ML20030C026
| ML20030C026 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/27/1981 |
| From: | Hovey G METROPOLITAN EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20030C015 | List: |
| References | |
| LL2-81-0178, LL2-81-178, NUDOCS 8108250320 | |
| Download: ML20030C026 (2) | |
Text
Metropolitan Edison Company l[l
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g j Post Office Box 480 L1 i-Middletown, Pennsylvania 17057 Writer's Direct Dial Number July 27, 1981 LL2-81-0178 Office of Inspection and Enforcement Attn:
Mr. Boyce H. Grier, Director Region 1 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 50-320/81-01 This supplemental response is being submitted based on discussions between oncitc NRC staff and our Licensing Department subsequent to our response of May 29, 1981 (LL2-81-0151).
In these discussions, it was emphasized that your main concern was the ability of personnel to implement a change to a procedure via the two man TCN rule without adequate review.
Specifically that personnel of one department could change a procedure to modify, remove, or in some manner alter a restriction or limit, which is under the cognizance of another department without that second departments awareness or concurrence. Your concern has echoed one which we have had and to which we were seeking a l
solution prior to the Inspection Report citation. Our efforts resulted in a modification to the two man TCN rule.
Essentially, the new rule referred to I
as the "two man plus" TCN rule was issued May 18, 1981 and added additional l
authorization requirements. Those relevant to this issue are:
1.)
the department head or his designee having custodial responsibility for the procedures or activities must approve the change, and 2.)
if the activity or procedare involves any kind of radiological involvement, impact or inter-face then a Radiological Engineer must review and approve the change prior to implementation. We believe that this administrative change will sufficiently address both the situation and your concerns.
The concept of the "Plus Rule" has also been incorporated into the new 4000 l
series Administrative procedures which are targeted for implementation about October 1981.
1 Although we are in agreement concerning the problem that existed with tle two man TCN rule, we contend that this subject is a discrete and separate issue from that of the cited changing of procedural intent. We are still of the belief, as stated in our previous response, that the intent of procedure 2104-4.39 was not changed by TCN 2-81-48 issued March 6, 1981 as cited in the Inspection Report.
R108250320 010817 PD8t ADOCK 05000320 0
PDR a an Ed: son Company is a Member of the General Pubbc UtMties Sys'em
=
Mr. Boyce H. Grier LL2-81-0178 The intent of the procedure, as reflected in its title, is to compact solid radwaste.
The purpose of the 500 mr/hr limit was to provide a front end guide by which one could reasonably ensure that the compacted drums would remain within the preferred type A LSA waste category during compaction of everyday' type Rad. Waste. However, this is not to imply that this procedure was intended only for the compaction of wastes of Type A LSA. This limit was derived from operational experience gained from compacting and shipping operations and was then utilized for the radiological evaluation and controls.
The generation of a large quantity of lower level radwaute (< 500 mr/hr) during the clean-up prior to this evolution afforded the opportunity to compact and ship the higher level bags as Type A LSA by mixing these higher level bags with the lower level, thus resulting in maintaining shipments within the Type A LSA category.
It was decided by the personnel involved with the TCN that to obtain a higher replacement limit for the TCN, the necessary survey of the bags to be compacted would result in unnecessary exposure to personnel. This was based on the high ambient radiation levels in the area the bags were stored and given that the operation was to be covered by Rad. Con, in accordance with the RWP for this function the limit was removed and not raised by the TCN.
Since the purpose of the 500 mrem /hr limit for the bags was to reasonably assure that compacted drums remained within Type A LSA limits, we feel that the TCN did not change the intent of the procedure.
As a matter of clarification the procedure has been revised to clarify how the >500 mr/hr bags are to be handled.
Sincerely,
\\
/
K l
. K. Hovey Vice-President and l
Director, TMI-2 GKH:SDC:djb cc:
L. H. Barrett, Deputy Program Director Dr. B. J. Snyder, Program Director - TMI Program Office I
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