ML19209A824

Responds to NRC 790430 Ltr Re Violations Noted in IE Insp Repts 50-277/79-07 & 50-278/79-06.Corrective Actions:Survey Conducted to Formulate Exposure Records

ML19209A824
Person / Time
Site:	Peach Bottom
Issue date:	05/18/1979
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19209A820	List: ML19209A824
References
NUDOCS 7910050443
Download: ML19209A824 (3)

Text

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PHILAD ELPHI A ELECTRIC .COM PANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. D ALTROF F stacTesc Pao crion May 18, 1979 Re: Docket Nos.: 50-277 50-278 Inspection No.: 50-277/79-07 50-278/79-06 Mr. George H. Smith, Chief Fuel Facility & Msterials Safety Branch U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Smith:

Your letter of April 30, 1979 forwarded combined Inspection Reports 50-277/79-07 and 50-278/79-06. Appendix A to your letter addresses one item which did not appear to be in full compliance with Nuclear Regulatory Commission requirements. The item is categorized as an infraction and is restated below with our response.

10 CFR 20.201(b), " Surveys," requires that such surveys be conducted as may be necessary to comply with the regulations contained in each section of Part 20. A " survey," as defined in Paragraph 20.?01(a), means "an evaluation of the radiation hazards incident to production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.

When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive materials present."

Contrary to this requirement, during the period from January through December, 1"78, evaluations adequate to assure 79100 k. .

1127 OSO

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Mr. ,Coorge H. Smith Page 2 compliance with 10 CFR 20.101 were not made when accumulated daily Thermoluminscent Dosimetry (TLD) badge results were discounted and the monthly TLD badge results used in determining quarterly accumulated exposure, when no factual basis for discounting the accumulated daily TLD badge results had been identified.

RESPONSE

Philadelphia Electric Company (PECo) did conduct surveys and evaluate radiation hazards in accordance with 10 CFR 20.201(a).

10 CFR 20.201(a) refers to performing an evaluation of the radiation hazards to which personnel might be or are being exposed (i.e. potential or actual exposure rate). l A " survey" would accomplish the following:

1. locate sources of radiation hazard

2. determine radiation hazard levels

3. determine concentrations of radioactive material.

This information would then be used for an evaluation of radiation hazards to personnel and such evaluation would be used to establish a plan of action to minimize personnel exposure. By contrast the dosimetry program determines the personnel exposure after the fact.  !

PECo. has variods techniques available for determining personnel exposure. The techniques of concern are the " daily in-house" program and the monthly vendor processed program, t Philadelphia Electric Company has consistent'.7 applied the monthly vendor processed data as the official expi are of record. l This vendor meets the performance requireme.:s of standards  !

developed by the Health Physics Society and the American National l Standards Institute and Regulatory Guides of the Nuclear d Regulatory Commission. In addition vendor data is available to  !

demonstrate initial and continuing c o mp li an c e with performance j testing requirements as specified in draft ANS N13.11 " Criteria for Testing Personnel Dosimetry Performance."

I The daily in-house program as currently structured was never intended to qualify as a source of official exposure records.

The primary purpose of the daily in-house program is for dose management during the interim between the monthly vendor supplied i reports. Because this system was designed for in-house  ;

unofficial dose monitoring purposes, it has not been subjected to a quality control p rogram to the degree that one would expect for  !

an official record system. The daily in-house system was not l I

intended for record use, but was used in managing exposures below site administrative guides.

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'}db . ,C p o r g t H. Smith Page 3 The monthly accumulation of the daily in-house data has been applied to the official record in instances where there is sound An example basis for not using the monthly vendor supplied data.

would be a lost vendor badge.

Philadelphia Electric Company recognizes a failing in the radiation protection program in that opportunities were lost for comparing dosimetry data. These comparisons could have led to improvements in the daily in-house program. The Philadelphia Electric Company does recognize the concern of the NRC regarding the discrepancies in thn dosimetry data. We have made an evaluation of our daily dosimetry system and we have isolated several factors which contributed to the consistantly high readings observed in this system. We are currently addressing the resolution of these problems which will require computer software changes, TLD reader hardware modifications and associated administrative changes. We believe that the resolution of these items will reduce the magnitude of the discrepancies between the monthly and daily programs. We expect implementation of these system changes to be complete by September of 1979. In addition, we vill be more conscious of discrepancies between the daily and monthly radiation exposure data.

We will continue to consider the monthly pro 3rra as the source of official exposure data. If for valid re sons other information such as that derived from the daily program or from survey data is considered more representative, then that data vill be incorporated into the official records.

Very truly yours, g.w,p y up

,s. / Lit =,q-1127 052