ML20006A659
| ML20006A659 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 01/15/1990 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9001290278 | |
| Download: ML20006A659 (9) | |
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' DUKE POWER.
' January 15,11990
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U. S.. Nuclear Regulatory Commission
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'Attnai Document Control" Desk i
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Subject:
McGuire Nuclear Station
' Docket Nos.- 50-369, 370 r
Inspection Report Nos.' 369, 370/89-28 Response to Request For Assessment of ALARA Improvements Gentlemen:
'As per your letter of November 15, 1989, please find attached Duke Power.
Company's response to your. request for a written assessment'of our plans for
, improvement'of the ten ALARA items outlined in Enclosure One of the subject report.
Shouldlthere be-any questions concerning this matter, contact W. T. Byers at.
'(704).373-6194.
.Very truly:yours,
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. Hal-. Tucker WTB153/lcs xc:. Mr. S. D. Ebneter T
' Regional Administrator, Region II U.-S. Nuclear Regulatory Commission f
101 Marietta Street, NW, Suite 2900 Atlanta,-Georgia -30323 Mr. Darl' Hood
'U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation i
Washington, D.C.
20555 Mr. P. K. VanDoorn NRC Resident Inspector i
McGuire Nuclear Station bhh jh8b15 _
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MNS Response Request For Assessment Of ALARA Improvements 50-369, 370/89-28 IFIt' 50-369/89-28-01 Plant-wide procedure for development and submittal of ALARA job action plans and for selection of ALARA job sponsors.
Response
The guidance for development and submittal of ALARA job action plans by ALARA job sponsors has been provided in Radiation Protection Manual Section 3.11, " Exposure Estimate and Exposure Goal Determination".
The station sponsor is provided an ALARA Planning Guideline to assist with the development of the routine and non-routine task. Each station sponsor is also provided with an ALARA contact (someone in the Radiation Protection ALARA staff) to assist them with the exposure estimate and exposure reduction techniques.
In contrast to the description of the selection process for job sponsors in Report Numbers:
50-369/89-28 and 50-370/89-28 paragraph 3.1. the job sponsors are presently being selected by the group superintendent. The superintendents choose the job sponsors based on their expertise in the particular area and the job sponsors are usually first line supervisors or staff personnel.
Sponsors are determined through the use of the outage significant job 1$.st or when the ALARA Planning Worksheets are sent to the superintendents. This process is sufficient, and no further guidanca is planned.
IFI:
50-369/89-28-02:
~ Controls for evaluation of on going work by upper management for jobs approaching'or exceeding dose estimates.
Response
To provide guidance and controls for the evaluation of ongoing work for jobs approaching or exceeding dose estimates, guidance has been incorporated into Section II " Elements of the ALARA Program," Part A (8) of the DPC ALARA Manual. This section provides the following guidance to station job sponsors regarding their responsibility to take appropriate actions when a job is exceeding or likely to exceed the estimated job dose, investigate the cause(s) of the dose overruns, n.
b.
determine what can be done reasonably achievable (either for the ongoing job or the next time the job is done),
c.
increase job monitoring to maintain an acute awareness of job progress with respect to ALARA goals.
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This section also provides guidance relating to methods which can be utilized _ to accomplish job monitoring and provides guidance for utilizing dose' projection curves for high dose jobs. (i.e. > 10 person-rem).
This.section will be, incorporated into the ALARA Manual by March 1, 1990.
IFI 50-369/89-28-03:
Increased job site visits in the radiologically controlled area.(RCA) by job E
planners.
Response
Job site visits by Planners are encouraged regardless of whether the work they are planning is inside the Radiation Control Area (RCA) or not.
Maintenance Management Procedure 1.7 (Maintenance ALARA Planning), which was i
implemented September 1, 1989, requires planners to estimate dose for jobs meeting'certain criteria and to look at the ALARA aspects of the job. This will result in-an increase in the number of job site visits inside the RCA.
IFI: 369/89-28-04:
Update and use job history files during job planning.
Response
Maintenance Management Procedure 1.7 provides for documentation of the ALARA planning and for feedback from the work supervisor on the effectiveness of the ALARA plan for selected jobs.
This documentation will be incorporated into the ALARA job history files in the Planning office for ALARA job planning.
IFI: 369/89-28-05:
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ALARA. Committee objective to perform post-job reviews for high dose rate jobs in cases where the actual dose was significantly greater than the estimated dose.
Response
At the present time, the' station is establishing the criteria for the high dose rate jobs that will be reviewed by the ALARA Committee. The criteria established will be governed by the desire to do a thorough review of the jobs identified. Basic guidelines for jobs > 10 Rem and an undetermined number of jobs > 1 Rem that exceed their estimated exposure by > 25% are being reviewed. This criteria will be discussed at the January 25th AIJJU(
Committee Meeting and full implementation of this program is set for September of 1990.
The implementation date is based on expected delays due to the upcoming Unit i EOC-6 Refueling Outage scheduled for April, May, and June 1990.
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I IFI: 369/89-28-06:
.i Improved use of the suggestion program for making ALARA improvements.
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Response
Use of ALARA suggestion boxes was incorporated into Station A.P. Manual Section 3.3 and approved on 11/30/89. Suggestion boxes have been placed in the designated areas to allow for prompt or spontaneous exposure reduction ideas to be turned in.
IFI:
369/89-28-07:
Improved use of protective clothing and equipment in mock-up training conducted for high dose jobs.
Response
While Mechanical Maintenance is in agreement with incorporating the use of protective clothing into a training environment to improve effectiveness and efficiency where high dose rates are a concern, we also feel that this should not be a part of any initial training and qualification program..
This would allow the employee the opportunity to learn and demonstrate all the necessary knowledges and skills required to perform the job in a safe and quality manner without the restrictions that protective clothing would normally impose.
It is our intention to work with the Planning and ALARA Organizations to identify available mock-ups and training aids that may.be utilized to improve proficiency beyond initial training and qualifications prior to actually working on the component in the field.
This will be accomplished through close interface between the Mechanical Maintenance Employee Training and Qualification Group, Planning, and ALARA Organizations while implementing the requirements set forth in the Maintenance Management Manual Procedure 1.7 (Maintenance ALARA Planning).
This evaluation will be.an ongoing effort. As work requests are planned and ALARA pre planning takes place, the need for proficiency mock-up training will be identified and scheduled based on the: potential dose reduction achievable and the improvement gained in personnel safety.
IFI:
369/89-28-08:
Documented guidance on acceptability of thermeluninscent dosimeter (TLD) vs.
pocket dosimeter (PD) correlations to facilitate job planning activities for work groups receiving high accumulated dose.
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Response
i We do not feel-that the difference in TLD/PD correlation adversely effects job planning.
We are aware of the variation patterns as they-relate to outage vs.
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non-outage periods and from work group to work group.
Each station has demonstrated the same predictable patterns, i.e. the higher the dose for a work group (outage), the better the TLD/PD correlation. Variations are primarily due to statistical errors in measuring and rounding off very low doses.- Jobs with significant dose typically-have' good correlations.
We feel that our current methods for planning job activities for work groups receiving high accumulated dose is sufficient and no further guidance is planned.
R IFIt 369/89-28-09:
. Knowledge and awareness by individuals and supervisors of departmental and section dose goals.
Response
q Presently, the formulation of the McGuire Exposure Estimate results in the development of section goals. These section goals are actually the 20 work groups identified for daily exposure tracking.
Attachment #1 is a list of the section break down. Once the section goal is established, the superintendents and section managers.will be updated monthly by the ALARA staff, when TLD results arc obtained, and are responsible for disseminsting j
this information to their respective area.
During' scheduled outages, the ALARA staff will provide a weekly (every 7 to i
10 days). update of projected exposure for the superintendents and section ll managers. Again, the superintendents and section managers will be responsible for disseminating this information to their respective areas.
i IFI:
369/89-28-10:
l Guidance for conducting and responding to General office evaluations, reviews, and audits.
Response
Assessment Guidance is being developed and will be incorporated into the L
Duke Power Company System Health Physics Manual. This guidance will consist l
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t of ten to. twenty pages of general guidance in the conduct of assessments.
This will include criteria, schedule, personnel selection, methods, communications, ethics, reports, responses, and problem resolution.
Specific guidance for performing each type of assessment will be provided in a one to three page appendix devoted to each type of assessment. The generic guidance and, especially, the assessment specific appendices will be subject to. future revision as appropriate. Approximately ten assessment.
specific appendices, including ALARA, will be developed and implemented with the generic ~ guidance. Others will be impicmented later as needed. This guidance will be implemented by July 31, 1990.
Also, in an effort to ensure a timely and complete response to findings from the General Office ALARA audits, McGuire will utilize the McGuire Action
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Directory (HAD) item list. Responses will be handled as MAD items, and this shall ensure that sufficient management involvement is obtained in reviewing the completion method and resolving any differences between the site and the General Office Radiation Protection groups, i
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- ,y ATTATCHMENT.#1.
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REC WORE GROUPS / DESCRIPTIONS gat.
35 DESCRIPTICW 1.
MAN 4GEMMT DPC Management personnel including: Station Manager and superintendants: GO Managers and System s
Engineers: CMD Managers. Design Eng. Managers and Principal Engineers. May also include-NSRS members, VIP's, visitors, etc.
2.
OPERATIONS Personnel associated with nuclear plant operations, e.g., station Staff and Operating Engineers, and the entire Operations staffs members of the 00 Operations staffs and visitors.
3.
MECHANICAL Station, utility, and contract personnel / visitors who are associated with the service / repair /asintenance of mechanical components (pumps, valves, diesels, turbines, etc.) necessary for plant operations.. Es:
The Maintenance staffi GO Maintenance personnel Oceaneering. Mstr-Lee. Westinghouse, TEM Welding Services, Daniel. VTS ENS, CE. APS. ANS. Purmanite,4
-CE. Diamond Power. NES, Power Cutting. NSS Leak r
Repairs. etc.
4.
EL8C/IAR
' Station, utility 'and contract personnel / visitors who
-are associated with the service / repair / maintenance of t
all electrical components (motors, eloc. generators.
valve actuators, etc.) and plant.instruasntation.
Examples include The IAE Maintenance Engineer and entire staff DPC Transmission-Lines and 00 IAE personnel GE. NSS. Rotord. Otis, Westinghouse, telephone workers..etc.
5.
RAD PROTECTION Personnel responsibio for the station radiological protection program.
Enamples: The Radiation Protection Manager and entire RP staff, contract RP's (IRM. Numanco. Bartlett, RP Technical Services. RTS.
etc.), visitors, and G0 Radiation Protection staff.
6.
CEIMISTRY Individuals who perform chemical analyses of plant primary and secondary systems. ' Included: ' Chemistry Manager and entire staff (excluding Radwaste),
Environnantal Chemistry, GO Chemistry staff. vendors, o
chemical workers from other departments, contract workers, and visitors.
7.
PERPORMANCE Station, utility, and contract (CE, W. NSS, ANP, etc.)personnel who do performance testing of plant systems and components.
e.g., turbine acceptance testing, etc. May also include GO Performance staff, and visitors.
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_QA/QC Individuals responsible for Quality Assurance and Quality Control prograss. This includes auditing radiography, eddy current, PIE and/or NDs testingi and in-service. inspections. May:
include on-site inspectors,- vendors (84M. NES.
Hartford Steam) Corporate QA, er visitors.-
9.
PROJ/ COMP Includes Project Service and Compliance Engineers and their entire staffs. _It also l-H includes SSRG 00 Projects, 1.icensing, and L
Emergency Planning personnel -Design Engineering visitors, contract, and regulatory personnel (INPO, ANI, OSHA, NRC, etc.)
10.
STA.SERVCS The entire Station Services staff'(excluding Security),
i.e., Contract Services, Administration. Safety, HMEC, agi contract housekeeping /decon/ utility personnel. (K-Mac, Bartlett,LIRM, etc).
It also includes 00 support personnel and visitors.
11.
INTG.SCHD Includes Unit and Integrated Scheduling Engineers, Shift Engineers, and their entire staffs. May al'so include Go, contract personnel, and Visitors.
12.
PLANNING Personnel who plan and schedule routine and outage' work.
This includes the Maintenance Planning Engineer and the entire staff, i.e.,
Mechanical Maintenance Planners. Electrical Maintenance Planners. Planning & Scheduling-Engineer, and their entire respective-staffs.
13.
SECURITY Includes all Station, contract, visitor, and GO Security personnel. (Globe, Pinkerton, Southern Security) 14.
RADWASTE All station, contract, and visitor personnel associated with radioactive wasta effluents and station Radwasta processing program.. Examples Quadrex, Chen Nuclear, etc.
(Chemistry excluded) 15.
MATERIALS Includes Materials General Supervisor, Supervisors. Storekeepers, Stock Handlers. etc.
This group may also include contract, Mill Power, Go support personnel and visitors associated with station materials.
16.
CMD/ CRAFT General Supervisors, Supervisors, and all craft personnel.
May also include contract workers (NSS. Starr Davis, T&M. Daniel. ANS. Bahnson, Covil. MCC Powers, etc.). GO CMD personnel, and visitors.
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CND/ MISC All personnel in the Materials and Equipment and "
the Human Resources staffs. May.also. include contract workers, 00 CMD personnel', and visitors.
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CMD/PL-ENG Planning & Control Supervisors. Engineering y
Supervisors and their antire respective rtaffs.
.l May also include contract workers, G0 CMD l
personnel, Design Engineering, and visitors.
19.
ENG SERV All station, contract, and vendor personnel associated with the Maintenance Engineering j
Services section.
l 20.
. SUPPORT Production Support Dept. (Training. TLD Lab TTC and PSB, etc) Human Resources Dept. (Medical staff, Industrial Hygiene, Safety): Visitor i
Center personnel visitors contract workers etc.
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