ML20031D913
| ML20031D913 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/25/1981 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20031D911 | List: |
| References | |
| 1-219, NUDOCS 8110140361 | |
| Download: ML20031D913 (4) | |
Text
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TOLEDO
%mm EDISON Docket No. 50-346 ACHAno P. Cnoust License No. NPF-3 O'"
14191259-5221 Serial No. 1-219 September 25, 1981 Mr. James G. Keppler, Director U. S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
This is in response to your letter of September 2, 1981 (Report No. 50-346/31-11) concerning the Health Physics Appraisal Report for Davis-Besse Nuclear Power Station during the inspection on January 12-23, 1981.
The Toledo Edison Company recognizes the importance of strong health physics programs at nuclear power plants. Each significant appraisal finding has been addressed in the enclosed attachment.
Very truly yours, f ; ::L -
RPC/DWB/lrh Attachment CC:
D-B NRC Resident Inspector 4
8110140361 811000 FDR ADOCK 05000346 G
PDR THE TOLECO EDISON COMPANY EDISOt' PLAZA 300 MADISON AVENUE TOLEDO OHIO 43652 SEP 3 01981
Docket No. 50-346 Page 1 of 3 License No. NPF-3 Serial No. 1-219 September 25, 1981 Response to the significant appraisal findings in the NRC letter dated September 2, 1981.
Number 1 The health physics training program requires improvement regarding contract technician training, refresher training for chemical and radiation testers, and effluent quantification training for shift personnel. (Section 4.a, 4.c, and 9.e)
Response
(1) Contract technician training.
In order to ensure adequate training for contracc technicians, a training cut-line and test has been prepared. This training covers the material required for the type of work they will perform. Contract technicians are not used as the responsible individual on back shifts who can work alone.
The conttact training program will consist of four to eight hours of classroom training. This is in addition to General Orientation and Radiological Controls Training and on-the-job training as required. Resumes of contract technicians will continue to be reviewed.
Ccntract technician training will be fully implemented by the 1982 refueling outage.
(2) Refresher training for chemical and radiation testers.
Continuing training has been formalized since February,1981, in accordance with Revision 2 to AD 1828.12 (Chemistry and Health Physics Training).
AD 1828.12 also covers training for new workers. For initial training, there are ten volumes of study guides; these also serve as refresher training material for all the testers.
Refresher training consists of monthly review sessions of approximately eight heurs duration except during outages.
(3) Effluent quantification training for shift personnel.
In August 1981, the Shif t Supervisors were given training on AD 1827.10 (Emergency Off-Site Dose Estimates). On September 17, 1981, a major modifi-cation was prepared to AD 1827.10 which directs the user to AD 1850.04 (Post Accident Radiological Sampling and Counting) if the station vent monitor readings are off scale for noble gases.
The Shift Supervisors will receive additional training on how AD 1850.04 is to be used with AD 1827.10 in the event that AD 1827.10 cannot be used with the ncrmal station vent monitors. This training will be completed by October 12, 1981.
Docket No. 50-346 Page 2 of 3 License No. NPF-3 Serie?. No. 1-219 t
September 25, 1981 Number 2 The high range noble gas monitoring program needs improvement regarding instru-mentation capabilities and procedure revisions.
(Section 9.e)
Response
Energy response of the high range noble gas monitor has been evaluated and a conservative energy was used for the calculation.
An investigation was performed for low range response and the nobic gas detectors can monitor radiation from
~,
the sample tube even with a background reading of 5 R/hr outside the lead cave.
The high range emergency station vent system has been tested by insuring air f'ow through the sampler and radiciodine analyses verified with the normal station vent sampler.
Shift Supervisor training was addressed in the response to the first finding. A major modification wcs prepared to EP 1202.57 (Steam Generator Tube Leak) which addressed analyses when the main steam isolation valves are
closed. AD 1850.04 will be revised to include radiation protection precautions when samples are collected, how the procedur,e is related to AD 1827.10, and how the information is disseminated. The modification will be completed by October 30, 1981.
Number 3 i
The ALARA program needs improvement regarding ALARA reviews, worker input, and management oversight.
(Section 10)
Response
1 The appraisal team's report classified Health Physics Procedure HP 1601.05 as being " passive" prior to its revision in 1980.
This was hardly the actual situ-ation because the content of the procedure (based on Regulatory Guides 8 8 and 8.10)was fully used in planning maintenance work and completing Radiation Ex-posure Permits (REP).
l The following actions have been implemented to ensure an active ALARA program:
1.
A dose compilation by REP for jobs exceeding 500 mrems.
2.
A structured radiation safety inft action report system.
l 3.
Documentation, pre-job and post-job where higher personnel exposures can occur.
4.
An ALARA oversight group already exists as a function of the Company Fuclear Review Board to provide independent review and audit of radiological safety.
Additaanally, the Nuclear Review Group provides an outside consultation overview service for Toledo Edison's executive management. The ALARA program falls into their expertise and review.
Docket No. 50-346 Page 3 of 3 License No. NPF-3 Serial No. 1-219 September 25, 1981 5.
Radiation pr3tection technician and plant worker input for ALARA suggestions i
by a comment aheet included in every REP.
6.
ALARA review for applicable major modifications to procedures.
7.
ALARA review for applicable Facility Change Requests.
8.
An ALARA promotion program through posters.
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