ML19350A339

TMI-1 Radiation Protection Plan.

ML19350A339
Person / Time
Site:	Three Mile Island
Issue date:	08/28/1980
From:	Heward R, Potts W METROPOLITAN EDISON CO.
To:
Shared Package
ML19350A334	List: ML19350A333 ML19350A336 ML19350A339 ML19350A340 ML19350A342 ML19350A343 ML19350A345
References
NUDOCS 8103130538
Download: ML19350A339 (23)

Text

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ATTACHMENT 1 TO LICENSEE'S TESTIMONY OF

RICHARD HEWARD, WILLIAM E. POTTS, RONALD A. KNIEF, JESSE W. BRASHER, AND RICHARD DUBIEL REGARDING CLI-80-5 ISSUE (4) AND SHOLLY CONTENTION 14(c)

AND RELATED BOARD CUESTIONS (HEALTH PHYSICS PRCGRAM)

THREE MILE ISLAND NUCLEAR STATION UNIT I RADIATION PROTECTION PLAN i

(REV. - AUGUST 27, 1980) l l

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August 27, 1980 ATTACEMF:IT 1 THREE MILE ISLAND NUCLEAR STATION UNIT 1 RADIATION.?ROTECTION PLAN

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41. E. Potts Manager, Radiological Controls l Jn P ~2 2*- C&

R. W. Hegard Director, Radiological and Envircnmental Controls w.- - +. : ,et,. Changes to this document require approval by these positions. . -. . . . .

Revision 1 January 16, 1980

'IHRE MIII ISIAND NCCIEX4, STATICN UNIT 1 RADIATICN PR.as 2 CN-PIM i

Table of Cente .ts Pace No.

Article 1 Fotriatien_for-the DfI-l Radiclogical Cbntrols Pr-+ c.ca 2 Article 2 Respecsibil.i ties of Werkers 5 Article 3 Audits, Reviews and Reports en the 'IMI-l Radiological Centrols Prcgra:n 7 Article 4 Radiological C::ntrols Trairing 10 Article 5 centrol of Ex:ernal Egesure 12 Article 6 centrol of Internal Dcpesure 15 Article 7 Cbntrol of Radicactive Centaminaticn 17 Article 8 Control of Radioactive t'a' rials 18 Article 9 Crganizatien fcr Radiological controls 20 b

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A'rticle' 1 - Fcundation for the THI-l Radiolcoical Controls Procram This document, the Three Mile Island Unit 1 Radiat'icn Protecticn Plan,. sets forth the philosophies, basic policies and objectives of Metropolitan Edison Company and General Public Utilities Corporation concerning theii TMI-l Radiological Centrols Program. The objective of the radiological controls program is to control radiation ha::ards to avoid. accidental radiation exposuces to maintain expcsures within the regulatory-requirements and also-to maintai.rexposures to workers and the general population a's icw as is reasonably achievable. These -

philosophies, policies, and cbjectives are based on and implement the regulations of the Nuclear Regulatory Cedission (NRC) as contained in Title 10 of the Code of Federal Regulations, Parts 19, 20, 50, and' 71, and appropriate Regulatory Guides, specifically 8^.2 (1973), 8.4 (1973),

8.8 Rev. 3 (1978), 8.9 (1973), 8.10 Rev.1-R (1975), 8.13 Rev.1 (1975),

8.14 (1977), and 8.15 (1976). The TMI-l Radiation Protection Plan is based on these references, therefore they are not repeated throughcut the remainder of this document.

Specific details as to how the TMI-l Radiation Protection Plan is implemented shall be premugated in the THI-1 Radiological Controls Procedures Manual -(RCPM) and shall include those applicable precedures ,

addressed in Reg. Guide 1.33 Rev. 2 (1978), App. A,'paragra'ph 7, and paragraph 8 (aa), (bb); further references to the TMI-l RCPM are not repeated thrcughout this document. The TMI-l RCPM will ccasist of revisiens to procedures which existed in the previcus HPP 16CO and 1700 series, applicable Administrative procedures, and additional precedures deemed necessary. This TMI-l Radiation Protection Plan is the first C l" W part of the TMI-l RCPM. RequiresdnTg'overn.ing releasamf radicactive ,

liquids and gases to the envircnment and the disposal of M

Revisica 1 /45 Januarf 16, 1980 solid radicactive waste are not addressed in this DC-1 Radiatica Protec-ica Plan, but are addressed in the Envircr. ental Technical Specificaticns.

Verbatim ccqpliance with the DC-1 RCPM is mandatory. In the event a procedure cancot be folleved exactly, work under that procedure shall be stopped and shall not ces rrence again until the procedure has been correcced.

This DC-1 Radiation Protectica Plan and the new DC-1 RCPM are being written prirarily to increase.the. effectiveness of the Radiologim' centrols Program at DE Lhit 1. Thus, the procedures have di.e applicabi14ty cnly to DE Unit 1. PrMTes shall provide adequate guidance and specify appropriate methcds er techniques to insure that the perfc=ance of each activity is in accordance with scund radiolcgical centrol principles, and is in c=r@liance with applimkle regulatory prodsiens. The RCPM s1 ='1 be t

prepared, reviewed, approved, and centrolled as described in the RCal Aininistrative procedures.

! The 92-1 Radiological Centrols P.wm is to be fully integrated into l

l each and everf phase of operatices at DE Unit 1. The DC-1 Radiological Cbntrols Program when carried out as specified will assure that the operation of thit 1 will.be perferred with personnel who werk at the site inc.==-ing radiation exposure as low as can reascnably be achieved.

In crder to meet this cbjective, the program r:ust be carried cut by each persen involved in the OE-1 activities. There is no group er persen involved in the DC-1 cperatie:ns who does not have seme degree of res;cnsibility 1

for the Radiological Centrols Program. Failure of any person to recognize this

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res;cnsibility or to corply with issued procedures will not be tolerated.

A radiologically safe operatien will be achieved if each individual carries cut his or her respcnsibility.

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i-5 w g Ja.uarf 16.1980 h perf=: mar.ce of each rar:ager ar.d superdscr :xst demer. strate sup;cet for the ccm .icent by t=p earagment of Ger.eral Public Utili.ies corporation and Met ==politan Ediscn Ccq:any to a st =r.g, effective

3diological c::nt71s p.egra=.

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Although pc=el specially trained in radiolegical centrcis ner-gally eversee radioactive werk, each individual in$cived in this verk est.st censtantly recain r.te of the ;ctential radiological proble s.

Each individual is res;cesible for raintaining his er her ex;csure as low as reascnably achievable. Each individual's actices directly affect his exposure, c=ntaminatien, and owrall radiological preblers asscciated with the ucrk. ?r.e fellcwing rules shall be fellevedby individuals to minimi:e radiological pr:bler.3:

1. Cbey r 4y " step-.crk" and " evacuate" crders of W8micgical control persennel.

2. Cbey ;csted, cral, and written radic1cgical centrcl instre.= ices

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and procedures, including instructices en P.adiatien Werk Ps:=its.

3. Wear 'IL9 and self readi .; cbsinater where rege. ired by sig.s er by radiolcgical c= trol pc=el. Re;crt loss er enexpected exposure and offscale desi.~eter to Radiological centrcl Depart:ent.

4. Keep track of penal radiatien ex;csure status and a. tid ex-ceeding exposure li. tits.

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5. Remain in as icw a radiation area as pra icable to a w ..,.lish work.

l 6. Do not loiter in radiation areas.

7. Do net smcke, eat, er chew in contaminated areas.

1 l " 8. Wear antic =nta=inatien clcthing and respiratcry prctectica pre;erly and wherever rete. ired by sig.s er radiological centrol pc:nel, i

l 9. Remcve anticentaminatien clcthing and respiratcry p=tectica prcperly

! to minimice spread c.} ccr.taminatien.

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10. Frisk or be frisked for contaminatien when leaving a ec.tarinated .

, 1 area or a radiological control point. Notify Radiological 6

Controls personnel if contadration is found.

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11. For a hncNn or pcssible radioactive spill, minimize its spread and notify radiological control persennel pretrptly.

l 12. Do not unnemssarily touch a centaminated surface or allow clothing, tools, or other equiprunt to do so.

4 13. place contami=ated tools, equipnent and solid wasta en dispes-able surfaces (for exarple, sheet plastic) when not in use and inside plastic bags when work is finishad.

14. Limit the arrount of raterial that has to be decentaminated or disposed of as r=dimeive waste.

15. Notify Radiological Centrols personnel of faulty or alarming radiation protection sp:1pnent.

16. Report the presence of open wounds to radiological control and medical persennel prior to work in areas where radioactive centam-ination exists ard imnediately if a wcund occurs while in such an area.

l 17. Notify Radiological Controls perscnnel upcn returning to the site afte:

medical administration of radiopharmaceuticals.

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18. Assure a rentally alert and physically scund conditien for performing assigned work.

19. Ensure that your activities do not create radiological problees for others and be aled for the possibilities that the activities of others pay change tk.e radiological ccnditions to which ycu are expcsed.

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Article 3 - Audits, Reviews and Recorts on the TMI-1 Radiolooical Controls Procram .

, As indicated in Article 2, each individual is responsible for maintaining his or her radiation exposure as low as reasonably achiev-able while completing the scope of work they are required to perfam.

Each will be required to ccmply with the applicable procedures of the TMI-1 RCPM and the specific radiological controls prescribed for work in whichsthey-are-engaged._.

In orde'r Yo ' ensure that these requirements are being met and to assist all site personnel in understanding and ccmplying with these requirements, a system of audit and review procedures shall be established including criteria for timely and appropriate corrective action'. The folicwing audit and review procedures shall be used:

1. Radiological control technicians shall monitor and aid the perfonnance of each individual insofar as radiological work practices are concerned.

2. The Radiological Engineering shall review on a regular basis the performance of the radiological control technicians.

This review includes shift coverage on those jobs which are e considered likely to have a high potential for radiological ,

difficulties.

3. Radiological assessments shall be conducted throughcut the Radiological Controls Program on a continuous basis. This assessment function shall report directly to the Director Radiological and Environmental Centrols. A written report of the findings of this assessment shall be prepared and m y o m .-- issued every month.v - -

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4. Quality Assurance audits shall be meducted of te ~ C-1 Radiological centrols Program by *achnically qualified persens ,

frcm outside the Radiological Centrols Depart ent. W ese audits will be cenducted in ace =rdance wit.h procsiures as cutlined in the D C-1 Quality Assurance Pl n. W e Cuality Assurance Methods, Cperations and Audit group will schedule these audits and will previde persconal frem their own depart:nent ard/or outside-centract=rs as appr=pdate to c=rduct the audits. These i

audits shall cover the applicable pertiens of the Cuality Assu-rance Plan, the DC-1 Radiaticn Pr=tection Plan and all precedures in the TE-1 RCPM cn at least an annual buis.

5. 'Ibe Plant Cperations Review Cxmittee shall review and c::mrent cn the DC-1 Radiatien Protecticn Plan and any changes threto.

'Ihey also have the responsibility to review t'.rse procedures requested by the Manager-Radiolegical Centrols.

6. Periodically, the services of an outside c=nsul*mt will be retained to provide evaluatien and guidance en ways to 1:rprove the DE-1 Radiological C::ntrols P_w ra.

7. In addition to tMse reviews and audits, a system shall be egloyed to identify radiological centrol deficiencies. A radiolcgical centrol deficiency is Aa*W as either a violaticn of an established procedure or a practice which could and should be inpreved. Such deficiencies are recer.*.ed in a Radiological Deficiency Repert. 'Ihis system shall be specified in the DC-1 RCTM errbodying the following concepts. A Radiological

. . .. . ._ , __ ...__ Deficiency. Rep . :nay be initiated by any individual who .

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, April 3. 1980 ebserves a deviation frcm gecd radiolcgical prac: ices. These reports shall be evaluated by Radiological Engineering for .

desirable er necessary corrective action. The purpose si this system is to identify all deff'ciencies, regardless of how small cr incensequential, correction of which will result in an improved Radiolegical Centrols Program. Radiological Engineering shall prepare a =cnthly report scar.ari:ing the Radiological Ceficiency Report fir. dings and corrective action taken. .

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3. The Nuclear Regulatory Ccamissien (NRC) also inspects and reviews the TitI-l Radiolegical Centrols Program. The TMI-l ,

Radiation Prctection Plan and any changes therete shall be submitted to the NRC af ter i=plementatien.

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9. In the event all the preceding measures fail te prevent a ,

radiological incident, an investigation shall be conducted to determine the causes of the incident and to deter =ine the -

corrective actions and i=preverents needed.

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Revision 1 January 16, 1980 Article 4 - Radiolecical C::ntrols Mnina

1. periodic radiological centrol training shall be given to ensure each person understands the radiological c=nditions to which he is exposed, understands his responsibility to rinirire his own exposure to radiation, and understand his own responsi-bilities fsr conplyilm; with radiological control procedures.

I Persennel e-T=tionally exposed to radiation shall receive inst.maction on the effects of radiation and the risks associated i with radiation exposure.

2. General radiological indcctrination shall be given to these not directly involved with radiatien so that they understand I

i not to enter areas requiring TLDs and not to cross radiation l barriers. 'Ihe indoctrination shall include explanation of the radiological environment in which they work.

3. Radiolegimi control training shall be given to perscnnel requiring access to a restricted area,. 'Ihese persennel shall be required to l

l pass a written examination, and they shall requalify by writtec l

examination at least annually.

4. In addition to the training and written examinatiens of para-graph 3, these who require access to areas centrolled by l

l Radiation Work Permits shall rec 2ive nere extersive training and shall be required to pass a radiological exaninaticn on their practical abilities, includira use of desimetry, frisking, antiwui.aninatien clothing, respiraters, ard res;cnse to un-usual sittutions. Retraining, and both written and practical exarinatiers shall be ccnducted at least annually. In additica, i

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c,ct d.ecks shall be rade that d et retain the receired 'r s -

ledge during de peded beween en.=inatic=s. S ecial br:.efirm and extra trairi=g inc1'v" :q use of cdv..;s wt.ere a;clicable, shall be ec . ducted fer werk in'.civing Figher can usual ewurss i

to radiatien ard radicactivity.

5. Radiological centrcl tad.nicia .s and their foreren shall re- l ceive thecretical a:4 practical trainirq ard trainirs fer =>-

usual sit.:ati==s. minirs shall also be gi.w. fer changes to proced:res, equi; rect ar4 pm s. ney shall pass bcth writter, and cral e.wi.naticns, in wt.ich the passing gm fcr fers:ac i

chall be higher than the passing grade fer technicians. M edic practical drills a:4 cral drills shall be req.: ired fer each tech- ,

i nician and ferecan. Arr.ual rare.alificatica shall 'ce rey,: ired including teth w:.tten and cral exa:-inatiens. Radicicqical cent:el. technician assistants shall perfc=a specific f=ccices u-der directica cf a ge.alified tedr.ician er fereren and cnly after,being qualified for the specific f=ctien.

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. Revision 2 e-f3 April 3, 1980 Article 5 - Control of External Excesure Control of radiation exNsure is based on the assumption that any exposure no matter hcw small involves seme risk; however, exposure with- ,

in the accepted limits represents a risk s=all compared with normal hazards of life. Therr. fore the policy of Metropolitan Edisen Ccepany ,

and General Public Utilities Corporaticn is to maintain exposures to individuals and total man-rems as icw as is reasonably achievable (ALARA).

Line management:frem all depart-.ents as well as each individual worker .

7 shall take an active role in radiation exposure reduction.

To aid in exposure reduction, administrative radiation exposure control i

levels shall be established. Radiation man-rem exposure goals shall be '

I established for each major jeb and for each year. Work involving radiatica l

exposure shall be preplanned. Major exposure jobs shall require that j radfological controls be incorscrated in the design, that written procedures  !

I be prepared, and that pre-jeb briefing and rehearsals be conducted prior to j ccmmencing work. A Radiation Work Permit will be required for any work or entry to restricted areas that would involve or create any of the follcwing: i I

(a) high radiation area, (b) airborne radioactivity area, and (c) contami-nated area, or (d) those radiation areas specified in applicable procedures. j Restricted areas used to control personnel access to radiation and {

radioactive materials shall be defined, access controlled, and pcsted in accordance with 10 CFR 20.203 with the follcwing mcdifications:

Each liigh Radiation Area shall be barricaded and conspi-1.

cuously posted as a High Radiation Area, and personnel desiring entrance shall cbtain a Radiation Work Permit (RWP). Any individual entering a High Radiation Area v c c'- shall (a) use a continuously indicating dose . .au -

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- January 16, 1930 rate r:enit= ring device er (b) use a radiatica dose rate integrating device which ala.ns at a preset dcse level, er (c) assure that a radiological centrol technician p:cvides pertoiic radiation surveillance with a dese rate ::enitoring instru er.t.

2. Any area accessible to perscnnel where a major portien of the body could receive in any one hcur a dose in excess of one thousand mrem, shall be lecked to prevent urauthori::ed entry.

'Ihe keys-to-these-locked-barricadas shall be maintained urrM- <

the W"htrative centrol of the Radiological Centrols Ferar:an ,

i en duty in accordance with the BCpM.

Radiological controls perscnnel shall be exempt f=m the R:G .

issuance requirenant during the perfer:rance of their assigned radiatien protecticn duties previding they are folleving radiological cent:el rdures for entry into High Radiatien Areas.

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'Ib evaluate radiological cceditiens, radiation surveys shall be conducted for air activity, reTevable surface centaminatica and ,

external radiation at regular intervals. Surveys are perfe: red in order to (a) nenitor Se suitability of cent:cl measures, (b) evaluate the needs for additiccal controls, (c) evaluate trends for ALARA pur;cer.s, and (d) evaluate radiological conditiens in t

areas routine'y entered withm.:t radiation work pe:mit coverage.

! Surveys in unrestricted areas are provided to insure the effective control of radioactive material. Unusual conditiens detected in the perfor. nance of either a reutine er special survey shall inrnediately be brought to the attentien of Radiological Cent.mls Managment. pertable radiation survey instru:ents will be i . 13.0

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. Revision 1 January 15, 1980 calibrated serri-annually, except for dose rata =easd=q ir; tree:.*a, which will be calibrated quarterly, to assure a censister.t. rel-de ar4 predictable response to radiation le/els. Recc 6 of surveys shall be =aintained on file. An A&::inistrative program will be used to verify the calibration of persennel ar4 field =enitoring inst:sw.ts.

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',,'i April 3,1980 Article 6 - Control of Internal Excesure The policy of Metropolitan Edison Ccmpany and General Public Utilities Corporation is not to have any significant in'ternal exposure to personnel from radioactivity associated with Three Mile Island Unit 1. For personnel exposed to radioactivity during their work, this means that no one should receive frem internal adioactivity more than ,

one tenth of the radiation exposure that 10 CFR 20 wculd allcw one to 1

accumulata in-a year...  !

Controls in other parts of this TMI-l Radiation Protaction Plan  ;

to minimize internal radioactivity, such as control of surface contamina-tion and control of wounds, are not repeated in this article. The g

folicwing controls are to minimize internal exposure frcm airborne radioactivity:

1. Engineering controls and controls on personnel access shall ,

be applied to the maximum extent practicable so that radio- l active work does not increase the amounts of airborne radic-I activity inhaled. When no other. controls are practicable, .

respirators shall be used. 'Those who may need to use respf-  :

rators shall be medical'ly qualified, trainad, tested for '

respirator efficiency, and requalified in this respirator program, at least annually.

2. Airborne radioactivity shall be measured regularly in areas where personnel may be exposed.

Continuous menitoring representative of air the person is breathing shall be performed to supplement periedic measurements during work which has the potential to cause a worker to receive measurable

. wa c ti.v i ty. internal radioactivity. 1 m. . ,

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Internal radioactivity shall be measured at least annually in each person who works in an area requiring a radiation werk permit; this

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• January 16, 1980 incitMes each persen who wears resp;ratory protection. Internal radio-activity shall be measured procptly in each person who receives radicactive centamination ca his skin, and in each persen who is suspected of id=" g sufficient radioactivity to cause.=easurable inte: a1 radioactivity.

Each measurement of internal r:.dicactivity above a level near back.grcund a shall be reviewed to deter:dne the cause and to assist in miW *.g i

intettal exposures.

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• i-if Revision 4 July 3, 1920 Article 7 - Control of 7.adioactive Centamination -

Radioactive surface centamination shall be controlled in order to minimize possible inhalation or ingestion of radioactivity and to mini-mize build up of radioactivity in the environment. Measures to contain radioactivity and to minimize the number and extent of areas contaminated shall be taken in order to minimize personnel radiation exposure, to simplify subsequent-persennel-and area or facility decentamination, and i to minimize the need to rely.on antic:ntamination clothing. a The release for uncontrolled use sur' face contamination level and skin -

contamination action level for beta-ga=a activity shall be 1000 dpm/100cm 2 for smearable' contamination using a shielded smear c:unter and 0.1 mr/hr for total contamination measured with a standard GM Tube j er 100 cpm for total I

contamination measured with a pancake GM detector. (The preferable means j of monitoring for surf ace centa=ination will be with a pancake GM detectori.  ;

For alpha activity, the surface c:ntamination level for uncontrolled releas t and skin contamination action level is 100 dpm/100 cm 3 when measured with a j shielded smear counter er icocpm when measured with an alpha survey meter.

Emphasis in olaming, training and working shall be placed cn =ini-I mizing the numbers of occurrences and amounts of radioactivity involved in l

l occurrences of radioactive surface contamination of a person's skin or of I

areas not controlled for radioactive surface contamination. Each such l occurrence shall be reviewed in detail to determine hcw to correct defi-l ciencies and improve control of radioactivity.

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January 16, 1980 Article 8 - Centrol of Pedicactive Materials Ds additien to the definitica of 10CFR20, any raterial having a dese' rate measured with a beta gamra survey :neter at 1 inch exceeding 0.1 mr/nr or with svrface contaminatien in excess of the limits specified in Article 7 shall be handled as radioactive. A radioactive material control system shall be established to ensure radioactive material is not lost er misplaced in a location where personnel could urJc.cwingly be i

ex;csed to radiation and to prevent the unccntrolled spread of radioactivitf to areas where the public might be affected. This system shall include i

the following re:[uirenants:

l. The nurber of areas in which radioactive raterials are stcred shall be minimized.

2. Any new radioactive material storage area shall be approved before use by the Marager-Radiological centrols.

3. The nurrbers of radioactive items and the a:: cunt of radio-activity in storage shall be m2.nimized.

4. Radicactive items shall be identified as radicactive before removing them frem a restricted area.

5. Radioactive materials rencved from the Protected Securitf Area 1

or renoved frcm a restricted area outside the protec*d Security Area shall be centrolled in accce:!ance with an acccuntability procedure which ensures the materials are rct lost er irprep--

erly handled during transfer or subject to unauthorized rer: eval.

This accountability procedure shall require inventory of radioactive naterials which remain cutside such areas.

6. Each inccming er cutgoing shipnent of radicactive raterial

r. Ys631%cTW.or'-fe. mss. all be'.hfAd1'ed-in. strict ccxrpliance with datailed written . --

> c precedures.

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. r.evist en Januar/ 15. 1980 Each case in Vnich radicactiva ; aterial is Icst or tr.accccted for shall be reviewed in detail to date.=ine the poter.tial radiatica e.pr.re. .

pe: sex.el night trJeod N 1y receive, to c::m deficiencies, >~8 to 1: prove centrol of ra!.ic#ve r aterials.

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Revision 4 August 27, 1980 Article 9 - Oreanization for Radiolooical Controls A radiological control program cannot be strono and effective if left solely to the Radiological Controls Department. Each worker and supervisor has responsibility for radiological control; consequently, the organization for the entire Three Mile Island Unit i represents the organization for radiological control.

However, the Manager-Radiological Controls is responsible for en-suring that a high quality radiological controls program is established and maintained. It is the responsibility of the Radiological Control Department to evaluate radiological conditions and recommend precautionary measures. To assist the Manager-Radiological Controls, a Radiological Controls Department is organized as shown in Figure 1.

At times when demands upon the Radiological Control Department are sufficiently heavy to require a temporary increase in staff, qualified contractor personnel will be used. These personnel will be 'ully inte-gratef into the department under the direction of the Manager-Radiological Controls. Support services (instrument calibration, respirator protection bicassay, TLD/ dosimetry, and training) may be provided by TMI-2 Radiological Controls or other GpU organizatiens. These support services will be .

administered by precedures which define the orgard::ational interface required to insure the quality of services provided meet the commitments of the TMI-l Radiation Protection Plan.

Qualifications for the key radiological managers in NRC Regulatory Guide 1.8, Rev.1-R, (1975) will be met as far as practicable. Where the cc=bination of strong manager and experience in radiological cJntrols

.cannot practicable be obtained in the same person, a deputy will be 2,MC3 appointed?who. meets the NRC.'s requirements. 2- . u =<.. n . t.m e co u tt er.t

. P.evision L August 27, 1980 One portion of the TMI-l radiological controls program is the U?.A program for personnel radiation exposures to be as low as reasonably ,

achievable. To accomplish this each engineer involved with TMI-1 has 1, to have radiological engineering as part of his assignment. Thus, most radiological engineering functions are performed in engineering groups rather than in the Radiological Controls Department. The overall coordi-nation of the TMI-l ALARA program, however, is assigned to Radiological Engineering in the Radiological Controls Department.

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ATTACHMENT 2 TO LICENSEE'S TESTIMONY OF RICHARD EEWARD, WILLIAM E. POTTS, RCNALD A. KNIEF, JESSE W. BRASHER, AND RICHARD CUBIEL REGARDING CLI-80-5 ISSUE (4) AND SHOLLY CONTENTION 14(c)

AND RELATED BOARD CUESTIONS (HEALTH PHYSICS PROGRAM)

EXCERPTS FRCM LICENSEE LETTERS TO NRC, DATED DECEMBER 16, 1980, DECEMBER 30, 1980, FEBRUARY 2, 1981, AND FEBRUARY 27, 1981, RESPONDING TO NRC HEALTH PHYSICS EVALUATION REPORT (IE INSPECTION REPORT NO. 50-289/80-19).

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