ML19350D390
| ML19350D390 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/13/1981 |
| From: | Hukill H Metropolitan Edison Co |
| To: | Grier B NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML19350D388 | List: |
| References | |
| L1L-023, L1L-23, NUDOCS 8104150403 | |
| Download: ML19350D390 (1) | |
Text
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.a PQ Metropolitan Edison Company Post Office Box 480 e
Middletown, Pennsylvania 17057 717 9444041 Writer's Direct Dial Number February 13, 1981 LlL 023 Office of Inspection and Enforcement Attn:
B. H. Grier, Director Region 1 U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Units 1 and 2 (TMI-1 and TMI-2)
Operating License Nos. DPR-50 and DPR-73 Docket Nos. 50-289 and 50-320 Combined Management Meeting (50-289/80-32, 50-320/80-21)
This letter is being submitted to clarify our position on the meeting summary provided in your letter of December 31, 1981. The following comments are given:
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Item 22-20 is distinctly different from those minutes taken and discussed by members of the Met-Ed/GPU staff. We did not commit to develop aad utilize a conservative neutron flux to dose conversion factors at this time as stated in your 12/31/80 letter.
Item 22-19 NRC minutes do not indicate as do the Met-Ed/GPU minutes that the current badge system was determined to be acceptable for TMI-1.
Sincereir, H. D. Hukill Director, TMI-l HDH:LWH:1ma cc:
L. Barrett 8104150 N r.ietrcoonta, Ed scn Company ss a ',temter of !ne General Puthc UtMes System
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s Metropolitan Edison Company Post Office Box 480 gj Middletown, Pennsylvania 17057 717 944-4041 Writer's Direct Dial Number February 27, 1981 LlL-063 Office of Inspection and Enforcement Attn:
B. H. Grier, Director Region I U. S. Nuclear Regulatcry Commission 631 Park Avenue King of Prussia, PA 19406 Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Health Physics Evaluation
Dear Sir:
In telephone conversations with members of your staff, we were advised that supple = ental information was desired to the responses given in my December 16 and 30, 1980 and February 2, 1981 letters.
This additional information is necessary to close those items identified in your November, 26, 1980 letter as requiring resolution prior to restart.
The supplemental responses which are enclosed have been reviewed and agreed to by members of our respective staffs.
Sincerely
/
I R. C. 4.. ld l
Chief Operating Executive RCA:WEP :JRP :bj o Enclosure l
cc:
L. Barrett i
R. W. Reid i
V. Stello l
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SUPPLEMENTAL RESPONSE TO FET-ED LETTER DATED DECEYBER 16, 1980:
Ite=s A1, A2 and 3:
In addition to the procedure revisions noted in our earlier response to Ite=s Al and A2, increased e=phasis on procedure co=pliance, other i= proved pro-cedures, additional assigned personnel resources and personnel reinstruction in the corporate policy of verbati: co=pliance function as a syste= to prevent re-l currence of this ite=.
Licensee will ensure that the =anage=ent policy on use of and verbati= co=pliance with procedures is included as part of the GET and 2
annual retraining programs.
l Ite: D:
The Whole Body Counting equipment =ust be operated by a certified indivi-dual. This require =ent is specified in the Whole Body Counter operating speci-fication. Individuals are certified by P3.C upon co=pletion of the Whole Body Counter Training Prcgram, which is established by a Training Outline. The Whole Body Counting equipment is operated in accordance with RMC written procedures.
These ite=s (Operating Specifications, Training Outline and Procedures) are a part of the Whole Body Countiag Manual, which has been approved by GPU Radio-logical Controls. The QA Progra=, which verifies the adequacy of the Whole Body
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Counter service, is specified in RCP 4239.
Included in these require =ents, a=ong other ite=s, are daily source checks and quarterly calibration checks with a phan-to= containing radioactive sources. These checks are reviewed by trained and ex-perienced personnel in the Radiological Controls organization. The RCP will be revised by May 30, 1981 to specify performance standards and review require =ent by the Radiological Health organization.
The Manager, Radiological Health, with assistance 'ro= the Manager, Radio-r logical Technical Support, is responsible for verifying co=pliance with the above procedures and for ensuring that the Whole Body Count Progra is =aintained consistent with applicable Regulatory Guides and Standards. The Quality Assurance Depart =ent also =onitors and audits perfor=ance in this area as a part of their regular audit progra=.
SUPPLEMENTAL RESPONSE TO MET-ED LETTER DATED DECEP3ER 30,1980:
Ite= 22-16:
The Training Department Ad=inistrative Manual describes programs already in place in the areas of Radiological Controls, General E=ployee, Rad Waste Training and the Instructor Develop =ent Progra=. Therefore, formal i=ple=entation for those areas is the date of issue of the =anual.
Ite: 22-17:
The TMI-2 Radiological Controls Section of the Corporate Radiological Con-l trols Training Manual was approved on February 27, 1981. This section of the
=anual is eff ective on issue. The responses provided by our letter refers to this manual section as a procedure.
Training of Unit 2 Rad Waste personnel is covered by the Training Depart =ent's Ad=inistrative Manual, f
Enclosure No. 1
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- SUPPLEMENTAL RESPONSE TO MET-ED LETTER DATED FEBRUARY 2,19f;1:
Item 22-19:
With noted exceptions, the beta correction factors used for TMI Station are based on a natural uranium correction factor.
Compared with a Strontium 90 beta correction f actor, this is a " conservative" or higher factor; therefore, if used La a beta radiation field composed of mixed isotopes, some of which were Stron-tium 90, use of this factor would yield a slightly higher exposure indication.
This correction factor is determined by technical personnel and then programmed into the computer for automatic beta interpretation and requires no manipulations or calculations on the part of the TLD equipment operator. Likewise, some Stron-tium 90 activity La a beta field will yield slightly higher exposure indications on the gamma component. S ince, in most areas, this is a small percentage and the exposure indications are higher than actual (conservative), normally no correction is cade.
In some areas of U' it 2, where significant quantities of Strontium 90 n
are found, dose assessments by technical personnel are made on a case basis where the indicated exposure warrants. Entry to these areas is rigidly controlled and requires completion of detailed data sheets and approval Director, Radiological Controls Unit 2.
4 Item 22-22:
Radiological Control Procedure 4200, TLD Assignment, Issue and Data Handling provides procedures for the issuance of extremity monitoring devices and special nonitoring devices; however, it lacks the specificity to ensure that the specific items noted in the Evaluation Report will be accomplished. RCP 4200 will be re-
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vised to add the needed specificity as to performance standards which must be considered in making individual dosimetry decisions. This revision will be com-pleted by May 30, 1981.
Item 22-34:
The hand and foot counters are currently being electronically calibrated and source checked. A procedure change is undergoing review and approval which will i
formalize this calibration / source check. The revision will be issued by May 30, 1981.
Item 22-36:
Licensee has confirmed the appropriateness of continued use of the present j
detector counting efficiency f actor. This is based on a report of calibration dated July 12, 1979 supplied by the source vendor and a report from the National Bureau of Standards dated August 22, 1979, both of which indicate a finding of essentially the same calibration source surf ace emission rate. Nevertheless, we are pursuing the question of source medium and have placed an order for filter media sources with a firm in California.
After receipt of these sources, checks including autoradiographs will be conducted by licensee. Additionally, it is in-tended that the sources be sent to NBS for their certification. After the sources are returned from NBS, efficiency studies will be conducted by licensee. The NRC will be advised within 60 days of our progress on procurement, checking and certi-fication of the filter medium source, and af ter completion of the efficiency studies, the "RC will be informed of the findings.
Enclosure No. 1
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