ML19308C241
| ML19308C241 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/29/1979 |
| From: | Jay Collins NRC - TMI-2 OPERATIONS/SUPPORT TASK FORCE |
| To: | Heward R RADIOLOGICAL CONTROLS |
| References | |
| NUDOCS 8001220191 | |
| Download: ML19308C241 (2) | |
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PSB r/f NOV 2 91979 TMI r/f p r/f CQ.ENTRALFILE)
I NRC PDR DOCIET MIDERER 50-320 LOCAL PDR JTCOLLINS Mr. Richard Mausrd Maasser 8
i Radiological Centrols F.O. Boa 480 Middletsua, PA 17057 1
Dear Mr. Howard
Subject:
Radiation Protection Flaa, Submittal 11/21/79 We have reviewed the subject document and attached our substantative comenents, which we believe need to be considered before you submit j
your final plan to us. We acknoerledge that the incorporation of these connants may cause a delay in providing us this final plan by the agreed upon date of Eevember 30, 1979. In view of this, we will provida 1
you an eatension to December 5, 1979.
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Sincerely, I
John T. Collins Deputy Director TMI Support Enclosure As stated cc w/enci:
l J. G. Herbein, Vice President Neclear Operations E. G. W=11===, Benager Licensing C. F. Millae, Measser Support Services and Logistics J. B. Legaa, Super $atendent Unit 2 G. A. Eunder, Unit 2 Superintendent - Techniesl Support J. J. Colita, Manager Flaat Engineering R. F. Wilace Director TMI-2 Basovery, Acting I.1. Fiafreek, Jr.
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G. F. Treerbridge, Esquire J. B. TAah====, Esquire Ms. M ry v. Se. e i, Cb.ir,e,
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_ _l DATE NRC Form J18 (RI) (4 79) NRCM C2040 Q U S. GOVERNMENT PRINTING OFFICE: 1979 289 368 g0g3gggj y T-
No'J53h Mr. Richard Howard 2
R. Vollmer D. Neely C. Smith T. P.urphy J. White i
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NRC Form 318 (RI) (4 79) NRCV 02040 Q U.S. GOVERNMENT. PRINTING OFFICE: 1979-289 368,.
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p1 November 28, 1979
,s MEMORANDUM FOR:
J. T. Collins, Deputy Director, TMI Support FROM:
J. R. White, Senior Radiation Specialist
SUBJECT:
RADIATION PROTECTION PLAN, SUBMITTAL 11/21/79 The November 21, 1979 submittal is much improved over the previous effort. The following is my assessment and coments on this latest submittal:
a.
Chapter 1 - Introduction.
The only objective of the RPP is the implied goal to keep exposures to both station and off-site personnel as low as reasonably achievable. While this is a worthwhile endeavor there is no tangible evidence, description or definition of the licensee's ALARA program, i.e., there is no criteria, guidelines, procedures, specifications, etc., that define the station's ALARA program.
Chapter 5.1 ALARA Program does not describe any existing program but rather indicates that a program will be implemented in the future based on something called "the ALARA philosophy," which is also undefined.
Recommendations - Specify the following objectives and the radiation protection systems required to achieve them:
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1.
Control Hazards to Avoid Acute Radiation Accidents; 2.
Maintain Exposures within the Regulatory Requirements;
- and, 3.
Maintain Exposures as low as Reasonably Achievable.
The type of processes that may have to be addressed to meet such objectives are: Job Safety Analysis, Indepedent Review System, Procedure Development a'nd Implementation System, Personnel Selection, Training, and Qualification, Worksite Control System, Hardware Evaluation and Analysis, Human Factors Consideration Process, etc.
b.
Chapter 2 - Radiological Controls Department.
Coments - It should be assured that the organization and personnel qualification cited here are in agreement with the proposed Technical Specifications.
c.
Chapter 3 - Standards for Radiation Exposure Control.
Coment - Section 3.4 indicates that ALARA administrative guidelines will be developed.
Same comment as Item a.
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November 28, 1979 d.
Chapter 5 - Radiation Exposure Control. Same comment as Item a.
Section 5.2.1 " Restricted Areas" - It should be assured that such a procedurq is specified in the RCPM. Currently we are only aware of AP 1050, " Control of High Radiation Areas."
Section 5.3, " Respiratory Protection Program" appears to be a policy statement but it is not in accord with Regulatory Guide 8.15.
At this time there is no policy statement addressing Respiratory Protection as is required by 10 CFR 20.103.
It is recommended that such a policy statement be incorporated into the RPP.
e.
Chapter 6 - Radiation Exposure Monitoring Program.
Section 6.1, " Policy" indicated that the RCPM addresses personnel responsibility in regards to wearing dosimeter devices. We are unable to find such procedures as specified.
l f.
Chapter 7 - Radiological Control Training.
It is recommended that this section address personnel selection, training and qualification, since all of these elements are closely related and pertinent to meeting the program's goal.
g.
Chapter 8 - Radioactive Materials Program.
This chapter does not describe a program but rather specifies some procedural items that are expected to'be implemented.
It is recommended that the program be des, Sed here including a description of the quality assurance 5ecam as required by 10 CFR 71.
h.
Chapter 9 - Radioactive Waste 0,isposal.
This subject is a major activity at TMI and as such should be described more fully than a single sentence stating that the regulatory requirements will be met.
J. R. White Senior Radiation Specialist cc:
D. Neely G. Smith T. Murphy e
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