ML19350D416
| ML19350D416 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/13/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19350D411 | List: |
| References | |
| NUDOCS 8104150455 | |
| Download: ML19350D416 (6) | |
Text
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V BALTIMOR E GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475. BALTIMORE, MARYLAND 21203 ARTHUR C. LuNOVALL. JR.
v,cc p.cs.oc~r sv.%v February 13, 1981 U.S. Nuclear Regulatory Commission Docket Nos. 50-317 Region I 50-318 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. B. H. Grier, Director Office of Inspection & Enforcement Gentlemen:
This refers to your Inspection Report 50-317/80-09; 50-318/80-07, the Health Physics Appraisal.
Please note that our response to Appendix B to this report was dated January 16, 1981.
Enclosure (1) to this letter is a written statement in response to Signif-icant Appraisal Findings noted in Appendix A of the same report.
Should you have further questions regarding this matter, we would be pleased to discuss them with you.
Very truly yours,
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o E. Lund*all, Jr.
Vice President - Supply l
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Mr. B. H. Grier February 13, 1981 STATE OF FMRYLAND:
TO WIT:
CITY OF BALTIMORE:
Mr. A. E. Lundvall, Jr., being duly sworn states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he executed the foregoing Response for the purposes therein set forth; that the statements made in said Response are true and correct to the best of his knowledge, information and belief; and that he was authorized to execute the Response on behalf of said corporation.
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WITNESS my hand and Notarial Seal, i
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My Commission Expires:
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ENCLOSURE (1)
REPLY TO APPENDIX A 0F IE INSPECTION REPORT 50-317/80-09; 50-318/80-07 HEALTH PHYSICS APPRAISAL ITD4 1 As a result of an organizational change of T-01-80, the responsibility for activities pertaining to radiation safety rests with the Radiation Safety Section of the Nuclear Power Department. The General Supervisor-Radiation Safety (GSRS) has the authority and responsibility to direct the operations of the Section. The Plant Health Physicist is one of three positions providing staff technical support to the GSRS in the areas of health physics, radvaste and emergency planning.
The General Supervisor-Radiation Safety is fully qualified as an RPM and assigns, reviews and approves those tasks undertaken by the Plant Health Physicist.
ITEM 2 The span of control of the Radiation Safety and Chemist.ry Foreman has been addressed in the organizational change of 7-01-80.
The Radiation Safety Section nov has three units, each with its own unit c pervisor reporting directly to the General Supervisor-Radiation Safety. This change, l
together with the placement of chemistry functions under a separate i
Genersl Supervisor-Chemistry, has relieved the high vor.ker per supervisor ratio. The new organization has the following ratios:
Position Sutervises (1) Supervisor-Radiation Control 19 Persons (1) Supervisor-Dosi=etry 6 Persons (1) Supervisor-Radiological Support 11 Persons During the outage situations additional =anpower is assigned to all three units, and vnere necessary, the General Supe-visor-Radiation Safety assigns portiens of the units ad=inistrative work load to the staff personnel. Additionally, the six Principle Technicians are utilized as work leaders in accordance with their job description. This provides the appropriate supervision of the extra v crk personnel brought in to aug=ent the Radiation Safety Section in the high vork lead periods.
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ITEM 3 In Dece=ber,1980, a calibration check was perfor=ed on Calvert Cliff s' whole body counter using a phantom containing radioactive sources of mock-iodine-131 (barium-133 plus cesium-137), cesium-137 and cobalt
-60.
Results were analyzed and comparisons were performed which indicated the response of the counter was within 5 percent of expected values. A program to ensure adequate calibration of the counter sufficient to assure reproducible quantitative evaluation in hu=ans vill be developed. Periodic calibration checks vill be conducted as part of the calibration program.
ITEM h B G & E is co==itted to ALARA as evidenced by a 1981 Corporate Goal to review systems and procedures to ensure that radiation exposures are ALARA. This Goal is reflected in Performance Objectives for the Radiation Safety Section supervision and staff.
A =ajor revision to upgrade the Radiation Safety Manual (Calvert Cliffs Instruction CCI h00B) is underway.
Included in this revision vill be the necessary policy statements with respect to ALARA.
This revision is currently scheduled to be put in effect in =id-1981.
At the present, statements stressing keeping exposures ALARA do exist in CCI LOOB and are presented in training of personnel. A prototype ALARA task analysis and check list is currently being imple=ented (during Unit 2 refueling) for a limited number of major exposure tasks to allow an evaluation of the method prior to for=alizing the ALARA reviews into a procram. The formalized ALARA program as described in Regulatory Guide 8.8 is planned to be co=pleted and i=plemented by the end of 1981.
l ITEM 5 Techniques and procedures sufficient to =eet " Category A" requirements of NUREG 0578 relating to Ite=s 2.1.8.a, 2.1.8.b and 2.1.8.c have been developed, included in our next revision of Calvert Cliffs E=ergency Response Plan Imple=entation Procedures (ERPIP), Revision 1, and are described as follows:
Centain=ent atmoshpere samples vill be obtained utilizing the radiation monitoring system (RMS):
for contain=ent area radiation l
monitor readings (RMS) of 200 =R/h to 3,000 R/h, samples are to be taken locally using the Service Water Roo= for access; for RMS j
l readings greater that 3,000 R/h, sa=ples are to be taken by grabbing l
a sample from the Main Vent after it passes through the hydrogen analyzer. This techniq1te vill assure that personnel exposures are as lov as is reasonably achi6vable.
Reactor coolant samples vill be obtained directly from the sa=ple sink utilizing re=ote handling devices. A five milliliter sample is takta and subsequently diluted to perform the necessary analysis.
e 3-ITEM 5 continued Shielding is provided for exposure control purposes during obtaining and transporting the reactor coolant sample and to assure that personnel exposures will be as lov as is reasonably achievable.
4 Main vent release rate techniques to be used in the event the
. Vain Vent RMS is off-scale vill be performed utilizing a high range exposure rate detector mounted externally to the Main Vent Stack with remote readout provided in an expected lov dose area, i.e., within the 69' elevation of the Auxiliary Euilding. This vill assure that personnel exposures vill be as lov as is reasonably achievable.
ITEM 6 The Training and Technical Services Section of the Nuclear Power Department is currently developing a formal training program to provide the necessary classroom training in radiation safety to take individuals with varying degrees of background training to a level of knowledge acceptable in comparison to the requirements of ANSI 18.1.
To complement this classroom training, the current practice of on-the-job training and qualification, with appropriate evaluation and sign-off by the responsible supervisor, vill be continued.
For those personnel currently in position as qualified technicians, case-by-case evaluation of the technical training needs is part of an on-going program.
Specialized training courses, off-site or on-site, vill be utilized as they are applicable and available to fill background
" weak spots" for these personnel.
Such training vill include testing and evaluation of student performance.
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ITEM 7 In regard to our emergency planning and preparation, the following items have been accomplished:
a.
An ensite individual has been assigned to perform as the Energency Response Plan Coordinator. Presently, this responsibility has been assigned to the Plant Health Physicist by title and a clear description of his responsibilities is contained in Calvert Cliffs' upgraded Emergency Response Plan (ERP), Revision 0, dated December 31, 1980, and D:ergency Response Plan I=plementation Procedures (ERPIP), Revision 0, implemented on Decenter 15, 1980.
Copies of these documents have been previously distributed to NRC Region I (IE).
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ITEM 7 continued b.
The ERP and ERPIP clearly describes the upgraded onsite emergency organization which includes responsibilities for offsite and onsite survey and environmental sample collection as well as in-plant aspects of a response related to radiation protection. The Radiological Assessment Director is responsible for offsite monitoring and sample collection and Radiation Protection Director is responsible for radiation protection, chemistry, in-plant surveys, personnel monitoring, etc. The reorganized emergency organization is adequate to cope with emergency situations of rather long durations due to the capability for covering shift work during emergency periods.
Separate procedures for each class of emergency specified in c.
the ERP have been included in the ERPIP.
Emergency Action Levels and preplanned response actions to be considered or implemented in response to each class of emergency are part of the immediate and emergency action procedures contained in the ERPIP.
d.
The ERPIP notification procedures clearly specify the action levels which would result in notifying the emergency response organization. Plant operating procedures have been developed which reflect the use of the Emergency Notification System for notifying NRC.
Specific procedures governing the performance of offsite, onsite e.
and in-plant radiation surveys and for the performance of emergency personnel monitoring and decontamination were developed and are included in the emergency action procedures of the ERPIP.
f.
The ERPIP's radiological assessment procedures provide for integrating and coordinating all sources of radiological and operational assessment information and data for evaluation of projected radiological consequences of an accident.
Provisions for conducting an emergency radiological environmental g.
monitoring program are contained i n the Radiologic al Assessment Director and Environmental Services Coordinator's procedures included in the ERPIP.
- h. through k.
Provisions covering the scope and nature of the radiatien protection program under emergency conditions, the conduct of emergency repair / corrective action (s) or teams, and for using observers during exercises and drills and for evaluating and correcting items highlighted during drills as needing improvement are ir.cluded in the ERPIP.
In addition, ERPIP procedures include the inventering and operationally checking all ite=s of emergency equipment and all emergency facilities.