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PHILADELPHI A ELECTRIC COM PANY2301 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. 50-27750-278

Mr. Thomas T. Martin, DirectorDivision of Engineering and Technical InspectionU. S. Nuclear Regulatory CommissionRegion I631 Park AvenueKing of Prussia, PA 19406

Dear Mr. Martin:

Your letter of December 30, 1981, requested additionalclarification of our June 5, 1981, response to CombinedInspection Report 50-277/80-18 and 50-278/80-10. The " Items forClarification" in this response were discussed in a telephoneconversation between Mr. R. Nimitz, Nuclear RegulatoryCommission, and Mr. W. Knapp, Philadelphia Electric Company, onNovember 25, 1981. Fo1 lowing are the items addressed in theattachment to your letter and our responses which include anysupplemental information discussed in the conversation betweenMr. Nimitz and Mr. Knapp.

Item No. * Description

A.1 Job / Position descriptions forRadioactive Waste Personnel

8204020285 820329PDR ADOCK 05000277G PDR

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Nr. Thomas T. Martin, Director Page 2

Items for Clarification

Response does not address the job description andresponsibilities of the Rad Waste Department, particularly theRad Waste Supervisor.

Response

Philadelphia Electric Company has committed to developing jobdescriptions for all positions identified on the OrganizationalChart. This wi]] include the job description andresponsibilities of the Radwaste Supervisor's position. Theexpected completion date for this document is May 28, 1982.

B.1 Formal training / qualificationprogram for personnel in tech-nical areas e.g., TLD system,external dosimetry, internaldosimetry, etc.

Items for Clarification

Response does not reflect training in progress, or managementinvolvement. Specific items are: sign-off sheets for procedurereview, determination that personnel can implement procedures,the frequency of training and management assurance that aprocedure is being implemented.

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Response

New procedures are introduced and discussed at Health Physicstechnician meeting with the TA group held weekly during non-outage periods. During major unit outages when work load isincreased, these meetings are held only when significant changesto procedures require additional attention or instruction.Frequently, instruction and clarification is provided by thesupervisor health physics. The attendarra and topics ofdiscussion for these meetings are presently being documented and

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Mr. Thomas T. Martin, Director Page 3

filed. The ability of personnel to implement procedures isdetermined by supervision and by the results of the QA audit.After instruction and training, all techs personally demonstratetheir ability to perform procedures to a member of the health j

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physics technical assistant staff.'

Management assurance that procedures are being properlyimplemented is provided by reports given HP supervision to thecorporate radiation protection management and plant management.Results of QA and NRC audits are passed to the highestdepartmental level.

Refer to the responses to items B-4 and B-5 for further detailson training.

B.4 Training program for healthphysics professional staff

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Items for Clarification

| Response does not identify a program that ensures proficiency ofI supervisory staff. This should include a supervisory review ofi procedures, a specified frequency of training, and evidence ofi the licensee's attitude toward keeping people proficient andi knowledgeable.|

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Response!

Training for the health physics professional staff is providedpartially by their attendance at seminars, workshops and coursesdesigned to supplement an individual 's knowledge in his generalareas of responsibility. These are chosen according to the needand the availability of supervisory personnel and the schedulingpossibilities of high quality programs. Philadelphia ElectricCompany has sent three members of its supervisory staff to theradiation specialty school and three members to the Chemistryspecialty school held by General Electric. Corporate radiationprotection staff also participate in special training programsconducted by vendors and consultants, e.g. Electric Boat's ALARA

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training and Babcock and Wilcox radio-chemistry course. Jobdescriptions of the professional staf f are being developed.Evaluations will determine the proficiency of the professionalstaff in their areas of responsibility. Staff meetings willprovide the opportunity for presenting specific proceduralchanges and serve as a procedural review format. These meetingswill be held weekly during non-outage periods, and as neededduring outages. The attendance and topics of discussion will bedocumented and filed.

Refer to the responses to items B-1 and B-5 for more information.

B.5 Training and qualificationsof health physics supervisorypersonnel

Items for Clarification

Response does not address how supervision is assured thatpersonnel can implement procedures, that on-the-job training doeswhat it is supposed to do, and some documentation that anindividual 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 arebeing developed. The yearly evaluation of performance isdesigned to measure the proficiency of an individual in the areato which he has been assigned. This evaluation demonstrates tomanagement the results of the individual's on-the-job training,and the ability to implement the appropriate procedures.

Philadelphia Electric Company recognizes the importance ofadequately trained personnel . This is quite evident in theextensive training programs conducted at Peach Bottom and at thecorporate office for all groups, especially for licensed reactoroperators. The need for improvements in training of groups suchas HP & C professionals is recognized. Documentation of this

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training also could be improved. Improvements in these areaswill be initiated immediately.

C.1.a Investigation, review andresolution of dosimetry QA/QCprogram discrepancies

C.I.b Same as C.1.a

Items for Clarificationi

HPO/CO 32 does not describe how data is evaluated, what is donewith QC data, management review of discrepancies,responsibilities for review and action, and details for resolvingdiscrepancies.

Response

Procedure HPO/CO 32 " Quality Control of Personnel Dosimetry" isbeing reviewed. It will be revised to include:

- a description of how data is evaluatedutilization of QC data-

- method and responsibility for review, reporting, and actionson abnormal data

- method and responsibility for resolving discrepancies

This revision will be completed by March 1, 1982.

C.2.a Periodic limited quantitativecalibration check of wholebody counter

Items of Clarification

Response does not provide sufficient detail to show that thewhole body counter is in calibration. Daily check source shouldbe more than a response check.

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Response

| Full quantitative r:alibrations of the whole body counter are done| 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 thedaily qualitative / quantitative response checks. These dailychecks follow the guidance of ANSI N343-1978. Counts are done onthe daily check sources and these reports, as well as backgroundcounts are kept on file in the dosimetry office. HPO/CO 26 willbe revised to include a better description of the daily operationof the whole body counter. The most recent revision of thisprocedure does describe what is done with the findings. The newrevision of HPO/CO 26 will be completed by March 1, 1982,

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C.2.c Procedures for collection,handling and transport ofbioassay samples

Items for Clarification

No procedures describe fecal analysis. No procedure describesthe collection, handling, preservation and transportation ofbiological samples.

Response

Internal dosimetry is monitored through the use of whole bodycounting. If the need for further analysis is determined, thenHP Supervision will be notified. Communications may beestablished with Radiation Management Corporation (RMC) for theirmedical / radio-analytical advice. If necessary, the PhiladelphiaElectric Company Medical Director is consulted. Based on thediscretion of HP supervision or RMC's consultation, appropriatesamples vill be collected and will be analyzed. Appropriateactions are then be taken. Follow up actions are to be based onthe advice of the Philadelphia Electric Company Medical Director.

HPO/CO 26 " PERSONNEL BIOASSAY PROGRAM" will be revised to addressmore fully the collection, preserving, handling and transport ofsamples for analysis. This revision will be completed by March1, 1982.

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C.2.d Maintenance Program for constantair 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 AirMonitors. This responsibility has already been assigned to anewly designed instrument and repair group which reportsfunctionally to health physics supervision. Thi s wi ] ] ensurethat an efficient and effective continuous air monitor program ismaintained. The estimated date for implementation is July 1,1982.

Very truly yours,

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