ML20125B373
| ML20125B373 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/13/1979 |
| From: | Herbein J METROPOLITAN EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20125B361 | List: |
| References | |
| NUDOCS 7911060141 | |
| Download: ML20125B373 (15) | |
Text
-..
- i. ? '
(
(
.(
Y Yhhh No?!'o O S O E ' " '
M;dd! stow.s. Pennsylvania 170s 717 944 4o41 i
August 13, 1979 Mr. B. H. Grier, Director Office of Inspection and Enforcement Region I U.S. Nuclear Regulatory Conaission 631 Park Avenue King of Prussia, Pennsylvania 19406 r
Dear Sir:
Three Mile Island Nuciear Station Units 1 & 2 (TMI-l and TMI-2)
Licerise Nos. DPR-50 and DPR-73 Docket Nos. 50-289 and 50-320 Radiation Protection Organization Met-Ed has continued its effort to meet the cenrnitments of our 7/18/79 htter (GQL 0909) as modified by our 8/6/79 letter (GQL 1018).
At our 8/10/79 meeting with Mr. White and Mr. Crocher of your staff, items pertaining to the overall Radiation Protection Program organization were presented t: maet the 8/1C/79 ccmitments identified in GQL 1018.
The specific status of each item identified in our-8/6/79 letter (GQL 1018) is presented below.
1.
The following items were presented to your representatives at the S/10/79 r.ee ti ng.
Copies of the formal documents are enclosed, Revi, sed Radiation Protection Program Organization Chart. FM a.
b.
Descriptions of the specific responsibilities of each functional area identified on the Radiation Protection Program Organization Chart.
The individuals responsible and the lines of responsibility for each c.
functional area are described in (a) and (b) above, i
d.
A plan view chart of Units 1 and 2 which delineates the geographic areas of responsibility for each unit.
2.
Met-Ed is continuing the review of the adequacy of the Q. A. program as it relates to providing for regular audits of the Radiation Protection Program by individuals who are independent of the day-to-day radiological protection activities.
Documentation of the review will be completed by 8/15/79.
i 3.
The procedure for the control of High Radiation Areas was reviewed by the Plant Operations. Review Committee with changes which include your staff's cements of. 8/3/79.
A copy of the approved procedure was provided to Mr. White of your staff on 8/7/79.
lv 7911060
?
ue: reman Lesen com;wny e, a Memte chhe General Pus.: unw sg:em
n =l -
~
' Mr. S. H. Grier, Dir' tor f August 13, 1979 4.
The procedure for evaluating air sample results with respect to beta-gac.a ratios and beta energies was implemented by a Temporary Change Notice (TCN) cn S/3/79.
The TCN was presented to Mr. White of your staff with an explana-tion which addressed the coments received from your staff.
5.
a) Health Physics Procedure " Internal Dosimetry / Bioassay Program" (HP 1528)
~
describes the subject program and has been revised to incorporate the guidance provided in ANSI N-347, Reg. Guide 8.15 and NuReg 0041.
A procedure (HP 1628.1) for implementing the Internal Dosimetry /
Bioassay Program described in HP 1628 has been prepared which contains action levels for whole body counting and urinalysis for suspected acute and chronic exposures of Sr-89 and Sr-90.
Procedures HP 1628 and HP 1628.1 are presently undergoing review by the Plant Operations Revi.ew Comittee.
b)
Health Physics Procedure' " Respiratory Protection Program " (HP 1616) has been expanded in the form of an implementing procedure (HP 1616.4) which includes a detailed air sample analysis sequence with action levels specified when airborne concentrations of Sr-89 and Sr-90 (based on Cs levels) are measured.
This procedure (HP 1616.4) is presently undergoing review by the Plant Operations Review Comittee.
c)
The calculation of MPC hours for airborne cuncentrations of radio-actitity has been included in Health Physics Procedure "RWP Procedure" (HP 1613) and in 'an implementing procedure "MPC Hours" (HP 1616.5).
Procedures (HP 1613 and HP 1615.5) include the requirement for a pariedic review of air sample results.
Both of these procedures are presently undergoing review by the Plant Operations Review Committee.
d)
Procedu'res specifying the care, use, and cleaning of the respiratory protection devices available, tritium air sampling and overall respiratory program implementation are presently undergoing review by the Plant Operations Review Ccmmittee.
e)
Health Physics Procedure " Air Test Booth" (HP 1717) has been n: vised and is presently undergoing review by the Plant Operations Review Cormittee.
f)
A training program for HP foremen and technicians will be acccmplished so that the ccaprehensive bicassay program will be implemented by 17 August 1979.
6.
A procedure providing for ALARA review and evaluation of potentiai ex-posures of individuals to concentrations of airborne radioactive materials, as required by 10 CFR 20.201(b), will be reviewed and approved by.
August 17, 1979.
Sincerely, E
e r
/
J. G. Herbein JGH:djh Vice President-Nuclear Operations
.jc1 See-Attached c.heet
.i
4 g
i 3-(
August 13, 1979
[ '.lir. B. H. Grier, Dii tor cc:
R. C. Arnold J. Barton R. W. Dubiel D.'F. Limroth G. P. lifiler J.
Mudge D..
Reppert J. R. Thorpe Enclocure::
6 W
e l
i l
1111 51ATIC11 11[Atlet MIT51ts OrdA't12 At103
~
~.
V.P. - l'et-[d r
R. C. Arnold
~
Y. P. huClear Ops.
Olr, invironrental J. C. l a beln liet th & Safety Dir. - TP.1 2
Eccovtry J. Inorpe
- To be esilgaed I
i I
It r. - SUPf 0f0 3CUa Envirornental Monitor.
1 Lo?titlC3 H. P. Audit Progra cir. - kas ti Managerent J. }Md;e ti,twsthe G. P. Erlier
']
D. Eeppert Deputy J. Bartcn Supv. - Radiation Protect!oa L Chen.
Rad. Protection &
R. W. hbfel
_. Chemistry l
D. T. Limroth
[
l l
1 l-1 I
I I
I Supv.-Rad.
' Resp. Pret.
It? Eng/
Supy.
SepV.
Sepv.-Red.
Supy. Chea
' 5cpy. Rad.
' Chem. Eng.
E#
inste Sup.
ALArA Dostnetr Ehemistry Cheri sup.
E. Tuhrer C. Wibiln L. Landry
(. Seyb d G. Reed L frederld K. Itarner T. hulleavy W. Pitha (GD Prot.
Support fg l
l
{n, HP TC iElWI ltP f 0H Et'.*4 l
t
[.
i CIFIC RESPONSIBILITIES OF FUN (
Support 3ervices and logistics - Radiation Protection and Chemistry 1.
Supervisor-Radiation Protection and Chemistry 2.
Supervisor-Dosimetry 3.
Respiratory Protection Supervisor 4.
Chemistry Supervisor-Unit 1 5.
Radiological Engineering /ALARA Unit 1 6.
Supervisde-Rad Waste Unit 1 7.
HP Foreman Unit 1
- g. Environmental Health and Safety 1.
Environmental Monitoring Program 2.
H.P. Audit Program C. Waste Management Activity - Radiation Protection and Chemistry 1.
Radiaticn Protection 'end Chemistry Group Head
- 7..
Radiochemistry Supervisor 3.
Radiation Protection Supervisor 4.
Chr.istry Supervisor 5.
Radiological Engineering /ALARA - Unit 2 6.
Chemistry Engineer Support - Unit 2 7.
H. P. Foreman - Uni t 2 6
5
l SUPPORT SEP.91CES AND LOGIS[..S
' ['
RADIATION PROTECT,10N AND CHEMISTP:Y Within the Operating Staff of Unit 1 is established a major group with the mission of providing radiation protection and chemistry support.
The organization of the Radiation Protection and Chem ~.3try group is illustrated in Figure 1.
Under the group head are:
~
1.
Supervisor-Radiation Protection and Chemistry 2.
Supervisor-Dosimetry 3.
Respiratory Protection Supervisor 4.
Chemistry Supervisor - Unit 1 5.
Radiological Engineering /ALARA - Unit 1 6.
Supervisor - Rad Waste - Unit 1 7.
H.P. Foreman - Unit 1 1.
Supervisor - Radiation Protection and Chemistry The head of the Radiati'on Protection and Cher.istry Department reports to the Manager, Support Services and Logistics.
Reporting to him are the heads of the six sub-groups listed above.
Direct liaison is also conducted idth the Director, Waste Management Activity and the P.adiation Protection and Chc-mistry Supervisor of the Waste Management Group for the coordination of station-wide Radiation Protection and Chemistry policy.
The incumbent is responsible for the overall coordination and performance of personnel assigned and specifically for ensuring that'the Radiation Protection function is accomplished in full compliance wi th 10 CFR 20 (and other such regulations issued by competent authority and approved procedures) and the management of all chemistry functions associated with Unit 1 in accordance with the Unit's Technical Specifications and prinary and secondary water chemistry and radiochemistry procedural requirements.
The incumbent is also responsible for the implementation of Station Health Physics support functions (such as Dosimetry, Bioassay, etc.) for both Unit 1 and Unit 2.
The incumbent is the normal point of contact in dialogue with representatives of the Nuclear P.egulatory Comnission in matters of radiological concerns Unit 1.
2.
Supervisor-Dosimetry Responsible to both Radiation Protection and Chemistry Supervisors for the ccmplete Internal and External Dosimetry program including the supervision of all personnel in the dosimetry group.
The major functions include:
Do,se Assessment The dose assessment section is responsible for evaluations, calculations, and investigations of dosimetry results to assure that prope,r data is used to determine each individuals dose.
These people are also responsible for maintenance and delivery of the self-reader reports.
I i.
, External Dosimetry This section is responsible to the Supervisor-Dosimetry for proper control and maintenance of the TLD system.
This function includes TLD issue, reader operation, system calibration TLD Anomaly investigation and liaison with on-site organizations.
Inttenal Dosimegg/ _
This section includes implementation of the internal dosiretry program, sample collection and delivery, report, review and evaluation and computer input.
3.
Respiratory Protection Superyisor
~
Conducts a program designed to maintain the effectiveness and adecuacy of respiratory protection.
Program review includes:
wearer acceptance,
)
examination of respirators in use, evaluation of protection afforded, correlation of M?C - hours with measured doses, and records. Writes or reviess procedures to implement the requirements of NRC Regulatory Guide 8,15 and NuREG-00al.
Establishes liaison among the various departments that support the activity.
4.
Chemistry Supervisor - Unit 1 The Chemistry supervisor is responsible for the coordination and perfor-mance of those personnel reporting directly to him which includes one Chemistry Foreman and Met-Ed Rad-Chem Technicians.
The Radiochemistry supervisor will normally be qualified for this position in accordance with ANSI N18.1 - 1971..
Specifically, this position is responsible for:
The management of the water chemistry sample and analysis program within Unit 1 including both auxiliary and plant systems.
The selection, supervision, set-up and calibration of all chemical analytic ec.ui pr.ent/ systems.
The development or technical review of new chemistry procedures to meet emergent requirements or to improve those in use.
The identification of training requirements for personnel assigned including the actual conduct of training which will be coordinated with the station Training Department.
The technical supervision of the operation of the water and waste treatment systems of Unit 1.
Tne maintenance of chemistry records and reports required by procedures under his cognizance and/or by state or federal agencies.
Other duties assigned by the Radiation Protection and Chemistry Group Head.
Q
t $
e e
,o s.
/
(
' ~.
The sampling and analysis and reporting of non-radioactive waste water discharges in'accordance with the station's NPDES (National Pollution Discharge Elimination System) permit.
<,. : ~- --r J
- l......
.i 5.
Radio' logic'al Engi6eering/ALARA - Unit 1 Assist in the planning, design and control of work in support of the ALARA principles by providing recommendations, guidance and/or review in the following areas:
Facility / Work space layout and arrangement Traffic / Material Flowpaths Shielding Remote indicating or monitoring equipment Ventilation requirements in support of respiratory protection Special tools / equipment to reduce or minimize exposure Contamination / radiological control techniques Draf ting or review of procedures concerned with radiation protection and radiological controls.
Other duties as may be assigned by the Radiation protection and Chemistry Group Head; 6.
Supervisor Rad Waste - Unit 1 Responsible for the operation of the solid radweste systems in Unit 1 including solidification of concentrated liquid waste and compacted trash.
Responsible for insuring compliance of all radwaste activities with Technical Specifi. cations, procedures and Federal and State regulations.
Responsible for the coordination with Waste Management Activities for the shipment of Unit i radioactive waste from the site.
Responsible to write or review procedures for the handling and packaging of weste material in Unit 1 to insure compliance with the regulations.
Responsible for engineering modifications to radwaste systems to insure prcpsr, efficient and economical operation.
7.
H.P. Foreman - Unit 1 Responsible to the Supervisor Radiation Protection and Chemistry for super-vision of technicians in:
1.
Laborat'ory counting and support - Unit 1 2.
Health Physics opera'tions, and monitoring (RWP usage, job coverage) 3.
H.P. Training - Unit 1 4.
Radiolcegical surveys i
l i
(
(
l ENVIRONMENTAL HEALTH AND SAFETY Within the Corporate Staff is established a major group with the mission of providing environmental monitoring services and an H.P. audit program.
1.
Environmental Monitoring Program Responsible to the Di' rector of Environmental Health and Safety for main-tenance and review of the environmental surveillance program, ALARA reyiew of effluent program and the reports related to the programs.
2.
H.P. Audit Program Responsible to the Director-Environmental Health and Safety for the Radiation Protection QA audit program.
n S
O e
I O
I I
ne
.G-s i.
F WA5TE KWAGEMENT ACTIVITY-RADIATION PROTECTION AND CHEMISTRY h
Within the Waste Management Activity is established a major group with the mission of direct operational and technical support of all facets of radiation
_ protection and chemistry associated with Unit 2 recovery operations; The organization of the Radiation Protection and Chemistry Group is illustrated in Figure 1.
Under the group head are:
Line Functions P,adiochemistry Supervisor Chemistry Supervisor.
P.adiation Protection Supervisor
~
Support Functions Radiological Engineering and AtJsRA Chemistry Support Engineering Material Expediting The functional responsibilities of these major sub groups are enumerated below.
1.
Radiation Protec,t,i,on and Chemistry Grouc Head.
The Head of the Radiation Protection and Chemistry Group reports to the Director, Maste Management Activity.
Reporting to hira are the heads of the six sub-
- groups listed -above.
Direct liaison is also conducted with the Manager, Support Services and Logistics, TMI Nuclear Station, for the coordination of station-wide radiation protection and chemistry policy a'nd for matters involving requisite station support functions (i.e. dosimetry, res-piratory protection and generic radiation pr.otection training).
The iricumbent is responsible for the overall coordination and performance or~ personnel assigned and specifically for ensuring that the radiation protection function is accomplished in full compliance with 10 CFR 20 (and such other regulations issued by competent authority and approved procedures) and the management of all chemistry functions associated with
-Unit 2 in accordance with standard technical specifications and primary and secondary water chemistry and radiochemistry procedural requirements.
The incumbent is the normal point of contact in dialogue with the repre-sentatives of the Nuclear Regulatory Commission in matters of radiologi-cal concerns affecting Unit 2, 2.
Radiochemistry Supervisor The Radiochemistry Supervisor is, responsible for the coordination and per-femance of those personnel reporting directly to him which include sample coordinators, sample compilers, and those contractor personnel wiio operate and maintain the various radiochemistry counting laboratories at TMF as a result of the Unit 2 accident.
The Radiochemistry Supervisor will normally be qualified in accordance with ANSI 18,1 - 1971.
Specifically, this position is r'esponsible for:
The selection, supervision and calibration of all radiochemistry analysis and counting equipment..
I
+
~
-2_
f The establishing and day-to-day conduct of a quality assurance program to ensure the highest standards of radiochemistry laboratory results (excluding field,or portable equipment).
The development or technical review of new radiochemistry procedures necessary to fulfill emergent requirements.
The (dentification of training requirements for personnel assigned, including the actual conduct of such training when the normal station training department or others cannot fulfill this reauirement.
The maintenance of radiochemistry records and reports required by procedures under his cognizance and/or reouired by state or federal agencies.
Other dut'ies assigned by the Radiation Protection and Chemistry Group Head.
The functions of the groups for which the Radiochemistry Supervisor is responsible are enumerated below:
a.
Sample Coordinator Coordinate the sampling effort throughout Unit 2 including ensuring recurring periodic samples are drawn as scheduled, arranging for other samples as requested, ensuring that samples are forwarded to the cognizant laboratory for counting and oncuring that recults are received in a timely manner end dis-tributed to cognizant personnel / offices.
Implementation of the emergency Simple Procedure.
(Z-33)
Implementation of the liqui,d discharge procedure.. (Z-46)
Implementation of the sewage procedure (Z-51).
Supervision of those personnel assigned to draw and transport sampics to and from Sample Labs.
Other duties as assigned or approved by the Radiochemistry Supervisor.
b.
Sample Corpilers Compila/ composite, store and dispose of samples as directed by the Radiochemistry Superviser, c.
Contractor Radiochemistry Laboratories Per."orn radiochemical analysis as directed by the Sample Coordinator.
4 0
- f
(
f l.
3-3.
Radiation Protection Suoervisor
-The Radiation Protection Supervisor..is responsible for the coordination and performance of those personnel assigned and especially for that of th contractor radiation protection supervisors and foremen.
He is specifically responsible for ensuring that the radiation protection funct is accomplished in full compliance with 10 CFR 20 (and such other regula-tions issued by competent authority and approved procedures.)
Specific responsibilities include:
The review of surveys, including radiation, airborne and surf ace con-tamination, to detect trends which would require increased personnel protective measures.
The review and approval for radioactive releases from Unit 2 and, when requested, from Unit 1.
Maintaining close liaison with the Waste Management Activity Disposal Group for purposes of day-to-day review of the handling, storage and shipping of radioactive material.
Specifically, the incumbent should review and approve shipping documents.
The calibration of survey and laboratory instruments assigned to Unit 2 it accordance with direction from the radiochemistry supervi'scr.
The identif.ication of training requirements for personnel assigned and for the monitoring of the quality of training conducted within his sub-g roup.
The maintenance of records and reports required by procedures, technical specifications and others required by state or federal agencies.
Other duties assigned by the Radiation Protection and Chemistry Group Hea.
The preparation or technical review of procedure's affecting radiation protection.
The incumbent is normally a member of PORC and/or RORC.
4.
Chemistry Suoervisor The Chemistry Supervisor is responsible for the coordination and per-formance of those personnel reporting directly to him which includes one chemist, one contractor chemistry laboratory supervisor and Met-Ed rad-chem technicians.
The radiochemistry supervisor will normally be qualified for this position in accordance with ANSI N18.1 - 1971.
Specificallly, this position is responsible for:
I The management of the water chemistry sample and analysis program within Unit 2 including both auxiliary and plant systems.
I 6
-,e
,e-
-r e
r
(
-4 The selection, supervision, set-up and calibration of all chemical analytic equipment / systems.
The development or technical review of new chemistry procedures to meet emergenj requirements or to improve those in use.
The identifibation of training requirements for personnel assigned including the actual conduct of training when the normal station's train-ing department cannot fulfill this requirement.
The technical supervision of the operation of the water and waste treatment systems (less those under the cognizance of the Waste Manage-ment Activity Processing Section) of Unit 2.
The maintenance of chemis try records and reports required by procedbres under his cognizance and/or by state or federal agencies.
Other duties assigned 'by the P,adiation Protection and Chemistry Group Head.
Th' e Chemistry Super visor shall be responsible for the time sheets for all Met-Ed bargaining unit personnel within the cheraistry and radio-chemistry groups.
The functions of the group for which the Chemistry Supervisor is responsible are enumerated belcw:
The B&W Laboratory Supervisor and technicians are responsible a.
for the maintenance of the B&W chemistry laboratory and for the perfonnance of analyses or other chemistry functions in accordance
- with approved procedures as directed by the Sample Coordina-tors.
)
~'
F4t-Ed" Rad-Chem'Techs a'rs responsible' for the maintenance and b.
operation of those chemistry systems assigned to or located with-in Unit 2 chemistry laboratory and for the conduct of such analyses,
or other chemistry functions in accordance with approved pro-cedures as may be assigned by the Sample Coordinators or other duly authorized supervisory personnel.
The Chemistry Supervisor will be assisted by a chemist who fills a staff rather than line position; however, direct supervision of personnel with-in the group may be required frca time to time.
The Chemist is responsible for:
i Assisting management and subordinates in the development, implementa tion calibration, and standardization of functional tests, analysis techniques and other programs as may be assigned.
e
.l.,
c
-S-i The development of a quality assurance / control program consisting of chemical calibrations and maintenance of instrumentation and, as necessary; per. iodic audits of the operation of associated systems and techniques and adequacy and accuracy of data As'sisting the Chemistry Supervisor in the development of budgets, providing pertinent data and information regarding expenditures and projected requirements both for the chemistry and radio-chemistry sections.
i
- The procurement of chemical laboratory equipment and supplies.
The instruction of technicians in review or unusual procedures and/or techniques associated with analytical procedures.
Other duties as may be assigned by the Chemistry Supervisor.
The Chenist will be the normal relief for the Chemistry Supervisor during periods of his absence, i
Three staff assistants or groups are assigned within the Radiation Protection and Chemistry Group.
Their functional responsibilities i
are listed below.
5.
Radiological Enaineering/ALARA - Uni t 2 Assist in the planning, design and control of work in support of the ALARA principles by providing recommendations, guidance and/or review in the following areas:
~
Facility / Work space layout and arrangement Traffic /tiaterial Flowpaths,
Shiciding Remote indicating or monitoring equipment' Ventilation requirements in support or respiratory Special tools / equipment to reduce or minimize expos. protection ure Contamination / radiological control techniques Draf ting or review of procedures concerned with radiation pro-tection and radiological controls.
Other duties as may be assigned by the Radiation protection and Chemistry Group Head.
6.
Chemistry Engineerlupcort - Unit 2 Engineering support, principally that concerned with sampling systems
, and. procedures.
Draft and review prodedures concerning samplink and analysis techniques.
Perform quality assurance checks and when directed, supervise the per-formance of technicians assigned to cuntractors laboratories.
r-.
a-
l
=
i e-a m
.~..n........u. m.a me R A D) ATION PR OTECTIO N..PL A N g,p 0e/1n./
(
FIGURE 2 - 2 D ^^ '#' #'
.~.....
. s. _..........
..g
.........:=__=
....t.
...-t2..,.t.
L..............t
..................... t....
............,...w
..d
.... t.......
.....................s......,....................4....
......................s............
.................t.........
.... ~.........
..a.......-~..
.....- ~.............................
..... a
............................................ ~..........
.................................. ~..............
..........................................~.........
..........v...
a.....
^. ~....
...~......
.e-............
....... n. u..
..,................_.._.........=.7,
....s.... _..
............... ~.
.... ~.........................
....... u,...........
...-a.
- .......:=.=
....t
,.................. a.
- ........t.
..~
.................. m..
...... = _
..........s w.........
.C
.e
. m
.... *....*.... *=*..*.............. =.......
. p.
......a.......................
.z......_
2......
....o,.......:s...
1...........
..... =. -
.. s..,
.............,e
.e,
.L,.,.. %........
v........
.=
.~
1...
...,.......s....
- ........_.r.
. =.
W
.G.,............ r.
3 c
1 o
~s..sn............
_t-1y
.............=
=.
.....t_.z t.
a.
u,,
............,.......,...m.....
.....=
..... = _..
.....c_...
.s......
.. :>,.. t..
.s...........t.......n.
........ ~,...
. q-..
.... =.
- s..
,......... = -
....r...,....r..
..._r
....,.w..
4......
....r.......
.s
..e..
..y.
,..., s. v........
y
. s.
...s...,,
.z.
u....
1 s........
1 g.3 1
=
..=
l S
%3,
e..6.....
e P
C*:
.s
.. =
..r--7 g*.
a I
es.
- C I
m kD
$.3
- d b
d.a j z e.. t L===
- s. a T
A.
n :
V e..
l g
e....
- V. M e f-N j
=.-
% g.P m_..
.h.l.
.D
.M.i..
n Qx I
--M M
l W
e t
~-e
(
-*i 3
l 1
q,g.
N N l
h D
f MN
-r 0
y6 s
i N
- :. i eQ i
=4
.l u< D l
y I_
g 4
f 3
~. -. -
r
.b b.
.h.h Eh m s. __
g g
w&
A.s O c J.
a y
t 0 4.
J N -
uN Q :' ';-
j d
~
a
- (g
_)
)
'"*~~~l D
l