ML19341C552
| ML19341C552 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/24/1981 |
| From: | Arnold R METROPOLITAN EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| LL2-81-0054, LL2-81-54, NUDOCS 8103030737 | |
| Download: ML19341C552 (48) | |
Text
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Metropolitan Edison Company F
Post Office Box 480 e
Middletown, Pennsylvania 17057 Writer's Direct Dial Number February 24, 1981 LL2-81-0054 t@ll m N/l'9 g 01987 g,{9 Harold R. Denton, Director 2
.0ffice of Nuclear Reactor kagulation E
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- E0 United States Nuclear Regulatory Commission Washington, D.C.
20555 V
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Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Special Panel Report In response to the Special Panel's Report, we prepared a Radiological Controls Program Management Plan. That plan was submitted to you by my letter of February 8, 1980, and we have been providing you quarterly status reports on progress in completing items in the Plan.
The current status of the Special Panel items which are addressed in our Management Plan is refle:ted in Attachment 1.
We have made substantial progress in many areas of our Radiological Controls Program even though the schedule for upgrading activities has required modification periodically over the last 15 months.
Presently, we have essentially completed all items resulting from the Special Panel's review except for two.
o Beta Monitoring Capability -- Extensive effort has been expended on tnis item, and we think the end is in sight.
Completion of the item has taken considerably longer than anticipated because an adequate system to meet our requirements was not available. We have worked extensively with several contractors to identify, test and prove an advance system which will meet our monitoring requirements.
The effort has included procurement of National Bureau of Standards certified sources for use in the research effort necessary for selecting a system.
The evaluations of the most promising systems were completed in January 1981. We anticipate it will probably be the end of 1981 before the new system is fully available.
In the interim, adequate beta monitoring capability is available aitnough it does not have the versatility of the system under development.
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s-o Radiological Control Procedures -- Although we have completed essentially all procedure revisions, it has taken longer than i
initially scheduled for several reasons. These reasons included difficulty in recruiting necessary technical personnel for staffing the Radiological Controls organization, and thac effort's impact on the time and attention of the management personnel, and a placing i
of a higher priority on ensuring work being done in the field was being accomplished safely. This effort was also impacted by our decision not to pursue obtaining a technical specification change to uncouple the review of Radiological Control procedures from the Plant Operations Review Committee (PORC) until we had completed other efforts related to the revision of administrative controls as part of the preparations for the restart of Unit 1.
Additional revisions to these procedures based upon experience with their use is continuing.
Even though we believe we have made substantial progress with our Radio-logical Controls Program upgrading, particularly in program design, staffing and organization, we continue to work on improving the implementation of the program. We currently believe we have sufficient control of work activities that our Radiological Controls Program can :dequately support an expanded clean-up effort. Our efficiency in doir.g radiological work should improve as the work force gains additional experience in working in very demanding radiological environments, but we are confident we can provide adequate protection for their health and safety with our current program during the learning period which must take place with an expanded worker force.
Consistent with Recommendation 3 of the Special Panel that, "the adequacy of the upgraded program be independently assessed prior to initiation of l
major recovery activities", we request that you again utilize the Special Panel for such an assessment of our Radiological Control Program. We suggest that the assessment be conducted sanetime during the month of April.
Sincerely, R. C. A no d Chief Operating Executive RCA:dms Attachment (1)
Enclosure (1) cc:
L. Barrett, Deputy Program Director B. J. Snyder, Program Oirector-TMI Office a
Status of Management Plan Committed Actions to Resolve the NRC Special Panel Findings This attachment is provided to summarize the actions cannitted to in the Management Plan for Three Mile Island Unit 2 Radiological Control Program in response to the NRC Special Panel Findings (NUREG 0640) and to present the current status of those canmitments.
The format used for this presentation is as fol10ws:
1., II., III., etc. Special Panel Canment (taken from NUREG 0640)
A., B., C., etc. Management Plan Response (to the specific Special Panel Comment) 1.
Committed Action (as originally stated in the Management Plan) 2.
Completed Action (the actions taken to satisfy, in whole or part, the cannitted action as stated in the Management Plan) 3.
Commitment Status (a states oi the efforts to accomplish the incomplete committed actions) 4.
Revised Commitment (if applicable, a redefinition of intended corrective actions to resolve incanplete comnitted actions)
s I.
Special Panel Comment: Management Commitment in Support of Radiation Safety Program On the basis of interviews with GPU/ Met-Ed senior management and others in supervisory positions, the Panel confirmed that a serious morale and attitude problem existed in the radiation safety organization.
Several personnel, both in operations and radiation safety, characterized personnel in the organization as being treated as "second class" citizens.
l As an exam,ple, first line radiation safety foremen were not convinced that they had the management support to stop operations in the interest 4
2 of worker safety.
(Panel Comment: GPU/ Met-Ed management recognized this attitude problem and took action to correct it.)
A.
Management Plan Response:
1.
Committed Action:
The Senior Vice President, Metropolitan Edison Company, held meetings with TMI's managerial and line supervisory personnel to express Met-Ed's strong commitment to achieving a high quality Radiological Control Program. He pointed out at these meetings that the Radiological Control Department is responsible for establishing and maintaining the Radiological Controls Program, which includes '.he stoppage of any work not being conducted in a radiologically safe manner.
It is, however, the i
responsibility of all personnel at TMI to ensure canpliance with the Radiological Control Program.
Due Date:
i None presented, policy statement session presented as stated.
Action complete.
t 2;
Completed Actions:
The Senior Vice President presented the session indicated during the week ending 11/3/79. Subsequent sessions were held during the month of October 1980, to reiterate upper management's position.
Management's cannitment to the Radiological Control program is formally stated in the Rcdiation Protection Plan and is a specific item covered in the General Employee Training Program.
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Special Panel Comment (Cont.):
B.
Management Plan Response:
1.
Committed Action:
The Radiological Control Department was restructured under a manager reporting directly to the Senior Vice President. The reason for this reorganization was to remove the Radiological Control organization from the direct management and influence 9
of the operations organizations and to provide a direct means of connunication between the Radiological Ccntrol Department and the top management personnel at Tiil Unit 2.
Due Date:
None presented, action completed prior to publication of the Management Plan.
2.
Completed Actior :
The initial re-s ructuring of the Radiological Control Depart-ment was effective November,1979, and announced. As part of the corporate re-organization plan, a separate radiological and environmental control division was created to provide over-all direction to the radiological control program from the corporate level. The Manager of the Unit 2 Radiological Control organization currently reports to the Director, Radio-logical and Environmental Controls.
Further refinements in the organization currently have been made to take advantage of the Unit 2 Radiological Control Staff's experience and education. The current Unit 2 Radiological Control organization is formalized in Revision 2 of Radiological Controls procedure 4010, " Unit 2 Radiological Controls Department Organization."
The current corporate organization chart is forwarded as Enclosure 1.
Date Completed:
Radiological Controls Procedure 4010 was originally distributed for implementation on April 28, 1980.
Revision 2 to this procedure will be distributed by February 28, 1981.
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- II. Special Panel Comment: Organizational Structure The Panel observed a high degree of uncertainty regarding responsibilities, function, assignments, and lines of authority.
For example, the Panel noted that the radiological engineering function lacked clear definition of its areas of responsibility.
(Panel Comment: GPU/ Met-Ed management has recognized this problem and is taking action to correct it.
See Attachment C of NUREG 0640).
A.
Management Plan Response:
i 1.
Committed Action:
The Radiological Control Department was restructured under a i
manager reporting directly to the Senior Vice President. The i reason for this reorganization was to remove the Radiological Control organization from the direct management and influence 4
of the operations organizations 'and to provide a direct means of cannunication between the Radiological Control Department and the top management perscnnel at TMI Unit 2.
Due Date:
None presented, stated action canpleted prior to publication of the Management Plan.
2.
Completed Action:
i To clarify questions concerning responsibilities, functions and i
assignments, the department organization and responsibilities l
were formalized in Radiological Control Procedure 4010, " Depart-ment Organization" issued on 4/28/80.
Recent changes have been incorporated by revisions to Radiological Control Procedure 4010.
To further clarify these responsibilities, functions, and assignments, position descriptions and position specifications for Unit 2 Radiological Control personnel were completed on j
February 11, 1981.
Date Completed:
Revision 2, Radiological Control Procedure 4010 will be distributed by February 28, 1981. The action taken, formal;zation and restructuring of the organization, issuance of RCP 4010, and 3
canpletion of the individual job descriptions and specifications is considered to be a comprehensive response to the Special Panel Comment.
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II. Special Panel Comment (Cont.):
B.
Management Plan Response:
1.
Committed Action:
The Manager of Radiological Controls reorganized the Radiological Control Department. The department reorganization identifies the chain of cannand and delineates areas of responsibility within the Radiological Control Department.
All contractor controlled radiological functions are included within this organization along with Met-Ed/GPU employees under the manage-ment and direction of Met-Ed/GPU supervisory personnel.
Included in this reorganization, tasks previously performed by radiological control personnel which were considered not to be essential to the Radiological Control program were reassigned to operationally orientated groups.
Radiochemistry operations are now the responsibiiity of a Chemistry Department and decontamir.ation operations are performed by a Decontamination Department. The Radiological Control Departnent activities and functions were j
reorganized into five sections under the direction of management level personnel as follows:
(a) Radiological Technical Support:
Prepares procedures used in the Radiological Controls Department.
Provides technical support for all groups in the Radiological Controls Department.
Coordinates the ALARA program.
(b) Radiological Field Operations:
Performs radiological monitoring and implements radio-logical controls in the field.
t (c) Radiological Training:
Trains radiological control technicians and their supervisors.
Oversees the radiological control training of workers.
(d)' Dosimetry:
Implements and administers dosimetry programs.
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-5 II. Special Panel Comment (Cont.):
B.
Managenent Plan Response:
1.
Cannitted Action (Cont.):
(e)
Radiological Support Services:
Radiation instrument calibration and repair, respirator testing, bioassay, radiological laboratory, radiation health activities.
A recruiting program is currently in progress to fill the manage-1 ment positions for the above five groups with personnel possess,ing previous supervisor skills in an attempt to upgrade the Radiological Control Department's capabilities to supervise its people and operations. Three of these positions have been filled to date.
Due Date:
None presented, reorganization canpleted prior to the publication of the Management Plan.
2.
Comoleted Action:
All of the positions, except the Dosimetry Department Manager, were filled by April 1980. After a number of interviews and three offers were rejected, it was concluded that available
~ talent and experience of the Manager, Radiological Support Services could be constructively utilized to meet this need. On December 15, 1980, Dosimetry and Radiological Support Services sections were reorganized to form the Radiological Health Section, under the direction of the Manager, Radiological Health. This change has been incorporated in a change to RCP 4010 which is expected to be distributed by February 28, 1981. With this reorganization, the Unit 2 Radiological Controls organization is shown in Enclosure 1.
Date Completed:
Revision 2, Radiological Controls procedure 4010 will be distributed by February 28, 1981.
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III. Special Panel Comment: Technical Depth of Radiation Safety Program The Panel noted that professional input for the radiation safety program is lacking.
For exanple, many of the decisions which should have professional review are being made by technicians.
(Panel Comment:
GPU/ Met-Ed has recognized this problem and is taking action to correct it.)
A.
Management Plan Response:
l.
Cannitted Action:
Sufficient professional depth has been available to TMI Unit 2 throughout the initial phases of recovery through contractor 4
organizations; however, their activities were not adequately coordinated or managed by Met-Ed supervision.
The previously described reorganization is expected to provide the desired level of coordination and management for these activities.
In addition, a recruiting program is currently in progress to place highly skilled managerial, professional and technical i
personnel with the structure of the TMI Unit 2 Radiological Control Organization. Authorization-has been received to add one management level, four technical supervisory, six operations supervisor, eleven technical / engineering, two training i
instructors, and eighteen technician personnel in addition to the existing Met-Ed and contractor personnel to reinforce the Radiological Control efforts.
Completion of the reinforcement program is expected prior to initiation of major evolutions inside of the reactor building following initial re-entry.
Due Date:
August 1, 1980 j
2.
Comoleted Action:
The management level, techrical supervisory and training instructor positions indicated in the original conmitment were filled prior i
to August 1, 1980. Eight of the Technical / Engineering, four of i
the Operations Supervisory ar ' twelve of the technician positions were filled prior to August i, 1980.
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III. Special Panel Comment (Cont. ):
A.
Management Plan Response:
Completion Date:
August 1, 1980 3.
Commitment Status:
.The numbers of personnel listed in the original management plan connitment has not yet been achieved. However the overall objective of reinforcing the Radiological Controls Program with sufficient professional depth was accomplished. The reduction in the level of work at TMI Unit 2 in November 1980 resulted in a re-evaluation of the manning requirements. With the exception of one manager, 4 engineering /techr'..al, and 2 technician positions currently filled by contre.t r personnel, the staffing requirements based upon current ' di tions have been filled by an intensive recruiting program. This program is considered to be a continuing effort to meet the staffing needs due to changing recovery efforts and attrition. All of the management positions in the Unit 2 Radiological Controls program down to the third tier are filled by company people with the following exceptions: the Field Operations Deputy Manager is a contractor employee and the Radiological Engineerina Manager is a contractor employee.
The availability of the type individuals needed for these jobs 1
nationwide is such that these positions have not been filled by company employees at this time. The placement of GPU/ Met-Ed employees above and below these two positions has established enough continuity and awareness to permit these contractor employees to function essentially as company employees.
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IV. Special Panel Comment: Training During the Panel's interviews, several deficiencies in the radiation safety training program were observed.
For example, the Panel noted that the understanding of risk of low level radiation exposure by radiation safety and operations personnel was inadequate.
In addition, specific training deficiencies were identified in:
i) operation of radiation safety instrumentation by field personnel, ii) understanding of radiological hazards associated with the recovery activities, iii)
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' familiarization with plant systems, and iv) radiation and contamination control measures.
(Panel Canment: GPU/ Met-Ed has included in its reorganized Unit 2 radiation safety program a training function which i
reports directly to the Radiological Controls Manager. The Panel j
considers that the deficiencies in training can be corrected by this increased management attention and commitment during the period between now and commencement of recovery operations. GPU/ Met-Ed should use this period to prepare for handling large quantities of radioactive material by gaining experiv.nce with the handling of radioactive materials in the auxiliary / fuel handling buildings. This training is mandatory if an adequate cadre of personnel capable of performing major recovery work is to be available).
A.
Management Plan Response:
I 1.
Committed Action:
As a part of the reorganization of TMI Unit 2 Radiological Control group, a Radiological Control Training group reporting directly to the Manager of Radiological Control has been established. The training group fonnalized the training program for technicians and foremen in December and began implementation d.
of the program in January. This training program requires formal qualification of Junior Technicians, Senior Technicians and foremen.
It states the required minimum acceptable knowledge, understanding, practical abilities and experience standard for qualification. Additionally, qualification is based upon satisfactory perfonnance on a written examination, demonstration of practical abilities and satisfactory performance on an oral examination covering response to abnormal situations.
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IV. Special Panel Comment (Cont.):
i A.
Management Plan Response:
1.
, Committed Action (Cont.):
A 40-l our training cours) is being given to technicians prior to the'r written examination. This course provides refresher trainir.3 on radiological fundamentals; relates these funda-mentals to the nuclides, instrumentation and procedures used at TMI U.di 2; provides thumb rules to allow technicians to make rapid field evaluation of abnormal conditions; familiarizes the technicians with TMI Unit 2 systems, expected concentrations of liquid in these systems and associated radiation levels; 4
informs the technicians of their responsibilities and expected !
response in routine and abnormal situations.
Included in the course are problem-solving sessions which review past abnormal radiological situations and postulated potential situations with student participation in the initial analysis of radiological data, immediate and supplementary protective and corrective actions, taking of additional radiological measurements and a review of the radiological consequences of the postulated situation.
To date,16 technicians and foremen have coupleted this course and satisfactarily passed their written exam.
Oral examinations have been administered to 3 foremen and 3 technicians to date who have satisfactorily denonstrated their knowledge, understanding and ability to handle unusual situations.
The examinations are administered by senior technical, training, and radiological control operations personnel. The examinee is presented with a situation in which radiological data is given or an unusual situation is observed. The examinee must then state his actions and assessment of the situation. Additional data is provided based on the examinee's responses. The examinee is required to provide an assessment of the radiological ccnse-quences of the occurrence based upon the data provided. The situations which are presented relate to high airborne activity, spread of surface contamination, liquid spills, contaminated injured personnel, and unusual gamma or beta levels / exposure.
The oral examination board then evaluates the performance, critiques the performance with the exaninee and documents the results.
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IV. Special Panel Comnent (Cont.):
A.
Management Plan Response:
1.
Committed Action (Cont.):
Practical ability demonstrations by technicians and foremen are required to assure that they understand the requirements for and can satisfactorily perform routine surveys and operations required of technicians. s Additionally, satisfactory performance in radiological spill drills are required as practical abilities.
These practical abilities are witnessed and verified by individuals who are responsible for the direction and/or review of performance of persons performing the practical ability, by '
training, or by radiological control technical support personnel.
Two instructors and one training supervisor have been hired and are expected to report to work within the next several weeks.
This brings the training staff up to our projected full-time 9
instructor manning level. We also intend to utilize others in the Radiological Control Department on a part-time basis in their areas of technical competence.
Although initial qualification will be a continuing effort, all currently qualified radiological control technicians and foremen will be qualified or be restricted in their assignments prior to June 30, 1980.
Due Date:
June 30,1980 2.
Canoleted Action:
All Radiological Control Technicians and Foremen who were assigned to TMI Unit 2 at the time the management plan was developed were trained in accordance with the program described in the original commitment or restricted in their assignments prior to the committed date of June 30, 1980.
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IV. Special Panel Comment (Cont.):
A.
Management Plan Response:
4 Commitment Status:
Although the original canmitted action was completed, the training effort is a continuing task. The program described in the original commitment has been formalized in Radiological 1
Control Procedure 4022. All newly hired Radiological Control Technicians or Foremen candidates, selected based upon minimum experience and/or educational levels established by the Radio-logical Controls Management, must satisfy the requirements of this procedure prior to achieving qualification.
B.
Management Plan Response:
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1.
Cannitted Action:
General Radiological Safety Training for personnel employed at TMI Unit 2 is being performed by the Met-Ed Training Department.
4 The responsibility to assure that this training meets the minimum standards necessary to perform work in a radiologically safe manner l
in-the radiological environment which exists and will exist in TMI Unit 2 has been assigned to the Supervisor of Radiological Control Training. The Supervisor of Radiological Control Training has been directed to review, change as necessary and approve course material examinations, presentations and practical factor perfonnance.
Implementation of the training program is expected l
to begin May 1, 1980.
Due Date:
May 1, 1980 i
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IV. Special Panel Comment (Cont.):
B.
Management Plan Response:
2.
Caupleted Action:
The General Employee Training program and retraining procedures are in effect.
The program was implemented prior to May 1,1980 as originally committed. The procedure /.escribing the program was issued on December 12, 1980.
Date Completed:
The program was implemented prior to May 1,1980 and the procedure describing the program was issued December 12, 1980.
i IV. Special Panel Comment (Cont.):
C.
Management Plan Response:
1.
Committed Action:
In addition to Radiological Control Training described above, special training such as mock-up training, walk-through exercises, and detailed worker briefings will be required for major evolutions and those tasks which may result in encountering unusual or uncertain radiological environments. The determination of the necessity for this additional training will be performed by the ALARA engineering personnel based on the review of work procedures or task definition. The actual training / briefings '
will be conducted by technical and operations personnel in conjunction with radiological control personnel.
An example of this type task is the reactor building initial entry for which training is underway.
The guidelines for making determination of which tasks require additional training will be established by the Radiological Technical Support Branch by July 1,1980.
In the interim, this determination will be made in consultation with the Manager of the Radiological Technical Support group.
Due Date:
Formalizing special training guidelines - July 1980.
2.
Completed Action:
The program identified by this conmitment was implemented prior to July 1,1980. The determination of the necessity for additional training was performed by ALARA engineering personnel based on the review of work procedures or task definition. An example of i
tasks for which special training was required is the reactor building re-entry program.
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IV. Special Panel Comment (Cont.):
C.
Management Plan Response:
2.
Completed Action (Cont.):
The responsibility for determining which task requires additional training has been assigned to the Radiological Technical Support section. The procedure establishing guidelines to assist in this determination was issued on January 2,3, 1981.
Date Completed:
The program was implemented prior to July 1, 1980 and the procedure establishing guidelines to assist in this determination was issued on January 23, 1981.
1 V.
Special Panel Comment:
Resolution of Audit Findings i
The Panel noted that there were several deficiencies in the resolution of audit findings. -It appeared to the Panel that management had not comprehended the importance of these findings.
(Panel Comment: The GPU/ Met-Ed management has recognized this problem and is taking action to correct it.).
A.
Management Plan Response:
l 1.
Committed Action:
l The responsibility for coordination of audit finding responses,
has been assigned to the Radiological Technical Support group.
A procedure describing the audit response process will be formulated and implemented by March 15, 1980. This procedure will include the following:
a.
All audit findings associated with Radiological Safety and operations will be distributed to individual assigned corrective actions and the Radiological Technical Support group.
b.
These findings will be reviewed by the Radiological Technical Support group and evaluated to assess the overall program perfonnance and identify trends which may indicate a decline i
in radiological control performances. These performance deficiencies may be further indication of generic procedural, I
operational, technical or managerial deficiencies.
c.
A connitment record documenting the suggested corrective action, action due date, and the individual responsible for the corrective action will be distributed to the management level individuals responsible for the area in which the deficiency was observed, d.
Upon receipt of notification of corrective action completion, the Radiological Technical Support group will perform a i
follow-up inspection of the area of deficiency to determine if the corrective action performed is acceptable prior to closing out the canmitment record.
e.
A monthly status report on all open action items will be documented and presented to the Manager of Radiological Controls.
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V.
Special Panel Comment (Cont.):
4 A.
Management Plan Response:
1.
Committed Action (Cont.):
l Although audits performed in radiological work areas customarily categorize the deficiencies as radiological deficiencies, the cause of the deficiencies and initiation of corrective actions l
is not entirely the responsibility of the Radiological Control Department. Many deficiencies are an indication of poor radio-logical work practices.
It is the responsibility of the Radio-logical Control Department to evaluate radiological conditions,'
initiate precautionary measures, and correct deficiencies, if possible, upon observation -- including stopping work which is not being performed in a radiologically safe manner.
It is, 5
however, the responsibility of all workers and their supervisors to ensure that all work performed in a radiological work area is performed in accordance with the established radiological procedures and concept of ALARA.
It is the intent of this procedure to identify responsibility for radiological deficiencies and hold the responsible group accountable for implementation and completion of the corrective actions.
4 DLe Date:
Procedure for Audit Responses - March 15, 1980.
2.
Campleted Action:
The procedure addressed in the original commitment was issued in June 1980.
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1 V.
Special Panel Comment (Cont.):
B.
Management Plan Response:
1.
Committed Action:
All previous NRC audit findings and the latest Quality Assurance audit (November 1979) findings are currently being reviewed by the Radiological Technical Support group to assign responsibility for corrective action, determine acceptability of intended corrective actions and assign action due dates for comp,letion of corrective actions. Canmitments for corrective actions will be assigned to the responsible individual by February 15, 1980.
Due Date:
February 15, 1980 2.
Completed Action:
All NRC and Quality Assurance audits addressed in the original Management Plan comnitment were reviewed by the Radiological Technical Support section to assign responsibility for corrective actions, acceptability of intended corrective actions, and assignment of completion dates.
Date Completed:
Prior to February 15, 1980 as committed.
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Special Panel Comment (Cont.):
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C.
Management Plan Response:
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Committed Action:
All audit findings, other than those indicated above, will be re-audited by the Quality Assurance audit group.
Any open items will be reissued as new audit findings, any items which nb longer apply due to changing conditions or operations will be closed out by the Quality Assurance audit group.
A report, listing the current open audit items, will be distrib :ted to the Manager of Radiological Controls.
Due Date:
1 March 1, 1980 i
Completed Action:
l The Quality Assurance group at TMI reviewed all audit findings i
previous to the development of the Management Plan as indicated j
in C. 1. above.
Findings that were no longer applicable to current conditions were closed out.
Findings that remained i
applicable were re-issued.
Date Completed:
Prior to March 1,1980 as committed.
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VI. Special Panel Comment: Preparaticn and Implementation of Procedures The NRC has determined that many Met-Ed procedures are written in such a manner that strict compliance is not possible. Strict compliance with procedures is a key to a successful radiation safety program.
(Panel Comment: GPU/ Met-Ed management has stated that the procedures for Unit 2 are being revised and that verbatim compliance will be required).
A.
Manaaement Plan Response:
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Connitted Action:
The format for all Radiological Control associated procedures 1
is currently being restructured to achieve verbatim canpliance.
These procedures will be incorporated in a Radiological Control Procedure Manual, separate from the TMI site procedures. The j
revision for all radiological control procedures is estimated to i
require six months of work. A priority list for procedure revision has been compiled with procedures important to the i
continuing work effort given the highest priority.
Following revision, all procedures will be field tested prior to formal implementation to ensure verbatim compliance is possible.
Revisions to existing routine procedures applicable to the current recovery operations have been initiated.
Revisions to the following procedures are expected to be issued following field testing and 1
training in their use by April 1,1980.
(1)
RWP Use (2)
Investigative Reports (3) ALARA Review (4) Administrative Procedure
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(5) Administrative Exposure Guidelines i
All current radiological control procedures are expected to be revised, as required, and implemented following field tests and training in their use by December 1,1980.
1 Due Date:
Initial (5) procedure revisions - April 1,1980.
l Radiological Control Procedure Manual - December 1,1980, 1
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VI. Special Panel Comment (Cont.):
i A.
Management Plan Response:
2.
Completed Action:
There were approximately 80 procedures originally scheduled for revision / development. The schedule for accomplishment of this task proved to be optimistic due to administrative obstacles l
presented by existing administrative procedures and the Technical Specifications for TMI-2. The original schedule was developed with the expectation that a Technical Specification change would be approved allowing the Radiological Control Department to 4
review and approve its own procedures.
Although the impleme9tation schedule slipped on nearly all of the Radiological Control procedures, all but two of the originally scheduled procedures were submitted for final review (the Plant Operations Review Committee) and approval (the Unit Superintendent) by December 31, 1980.
Prior to submittal for final review and approval, all procedures were reviewed by all Radiological Control Department Sections directly involved with the administration of the procedures. All procedures requiring other than administrative actions were validated (field tested) by an individual who would have to use the procedure.
Training on all procedures prior to implementation did not occur universally or in the detail originally intended in the Manage-j ment Plan connitment. The major reason for this case is:
the existing administrative procedures and the Technical Specifications 4
stated that the procedures are in effect upon signature of the Unit Superintendent. An effective date following the approval of the Unit Superintendent, which would allow sufficient training time prior to implementation, could not be established.
t Failure to achieve the Technical Specification change coupled with the difficulty obtaining qualified personnel to assist in this extensive effort resulted in our inability to achieve the committed dates. To compensate for the effective-upon-issue problem with the procedures Radiological Control Field Operations is requiring procedure training for all of the Field Operations personnel.
Date Completed:
These procedures were submitted for final review and approval on December 31, 1980 and distributed for implementation on January 31, 1981.
VI. Special Panel Comment (Cont.):
A.
Management Plan Response:
3.
Comnitment Status:
i The two procedures that were not submitted for final review and approval were the Exposure Tracking and Radioactive Material Handling procedures. The Exposure Tracking procedure is currently awaiting computer capabi.ities for exposure tracking by specific tasks.
The large backlog of computer program system modifications generated since the accident has been such that the resources are prioritized to the most important programs.
There are canputer exposure tracking programs in effect which !
pennit individual dose assessments and job category dose assessments and specific job exposure tracking. The Radio-active Material Handling procedure generated significant comments during the inter-department review. Several meetings 1
were conducted to resolve the connents.
Resolutions, resulting from these meetings, are currently being incorp6 rated into the procedure. Two other procedures were submitted for approval by December 31, 1980 but were not fully implemented by January 31, 1981. These were the Radiological Critique and Radiological Review of Work Instruction ( ALARA) procedures. The Radiological Critique procedure is currently awaiting the Unit 2 Superintendent's approval. The Radiological Review procedure was distributed on January 5,1981, however, due to the magnitude and importance of this procedure to the ALARA program for Unit 2, it was suspended until February 16,1981, to allow adequate training in its requirements for all departments at Unit 2.
4.
Revised Commitment:
a.
See Section VII.D. of this report regarding implementation of the Exposure Tracking procedure.
b.
The Radioactive Material Handling procedure will be implemented by April 30, 1981, c.
The Radiological Critique procedure will be implemented by March 31, 1981.
d.
The Radiological Review of Work Instructions procedure was
~
implemented on February 16, 1981.
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- 1 VI. Special Panel Comment (Cont.):
B.
Management Plan Response:
1.
Committed Action:
l Action sign off steps will be added to all work procedures for work on major evolutions during the procedure review perfonned l
by ALARA engineers. The purpose of these sign off steps is to l
e ure a responsible individual verifies by signature that the i
radiological safety requirements have been satisfied prior to continuing with the work evolution. This format will be used i
l for the Reactor Building re-entry procedure and a procedure l
defining this practice and establishing the criteria for its j
j use will be implemented by August 1,1980.
Due Date:
l l
Procedure implementation - August 1,1980 2.
Completed Action:
4 i
The requirements for action sign-off steps were added to the i
ALARA program procedure (issued on 12/23/80) and the Radiological Review of Work Instructions procedure (issued on January 5,1981 and implemented on February 16, 1981). A separate procedure for action sign off steps is nc longer considered necessary.
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VI. Special Panel Ccmment (Cont.):
C.
Manaaement Plan Response:
1.
Cannitted Action:
The current procedure review circuit snployed at TMI Unit 2 prohibits the expedient implementation of procedures and procedure changes. A revision to the TMI Unit 2 Technical Specifications is corrently being discussed with the NRC to expedite the review precess for radiological control procedures while maintaining canpliance with the review requirements.
Due Date:
1 Pending resolution by the NRC.
2.
Canoleted Action:
The subject Technical Specification change was submitted to the NRC for consideration in February 1980.
The canmission had, at that time, just canpleted the review and approval of the Recovery Technical Specifications and the Technical Specification change was returned unaddressed, apparently because review of the change would have required a complete review of the Recovery Technical Specifications and consequently delay in the issuance of the Technical Specifications.
Since the return of the subject Technical Specifications change, Section 6 Technical Specification efforts have been focused on Unit 1.
Once agreement is reached for Unit 1, a chance will be submitted for the Unit 2 Technical Specifications.
Date Completed:
Not applicable - Not complete.
VI. Special Panel Comment (Cent.):
C.
Manacement Plan Response:
3.
Comitment Status:
The earliest projection for submittal of a complete change to Section 6 of the Unit 2 Technical Specification is January 1982. Considering the long lead time for a potential Technical Specification change for Three Mile Island Unit 2 and the fact that major revisions have essentially been completed to all of the procedures, it is considered that this cannitment can be closed out for purposes of the Management Plan. We will pursue the Technical Specification change which will facilitate quicker review and future procedure revisions or issues.
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I VII. Special Panel Comment: External Personnel Dosimetry i
The response of the TLD badge is known to be inadequate for the beta l
radiations that are present in the mixture of ra'.stonuclides,present l
in Unit 2.
Non-penetrating doses can be underestimated, and pene-trating dose can be overestimated using this badge.
l Although plans have been made by GPU/ Met-Ed to improve the quality j
assurance of personnel dosimetry through inter-comparison with accepted programs, no such program exists at present.
I j
The present system of radiation exposure management does not permit j
assessment of exposure by job or by group. Furthemore, the system does not pemit the rapid updating of exposure totals in a timely j
fashion.
The investigation of unusual exposures is conducted by members of the dosimetry group. The Panel is concerned that there is not sufficient technical expertise within this group to pemit a comprehensive evalu-l ation. The initial failure of the dose assessment group to consider i
gonadal exposure and exposure to the lens of the eya in the radiation i
incident of August 28, 1979 is an example of this weakness. The long
)
time period that has been spent reviewing the gonadal exposure question j
(as yet this issue is still unresolved) is another example.
(Panel Comment: GPU/ Met-Ed management has informed the Panel that evaluations are underway to correct the problems with the badge and the exposure managementsystem).
A.
Manaaement Plan Resoonse:
l.
Comitted Action:
I Beta radiation associated with post accident primary coolant at TMI Unit 2 presents a complication to personnel exposure monitoring. At present, there is no known comercially available syster. in use within the industry that possesses the capability of measuring the beta radiation exposures with the high degree of accuracy desired by Met-Ed. At present, dosimetry systems l
l l
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VII. Special Panel Comment (Cont.):
A.
Management Plan Response:
1.
Committed Action (Cont.):
under development and modifications to the presently used Harshaw TLD system are being evaluated to determine their ability to more precisely measure beta exposures.
In addition to the accuracy factor, these systems are be4W evaluated to determine their compatability with the existing reading equip-ment in order to reduce the cost of system changeovers if possible.
All test data and cost study information resulting from the dosimetry system evaluations will be available in time to pennit'.
a decision on system selection by July 1, 1980.
System implementation will be accomplished by December 1,1980.
Tests are currently being performed to detennine the ability of existing dosimetry equipnent to accurately monitor the exposures received by personnel performing the initial Reactor Building re-entry. The results of this analysis and subsequent reconnend-ations will be made by February 15, 1980.
Beta radiation exposure determinations made to date for personnel entering high beta radiation fields have not relied solely on the existing TLD system results due to the known inaccuracies associated with beta radiation detection.
Evaluations are performed by professional Health Physics personnel.
Due Date:
Reactor Building Recommendations - February 15, 1980 System Modification Implementation - December 1, 1980
. 4 1
VII. Special Panel Comment (Cont.):
j 1
A.
Management Plan Response:
4 j
2.
Completed Action:
The Reactor Building recommendations were submitted prior to i
February 15, 1980 as scheduled.
. Based on post-accident experience with the current Harshaw 2-chip per'sonnel dosimeter, it was concluded that a new dosimetry system was needed. This decision was made in December 1979. The search for a new system revealed that only one system, Panasonic, was commercially available. This system was used mainly for gamma i' dosimetry and environmental work, and its beta response had l
not been adequately studied. Two other systems were being developed, one by the Department of Energy at Idaho Falls and l
a second by Harshaw Chemical Company.
It was necessary to evaluate the response of all three systems, particularly to j
beta radiation, prior to selecting one on the basis of the results, hardware design and availability.
F I
Calibrated beta sources were necessary to accomplish an evaluation.
No sources of the quality and type needed were available in the United States in January 1980.
DOE-INEL had initiated procure-l ment; however, the manufacturer was experiencing difficulty with making the sources.
Consequently, three beta sources suitable for precise dosimetry work were ordered from Amersham Corporation. The sources were received in May 1980 and were then sent to the National Bureau of Standards for calibration.
The results of this calibration were received by Met-Ed/GPU at l
the end of July 1980.
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VII. Special Panel Camment (Cont.):
A.
Management Plan Response:
2.
Completed Action (Cont.):
Preliminary measurenents were started on the Panasonic dosi-meters using an off-site reader. These measurements revealed that the filtration on the badge elements was not precisely j
suitable for our purposes, and also that the statistical un-certainties in the TLD readouts were not adequate to permit adequate beta dosimetry.
Consultations with the Panasonic representative lead to a temporary solution to the filtration problem. Arrangements were also made to obtain a Panasonic reader onsite on a loan basis for the duration of the evaluation project. Such an arrangement would allow closer control over the reader calibration and possibly improve readout precision.
During this same time period, the Department of Energy experi-mental INEL badge became available and an evaluation of its response was initiated. Personnel from EG&G Idaho, through a DOE grant, assisted in this work, which was completed at the end of November (PCI Tech Report TR-187). Although the badge performed satisfactorily, some limitations were found which may be common to any similar system. The INEL operation is completely manual and as such cannot be adopted for station use immediately.
It is anticipated that the first semi-automatic reader would be available sometime July 1981.
EG&G Idaho has completed additional evaluations of the INEL badge and has more canpletely characterized the beta source in use at TMI with respect to dose rates and energy spectra. The results of this work was presented to GPU/
Met-Ed on December 12, 1980.
Panasonic has supplied Met-Ed/GPU with a limited number of modified badges to a configuration more suitable for our purposes and the loaned Panasonic reader was received at TMI about the first of December. The first group of Harshaw four-chip dosimeters was received on December 4, 1980. Obtaining and setting up a Harshaw reader for this system delayed completing the evalu-ation of this badge until the end of December.
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I VII. Special Panel Comment (Cont.):
l 4
i A.
Management Plan Response:
I 2.
Completed Action (Cont.):
i Upon review of the above described evaluations, the radiological controls management has determined that a Panasonic four-chip i
systen would be the most suitable of available systems for TMI-2 dosimetry needs.
Date Completed:
System selection based upon technical evaluations - January 31,\\ 1981 3.
Comitment Status:
Radiological Controls management and consultant personnel reviewed the systems available and concluded that a Panasonic 4-chip system could accanplish the monitoring objectives with some modification to the badge available and is obtainable in a 4
reasonable period of time. The complete conversion to a new I
automated TLD system with computer tie-in is relatively expensive.
Consequently the proposed system is being evaluated to assure it is the most cost effective. The proposal submittal will be canpleted by April 30, 1981 i
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VII. Special Panel Comment (Cont.):
B.
Management Plan Response:
1.
Committed Action:
Although technical expertise has teen available to TMI Unit 2 in the form of contracted advisors present at TMI and support agencies outside TMI, coordination and direction of this expertise was not achieved.
Coordination of these efforts is assigned as the responsibility of the Radiological Technical Support group. This responsibility will be docunented in the Organization and Responsibilities Chapter of the Radio-logical Control Procedures Manual scheduled for completion by February 1980. All dose assessments for non-routine exposure evaluations will be reviewed by the Radiological Technical Support group.
Due Date:
February 1980 2.
Canpleted Action:
The subject contracted advisors were placed within the Radio-logical Technical Support Section during the reorganization verformed in November 1979. These advisors report directly to the Manager, Radiological Technical Support as described in Radiological Controls Procodure 4010.
Date Comoleted:
This procedure was implemented on April 28, 1980.
m
I VII. Special Panel Comment (Cont.):
C.
Management Plan Response:
1.
Committed Action:
i j
The current TLD system quality assurance program is being expanded to include comparison with outside agencies. The j
procede.e defining this quality assurance program will be issued by 4pril 30, 1980.
Due Date:
April 30, 1980 l
2.
Completed Action:
l The annual quality assurance irradiations of the TLD system was completed in March 1980, and checked with additional irradiations on a monthly schedule. The procedure defining the quality assurance program was issued on November 10, 1980.
This procedure instituted an additiona quarterly quality assurance test. Both the quarterly and annual irradiations are performed by an agent independent of GPU/ Met-Ed.
Date Completed:
i November 10, 1980 D.
Management Plan Response:
1.
Committed Action:
I The current computerized exposure record system is designed to maintain accountability of personnel exposures, however, it does not provide a means of tracking exposures by the tasks performed. A study is presently being conducted to determine the best method to ratisfy the above goal. By April 1,1980, a system capable of tracking personnel exposures by work groups and by major tasks.4ill be implemented.
By December 31, 1980, a system capable of trccking exposures by specific individual tr.sks will be implemented.
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VII. Special Panel Comment (Cont.):
1 D.
Management Plan Response:
Due Date:
Exposure Tracking by work group and major task - April 1,1980 1
Exposure Tracking by specific tasks - December 31, 1980 2.
Completed Action:
{
}
Exposure tracking by work groups and najor tasks was accomplished by April 1, 1980 as scheduled.
4 Date Completed:
April 1, 1980 3.
Connitment Status:
i i
The computer capabilities to support an exposure tracking program as defined by the original commitment exists as a result of modifications made to the previously existing exposure records i
computer program. Exposure tracking by specific tasks on other than a limited basis has not been achieved due to the large backlog of computer program 'Jork and a lack of a company-wide standardized coding system for task description.
A cooing sytem (COMEC) for organization and task descriptions has recently been developed and was implemented by corporate directive for financial tracYing by December 31, 1980.
It was the intent to expand the scope of the COMEC !. stem to include exposure accounting within two months of introducti;n, however, the maintenance group at TMI 2 uses a different syst sn to codify tasks.
Efforts are in progress to resolve these dif.erences and produce a coding system compatible with the exposure tracking objectives.
1 4
. o VIII.
Special Panel Comment:
Internal Dosimetry The Panel was informed of several examples of problems in determining internal dose. These problems include:
i) overestimate of dose to the thyroid because of failure to consider the fractional transport, ii) assignment of iodine uptake based on peaks produced by cesium Compton scattered peaks, and iii) failure to interpret the effective half-life of iodine properl <.
The GPU/ Met-Ed criteria for requiring Sr-90 bioassay is a Cs-137 uptake of 150 nCi as measured by whole body monitoring. However, to the dosimetry group's knowledge, no assessment has been made which demonstrates that this technique is adequate to assure that significant Sr-90 uptake will not go undetected.
A.
Management Plan Response:
1.
Committed Action:
Through contractor support, technical expertise has been available and utilized to evaluate results obtained from the internal exposure monitoring program.
These efforts will be coordinated and managed by the Radiological Control Department re-organization described earlier in this plan.
Due Date:
None presented. Action, as stated, completed prior to publication of the Management Plan.
2.
Completed Action:
See Section VII. B. 2 of this report.
c.
I t
VII.
Special Panel Comment (Cont.):
B.
Management Plan Resnonse:
1.
Comitted Action:
The current bioassay program is being revised to formalize the basis for bioassays under routine conditions, following skin contamination or internal deposition, and evaluations for Sr-90 depositions. All dosc assessments and evaluations of internally deposited radionuclides will be performed by the Radiological Technical Support group.
Due Date:
Revision of Bioassay Program - April 1,1980 2.
Comoleted Action:
Radiological Control Procedure 4238 " Bioassay Program" was issued and implemented on July 25, 1980.
Date Completed:
July 25,1980
j.-
IX. Special Panel Comment:
Instrument Program The Panel is concerned that sufficient professional input into the j
instrument program is lacking. Selection of instruments, installation, calibration, and maintenance is perfonned by contractor technicians.
(Panel Comment: The Panel encourages the evaluation by the Radio-logical Engineering group of portable survey instruments which are needed for the major recovery activities. The Panel also believes that an auditing program needs to be established by GPU/ Met-Ed to assure that instruments are being properly calibrated and maintained).
A.
Manacement Plan Response:
L 1.
Committed Action:
l All instrumentation selection, installation, calibration and maintenance currently performed by contractor technicians will be coordinated and managed by the Radiological Support Services in the Radiological Control Department organizational gr. 1
- struc,
' identified earlier in this plan, Due Date:
A Nonc presented, action Com
' ori" to publication of the s
i Management Plan.
2.
Completed Action:
All instrumentation technicians were incorporated into the i
Radiological Support Services group in the Radiological Control i
Department - Unit 2 as identi.'ied in Radiological Controls 4
procedure 4010 issued in April 1980. The Radiological Support Services group and the Dosimetry group have been combined under the Manager, Radiological Health as identified in Revision 2 to Radiological Control procedure 4010.
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IX. Special Panel Comment (Cont.):
3 B.
Management Plan Response:
1.
Carmitted Action-Instrumentation evaluation and subsequent selection is a 3
continuing task at TMI Unit 2 to ensure the most accurate and l
reliable instrumentation available is employed in the Radio-logical Control Program. As advances are made in instrumentation or as the current instrumentation proves to be inadequate for conditions encountered, the search for, evaluation of, and sub-l j
sequent selection of tne most reliable instrumentation available, to the industry will be made. There are currently two areas l
in which the current instrumentation used at TMI Unit 2 proves to be less than desirable, high level energetic beta fields associated with undiluted post accident primary coolant and radiation measurements taken within the Kr-85 environment of the i
Reactor Building.
The search for a beta instrument capable of accurately measuring the beta fields associated with the post accident primary coolant is a difficult task complicated by the fact that accurate measurement of beta radiation has,been neglected in the field of Health Physics. The Departnent of Energy and its' contractors at the Idaho National Engineering Laboratory have been focusing on this problem for 2 to 3 years and consequently have made significant steps towards improving the capability to monitor for and calibrate instruments for beta radiation. The Radiological Technical Support group sent an instrumentation team to the Idaho National Engineering Laboratory during the month of January with newly developed high-range and existing beta instruments to perform calibration and comparative performance tests. The information obtained will be used to make a selection of the most suitable instrument for measuring beta radiation fields.
i l
IX.
Special Panel Comment (Cont.):
B.
Management Plan Response:
1.
Catmitted Action (Cont.):
The second condition in which the currently used instrumenta-tion proves to ineffective is radiation measurements perfonned within the Kr-85 environment con.tained in the Reactor Building as a result of the post accident conditions.
The Kr-85 apparently migrates through instrumentation sealant materials producing unreliable measurements.
A search is currently being conducted by the Radiological Technical Support group for instrumentation '
or sealant systems capable or producing reliable measurst.ents under the conditions described.
Instrumentation selection for the Reactor Building re-entry program will be made, following resolution of the above indicated problem areas, prior to March 1,1980.
2.
Due Date:
Reactor Building Entry Instrumentation - March 1,1980 3.
Completed Action:
A high range beta instrument was developed by Eberline.
Two of these were obtained for use in the Reactor Building re-entry prog ram. However, mea'surements with these and other survey instruments indicated that beta radiation is not a controlling exposure pathway in the Reactor Building.
Date Completed:
Prior to March 1, 1980 as committed.
. ' ' IX. Special Panel Comment (Cont.):
C.
Management Plan Response:
1.
Comuitted Action:
The Radiological Technical Support Branch is currently preparing a Quality Assurance program for instrument calibration. This program is considered necessary to ensure that all portable instrumentation used at TMI Unit 2 are properly calibrated.
This program will cover calibration procedures performed at TMI facilities and off-site facilities.
Due Date:
Quality Assurance - July 1, 1980 2.
Completed Action:
The procedure defining the subject program was distributed for implenentation on September 9,1980.
D.
Management Plan Response:
1.
Committed Action:
The TMI instrument maintenance and calibration facility has been upgraded and is currently considered adequate to meet our current needs. The Radiological Technical Support group has presented design criteria for a new facility to Bechtel Corporation for design and construction.
This facility should be operational prior to expanding decontamination activities into the Reactor Building.
Due Date:
December 31, 1980
IX. Special Panel Comment (Cont.):
D.
Management Plan Response:
2.
Completed Action:
A cost-benefit analysis was performed prior to authorizing the new facility design and construction.
It was decided that a new facility was not cost effective.
The existing facility could be refurbished to meet the existing and immediate future needs. The existing facility was upgraded, as reported in the first quarter 1980 report, prior to March 31, 1980.
Date Completed:
Modification of existing facility - prior to March 31, 1980 E.
Management Plan Response:
1.
Cannitted Action:
Rapid and accurate assessments of radiation and contanination levels in the TMI Unit 2 work areas is essential to the Radio-logical Control Program. The current counting facilities for air activity and surface contanination levels are inadequate.
There is a need for improved contamination analysis, isotopic analysis, and low energy beta analysis capabilities.
Recommendations are being prepared by the Radiological Technical Support group to upgrade the existing Health Physics Counting Laboratory.
Due Date:
Recommendations - February 15, 1980 Implementation - June 1, 1980
IX.
Special Panel Comment (Cont.):
l E.
Management Plan Response:
2.
Completed Action:
The existing Health Physics Counting Laboratory counting facilities were evaluated and upgraded based on the evaluation prior to June 1,1980.
Isotopic analysis equipment was not considered necessary for this laboratory, since the chemistry facilities have adequate analysis equipment which is readily available for the Radiological Control Department's needs.
Date Completed:
i Health Physics Laboratory Improvements - June 1,1980 X.
Special Panel Comment: Radiation Control The Panel notes that the radiation protection plan does not include adequate emphasis on reduction of personnel exposures to ALARA.
Such enphasis should include goals and mechanisms for demonstrating progress.
A.
Management Plan Response:
1.
Committed Action:
The TMI Unit 2 Radiation Protection Plan stresses Met-Ed managements total cannitment to achieving a strong Radiological Control Program within the concept of ALARA. With the implementation of the articles contained in the Radiation Protection Plan and canpletion of the corrective actions assigned in this plan, this comnitment is expected to be achieved.
Due Date:
None presented.
I i
1 X.
Special Panel Comment (Cont.):
i A.
Management Plan Response:
1 2.
Completed Action:
The Radiation Protection Plan was modified and the requirements i
of this plan have been incorporated into the revised Radio-l logical Control implementation. procedures. The Radiation Protection Plan has been submitted but has-not been approved by the NRC to date. Sessions presented by the senior management representative j
to supervisory personnel.it TMI-2 have re-iterated manage-ment's commitment to achieving a strong radiological control program within the concept of ALARA. With the exception of i
the few itens indicated in this report the commitments indicated in the Managenent Plan were accomplished.
Date Completed:
I Continuing 3.
Connitment Status:
l The cannitment to stress management's 'annitment to achieving a strong radiological control pregram within the concept of ALARA is a continuing effort. Aa exposure goal for TMI-2 was established at 218 man-rem for 1980. The exposure returns for 1980 indicated an expenditure of 199 man-rem. An exposure goal for the year 1981 has been established at 171 man-rem.
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X.
Special Panel Cannent (Cont.):
1 B.
Management Plan Response:
1.
Committed Actions:
l To aid in radiation exposure reduction, man-rem exposure goals i
shall be established by ALARA engineers for each major job and for each year.
Exposure returns received from the computerized program scheduled for implementation on April 1,1980 will be used to track the exposures and perform a trend analysis to 4
determine if a review of the operations is required to reduce exposures even further.
Reports will be issued to responsible operations supervision so they can munitor the effectiveness of their performance. This program is currently being developed and fonnalized in a procedure format by the Radiological Technical Support group. This procedure will be ready for implementation following the implementation of the computerized exposure i
tracking system.
Due Date:
t September 1,1980 2.
Completed Actions:
A The procedure which implements radiological reviews of work requires that an estimate of radiatien exposure be made for each major job by the job supervisor. Those estimates are reviewed by the i
Radiological Technical Support engineers.
If the actual exposure I
incurred during the job differs from the estimate by 25%, a special review is made to improve the estimating and planning process.
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Special Panel Comment (Cont.):
C.
Manacement Plan Response:
l-Committed Action:
It is the responsibility of all Met-Ed/GPU and contractor supervision to ensure that radiation exposures received by individuals reporting to them are as low as reasonably achievable.
The reports, based on the canputer returns described above, issued by the Radiological Technical Support group should be used as an aid in tracking personnel exposures and identifying operations which may need ALARA engineering reviews to reduce exposures received.
Due Date:
None presented, this is a continuing task.
2.
Completed Action:
See Section VII.D. of this report.
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