ML20211J308
| ML20211J308 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/23/1987 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 8702260413 | |
| Download: ML20211J308 (2) | |
See also: IR 05000298/1986033
Text
- p
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FE8 2 31987
In Reply Refer To:
Docket:
50-298/86-33
Nebraska Public Power District
ATTN: George A. Trevors
Division Manager - Nuclear Support
P. O. Box 499
Columbus, NE
68601
Gentlemen:
Thank you for your letter of January 26, 1987, in response to our letter
dated December 23, 1986. We have reviewed your reply and find it responsive
to the concerns raised regarding the implementation of a comprehensive ALARA
program. We will review the implementation of your ALARA program during a
future inspection to determine agreement with your response.
Sincerely,
ORIGINAL SIGNED BY:
J. E. Gagliardo, Chief
Reactor Projects Branch
cc:
Guy Horn, Division Manager
of Nuclear Operations
'
Cooper Nuclear Station
P. O. Box 98
,
'
Brownville, Nebraska
68321
Kansas Radiation Control Program Director
f.ebraska Radiation Control Program Director
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CNSS875538
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January 19, 1987
,
.
.
i\\; JAN 2 6SBT
Mr. J. E. Gagliardo, Chief
h'
_
Reactor Projects Branch
U. S. Nuclear Regulatory Commission
_.
Region IV
611 Ryan Plaza Drive
Suite 1000
Arlington, Texas 76011
Subject: Nebraska Public Power District Response to IE Inspection Report No.
50-298/86-33
Dear Mr. Gagliardo:
This letter is written in response to your letter dated December 23, 1986,
transmitting Inspection Report No. 50-298/86-33. Therein you indicated a
concern with regard to implementation of a comprehensive ALARA program.
Following is a statement of the concern and our response to this concern:
Statement Of Concern
ALARA Program
The NRC inspector reviewed the licensee's ALARA program to determine
agreement with the recommendations of RG 8.8 and 8.10.
The licensee had implemented an aggressive ALARA program during the 1985
pipe replacement outage; however, this ALARA program was not continued to
include the normal operations and outage conditions.
The NRC inspector expressed concern that the CNS ALARA program does not
follow the recommendations of RG 8.8 and 8.10 and that these concerns
were previously addressed in NRC Inspection Reports 50-298/80-07, 82-20,
83-11, 85-04, and 86-05.
The NRC inspector noted that the present CNS
ALARA program did not include the following features:
An ALARA committee
ALARA checklists
ALARA goals
ALARA coordinator involvement in design change discussions
Adequate staffing
(,O $ +n1-wvgg
4'j f
J. E. Grgliardo
January 19, 1987
Page 2
.
NPPD Response
A proposal for the development of a comprehensive ALARA program for Cooper
Nuclear Station was approved and authorized for immediate execution at the
December 1986 NPPD Board of Directors Meeting. The vendor who is contracted
under this proposal is the same vendor who assisted NPPD in developing and
implementing its aggressive ALARA program during the 1985 pipe replacement
outage. As a result, the vendor is very familiar with existing NPPD ALARA and
Radiation Protection Programs and will be able to provide a comprehensive
ALARA program utilizing the very near term milestone dates listed in
Attachment 1.
The work scope for the NPPD ALARA Program has been divided into three major
phases in order to meet the milestone dates. Phase I, Program Scoping and
Review, was completed on January 13, 1987, and is presented as Attachment 2.
This document provides the outline around which the detailed ALARA program
will be developed. Work began on Phase II, Program Development, January 13,
1987, and is scheduled for vendor completion on May 8, 1987.
In this phase
the outline developed in Phase I will be used to generate detailed CNS ALARA
procedures for Station Operations Review Committee (SORC) review and approval.
Phase III, Computerized Dose Tracking Development, is scheduled for completion
on May 29, 1987. This phase will generate a personal computer program,
utilizing Lotus 1-2-3 software for the purpose of historically tracking dosa
exposures by job. This tracking program will replace the existing dose
tracking program which is cumbersome and has inherent software problems.
Because Phase III is only a replacement of an existing ALARA dose tracking
computer program, vendor completion and SORC approval of Phase 11 procedures
will denote the point where NPPD will be operating under an ALARA program
which follows the recommendations of Regulatory Guide 8.8 and 8.10.
As such,
the program will include the following features:
An ALARA committee
ALARA checklists
ALARA goale
ALARA coordinator involvement in design change discussions
Additionally, Nuclear Power Group (NPG) management has recognized the need for
supplemental manpower to support such a program and has authorized two
additional positions. These positions are an ALARA technician and an ALARA
clerk.
It is expected that these positions will be created and filled within
the next six months.
In summary, NPG management has taken an aggressive stance towards developing
and implementing a comprehensive ALARA program in a very short time frame.
It
is hoped that the actions dincussed above are responsive to the NRC concerns
and represent a positive commitment to ALARA.
.
__
- _ _ _ _ _ - - _ _ _ _ - _ _ _ _ _ _
,
.
J. E. Grgliardo
January 19, 1987
Page 3
.
If you have any questions regarding this response, please contact me or
G. R. Horn at the site.
Sincerely,
. A.
revors
Division Manager of
Nuclear Support
RLB:ya
Attachments:
1.
Milestone Schedule
2.
ALARA Program Outline
. . _ . . . . . . . . . . .
.4
'
Attachmsnt 1
.
SCHEDULE P'~
SIONES FOR ALARA PROGRAM DEVELOPMENT
DATE
ACTIVITY
12/05/86 TASK AUTHORIZATION INITIATED
PHASE I
1/13/87
REVISION 5 0F ALARA PROGRAM OUTLINE APPROVED
PRASE II
1/16/87
ALARA ORGANIZATION AND MANAGEMENT SYSTEM PROCEDURE COMPLETED
1/30/87
ALARA WORK REVIEW PROCEDURE COMPLETED
2/20/87
ALARA REPORTS AND AUDITS PROCEDURE COMPLETED
3/13/87
DATA COLLECTION PROCEDURE COMPLETED
4/03/87
ALARA TRAINING PROCEDURE COMPLETED
4/17/87
DOCUMENT CONTROL PROCEDURE COMPLETED
5/08/87
ALARA PROGRAM DESCRIPTION COMPLETED
PHASE III
5/29/87
COMPUTERIZED DOSE TRACKING COMPLETED
5/29/87
ALARA PROGRAM DEVELOPMENT COMPLETED
i
-
Attachment 2
.
Rev. 5
1/13/87
.
OUTLINE FOR COOPER NUCLEAR STATION ALARA PROGRAM
I.
ALARA PROGRAM DESCRIPTION
j
A.
Statement of CNS Management Commitment to ALARA Program
B.
Function and Purpose of ALARA Program
C.
Scope of ALARA Program
i
D.
Goals of ALARA Program
E.
Listing of ALARA Procedures
,
F.
Definition of Terms
'
G.
Reference Index
II.
ALARA ORGANIZATION AND MANAGEMENT SYSTEM
A.
ALARA Job Responsibilities
B.
Organizational Chart
C.
ALARA Committee
1.
ALARA Committee Charter
2.
ALARA Committee Responsibilities
3.
Members of the TTARA Committee
III. ALARA WORK REVIEW PROCEDURE
A.
ALARA Job Review
1.
Pre-Job Review
2.
During Job Review
3.
Post Job Review
4.
Emergency Work Requests
5.
Preventative Maintenance Items
1
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s
.
B.
Procedural Eeviews
C.
Design Changes and Equipment Specification Changes
D.
ALARA Suggestions by CNS Personnel
IV.
DATA COLLECTION
A.
Job Codes and Files
B.
Data Collection Frequency
V.
ALARA REPORTS AND AUDITS
A. ALARA Reports
1.
Short Term Reports
2.
Long Tern Reports
3.
Trending Reports
4.
Annual ALARA Goals Report
5.
Outage Goals Report
6.
Distribution of Reports
B.
In house Audits of ALARA Program
VI.
ALARA TRAINING
VII. DOCUMENT CONTROL
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I.
ALARA PROGRAM DESCRIPTION
A.
Statement of Commitment of CNS (NPPD) Management to the
Program
B.
Function and Purpose of the ALARA Program
C.
Scope of ALARA Program - This ALARA Program shall be in
effect
for all work at CNS during normal plant
opera-
ting
and outage conditions.
Large outage items (such
as
recirculation pipe replacement) may not be
subject
to
this program.
Instead,
a special
program
specifically developed for that item may be substituted.
D.
Goals of the ALARA Program At CNS
i
!
E.
Listing
of ALARA Procedures Including the Purpose
and
Scope of each Procedure.
-
F.
Definitions of Terms Used in the ALARA Procedures
G.
Reference
Index
I
This
index will
list
major
topics in
alphabetical
order
covered
in the
Procedures
and
pro-
vide
the
section
number where the topic is discus-
sed.
.
3
1
. _ _
II.
ALARA ORGANI2ATION AND MANAGEMENT SYSTEM
A.
ALARA Job Responsibilities
This
section
will
provide
the
job
descriptions
for
specific CNS
personnel
directly
involved or
responsible for
program.
The
job descriptions
listed in this
procedure
are
in addition
to their regular responsibilities.
The
job
titles
that
will
have
specific
responsibilities
are:
Division Manager of Nuclear Operations (DMNO)
Radiological Manager
Chemistry / Health Physics Supervisor
Assistant Chem /HP Supervisor
ALARA Coordinator
Health Physicist
Lead Health Physics Technician
Health Physics Technicians
Plant Chemist
Senior Manager of Technical Support Services
Engineering Manager
Plant Engineering Supervisor
Operations Engineering Supervisor
Plant Services Manager
Operations Manager
Operations Supervisor
Irstrument and Controls Supervisor
.
4
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Maintenance Manager
Maintenance Supervisor
,
1st Line Job Supervisor or Foreman
Outage Coordinator / Job Planner
-
Individual Workers
Training Manager
Training Instructor
Quality Assurance Manager
Quality Assurance supervisors
B.
Organizational Chart for ALARA Program
An
organizational chart of the CNS ALARA Program will
.
be developed.
The chart will be based on the existing
CNS Organizational Chart.
However, modifications will
be
made to the chart to show the realtionship
between
J
CNS departments and the ALARA Committee and to identify
formalized
lines
of
communication
between
departments
for ALARA concerns.
Text will
accompany
the
chart to help explain the connections between
job
,
titles.
'
.
C.
ALARA Committee
l
A
permanent
Committee
will
be
created
with
i
this
revision
to
the
Program.
This
section
will
describe the primary
responsibilities
!
of the ALARA Committee.
4
5
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.,__-.____,,,.__,.,..,,_.,_,,,,,.__,..,,____._,r-_,_.-,_,,.__,.___,_
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1.
Charter of the ALARA Committee
'
This
will
be
a brief statement
describing
the
purpose and
function of the ALARA Committee.
-
2.
ALARA Committee Responsibilities
The major responsibilities of the ALARA
Committee
are
listed in this section.
Responsibilities of
the ALARA Committee will include:
a.
Approval of
pre-job and post-job reviews for
all
jobs estimated to exceed 5 Man-Rem.
b.
Review
and
discussion of
quarterly
and
annual
exposure
reports
submitted
and
presented by the ALARA Coordinator.
c.
Review
and
approval
of
annual
exposure
goals for the plant.
d.
Review
of
suggestions
or
concerns
brought to committee's attention by the ALARA
Coordinator.
e.
Review
of
all
procedures,
test
procedures,
design
changes, etc. that
are
brought
to
the
Committee's
attention by the ALARA Coordinator.
f.
Perform
post job reviews on
all
procedures
brought before the Committee's attention.
6
.
3.
ALARA Committee Meeting Frequency
Committee shall
meet at
least on
a
quarterly
basis
during
normal
plant
,
operation.
During
outages,
the
'
Committee
shall
meet
at
a
frequency
determined
by
the
Committee
Chairman.
The ALARA
Committee Chairman
is
vested
with the
authority to
call ALARA
Committee meetings
as he
deems necessary.
Attendance
of the Chairman
or
Co-chairman
and at least four other members
of the ALARA
committee shall
constitute a quorum.
4.
Members of the ALARA Committee
The following personnel will make up the permanent
ALARA Committee.
Radiological Manager *
ALARA Coordinator **
HP/ Chem Supervisor
Assistant HP/ Chem Supervisor
Health Physicist
-
Operations Engineering Supervisor
Instrument and Controls Supervisor
Technical Training Supervisor
!
Operations Supervisor or Assistant Operations Supervisor
!
Maintenance Supervisor
Plant Engineering Supervisor
!
Maintenance Planner / Scheduler
Outage Coordinator
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Chairman of Committee
- Co-chairman of Committee
The
preceding
personnel will make
up
the
base
-
Committee
during normal plant operation.
The ALARA Committee Chairman
has the
authority
to
expand the size of
the ALARA Committee
as
necessary
to
fulfill
its
duties
for
special
circumstances.
(outages, etc.).
.
The
Chairman
of the ALARA
Committee
shall
be
vested
with the
authority to
make all
final
decisions
relating
to matters
that come
up
before the Committee.
Any disagreements made
by
-
other
Staff
Managers
of
the
'
Committee's
final
decision will be resolved by
the DMNO.
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III. ALARA WORK REVIEW PROCEDURE
A.
ALARA Job Review
.
1.
Pre-Job Review
Work
requests
written by the Work Item Tracking
Office
shall be assigned a time estimate
by
the
Job
Planner.
After
the
time estimate
is
assigned,
the
Work
Request shall be immediately
forwarded
to
the
Coordinator.
After
reviewing
the
job,
the ALARA
Coordinator
will
determine
if
an
review
is
required
directly
on
the
Work Request
form.
If
no
ALARA review is required,
the Work Request
form
is
routed
back
to
the
Job Planner.
If
an
ALARA review is required ,
the ALARA
Coordinator
will
assign a man-Rem estimate and a job code for
dose
tracking
purposes.
The
Coordinator
will attach the appropriate ALARA Job
Review Checklist with the
man-Rem
estimate
and
dose tracking job rode recorded on it.
Copies of
the
ALARA Job review checklist
for
that
job
will
remain with the Work Item and
the
Special
Work Permit until <>mpletion of the work.
Jobs
will
be reviewed for
considerations
based on the ALARA Coordinator's Man-Rem estimate.
As
the exposure estimate increases,
so does
the
severity
of
the
review.
The
following
divisions
describe the increasing severity of the
Pre-Job Reviews.
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Jobs with Estimates less than 0.5 Man-Rem
No ALARA Review Req'd
1
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Jobs estimated to incur less than 0.5 man-rem will
not be subject to an ALARA review.
Job codes and
man-rem
estimates will not be assigned
to
these
jobs.
However,
the
coordinator has
the
option to subject a job with less than 0.5 man-Rem
j
to
an
review.
If
an ALARA
review
is
requested,
the
review will be
similar
to
the
'
review for jobs estimated between 0.5-1.0 Man-Rem.
Jobs
with Estimates between 0.5 and 1.0 Man-Rem
Least Intense ALARA Review
Jobs
estimated
to
take
between
0.5
and
1.0
Man-Rem
will
be directly forwarded to
the
Health Physics
Technician.
Any special
considerations for that job will be written by the
Technician on
the
job
review
l
checklist.
The
original
Job
Review
checklist
will
be
returned
to
the
Coordinator for filing.
Copies of the
checklist
will
be
attached to
the
Work Request
and
the
Special Work Permit issued for that job.
Jobs with Estimates between 1 and 5 Man-Rem
Moderate ALARA Review
l
If
the
Coordinator
assigns
a
Man-Rem
estimate between 1 and 5 Man-Rem, the Work Request
i
will
be
sent
to the 1st
level
Job
Supervisor
(foreman)
along
with an
checklist.
The
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checklist
shall
be
filled
out by
the
job
supervisor
and returned to the ALARA Coordinator.
At this point,
the ALARA Coordinator will
review
the
completed checklist using an ALARA/HP
review
.
sheet.
The
Coordinator will
have
two
options at this point.
Option 1-
Approve
the Job Supervisor's checklist
by
signing it and forwarding a copy of both chec-
klists
with
the
Work Request
to
the
Technician who
will use the checklists
to
help
,
.
I
write
up
the
SWP.
The
Coordinator
will
keep the approved checklists.
Option 2- If the ALARA Coordinator is dissatisfied
with
the
Job Supervisor's responses,
the
coordinator
can request an informal meeting
with
the
job supervisor to resolve the
problems.
If
necessary,
new
checklists will be filled out
at
this
time
by
the
Coordinator
and
Job
Supervisor.
Once
both are satisfied,
the ALARA
Coordinator and 1st Line Job Supervisor will
sign
both
checklists
indicating that they agree
with
the
ALARA conditions.
The Job
Supervisor
will
forward
the
Work
Request
with
the
checklists
attached to the Maintenance Planner for scheduling
purposes.
Copies of the approved checklists will
be
forwarded
considerations
can be incorporated into the
SWP.
SWP's
will not be written for any
job
estimated
between
1
and
5 Man-Rem not authorized
by
the
ALARA Coordinator.
Copies of the approved
checklists
will remain with the Work Request
and
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_
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the SWP until completion of work.
If
disagreements
between
the
Job
supervisor
and
the
ALARA Coordinator cannot be reconciled,
'
the
problem
will
be
brought
to
the
Committee chairman's attention.
The resolution to
the
discrepancy
by the ALARA Committee
chairman
will be final.
Jobs With Estimates Greater Than 5 Man-Rem
'
Most Intense ALARA Review
'
For jobs estimated to exceed 5 Man-Rem,
the
most
intensive
review
process
will
be
implemented.
Once
the
Coordinator
has
determined that the proposed job will require more
!
than
5
man-Rem to complete,
he will forward
an
ALARA checklist to the Job Supervisor.
This ALARA
checklist
will
be much more
detailed
than
the
checklist
for
the
1-5
Man-Rem
jobs
and
will
require much more input from the job supervisor to
properly answer the questions.
In addition,
the
Coordinator
will
fill
out
a
separate
checklist
to
assist in his review and to
assist
the HP Technicians in filling out the
SWP.
Once
the
Job Supervisor's checklist is
completed,
it
will
be forwarded to the ALARA Coordinator for
a
preliminary review.
The job supervisor and ALARA
l
Coordinator
should
have an informal
meeting
at
this
point
to discuss the job and the
completed
checklists
if
either party
feels
it
is
necessary.
Any
disagreements
between
the
Job
Supervisor
and
the
Coordinator will
be
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resolved in the manner described for the 1-5
Man-
Rom jobs.
Once
accepted
by
the
Coordinator,
the
.
Work Request
and copies of the
completed
checklist
should
be distributed
to
the
committee
members
for
review.
An
committee
meeting
shall be called by
the
committee
chairman
if
the regularly
scheduled
ALARA meeting is not at a convenient time.
The
job
supervisor
should
attend
the
Committee
meeting to discuss
the job
with
the
committee
members.
Committee
recommendations
shall
be included on
the
checklist.
After
revising
the checklists based
on
the Committee's
recommendations,
the
Coordinator,
Job
Supervisor
and
Committee
chairman
shall
sign
the
checklists,
agreeing
to
the conditions on the
checklists.
Copies of the
approved
checklists
should
be
forwarded to the lead HP Technician so
the SWP can be written.
As before,
the original
checklists
will
be
filed
by
the
Coordinator in the Job File.
2.
In-Progress Job Review
The
Coordinator shall keep a list
of
all
active jobs that have undergone ALARA reviews.
At
his discretion, the ALARA Coordinator will perform
random
inspections of jobs in
progress.
During
inspection, the ALARA Coordinator will verify that
13
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.
items
agreed to on the ALARA checklists are being
followed
by the workers.
If conditions are
not
being
met,
then
the
Coordinator
should
remind the Job Supervisor of the ALARA
conditions
-
that he agreed he would follow.
If this informal
meeting
does
not resolve the problem,
then
the
.
Coordinator has the authority to
stop
the
work.
If
a
greater than 5 Man-Rem job is
in
progress
during a regularly scheduled
meeting,
the
coordinator
shall give a report
to
the
committee on the progress of the job.
3.
Post Job Review
As
with the pre-job review,
the post job
review
will follow a four divisional review process.
Jobs Estimated to Be Less Than 0.5 Man-Rem
No
post
job review required unless requested
by
ALARA Coordinator.
.
Jobs Estimated Between 0.5 and 1.0 Man-Rem
once
a
0.5
to
1
Man-Rem job is completed, the
Job
Supervisor should
return
the
checklist
to
the
Health
Physics
Technician.
Any
l
problems
encountered during the progress
of
the
job should be written on the checklist by the lead
l
Health
Physics
Technician or HP Technician
that
l
covered
job.
The
completed checklist
should
I
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.
be returned to the ALARA Coordinator for filing in
job file.
Any
discrepancies,
lessons
learned
or
severe exposure
overruns
shall be brought to
the attention of the ALARA Committee. .PA
-
Jobs Estimated
To Be Between 1 and 5 Man-Rem
The
post job review for jobs estimated between
1
and
5
Man-Rem shall be performed by
the
Coordinator.
Once the job is completed,
the job
l
supervisor
shall
complete the questions
in
the
)
post job review section of the ALARA checklist and
j
return
the
form to the
Coordinator.
Any
additional comments by the ALARA Coordinator shall
be
written
on the ALARA checklist at this
time.
i
Also,
any lessons learned that could be
utilized
for
future jobs should also be included.
If re-
,
l
quired,
the Job supervisor should be
interviewed
l
by
the
ALARA Coordinator'for more
information.
I
once
completed,
the ALARA Coordinator shall file
'
the
checklist
in the permanent
job
file.
Any
discrepancies,
lessons learned or severe exposure
,
overruns shall be brought to the attention of
the
ALARA Committee.
Jobs Estimated to Be Greater Than 5 Man-Rem
Post jobs review
forms will be filled out by
the
Job
Supervisor and the
Coordinator
which
will
detail
the
jobs successes
and
failures.
Special
emphasis will
be
placed
on
" lessons
learned".
Both
Post
Job Review Forms
will
be
filed
by the ALARA Coordinator in
the
permanent
.
15
.
.
job file.
A complete account of the job
will
be
presented
to the
Committee
at
the
next
scheduled
meeting.
Any discrepancies,
lessons
learned
or
severe exposure
overruns
shall
be
brought to the attention of the ALARA Committee.
.
4.
Emergency Work Requests
occasionally,
emergency
work needs to be perfor-
med that, in the opinion of the Shift
Supervisor,
cannot
wait
for
the
normal processing of
the
Work
Item.
If this is the case,
Emergency Work
Requests
are
used
instead of the
normal
Work
Item Request.
An Emergency Work
Request,
with
the
verbal
concurrence
of
the
operations
Supervisor, is filled out by the Shift Supervisor.
No work
involving
radiological
hazards shall be
initiated without suitable Health Physics
Review.
The
Health Physics Technician on shift
will
act
in
place of the ALARA Coordinator if
the
Coordinator
is
not
available.
For
Emergency
Work
Requests,
a formalized
pre-Job ALARA
re-
view
can
be
bypassed,
but a post
job
review will still be required at the completion of
the job.
5.
Preventative Maintenance Items
For Preventative Maintenance Items,
Preventative
Maintenance
Cards
will
be
reviewed
by
the
Coordinator
prior
to
initiation
of
work.
A Manhour estimate shall be written on the
P.M.
card
prior to ALARA review.
The
16
--.
Coordinator will assign
a
man-Rem
estimate
on
the
P.M.
card.
ALARA reviews for
Preventative
Maintenance
jobs
will follow the same format
as
for Work Items.
-
B.
Procedure Reviews,
Special Procedures and Special Test
Procedures
All
procedures
and
revisions to procedures
will
be
reviewed by the Radiological Manager as a result of his
position
on
SORC.
The review
by
the
Radiological
1
Manager
may
include a detailed serial review by
sign
j
off
or
an
in
committee
review
during
SORC
final
approval.
The Radiological Manager may forward any of
these
procedures
to
the ALARA
Coordinator
for
his
review prior to SORC's final review.
If
a procedure is forwarded to the ALARA
Coordinator
l
for
review,
the
ALARA Coordinator will
fill
out
a
j
procedure
review
checklict
to
assist
him
in
the
'
review.
At
this
time,
the ALARA
Coordinator
will
assign a job code to the procedure.
In addition,
the
Coordinator
shall
make
appropriate
comments
on
the procedure.
During
the
review,
the
originator
of
a
procedure
may
be
interviewed
by
the
Coordinator
to
resolve
certain problems with the draft procedure.
The
ALARA Coordinator will return the draft
procedure
with comments and the procedure review checklist to the
Radiological
Manager.
As
part
of
the
procedure
approval
cycle,
the
originator
shall
revise
the
17
___
- -
.
_ _ _
_ _ _ _ _ _ _
_ _ - _ _ . - - . -
_ - - _ _ _ _
_ . _ _ . - - _ - -
_
-
-
.-.
.
. __- -.
'
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,
/
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(L
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-
'
,
.
,,
,
s
-
u,
,
.n
,
.
.-
a
mn
_c
- :
'
'
procedure
to
incorporate
the
AIARA
Coordinator's
-
,,<c
/; ;
comments.
It
is
the
Radiological
Manager's
j
responsibility
to
insure that the AIARA
Coordinators
rf
/
,
.
comments are incorporated into the apprbved ' procedure.
/.,
, i,
.
A
copy
of the AIARA Procedure Review
checklitx will
h
staywiththeprocedurecoversheet:,)"
' k
' ,.
t
.
i
s.
t
,;
O>
- ,
The
original
AIARA
Procedure review checklist
will r
'
,
i
be
filed
by
the AIARA Coordinator in the
job
fil'. 5
,'
c
When
the
procedure
is ready,to
be
initiated,.,the
['
.
AIARA
Coordinator
shall 7 forward
a
copy
of
/ithe
'
Procedure
Review
Checklist
to
the
Load
Health
Physics Technician to assist him in writing the SWP.
.
<
'
- ,i
.
.
'
j'&
'a.
.
t
c.
Design Changes and Equipment Specification Changes
!
,
Design Changes and Equipment. Specification Changes will
be handled slightly differently than ordinary procedure
review.
For design changes or equipment specification
gre5Ee'r AIARA impact can be made if
items
changes,
a
such as equipment placement, actual design, and ease of
i
problems can be addressed early in
the
design
'
access
!
j
change process.
Obviously,
once the design chang 2 is
written,
it
may be too late to implement
significant
exposure saving ideas.
The AIARA ::hecklist for design
i
i
changes
and
equipment
specification
changes
will
'
I
emphasize long term dose reduction questions.
'
3
!
The
AIARA
checklist
for
design
changes
and
'
l
equipment specification changen shall be coupleted when
Attachment D of CNS Procedure 3.4-
is
filled
out
by,
'
!
the
Design
Engineer.
The
questions
in
the
checklist for the design engineer,will determina if
an
!
18
'
~
!
I
'
- -.-
- .. - - . - - . ...
.- .-.-
. . -
- . - - :::.. -
--
-
- - -
- - _
_.
- _ . - .
_.
_ - - - -
_
__
l
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<:
f
r!s\\
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, ,, s
,
,
'
! q ., Is
I
,
p
-
, . .
'
/
'
'L ALARA
review
<is required.
If required,
then
the
5
'
e
, Design,7,Chan'geI shall- be
forwarded
to
the
',
Coordinator
sfor
review.
Using
the
review
checklist
as 'a
guide,
the
ALARA Coordinator will
L'
-
,<
s
makeff omments
on the design
change
and
submit
his
t
r
, . .
!
' ,reco' Emend'ations
to the design engineer on the
Design
a
i,hange ALARA checklist.
The ALARA Coordinator, at his
4
,
,
option,
may -ask other
personnal
in
the Chemistry /
g
Haalth
Physics
Department
to assist
in
the
design
,
,
change
review.
A
copy of the Design
Change
checklist snall remain with the design change package.
.
D.
ALARA Suggestions by CNS Personnel
.
Personnel at CNS not directly involved in the CNS ALARA
,
,
',
Program will
be able to contribute to the
program through the use of ALARA suggestion forms.
If
a
worker has an idea that could contribute
to
saving
.
exposure
at
the plant,
an ALARA suggestion
form
is
,
' '
filled
out
by the worker explaining the
idea.
Once
completed,
the ALARA Suggestion Form is then forwarded
'
,
to
the ALARA Coordinator.
After
review,
the
Coordinator will either reject or accept the idea.
If
the
idea is rejected,
a written memo to the suggester
v
or
an
informal
meeting with the
suggester
will
be
fh
completed
to
explain why the idea does not
meet
the
ALARA objectives of the plant.
,
.
If
the ALARA Coordinator feels that the idea is
worth
,; s
consideration,
he will forward the suggestion to ALARA
Committee
Members.
At
the
next
scheduled
ej7
'
Committee
meeting,
the suggestion will be brought
up
/
for
discussion.
The
ALARA Committee will
have
four
,,
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.
.
'
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v-n-.
m
ww,,
.
, . _ .
e
.
.
options
on
all
ALARA suggestions
brought
to
their
attention:
,
~
'
a.
Approve the
suggestion without modification,
b.
Modify the suggestion and approve it.
A
c.
Forward
the
suggestion
to
the
appropriate
personnel
for
further
study.
<
4
d.
Reject the suggestion as not meeting ALARA
objec-
tives.
If
approved,
the ALARA idea will be
implemented
.
into the ALARA program as soon as
practical.
If
rejected,
a
written response will be ser.t to the
suggester
explaining the reasons
for
rejection.
All
suggestions requiring further study,
will be
brought
up
at future ALARA Meetings
until
the
suggestion
is
approved or rejected by the
Committee.
,
i
20
!
..
. _ _ .
. - .
. _ .
.
-
-
.
.
.
- . -
.
.
.
IV.
DATA COLLECTION
A.
Job Codes and Files
.
Jobs shall be assigned job codes which will be the base
.
of the computerized dose tracking operation.
Each job
will
be
given an individual number that
will
easily
identify
it.
Possibilities for the numbering
system
basis include:
WIT #
SWP#
Job Location
Date of Issue
Equipment Type to Be Worked On
,
'
The
Job Code Number will be assigned upon
receipt
of
the
ALARA Job
Review or the ALARA
Procedure
Review
checklist.
The
job
code number will
serve
as
the
reference
number
for the permanent ALARA
file.
The
Job Code # shall be entered by personnel on
the
SWP
log sheet upon entry into the SWP work
area.
Job
l
codes
should
only
be
used
once.
The
Job
Supervisor / Foreman is responsible for insuring that the
Job Codes are er:tered on the appropriate SWP log.
.
Files
for all
jobs will be maintained by
the
Coordinator. As the jobs progress, the job
file should
become
an archive file for any information relating to
i
that
job.
For example,
other data that
would
prove
useful
would
be
copies
of the
job's
review
i
checklists,
survey maps,
copies
of SWP's,
lessons
learned
and
notes
made
by
the
Coordinator
l
21
!
l
l
l
-
- ..
- .
.
. - . . . - - . . - -
.--
. - - - - . .
. . . . -
. - - . -
. . -.
.
.
.
.
during inspection of the job while it was in progress.
For
the data
input,
pocket dosimeter
readings
will
be
used.
These will
suffice for
daily and
weekly
'
reports.
However, for quarterly
and annual
reports,
the most current
TLD/ dosimeter factor will be used as
a correction factor.
B.
Data Collection Frequency
,
For Jobs Estimated Between 0.5 to 1.0 Man-Rem -The
SWP
exposure
data sheet will be entered into the
computer
upon completion of the job,
when the SUP sign in sheet
is completed, or at the end of a calendar quarter.
For Jobs
Estimated Between 1-5
Man-Rem-SWP
exposure
data
will be entered upon completion of the
job,
the
SWP
sign in sheet is completed or on at least a weekly
basis.
For Jobs creater Than 5 Man-Rem-SWP exposure data
will
be entered into the computer on at least a daily basis.
l
I
22
__
_
_ _ _
_
.
.
.
.
k
V.
ALARA REPORTS AND AUDITS
A.
ALARA Reports
.
Reports
will be
generated on
a
periodic basis
to
assess
the success of the ALARA program.
The reports
are separated into two basic
categories,
short-term
and
long-term.
The
ALARA Coordinator will
be
responsible for producing both the short term and
long
term ALARA reports.
1.
Short Term Reports
The
main purpose of the short term reports are to
keep
up
to date exposure
records
on
current
jobs
having
exposure
estimates greater
than
1
Man-Rem.
These
reports
will
essentially
be
computer printouts
and will
not
include
any
text.
Short
term reports will only
track
the
Man-Rem
totals
for
individual
jobs.
Overall
,
plant totals
will not
be
provided in
the short
I
term reports.
The two short term reports are:
Daily
Reports
Will
report
the
exposure
-
incurred
on
jobs greater than 5 Man-Rem.
Weekly Reports - Will
report
the
exposure
in-
curred on
jobs greater than 1 Man-Rem.
Jobs less
than
1
Man-Rem will be included on
the
weekly
report,
but the exposure data may not necessarily
be up to date.
If
no
jobs
are in progress that
have
exposure
l
!
23
i
ew---
-
Wm----
yv-,
w-
,-w.,
.-
c- -r3
-w.----wg-
- - - - - - - - - - - - - - - - - -
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e
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-,,,----.-,.,_m,
-,__.____---_---r------w--
-ww-
-
-w'
-
_
_
_
_
_
.
.
estimates
greater
than
5
Man-Rem,
then
daily
reports will not be required.
'
Long Term Reports
2.
~
The long term reports are different
in scope than
the
short term reports.
Rather than
show
the
exposure incurred
on individual jobs,
the
long
term
reports
will
group
the
totals
of
the
individual
jobs into broader categories
so
that
trends
and
goals can
be
analyzed.
The
main
purpose
of
the long
term reports are to
report
on
the plant
condition from
an ALARA point
of
view.
Two
types
of
long term reports
will
be
generated; quarterly and annual reports.
A quarterly report will be generated at the end of
,
each calendar quarter.
The ALARA Coordinator will
update
the
exposure incurred on
all
individual
jobs which he is tracking.
Then,
the individual
l
jobs will be grouped in categories consistent with
the
annual
ALARA goals
report.
In
this
way,
exposure
results can be compared directly to
the
annual
ALARA goals.
The ALARA Coordinator will
write
a short report ,on the quarter's and current
year's exposure totals and present this report
to
the
Committee at its
regularly
scheduled
meeting.
If
an
outage
is in progress
or
has
occurred in the reported quarter, then the results
of
the outage should be included in this
report.
Based
on
the discussion at the
Committee
meeting,
the quarterly report will be revised
to
reflect
any action that will be taken on
proolem
24
- ..
-
. . - . . . - _ _ - _ - _ _
- - .. -. .
..
-
- . .
.
.-.. . .-..
.
--
.
.-.
.
i
'
.
.
.
areas.
The
revised quarterly ALARA report
will
then be
submitted
to the
Division Manager
of
Nuclear Operations.
At the
end of the
4th quarter,
an
annual ALARA
report
will be prepared instead
of a
4th quar-
ter
report.
This
annual report will be
very
similar
to a
quarterly ALARA report
except
in
the
annual
report,
the ALAEA
Coordinator will
recommend
improvements that
should
be
insti-
tuted
for
the
coming
year.
These improve-
ments
may
be
suggestions
to
reduce
exposure
in
the upcoming
year
or to
propose
revisions
to the
program itself. As with the quarte-
rly
reports,
the ALARA Coordinator will
present
the
annual
report to
the
CLamittee
for
discussion.
An
Committee approved
annual
report will be
submitted to the Division Manager
of Nuclear Operations.
3.
Trending Reports
When
requested
by
the
Committee
Chairman,
the
ALARA Coordinator will be respon-
sible for generating graphs and
charts
detailing
l
l
l
exposure
trending patterns
incurred
at
CNS.
Exposure trending reports will be required on
at
l
least
a
weekly
basis during extended and plan-
ned outages.
4.
Annual ALARA Goals Report
once a year,
the ALARA Committee shall
establish
the plant ALARA goals.
These goals will be writ-
25
_
_ . _ . - _ __ . _ _ _ _ _ _ - - - . - - - - - _ _ _ . , _ - - - _ _ _ _ _ _ _ _ . - . _ _
.
_
._-
,
.
.
.
.
ten
in
a
report
format and
submitted
to
the
Division Menager of Nuclear Operations for his and
NPPD Management approval.
These goals
will
be
very
broad
in scope and will establish
exposure
-
goals
by department.
Goals for individual
jobs
will be avoided in this report.
Each
member
of the
ALARA Committee who
is
a
representative
of
their
respective
department
,
shall
be
responsible for writing their
depar-
tment's
ALARA goals for
the coming
year.
The
ALARA Coordinator will
not be expected
to estab-
lish
any
departmental ALARA goals
but
instead
will
compile
the
individual
department
goal
reports
into a coherent plant ALARA
goals
report.
After the ALARA Coordinator has compiled the draft
ALARA goals report,
he will submit copies of
the
goals report to the ALARA Committee members
for
review and comments.
The ALARA
Coordinator
will
revise the report based on the comments
re-
ceived
and
resubmit
the
report
to
the
Committee members.
A special meeting of the ALARA
'
Committee
will be called ht this time to
approve
the
goals report.
Once approved
by
the
Committee,
the report will be sent to
the
DMNO
for
final
review
and
approval
by
Management.
Department
Exposure
Goals
and
Objectives
may
be
included
in
the
Division
Manager's
Goals
and Objectives
Program.
Total
station exposure goals may be included as part
of
the Nuclear Power Group's Performance Goals.
26
-
4
---.-
y
w-
-
,.
- - -
g
..-.m.--
- . - - . - , - - -
-m
i,.m
-s
.,- - - - - _ - _ . _ . , _ _ _ . , , _ _ _
--
-
4
&
.
.
Once
the
Annual ALARA Goals are
approved,
each
Committee
member who
holds
a
Supervisor
'
position
will
be
responsible for
insuring
his
department meets its approved ALARA goals for
the
year. The ALARA Coordinator will work closely with
managers and supervisors throughout the
year
to
increase
management
awareness of
the
Program
and to' assist the Department
Supervisors
in meeting the established ALARA Goals.
l
5.
Outage Goals Report
Prior
to
scheduled
outages,
the
Coor-
dinator
will
be responsible for submitting
an
Goals
Report.
This report has
two
major
objectives.
a.
List
the major jobs that will be
performed
in
the outage and
identify
methods
that
will
be
used
to
keep
exposures
for those jobs.
b.
Generate
Man-Rem
estimates for those major
jobs and for the
entire outage.
6.
Distribution of Reports
Daily and Weekly ExDosure ReDorts
l
Division Manager of Nuclear Operations
,
i
Job Foreman
Responsible
Dept Supervisor
27
_
.
.
.
.
.
.
,....
._ ___ _ _ . . _ _
_ . - _ _ _ . _ _ _
.
_
- - -
.
,
'
4
ALARA Coordinator
Chem /HP Supervisor
All CNS Department Managers
.
Ouarterly ExDosure ReDort
Division Manager of Nuclear Operations
ALARA Committee Members
All CNS Department Managers
Annual
Exposure
ReDort,
ALARA Goals ReDort
and
Outace Goals ReDort
Division Manager of Nuclear Operations
F M Committee Members
SORC Members
CNS Department Managers
Key Corporate Personnel
B.
In-house Audits of ALARA Program
In-house
audits of the the CNS ALARA program
will
be
performed
in
conjunction with the regular
audit
of
Health
Physics
Activities as determined by
the
l
Quality
Assurance
schedule
or
requested
by
the
Radiological Manager.
The purpose of this audit is to
identify
any deviations from the approved ALARA
prog-
ram.
Actual
practices will be compared
against
the
written ALARA procedures.
Results of the audit will be
distributed
as
specified in the QAI and Policy
docu-
l
ment.
Findings will be corrected as soon as possible.
The
ALARA Coordinator will be responsible for
correc-
ting audit findings.
28
-
,
. , . . _ . , _ - - - - - . . _ - _ - . -,
. -
- - - -
. . - . -
- . - - -
- -
_ - _ _ .
_
_
\\
.
.
e
VI.
ALARA TRAINING
ALARA Training will be separated into 6 major categories The
type of training received will depend on job classification
A.
Management / Supervisory
B.
Maintenance / Electrical
C.
Health Physics / Chemistry
1
D.
Operations
E.
Engineering / Design
F.
Quality Assurance / Quality Control
G.
General
Employee / Visitor
The
training received
by
each
group will
be
directed towards
their individual
ALARA responsibili-
ty
and their ALARA responsibility as
a member
of
a
department.
Special
emphasis will be placed on their
departmental responsibilities to the CNS ALARA Program.
Each
group
will
be
initially
trained
in
practices
with re-training repeated every
two
years.
New
employees and visitors to CNS will receive General
Employee ALARA training
as
part
of the the introduc-
tory training program already established.
The
Coordinator
shall
periodically
review
the
ALARA Training Programs to
insure that are consi-
29
, _ - - - _
.
_ .__
.
. .
.
.
-
.
.
.
.
.
.
.
stent
with
the
latest revision
of
the
Program.
Details
of
the
training program are covered
in
the
'
Training Department Instructions.
L
,
G
,
l
!
l
l
!
.
30
. .
. .
.
.'
'
.
VII. DOCUMENT CONTROL
The
ALARA Coordinator will be
responsible for
setting up
and maintaining the
job files
necessary to permit
access
to
related
information.
Job
files
should
be
maintained
in
a
permanent
file
either by
the
Coordinator or by the Document Control
Staff.
These
job
files
are
invaluable
aids
for establishing
historical
base
line
data for work
that is
to be repeated or is
to
be performed in the vicinity of completed jobs.
All
short
term exposure
reports may be
discarded by
the
ALARA Coordinator,
if desired,
once the
next year's ALARA
goals
report
is
approved
by
the
Division
Manager
of
Nuclear Operations.
All
quarterly
and
annual
reports
shall
be main-
tained permanently in accordance with CNS
Document
Control
Procedure. 1.9
31
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.-.
.
-.
.
-
.
. __