ML20009E869
| ML20009E869 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/11/1981 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20009E858 | List: |
| References | |
| 81-93, NUDOCS 8107280499 | |
| Download: ML20009E869 (4) | |
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BOSTON EOtsON COMPANY DENERAL OrrecEg 500 ggyLgTON STnEET SO sTON. M AE BACHUS ETTs 02199 A. V. M O Rt 51 MANAGER NUCLEAR OPERATIONS SUPPORT DEPARTMENT May 11, 1981 BECo. Ltr. #81-93 Mr. Boyce Grier, Director Office of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA.
19406 License No. DPR-35 Docket No. 50-293 Supplemental Response to IE Inspection No. 80-05 Ref. ( A) Response to IE Inspection No. 80 BECo. Ltr.
No.80-202 dated August 29, 1980 (B) Special NRC Health Physics Appraisal, IE Inspection Report No. 80-05 dated July 22, 1980
Dear Sir:
In Reference ( A) Boston Edison Company responded to IE Inspection Reoort No. 80-05.
Within that response BECo provided its plans for implementation of corrective actions and the schedules for completion of the actions for each of the items identified in Appendix A to Reference (B) as Significant Appraisal Findings. The purpose of this letter is to notify you that the completion dates, provided in Reference ( A), could not be met for two items :
Internal Dosimetry Program and Respiratory Protection Program. Attachment ( A) to this letter contains a descrip-tion of each item, the original commitment, the detailed reasons for the delay in program completion, the current status of each program and the newly projected completion dates.
Boston Edison Company is committed to achieving and maintaining a strong, effective health physics program and the concerted ef fort being exoended to produce totally integrated, state of the art Internal Dosimetry and Respirator; Protection programs, docunents that conmitment.
We trust that the information supplied in Attachment A to this letter substantiates the extensions necessary to complete implementation of the programs. However, 1
should you have any comments or questions concerning this matter, please do not hesitate to contact us.
Very truly yours, 8107280499 810724 PDR ADOCK 05000293 PDR g
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Attachment ( A)_to BECo. Letter No. 81-93 The following format is used for each of the items addressed in the cover letter:
(a) The Significant Appraisal Finding as identified in IE Inspection Report No. 80-05, Reference (3)
(b) Boston Edison Company response to that finding as provided in Reference (A)
(c) The supplemental response to that finding including reasons for completion delay, current status of each item and the newly projected completion date.
SIGNIFICANT APPRAISAL FINDING - Reference (B)
A.
Internal Exptsure Control Program The overall program for internal exposure control was found to be in-adequate and not effective due to:
2.
lack of procedures to provide for proper collection, handling and analysis of indirect bioassay samples; together with a lack of pro-cedures establishing biological models and calculational techniques necessary to evaluate monitoring data in terms of dose assessment and compliance with intake limitations set forth in 10 CFR 20.103.
Response A-2. - As Provided in Reference (A)
In the month of June, four Health Physics Engineers attended a one week course on Internal Dosimetry at the University of Lowell, Lowell, MA.
At the present time, indirect bioassay sampling and interpretation of results is under evaluation.
Consultants are in the process of being contacted to assist Boston Edison in developing a comprehen-sive Internal Dosime'.ry Program.
Supolemental Response to A-2.
Following the completion of the Internal Dosimetry training course by members of its staff, Pilgrim Station's Health Physics Group initiated a reevaluation of its planned internal dosimetry prograr developments.
Considered during this reevaluation were the pending International Committee on Radiation Protection (ICRP) recommenda-tions which had been issued in draft fomat during 1980.
It became obvious during the reev='.uation process that the scooe of the internal dosimetry program development was much larger than originally conceived and its nature more complex t,han initially anticipated.
In the late fall of 1980, a decision was made to ex-pand thb scope of the program to encompass the proposed ICRP recommendations as much as possible.
To achieve this goal, an emminent figure in the Health Physics Consulting a ca was contracted to develop th> internal dosimetry L
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program for Pilgrim Station which would incorporate those aspects of the ICRP draft recommendations deemed applicable.
Due to the complexities invcived in this newly scoped program development the projected completion date for this effort is January 1,1982.
(SIGNIFICANT APPRAISAL FINDING)
A.
3.
failure to ensure consideration of engineering controls for airborne radioactivity areas or to evaluate and doctnent the practicability of applying process or engineering controls in airborne radioactivity areas. Excessively high loose radioactive contamination levels existed in many areas of the olant and a program to reduce and maintain significantly lower levels was not implemented.
Response to A-3.
As Provided in Reference (A)
The consideration of engineering or process controls and the practicality of their use in airborne radioactivity areas is currently being implemented through the ALARA Program Procedures.
In addition, these procedures address the initial decontamina-tion of areas containing high levels of radioactive contamina-tion as well as making reasonable efforts to maintain low con-tamination levels.
The Respiratory Protection Program and accompanying procedures, which are in the process of being written, will incorporate the consideration and use of engineering and process controls in air-borne radioactivity areas on an expanded scale to raeet the guide-lines of NUREG-0041.
Full r.plementation of the ALARA procedures was achieved on August 4,1980, and full implementation of the Respiratory Protection Program and accompanying procedures will not be achieved until Marcn 1,1981, depending upon the procurement of necessary equipment and facilities. Several facilities are being evaluated at this time, which could result in implementa-tion of the Respiratory Protection Proaram and accompanying procedures as early as January 1,1981.
Supplemental Response to A-3.
Delays have been experienced in equioment procurement and delivery, facility modifications and recruitment of experienced personnel each of which is an essential component utilized in development of the Resoiratory Protection Program.
Modifications to the station air system are necessary to facilitate a fresh air supply network. The naturi and scope of these design changes have been determined and equipment ordered.
Installation is dependent upon receipt d'f the equipment.
A drycleaning system for cleaning respirators, health physics test equipment and new respirators / face masks nave been purchased and are on site awaiting completion of the modifications to the dedicated facility.
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At this juncture the Respiratory Program is approximately 80%
complete. The procedures, which are an adjunct of the program, are approximately 50% complete.
Completion of the total program is contingent upon completion of the essential components and the major contributor to the delay, the facility modifications, is now scheduled for completion during August,1981. A draft of the program and its implementing procedures will be available at that time.
Implementation of the final Respiratory Program will be achieved by September 1,1981.
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