ML19350A343

Provides Responses to 44 Remaining Items Set Forth in Health Physics Evaluation as Requiring Resolution Prior to Restart

ML19350A343
Person / Time
Site:	Three Mile Island
Issue date:	02/02/1981
From:	Arnold R METROPOLITAN EDISON CO.
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19350A334	List: ML19350A333 ML19350A336 ML19350A339 ML19350A340 ML19350A342 ML19350A343 ML19350A345
References
L1L-024, L1L-24, NUDOCS 8103130557
Download: ML19350A343 (8)

Text

.

O*;

8 -i n

mg3 ,

Metrood:.an Esison tomaany  ;

l , , I *,.J W ae w[.-

+

F3 >

P:st O*fice Ecx 480 '

weei.t= . an,im .m. :::s7 717 944 4t41 I

Wnter's Dire:t San P,wmeer February 2 ,1951 Lil C24 Office of Inspection & Enforcement Attn: 3. H. Grier, Director Region I U. S. Nuclear Regulatory Co:nission 531 Park Avenue King of Prussia, Pa. 19046

Dear Sir:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. OpR-50 Docket No. 50-289 Health Physics Evaluation At the Cecoined Manage =ent Meeting held at the NRC Region I Office, King of Prussia, Pennsylvania on Dece=ber 17, 1980, Metropciitan Edison Cc=:any agreed to provide written response, by January 30, 1981, for those ite=s which require corrective action prior to Unit 1 Restart. As a result of that same meeting, Metropolitan Edison Com:any provided early submittai cf responses to the first thirteen (13) ite=s which pertained to =anagement effectiveness.

Attached please find responses to the re aining forty-four (44) ite=s requiring resolution prior to Unit 1 Restart.

We believe the responses enclosed are consistent with the discussions held on December 17 and should resolve each ite as identified by the NRC. Some of the itec:s provide additional details or explanations wnich may assist you in evaluating the responses.

Sincerely,

/s/ R. C. Arnold i.. C. Arnold Chief Operating Executive RCA/WE?/jpr Enclosures cc: V. Stello L. Barrett R. Reid 1810313o 559'

%.m.- sem ::.- , s c.*- r :- a n = : =e, sme-

2 .- < 3 REQUIRED PRIOR TO RESTART HEALTH PHYSICS EVALUATION -

22-19 Resolution of the effect of high energy (s2.2 MeV end;oint) beta radiation en the TLD ga=a ex;csure results.

RESPONSE: The effect of high energy (i.e. 2.2 MeV endcoint) beta radiation on the TLD gasta exposure results is limited to the effect of strontium activity in Unit II and is not a factor on TLD exposures in Unit I under nomal operating conditions.

The effect of high energy beta radiation on the TLD gamma results is a consideration in some areas of Unit II. During the past 15 months the cempany has expended extensive research resources to obtain an approved beta monitoring capability. Since there was no comercial system readily available which was considered acceptable for use without some modift:ation, three systems, a Harshaw system, a Panasonic system and an INEL system have been researched.

None of these systems as presented by the manufacturer are acceptable as is for TMI use. Two of the systems are not on the market (readily available for short term order) and one of the systems is still in the development stage.

GPU/ Met Ed has been working closely with one of these companies in particular and has had on site representatives of the other two companies. Any of the three systems will ulti-mately require additional technical and management efforts by GPU/ Met Ed to ensure that the system procurred for use is adequate for our purpose. The reconnendation to improve the TMI beta monitoring system could only be achieved with an extensive research and investigative effort on the part of the company and with the coo::,eration of the vendors.

Due to our efforts and the efforts of the cognizant vendors a final decision on one of the three systems which will

. improve the beta monitoring capabilities at TMI has been made.

' It is expected that the, procurement and installation, calibration, computer software, preparation and computer tie-in will require several months. Since the high energy beta radiation is not r

a factor in TLD excosures in Uniti under nonnal operating conditions the implementatien of this new system is not considered i a prerequisite to start-up of Unit 1.

22-20 Decision as to what neutron monitoring equipment will be used at TMI for monitoring neutron exposure and implementation of that program. If a badge device is selected, the device should be capable of resconding to neutrons of energies from themal to at least 1 MeV and should have a lower limit of detection of not greater than 30 millirems. Soecial consideration of neutron threshold energies for the detector (140 key) when major portions of neutren expcsures are from energies <140 kev shcuid be applied. ,

RESPONSE: In tne current shutdown condition, neutron monitoring is being performed by a desimetry c:n:ractor, R. S. Lancauer.

.2 - 4 Landauer is a sucplier cf beta, gam a and neutron monitoring devices on a nationwide basis. Under shutdown conditions the vendor neutron dosimetry device is considered adequate.

The company has made extensive contacts with vendors and with other professionals in neutron dosimetry monitoring and has been unable to locate a supplier of neutron monitoring equipment which is considered cacable of meeting the criteria specified by the NRC. Therefore, when Unit I becemes operational the neutron desimetry monitoring precedures in effect for Unit 1 prior 0 Maren 28, 1979 will be used with additional confirmation of correction factors for specific plant areas should the additional correction facters be warranted. The additional correction vculd, of course, be deter =ined after start-up of Unit I when dose rates can be taken. Although the technique will require the use of dese rate instrument deternined correction fac:crs to be applied to the neutron monitoring badge, it has the advantage of full time personnel menitoring while in the neutron field.

GPU/ Met Ed will continue to pursue investigations of neutren monitoring devices from comercial or research resources and will consider the use of any advances in neutren monitoring as new devices are available on the market and as they are considered to meet the NRC respense criteria.

~

22-23 Development and implementation of a QA program for vendor su: plier and processed extremity monitoring devices.

RESPONSE: The QA Program for extremity =cnitcring was imple-mented in October,1980. The program includes a

" spike" test for finger rings which are prccessed by the vendor. The program requires a semi-annual test with acceptance criteria as defined in NUREG/

CR-1063 mcdified by HPSSC WG-4. A PCR to RCP 4220 has been submitted to incer; crate the finger ring test requirements and is expected to be issued 5/30/81.

. 2 -ic' 22-24 Within the existing CA progra=, develo?=ent and i=ple=entation of provisions for deter =ining correction fae: Ors :: te applied in the deter =ination of ga==a d ses received in =ixed radiation fields.

RESPONSE

Ga==a calibratien factors are not a:clied to Unit I TLD data as i=: lied in :ne finding. The expcsure received en the deep chip is teken as the penetrating dese. The beta emitters expected : be enc:untered during normal Uni: !

operations have energies too icw to penetrate to the deep chip. Thus no ga==a corre::icn fa:: Ors are required in deter =ining the ga==a dese. Ga==a calibration fact:rs is a dose evaluation fa:: r in Uni: II in selected areas with significant high energy : eta is0:0;es. It is ex:e:ted that this factor will be adequately corrected by the i= le=entation of the new TLD =onitoring syste=. (See response to Ite: 22-1g).

l l

l l

l I

• i I

l t

3 l

t

2-tc 22-26 Development and implementation of a bicassay procedure, common to botn Units I and II, which details criteria, collection methods  ;

and e.andling techniques for each type of indirect bioassay per- '

formed at the site in order to insure uniform coordination and implementation of the bicassay program. I RESPONSE: RCP 1628 (Unit I implemented 11/19/80) and RCP 42'3 i (Unit II implemented 7/25/80) documents the indirec:

bicassay requirements for Unit I and Unit II. The requirements contained by these procedures are ecn-sistent and common to both units. These procedures currently invoke ANSI N343-1978 which provides guidelines on collecticn, handling and performance criteria for indirect bicassay. To ensure clarity and specificity, the applicable guidelines from ANSI N343-1978 will be incorporated into the aforementioned procedures by 5/30/81.

O e

4

.a - / 7 22-29 Establishment of Resof rator o rotection Instructor selection criteria and provisions for qualifying instructors ::rior to assuming instructor duties.

RESPONSE

The selection cderia and cualification standards for Respiratory Protection Instructors were provided to the NRC in August,1980. These criteria are to be formalized in the position speci'ications for this job by August 21, 1941.

22-30 Upgrade of the existing Unit I Respiratory Protection Training Program to include the elements contained in "UPEG 0041, Section 8.3.

RESPONSE

Subject to the evaluation, the lesson plan for the Respiratory Protection Training Program was reviewed and revisec to comply with applicable portions of Section 8.3 in MURTG 0041. This Prograc, which has been reviewed and approved by the 0.espiratory Protection Supervisor, includes all items required by the NUPE3 22-33 Development and implementation of a contractor-independent GA Program for the 'icassay u program which includes: fixed audit schedules; use 4.35 Traceable sources, acceptance / rejection criteria; accuracy and precision requirements; MDSs; and use and adequacy of license procedures.

RESPONSE

RCP 4239 provides the OA Program for the bicassay program and invokes the requirements of ANSI N3a3-1978. As part of the OA Program, an annual audit and calibration check is performed. The procedure will be expanded by 5/30/81 to incorporate the applicable specifications of the ANSI standard.

22-34 , Establishment of portal and hand and foot monitor calibration programs

- which include instrument the use ofcriteria.

acceptance NBS traceable radiation sources and I

AESPONSE:

Use of the hand and foot monitor in Unit I was dis-1 continued prior to the evaluation. All personnel must perform a contamination survey usinc a "frisker" when leaving potentially contaminated areas. The portal monitors are precautionary monitoring devices used only as secondary or tertiary contamination control monitors when leaving the Security Protected Areas. The calibration procedure (PCP 1745) recuires that the monitors be calibrated electronically and source checked. This is an industry practice and has been

! considered acceptable. Nevertheless, as an additional improvement to our calibration program, the procedure will be revised by 5/30/81 to provide source calibration i

l of the portal monitors with '!PS traceable sources.

l

t t Q

2 */ Y 22-35 provisions for resolving time corrections in G" cete:ter ::unt-ing procedures and determination of the gr:ss beta ef'icien v using appropriate backscatter :Orrections 'er the medium beina

unted.

R!sp0NSE: Resolving time :Orrections are needed only for 0unting high level samples with GM detectors.

A Provision will be added to the applicable Arceedures by 5/30/31 to either : rre:: for resolving times at high : cunt rates, or :: use proportional :Ounters for samples wnere crecise activity levels are recuired.

The sources used at ?! for beta efficiencies are standard sources used througneut the industry and are considered ade uate. However, in an effor t to continue im roving cmcarisons between the scur es used in determining beta efficiencies and the samcles taken in the field, . Met-Ed/GP'! is attempting to locate a supplier of N95 traceable sources prepared on air sample filter paper. An earlier verbal report to the NRC indicated that the National Bureau of Standards would supply these sources. Subsecuent to that, the N95 has stated that they cannet supply the sources as recuested.

- /1 22-51 Revision of procedures to eliminate reference to entire collections l of regulatory requirements and incorporate specific Certificate of Compliance, requirements.

RESPONSE: Procedures involved with radioactive waste handling are currently being reviewed and revised as necessary to eliminate reference to generic regulatory documents.

• Included in this effort will be the incorporation of specific Certificate of Compliance requirements.

This effort is scheduled for completion by April 1,1981.

==- 22-52 Development and implementation of provisions for performing and

=- documenting radiation surveys of shipping ccsks prior to intrasite transfer.

RESPONSE: Procedures governing the intrasite movement of shipping casks are being reviewed and revised as necessary to require HP surveys of the vehicle and shipping cask, and to document such surveys, prior to the liner being moved. This action will be canplete by April 1, 1951. .

O t

i