ML20009H555

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Responds to NRC Re Violations Noted in IE Insp Rept 50-320/81-03.Corrective Actions:Radiological Controls Procedure Manual Completed & Guidance Provided to Personnel
ML20009H555
Person / Time
Site: Crane 
Issue date: 07/02/1981
From: Hovey G
METROPOLITAN EDISON CO.
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20009H548 List:
References
LL2-81-0172, LL2-81-172, NUDOCS 8108100237
Download: ML20009H555 (2)


Text

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Metropolitan Edison Company Post Office Box 480 0

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Middletown, Pennsylvania 17057 vvnter's Direct Dial Number July 2, 1981 LL2-81-0172 Office of Inspection and Enforcement Attn:

Mr. Boyce H. Grier, Director Region I U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406

Dear Sir:

Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Inspection Report 50-320/81-03 This is in response to the subject Inspection Report issued on May 19, 1981. As stated in the Inspectica Report, no items of non-compliance were observed. However, swo areas of concern were identified in the area of administrative control for the Radiation Protection Plan imple-menting procedures. These areas of concern are addressed below:

Item A Item 8a remains open pending:

1.)

Licensee appioval and issuance of the complete Radiological Controls Procedure (RCP) Manual, 2.)

the Licensee review / revision of procedures to assure health physics personnel are not adversely impacted on performance of radiological work coverage, and 3.)

the Licensee revising the procedural control system to address Radiological Control's Department inter-facing with respect to procedure changes / revision.

Response

1.)

All of the originally committed procedures have been approved and implemented except the exposure tracking program. The NRC has been previously advised of the delay of issuance of this procedure.

This item is addressed in Item 14.b and c of the subject Inspection Report.

Since this procedure is the only outstanding item and since it is the subject of a separate audit finding as discussed above, the RCP Manual committment is considered complete.

l 2.)

The primary objectives of shift radiological control personnel includes radiological work coverage as well as periodic surveillances and surveys of posted areas in compliance with regulatory require-ments and existing company procedures.

In the preparation of the procedures which constitute the Radiological Control Procedure Manual, 0

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3 Mr. Boyce H. Grier LL2-81-0172 rigid guidelines were followed to ensure that the responsibilities of the shift radiological control personnel were inclusive of but limited to the department responsibilities. Complir.nce with written procedures is stressed by departmental and company management.

Therefore, the licensee feels that the procedures not only do not adversely impact the performance of primary objectives, but accurately reflect and. implement the primary objectives of the shif, personnel.

3.)

Guidance has been provided to persons responsible for processing TCN's and PCR's involving Radiological Engineering related metters to obtain the review of Radiological Engineerirg prior to implementing the change. This item is addressed further in our response to Inspection Report 50-52J/81-01.

item B Se subject Taspection Report indicates that interim measures 7*

.ed to expedite procedure review for procedures involved s

.auiological controls. These interim measures should be used until a change to Section 6 of the Technical Specifications is submitted.

Eesponse j

The licensee has reviewed the area of concern.

It is felt that some of the problems related to lengthy procedure review were caused by the extensive number of procedural changes and revisions experienced in the past. The number of these changes have been substantially reduced. This reduction should result in

.1 faster turn around time for procedure review.

Additionally, personnel involved in the review as well as administrative functions (typing and printing) have been requested to expedite their work on Radiological Controls type procedures to ensure as quick of turn around tine as possible.

It is felt that these items will result in a substantial time reduction in the procedural review process and constitute a satisfactory interim measure.

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f G.,K vey Vi: President and rector, TMI-2 GYh:RBS:SDC:djb cc:

L. H. Barrett, Deputy Program Director Dr. B. J. Snyder, Program Director, TMI Program Office