ML20054M508

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Responds to NRC Re Violations Noted in IE Insp Rept 50-285/81-28.Corrective Actions:Upgraded ALARA Program Defined & Developed.Program Description Encl
ML20054M508
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 06/01/1982
From: William Jones
OMAHA PUBLIC POWER DISTRICT
To: Seidle W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20054M502 List:
References
LIC-82-222, NUDOCS 8207130527
Download: ML20054M508 (4)


Text

Omaha Public Power District 1623 HARNEY a OMAHA, NEGRASMA 68102 m TELEPHONE 536-4000 AREA CODE 402 82522 b

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3JN 31982 I h.)

j f <l m D Mr. W. C. Seidle, Chief Reactor Project Branch 3 U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Reference:

Docket No. 50-285 IE Inspection Report 81-28

Dear Mr. Seidle:

Fort Calhoun Station ALARA Program Omaha Public Power District's letter to the Commission, dated December 21, 1981, stated that an upgraded ALARA program for the Fort Calhoun Station would be defined and program improvements initiated by June 1, 1982. The District has defined and developed the ALARA program content and a brief overview of this program is attached. As detailed in the attachment, the District began implementation of the upgraded program with the issuance of the Corporate Policy Statement regarding ALARA and with the issuance of Administrative Standing Order G-50,

" ALARA Radiation Exposure P"ogram". The detailed program operating procedures are presently being developed for inclusion into the Fort Calhoun Station Radiation Protection Manual. The District will expedite the completion and implementation of these procedu' s to ensure that the Fort Calhoun Station maintains an ALARA policy tha is consistent with the objectives detailed in the Corporate Policy Statement and Standing Order G-50.

Although many aspects of ALARA have previously been included in the Fort Calhoun Station health physics and radiation protection program as nonnally accepted exposure control practices, the upgraded ALARA program ensures that a formal, comprehensive program with complete corporate 8207130527 820707 PDR ADOCK 05000285 O PDR j

r e O Mr. W. C. Seidle LIC-82-222 Page Two support is dedicated to the goal of personnel radiation exposure re-duction. This goal will be achieved through organized authority, procedures application, and documentation.

Sincerely, j ! li / l10 lV\ ' l

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W.(ib'kh'n C. J,ones Division Manager Production Operations Attachment cc: U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D.C. 20555 LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, D.C. 20036 s

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ALARA PROGRAM ,

The Omaha Public Power District ALARA program is controlled by three basic documents. These documents are: (1) a written management policy statement, (2) an administrative procedure, and (3) ALARA oper-ating procedures.

(1) Written Management ALARA Policy On June 1, 1982, Mr. B. W. Reznicek, General Manager, approved for issue Omaha Public Power District Policy No. 9.03 to the Corporate Supervisors Manual. This document, entitled "0ccu-pational Radiation Exposure ALARA (As low As Reasonably Achievable)", provides the following features:

a. A written management policy statement which establishes and commits the Omaha Public Power District to an ALARA program dedicated to maintaining exposures as low as reasonably achievable,
b. The management statement as:>igns the responsibility and authority for the operational ALARA program development to the Division Manager - Production Operations.
c. The statement assigns responsibility to all Omaha Public Power District managers involved in Fort Calhoun Station support activities related to design, engineering, and modifications to establish and implement ALARA practices in conducting these activities.
d. The statement assigns individual responsibilities to each District or contract worker for the strict adherence to ALARA requisites and procedures.

(2) Administrative Procedure Standing Order G-50, entitled "ALARA (As Low As Reasonably Achievable) Radiation Exposure Program", has been implemented as the plant's procedural method for achieving the ALARA goals. This procedure is maintained in the Fort Calhoun Station Operating Manual, Volume A, Administrative Procedures.

The stated goals of the program are to maintain individual and collective dose exposure for personnel assigned duties in the controlled area of the Fort Calhoun Station to as low as -

reasonably achievable. The procedure presents the following provisions:

a. A procedure which implements the ALARA program.
b. Designates the Plant Manager - Fort Calhoun Station the responsibility for all aspects of the plant's operational ALARA prngram.
c. Designates the Supervisor - Chemistry and Radiation Protection the responsibility for directing and applying the mechanics of the program. NOTE: This function is sometimes described as the onsite Radiation Protection Manager.

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d. Reaffirms the ALARA responsibilities of all functional Omaha Public Power District departments providing support to the station by means of equipment modifications and/or design work.
e. Incorporates required in-plant ALARA actions and efforts into the Fort Calhoun Station. radiation protection program. This program controls the pre-planning and review of proposed projects and, also, the radiological

' evaluation of routine plant operations and maintenance.

f. Establishes an ALARA committee to review, evaluate, and advise the Plant Manager, as Plant Review Committee

' Chairman, on the progress and results of radiation exposure reduction goals -for facility projects,

g. Establishes an ALARA goals program with corporate par-ticipation and oversight.
h. Specifies document control, training, pre-job briefing, and post-job review as necessary tooli of a thorough and effective ALARi program.

Administrative Standing Order G-50 was implemented on June 1, 1982.

(3) ALARA Operating Procedures A series of operating procedures are being developed and will be implemented to provide detailed instruction for the in-corporation of ALARA' efforts into all radiological tasks.

Section 7.0 of the Fort Calhoun Station Radiation Protection Manual (0perating Manual - Volume VII) is being revised to contain these instructions. The content of this section will be structured.to include the following items:

Section 7.0 - Station ALARA Program 7.1 - Definitions 7.2 - Administration 7.3 - Training 7.4 - Operational ALARA Evaluation 7.4.1 Work Planning 7.4.2 Work Reviews 7.4.3 Work Sheets 7.5 - Work Factor Analysis 7.F - Engineering Design Review

/ - ALARA in Radiation Protection Procedures

.8 - Cost Benefit Evaluation Method 7.9 - Past Job Review and Evaluation 7.10 - ALARA Records Operating procedures specific to ALARA will be implemented as approved by the Plant Review Committee.

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