0G monitors at several points, and the plant stack). The appraiser noted the location of most monitors during a plant tour. The house heating boiler monitor and most of the I
A0G monitors were not visited.
Liquid process monitors contained NaI detectors.
The gaseous process and effluent monitors also contained NaI detectors, except for the off gas monitor, which consisted of three ion chambers.
The appraiser reviewed the calibration records for the liquid and gaseous monitors. With the exception of the off gas monitor, all monitors were calibrated quarterly with various physical configurations of radionuclide sources.
The sources did not appear to be traceable l
to the National Bureau of Standards.
The off gas monitor was l
calibrated annually with an external source in accordance with Technical Specifications.
1 The stack monitor (a beta scintillator) was calibrated quarterly with two point sources (Ba-133 and Cs-137) which were referenced back to a Xe-133 calibration performed by the vendor prior to the installation of the monitor.
The appraiser noted that this calibration methodology is not consistent with that intended by
26 ANSI N13.10-1974, " Specification and Performance of Onsite In-strumentation for Continuously Monitoring Radioactivity in Effluents."
The appraiser noted that procedure OP 4511 would have to be l
modified if a stack monitor calibration consistent with the ANSI t
standard is adopted. The standard would be met if known quantities of noble gases (the parameter monitored) are introduced into the t
detector while in place.
The appraiser accompanied a Chem and HP Assistant during the changeouc of the stack particulate filter and charcoal cartridge.
The appraiser was using Figure III of Procedure OP 2611 to follow the sample changeout.
It was noted that Figure III does not describe the present stack monitoring system (e.g., the monitored iodine cartridge is no ic.1ger in place).
The appraiser noted i
that this figure needs to be revised to accurately depict the current system.
The appraiser reviewed monitor sensitivities, particularly those i
monitoring actual discharges to the environment, and noted that the sensitivities were not consistent ANSI N13.10-1974. Specifically, the lower limit of detection calculated by the appraiser, using appropriate calibration curves for the stack monitor and the plant liquid discharge monitor, was about 1.5 E-6 uCf/ml for each instrument. The ANSI Standard, however, recommends a lower limit of detection of SE-7 uCi/cc for Xe-133 for gas monitors and 3E-7 uCi/mi for Co-60 and 4E-7 uCi/ml for Cs-137 for liquid monitors.
The appraiser noted that the licensee should investigate means for increasing the sensitivity of these monitors to meet the values contained in ANSI N13.10.
^
4.7 Conclusion The licensee had the necessary equipment and personnel to operate the radwaste system such that releases were, in general, maintained as low as reasonable achievable.
Based on the above findings, the following matters should be considered for improvement of the program:
Modify form VYAPF 0504.04 to preclude inserting incorrect values for the activity concentration (uCi/g) and the total activity shipped (mci).
Develop and implement a stack monitor calibration procedure l
which employs noble gases circulated through the detector 4
.while on line.
Update Figure III of Procedure OP 2611 to depict the current stack monitoring system.
f l
l i
i
-27 Investigate the means for increasing effluent monitor sensitivity il by a factor of 3 - 5 to be consistent with the levels reflected
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in ANSI N13.10-1974.
5Property "ANSI code" (as page type) with input value "ANSI N13.10-1974.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..0 ALARA 5.1 Documents Reviewed Procedure AP 0501, " Radiation Protection Standards," Revision 5, dated August 17, 1979.
Yankee Atomic Electric Company Technical Administrative
-Guideline No. 4, Revision 7.
Report of the Vermont Yankee Personnel Radiation Exposure Task Force, dated September 9, 1980.
l 5.2 Plant ALARA Program The appraiser reviewed documents, procedures, and reports to i
determine the extent to which the ALARA program conformed to Regulatory Guides 8.8 and 8.10.
It was found that the ALARA I
effort was fragmentory and in many aspects it did not conform to the Regulatory Guides. A substantial plant level effort at consideration of ALARA was reflected in the Vermont Yankee Personnel Radiation Task Force Report of September 1980, however, there was j
little evidence of corporate level involvement.
Although there was a management commitment to an ALARA principle, there was no policy statement which reflected the guidance of Section C.I. of Regulatory Guide 8.8.
The station did not have written ALARA procedures or instructions l
for ALARA review.
However, references in various station procedures, such as AP 0501, did indicate that exposure should be kept ALARA.
The training program, an ALARA lecture and a commercial videotape discussed the principles of ALARA.
i The Plant Health Physicist stated during discussions with the I
appraiser that he had conducted reviews of many of the engineering projects with ALARA considerations in mind. However, no formal documentation of such reviews was maintained. ALARA recommendations made by the Plant Health Physicist were often presented to review groups such as the Plant Operations Review Committee.
p The lack of a formalized program committed to ALARA precludes discussion of the integration of ALARA with the radiation program' in a formal sense.
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28 It appeared that the facilities and equipment provided for the purposes of radiation protection, including the instrumentation for measuring radiation levels are adequate to support most aspects of an adequate ALARA program at the station. No formalized documents exist to describe procedures for incorporation of that radiation survey and exposure data into an on going ALARA program.
5.3 Conclusion Based on the above findings, improvement in the following areas is required to achieve an acceptable program:
A formal ALARA program that conforms to the guidance in Section C of Regulatory Guide 8.8 and to Regulatory Guide 8.10, including both a corporate and a plant component, must be developed, documented and implemented.
Full-time professional level manning plus the necessary supporting personnel must be provided to operate the plant ALARA program. The necessary corporate level manpower commitment must also be provided.
Procedural action levels in radiation work permit review, planning and job review, consistent with good ALARA principles for individuals, as well as the collective worker exposure group, were needed.
(50-271/80-14-03) 6.0 Facilities and Equipment 6.1 Radiation Protection Facilities The licensee performed sample counting generally in two areas -
the counting room and the HP Control Point.
The counting room contained a 20% GeLi detector which was coupled to a 4096 channel analyzer and a 3" x 3" NaI well crystal which was coupled to a scaler for gross gamma counting. A liquid scintillation counter was located in another room.
These counting facilities were used primarily for analysis of samples associated with the chemistry program.
However, the GeLi system was also routinely used to analyze air samples, and other samples collected as part of the radiation protection program.
Routine counting of radiation protection related samples (air samples, smear surveys, nasal swabs) was accomplished with three GM scalers, one of which was equipped with a sample changer.
The calibration facility was located in a dedicated room (approximately 30' x 30') in the Reactor Building.
Primary calibration sources
29 for survey instruments included: 50 Ci Cs-137, 25 mci Co-60, and 5 Ci Am-Be. A wooden table was used to minimize scattering.
No problems were noted with either the facility or the sources contained therein.
The personnel decontamination facility contained three showers and was located adjacent to the HP Control Point.
The area was kept clean and available for use. Equipment decontamination facilities were located in the control rod drive laydown area and in a room near the personnel decontamination showers.
Laundering of protective clothing was accomplished by two dry cleaning units located on the 252 ft level of the Turbine Building.
No particular problems were noted with the operation of these units.
Respiratory protective equipment was laundered and stored at the HP Control Point. The appraiser noted that it was not appropriate to handle potentially contaminated equipment in an area where samples were counted because of the potential for cross-l contamination and possible increase of counter background.
l Normal (non-outage) change room space appeared adequate in terms of size and proximity to both the HP Control Point and the personnel decontamination facility.
During the outage which began September 27, 1980 it was noted that the licensee had established several additional change areas, e.g.,
at the 252 ft, 318 ft and 345 ft elevations of the Reactor Building.
6.2 Radiation Survey Equipment As discussed in Section 3.3.3 of this report, the number and types of survey instruments maintained by the licensee appeared adequate to ensure that appropriate health physics coverage could be maintained for the various tasks being conducted during the outage.
.The HP Control Point was used as the point of entry and egress from the radiation control area. Adequate frisking equipment, including a portal monitor, was on hand at the point of egress.
The appraiser checked the response of the portal monitor (which contained large liquid scintillators) to point sources having activities ranging from 0.03 to 1.2 uCi and gamma energies ranging from 0.1 - 1.3 MeV. With few exceptions, the monitor failed to alarm when these sources were walked through.
Some directional sensitivity (i.e., exiting as compared with entering) was apparent.
l The inability to detect a point source of activity, such as might i
be present on the soles of an individual's shoes, was judged to i
be somewhat of a drawback with the portal monitor. Other units, which were located at the egress from the Turbine Building and at 1
n
r 30 Security Gate No. 2, behaved in a similar fashion. The monitor did, however, readily detect distributed sources of activity such as the residual activity on laundered protective clothing.
Licensee representatives indicated that they would investigate the variations in monitor response.
During a facility tour, the appraiser and a licensee representative compared readings obtained with their respective survey instruments.
The appraiser's survey instrument had been calibrated with an NBS-traceable source. A licensee representative also exposed the appraiser's instrument (a cutie pie ion chamber) to known exposure rates associated with the licensee's calibration sources. The following results were obtained:
a.
Instrument Comparisons Licensee's Appraiser's Area Surveyed Instrument Instrument I
scram discharge piping 13 mR/hr 14 mR/hr hot spot associated with above 36 34 t
at entrance to solid waste 11 11 drum storage area b.
Exposure to Licensee's Calibration Source Exposure Rate Response of i
Attributed to Appraiser's Source Calibration Source Instrument i
75 mci Co-60 2.0 mR/hr 2.1 mR/hr 75 mci Co-60 20 23 75 mci Co-60 100 110 50 C1 Cs-137 1700 1700 I
The appraiser also toured facilities related to the chemistry program. Reactor Building and Radwaste Building sample sinks appeared to be those originally installed in the facility and most sample lines were not shielded.
In the chemistry area, the appraiser witnessed collection of samples from the Turbine Building sump, the closed cooling water system, and from the condenser circulating water.
The stack charcoal and particulate filter changeout was also observed. No problems were noted.
6.3 Protective Equipment Because the refueling outage began during the appraisal, the appraisal team was able to observe the licensee's increased stock of protective clothing necessary to support outage work.
No problems were noted. Adequate supplies of temporary shielding i
were available. Two large HEPA/ charcoal - filtered ventilation l
e...
31 systems were noted to be in use. These temporary systems had been installed as part of the engineering controls required by 10 CFR 20.103.
6.4 Conclusion In general, the licensee had the necessary facilities and equipment to adequately support the health physics program.
Based on the above findings, the following matters should be considered for improvement of the program:
An alternate location to the HP Control Point for mask decontamination should be chosen.
Sensitivity of the portal monitors should be optimized.
7.0 Exit Interview The Appraisal Team met with licensee representatives (denoted in Annex A) at the conclusion of the appraisal on October 3, 1980.
The Appraisal Team summarized the scope and findings of the appraisal. The findings were grouped into two categories:
a.
Significant appraisal findings are summarized at the conclusion of the applicable Sections or Subsections of this report and are contained in Appendix A to the letter forwarding this report.
The licensee's response to these findings, to be submitted in writing, will be reviewed upon receipt.
b.
Findings of lesser significance, but which are considered instrumental to improvement of the licensee's program, are summarized at the conclusion of the applicable sections or subsections of this report.
)
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