ML18152B212
| ML18152B212 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna, 05000000 |
| Issue date: | 09/16/1988 |
| From: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8809270131 | |
| Download: ML18152B212 (5) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 16, 1988 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.. C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NORTH ANNA POWER STATION UNITS 1 AND 2 Serial No.88-565 NO/SEC/NAPS-LIC:vlh Docket Nos.
50-280 50-281 50-338 50-339 License Nos. DPR-32 DPR-37 NPF-4 NPF-7 INSPECTION REPORTS 50-338/88-03, 50-339/88-03, 50-280/88-03, 50-281/88-03
- We have reviewed your letter of August 17, 1988 wh.ich transmitted NRC Inspection Reports No. 50-338/88-03 and 50-339/88-03 for North Anna, and 50-280/88:.03 and 50-281/88-03 for Surry Power Stations.
These inspections evaluated our efforts to reduce collective radiation exposures at our nuclear facilities and were conducted at North Anna and Surry Power Stations, and our Richmond, VA corporate office, during the weeks of.March 14 - 18, 1988 and April 4 - 8, 1988.
A number of strengths and weaknesses in our program to reduce collective radiation exposures were identified in Enclosure 1 to your letter.
Our assessment of the identified weaknesses, including actions taken or p 1 anned to correct the weaknesses and the dates when the act i ans wi 11 be completed, is provided in the attachment to this letter.
Reducing collective radiation exposures at our nuclear plants is of utmost importance to Virginia Power, and is an integral part of our daily operating decisions and our planning for future activities and plant improvements.
We greatly appreciate your insight and suggestions for improvement in this very important area.
If you have any further questions or comments, please contact me.
Very truly yours,
. W. R. Cartwright Vice President - Nuclear Attachment 8809270131 8809i6 PDR ADOCK 05000280 Q
cc:
U. S. Nuclear Regulatory Commisiion Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station
NRC Comment RESPONSE TO WEAKNESSES IDENTIFIED IN NRC INSPECTION REPORT NOS. 50-338/88-03, 50-339/88-03, 50-280/88-03 AND 50-281/88-03 REGARDING PROGRAMS TO KEEP RADIATION EXPOSURES ALARA
- 1.
Exposure goals are based on the historic average person-rem incurred per day of outage and non-outage periods rather than basing the goals on the specific task to be performed (North Anna arid Surry).
Response
Two types of exposure goals are utilized in our programs to reduce collective radiation exposures at North Anna and Surry.
Annual exposure goals are established and tracked in order to ensure that the corporate goal of reducing radiation exposures to less than or equal to the industry average in 1990 is met. - These goals are developed based on hi stori cal performance during outage and non-outage periods, exposure estimates for significant, exposure-related, work tasks that are known at the time the goals are established, and management's expectations regarding future improvements in exposure performance.
From these annual goals, daily exposure goals are established to provide management with a means of quickly identifying abnormal exposure trends.
For specific* work tasks, task-specific exposure goals or projections are" established at the time the work is planned.
These goals are tracked and documented for each Radiation Work Permit.. These goals are utilized by first-line supervision in assuring that task-specific exposure goals are met, and by ALARA program personnel in i dent i fyi ng potential areas for future improvements in exposure performance.
Department daily exposure goals should not be substituted for task-specific exposure goals and their use will be discontinued.
The purp6se of annual and daily exposure goals in conjunction with*
task-specific exposure goals will be reviewed with ALARA program personnel and first-line supervision to ensure proper focus on task-specific exposure goals.
This will be accomplished by October 31, 1988.
Our historical data base of actual exposures for specific work tasks is being
- expanded, and will be used to a greater extent in the future in establishing annual as well as task-specific exposure goals.
.NRC Comment
- 2.
The licensee accepts contractor-established collective dose goals for work performed by the contractor which significantly exceed the collective dose received by the 1 i censee when similar work was performed by the pl ant staff (North Anna).
Response
Our policy is to establish contractor dose goals during the work planning process where agreement on the goals is reached between the contractor and the department supervising the work.
Exposure goals for repetitive work are reviewed against historical work performance to ensure the standards of performance and improvements in exposures are maintained.
This policy is being re-emphasized to the appropriate supervisors and ALARA Program personnel.
NRC Comment
- 3.
Dose projections for some work covered by Radiation Work Permit are being exceeded without management review or concurrence (Surry and North Anna).
Response
Procedures currently require the Station ALARA Coordinator to review RWPs with projected exposures of one or more man-rem and to distribute an "ALARA Hold Notification" to. the applicable department when a RWP's accumulated exposure exceeds both* one man-rem and 100% of the projected exposure.
If it is determined that the job cannot be completed within 125% of the projected man-rem, a RWP reevaluation meeting is scheduled.
RWPs which both accumulate more than one man-rem and exceed 125% of the projected man-rem are placed on "ALARA Hold."
"ALARA Holds" can be rescinded following a RWP reevaluation meeting or as directed by the Superintendent of Hea 1th Physics.
Comp 1 i ance with this process wi 11 be reemphasized to ap.propriate supervisors and ALARA Program personnel.
In order to promptly implement an "ALARA Hold," a Personnel Exposure Management System (PREMS) computer software change is being initiated to automatically prevent additional use of a RWP when the actual exposure for the RWP exceeds 125% of the projected exposure.
The software changes will be fully implemented by March 31, 1989.
NRC Comment
- 4.
ALARA Program procedures have not been revised in a timely manner to conform to licensee's corporate radiation protection plan (Surry).
Response
The ALARA Program procedures at Surry were implemented on April 28, 1988.
NRC Comment
.5.
Entries into the containment building when plant is at power has become so routine that there is little or no management involvement in the decision process (Surry and North Anna).
Response
Station management now requires that a detailed pre-job briefing be conducted between Health Physics and the work crew, prior to containment entries at power.
In addition, station administrative procedures have been revised to require* approval from the Station Manager or Assistant Station Manager for entries with the containment subatmospheric (this
- includes entries at power).
NRC Comment
- 6.
The licensee's ALARA Action Plan does not include a formal schedule with milestones for implementing the recommendations (North Anna and Surry).
Response.
The ALARA Action Plan was completely reviewed and updated during July and
- August, 1988 by the Corporate ALARA Coordinating Committee (ACC).
Responsible parties and implementation milestones were confirmed.
Each i tern wi 11 be reviewed at the quarterly Corporate ACC meetings, and the status reported to Station and Corporate management in the ACC minutes.