ML19350A336
| ML19350A336 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/04/1981 |
| From: | Brasher J, Dubiel R, Heward R, Knief R, Potts W METROPOLITAN EDISON CO. |
| To: | |
| Shared Package | |
| ML19350A334 | List: |
| References | |
| CLI-80-5, ISSUANCES-SP, NUDOCS 8103130529 | |
| Download: ML19350A336 (16) | |
Text
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 SP
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(Restart)
(Three Mile Island Nuclear
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Station, Unit No. 1)
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LICENSEE'S TESTIMONY OF RICHARD HEWARD, WILLIAM E.
- POTTS, RONALD A. KNIEF, JESSE W.
- BRACHER, AND RICHARD DUBIEL REGARDING CLI-80-5 ISSUE (4) AND SHOLLY CONTENTION 14(c) l AND RELATED BOARD QUESTIONS (HEALTH PHYSICS PRCGRAM) 1 l
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r OUTLINE The purpose and objective of this testimony is to respond to Issue 4 in Commission Order CLI-80-5 and to Sholly Contention 14(c), which address the adequacy of the TMI-l health physics program, including the sufficiency of the health physics organization and its staff.
The testimony addresses as well related specific areas identified by the Licensing Board.
i Licensee's Radiological Controls Department has been reor-ganized since the TMI-2 accident.
Reorganization has resulted in greater independence of the TMI-l health physics organiza-tion from other TMI-l activities.
The TMI-l Radiological Controls Department staff has increased from nine to seventy-nine.
Licensee has also rewritten the TMI-l Radiation Protection Plan and implementing procedures, developed and instituted a new radiological control training program, and purchased new radiological controls equipment.
These changes ensure that Licensee is sufficiently staffed, organized and prepared to control radiation exposure, avoid accidental radiation exposures, maintain exposures within the regulatory requirements, and keep exposures to workers and to the general population as low as is reasonably achievable.
BY WITNESSES HEWARD, DUBIEL, AND POTTS Introduction This testimony, by Richard Heward, Vice President of Radiological and Environmental Controls, GPU Nuclear Corporation, William E. Potts, Manager, TMI-l Radiological Controls Department, Ronald A.
Knief, Manager of the TMI-I T *ininT Department, Jesse W.
Brar.her, Director of Radiological Controls, TMI-2, and Richard Dubie.. Radiological Engir.eering Manager TMI-1, is addressed to the following question and contention:
CLI-80-5, ISSUE (4) l Whether the Unit 1 Health Physics program is appropriately organized and staffed with qualified individuals to ensure the safe operation of the facility.
SHOLLY CONTENTION 14(c)
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1 The Licensee's management capability, in terms of organizational, staffing, and technical capabilities, is not sufficient.
Specifically, the following deficiencies in Licensee's management capability are contended:
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Licensee's Health Physics program is not appropriately organized, nor-is it staffed with sufficiently qualified individuals to ensure safe operation of TMI-1.
The testimony also addresses specific areas related to health physics which the Licensing Board has indicated should be covered in testimony on this subject.
(See tr. 13,428-30.)
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The objective of the Three Mile Island Unit 1 Radiological Controls Program is to control radiation exposure, to uvoid accidental radiation exposures, to maintain exposures within the regulatory requirements, and to keep exposures to workers and to the general population as low as is reasonably achievablo (ALARA).
In order to meet these objectives, Licensee's Radiological Controls department has been reor-ganized; staffing has been increased from approximately 9 ro 79; and the TMI-l Radiation Protection Plan and implementing procedures have been rewritten.
A copy of the Plan is attached to this testimony ( Attachment 1).
In addition, in order to ensure that the new department is maintained in the best possible form to reduce personnel radiation exposure, a new I
radiological control training pregram has been developed and instituted, and additional equipment purchased.
BY WITNESSES HEWARD, CUBIEL, AND PCTTS Organization l
l The reorganization of raciological control perscnnel working at Unit 1 included important steps in improving the independence of the TMI-l Radiological Controls Department frcm other TMI-l activities.
A Manager was appointed who now I
report' the GPU Nuclear Corporation's Vice President of Radiological and Environment Controls, although a close l
coordination with TMI-1 plant management _s maintained.
This
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encourages independence from operational considerations and facilitates achievement of higher standards of radiological control.
The Department was reorganized into three groups:
a Ra/iological Engineering group; a Radiological Technicians group; and an Administrative group.
The Radiological Engineering group consists of a Manager and 6 engineers, compared with the single engineer formerly available to TMI Unit 1 in the Radiological Controls department.
The radiolog-ical engineers are responsible for anticipating and solving technical radiological controls problems; planning and development of the Radiological Controls Program; providing technical support to the TMI-l unit organization; and assessing the performance of the radiological controls crganization to ensure continuous improvement in the Radiological Controls Program.
The Radiological Technicians group consists of a Manager, 6 foremen, and 30 technicians, an increase by a factor of approximately four.
This significant increase in personnel allows around the clock coverage of radiological control work.
The Radiological technicians monitor ongoing radiological work and ensure that the best possible radiological control practices are used.
The Administrative arm of the TMI-1 Radiological Controls Department consists of an Administrator and 4 clerks who ___
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perfor= =ost administrative and clerical work for which Radiological Controls is responsible, thereby =aximizing -he time available for the ene..neers and field group to perfor=
their functions.
In addition to the TMI-1 Radiological Centrols staff, the GPU Nuclear Radiological and Environmental Controls organiza-tion includes a Radiological Assessment branch which provides evaluations independent of the Unit I crganization and repcrts directly to the Vice President - Radiological and Environ = ental Centrols.
In addition, selected support functions such as dosimetry processing, bioassay services, radiological control instrument calibration and =aintenance, and respiratory maintenance are provided by the TMI-2 Radiological Controls organizatlun to =inimize redundancy in these areas where a single organization can optimize quality and efficiency.
BY WITNESSES EEWARD, CUEIEL, FCTTS, AND KNIEF Traininc i
l Licensee has institt ced a ccmprehensive training prcgra=
for Radiclogical Controls technicians and supervisers which I
t currently provides for cne week in each shift rotation sec.. tce i
to be dedicated to training.
The classrec= pregram consists of both practical and theoretical aspects of radiation protection.
I Students are evaluated with written exams and are required to achieve high grades in crder to centinue performing their jcb I
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functions.
In addition, Radiological Controls technicians and foremen are required to pass oral and practical examinations in order to maintain a high degree of proficiency in responding to unusual and normal events.
The training program for radiation workers has also been upgraded.
Practical aspects of reducing exposure are emphasized.
Procedures to minimize the spread of contami-nations are taught.
As better methods for controlling and minimizing radiation exposure are found in che plant, they are factored back into the training programs.
BY WITNESSES HEWARD, DUBIEL, AND POTTS Ecuipment The equipment available to Radiological Controls personnel and radiation workers has been upgraded in order to keep up with improvements in design and to help reduce radiation l
l exposure to workers.
Twenty continuous air monitors with local read-out and alarms have.een added.
Additional laboratory l
analytical equipment has been purchased to allow more rapid assessment of radioactive contamination and airborne radioac-j tivity.
Improved respiratory protection devices are now in use l
l for increased protection of the worker from airborne radioac-l tivity and for increase in worker comfort.
As a result, 1
l Licensee has excerienced nigher worker efficiency s.sd lower exposure to personnel.. -.
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BY WITNESSES HEWARD, DUBIEL, AND POTTS Planning A major emphasis of the revisions Licensee has made to the TMI-l Radiological Controls Program implementing procedures is in the area of job planning and evaluations of unusual events.
Under this program, basic radiological control procedures were revised and now require verbatim compliance.
Specific scheduling of work in radiation or contamination areas and adherence to that schedule by maintenance and operations personnel has resulted in improvements in the ability of Radiological Controls personnel to control radiation exposure and radioactivity.
Radiological work functions above specific exposure limits are reqaired to be reviewed by a radiological engineer to ensure that proposed actions are in keeping with the requirement to maintain exposures as low as reasonably achievable.
Depending on the potential radiological exposure involved, a specific work function may require a review of proposed procedures, pre-job briefings, an on-the-job eval-uation or a post-job critique.
Techniques to contain contami-nation have been Laproved and a major plant decontamination effort has been undertaken.
To ensure that workers' input on Radiological Controls practices is brought to management's attention, a system has i
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.been established to encourage personnel to identify items which
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may be improved.
These reports are evaluated and incorporated as appropriate into the Radiological Controls Program by the Radiological Engineering group.
A response is always provided to the originator.
Additionally, unusual radiological events are investigated by Padiological Engineering with reports, including recommendations, made to the Manager of Radiological i
Controls.
The objective of these systems is to anticipate and correct small problems before they grow, and thereby achieve day-by-day improvements in the program.
BY WITNESSES HEWARD, DUEIEL, POTTS, BRASHER, AND KNIEF i
l Board Questions i
The NRC conducted a Health Physics Evaluation of TMI Unit i
l in the nummer of 1980.
Their concerns are summarized in l
Appendiz B of NUREG 0680 and generally addressed the areas of organization relationships and staffing, bicassay program, exposure control and personnel dosimetry, and radioactive waste management.
(The evaluation also covered <mergency plan l
implementation which is not addressed in this testimony. )
The Licensing Board has expressed an interest in receiving l
l evidence on a number of the specific concerns identified by the NRC in its evaluation.
The Licensee has responded aggressively to NRC's concerns.
The responses by Licensee to each of the items identified by the Board from NRC's evaluation are set forth in Attachment 2.
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BY WITNESSES HEWARD, DUBIEL, ANL POTTS Ocerational Readiness of Radiological Controls Decartvent Because there is radiation in TMI-l from years of reactor operation, waiting for future rea; tor operation is not required to demonstrate the operational readiness of the Radiological Controls Program at TMI.
In 1980, 13,309 Radiation Work Permits were isrued at TMI-1, averaging 37 per day.
Four hundred and five ALARA Engineering Reviews were conducted from May through December of 1980, averaging thirteen per week.
Total manrem exposure in 1980 was 201, a significant reduction from the originally projected total of 320.
The reduction is l
primarily the result of the improved ALARA program and the formation of an H.P. Awareness Committee.
The highest l
individual occupational exposure for 1980 was 1.005 Ram which was less than 10% of the NRC allowable exposure.
The average exposure, excluding all exposures less than 10 MR, was 84 MR.
The 1981 manrem budget is 140 man rem, an ambitious 30%
i reduction over a successful 1980.
The Internal Exposure Control Program includes the i
requirements for a whole body count for each individual prior l
to issuance of a TLD and upon termination and also of any individual who becomes contaminated.
Each contemination incident is critiqued to determine cause and corrective action.
The results of the Whole Body Count Program in 1980 showed that l...
no individual working in Uni I received more than 1% of the limits established for internally deposited radioactivity.
A major maintenance effort of 6 to 8 weeks duration was successfully completed.
This work included a stea= generator eddy current inspection; high pressure injection cross connect modification (32 welds); berated water storage tank line weld repairs; and reactor coolant relief valve inspection, testing and maintenance.
During the year 1980, a major effort to deconta=inate the plant was started.
As of January 1, 1981, 88% of the Auxiliary and Fuel Handling Buildings were deconta=inated.
In the Reactor Building, we have achieved a reduction in contamination levels of at least a factor of ten.
The Rad Waste generation rate in 1980 was reduced by approximately 50%.
This was accc=plished through a progra:
that included:
Plant decontamination; Restrictions on equipment and =aterial allowed to i
enter the controlled areas; and A greater awareness by the workers in =ini=izing the amount of waste generated during cperations and
=aintenance.
Thus, the operational readiness of Radiological Controls Program at TMI Unit 1 has been demonstrated.
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BY WITNESSES HEWARD, CUBIEL, AND PCTTS Conclusion At TMI-l the health physics program has undergone co=plete revamping.
TMI-l's Radiological Controls Cepartment now is independent of operations, reporting to GPU Nuclear's Vice President of Radiological and Environmental Controls.
Close coordination with TMI-l management, however, is maintained.
The Department is guided by a new comprehensive Radiation Protection Plan, follows revised detailed implementing proce-dures, and is staffed with sufficient, adequately trained and qualified personnel to ensure effective i=plementation of the Plan.
The Cepartment's current operational readiness is demonstrated by actual performance.
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QUALIFICATIONS CF J.
W.
BRASHER Mr. Brasher is currently employed at Three Mile Island Unit 2 as Director of Radiological Controls.
Prior to employment at TMI in July, 1980, Mr. Brasher was employed at Ingalls Shipbuilding Division of Litton Industries in the position of Director, Radiation Controi.
Mr. Brasher was with Ingalls for 19 years.
Prior to his association with Ingalls, he was employed by E.
I. Dupont de Nemours at the Savannah River Plant.
Mr. Brasher was supervisor in the health physics section at that plant.
Mr. Brasher graduated from Millsaps College in Jackson, Mississippi with a degree in chemistry in 1956.
Mr. Brasher has been certified by the American Board of Health Physics since 1964.
He has served as an industry advisor on the Mississippi State Board of Health Radiation Advisory Council and on the Mississippi Energy Research Committee.
Mr. Brasher currently holds memberships in the Anerican Nuclear Society and the Health Physics Society.
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RICHARD W.
HEWARD, JR.
Professienal Experience GPU Service Corporation, 1967 to Present Director, Radiological and Enviren= ental Centrols Manager, Radiological Controls, TMI-2 Manager, TMI-2 Recoverv. Engineerinc Manager of Projects Project Manager, Three Mile Island Project Manager, Forked River Safety and Licensing Manager Me=ber, General Office Review Board, TMI-l New York Shipbuildine Corporation, 1957 to 1967 Chief Naval Nuclear Engineer (Last Pcsition)
Education and Licenses 3.S. Civil Engineering, Swathnere College Certification - Oak Ridge School Of Reactor Technology Certification - Reactor Safety Course, U.K.A.E.A. Harwell, England Registered Professional Engineer, Pennsylvania l
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WILLIAM E.
POTTS PRESENT POSITION:
Manager Radiological Controls TMI Unit 1 12/79-Present Metropolitan Edison Company Three Mile Island Nuclear Station Responsible for all matters related to the implementation of the Radiological Control Program including design, support and enforcement functions in the operation, maintenance and construction associated with TMI Unit 1.
PAST POSITIONS - METROPOLITAN EDISON COMPANY Superintendent - Technical Support Unit 1, 1979 Supervisor - Licensing, 1976-1979 Supervisor - Quality Control, 1972-1976 Supervisor of Reactor Plant Services, Saxton Nuclear Experimental Corporation, 1970-1972 Test Engineer, Saxton Nuclear Experimental Corporation, 1970
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MILITARY EXPERIENCE U. S. Navy, Electronics Technician, 1960-1966 I
l EDUCATIONAL BACKGROUND B.S.E.E. - Pennsylvania State University U.S. Atomic Energy Commission Senior Operator License Various educational and training courses, including: Basic Radiological Health (U.S. Department of Health, Education and Welfare), Occupational Radiation Protection (U.S.
Department of Health, Education and Welfare), Basic Nuclear Power Review, PWR Simulator Training, Effective Communica-tions, ASME Quality Assurance, Auditing Nuclear Quality, Supervisory Development Course, Management Development; and Naval Schools on Physics, Mathematics, Electronics, Computers, and Inertial Navigation.
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