ML20050D495

To Procedure OAP1895.01N, ALARA Reviews

ML20050D495
Person / Time
Site:	Clinton
Issue date:	04/10/1981
From:	Harris R ILLINOIS POWER CO.
To:
Shared Package
ML20050D489	List: ML20050D488 ML20050D491 ML20050D495 ML20050D496 ML20050D511
References
OAP1895.01N, NUDOCS 8204120260
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ILLINOIS POWER COMPANY CLINTON POER STATION CPS No.

0AP1895.0lN Revision No.

1 TITLE:

ALARA REVIEWS Scope of Revision:

r Rev. 1:

Added clarification of cost / benefit study and examples of methodology.

Changed titles in i

accordance with CPS changes.

Added requirement for numbering of ALARA Reviews on Cover Sheet.

Added; section on resolving "0 PEN" items.

Added more references.

Changed Cover Sheet to be consistent with new ALARA Committee composition.

Added an "Other" category to Reviews C001 and C002 for additional concerns not previously denoted.

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SIGNATURES I

Rev. 1 I

Prepared by ttuo R.E.

Harris Interface

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O Department Head /

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Superviser j _

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FRG Approval Power Plant Manager Annroval

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ILLINOIS POWER COMPANY CLIh"I'ON PCWER STATION CPS No. 0AP189 5 AIN Revision No.

O TITLE:

ALARA REVIEWS Scope of Revision:

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Quality Control Suoervisor i/

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c?S No.

0AP1895.01N LIST OF EFFECTIVE PAGES Pace No.

Revision No.

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0AP1895.01N TABLE OF CONTENQ l.0 Purpose 2.0 Discussion / Definitions 3.0 Respons i'oility 4.0 Precautions - None 5.0 Prerequisites 6.0 Limitations and Actions - None 7.0 Materials and/or Test Equipcent - None 8.0 Procedure 9.0 Acceptance Criteria - None 10.0 F.inal Conditions - None 11.0 References 12.0 Appendices - None 13.0 Documents

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0AP1895.01N c?s No.

1.0 PURPOSE The purpose of this procedure is to describe the CPS ALARA Review process as it relates to ensuring that plant design, construction, modifications, and operational activities maintain occupational exposure "as low as reasonably achievable" (ALARA).

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3, 2.0 DISCUSSION / DEFINITIONS 1(j: 1;g 1

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v. as2 2.1 Discussion 2.1.1 The relationship between radiation dose and biological effects is reasonably well known only for doses that are high compared to current annual dose limits and only when such doses are delivered at high dose rates.

The radiation protection goal is to reduce exposure wherever and when-ever reasonably achievable, thereby reduc-ing the risk to personnel 2.1.2 Merely controlling the maximum dose to individuals is not sufficient; the collec-tive dose to the group (in man-rem) also should be kept as low as reasonably achiev-able.

2.2 Definitions Reasonably achievable - Reasonably achievable is judged by considering the state of the technology and the economics of improvements in relation to all of the benefits from these improvements.

In assessing the economic portion of potential modifications or programs the following guidelines should be used.

When only the health benefits to the general public or plant radiation workers need 1

be considered the 10CFR50 value of $1000 (1975 dollars) per man-rem, integrated over the period of exposure, should be used.

When a potential dose reduction Page No.

1 Rev. No.

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c?S No.

0AP1895.01N i A P. I \\ii D i~

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v v ;,2 2 affects plant radiation workers because of the added cost of replacement workers, a dollar value of

$6000 (1975 dollars) per man-rem per year, averaged dose rate reduction, should be used.

This figure represents an economic equivalent of a dose rate reduction (dose per year) and cannot be integrated over the period of exposure.

However, an additional value of $1000 per man-rem, integrated over the period of exposure, should be added to this calculation to account for the health benefits to the radiation workers (see example).

It should be emphasized that a dollar value, as calculated above, is not sufficient j ustification alone in deciding on the merits of a given modifica-tion.

Instead, careful consideration of all factors followed by prudent j udgment related to this considera-tion will dictate the final decision.

EXAMPLE l_

7 A proposed modification results in a savings of 5 man-rem every other year for the life of the plant.

Average man-rem /yr reduction = 5/2 = 2.5 man-rea/yr ALARA cost = replacement cost + health cost Replacement cost = $6000 x 2.5 = $15,000 Health cost = $1000 x 2.5 x 40 = $100,000

$115,000 ALARA cost

=

EXAMPLE 2 For a one-time reduction of 2.5 man-rem (all in the same year) the ALARA cost would be:

$6000 x 2.5 + $1000 x 2.5

= $17,500 Page No.

2 1

Rev. No.

c?s No.

0AP1895.01N 3.0 RESPONSIBILITY The Power Plant Manager is responsible for implementation 1

of this procedure.

The Supervisor - RadChem is responsible for review of this procedure.

The Supervisor-Radiation Protection is responsible for the implementation and conduct of ALARA Reviews.

4.0 PRECAUTIONS i ;3 P' 1 T. ! 7~D ' n a n -" n a j,n 'I.i f '.7

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': s 5.0 PRERErUISITES An ALARA Review shall be initiated for any of the following conditions:

a.

If the dose is either estimated or known from past 1l experience to be greater than ten man-rem total for the particular job.

1lb.

If the dose is greater than ten man-rem per year for routine recurring jobs.

c.

If operational plant activities have a potential to cause or have caused significant radiation exposures to personnel.

d.

If new or modified plant facilities and/or equipment would cause a detrimental affect on existing radiation 1l levels or which caa affect radiation exposure to personnel.

6.0 LIMITATIONS AND ACTIONS None 7.0 MATERIALS AND/OR TEST EQUIPMENT None Page No.

teV. 50.

9 c?s No. 0AP1895.0lN

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• 8.0 PROCEDURE tl 8.1 The Supervisor - Radiation Protection shall determine the need for an ALARA Review per Section 5.0 of this procedure and assign an individual from the RadChem Department to complete the reveiw.

8.2 Conductine an ALARA Review 8.2.1 The assigned individual shall obtain either a copy of CPS No. 0AP1895.01C001, CPS ALARA RE VIEW-DES I GN / CONS T RUCTI ON / MODI FI CATION CHECKLIST for reviews to be conducted during 1

plant design, plant construction or plant /

equipment modification, or obtain a copy of CPS No. 0AP1895.01C002, CPS ALARA REVIEW-OPERA-TIONS CHECKLIST for reviews to be conducted for operational activities.

8.2.2 Complete the required information at the top of the checklist:

Date, System / Component /

S ubj e ct, and System / Component Designator (if applicable).

8.2.3 Check off the item on the checklist if it is determined that the ALARA concept is being

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fulfilled.

If an area of concern is encounter-ed, assign it a sequential numeric designator, t

then note and fully explain the area of concern and if possible, recommend possible solutions to the problem on CPS No. 0AP1005.01F002, 1

CPS CODIENT CON'I'ROL FORM (or equivalent document).

NOTE A cost / benefit calculation may be performed to substantiate or refute the need for ch an g e.

It should be performed in accordance with the guidance provided in Section 2.2 Page No.

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0AP1895.0lN gpg F A Q I M [ [' D i'.d Y ] O S,! 8 3 _ Y n !n u h.,n:9.

c.4, b i l 8.2.4 All reference material utilized in complet-ing the ALARA Review shall be listed at the end of the appropriate checklist.

8.2.5 When the ALARA Review is completed, attach the CPS COMMENT CONTROL FORMS to the appropriate checklist and submit the review to the Supervisor - Radiation Protection.

I 8.3 Resolution of Noted Concerns 8.3.1 Upon receipt of a completed ALARA review, the Supervisor - Radiation Protection shall attach CPS No. 0AP1895.01F001, ALARA y

REVIEW COVER SHEET to the ALARA review and complete the following information:

a.

Circle the appropriate review:

Design / Construction / Modification /

Operation t i b.

Assign a sequential number, year and I

number, and record appropriately.

c.

System / Component / Subj ect d.

System / Component Designator (if applicable) e.

Review conducted by:

f.

Date 1

8.3.2 The Supervisor - Radiation Protection shall review the document and resolve all concerns, if possible.

Actions required to alleviate the radiological hatard may be accomplished via CPS No. 0AP1029.01F001, MAINTENANCE WORK REQUEST or CPS No. 0AP1016.01F001, CPS CONDITION REPORT.

5 Pace "o.

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Rev. No.

0AP1895.01.7 cps No.

-,,, - m ii s r TUN u1 ROW am 8.3.3 At the required frequency or as requested by two or more ALARA Committee members, an ALARA Ccamittee meeting shall be scheduled.

Approximately one week prior to a

normally scheduled ALARA Committee meeting, the Supervisor - Radiation Protection should submit to the committee members the meeting agenda, status of "open" items, and a copy of all ALARA Reviews generated since the last meeting.

3.3.4 Items which are identified as concerns shall be addressed at the committee meeting.

Items which are considered "open" items shall be 1

listed on the CPS ALARA REVIEW COVER SHEET.

These shmild be addressed at subsequent meet-ings until considcred " closed"'.

8.3.4.1 Concerns which are identified at an ALARA Committee meeting, but for which there is no formal ALARA Review, shculd be thoroughly 1

documented in the minutes of the meeting and an ALARA Review conducted, if appropriate, followinF the meeting.

1l 8.3.4.2 A concern shall be considered "open" if it l

is determined by the ALARA Committee to be

" reasonably achievable".

8.3.4.3 A concern shall be considered " closed" if it is determined by the ALARA Ccamittee not to be a valid concern or if the resolution to the concern is not " reasonably achievable".

8.3.5 At the completion of the ALARA Committee meeting at which a formal review was initially presented, attendees shall be listed on the CPS ALARA REVIEW COVER SHEET along with the date of the meeting.

1l 8.3.6 When all ALARA Review concerns are " closed",

the ALARA Chairperson shall sign and date CPS ALARA REVIEW COVER SHEET.

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4 0AP1895.0lN c?S No.

8.4 Resolving "Open" ALARA Items 8.4.1 Items which are approved for resolution by the ALAFA Committee should be assigned to the RadChem Engineer or a designee to pursue i

for implementation as the coordinator.

8.4.2 The coordinator shall make all arrangements with appropriate personnel or groups, and draft necessary paperwork, etc. for implementation.

8.4.3 All correspondence shall be attached to the ALARA documentation to substantiate action.

8.4.4 Upon completion of the work the coordinatcr shall prepare a summation of the task accomplished for presentation to the ALARA Committee and shall conduct any testing or verification as appropriate to "Close" the item.

8.5 Record Retention 8.5.1 The RadChem Department shall maintain control of all ALARA Reviews which are not complete.

8.5.2 Completed ALARA Reviews shall be maintained in accordance with CPS No. 0AP1917.01N, 1l RADCHE'i RECORDS.

j 9.0 ACCEPTANCE CRITERIA l

None

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10.0 FINAL CONDITIONS

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e 0AP1895.01N cps No.

11.0 REFERENCES

11.1 Regulatory Guide 8.8, Rev. 3 (June, 1978) "Information 1

Relevant to Ensuring That Occupational Exposure at Nuclear Power Station Will Be As " Low As Reasonably Achievable".

11.2 CPS Technical Specification, Section 6.0 11.3 CPS No. 0AP1005.01F002, CPS COMPENT CONTROL FORM 11.4 CPS No. 0AP1016.01F001, CPS CONDITION REPORT 1

11.5 CPS No. 0AP1029.01F001, MAINTENANCE WORK REQUEST 11.6 CPS No. 0AP1895.00N, ALARA PROGRAM 11.7 CPS No. 0AP1895.02N, ALARA COMMITTEE 11.8 CPS No. 0AP1917.0lN, RADCHEM RECORDS 12.0 APPENDICES None 13.0 DOCUMENTS A.

CPS No. 0AP1895.01C001, CPS ALARA REVIEW - DESIGN /

CONSTRUCTION / MODIFICATION CHECKLIST 3.

CPS No. 0AP1895.01C002, CPS ALARA REVIEW - OPERATIONS CHECKLIST C.

CPS No. 0AP1895.01F001, CPS ALARA REVIEW COVER SHFET l

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CPS ALARA REVIEW (DESIGN / CONSTRUCTION / MODIFICATION CHECKLIST)

C. A O p r M r o !st Sys tem / Component /S ubj ect I N n o.1 3 3 T !t y i

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AWD G JA;CE Oii:_Y System / Component Designator Check item off if it is determined that the ALARA concept is being fulfilled.

If an area of concern is encountered, assign it a

sequential numeric designator, then note and explain the concern fully on CPS CODIENT CONTROL FORM 0AP1005.01F002 and attach it to the review.

If an area is not applicable, place UA in the box.

Access Control of Radiation Areas Positive control of ingress, shielding, source removal, etc.

Standard Operating Procedures in the event of transfer of radioactive materials.

Means for prompt accessibility for inspection and/or servicing of components.

Radiation Shields and Geometrv Shielding between individual components that constitute substantial radiation exposure.

Reduction in exposure by providing maximum distance between serviceable conmonents and the substantial radiation source in the area and/or providing temporary shielding around components that contribute substantially to the dose rate.

Page 1 of 7

CPS 3o. 0AP1895.01C001 (Rev. 1) l Use of labyrinths, (or other design features), ensuring a

l l N ility of components to be readily removed for repair D

ar /or replacement.

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M^ R stields (shields of limited size to prevent s treaming).

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O se of shielded chases for piping runs containing radio-fbgt active materials.

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/ Shielding, insulation, etc., designed for rapid removal qc= ~

% e" LA.J and reinstallation.

WQ ILavdown space allotted for maintenance in cubicles.

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/ Ct-T Ability for prompt removal and reinstallation of components l

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for repair replacement in area of high radiation levels.

U Radwaste system sumps, piping, etc., located in shielded 4

I areas or shielded pipe chases.

I Process Ins trumentation and Controls Use of reach rods or remotely-operated valves or controls,

(consider maintenance on these items).

l Ensure readouts or control points located in low radiation areas.

The use of instrument'ation that is selected and located with consideration for long service life, ease and low i

frequency of =aintenance and calibration, and of icw crud accumulation.

b Use of instrumentation which contains minimal quantities of contaminated working fluids.

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CPS No. 0AP1895.01C001 (Rev. 1)

Control of Airborne Contaminants and Gaseous Radiation Sources Use of air pressure gradients and air ficw from areas of low potential airborne contaminants to areas of higher 1

25 potential centamination.

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I Ventilation and gaseous treatment systems designed for 4

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Use of portable ventilation systems / portable equipment J n

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_g_g-utilizing existing ventilation equipment for control of

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LLJ CI) localized airborne contamination (e. g., machining, sampling, 02:

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tanks, etc. ).

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r-Utilization of wet transfer or storage for contaminated j

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LA-components.

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Crud Control Use of low nickel and low cobalt bearing materials (limits production of Co-58 and Co-60).

On load bearing surface, the use of lubricants and favor-j able geocetries and the use of controlled leakage on l

j ournal sleeves to prevent entry of particles into the reactor coolant.

The use of chemistry controls in the reactor systems.

Use of decontamination, flushing, filtration on reactor systems.

Providing for laminar ficw and smooth surfaces for primary systems and by minimizing crud traps in the I

system to the extent practicable.

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CPS No. GAPlS95.01C001 (Rev. 1)

Isolation and Decontamination Decrease deposition of radioactive materials in piping by: avoiding stagnant legs, connections located above pipe centerlines, using sloping rather than horizontal c

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runs for pipe and drains provided at low points in c' - >-

% d system.

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Z Use of measures that reduce probability of release,

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<C from the source ( e. g., H VAC, curbing, sloping floors l --., Q 3

<C to local drain, sumps, etc. ).

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.i 2 Use of recirculation / flushing lines to allow from chemical

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Use of redundant systems to allow for maintenance or i

,C shutdown for repairs (e.g.,

processing or ventilation systems).

Design systems which carry radioactive materials for the lifetime of the plant.

Prevents contamination of clean systems / surfaces if the system fails.

l Appropriate finishing work on surfaces where contamination can be expected (i.e., use of surf aces which have smooth, i

non-porous surfaces and are free of cracks and sharp corners).

Features which will provide for alternate decontamination methods if anticipated failure of a critical component would prevent decontamination of important systems by normal means.

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GPS No. 0AP1895.01C001 (Rev. 1)

The use of treatment systems to allow for removal of con-taminants from tanks (e.g., spent fuel, radwaste tanks, l

etc.).

The use of agitators to reduce the settling of crud on surfaces in the tanks.

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l Emu.c_ ion Monitorinz Systems

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l Readout capability at the main radiation protection control CD

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area.

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l 2EE 2EE Placement of detectors for optimum coverage of areas.

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Local alarm and readout.

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Clear and unambiguous readout.

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Capability to record the readout of all systems.

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nesta and Sludge Treatment System i

i Accumulation of radioactive materials in components can i

be reduced by use of:

short runs of piping large diameter pipe reduced number of pipe fitting avoiding dead legs and low points in system use of gravitational ficw to extent practicab le minimite flev restrictions of processed material

(([ Need for maintenance and the presence of intense local radiation sources can be reduced by:

use of full ported valves avoiding cavities in valves Page c c.

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l CPS No. 0AP1895.01C001 (Rev. 1) j Smooth interior pipe surfaces achieved by butt welds

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and the use of consumable pipe inserts.

When use of tees required, normal ficw through the straight run of the tee and the branch of tee located above run.

i Ability to backflush lines which are subj ect to plugging.

Use of sparging systems to fluidize slurries or sludges in storage tanks.

l Prevent loss of solids from tanks into overficws by use of screens, filters, etc.

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I The selection of radiation damage resistant materials for

, use in radiation areas.

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' The use of stainless steel for use as lining in piping or for f=)

construction of components, where it is compatible, to limit e-J

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corrosion.

f C-C2C Standardination of filters and the remote servicina of C Lt.

hh~ $d3 componentc which constitute substantial radiation sources.

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Providing accessibility for the servicing of valves and ca; Q Z

components.

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.c; correctly in systems to prevent radioactive material C::

O a ccu:".mulation.

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The use of seal flushing when mechanical seals are utilized for Page 6 of 7

CPS No. 0AP1895.01C001 (Rev. 1) slurry service and the use of drains on pump housing can decrease radiation field accu==ulated during service.

The use of sloping tank bottoms and the use of sprays or spargers to allow for sedimentation re= oval when required i"

for maintenance.

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Spare connections on tanks located in higher radiation

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areas to allow for flexibility in operation.

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shielding, special tools / instruments for remote operation /

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inspection on compcnents containing potential radiaticn sources.

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The use of live loaded packing or bellows seals on valving LLJ C]

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in radiation systems.

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.c; Expeditious removal of components from a system located I Cr c-)

in a higher readiation area.

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lighting, ventilation, i

working space, etc.).

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Use of extended service lighting components.

Adequate emergency lighting systems.

Other (note eacn concern separately and attaen accitional pages as necessary.)

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' CPS No. 0AP1395.01C002 (Rev. 1)

Date:

CPS ALAPA REVIEW OPERATIONS CHECKLIST System / Component /S ubj ect AiND GlinMC OM_Y System / Component Designator Check item off if it is determined that the ALAPA ccncept is being fulfilled.

If an area of concern is encountered, assign it a sequential numeric designator, then note and explain the concern fully on CPS C0rlNT CONTROL FORII, CPS No. 0AP1005.01F002, and attach it to the review.

If an area is not applicable, place NA in the box.

Access Control Positive control of ingress and egress to area.

Individual assigned to contribute to and coordinate ALARA efforts.

Performance of a "preoperational" brief for personnel who will perform services in high radiation areas.

Utilication of "drv runs" on mock up equipment to train personnel, identify problems, and selecting and qualifying special tools and procedures.

Maintenance and/or inspections scheduled such that sources of radiation are allowed to decay off.

Completion of the Radiaticn Work Per=it.

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-QPS No. 0AP1895.01C002 (Rev. 1)

Surveyu and Inspections, Ensure completion of radiation, contamination, airborne contamination surveys.

Ensure that nature of the radiation fields are determined during inspection (e.g., hot spots, piping runs, tanks, etc.).

]Ensurethatmechanicaldifficultieswhichmaybeen-countered are noted.

Insulation and Shieldine 1

.c Use of recirculation / flushing lines to allow for chemical C:?

or physical removal of radioactive caterial to reduce r-- >-

$< _j radiation levels.

C {- Use ability to drain / flush tanks containing radioactive C3:a w_

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liquids to reduce. radiation levels.

Z Z{} Reduction in exposure by providing temporary shielding l <C around components that contribute substantially to the C2: 2 L2.J C.D 2E: dose rate. L1J CE) vl{L_ Reduction in exposure by removal and transport of component i g r- <) to an area of lower radiation levels. I LL. Control' of Containments Use of portable ventilation systems / portable equipment l l for control of localized airborne containments. l b ) Ensure air pressure gradients and air flow from areas of low potential contamination to areas of high potential l contamination are maintained l l il Fi ?a. I I i[ ., es . ll .) 'e (. t'

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• CPS Mo. 0AP1895.OlC002 1.

(Rev. 1) Use of continuous air ~ monitoring systems in areas uhere there is a high potential for airborne contamination i j (e.g., eachining, grinding, etc.) l j Miscellaneous i Adequate auxiliary lighting and a comfortable environment i (e.g., ventilation, heating, etc.) )' ] Contingency planning to cope with potential accidents JN expeditiously. /ph l s()r ??,3.? - N 'I l 0ther r / (Note each concern seprfrately nba.t;,Ey,s/ adeiqional pages 8d, 7,3,ir. s~.. as necessary) s l4l/v., ,,) ....,, i in i ~ Y Q, ,I ' > i gj l

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' GPS :To. 0AP1895.OlF001 '(Rev. 1) .l CPS ALARA REVIEW COVER SEEET ALARA Review - Design / Construction / Modification / Operation Nn Sys tem / Component /Subj ect i ni rnO s.ii\\TIO N g Q[\\j C,{1RL 11 a i V: u n. i ' - > i g,)PO v iDANCE. OSILi ) System / Component Designator Review conducted by Date ALARA Con:aittee Attendees Date of Meeting 4 Power Plant Manager / Designee Assistant Power Plant Manager / Designee Superiisor - RacChem/ Designee i Supervisor - Padiation Protection / Designee Memoer-at-Large NSE P.epresentative Open concerns: 1., \\ ') {\\.'\\ l1 \\l . n p ;:7.y.. m ~ ~- _

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ge u g ...s j U t s. i j l t_ ; a v ~, s i, v aviu-- I All concerns closed: Chairperson ALARA Conn:u.ttee Date; -. ~ .}}