ML20050A801
| ML20050A801 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/29/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20050A800 | List: |
| References | |
| NUDOCS 8204020285 | |
| Download: ML20050A801 (7) | |
Text
E PHILADELPHI A ELECTRIC COM PANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIE LDS L. D ALTROFF attcf m c Pm o CTioN January 29, 1982 Docket Nos. 50-277 50-278 Mr. Thomas T.
Martin, Director Division of Engineering and Technical Inspection U.
S.
Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Your letter of December 30, 1981, requested additional clarification of our June 5, 1981, response to Combined Inspection Report 50-277/80-18 and 50-278/80-10.
The " Items for Clarification" in this response were discussed in a telephone conversation between Mr. R.
Nimitz, Nuclear Regulatory Commission, and Mr. W.
Knapp, Philadelphia Electric Company, on November 25, 1981.
Fo1 lowing are the items addressed in the attachment to your letter and our responses which include any supplemental information discussed in the conversation between Mr. Nimitz and Mr. Knapp.
Item No.
- Description A.1 Job / Position descriptions for Radioactive Waste Personnel 8204020285 820329 PDR ADOCK 05000277 G
PDR l
i
Nr. Thomas T.
Martin, Director Page 2 Items for Clarification Response does not address the job description and responsibilities of the Rad Waste Department, particularly the Rad Waste Supervisor.
Response
Philadelphia Electric Company has committed to developing job descriptions for all positions identified on the Organizational Chart.
This wi)) include the job description and responsibilities of the Radwaste Supervisor's position.
The expected completion date for this document is May 28, 1982.
B.1 Formal training / qualification program for personnel in tech-nical areas e.g.,
TLD system, external dosimetry, internal dosimetry, etc.
Items for Clarification Response does not reflect training in progress, or management involvement.
Specific items are:
sign-off sheets for procedure review, determination that personnel can implement procedures, the frequency of training and management assurance that a procedure is being implemented.
Response
New procedures are introduced and discussed at Health Physics technician meeting with the TA group held weekly during non-outage periods.
During major unit outages when work load is increased, these meetings are held only when significant changes to procedures require additional attention or instruction.
Frequently, instruction and clarification is provided by the supervisor health physics.
The attendarra and topics of discussion for these meetings are presently being documented and l
l
l Mr. Thomas T.
Martin, Director Page 3 filed.
The ability of personnel to implement procedures is determined by supervision and by the results of the QA audit.
After instruction and training, all techs personally demonstrate their ability to perform procedures to a member of the health j
physics technical assistant staff.
Management assurance that procedures are being properly implemented is provided by reports given HP supervision to the corporate radiation protection management and plant management.
Results of QA and NRC audits are passed to the highest departmental level.
Refer to the responses to items B-4 and B-5 for further details on training.
B.4 Training program for health physics professional staff Items for Clarification l
Response does not identify a program that ensures proficiency of I
supervisory staff.
This should include a supervisory review of i
procedures, a specified frequency of training, and evidence of i
the licensee's attitude toward keeping people proficient and i
knowledgeable.
l
Response
Training for the health physics professional staff is provided partially by their attendance at seminars, workshops and courses designed to supplement an individual 's knowledge in his general areas of responsibility.
These are chosen according to the need and the availability of supervisory personnel and the scheduling possibilities of high quality programs.
Philadelphia Electric Company has sent three members of its supervisory staff to the radiation specialty school and three members to the Chemistry specialty school held by General Electric.
Corporate radiation protection staff also participate in special training programs conducted by vendors and consultants, e.g.
Electric Boat's ALARA
Mr. Thomas T.
Martin, Director Page 4 training and Babcock and Wilcox radio-chemistry course.
Job descriptions of the professional staf f are being developed.
Evaluations will determine the proficiency of the professional staff in their areas of responsibility.
Staff meetings will provide the opportunity for presenting specific procedural changes and serve as a procedural review format.
These meetings will be held weekly during non-outage periods, and as needed during outages.
The attendance and topics of discussion will be documented and filed.
Refer to the responses to items B-1 and B-5 for more information.
B.5 Training and qualifications of health physics supervisory personnel Items for Clarification Response does not address how supervision is assured that personnel can implement procedures, that on-the-job training does what it is supposed to do, and some documentation that an individual has profited from on-the-job training.
Response
Individuals in eupervisory positions are at a professional level.
Job descriptions and responsibilities for all these positions are being developed.
The yearly evaluation of performance is designed to measure the proficiency of an individual in the area to which he has been assigned.
This evaluation demonstrates to management the results of the individual's on-the-job training, and the ability to implement the appropriate procedures.
Philadelphia Electric Company recognizes the importance of adequately trained personnel.
This is quite evident in the extensive training programs conducted at Peach Bottom and at the corporate office for all groups, especially for licensed reactor operators.
The need for improvements in training of groups such as HP & C professionals is recognized.
Documentation of this l
l l
Mr. Thomas T.
Martin, Director Page 5 training also could be improved.
Improvements in these areas will be initiated immediately.
C.1.a Investigation, review and resolution of dosimetry QA/QC program discrepancies C.I.b Same as C.1.a Items for Clarification i
HPO/CO 32 does not describe how data is evaluated, what is done with QC data, management review of discrepancies, responsibilities for review and action, and details for resolving discrepancies.
Response
Procedure HPO/CO 32 " Quality Control of Personnel Dosimetry" is being reviewed.
It will be revised to include:
a description of how data is evaluated utilization of QC data method and responsibility for review, reporting, and actions on abnormal data method and responsibility for resolving discrepancies This revision will be completed by March 1, 1982.
C.2.a Periodic limited quantitative calibration check of whole body counter Items of Clarification Response does not provide sufficient detail to show that the whole body counter is in calibration.
Daily check source should be more than a response check.
1 j
Mr. Thomas T.
Martin, Director Page 6
Response
l Full quantitative r:alibrations of the whole body counter are done l
by our radiation consultant, Radiation Management Corporation, (RMC).
Procedures and records are available for your review.
Full calibrations are performed when the need is indicated by the daily qualitative / quantitative response checks.
These daily checks follow the guidance of ANSI N343-1978.
Counts are done on the daily check sources and these reports, as well as background counts are kept on file in the dosimetry office.
HPO/CO 26 will be revised to include a better description of the daily operation of the whole body counter.
The most recent revision of this procedure does describe what is done with the findings.
The new revision of HPO/CO 26 will be completed by March 1,
- 1982, s
C.2.c Procedures for collection, handling and transport of bioassay samples Items for Clarification No procedures describe fecal analysis.
No procedure describes the collection, handling, preservation and transportation of biological samples.
Response
Internal dosimetry is monitored through the use of whole body counting.
If the need for further analysis is determined, then HP Supervision will be notified.
Communications may be established with Radiation Management Corporation (RMC) for their medical / radio-analytical advice.
If necessary, the Philadelphia Electric Company Medical Director is consulted.
Based on the discretion of HP supervision or RMC's consultation, appropriate samples vill be collected and will be analyzed.
Appropriate actions are then be taken.
Follow up actions are to be based on the advice of the Philadelphia Electric Company Medical Director.
HPO/CO 26 " PERSONNEL BIOASSAY PROGRAM" will be revised to address more fully the collection, preserving, handling and transport of samples for analysis.
This revision will be completed by March 1,
1982.
~
=
Mr. Thomas T.
Martin, Director Page 7 C.2.d Maintenance Program for constant air monitors Items for Clarification 1
(None provided)
Response
It is recognized that there is a need to develop a comprehensive, routine maintenance program for the Peach Bottom Continuous Air Monitors.
This responsibility has already been assigned to a newly designed instrument and repair group which reports functionally to health physics supervision.
Thi s wi ] ] ensure that an efficient and effective continuous air monitor program is maintained.
The estimated date for implementation is July 1, 1982.
Very truly yours,
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