ML20213A269

Responds to NRC Expressing Concerns Re Implementation of Comprehensive ALARA Program as Noted in Insp Rept 50-298/86-33.Schedule Milestones for ALARA Program Development & Outline of ALARA Program Encl

ML20213A269
Person / Time
Site:	Cooper
Issue date:	01/19/1987
From:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
To:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
CNSS875538, NUDOCS 8702030188
Download: ML20213A269 (35)

Text

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f i COOPER NUCLEAR ST ATioN i

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Nebraska Public Power District '" " * "A"c"O"R@l0.^i

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CNSS875538 _.

1 January 19, 1987  ;;. _

p 2 61981 Mr. J. E. Gagliardo, Chief _

Reactor Projects Branch _

U. S. Nuclear Regulatory Commission t 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

$g follow the recommendations of RG 8.8 and 8.10 and that these concerns

[Q@ were previously addressed in NRC Inspection Reports 50-298/80-07, 82-20,

-o 83-11, 85-04, and 86-05. The NRC inspector noted that the present CNS 08 ALARA program did not include the following features:

bo (D E An ALARA committee b8 Q

O ALARA checklists

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• ALARA goals tr a ALARA coordinator involvement in design change discussions Adequate staffing 6 L

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J. E. Gagliardo 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 orovide a comprehensive ALARA program utilizing the very near term milest ue 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 dose 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 II 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:

4 An ALARA committee ALARA checklists ALARA goals ALARA coordinator involvement in design change discussions i

l 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 i clerk. It is expected that these positions will be created and filled within the next six months.

l 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 discussed above are responsive to the NRC concerns and represent a positive commitment to ALARA.

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I i r J. E. Gaglicrdo 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

F 4 P Attachm nt 1 SCHEDULE MILESTONES FOR ALARA PROGRAM DEVELOPMENT DATE ACTIVITY 12/05/86 TASK AUTHORIZATION INITIATED PHASE I 1/13/87 REVISION 5 0F AL/.RA PROGRAM OUTLINE APPROVED PHASE 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 1

l Attachment 2 Rev. 5 1/13/87 OUTLINE FOR COOPER NUCLEAR STATION ALARA PROGRAM I. ALARA PROGRAM DESCRIPTION A. Statement of CNS Management Commitment to ALARA Program B. Function and Purpose of ALARA Program C. Scope of ALARA Program 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 ALARA 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

B. Procedural Reviews 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 Term 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 2

F I. ALARA PROGRAM DESCRIPTION A. Statement of Commitment of CNS (NPPD) Management to the ALARA 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 ALARA program specifically developed for that item may be substituted.

D. Goals of the ALARA Program At CNS 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 This index will list major topics in alphabetical order covered in the ALARA Procedures and pro-vide the section number where the topic is discus-sed.

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• II. ALARA ORGANIZATION AND MANAGEMENT SYSTEM A. ALARA Job Responsibilities This section will provide the ALARA job descriptions for specific CNS personnel directly involved or responsible for the CNS ALARA program.

The job descriptions listed in this procedure are in addition to their regular responsibilities. The job titles that will have specific ALARA 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 Sdrvices 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 CNS departments and the ALARA Committee and to identify formalized lines of communication between CNS departments for ALARA? concerns. Text will accompany the chart to help explain-the connections between job titles.

C. ALARA Committee A permanent ALARA Committec will be created with this revision to the CNS ALARA Program. This section will describe the primary responsibilities of the ALARA Committee.

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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 ALARA 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 ALARA Committee's attention by the ALARA Coordinator.

f. Perform post job reviews on all procedures brought before the Committee's attention.

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3. ALARA Committee Meeting Frequency ALARA Committee shall meet at least on a quarterly basis during normal plant operation. During outages, the ALARA Committee shall meet at a frequency determined by the ALARA 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 7

• Chairman of Committee

• • Co-chairman of Committee The preceding personnel will make up the base ALARA 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.).

l The Chairman of the ALARA Committee shall be l vested with the authority to make all final decisions relating to matters that come up before the Committee. Any disagreements made by other CNS Staff Managers of the ALARA 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 ALARA Coordinator. After reviewing the job, the ALARA Coordinator will determine if an ALARA 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 ALARA Coordinator will attach the appropriate ALARA Job Review Checklist with the man-Rem estimate and dose tracking job code recorded on it. Copies of l the ALARA Job review checklist for that job will remain with the Work Item and the Special Work Permit until completion of the work.

Jobs will be reviewed for ALARA considerations based on the ALARA Coordinator's Man-Rem estimate.

As the exposure estimate increases, so does the severity of the ALARA review. The following divisions describe the increasing severity of the Pre-Job Reviews.

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. o Jobs with Estimates less than 0.5 Man-Rem No ALARA Review Req'd 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. Hcwever, the ALARA coordinator has the option to subject a job with less than 0.5 man-Rem to an ALARA 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 Lead Health Physics Technician. Any special ALARA considerations for that job will be written by the Lead HP Technician en the ALARA job review checklist. The original ALARA Job Review checklist will be returned to the ALARA 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 If the ALARA Coordinator assigns a Man-Rem estimate between 1 and 5 Man-Rem, the Work Request will be sent to the 1st level Job Supervisor (foreman) along with an ALARA checklist. The 10

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 ALARA 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 Lead HP Technician who will use the checklists to help write up the SWP. The ALARA Coordinator will keep the approved checklists.

Option 2- If the ALARA Coordinator is dissatisfied with the Job Supervisor's responses, the ALARA 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 ALARA 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 to the Lead HP Technician so ALARA 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 ALARA checklists will remain with the Work Request and 11

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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 ALARA 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 ALARA review process will be implemented. Once the ALARA 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 ALARA 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 Coordinator should have an informal meeting at this point to discuss the job and the completed AL. IRA checklists if either party feels it is necessary. Any disagreements between the Job Supervisor and the ALARA Coordinator will be 12

0- y resolved in the manner described for the 1-5

, Man-Rom jobs.

l . Once accepted by the ALARA Coordinator, the i

Work Request- and copies of the completed ALARA checklist should be distributed to the ALARA committee members for review. An ALARA

, Committee meeting shall be called by the ALARA I Committee chairman if the regularly scheduled ALARA meeting is not at a convenient time.

The job supervisor should attend the ALARA Committee meeting to discuss the job with the committee members. ALARA Committee j recommendations shall be included on the ALARA l checklist. After revising the checklists based l on the Committee's recommendations, the ALARA f Coordinator, Job Supervisor and ALARA Committee chairman shall sign the ALARA checklists, agreeing to the conditions on the i

checklists. Copies of the approved checklists should be forwarded to the lead HP Technician so the SWP can be written. As before, the original l ALARA checklists will be filed by the ALARA i j

Coordinator in the Job File.

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2. In-Progress Job Review i

l 1 The ALARA Coordinator shall keep a list of all f active jobs that have undergone ALARA reviews. At 4

his discretion, the ALARA Coordinator will perform random inspections of jobs in progress. During I

inspection, the ALARA Coordinator will verify that j 13 l

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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 ALARA 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 ALARA Coordinator has the authority to stop the work.

If a greater than 5 Man-Rem job is in progress during a regularly scheduled ALARA meeting, the ALARA 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 lead Health Physics Technician. Any  :

problems encountered during the progress of the '

job should be written on the checklist by the lead Health Physics Technician or HP Technician that covered job. The completed checklist should 14

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l 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 ALARA Coordinator. Once the job is completed, the job supervisor shall complete the questions in the post job review section of the ALARA checklist and return the form to the ALARA Coordinator. Any additional comments by the ALARA Coordinator shall be written on the ALARA checklist at this time.

Also, any lessons learned that could be utilized for future jobs should also be included. If re-quired, the Job Supervisor should be interviewed by the ALARA Coordinator'for more information.

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-Bem Post jobs review forms will be filled out by the Job Supervisor and the ALARA 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 -

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job file. A complete account of the job will be l presented to the ALARA 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 i 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 ALARA Coordinator is not available. For Emergency Work Requests, a formalized pre-Job ALARA re-view can be bypassed, but a post job ALARA 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 ALARA Coordinator prior to initiation of work. A Manhour estimate shall be written on the P.M. card prior to ALARA review. The ALARA 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 Manager may include a detailed serial review by sign 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 for review, the ALARA Coordinator will fill out a procedure review checklist to assist him in the review. At this time, the ALARA Coordinator will assign a job code to the procedure. In addition, the ALARA Coordinator shall make appropriate ALARA comments on the procedure. During the ALARA review, the originator of a procedure may be interviewed by the ALARA 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

procedure to incorporate the ALARA Coordinator's comments. It is the Radiological Manager's responsibility to insure that the ALARA Coordinators comments are incorporated into the approved procedure.

A copy of the ALARA Procedure Review checklist will stay with the procedure cover sheet.

The Original ALARA Procedure review checklist will be filed by the ALARA Coordinator in the job file.

When the procedure is ready to be initiated, the ALARA Coordinator shall forward a copy of the Procedure Review Checklist to the Lead Health Physics Technician to assist him in writing the SWP.

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 changes, a greater ALARA impact can be made if items such as equipment placement, actual design, and ease of access problems can be addressed early in the design l change process. Obviously, once the design change is written, it may be too late to implement significant exposure saving ideas. The ALARA checklist for design changes and equipment specification changes will emphasize long term dose reduction questions.

The ALARA checklist for design changes and equipment specification changes shall be completed when Attachment D of CNS Procedure 3.4 is filled out by i the Design Engineer. The questions in the l

checklist for the design engineer will determine if an i

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. o ALARA review is required. If required, then the Design Change shall be forwarded to the ALARA Coordinator for review. Using the ALARA review checklist as a guide, the ALARA Coordinator will make comments on the design change and submit his recommendationn to the design engineer on the Design Change ALARA checklist. The ALARA Coordinator, at his option, may ask other personnel in the Chemistry /

Health Physics Department to assist in the design change review. A copy of the Design Change ALARA Checklist shall 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 CNS ALARA 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 ALARA Coordinator will either reject or accept the idea. If the idea is rejected, a written memo to the suggester or an informal meeting with the suggester will be 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 consideration, he will forward the suggestion to ALARA Committee Members. At the next scheduled ALARA l Committee meeting, the suggestion will be brought up I for discussion. The ALARA Committee will have four 19 l

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• & s options on all ALARA suggestions brought to their attention:

a. Approve the suggestion without modification.

b. Modify the suggestion and approve it.

c. Forward the suggestion to the appropriate personnel for further study.

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 sent to the suggester explaining the reasons for rejection.

All suggestions requiring further study, will be

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arought up at future ALARA Meetings until the suggestion is approved or rejected by the ALARA Committee.

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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 ALARA Job Code # shall be entered by personnel on the SWP log sheet upon entry into the SWP work area. Job codes should only be used once. The Job Supervisor / Foreman is responsible for insuring that the Job Codes are entered on the appropriate SWP log.

Files for all jobs will be maintained by the ALARA Coordinator. As the jobs progress, the job file should e

become an archive file for any information relating to that job. For example, other data that would prove useful would be copies of the job's ALARA review checklists, survey maps, copies of SWP's, lessons l

learned and notes made by the ALARA Coordinator 21 f

E - - _ - - - - - - - - - _ - - - - - - --

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4 a e 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 SWP 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.

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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 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 23

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s o estimates greater than 5 Man-Rem, then daily reports will not be required.

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2. Long Term Reports 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 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 ALARA Committee at its regularly scheduled meeting. If an outage is in progress or has occurred in the reported quarter, then the results 4

of the outage should be included in this report.

Based on the discussion at the ALARA Committee meeting, the quarterly report will be revised to

reflect any action that will be taken on proolem I 24 i

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s 3 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 ALARA 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 ALARA program itself. As with the quarte-rly reports, the ALARA Coordinator will present the annual report to the ALARA Committee for discussion. An ALARA Committee approved annual report will be submitted to the Division Manager of Nuclear Operations.

3. Trending Reports When requested by the ALARA Committee Chairman, the ALARA Coordinator will be respon-sible for generating graphs and charts detailing exposure trending patterns incurred at CNS. )

Exposure trending reports will be required on at 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 l

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. . e ten in a report format and submitted to the Division Manager of Nuclear Operations for his and NPPD Management approval. These goals will be very broad in scope and will establish exposure r

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 ALARA 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 ALARA goals report to the ALARA Committee members for revicw and comments. The ALARA Coordinator will revise the report based on the comments re-ceived and resubmit the report to the ALARA Committee members. A special meeting of the ALARA Committee will be called at this time to approve the ALARA goals report. Once approved by the ALARA Committee, the report will be sent to the DMNO for final review and approval by NPPD Management. Department Exposure Gorfs 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.

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s u Once the Annual ALARA Goals are approved, each j ALARA Committee member who holds a Supervisor 4

position will be responsible for insuring his department meets its approved ALARA goals for the year. The ALARA Coordinator will work closely with CNS managers and supervisors throughout the year to increase management awareness of the ALARA Program and to assist the Department Supervisors in meeting the established ALARA Goals.

5. Outage Goals Report Prior to scheduled outages, the ALARA Coor-dinator will be responsible for submitting an ALARA 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 ALARA for those jobs.

b. Generate Man-Rem estimates for those major jobs and for the entire outage.

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6. Distribution of Reports Daily and Weekly Exposure Reports Division Manager of Nuclear Operations Job Foreman Responsible Dept Supervisor 27 l

l ALARA Coordinator J Chem /HP Supervisor All CNS Department Managers Quarterly Exposure Report Division Manager of Nuclear Operations ALARA Committee Members All CNS Department Managers Annual Exposure Report. ALARA Goals Report and Outace Goals Report Division Manager of Nuclear Operations ALARA 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 CNS 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-ment. Findings will be corrected as soon as possible.

The ALARA Coordinator will be responsible for correc-ting audit findings.

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. w 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 D. Operations E. Engineering / Design F. Quality Assurance / Quality Control G. General Employee / Visitor The ALARA 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 ALARA 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 ALARA Coordinator shall periodically review the ALARA Training Programs to insure that are consi-29 l

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.s- w stent with the latest revision of the CNS ALARA Program.

Details of the training program are covered in the Training Department Instructions.

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, w- e VII. DOCUMENT CONTROL The ALARA Coordinator will be responsible for setting up and maintaining the job files necessary to permit access to ALARA related information. Job files should be maintained in a permanent file either by the ALARA 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 ALARA reports shall be main-tained permanently in accordance with CNS Document Control Procedure. 1.9 31 l

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