DEFENSE NUCLEAR FACILITIES SAFETY BOARD July 29, 1994 MEMORANDUM FOR:G. W. Cunningham, Technical Director COPIES: Board Members FROM: J. W. Troan SUBJECT: Report on the Radiation Protection Program at the Idaho National Engineering Laboratory 1. Purpose: This memorandum documents the Defense Nuclear Facilities Safety Board (DNFSB) technical staff and outside expert assessment of the Radiation Protection Program at the Idaho National Engineering Laboratory (INEL). The review was based on a visit to INEL on March 7-11, 1994. 2. Summary: The Radiation Protection Program at INEL was reviewed at the site and facility level for two specific facilities: the New Waste Calcining Facility (NWCF) at the Idaho Chemical Processing Plant (ICPP) and the Radioactive Waste Management Complex (RWMC). Based on the site and document reviews, the program was considered satisfactory. However, some weaknesses were identified that indicate the adherence to requirements are in need of improvement. Highlights of the program's strengths and weaknesses include:  The organization is structured appropriately to support implementation of an effective Radiation Protection Program.  Full implementation of the Radiological Control Manual is planned for 1996, and not this fall as had been stated by DOE Idaho and Westinghouse Idaho Nuclear Company (WINCO) personnel at the July 1993 Public Meeting.  The Order assessment process sometimes lacked rigor and effective management.  Field implementation of radiological work practices do not consistently support maintaining radiation exposure As Low As Reasonably Achievable (ALARA).  The level of knowledge acquired through General Employee Radiological and Radiological Worker Training appeared satisfactory for basic understanding. The current training of Radiological Control Technicians and their Supervisors was not as effective. Moreover, implementation in the field does not always reflect good radiological work practices commensurate with the training. The ICPP NWCF Facility Representative training and qualification process is in progress. This training and qualification process may be impacting available resources for oversight of the activities at the NWCF, and it was not apparent that appropriate consideration was given to this situation. 3. Background:DOE Order 5480.11, Radiation Protection for Occupational Workers, DOE Notice 5480.6, Radiological Control (Radiological Control Manual), and DOE Order 5400.5, Radiation Protection of the Public and the Environment, establish the requirements for radiation protection for workers, the public and the environment. These standards were used in the assessments of the program, and of employee work practices, training and knowledge level. The review included a spot check of compliance with DOE Orders, including the Radiological Control Manual (Manual), and other applicable standards. Compliance was assessed from two perspectives. First, compliance was reviewed from the administrative or procedural standpoint. Second, an adherence based assessment of compliance was made that consisted of tours of work areas and discussions with operators. The review was conducted by: Lester Clemons, Jim Troan, DNFSB Staff, Ned Dietrich and Ted Quale, Outside Experts. 4. Discussion/Observations: a. Organization: The organization at the INEL is structured in a manner that supports the implementation of an effective Radiation Protection Program. It was encouraging to note a commitment to consistency among the contractors and DOE-Idaho (DOE-ID). Management appeared to be committed to developing ideas that will improve the radiological control program, and has established committees that help to facilitate program uniformity across the site. b. Radiological Control Manual Implementation: INEL contractors are progressing toward implementing the requirements of the Manual. However, full compliance is not planned to be achieved until 1996. Overall, the INEL's plan to accomplish Manual training is consistent with the DOE Implementation Plan for DNFSB Recommendation 91-6. Progress and status of implementation is given in Figure (1) and Attachment (1). Although the Manual implementation schedule is in agreement with the Recommendation 91-6 Implementation commitment, it is inconsistent with that presented by DOE and WINCO at the July 13, 1993, Public Meeting on Health and Safety Issues at the INEL. Specifically, a Deputy Manager from DOE-ID indicated that implementation plans were issued and tracked, and that all actions were to be completed before November 1994; and the WINCO President stated that the date of full implementation of the Radiological Control Manual will be November 1994. Funding for implementation of the Manual was described by DOE-ID as transparent to DOE-HQ. In the case of WINCO, it appeared that implementation was being accomplished within the existing budget and no further funding requirement requests were expected. However, during a briefing, EG&G identified a need for some additional funding, and stated that information regarding these requests would be forthcoming. These additional requirements appeared to be unexpected by DOE-ID personnel. The following highlights the review of the Manual's implementation: 1) Contractor specific Manuals were reviewed, and it was noted that contractors that relied on other contractors for radiological control services had or were developing Memoranda of Understanding; 2) In some of the Manual Implementation Plans, the technical justification for "compensatory measures" and "not applicable" items were not always provided; 3) The Protection Technology Incorporated (PTI) Manual did not include Article 514, Area Monitoring Dosimeters, and Article 515, Nuclear Accident Dosimetry; and 4) The results of DOE-ID's Manual compliance assessment were not presented. It was stated that DOE-ID is not under Defense Programs (DP), and it was not considered that this would be of interest to the DNFSB staff. c. DOE Order Compliance: Compliance with the DOE Manual and related DOE Orders appears to be acceptable but some weaknesses were identified. For example: 1) DOE oversight of the Management and Operations (M&O) contractors' order compliance process appears to be weak in that DOE-ID personnel were unable to discuss the contractors' status of assessing compliance with DOE Order 5400.5. The methodology presented did not utilize the current order compliance philosophy, and the DOE-ID personnel were not able to discuss whether a compliance assessment had been performed by the various M&O Contractors on this order; 2) DNFSB Staff review of WINCO's Implementation Plan for DOE Order 5400.5 identified that WINCO considered the Order's Chapter IV, Residual Radioactive Material, as "Not Applicable." The justification for this position was that WINCO does not lease land or buildings back to the public. However, the scope of this chapter goes beyond this concern; and 3) One contractor assessed compliance with the DOE Manual on an article-by-article basis rather than on a requirement-by-requirement basis. d. ALARA Program: It appears that mechanisms are in place to facilitate communication and coordination of the ALARA program among facilities within each contractor, and among the various contractor and government organizations at the INEL. Highlights of the review include: 1) DOE-ID has an ALARA program only for personnel assigned to the Radiological and Environmental Services Laboratory (RESL) project. This is reportedly based on the premise that these are the only personnel who do radiological work. However, since DOE-ID personnel routinely enter other radiological areas on the site, it is not clear why this program does not include other DOE-ID personnel (i.e., Facility Representatives); and 2) an ALARA review was discussed, and it appeared that the process was effective in identifying a problem associated with dose estimation. However, the process did not recognize nor take corrective actions relative to the cause of the problem (inadequate engineering to reduce exposure). In fact, when questioned on this point, the responsible Radiological Control Manager initially stated that, as long as such problems were corrected at any point by the ALARA process, there were no deficiencies to be corrected. After additional discussions, the Radiological Control Manager concluded that additional investigation was warranted. e. Radiological Control Training: Training was discussed, and DOE-ID personnel reported that DNFSB Recommendation 91-6, Radiological Training for General Employees and Radiological Workers, has been completed; and Radiological Control Technician training to meet the Manual's training requirements is expected to be complete by December 1994. Highlights include: 1) The Visitor Orientation video tape appeared to be outdated. For example, several actions recommended by the tape could result in a significant increase in personnel exposure, if followed during an evacuation due to an inadvertent criticality; 2) Overall, those interviewed in the Radiological Worker I and II, and the General Employee categories appeared to be better trained to the requirements than did those qualified as Radiological Control Technician and Supervisor. The Radiological Worker and General Employee personnel appeared to have a good practical understanding of radiological principles and controls, while some Radiological Control Technicians did not have an appreciation for applying theory to practice; and 3) In a recent incident, workers exceeded the weekly administrative radiation exposure control level. Although, the workers had just completed Radiological Worker (RW) II retraining as recently as October 1993, they did not adequately employ basic good radiological work practices. The cause of these deficiencies is not clear (e.g., training program, retention, work culture). f. Work Procedures: Select procedures were reviewed by the Staff and, in general, the procedures provide adequate guidance. A Westinghouse Government-Contractor (GOCO) effort has resulted in Radiological Control Work Practice manuals that should be of benefit to the INEL and other sites. Highlights include: 1) The staff noted an inconsistency among contractors in the requirements for respiratory protection, as well as some errors in procedures. For example, an error was noted in EG&G Procedure 10.3, Airborne Radioactivity Monitoring, dated 1-28-94, and Document Revision Request (DRR) dated February 14, 1994. These documents gave equations for computing High Alarm Setpoint that are not correct; and 2) Other procedural discrepancies were noted, and ranged from inconsistencies with the Manual to limited details for implementing the program. For example, EG&G Procedure 10.5, Personnel Dosimetry and Response to an Accidental Criticality, did not give detailed guidance for managing the application of Field Correction Factors, and set the threshold level for requiring a neutron dosimeter above that specified in the Manual. g. New Waste Calcining Facility: A review and tour of the New Waste Calcining Facility (NWCF) were conducted. Highlights include: 1) Maintenance of radiological controls was deficient in some areas. For example: a posted fixed contamination area in a stairwell had paint chipping from the walls; bags of radioactive waste were not appropriately marked; yellow herculite on walls adjacent to a contamination area was not draped and was falling into the area; and a headset for two-way communications was lying in the contamination area; 2) The Manual's requirements for posting and use of personal protection equipment were not met at a valve operating station; 3) air flow reversal between rooms in the NWCF may occur when there is a total loss of electric power. Emergency electrical power supplies are available to prevent this event. However, emergency power failed to come on-line during a recent power outage; 4) air monitoring for alpha radioactivity in the building is accomplished by one continuous air monitor. The technical basis for its placement was not discussed and will have to be examined by the Staff; and 5) conversations at the NWCF revealed that Facility Representative training and qualification has been given a high priority, and, therefore, a significant amount of the representative's time is dedicated to the effort. It is the Staff's understanding that this training and qualification process may be impacting available resources for oversight of the activities at the NWCF, and it was not apparent that appropriate consideration was given to this situation. h. Radioactive Waste Management Complex: A review and tour of the Radioactive Waste Management Complex (RWMC) were conducted. Highlights include: 1) The existing method of stacking drums of waste in the air supported buildings in the RWMC does not allow for inspection of the drums for leakage or other deterioration, and is not in keeping with good practice; 2) Radiation surveys performed in the high level waste pit area, an area controlled as a high radiation area, were not documented as required by the Manual; 3) The postings in radiation areas to alert personnel to the presence of radiation and radioactive materials in order to aid in minimizing exposures did not always appear effective; and 4) Although several individuals are involved in operations in the high level waste pit area where dose rates can reach several rem per hour, standard actions are not taken to control personnel exposure and preclude unnecessary exposure. 5. Future Staff Actions: Staff actions are expected to include the following: a. At the EG&G RWMC: 1) Evaluate workplace conditions and compliance for posting radiation signs in appropriate locations. Specifically, monitor for the use of radiation sign postings where there is the potential for workers to receive non-productive exposures; and 2) Evaluate the application of neutron dosimeter field correction factors. b. At the WINCO NWCF: 1) Observe an emergency drill, such as a radioactive liquid spill drill complicated by an injured person; 2) Evaluate the technical basis for air monitoring; and 3) Evaluate the results of corrective action taken to increase the reliability of the emergency power supply. c. At the various contractor levels: 1) Verify that Memoranda of Understanding (MOU) between parties are established for Manual requirements as generally identified by the Manual Implementation Plans; 2) Review select Manual compliance assessments that report partial compliance; 3) Monitor progress of incorporating "lessons learned" from the occurrence where personnel exceeded administrative control level into tank farm conduct of operations; and 4) Review implementation and assess effectiveness of Radiological Control Training.