B12777, Forwards Addl Info for 861222 Amend Request for 40-yr Ol,Per NRC 871210 Request.Extent & Effectiveness of Util ALARA Programs at Other Plants Evident When Reviewing Encl Chronology Program & Achievements to Date
| ML20237D311 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/18/1987 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| B12777, TAC-64245, NUDOCS 8712230181 | |
| Download: ML20237D311 (148) | |
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NORTHEAST UTILITIES o nerai Orvices . seiden street, seriin. Connecticut n tw1,cm<,.a . %.a cow.e e.m.saca.unnarmc cow =* P.O. BOX 270 am ..n. m a ce*** HARTFORD, CONNECTICUT 06141-0270 L & j ((((((L(( (203) 665-5000 December 18,1987 Docket No. 50-336 i
B12777 Re: 10CFR50.51
) U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 Additional Information for Forty-Year Operating License Amendment By letter dated December 22, 1986,(1) Northeast Nuclear Energy Company (NNECO) requested an amendment to the Millstone Unit No. 2 Facility Operating k License in order to extend the duration of the license to 40 years from the date ,
l of issuance of the operating license. 1 On December 10, 1987, the NRC Staff, NNECO, and the Connecticut Yankee Atomic Power Company met to discuss questions that the Staff had raised on worker radiation exposure. These questigns were submitted to NNECO with the meeting notice dated December 2,1987.t2) As requested by the NRC Staff at !
the December 10 meeting, NNECO hereby formally submits the responses to these questions (Attachment 1) and the material that was presented at this meeting (Attachment 2).
The extent and effectiveness of the Northeast Utilities (NU) As Low As Reasonable Achievable (ALARA) programs at the Millstone Nuclear Power Station and the Haddam Neck Plant is evident when reviewing the chronology of the program and the achievements to date. (See page 6, Attachment 2.) It should be noted that NU was one of the first utilities to implement a computerized exposure tracking system that tracks exposure by system component and job. NU has expended significant resources, utilizing state-of-f (1) E. 3. Mroczka letter to A. C. Thadani, " Millstone Nuclear Power Station, Unit No. 2, Proposed Amendment to Facility Operating License, Extension l of Facility Operating License," dated December 22,1986.
(2) David H. Jaffe memorandum to John F. Stolz," Forthcoming Meeting with Northeast Utilities (NU) on Forty-Year Operating Licenses," dated December 2,1987. of
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U.S. Nuclear Regulatory Commission B12777/Page 2 December 18,1987 the-art technology to reduce man-rem. Examples of these are the use of robotics in steam generator tube plugging and sleeving since 1983 at Millstone Unit No. 2 that resulted in major man-rem savings; the use of chemical decontamination in steam generator channel heads at Millstone Unit No. 2 in 1983, 1985, 1986; the utilization of channel head decontamination at Haddam Neck in 1986; mock-up training for steam generator work and reactor coolant pump work, etc., has been in place since 1982; and the use of chemical decontamination on Millstone Unit No. I recirculation system piping in 1985; and both recirculation and reactor water clean-up system piping in 1987.
A radiation exposure study was completed in December 1984 that compared NU's plants. to like plants with exposures equal to or better than industry averages.
This study (copy provided to NRC at December 10, 1987 meeting) identified areas of improvement in the ALARA program and set the stage for a change in direction. Major management initiatives were instituted in 1985-1986. The first initiative was the utilization of $20,000 per man-rem in decision-making processes in place of the previous $1,000 per man-rem. An Exposure Reduction Program was developed in 1986 and approved for initiation in December of 1986.
This is a two-pronged program, the first prong dealing with the utilization of three-year average goals and annual ALARA budgets, similu to cash budgets.
The second prong is a number of exposure reduction initiatives that would enable NU to achieve the three-year average goals that make our exposures comparable to like plants by 1990. This program is described below.
The Exposure Reduction Program is identified on page 12 of Attachment 2. The intent was to achieve a major culture change by identifying that worker exposure reduction is the same as reducing risk to public health and safety; ALARA is mandatory; exposure reduction is an integral part of design, installation, and maintenance; and exposure reduction is everyone's job, not just that of Health Physics. The intent of the exposure reduction initiatives is to reduce rad-area work, to increase rad-worker efficiency, and to reduce area dose rates. The short-term and long-term initiatives that were developed are described in greater detail in the response to Question 5 in Attachment 1. The man-rem goals process was revised and implemented in 1987. Three-year average goals for the 1987-88-89 time period were established. These are as follows:
Millstone Unit No. 1 - 484 man-rem; Millstone Unit No. 2 - 585 man-rem; Haddam Neck - 629 man-rem; and Millstone Unit No. 3 - 252 man-rem. These three-year averages will be revised on an annual basis as plants improve their performance. In addi: ion to the three-year average goals, we have established a process of setting up an outage exposure goal,30 to 60 days prior to the start of the outage. This requires that all outage work be identified early in the process l and a man-rem estimate be established sufficiently in advance to allow ALARA controls to be implemented. During outages, plant management reviews the occupational exposures daily. The three-year cycle of planning has been a major breakthrough in identifying man-rem jobs early and evaluating their need and scope.
The man-rem history of NU is provided on pages 8 and 10 of Attachment 2.
When the annual man-rem is plotted (page 8), a typical saw-tooth curve is observed that is characteristic of plants that have major outages in a year
U.S. Nuclear Regulatory Commission B12777/Page 3 December 18,1987 followed by a non-outage year. The data, when presented in this fashion, does not allow one to observe any major trend. Observe that when the total NU exposure, designated by the letter 'N', is plotted, there is an overall trend downwards from 1979 through 1986-87 and beyond. The data beyond 1987 is estimated. It is also important to recognize that the NU exposure total rises a little in 1989 as a result of a.'! four units being in an outage.
A better way to trend this data is to look at three-year averages, which is done on page 9, Attachment 2. It is clear from this data that downward trends are present for all four units. For example, for Millstone Unit No.1, there is a major reduction in man-rem starting in the 1981-83 time frame, and for Millstone Unit No. 2, the reduction is obvious in the 1984-86 time frame. In recent years, Millstone Unit No. I has been one of the BWRs in the U.S.A. with the lowest man-rems. In the case of Haddam Neck, the reduction is anticipated to occur in the 1986-88 time frame and into the future. This curve also shows the three-year average 1990 goals that have been set for the four units. These goals were set in the middle of 1986 and will be revised downwards especially for Millstone Unit No. 1. The 1990 three-year average goals are as follows:
Millstone Unit No.1 - 580 man-rem; Millstone Unit No. 2 and Connecticut Yankee - 525 man-rem; Millstone Unit No. 3 - 250 man-rem. These are our targets for 1990 and beyond. They will be revised based upon our experiences in the 1987-89 time frame. Based on the utilization of three-year averages for the 1987 through 1988 time period, our experiences to date have shown that the man-rem totals are decreasing.
NU has expended significant resources to reduce exposures at our sites. This is not immediately evident when looking only at the annual exposure totals, however, collected information, shown on pages 57-61, Attachment 2, and on pages 1-6, Attachment 3, shows the significant amount of exposures that have ;
been avoided through our ALARA programs. Many of the state-of-the-art techniques used by NU since the early 1980s have resulted in the savings of l thousands of man-rem at our sites. In the case of Mi!1 stone Unit No. 2, some examples are provided on page 57, Attachment 2. In particular, the use of chemical decontamination of the steam generator channel heads and loop area shielding for steam generator work has resulted in 1,400 man-rem savings during i the 1985 outage and about 130 man-rem during the 1986 outage. A similar view is obtained when you view the data for the Haddam Neck facility and identify that hundreds of man-rem were avoided in every outage from 1980 through 1987.
In the case of Millstone Unit No.1,1,300 man-rem were avoided in the 1984 outage, primarily as a result of chemical decontamination of the recirculation system. These are all significant examples of man-rem savings, in summary, NU believes that its ALARA programs are effective and will become more effective in time.
We trust that this information will enable the NRC Staff to complete their review and prepare a favorable safety evaluation and thereby issue the Millstone Unit No. 2 Forty-Year Operating License Amendment in December 1987.
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U.S. Nuclear Regulatory Commission
' B12777/Page 4 December 18,1987 Please contact us if you have any questions.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY 4 fu ,
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Sen' Vice President cc: W. T. Russell, Region 1 Administrator D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 W. 3. Raymond, Senior Resident Inspector, Millstone Unit Nos.1,2, and 3 l
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Docket No. 50-336 B12777 s
Attachment 1 Millstone Nuclear Power Station, Unit No. 2 Additional Information for Forty-Year Operating License Extension December 1987 ;
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l o U. S. Nuclear Regulatory Commission I Bi2777/Page 2 December 18,1987 1
MILLSTONE UNIT 2 LICENSE EXTENSION:
Question No.1 l
In ~ Ref.1. p. I Northeast Nuclear Energy Company (NNECO) very briefly described the plant activities which have contributed to high annual doses at Millstone Unit 2 for six of the last nine years. The staff notes, however,
.that Millstone Unit 2 has one of the highest cumulative average exposures of any operating pressurized water reactor (PWR) in the- United States, in addition, the average exposure for the three most recent years (i.e.,1984 -
1986) has remained relatively high. Given the magnitude and persistency of these exposures, the staff requests that NNECO provide a more detailed breakdown of the annual occupational exposures for Millstone Unit 2 for every year from 1978 to the present. As part of this breakdown, NNECO l should identify and describe, to the extent feasible, every job performed during this period in which more than 10 person-rems were expended (similar
. to Table 8 of Reference 2). NNECO should provide its definition of "special maintenance" work and, for each job listed, should state whether this work was classified as being a special maintenance job.
No.1 Reply NNECO's chronology of achievements in the ALARA area were described in the cover letter. However, a detailed breakdown of the annual occupational exposures from jobs that expended more than 10 man-rem for Millstone Unit No. 2 for every year from 1980 to the present is given on pages 41-45 of Attachment 2.
The breakdown of occupational exposures for 1978 and 1979 is not given because the computerized exposure tracking by system and job component which allows for a detailed breakdown of exposures, was not instituted until 1979.
The definition of special maintenance work has been changed through the years as is evidenced by the variety of jobs that have been classified as special maintenance as shown on pages 41-45, Attachment 2. However, in general, special maintenance work is defined as any non-routine work.
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i U. S. Nuclear Regulatory Commission B12777/Page 3 !
December 18,1987 Question No. 2 For those jobs described on the previous page that are of a repetitious nature,
- a. Provide a table listing each of these jobs along with the corresponding exposures expended for each of the years from 1978 to present (similar in format to the table on Page 5 of the 1986 Refueling and Maintenance Outage ALARA Report),
- b. Describe the measures that NNECO has taken to eliminate or reduce the frequency of performing these jobs, or parts of these jobs;
- c. Describe the measures that NNECO has taken to reduce exposures received from performing these jobs. For those jobs listed where the yearly exposures have increased or remained the same over the last several years, describe why efforts have been unsuccessful in reducing exposures related to these jobs.
- d. If these jobs are being performed on the same or similar equipment or components, identify the components, the nature of the work (repair, maintenance, or replacement), and what is being done to avoid repetition.
No. 2 Reply
- a. Jobs of a repetitious nature along with the corresponding exposures for each of the years from 1980 to present include refueling, inservice inspection (ISI), reactor coolant pump (RCP) seal repairs and steam generator repairs. These are listed along with their corresponding exposures on pages 46-49 of Attachment 2.
- b. NNECO has taken the following measures to eliminate or reduce the frequency of performing these jobs:
o Refueling - As of Cycle 10, the operational cycle will be extended to 18 months.
o RCP Seal Repairs - NNECO is taking the following actions regarding RCP seal repairs:
Performing one possible seal change-out per outage and 3 motor preventative maintenance, Evaluating an upgraded seal package, i 1
Evaluating shortening the RCP motor shaft to make seal removal and installation easier, and l l
Upgrading seal handling devices. !
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o S/G Repairs - Please see our response to question 3. 4 s n in addition, NNECOs intends to more equally distribute '
thejnservice inspection over the 10 year period. Yg 1/ ,
- c. .The measures that NNECO has taken to reduce expc gres received from l 1hese repetitive jobs are described on, pages 46-50, <
Attachment 2. Most of our efforts to (educe exposures have been ,.'
succeshal as is shown on pages 57-6 $ Attachment 2, and' pages 1-6, !
Attachment 3. However, a descriptkn' of why certa:r,bfforts have i been unsuccessful in reducing exposures related to the ' jobs where ,
yearly exposures have increased or ren'alned the same over the last s several years it, given in the outage ALARA reports which were[_
provided to the NRC Staff at the December 10,1987 meeting, a y
- d. .NNECO utilizes a plant maintenance management system (PMMS) to determine which jobs are being performed on the same or similar ,
equipment or components each year. Recommendations and corrective actions are taken as a result of that review to reduce- N radiation exposure. The measures that are being implemented to 'Y' reduce the RCP seal repain were initiated through this process.
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U. S. Nuclear Regulatory Commission B12777/Page 5 December 18,1987 Question No. 3 )
In Ref.1, p.1 NNECO stated that: "In all the aforementioned years ,1978, 1980,1982,1983,1985, and 1986), except 1980, steam generator inspection and. repair projects were the primary contributor to exposure above PWR averages." It appears that steam generator related work has been a recurrent problem at Millstone Unit 2. Describe the steps that NNECO has taken over the preceding years to prevent these relatively high exposures from steam generator inspections and repair projects. Specifically, provide the following information:
- a. Identify and describe the steps that NNECO has taken to reduce exposures (e.g., use of automation, robotics, etc.) during steam generator. Inspection and repair projects. Note the time periods in which these steps were taken and describe their degree of success in reducing exposures. Describe what further steps NNECO plans to take to reduce steam generator work related exposures,
- b. Identify and describe NNECO's efforts to lower dose rates (e.g., through decontamination and/or shielding)in and around steam generators prior to maintenance. Describe the success of these efforts in reducing area dose rates.
- c. In the 1986 Annual Exposure Report, NNECO states that since the 1981-82 refueling outage, approximately 65% of the refueling outage exposures has been due to steam generator work, in 1986, steam generator work accounted for only 40.8% of the outage exposure. By eliminating or minimizing the amount of steam generator related work performed during outages, NNECO will have made a big step in realizing their outage year exposure goal of 500 person-rems. Assuming that their outage year exposure goal of 500 person-rems. Assuming that Millstone Unit 2 does not replace its current steam generators during the next five year period, provide an estimate of what percentage of the annual exposure will be due to steam generator related work at Millstone Unit 2 over each of the next five years.
Identify and describe the steps that NNECO has taken to minimize the j need for steam generator repairs. For example, describe any changes in water chemistry control made to minimize steam generator tube corrosion. Have condenser tube leaks contributed to degradation of the steam generator tubes, and, if so, what has been done to alleviate this problem?
- d. Describe NNECO's plans and time schedule to replace the steam generators at Millstone Unit 2. Describe what steps will be taken to I ensure that NNECO will not have the same recurring problems with the new steam generators.
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- e. State what job < other than steam generator related work are large contributors to the annual dose at Millstone Unit 2 on a repetitive basis.
What efforts hsve been made to minimize the exposures related to these jobs. ,
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U. S. Nuclear Regulatory Commission B12777/Page 6 December 18,1987 No. 3 Reply
- a. NNECO has specifically used the following to reduce exposures:
Automation Robotics Mock-up Training Video Taping Probe Entry Data Acquisition Outside Containment Analyst Training The above inspection practices are periodically reassessed in order to incorporate appropriate changes in inspection technology. . The time periods in which the above practices were taken and the degree of their success is detailed on pages 49 and 50, Attachment 2.
Future practices that NNECO intends on utilizing are listed on page 27, Attachment 2.
- b. As identified on pages 15,17,18, 26, 28, 49 and 50, Attachment 2, NNECO has effectively used shielding and inspection practices, multiple chemical decontamination and substantial chemistry improvements to lower man-rem exposure. The success of these efforts is detailed on page 57.
- c. NNECO has estimated the number of steam generator tube repairs that will be necessary during the next five fuel cycles (see page 29, Attachment 2). . Based on experience, it is estimated that the total steam generator man-rem in 1983 and 1989 will be significantly less than that in previous years. The percentage of the annual exposure that will be due to steam generator related work at Millstone Unit No. 2 over the next two years is shown on page 39, Attachment 2 and is estimated to remain approximately 45% of the total occupational exposure. In an effort to minimize the need for steam generator repairs, NNECO has undertaken replacement of all the feedwater heat exchanger and condenser tubes, and has instituted additional primary and secondary water chemistry controls. These chemistry controls are detailed on pages 15,19-25, and 28, Attachment 2. In addition to efforts that NNECO has already undertaken, the on-going efforts listed on page 17-18, Attachment 2 are expected to further support improvements that would minimize the need for future steam generator repairs.
- d. NNECO presently does not plan to replace the Millstone Unit No. 2 steam generators. Although the present steam generators have suffered from a variety of corrosion processes, current chemistry and material related counter measures are expected to significantly reduce the amount of future repairs. Lased on this, value-impact studies indicate that continued periodic repairs are preferable to a single radiation exposure intensive (1,400 man-rem) owage. However, since
- 4 U. S. Nuclear Regulatory Commission B12777/Page 7 i December 18,1987 unexpected problems could force replacement, NNECO is ordering l; replacement steam generators. By having these steam generators l available, NNECO is protecting against excessive forced outages in the L event new concerns necessitate . future replacement of the current l steam generators.
I NNECO is evaluating the design considerations listed on page 30, Attachment 2 to ensure that the new steam generators are not subject to the same design problems as the present steam generators,
- e. Please see our reply to question 2.
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'U. S'. Nuclear Regulatory Commission B12777/Page 8 December 18,1987
_ Question No. 4
,. In Ref.1, p.2, NNECO stated that: "Our exposure goal of less than 500 I man-rem per year includes steam generator work." However, a time frame L was not. given for. attaining this goal. Provide NNECO's time frame for meeting this goal, and describe the specific steps that NNECO will take tu reduce exposures at Millstone Unit 2 to 500 person-rems per. year or less.
' Assuming that this annual goal of 500 person-rems is for an outage year, ll state what the non-outage year annual exposure goal is. Describe how you
! plan to implement these exposure goals by assigning individual exposure goals to the various departments at Millstone Unit 2. Describe how you plan to enforce these exposure goals and what steps you plan to take when these goals are exceeded.
No. 4 Reply The Northeast Utilities exposure goal process was revised in 1987 from a "per year" to a "3-year average" process as is discussed in the cover letter. It is important to recognize that the utilization of the 3-year averages enables a planning cycle that is effective in reducing man-rem by more up front identification of high man-rem jobs and better planning. The 3-year average goal for Millstone Unit No. 2 for the 1987 through 1989 time period has been set at 585 man-rem. The 1990s and beyond 3-year average goal for Millstone Unit No. 2 has been set at 525 man-rem. Our experience to date with the Exposure Reduction Program has indicated that it is very likely that these goals will be met.
The 3-year exposure goal is approved by the Senior Vice President, Nuclear Engineering and Operations and then assigned through line function management to the Millstone Unit No. 2 Superintendent as part of the overall Management Planning and Performance Evaluation Program (MPPR). This is the Northeast Utilities version of management by objectives (MBO). The Vice President of Nuclear Operations has established a process that ensures that the 3-year average goal will be met. This process includes an annual man-rem budget similar to a cash budget and a 2-year forecast. The man-rem budget for 1987 for Millstone Unit No. 2 was assigned to the Unit Superintendent as part of his MPPR goal. The Unit Superintendent in turn apportions the annual man-rem budget by department and these become part of the department heads MPPR goal process. Awareness of these goals occur through accountability processes established by management. In addition, ALARA goals are posted and progress is tracked on a daily basis. A number of examples were presented at the December 10, 1987 meeting. The Unit Superintendent cannot exceed the assigned annual goal bdget without prior approval from the Vice President of Nuclear Operations. In addition, if it is determined that exceeding the annual budget would cause the 3-year average to be exceeded, a variance has to be approved by the Senior Vice President of Nuclear Operations. This process ensures that significant resources would be expended in finding alternatives to proposing the variance.
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U. S. Nuclear Regulatory Commission B12777/Page 9 December 18,1987 Question No. 5 In Ref.1, p. 3, NNECO stated that: "NNECO is taking an aggressive stand for the ALARA philosophy," and that the " Exposure Reduction Initiative Program is a major effort on the part of NNECO" to reduce person-rems.
Although the " Exposure Reduction Initiatives" are listed on p. 4 of Ref.1, these initiatives are not described in enough detail for the staff to reach a favorable conclusion. Describe each of the initiatives in more detail. In particular, describe the scope, expected results (e.g., expected person-rem savings), schedules, costs, level of effort, and how these initiatives are expected to contribute towards the exposure goal (s) for Millstone Unit 2 (i.e., NNECO's response to Question #4 of Ref.1).
No. 5 Reply The second prong of the two pronged Exposure Reduction Program described in the cover letter (3-Year Average Goals being the first prong) initiated in September 1986 is the Exposure Reduction Initiatives (ERI). The purpose of the initiatives is to reduce work in radiation areas, reduce area dose rates, and increase work efficiency. These were identified in the 1984 Northeast Utilities Radiation Exposure Study, (provided to the NRC Staff at the December 10,1987 meeting) as being the three (3) issues to address.
The ERI Action Plan first requires a satisfactory evaluation of the feasibility and cost-effectiveness before the ERIs can be implemented. A good example is the Short Term ERI GEZIP at Millstone Unit No.1. An initial evaluation of impact on Millstone Unit No. I specific plant materials, nuclear fuel, etc., was conducted prior to proceeding with implementation during 1987.
The attached tables list the short-term and long-term ERIs. Short-term means that exposure reduction can be obtained during the 1987-1988 outages. Long-term means that exposure reduction will be observed in 1990 or shortly thereafter because of the time required for implementation. However, short-term actions are necessary to initiate implementation of these long-term initiatives.
I Most of the short-term initiatives can be immediately implemented, however, some of the short-term initiatives and most of the long-term initiatives need feasibility and cost benefit evaluations prior to implementation.
The feasibility of attaining the 1990 and beyond 3-year average goal through implementation of ERIs has been qualitatively evaluated. In the case of Haddam I Neck and Millstone Unit No. 2, it appears that it is necessary to evaluate all the j proposed ERIs to enhance the chances of achievement of the 1990 goal. In the l case of Millstone Unit No.1, only the short-term initiatives, if shown to be cost q l beneficial, will be needed to lower exposures to the 1990 goal. In general, !
( because of the overlapping man-rem paybacks and 3-year average goal, an exact l estimate of the man-rem reduction is not possible. However, on an annual basis 1
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U. S. Nuclear Regulatory Commission B12777/Page 10 December 18,1987 as the different ERIs are implemented, a better estimate of their effectiveness in reducing man-rem will be determined.
A brief description of each short-term ERI now follows with a status as of ,
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TABLE 1 EXPOSURE REDUCTION INITIATIVES ,
INITIATIVE # . INITIATIVE TITLE Short-Term Initiatives
. ST # 1 Increase ALARA Awareness- All units ST #2 Job cancellation / scope reduction - All units ST #3 Work practice Review- All units ST #4 - Construction Work efficiency - All units a ST #5 Decontamination - CY, MP-1. MP-2 ST #6 CET Grayloc flanges and reactor head stud tensioners- CY ST #7 Permanent neutron shield - MP-2 ST #8 GEZIP - MP-1 i
ST #9 Snubber reduction - MP-2, MP-3
- ST # 10 ALARA installation reviews - early stage - All units ST #11 Cobalt reduction - All units ST #12 MP-3 project list ST #13 Hydrogen water chemistry - MP-1 Lono-Term Initiatives LT #1 Decontamination improvements- All units LT #2 Longer fuel cycles MP-2, MP-3, CY LT #3 Steam Generator inspection / plugging criteria - CY, MP-2, MP-3 LT #4 Primary chemistry controls - CY, MP-2, MP-3 LT #5 Robotics- All units i
LT #6 Steam generator replacement - MP-2 LT #7 Cobalt material alternatives- All units 1
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12 TABLE 2 SHORT-TERM INITIATIVES ST1 Increase ALARA Awareness All units This initiative is aimed at making the culture change within NE&O through:
- 1. Increasing the awareness of ALARA importance through advertising the overall Exposure Reduction Program's purpose, the 3-Year Average Goals, and the ERis in a special Radworker Training Module
- 2. Utilization of various posters (inspirational / motivational / practical)
- 3. Utilization of more aggressive ALARA walk-throughs
- 4. Special training for construction job supervisors (Company and contractors)in ALARA procedures and concepts
- 5. Emphasizing job supervision accountability.
Status: Completed in 1987 ST2 Job CancellationlScope Reduction AII Units
- 1. Require the man-rem estimate for all projects be made at the conceptual approval stage and again prior to construction budget approval. Question the need for high man-rem jobs through an evaluation process like ISAP (Integrated Safety Assessment Program).
- 2. Provide a firm outage total man-rem goal 30 to 60 days prior to the start of the outage to ensure adequate up-front ALARA planning
- 3. Within the frame of the 3-Year Average Goals for 1987-1989, establish an annual man-rem budget for each unit similar to a cash budget, have it approved by the Sr. VP NEO. This will ensure integrated 3-year planning for plant work. Exceeding the budget requires approval at the Sr. VP level.
Status: Implemented in 1987 ST3 Work Practice Review Unit- All Optimize security rules, fire watches, safety watches, HP coverage, QA inspections, etc., to minimize number of required personnelin area.
Consider sliding / variable requirements depending on dose rates.
Status: Under evaluation
13 ST4 Construction Work Efficiency Unit- All
- 1. Evaluate exposure reduction incentives in contracts.
- 2. Reduction of union jurisdictional requirements for the different crafts in rad areas.
- 3. Use in-house roving construction crew for hot side vs. cold side work.
More experienced, hence more efficient working will result in less total exposure.
- 4. Optimize contractor hiring practice to minimize numbers of contractors on-site at any given time. j Status: Under evaluation STS ChemicalDecontamination Unit - CY, MP-2, MP-1 An evaluation of feasibility and cost benefits is necessary before decision is made on a case-by-case basis.
- 1. MP-1 recirc/ cleanup decon.
- 2. CY and MP-2 channel head decon.
Status: A Decon was done in 1987 for MP-1. Because of the use of robotics and a low projected work scope, a SG Decon was determined not to be cost-effective and was not aerformed in 1987 at CY. A S/G channel head decon has been cetermined to be not cost-effective for MP-2 for the 1988 outage because of reduced workscope and the use of robotics.
ST6 CET Gravloc Flanges & Rx Head Stud Tensioners Unit- CY Initiate necessary work for 1989 installation. Include in budget. Will save about 30 man-rem / outage.
ST7 Permanent Neutron Shield Unit - MP-2 The shield design will be completed in 1989 for installation in that outage.
Will save about 10 man-rem / outage.
ST8 GEZIP Unit - MP-1 The GE Zinc Injection Process to minimize corrosion buildup of cobalt was evaluated and, implemented at MP-1 in 1987.
ST9 Snubber Reduction Unit -MP-2, MP-3 Evaluate reducing the number of required snubbers in order to minimize future inspection / repair man-rem. A significant number of snubbers were l removed at MP-3 in 1987 and more are planned for the next outage. At MP-2, an evaluation is underway and the plan is to gain NRC approvals for a project in the 1990 timeframe.
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14 ST10 ALARA Installa tion Reviews - Early Staae Units- All .;
ALARA installation reviews are currently performed within a few days to weeks that time.of However, actual work performance.
there They should is merit to performing suchcontinue reviews to at be up(dated at least specified questions from the checklist) during the design phase - perhaps 6-12 months prior to the outage. This may key some ALARA ideas that require long lead times, such as decontamination or mock-up construction. It may result in schedular adjustments, better planning, etc. A procedure revision is underway to require this by late 1987, early 1988. However, the process was in effect in 1987.
ST11 Cobalt Reduction Units- All Each unit should implement the EPRI recommended post maintenance cleaning procedures for stellite faced valves. MP-1 has replaced the feedwater reg valve plug with a non-cobalt material in the 1987 outage.
Future required valve replacements should consider non-stellite faced valves.
ST12 MP-3 Project List Unit - MP-3 The MP-3 list of outstanding projects was re-evaluated to increase the priority for ALARA improvement projects. Jobs such as RTD by-pass loop l replacement were put on the list for the 1987 outage.
ST13 Hydrogen Water Chemistry Unit - MP-1 Feasibility testing was done in 1987. Results are being evaluated.
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U. S. Nuclear Regulatory Commission B12777/Page 15 December 18,1987 l Question No. 6 l
l Describe NNECO's criteria for performing ALARA reviews over the time period 1978 through the present. In particular, state NNECO's cutoff exposure above which an ALARA review must be performed. Provide, to the extent feasible, the percentage of jobs receiving ALARA reviews for !
.each of the years 1978 through present. An integral part of any ALARA i review is the post-job review. This review consists of comparing any differences between estimated and actual job exposures, and recommending better ways to perform the task in the future (e.g., use of mockups and testing for operability of equipment prior to initiating the job, use of different equipment, use of shielding, changes to job procedures, erection of permanent staging and/or platforms, use of experienced workers) that wouid result in even lower overall exposures. Describe NNECO's procedures for evaluating and implementing post-job review ALARA recommendations which may result in lower future exposures for performing repetitive jobs.
No. 6 Reply The criteria for performing ALARA review is as follows:
Beginning in 1980 detailed ALARA job reviews were performed for all
. projects estimated to result in greater than 1 man-rem of exposure. In 1985 an analysis was performed that indicated that only 2.4% of the exposure received at the Millstone and Haddam Neck plants (2.0% at Millstone Unit 2) was due to jobs estimated to result between 1 and 5 man-rem. Based on these results, the criteria for performing detailed ALARA Job reviews was revised to greater than 5 man-rem as the large majority of the total exposure is due to jobs estimated at greater than 5 man-rem and department blankets (RWP's for routine activities for which reviews are not performed).
For jobs which are expected to result in greater than 1 but less than 5 man- i rem, a less detailed ALARA review for ALARA controls is performed by a plant Health Physics technician.
1 Concerning the NNECO procedure for implementing the results of post-job ALARA reviews; it is required by procedure that the history of a repetitive job be reviewed when performing the ALARA review for the job. As an additional practice, the major ALARA recommendations made after an I outage are issued by plant management as a controlled routing requiring i plant department response in time to implement any changes in the next outage. In addition a formal response to the recommendations contained in ,
each ALARA outage report is required by station management.
1 3
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U. S. Nuclear Regulatory Commission B12777/Page 16 December 18,1987 Question No. 7 Provide any additional information that NNECO thinks is relevant for the staff to reach a favorable conclusion regarding the license extension at this time, rather than deferring consideration of NNECO's request to allow NNECO additional time to identify root causes of, correct, and reduce occupational exposures at Millstone Unit 2.
No. 7 Reply As was discussed during the Decernber 10, 1987 meeting and in response to previous questions, NNECO has identified the root causes of high occupational exposures at Millstone Unit No. 2 and has been reducing these exposures since 1986 utilizing our new Exposure Reduction Program. Examples of significant occupation exposure savings are provided on pages $7-61, Attachment 2 and pages 1-6, Attachment 3.
As requested by the NRC Staff, Attachment 4 provides a copy of the November 1986 ALARA Program Appraisal. Also attached are status reports dated April 22,1987, June 3,1987 and December 14, 1987 on the actions taken to address the recommendations contained in the appraisal report. It should be noted that the appraisal was conducted in late 1986, just before Northeast Utilities initiated its new three-year average goal process and Exposure Reduction initiatives. As such, some of the finding were overtaken by circumstances and resolution of these findings is still underway.
In addition, as requested the Trend Analysis Report for the Health Physics Audit Results in 1986 is provided as Attachment 5.
NNECO believes that the information provided in this letter and during the December 10,1987 meeting will enable the Staff to reach a favorable conclusion on our pending license extension at this time. We request an expedited review of the pending license amendment which will provide a substantial savings to our ratepayers over the remaining life of the plant, t.
i References
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Docket No. 50-336 B12777 fL Attachment 2 Millstone Nuclear Power Station, Unit No. 2 Additional Information for Forty-Year Opet ating License Extension .-
Decernber 1987
l DOCKET NOS. 50-213 !
L. 50-336 ,
t I
NORTHEAST UTILITIES MILLSTONE NUCLEAR POWER STATION UNIT NO. 2 HADDAM NECK PLANT l
FORTY-YEAR OPERATING LICENSE AMENDMENT n
DECEMBER 10, 1987 i
N. _
j
t q
i i
PURPOSE
- 1. RESPOND T0 NRC STAFF QUESTIONS ON OCCUPATIONAL EXPOSURE AT MILLSTONE UNIT ~NO. 2 AND CONNECTICUT YANKEE,
- 2. REACH A FAVORABLE CONCLUSION TO ALLOW NRC STAFF ISSUANCE ~.0F THE CONNECTICUT YANKEELAND MILLSTONE UNIT NO. 2 FORTY-YEAR LICENSE AMENDMENTS IN DECEMBER 1987.
cf_s - 12/10/87 r .-
- - - - _ _ _ - _ . 1
c ,. .
- a l 1
l NU PARTICIPANTS I
o DR. C. F. SEARS -
VICE PRESIDENT, NUCLEAR AND ENVIRONMENTAL ENGINEERING I
o DR. R. C. RODGERS -
MANAGER, RADIOLOGICAL ASSESSMENT BRANCH o J. W. KLISIEWICZ -
SUPERVISOR, NUCLEAR MATERIALS AND CHEMISTRY o F. R. DACIMO -
SUPERVISOR, MILLSTONE UNIT NO. 2 ENGINEERING o E. A. DEBARBA -
SUPERINTENDENT, HADDAM NECK STATION SERVICES o G. P. VAN N00RDENNEN -
SUPERVISOR, GENERATION FACILITIES LICENSING CFS - 12/10L8Z
. = . .. .
. .. AGENDA
- 1. NU Management - Overview C. F. Sears
- 2. ALARA Overview - Where Are We Now R. C. Rodgers Where AreWe Going Exposure Reduction Plan Exposure Goals / Budgets Station implementation ,
Of Goals F. R. Dacimo
- 3. Exposure Reduction initiatives R. C. Rodgers
- 4. Chemistry and- -
Inspection / Repair J. W. Klisiewicz Material Controls- Decontamination i
Chemistry Primary / Secondary i S/G Replacement !
Exposure Data 1980-1989 R. C. Rodgers
- 5. Greater Than 10 Man-Rem Jobs - MP-2 F. R. Dacimo 6.. Repetitive Jobs - ALARA Data / Efforts F. R. Dacimo/
(Refuel, S/G,151, RCP)
- Station System /Compontent Tracking
Post Job Reviews E. A DeBarba l
- 8. ALARA Screening in ISAP G. P. van Noordennen
- 9. AdditionalInformation on ALARA Savings R. C. Rodgers
- 10. Summary C. F. Sears CFS - 12/10/87
l: .
._4 l
. FORTY-YEAR OPERATING LICENSE AMENDMENTS l REDUCT10N OF-OCCUPAT10NAL EXPOSURE AT NU MANAGEMENT OVERVIEW-o IMPORTANCE o ATlTUDE CHANGES q
l o PHYSICAL CHANGES
.o' EFFECTIVENESS OF ALARA GOALS CFS - 12/10/87
FORTY-YEAR OPERATING LICENSE AMENDMENTS o NU HAS AN EFFECTIVE ALARA PROGRAM o SIGNIFICANT. RESOURCES HAVE BEEN AND ARE BEING APPLIED TO
' CONTINUE TO REDUCE OCCUPATIONAL EXPOSURE o TIMELY APPROVALLOF THE FORTY-YEAR OL AMENDMENT LOWERS COST TO OUR CUSTOMERS i
CFS - 12/10/87
.t
7--
NU ALARA PROGRAM CHRONOLOGY-ACHIEVEMENT e ALARA part of routine operation Since Plant Start-up e Formal ALARA programinitiated 10/77 Mgmt. commitment, cost-benefit, ALARA reviews, etc.
e Computerized exposure tracking by system 1979 component / job e INPO-NU-ALARA Operating Experience Note-8A 9/82 e Robotics in S/G tube plugging / sleeving
-CY 1987
-M P-2 Since1983 e S/G channelhead decon -CY 1986 (Industry First) -M P-2 83/85/86
, o Mock-up training, S/G, RCP, etc. Since 1982 e MP Recirc. piping chemical decon 84/87 e NU Radiation Exposure Study 12/84 e $20,000/- per man-rem. Mgmt. initiative 7/86 e NRC l&E findings in positive 1986-1987 e New Exposure Reduction Program 12/86
- three (3) year average goals, annual budgets
- exposure reduction initiatives e MP-1 GEZIP 1987 i
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- NRC IE Bulletins 79-02 and 2N 14.92 223.160 79-14 (Hangers )
- l
- Special Maintenance Jobs j i
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QUESTION NO.1 MP-2 JOBS GREATER THAN 10 MAN-REM 1983-1984 .- IM Actual AcdIal Manhours M a n~-Rem Refueling 10134.75 77.215
- Steam Generator Eddy 11340.33 355.765 Current Testing (ECT)
- Steam Generator Channel 11175.92 129.760 Head Decontamination
- Steam GeneratorTube 29387.33 572.290 Sleeving
- Steam GeneratorTube 2352.33 61.075 Plugging
*
- Steam GeneratorTube 1621.92 56.665 Repair
- Steam GeneratorTube 982.42 13.020 Radiography
- Steam GeneratorTube 1000.58 26.460 Sample
- Steam Generator Sludge 2291.83 66.785 Lancing
- ThermalShield Removal 57281.33 135.585
- Class 1 In-Service Inspection 2795.42 24.025 (151)
- Class 2 and 3151 1913.00 14.100
* ' Reacotr Coolant Pump Seal 608.25 13.855 Replacement Preventative Maintenance 1565.75 31.160 Miscellaneous Component 1267.58 11.470 Repairs
- RCS RTD Connector Head 2084.33 46.635 Replacement
- Wide Range Nuclear 2582.08 29.640 Instrumentation Mods.
- RCS Loose Parts Monitor 248.92 10.200 System Installation
- Pressurizer Loop 5eals 1885.92 14.545 ,
Replacement i NNECO Personnel Blankets 40125.67 168.525 l Contractor Personnel 4345.33 16.775 Blankets Radwaste Work and 130.17 21.390 Personnel Blankets
- Special Maintenance Jobs i
, [ ., .- l
. Q UESTION NO. {.
MP-2 JOBS GREATER THAN 10 MAN-REM 1985 Job Actual Ac al
- Manhours Man [-Rem l
Refueling . 6796.75 101.535
- Steam GeneratorTube 12924.17 525.520 Sleeving Steam Generator Eddy 4072.17 243.235 Current Testing (ECT)
- Steam Generator Chemical 8645.42 95.680 Cleaning *
- Steam Generator Channel 4060.42 58.080 Head Decontamination
- Steam GeneratorTube 373.17 16.490 '
Sample
- Steam GeneratorTube 156.92 13.145 Plugging
- Steam GeneratorTube 759.09 12.580 Lancing
- Steam GeneratorTube 364.42 12.250 Radiography
- Class 1 In-Service Inspection 4705.00 118.055 (151)
- Corrective Maintenance 5029.42 47.870
- Inadequate Core Cooling 1856.50 38.450 Modification
- Refuel Cavity Drain Line 1067.58 21.410 Hanger Modification Reactor Coolant Pump Seal 405.43 13.595 Replacement
- Preventative Maintenance 732.67 11.170
- Incore InstrumentStalk 610.50 17.595 Repairs Trash & Laundry Pick-up 816.92 12.840 NNECO Personnel Blankets 597.84 52.700
- Special Maintenance Jobs l 1
j j i l l _ _ _ _ _ ---_-- - -- - i
QUESTION NO.1 ;
^
MP-2 JOBS GREATER THAN 10 MAN-REM 1986 Job Actua! Acytal
- Manhours Man Rem Refueling 4034.25 82.220 j
- Steam GeneratorTube 4317.92 137.830
]
Sleeving and Pivging a steam Generator Nozzle 607.00 92.265 I Dam Installation / Removal Steam Generator Eddy' 1020.91 50.235 ,! Current Testing (ECT) Steam Generator Channel 2463.34 47.430 Head Decontamination Steam Generator Sludge 292.83 16.095 Lancing Containment Staging and 7831.67 122.115 Shielding l Class 1 In Service inspection 2305.33 61.285 (151) Corrective Maintenance 2602.58 33.475 Preventative Maintenance 1693.33 31.065
-
- Appendix "R" Modifications 3237.92 23.385 "C" Reactor Coolant Pump 895.84 17.860 (RCP) Motor Replacement RCP Seal Replacement 504.50 15.305 Regen. Heat Exchanger 156.58 10.185 Shield installation L
Component inspections for 843.91 10.090 EEQ Qualifications NNECO Personnel Blankets 1616.75 24.265
- Special Maintenance Jobs 1 ,
l l I l l 1
. - - - ___ -- - _ --- -- _ a
MILLSTONE UNIT 2 EXPOSURE TRENDS FOR REPETITIVEJOBS EXPENDING MORE THAN 10 PERSON-REM Refueling -This job includes reactor disassembly, fuel shuffle and reactor reassembly Year 1980 1981-82 1983 84 1985 1986 Person-Rem 101 84 77 101 82 Exposure Controls 1980
- 1. Worker briefings on radiation conditions and "hotspots"
- 2. Equipment decontamination
- 3. Audio communication equipment
- 4. Localshielding
- 5. Spare tensioner used for training
- 6. Reactor head studs cleaned with machine 1981-82 As above plus:
- 1. New graylock flanges facilitate in Core Instrumentation (ICl)
- 2. More experienced work crew used relative to prior outage 1983-84 As above plus:
1 Reactor Head laydown area shielding, this saved about 8 man-rem 1985 As above plus: '
- 1. An improved shielded cavity drain filter sysem was used ;
i 1986 i As above plus:
- 1. A new cleaner was used for post-refuel stud hole cleaning l
[ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _
-L.-
Reactor' Coolant Pump Seal Repairs Year 1980 1981 82 1983 84 1985 1986 Person Rem 20.7 5.6 13.8 13.6 15.3 Seals 4 1 2 2 3 Exposure Controls 1980
- 1. The RTD connectors were modified to facilitate removal and replacement
- 2. The seals are disassembled under water which provides shielding and eliminates the need for decontamination 1981-82 As above plus:
- 1. New seal cartridge used for training 1983 84
, As above plus:
- 1. Shielding was insta!!ed between the "B" RCP seal area and the pressurizer auxiliary spray line 1985 Asabove 1986 Asabove L
l I
j e, . Class 1 Inservice Inspection 1 Year 1C30 1981-82 1983 84 1985 1986 { Person. Rem 19.9 34.5 24.0 118 61.3 Exposure Controls 1980
- 1. Coordinated 151, where possible, with other jobs to exploit staging and shielding already in place
- 2. Localdecontamination !
1
- 3. CCTV was used for reactor vessel 151 l 1
1981-82
.l As above plus:
- 1. Hi-jackers and ladders used instead of staging where possible
- 2. Local shielding used where possible 1983 84 As above plus:
- 1. Used automated ISI equipment on the reactor vessel 1985 As above plus: 1
- 1. RCS piping was prepared and inspected with water level above the centerline. l This saved about 6 person-rem ;
- 2. A new RCP rotating device allowed inspection of the flywheel without having to j remove the spool piece coupling the pump and motor 1986 {
As above plus:
- 1. Master-slave ultrasonic testing equipment was tried but did not work well )
1 l { L __ - - - -
_ _ _ = ._ _ _ - - _ _ _ _ _ _49_ - Steam Generator inspection & Repair This job includes manway removal and replacement, nozzle dam installation and removal, decontamination, eddy current testing, tube plugging, sleeving and sampling (i.e. tube pulls), radiography and sludge Iancing. 1980 1981-82 1983-84 1985 1986 ECT 49.3 154.5 147.9 197.5 50.2 Nozzle Dams - 296(1) 207.9 45.6 92.3 Decontamination - - 129.8 58.1 47.4 Tube Plugging 8 584.2 61.1 13.1 137.8 Sleeving - - 572.3 525.5 - Plug Repair - - 56.7 - - Radiography - - 13.0 13 7.5 Tube Sample - 55.7 26.4 16.5 - l : Sludge Lancing - - 66.8 13 16.1 l Chem. Cleaning - - - 96 - l Sec. Side Inspec. 6 7 8 - - l Total 63 1098 1289 1026 351.3 (1) Initial Modification Exposure Controls 1980
- 1. Used manway cover shield
- 2. Had alljumpers mockup trained
- 3. ECT controls set up in low dose rate area 1981-82 As above plus:
- 1. Manway diaphragms were shielded l
- 2. CCTV used for remote observation '
- 3. Shielded waiting areas were constructed. These saved about 40 person-rem 1983 84 As above plus: )
- 1. The channel heads were chemically decontaminated (DF = 3). Exposure savings are estimated as follows:
Task Loop Area Shielding Decontamination ECT 61 30 Plug Repair 11.1 260 Tube Sample 5.7 130 l
~
. a.
~ 5 team Generator inspection & Repair (Cont'd.)
1983 84 (Cont'd.)
- 2. New manway stud tensioner employed
- 3. Use automated ECT equipment
- 4. The honing device, used in the sleeving operation, filter was remotely located and shielded
- 5. The decontamination skid was shielded
- 6. Auto, mated tube plugging, equipment was tried but didn't work well, thus requiring a manual operation 1985 As above plus:
- 1. Decontamination Factor-4.6
- 2. Exposure savings are as follows:
Task Loop Area Shielding Decontamination Sleeving 120 1200 Plugging 2 82 Radiography 4.5 37 Tube Sample 4.5 55
- 3. Special robot, ROSA, used for sleeving cold leg tubes. Manual method used on hot leg
- 4. New honing machine didn't cause high contamination exposure problems as prior model did
- 5. New robot, Genesis,was tried for radiography. It was unsuccessful 1986 As above plus:
- 1. Chemical decontamination factor = 2.2
- 2. Special robot (ROSA) was used for plugging as well as sleeving. Using ROSA ij saved about 170 person-rem ]
- 3. New manway shields permitted ECT with shield in place
- 4. Changes in sludge lancing equipment saved 40-45 person-rem
- 5. Radiography was performed,this time successfully with Genesis and saved 7 person-rem
- 6. Other exposure savings are:
Task Loop Area Shielding Decontamination Plugging & Sleeving 28.0 57.3 ECT 1.5 12.5 t Studge Lancing 3 - f Radiography 4.2 - t l ____-_-__L
e4& "
- ALARA IMPLEMENTATION AT MILLSTONE UNIT 2 ACP 6.02, MAINTENANCE OF OCCUPATIONAL RADIATION EXPOSURE ALARA 1
TO PROVIDE THE METHOD, ESTABLISH THE AUTHORITY AND DELINEATE RESPONSIBILITIES TO ENSURE THAT ALARA EXPOSURE CONTROLS ARE EXERCISED AND DOCUMENTED ON JOBS WITHIN RADIOLOGICAL CONTROL AREAS AT MILLSTONE STATION THROUGH A SYSTEMATIC PROGRAM 0F PLANNING WORK \ SIGNIFICANT PART OF STATION, UNIT AND DEPARTMENT G0ALS; BASED ON CORPORATE G0ALS EXPOSURE REDUCTION PROGRAMS (4 ITEMS) VIG0ROUS APPLICATION OF PERMANENT AND TEMPORARY SHIELDING DURING OUTAGES (ACP6.10) ALARA C0ORDINATOR INVOLVEMENT WITH APPLICABLE UNIT DEPARTMENTS BEFORE AND DURING REFUEL OUTAGES UNDER ACP6.02 FRD - 12/10/87
~
-s2-t ALARA REVIEW PROCESS
- 1. PERFORMANCE OF WORK - ACP 6.02 L
IF ESTIMATED EXPOSURE BETWEEN 1-5 MAN / REM, UNIT EVALUATES THE NEED FOR AN ALARA~ INSTALLATION REVIEWS. IF ESTIMATED EXPOSURE GREATER THAN 5 MAN / REM, AN ALARA INSTALLATION REVIEW IS IMPLEMENTED BY JOB TASK LEADER ON SF847 AND 848,
- 11. DESIGN CHANGES - ACP-0A-3.10 IF ESTIMATED EXPOSURE MORE.THAN 1 MAN / REM, APPLICABLE SECTIONS OF SF338 ARE REVIEWED.
FRD - 12/10/87
I ROUTINE MANAGEMENT INVOLVEMENT IN ALARA CONCERNS
'0UTAGE ALARA REPORT PROMULGATED BY ACP6,13 (SEE EXAMPLE)
FORMAL STATION RESPONSE TO ALARA OUTAGE REPORT RECOMMENDATIONS (SEE EXAMPLE) STATION SERVICES SUPERINTENDENT (H. HAYNES) INVOLVED WITH CORPORATE EXPOSURE REDUCTION INITIATIVES STATION G0ALS DIRECTLY RELATED TO G0ALS ESTABLISHED BY CORPORATE RADIOLOGICAL ASSESSMENT BRANCH l INCREASED ALARA STAFF ASSIGNED FOR OUTAGES INCREASED ALARA AWARENESS DURING OUTAGES: ADMINISTRATION LETTER, OUTAGE MEETINGS, VISUAL AIDS, ETC. SIGNIFICANT EMPHASIS ON TEMP 0P.ARY AND PERMANENT SHIELDING (NON-REGENERATIVE HEAT EXCHANGER, STEAM GENERATOR PLATFORM SHIELDING CAPABILITIES, ETC,) DAILY STATUS REPORT (SEE EXAMPLE) { i FRD - 12/10/87 l l
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. _ . _ . _ . . . . . . ~ . . . -__ . . . . . _ _ _ .--- _ -
EXPOSURE REDUCTION PROGRAMS M0CK UPS PHOTO BOOKS /. COMPLETE VIDE 0 e DOCUMENTATION 0F CONTAINMENT DURING 1988 REFUEL OUTAGE DURING 1988 REFUEL OUTAGE CHEMICAL DECONTAMINATION CONTAINMENT DECONTAMINATION 1 i FRD -12/10/87 : J ____-______a
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- I A S E A G T E S D L R N N A S L E E T G I I P N A C E E L W S U E I R N I T U O T C P R U N N DS L C C X E O O R T I EE L A 0 E T S I E I HI CD O P S / A E T W N F M G S D M R A O U SU - I N L N / R P T E -
I A A T L U S FS H L K O N E D L I O T A N G L E N A G N A A M N E N T NN N R R A T P O G O C OI I E R I I S A I U I R T M A P U R T G D TE S X R L A Q E U E O AE R E A A C E P O R R UN O P LI T - - - - - - - - AG C D VN A N _ EE F E o o o
S R O T C A F E V I T S A C T I I T L S A I U R Q E T D Y C N G A A OE R LT A E OU H V DB C I OI T HR O A TT W T ET T I MA T F N
.GY O A PNT E U AI E D R Q S KF E U I
NA S S F AS O O O R P P
.L M X N LE O E O M AN C I E CN N T R Y I O E O A - A TS T I N N D YR U T I A -
LE B A B M K AP I I Y M R N R D T O R O A T A E C E W T R F P A A Y T L S B E S Y A U O T N L D L L E O A E A F I I R V R A T R U E S A T S R P P S A A L U U E L T E C D M L S N C N 0 O N O I T D C O C S - - A - - R P E M P I o o
~
MILLSTONE UNIT 2 1 EXPOSURE SAVINGS THRU' ALARA (man-rem) 1981 82 Shfided Waiting Areas 40 1983-84 Task Channel Head Decon Loop Area shieldina , ECT 30 61 Plug Repair 200 11 Tube Sample 130 5.7 l 1985 Task Channel Head Decon Loop Area shieldina Sleeving 1200 120 Plugging 82 2 Radiography 37 4.5 1 Tube Sample 55 4.5 1986 Task Channel Head Decon Loop Area Shieldina Plugging & Sleeeving 57.3 28 ECT 12.5 1.5 Sludge Lancing - 3 Radiography - 4.2 i I l 1 l 1
.. m . I Haddam Neck (Connecticut Yankee) l 1986 Exposure Savings Realized by ALARA Controls Estimated Savings ALARA Control (Person Rem)
- 1. Shielding for RCS temperature element mod. 137
- 2. Monitoring above job with CCTV 21
- 3. Shielding for hanger work 24
- 4. CCTV monitoring for steam generator work (primary side) 32
- 5. Usinc robotic equipment for steam generator (secondary side i)nspection (ECT) 86
- 6. Shielding used for cavity seat replacement 48
- 7. Shielding for valve operator work in loop area 19
- 8. Shielding for in-service inspection 10
- 9. CCTV monitoring for RCP seal repairs 10
- 10. Shielding for RCP seat repairs 6
- 11. Shielding for various Appendix R modifications 10
)
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4 4
- MILLSTONE UNIT 1 1984 Exposure Savings Realized by ALARA Controls Estimated Savings ALARA Control (Person Rem)
- 1. Flush concentrator prior to repair. 5.0
- 2. Replace lower head of 'B' concentrator 4.7 with a better designed one.
- 3. Use a better grade material to retube 5.2
'B' concentrator.
- 4. Worker familiarization for hose installation 2.1 into the spent resin tank.
- 5. Removal of corrosion ring from fuel pool 23.7 to reduce general area dose rates for clean-up work.
- 6. Coordinating down power operations 1.0 with condenser bay work.
- 7. Shielding CRD saw. 2.0
- 8. Modify chain hoist so one man can handle 2.0 radwaste drums.
- 9. Chemical decontamination of the recirculation system
- a. Pipe Repairs 600.0
- b. Class 1 In service inspection 100.0
- c. Hanger Modifications 25.0
- d. Other Drywell Work 575.0 Total 1345.72 4 t __ -_
r~s MILLSTONE UNIT 1 1985 Exposure Savings Realized by ALARA Controls Estimated Savings ALARA Control (Person-Rem)
- 1. _ Fuel pool " rust ring" decontamination for LPRM .19.8 i and control rod blade disposal.
- 2. Replacement of the refueling mast take-up cable. 31.2
- 3. Shielding for hanger work 2 I
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[- ._.... :-61-. MILLSTONE UNIT 1 1986 Exposure Savings Realized by ALARA Controls Estimated Savings ALARA Control (Person-Rem)
- 1. Improved material logistics for turbine 5 building roof repairs.
- 2. Shielding for hanger work 3
- 3. Decontamination 10 i
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FORTY-YEAR OPERATING LICENSE AMENDMENTS S o NU HAS AN EFFECTIVE ALARA PROGRAM l 0 SIGNIFICANT RESOURCES HAVE BEEN AND ARE BEING APPLIED TO CONTINUE TO REDUCE OCCUPATIONAL EXPOSURE o TIMELY APPROVAL OF THE FORTY-YEAR OL AMENDMENT LOWERS COST TO OUR CUSTOMERS l l l cf5 - 12/10/87 _ _ _ . - _ . ._________-____-_____A
i Docket No. 50-336 B12777 Attachment 3 Millstone Nuclear Power Station, Unit No. 2 Additional Information for corty-Year Operating License Extension l 1 l I l Decernber 1987
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. , 1 MILLSTONE UNIT 2 EXPOS _URE SAVINGS THRU' ALARA(man-rem) 1981-1982 Shielded Waiting Areas 40 1983 1984 Task Channel Head Decon Loop Area Shielding ECT 30 61 Plug Repair 200 11 Tube Sample 130 5.7 1985 Task Channel Head Decon loop Area Shieldina Sleeving 1200 120 Plugging 82 2 Radiography 37 4.5 Tube Sample 55 4.5 Inspection of RCS piping with water level above centerline saved 6 man-rem. 1986 Task Channel Head Decon loop Area Shieldina Plugging & Sleeving 57.3 28 ECT 12.5 1.5 Sludge Lancing - 3 Radiography - 4.2 I l
. , '2 HADDAM NECK (CONNECTICUT YANKEE).
1981 Exposure Savings Realized by ALARA Controls' Estimated Savings ALARA Control (Person-Rem) s 1. Reactor Vessel Head Shield, Cavity Seal Plate 25 _) Shield, Used Personnel Shields during Refueling .
- 2. Steam Generator in Wet Layup during RCP Seal Work -28
, L3. Shield Loop Bypass Line during RCP Seal, Secondary 7 S/G, Valve Packing 3 '
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- 4. Steam denerator Manway Shields
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HADDAM NECK (CONNECTICUT YANKEE) 1983 Exposure Savings Realized by ALARA Controls Estimated Savings ALARA Control (Person. Rem)
- 1. Shielding for Seismic Support Repair / Modifications 55
- 2. Shielding of Head Area Cable Support Structures 3
- 3. Reactor Vessel Head Shielding, Personnel Shield, Maintain Maximum Water Levelin Reactor Vessel during Refueling 75 and CRD Repair
- 4. Increase Water Levelin Transfer Canal during Blind Flange 5 Removal / Replace
- 5. Shielded Loop Bypass Line during RCP Seal, Secondary 5/G 7 and Loop Stop Valve Packing
- 6. Manway Shielding during ECT Probe Changes 9
- 7. Shielding of Manways during ECT 13 1
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4 HADDAM NECK (CONNECTICUT YANKEE) i 1984 Exposure Savings Realized by ALARA Controls Estimated Savings ALARA Control (Person-Rem)
- 1. S/G Manway Shielding during ECT Probe Changes 9
- 2. Reactor Head Shield during Core Exit Therm. Steeve Mods. 15
- 3. Increased Water Level in Transfer Canal during Blind Flange Removal / Replace 5
- 4. Shield Loop Bypass Line during RCP Seal, Secondary S/G, 7 Valve Packing
- 5. S/G Manway Shielding during ECT/ Profilometry 12
- 6. S/G in Wet Layup during RCP Seal Work 31 7/ Reactor Vessel Head Shielding, Personnel Shields, Maintain 15 Maximum Water Level in Reactor Vessel during Refueling
.o . ~5 Haddam Neck (Connecticut Yankee) 1986 Exposure Savings Realized by ALARA Controls' l :.
Estimated Savings ALARA Control (Person Rem)
- 1. Shielding for RCS temperature element mod. 137
- 2. Monitoring above job with CCTV 21
- 3. Shielding for hanger work 24
- 4. CCTV monitoring for steam generator work (primary side) 32
- 5. Using robotic equipment for steam generator (secondary side inspection (ECT) 86
- 6. Shielding used for cavity seat replacement 48
- 7. Shielding for valve operator work in loop area 19
- 8. Shielding for In-service inspection 10
- 9. CCTV monitoring for RCP seal repairs 10
- 10. Shielding for RCP seal repairs 6
- 11. Shielding for various Appendix R modification 10
. . 6-HADDA!A NECK (CONNECTICUT YANKEE) .
1987 Exposure Savings Realized by ALARA Controls (Preliminary Information for SIG Projects Only) Estimated Savings ; Al. ARA Control (Person-Rem)
- 1. Use of Robotic Equipment for S/G ECT 86
- 2. Use of Robotic Equipment of S/G Tube Plugging 380
. 3. Locating ECT Probe Pusher Outside 5/G/ Skirts 21 I
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Docket No. 50-336 B12777 l Attachment 4 Millstone Nuclear Power Station, Unit No. 2 Additional Information for Forty-Year Operating License Extension i December 1987 i
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NORTHEAST UTILITIES
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* ' ' ' " H.W.S. l}{ys December 18, 1986 R.C.R._j ~
NE-86-RA-1229 P,.T.H, l - C.F.S. - T0: S. E. Scace - Millstone Station Superintendent - R. H. Graves - CY Station Superintendent R. C. Rod rs - Manager Ra logical Assessment h
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W. G. Collins C. A. F ory f c,4 (Ext.5279) (Ext. 5472) (Ext. 3597) j p+
SUBJECT:
ALARA PROGRAM APPRAISAL
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1.0 INTRODUCTION
A special ALARA Program Appraisal was conducted at Millstone, Connecticut Yankee, and the NUSCO corporate office during the month of November,1986. Seventy-four man-hours were expended on-site during the performance of this audit (62 at Millstone,12 at CY). Additional hours were expended at the corporate office. We would like to thank all the personnel contacted during the course of this appraisal. Many interviews were scheduled with short notice; yet everyone was willing to provide their time, cooperation an! candid opinions. Personnel contacted included: C. Bacon - MP2 Health Physics T. Blanchard - MP2 Engineering , G. Bouchard - CY Station Services Superintendent ' M. Brennan - MP1 Radiation Protection Supervisor j D. Chick - NUSCO Construction Representative i H. Clow - CY Health Physics Supervisor l R. Crandall - NUSCO RAB Radiological Engineering Supervisor l J. Crockett - MP3 Unit Superintendent { F. Dacimo - MP2 Maintenance Supervisor R. Doherty - MP1 ALARA Coordinator , B. Duffy - MP2 Assistant Engineering Supervisor ] D. Fitts - MP2 ALARA Coordinator ! E. Foster - MP2 Engineering ) B. Granados - MP Health Physics Supervisor E. Guzallis - CY ALARA Technician s M. Heinonen - MP2 Assistant Maintenance Supervisor M. Joyce - MP2 Health Physics G. Komosky - MP2 Engineering H. Labiniack - C.E. ECT Supervisor E. Laine - MP2 Radiation Protection Supervisor I OS70 REV. 3-83
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Personnel Contacted (Contd.): j J. McHugh - NUSCO RAB . ] J. Powell - CY ALARA Coordinator
.W. Rambow:-' NUSCO Gen. Construction ALARA Coordinator j R. Sachatello- MP3 Radiation Protection Supervisor .j S. Scace - MP2 Unit Superintendent P. Simmons -1MP Radiation Protection Support Supervisor ]j
.J. Stetz'- MP1 Unit. Superintendent S.LTurowski - MP2-ALARA Coordinator W. Varney MP1 Maintenance Supervisor-R. Veilleux - CNF HP Coordinator -
Various exit interviews were conducted between December 4 and December 16, 1986. 1 Attending.these interviews were: R. A. Crandall J. G. McHugh-R. N. McGrath R. C. Rodgers H. E. Clow J. O. Powell
.E. C. Guzallis r
E. A. DeBarba G. H. Bouchard B. L. Granados J.- P. Kangley J. J. Kelley R. A. Grebasch
- W. Rambow 2.0 MANAGEMENT
SUMMARY
This ALARA Appraisal was conducted primarily through interviews 'o f personnel at all levels of the organization. Topics of discussion included: the responsibility for and the effectiveness of ALARA controls; the communication of program goals to various levels of management and. the rad-worker; upper management support; site and corporate communications; goals and estimates; training; and perceptions of roles, goals, and attitudes. Much of this appraisal focused on the on-going Millstone 2 outage since most of the plant's exposure and ALARA activities occur during an outage. L c _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -
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I 1 l 2.0L MANAGEMENT
SUMMARY
(Contd.) 1 ! Some recent changes and improvements in the ALARA program were notedi o The establishment of the Exposure -Reduction Initiatives (in. the
- creas of _ Radiation Field Control, Work Scope Reduction, and Worker L
. Efficiency Improvement) gives significant: direction to the task of L reducing exposures.
, o A recent meeting concerning ALARA review of 1987 CY Outage Projects l . included representatives of RAB, CY, Generation Engineering and' Generation Construction. .The five upcoming outage projects with the highest estimated exposure were discussed. Exposure reduction . and work scope reduction alternatives were reviewed. t-
. The results of _ the appraisal fall into two major areas of Communications and Responsibilities.
In the area of Communications there were some instances in which the root causes
.of' problems--could be traced to either 1) a breakdown in the communications flow l or 2) communications barriers created by the established work methods. Section 3.1 identifies- 5 'such problem areas. These are listed .below along with the associated finding'or recommendation numbers.
3.1.1 ALARA Goals (11-26-86-1) 3.1.2 Radiological Assessment Branch Functions (11-26-86-2) 3.1.3' ALARA Design and Engineering (11-26-86-3 and 11-26-86-4) 3.1.4 Unit ALARA Coordinator Functions (11-26-86-5 and 11-26-86-6)
-3.1.5 . Training (11-26-86-7)
The second major area is.that of Responsibilities. Section 3.2 identifies. seven
- areas in which the root. causes of some problems can be traced to a failure to assign. responsibility, provide the requisite authority, or provide the resources
- i. needed to meet a responsibility. The seven areas are:
3.2.1 . Job Procedure Reviews (11-26-86-8). 3.2.2 ALARA Exposure Control (11-26-86-9) 3.2.3 Pre-Job Briefings (11-26-86-10) 3.2.4 . Audits and Inspections of ALARA Controls (11-26-86-11) 3.2.5 Enforcement Authority (11-26-86-12) 3.2.6 Control of the number of workers on a job (11-26-86-13) 3.2.7 Exposure Equalization (11-26-86-14) Section 3.3, Dose Accounting, identifies a concern brought to our attention on the anomalies of using Pocket Ion Chamber (PIC) results for exposure tracking versus the use of TLD results. (11-26-86-15) The 15 separate findings or recommendations have been detailed in this Appraisal Report. Summaries of each item have also been entered on our standard finding forms and are attached for tracking purposes. I. - _ - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ -
, I o To ease the logistics of responding to this apprasal, we are soliciting specific responses from the organizations listed below for each item:
11-26-86-1 : RAB 11-26-86-2 : RAB 11-26-86-3 : Millstone 11-26-86-4 : RAB, Millstone, and CY 11-26-86-5 : RAB, Millstone, and CY ' 11-26-86-6 : RAB, Millstone, and CY 11-26-86-7 : RAB, Millstone, and CY 11-26-86-8 : RAB, Millstone, and CY 11-26-86-9 : Millstone 11-26-86-10 : Millstone, and CY 11-26-86-11 : Millstone, and CY 11-26-86-12 : RAB, Millstone, and CY 11-26-86-13 : RAB, Millstone, and CY 11-26-86-14 : RAB, Millstone, and CY 11-26-86-15 : RAB, Millstone, and CY As discussed and accepted at the exit interviews, responses will be submitted to each of the Station Services Superintendents and the Manager, RAB. The station and corporate responses should then be coordinated so that a combined response can be issued by April 15, 1987. l 3.1 BREAK-DOWN IN OR BARRIERS TO COMMUNICATIONS 3.1.1 ALARA Goals In the last few years goals have been established for total person-rem exposure by unit. These goals were developed by RAB and were based upon meeting INP0 Guidelines for person-rem i exposure at a future date. Often these goals did not reflect the l actual planned work and estimated exposures for the unit. Subsequently a large amount of time was expended in justi fying and explaining why the goals were not met. Since the goals were ! perceived as being unrealistic, they were often not communicated i to the workers. This situation created a serious barrier to communications between the station and RAB. For 1987, goals are being developed based upon job estimates and past exposure histories alone. The goals will not be tied to the INPD Guidelines. The establishment of goals based on exposure histories and job estimates requires close cooperation between RAB and each unit. This cooperation was evident at Connecticut j Yankee. At CY all levels of management were aware of the new ( goals process and were satisfied with the attempts to correct the l past problems. At Millstone, however, most interviewees { continued to discuss the goals as though the past experiences l were to be repeated. All levels of management attacked the goals l process as not being based upon actual work or realistic dose I rates. They insisted that their input for goals development was ; not sought. s
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l 3.1. BREAK-DOWNINORBARRIERS'TOCOMMUNICATIONS(Contd.) 3.1.1 ALARA Goals (Contd.) A review of RAB's" work in development of new goals was conducted. Memos to' Mi11 stone' asking .for exposure estimates and input were .
. evident. .However, when responses to these . requests were .not received, there was no evidence of. follow-up requests.
- A' breakdown- in communications between Millstone and RAB seems to exist. Part of this problem is due to there being no . formally:
accepted process for goal development. Exposure goals are not mentioned-in the ALARA Program Manual. Establishment of goals is mentioned only briefly in NE0 2.05. As a recommendation '(11-26-86-1), the description of the goals process should bef expanded in the NE0 procedure or the ALARA Program - Manual . Once established, this process should be communicated to all management levels down to line supervisors. Support from all levels of management is needed to implement an effective goals program. 3.1.2 RADIOLOGICAL ASSESSMENT BRANCH FUNCTIONS During' the appraisal interviews it was apparent that there is much confusion concerning : the functions of ' RAB in .the ALARA program.- Perceptions have been formed at the station which often do not match RAB's. perception of their function. This has created another barrier to effective communications. For example:
- 1) RAB performs PDCR ALARA Design Reviews for projects initiated at NUSCO. RAB's ALARA involvement with the project ends upon completion of the Design . Review. However, some station personnel expressed the sentiment ' that RAB's involvement in the project should continue' at the station by verifying the implementation of the Design criteria. Questions included:
Why aren't they down at the site more often? How can they do an ALARA Design Review at the corporate office?
- 2) ALARA Procedure 1/5 entitled " ALARA Job Reviews", paragraph 8.1.3, states: 'For job (s) estimated to exceed 30 person-rem, NUSCO RAB personnel should be contacted to provide assistance in the ' performance of the job review' . This requirement has not been implemented. The ALARA coordinators consider RAB personnel too removed from the job site to be of assistance during the job reviews. Priorities for RAB ALARA personnel do not include being involved in the job reviews. This procedure requirement should be implemented, deleted, or revised to clarify RAB'.s function.
- 3) RAB has spent a considerable amount of time developing and refining the Exposure Reduction Initiatives (ERI's). At this point, however, it's not clear who takes the next step.
t T.J 3.1 BREAK-DOWN IN OR BARRIERS TO COMMUNICATIONS (Contd.) 3.1.2 RADIOLOGICAL ASSESSMENT BRANCH FUNCTIONS (Contd.). Is RAB's function simply to suggest ERI's; or does RAB obtain the ' upper management commitment of resources to complete. the initiatives; or even fu rther, does RAB develop the ., specifications and instructions. necessary to implement the ; initiatives? All of these options were mentioned during the interviews. The confusion over RAB's function in the' ALARA program has ; by the ambiguity of the ALARA Program been compounded Procedures themselves. The Responsibilities Section of ALARA Procedure #2, concerning Cost Bene fit Evaluations; Procedure.
#4, concerning ALARA Design Reviews; Procedure #5 concerning
. ALARA Job Reviews; and others only state ' that RAB 'provides radiological assistance...'. There are no ALARA program procedures detailing Exposure Goals or Exposure Reduction Initiatives.
As a recommendation (11-26-86-2), the communication of RAB's function should be -improved by 1) revising the present ALARA program procedures, 2) developing other procedures. as necessary to : detail all of RAB's functions, and 3) establishing open communications with the stations to clarify l RAB's functions. 3.1.3 ALARA DESIGN AND ENGINEERING The ALARA involvement in the plant design change process suffers from a lack of communications and a lack of feedback of information. Several ongoing projects for the Millstone Unit 2 outage were reviewed during this appraisal. Concerns with two of those projects are described below: PDCR 2-64-86 Millstone 2 Steam Generator Channel Head Decon The ALARA design review for this project was completed in August,1986 and was reviewed by the RAB ALARA group 8/13/86. One design review checklist item, (Section 1, item 5) asked: 1
'Do design features prevent personnel from inadvertently l entering areas where a significant dose could be received in a ;
short period of time?'. The answer to this question in August
' Shield wall will prevent personnel access to ion was, exchange c0lumns' . As this project progressed, the shield wall design was changed; first to allow personnel access and finally to remove the wall altogether.
L _ _ __-_-____________D
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3.1 BREAK-DOWN IN OR BARRIERS TO COMMUNICATIONS (Contd.) 3.1.3 ALARA DESIGN AND ENGINEERING (Contd.) There was no evidence that the ALARA Design Review Checklist was revised or that there was any feedback of information to the RAB ALARA reviewer. Additionally, on the PDCR, there was no sign off for the ALARA installation review by the unit ALARA coordinator. The unit ALARA Coordinator had not yet seen tne ALARA Design Review Checklist for the project although the Steam Generator decon was in process. PDCR 2-85-86 Neutron Shield Tank The ALARA Design Review Checklist for this project was also reviewed by RAB and included the following statement on the Checklist cover page: ' Construction activities will be evaluated under (the) installation review'. This project was in progress at the time of the appraisal yet the installation review had not been conducted. However, this PDCR had received "early approval for construction", a process that allows construction prior to completion of all design reviews. , By this interpretation, the PDCR procedure allows work to ! start on a project before any ALARA review. The change in design without a change in the ALARA Design Checklist, the failure to complete the installation review, and the possible performance of work without an ALARA review are presented as Finding 11-26-86-3. These are just examples (symptoms) of the lack of communications and feedback in the ALARA Design and Engineering process. As a recommendation (11-26-86-4), the following issues should be evaluated:
- 1) Should RAB continue to be involved in the ALARA design review process? If so, how do they communicate the results of their review to the Unit ALARA Coordinator?
- 2) Is an overview or monitoring of a project necessary to ensure that ALARA design criteria are in fact implemented?
If so', who should have responsibility for this task?
- 3) What is the extent of the ALARA Installation Review? The PDCR procedure only includes a definition. Further l guidance for the ALARA Coordinators should be provided.
l I 3.1.4 UNIT ALARA COORDINATOR FUNCTIONS Each unit has an ALARA Coordinator who reports to the unit's Radiation Protection Supervisor. Connecticut Yankee provides an additional permanent ALARA Technician to work with the ALARA Coordinator. Millstone provides contractor technician assistance during outages. i
3.1 ppNK-DOWNINORBARRIERSTOCOMMUNICATIONS(Contd.) 3.1.4 UNIT ALARA COORDINATOR FUNCTIONS (Contd.) ; During the' Appraisal, it was noted that each of the ALARA l Coordinators approach their job ' differently although each is ' implementing the same ALARA Program. The differences . in approach consist mainly of the division of time among their various duties. . The reason for the differences can be traced to:
- 1) Location: Physical proximity of the ALARA Coordinator 'to the Health Physics office (at MP3 and CY) seems to involve the ALARA Coordinator in more day-to-day activities.
- 2) Variations in supervision: Each ALARA Coordinator reports to a different supervisor with differing priorities.
- 3) Variations in Unit Management expectations: There is varying emphasis on exposure tracking duties versus ALARA control implementation duties at each of the units.
The different approaches to the ALARA Coordinator's job has created communication problems with those who must deal with all four units. For example: r
- 1) Each ALARA Coordinator has developed his own unique RWP L ALARA codes. The lack of standardized coding makes it nearly impossible for anyone else to extract past exposure l histories for similar' types of jobs. _ It also necessitates l
using a large amount of the ALARA Coordinator's time during an outage to properly code the RWP's.
- 2) There are widely differing opinions of what an ALARA Coordinator should be doing. Interviewees have stated that the ALARA Coordinator's primary function should be:
- exposure tracking
- ALARA Control development and verification
- planning for future outages
- reviewing modification and maintenance techniques for exposure reduction.
While each coordinator performs these functions, even the coordinators do not agree on their primary function. This results in different emphasis on different aspects of the job.
- 3) The differing locations of the ALARA Coordinators in relation to their HP offices has resulted in different leve'Is of involvement in pre-job activities. This adds a level of confusion for job supervisors who must deal with all the coordinators.
As a recommendation (11-26-86-5), consideration should be given to standardization of the ALARA Coordinator's function. This should include an agreement, through all levels of Station Management, on the expected functions of the ALARA Coordinator.
9_ 3.1 BREAK-DOWN IN OR BARRIERS TO COMMUNICATIONS (Contd.) 3.1.4 UNIT ALARA COORDINATOR FUNCTIONS (Contd.) One other communications difficulty arises because the ALARA Coordinators must deal with a large number of job supervisors. Each of these job supervisors has different levels of experience with the ALARA program. The Generation Construction Department has taken a step toward relieving this problem by establishing their own department's Construction l ALARA Coordinator to act as liason between representatives and the ALARA Coordinators and the other Health Physics personnel . Establishing department level ALARA Coordinators has been recommended by an INP0 Good Practice. This has al so been formally recommended by the Connecticut Yankee ALARA Coordi na tor. At CY, unofficial department liasons between HP/ALARA and each department have been effective. As a recommendation (11-26-86-6), the establishment of departmental ALARA Coordinators on a formal basis should be considered. This is not necessarily another full time position but could be an individual in each department to act as a liaison. This should include Unit departments, NUSCO departments, and even contractor / vendor representatives. This would reduce the number of contacts for each ALARA Coordinator. This would allow extensive ALARA and exposure reduction indoctrination to a relatively small number of people across a wide span of organizations. Finally, this would also provide a direct ALARA contact for the workers to encourage 2-way communications. 3.1.5 TRAININt There are presently two requirements for ALARA training: ALARA Procedure #5 entitled " ALARA Job Reviews", section 5.2 states: ' Unit Superir;tendents , Station Services Superintendents, and the Betterment Construction System Superintendent shall ensure their personnel are trained in and adhere to this procedure and are aware of and understand the requirements for ALARA' . NEO Procedure 2.05 entitled ' Radiation Protection and Maintaining Occupational Radiation Exposures as Low as Reasonably Achievable ( ALARA)', paragraph 6.4.7, states: 'The Manager, NUSCO RAB, will, jointly with Nuclear Training Department, coordinate and conduct discipline specific training in ALARA for all NE0 departments. Neither of these training requirements has been met. (Finding 11-26-86-7).
( n- ,,, l l-3.1 BREAK-DOWN IN OR BARRIERS TO COMMUNICATIONS (Contd.) j 3.1.5 TRAINING (contd.) Most interviewees indicated that their only ALARA indoctrination has been through General Employee Training (GET). An ALARA training course for Engineers was held a couple of years ago but this focused only on performance of ALARA Design Reviews and Cost Bene fit evaluations. Nearly everyone interviewed recognized the need for socne specific ALARA training for the fi rst line job supervisors and job leaders. They have the majority of responsibility for implementing ALARA requirements and yet they have had no training in 1) the ALARA Program, 2) ALARA goals, 3) conductng ALARA required pre-job briefings, or 4) different techniques for high versus low exposure jobs. This type of training should also be available to the various contractor job supervisors. Increased training for job supervisors is included in the Exposure Reduction Initiatives. l Additionally, some interviewees questioned why ALARA training in GET is the same for all employees . Why does a Steam Generator worker have the same ALARA indoctrination as people . who may never enter a high radiation area? ! 3.2 FAILURE TO ASSIGN RESPONSIBILITY, PROVIDE THE REQUISITE AUTHORITY, OR PROVIDE THE RESOURCES NEEDED TO MEET THE RESPONSIBILITY 3.2.1 Job Procedure Reviews The ALARA job checklist used at Millstone (Station Form 848), includes item #8 ' Job procedures have been prepared or modified to minimize exposures. Expl ai n. ' For jobs reviewed during this a ppraisal , the answer to this item was "yes". There were no details of which procedures were reviewed and or revised. Millstone's procedure ACP 6.02 states that controlled copies of any special procedures should be forwarded to the unit ALARA Coordinator. This is not done. The Job Leader has responsibility to complete the ALARA Job Checklist and presumably the responsibility to review the procedures. However, this was not clear to the Job Leaders interviewed. The Job Leaders also expressed some doubt as to how to review the procedures for exposure reduction. It seems that the ALARA Coordinators are the ones with the expertise to perform this function, but that responsibility is not assigned. l As a recommendation, (11-26-86-8) the function and responsibilities for job procedure reviews should be l reassessed and revised to clearly assign responsibilities. The previously recommended department level ALARA Coordinators l could assume some of the responsibilities in this area. -m_._m_______
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- a 3.2 FAILURE TO ASSIGN RESPONSIBILITY, PROVIDE THE REQUISITE AUTHORITY, OR PROVIDE THE RESOURCES NEEDED TO MEET THE RESPONSIBILITY (Contd.)
3.2.2 ALARA Exposure Controls ALARA Procedure #5 entitled ' ALARA Job Reviews', states in section 5.7 that 'Radworkers shall be responsible for: 5.7.1 Keeping their exposures ALARA by remaining knowledgeable in and strictly adhering to the ALARA exposure controls'. In practice, there is confusion in responsibilities for being cognizant of the ALARA Exposure Controls. For repetitive jobs, the ALARA controls tend to be repetitive so a sense of apathy was noted. The controls are met because "that's the way the job has always been done". Workers expressed the feeling that the ALARA Exposure Control Sheets used at Millstone are only reminders for the Job Supervisors. The lack of importance of the ALARA controls is due to a combination of weakly worded ALARA Controls (using words like "should", "as appropriate", "when necessary") weak pre-job briefings and little or no enforcement of the ALARA Controls. The pre-job briefings and enforcement issues are covered in subsequent sections of this report. Connecticut Yankee has successfully implemented the use of ALARA Control Area postings to draw attention to the ALARA Controls, and ensure that they are ,not overlooked. As a recommendation (11-26-86-9), Millstone should consider revising the method in which ALARA Controls are communicated. The ALARA Controls should be written as controls, i.e., with strong words of requirements (shall, will, etc). These requirements should be communicated during the pre-job briefing and should be posted at the job site. The Job Supervisor should have the ability to revise the controls with the ALARA Coordinator's approval. This would eliminate the need to write controls with provisional words such as : when i needed and as appropriate. 3.2.3 Pre-Job Briefings ALARA Procedure #5, paragraph 8.2.5 states that 'The Job / Task Leader shall ensure that all job / task workers are ... briefed on the work to be performed'. Most interviewees admitted that the pre-job briefings in ALARA Controls for the job, are weak or non-existent. This is partly due to the indifference resulting from repetitive jobs. Al so , for any particular job there are a large number of people who could be considered as the job or task leader. It is not clear who has the final responsibility for the pre-job , briefings. l
s ,, < p . L i 3.2 FAILURE TO ASSIGN RESPONSIBILITY, PROVIDE THE REQUISITE AUTHORITY, OR-1 PROVIDE THE RESOURCES NEEDED TO MEET THE RESPONSIBILITY (Contd.) 3.2.3 Pre-Job Briefings (Contd.) : As a recommendation (11-26-86-10), the responsibility for the ALARA- portion of pre-job briefing should be re-assigned to: the:ALARA Coordinator
- lthe Health Physics staff, or
- a . departmental ALARA Coordiiiator (previous recommendation 11-26-86-6) 3.2.4 Audits and Inspections of ALARA Controls ALARA Procedure #5, paragraph 5.3, t states that the ' Health Physics- Supervisor. or the ALARA Coordinator shall be responsible for auditing RWP and ALARA Control commitments to ensure they are being adhered to ~ by Job / Task Leaders and workers'.
Paragraph 8.1.6.2.b expands on this and states: ' A copy of (the ALARA Controls are) ... sent to HP to permit the HP technician assigned. to the job or work area zone to check the job for compliance with the speci fied ' ALARA exposure controls'. Through discussions with both the Millstone and .CY Health Physics staff, we found that HP personnel do not audit the ALARA controls unless the controls happen to coincide with the RWP requirements. The audits conducted by the. ALARA Coordinators are generally.not documented (with the~ exception of Connecticut Yankee where an informal log is maintained). As recommendation (11-26-86-11), the responsibilities for conducting the audits of ALARA Controls should be reemphasized with the HP Staff and ALARA Coordinators. The performance of audits may not need to be formally documented; however, some form of feedback should be established. This feedback should include 1) notification from HP to the ALARA Coordinator of ALARA Controls which were checked and the subsequent results; and 2) notification from the ALARA Coordinator to the Job / Task g Leaders of the results of ALARA Control Audits. l
g ,,, E a l 3.2 FAILURE TO ASSIGN RESPONSIBILITY', PROVIDE THE REQUISITE AUTHORITY, OR 4 PROVIDE THE RESOURCES NEEDED TO MEET THE RESPONSIBILITY (Contd.) 3.2.5 Enforcement Authority ALARA procedure #5 specifies only one enforcement recourse for the violation of ALARA Controls: The Stop Work Order. The responsibility for exercising the Stop Work Order is ambiguous. Paragraphs 4.4 and 5.3.7 discuss the Stop Work Authority and responsibilities but do not mention the ALARA Coordinator. However, paragraph 8.2.7 states that the ALARA ; Coordinator can exercise the Stop Work Order. ; Discussions with ALARA Coordinators and HP Staff indicate that l Stop Work Orders are seldom exercised. All agreed that a violation of one ALARA Control would probably not result in a Stop Work Order. This enforcement tool is usually only used for violations of Federal Regulations or to prevent over exposures. There is an impression that there would be little } upper management support for stopping a critical path job ! because of failure to implement an ALARA Control. Procedure
#5 enforces this impression by noting in paragraph 8.2.7 that i senior station management is notified only if there is no i resolution of the Stop Work Order.
As a recommendation (11-26-86-12), the responsibilities for and the use of Stop Work Authority for violations of ALARA Controls should be reassessed. Perhaps some lower level enforcement tool could be developed. This could take the form of a formal violation notification to the job leader with copies to upper management followed by some logical escalation to the Stop Work Order. It was noted that CY has established a Radiological Deficiency 2 Report which could be used for a minor violation of an ALARA control. 3.2.6 Control Of The Number Of Workers On A Job Control of the number of workers assigned to a job was one of the problems voiced by all interviewees. A revision to ALARA Procedure #5 in August of 1985 added a responsibility for the Job / Task Leader to ensure 'that the minimum number of workers nceded to do the job has been determined and that no more than that number has been assigned to it'. The ALARA Job Estimate form in Procedure #5 added a requirement to ' list the number of each of the various type workers needed to do the job. Include analysis that this is the minimum number of workers required for efficient performance'.
j j l j I l I t I 3.2 FAILURE TO ASSIGN RESPONSIBILITY, PROVIDE THE REQUISITE AUTHORITY, OR PROVIDE THE RESOURCES NEEDED TO MEET THE RESPONSIBILITY (Contd.) ; 3.2.6 Control Of The Number Of Workers On A Job (Contd.) 1 These requi rements for estimating and listing the minimum number and types of workers have not been implemented at either station. At Millstone, the Job Estimate form (SF 847) has not been revised to include the requirement. Based on discussions during this appraisal, the delay in implementation j seems to stem from several concerns.
- 1) The responsibility assigned to a Job / Task Leader is too !
broad based. Who actually should be doing this for a major Betterment project? The construction representative? The various contract supervisors? A job foreman? 1
- 2) The logistics of making the determination of the minimum number of worbrs seems overwhelming considering the number of contractors on-site and the many last minute changes to a project or job.
- 3) There are no requirements for follow-up or monitoring of the workers. Who checks that the speci fied number of workers is appropriate and not exceeded?
As a recommendation (11-26-86-13), the entire issue of l determining the number of workers on a job should be reassessed. Further detailed guidance should be provided specifying responsibilities and specific methods for l performing and following up the worker estimates. Note that this may be another area in which a Department ALARA Coordinator may provide assistance and consistency (recommendation 11-26-86-6). Another approach may be to tighten Radiological Control Area (RCA) access control . This has a disadvantage of putting the enforcement responsibility on the HP Technicians and Control Point Monitors. It was noted that stricter access control is included in the Exposure Reduction Initiatives. 3.2.7 Exposure Equalization One of the stated objectives of the ALARA program (Part A, Objective 3.A.4) is 'to balance individuals exposure within the various work groups consistent with experience, manpower, and union agreement limitations'. ALARA Procedure #5, paragra ph 5.4 states that ' Job / Task Leaders and/or Department Heads shall be responsible for: 5.4.4 ' ensuring that exposures incurred by department personnel are as evenly distributed as possible within the different skills'. _ __-__________-_A
L. n, - :.G 1
;w r 3.2 - FAILURE TO ASSIGN RESPONSIBILITY, PROVIDE THE ' REQUISITE AUTHORITY, OR PROVIDE THE RESOURCES NEEDED TO MEET THE RESPONSIBILITY-(Contd.)
3.2.7 Exposure Equilzation (Contd.) Although this requirement is recognized and included on the ALARA Job. Checklist, most ' interviewees have the impression that this- requirement is not implemented. For example: One Millstone Unit 2 ALARA Job Checklist stated:
'Yes, Wexsum (the weekly exposure summary).will be made available for review'. Left ' unanswered are the ' questions: by whom? How often? and what actions can or will be taken?
As a recommendation (11-26-86-14), more detailed' guidance should be provided indicating responsibility for tracking the exposures and taking action, responsibility for monitoring the performance of the task, and methods of enforcement, One interviewee noted that union overtime hours are easily monitored and eoualized. Why can't we do this for exposures? 3.3 DOSE ACCOUNTING' One concern within the ALARA - program has been the comparison of our relatively higher exposure histories versus other nuclear plants. Much of. Our time is spent justifying the person-rem expended over any one year period. One point brought out during the appraisal is that our total person-rem' may be inflated because it is based on Pocket Ion Chamber (PIC) results instead of the ' permanent Thermoluminescent Dosimeter (TLD) results. The use of multiple dosimetry introduces an even larger disparity. With multiple dosimetry, the highest PIC reading is entered in the exposure record and used for ALARA reports. This can result in readings significantly higher than the individuals permanent exposure results. As an illustration, one Steam Generator worker's October exposure is detailed on the next page. Note that five separate packs of dosimetry are used for Steam Generator work: one each on the head, chest, back, left knee and right knee.
a m <..,
- 16 '
l u 3.3 DOSE ACCOUNTING (Contd.) l l PIC Results:
-Highest PICL !
, Reading Entered Left Right On The Date Head Chest Back Knee Knee. RWP-10/14 80 20 80 80 100 .100 10/15 25 0 25 100 50 100 10/26 25 50 25 0 25 50' u 10/27 75 lii0 100 125 200- 200 10/28 50 50 0 50 50 50 10/30 100 TS 50 50 50 100 Total by RWP.= 600 l TLD results for the same Steam Generator entries:
Highest Used For
.Left Right- Whole Body Head Chest Back Knee Knee' Exposure 427 409 286 402 332 427
-The legally reported total for this individual is 427 millirem.
However, the figure used for the ' job exposure totals is 600 millirem. We recognize that a shift to the use of TLD data for ALARA exposure tracking may be logistically difficult because of the time needed for , processing. As a recommendation (11-26-86-15), the use of permanent TLD ! results should be investigated for the person-rem ' comparisons of NU's plants to other plants. This may improve our appearance to outside agencies. , 1 1 i
4.0 STATUS OF PREVIOUS FINDINGS Not applicable to this Appraisal 5.0 ATTACHMENTS Findings and recommendations: 11-26-86-1 through 11-26-86-15 MRB/pb Attachment c: E. J. Mroczka W. F. Nevelos W. D. Romberg F. C. Rothen C. F. Sears W. Rambow R. P. Werner R. K. Doherty R. T. Harris D. W. Fitts G. L. Johnson S. M. Turowski E. R. Foster J. O. Powell J. J. Kelley R. A. Crandall G. H. Bouchard H. W. Siegrist H. E. Clow I. L. Haas J. P. Kangley B. L. Granados Audit File E. J. Laine M. J. Brennan R. J. Sachatello 1 i I E_______.___________._
.*- .~. Rev. 8 Date'1/86 Page B/3-15 Health Physics Audit Tinding Torm
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Description:
Tinding Number: ll 7.t,- 8(, - I l~mpwa corrimovic Adoo or wa ALARA 6 wrc Auditee: CY, tipi, tiP2, f1P3, wv1 6oALs facesss 7e Av. c406t.s of MA*JA96HcuT. ( R A 612 &3, POSL, NUDL Coodoen. verectu3 ne Paoesss ,o su Mco oe ALARA Paooenod . B. Classification: C Noncompliance I - Violation of D Noncompliance II - Violation of D Deficiency m-poa yearreteseersoo lar/Viu, 3.1
- Isee AUWA 6PAisAC.
(2 Recommendations 3 C. Immediate Actions Taken (if recuired) and Priority of Corrective Actions:
- 1. Immediate Actions Taken D # If yes, detail actions below:
(NOTE: A Noncompliance I Y N requires a Yes)
- 2. Corrective Actions ? iority: -
D Within 3 verhinE day D Short-term days E Long-term - months iCc__c; N Y i::c Due by: A94n. If,
~
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- Fir - -N CE : Cerpcrate ju_?a D.neti, Ptn 3, ? ocedure 63 l
1 I
,d* ,.. Rev. 6 Date 1/86 i
PaFe B/3-15 Health Physics Audit Tinding Torm
- Part 1: Documentation and Identification of Responsible Supervisor A. Tinding
Description:
Tinding Number: 11 - fis- 8(o - f. Im peve n,c commooiem'oo or RA6's A4/2A Auditee: CY, MP1, MP2, MP3, rv9e b s rara m F e ucocc e M sro m o g us.O e, ? P4ce bu4c tevo to/msar. (RAB) ,g3, Post, guet B. Classification: C Noncompliance I - Violation of D Noncompliance II - Violation of D_ Deficiency ( ga og,.,;q gy Aoqap gg,,,e flitRecommendationl l'.spoer Sten 6a 3. [ . 2 C. Immediate Actions Taken (if recuired) and Priority of Corrective Actions:
- 1. Ic: mediate Actions Taken D Sr If yes, detail actions below:
(NOTE: A Noncompliance I Y N requires a Yes)
- 2. Corrective Actions ?:iority:
C Within 3 verting day C Short-te:m days F Long-ter= - conths E=::: - Due b T; N' /S' 87 - - -
'*b' fK (onec. rive AcAo.J hu. D.we Late Auditor Late T6 Ed DETE4dw(b I). Tindi=r True and Resaensibili v:
O E.?. 2 Non-I.P. responsible Supr.: O4 / ron. Wes A%'idisnt 44 I. Acknowledgement: 71/t. Exir- /urtewh R A.dnAmALL 4 R. O. MoE 6cs 12 6!af. 52 i:: Eeprese:n z ive ' Iz e R4G
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,_ ________mu
. . . . , Rev. G ,
l Date 1/86 Page B/3-15 Health Physics Audit Tinding Torm
- part 1: Documentation and Identification of Responsible Supervisor A. Findint
Description:
Tinding Number: fl- % - 8[o - 3
- 6. Aw w.pacea.:, pA.49c ro e bedcno i4V AO bArtb N Auditee: CY, tipi,(?))11P3, ALAftA Deo w (Wia.
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- 1. Immediate Actions Taken o sr If yes, detail actions below:
(NOTE: A Nonco:pliance I Y N requires a Yes)
- 2. Corrective Actions Priority:
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Date 1/86 PeFe B/3-15 Health Physics Audit Tinding Torm
- Fart 1: Documentation and Identification of Responsible Supervisor A. Tindint
Description:
Tinding Number: ll- %- @a - N
- s. G Acuenz RA% coui uot.o auvow.adeavr s'n MARA Auditee: CY,(MPl. MP2, MP3, beses,a ua,'s as .
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(NOTE: A Noncot:pliance I Y N recuires a Yes)
- 2. Corrective Actions Tricriip:
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- t Part 1: Documentation and Identification 'of Responsible Supervisor l l
, . I. . Tinding
Description:
J Tindint Number: _ ll- 2(0 -8f.o - 6~ ! d Cousioctt siwt:M.t tarioo oF dair SIhtA *
- Auditee: C1, MP3, MP2, MI 3, j i
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b A. Finding DescripEdon: I' Tindinr Number. )_I- D - N - 0 Coas.bt4L crsrased.41 a3 StAvatmcurm ALAfdA Auditee: F CY,~lMP3, MP2, MP3, F. dea.dicaroes B8t e ott ste u Lt4&o to ner as eks** MP1,2,&3' POSL' WDL c5eaca o paarew w Artm i coo 4o u roes nuo we woe = des q l i ;
,B.
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. H -
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(NOTE: A Noncompliance I Y N requires a Yes) , n , s.
- 2. Corrective Actions ?:iority: -
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,.i hev. S Date 1/86 Page B/3-15 Health Physics Audit Tindint Torm
- Documentation and Identification of Responsible Supervisor
, Part 1: l l A. Tinding
Description:
Tinding Number: //- 2(o 7 l ' CY ,lMP1, MP2,11P3, NCO 2.0( PAAA 6 41 A* sh Al.AllA kaoc. *$~ Auditee: TRAiuluj Rgovis_ttrdurs not Aer Edgw rw(r. MPI 2,&3' POSL, NUDL RAB ; { B. _Cl a s s i fi ca ti on : D Noncompliance I_ - Violation of I la Noncompliance 11)- Violation of QCO 2.Q S w RUVLA Pacac. *$' D Deficiency l
'F D Recommendation Fembede sed 44/2R RyMim o g.r- scers'w 1 .l. d C. Immediate Actions Taken (if recuired) and Priority of Corrective Actions:
- 1. Immediate Actions Taken D E If yes, detail actions below:
(NOTE: A Noncompliance I Y N requires a Yes)
- 2. Corrective Actions Priority:
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Rev. 6 Date 1/86 PaFe E/3-15 Health Physics Audit Tinding Torn,
- l Part 1: Documentation and Identification of Responsible Supervisur A. Finding
Description:
Tinding Numbe_r,: ll- 2G -elo - 8 TNc, retovhteaduts for Aoa Procesva> AouA Auditee: MP2, MP3, R.duid un voo@ SE GlAS5dsidD 4u0 R.(Jas(D To f up CYg* "' 3 POSL ' h'UD* {'1
~
CLcanc3 Asss9,v d6sfewsscitirits B. Classification: D Noncompliance I - Violation of __ D Noncompliance II - Violation of _ D_ Deficiency I p.on fvan.m b(T Aks , sed AUMA
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[ 2 Recommendation] gg oaf g.goa y g l C. Immediate Actions Taken (if recuired) and Priority of Cerrective Actions:
- 1. Ic: mediate Actions Taken D 2 If yet. , detail actions below:
(NOTE: A Nonco:pliance I Y N requires a Yes)
- 2. Corrective Actions ?:Lority:
D Withi: 1 verhing day 0 Shen-:.er: days W Long-ter= -
- c:ths h:::::i=; 24s p:.ews4
- Ms Due by: Nsc fsb %/2/$.cu (( a1{stlxL Late Audizer La e I. Findi r True and iies ersibili:v:
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- 3. A diter Closee ::
Audi :: Date
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- F.IFIF.IS CI: Cc:perate /~AF.A Fr uti, ?t:- 3, ?:ocedure f3 i
I
f Rev. 6 Date 1/86 Page B/3-15 Health Phys.ics Audit Tinding Form
- Part 1: Documentation and Identification of Responsible Supervisor A. Finding
Description:
Tinding Number: 11 - 2(s - % C) Cousiota. ite d W3 rud Netwoo lo wwic,, Auditee: CY. MP1, MP2, MP3, ( [MP1,2,&3]POSL, NULL
- ALARA Coorou anf co mm udse.artu l
B. Classification: D Noncompliance I - Violatica of l D Noncompliance II - Violatien of D Deficier.ry - . M DEN"'", D"
- i i
[~5 RecoFendation) IP.4 Dart 5da11C ~3. t2 w I C. 'Icimediate Actions Taken (if reouired) and Pritrity of Corrective Actions:
- 1. Icimediate Actions Taken D ;K If ye s, detail actions below:
(NOTE: A Noncompliance I Y N requires a Yes)
- 2. Corrective Actions Prierity: .
D Within 1 vorhing day 0 Short-term days Y Long-term ~ sc= hs o r= u f ".C E nue by: 9 l.,/n ~K<. - (L(L - - n/m/u d**Merivs 4creo h,, w Late Ani:.tcr Late ' Tb ~da bdrcamauth
'D . Tisdi=r Irpe and Resaensibili:v:
T I.P. O Non-E.P. Ie.spensible Supr.: 4)/4 I. Arinowiedre ent: PM. Esir ivrda.a & h A VEu.L4 i'Lfst.h 8C 5 t _1c: Eepreh_:_zzive 3tte
?z-: 2: Cerre::ive A::ie:s Dor ==e _ztic: z d Ez=agement Review A. Cc=ertive Artic=s Tzher:
- 3. 3zte cf Cere:-dre Ar-ie s:
?.erpe .sible 5 pc:-._s c:
_ LI e C. E_-W ewe d b : 5 z :.c: Ser. 5=;::.. Late 5 ::1c: 5 p*- te der: Late
- 3. Auditer Closeo ::
Andi_:: Let e Par: 3: Ezzefect:0 Dve -~iev 5upr. Ez d. Pre . 5e: tic:/2:2:2 g e: . IJ 3
- F.E?IEE';CE : Corportte LA.?.A Ernet1, Par: 3, Procedure s3
.. e$ . .
Rev. 6 Date 1/86 Page B/3-15 Health Physics Audit Tinding Torm
- Part 1: Documentation and Identification of Responsible Supervia.or A. Tinding
Description:
Tinding Number: 11- 2L -8G -10 be'oeri., RJ.Assdaluj we (2ssAuss; 31(;rg fos N Auditee: r CY , MP1 MP2, MP3, Amtm parnia or ryg Pu led rs/derA) mm wt AoS L MP1,2,&3 POSL, NUDL sogaasoa. ro ruc u"er AN co eb,Lermt, y smrr, ori. e terwTec.ur ALAttA cooeo,uaro,a B. Classification: C Noncompliance I - Violation of D Noncompliance II - Violation of D Deficiency r (2 Recommendation) Volt (v/tTut L %dTAk% , see ALAaA A@its..ss e o ttT' 3 d'c rto.3 ~1. 7. 3 u C. Immediate Actions Taken (if recuired) and Priority of Corrective Actions:
- 2. Ic: mediate Actions Taken D 2r If yes, detail actions below:
(NOTE: A Noncompliance I Y N requires a Yes)
- 2. Corrective Actions ?:iority:
D Vithi I w.+:hing day 0 Shon-ter::: days & 1,ong-ter= months Cz:.:cti Y Due by: H Ns'l8'1 W^ - - et{ssltc do/uttan*vd A e rio s b oc b are
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- 3. 7'-'"r True and Restensibility:
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4
- 3. Dzte cf Cere::ive A:-iers:
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- FZ~EEENCE: Cc pcra:e >* !.?.A ):22:al, ?En B, ?:oeeinre s3
or .o hev. 6 Date 1/86 Page E/3-15 Health Physics Audit Tindint Form
- Part 1: Documentation and Identification of Responsible Supervisor A. Finding
Description:
Tindint Number: Il- % -Sb -ll P4-(mpn4sitd A4NA [m Auoir R(PMS/ Git'irits Auditee: CY ,1 tipi , tiP2, MP3, AND ( ET Asciss FiZDBACX M6c444rD't5 FoR po7irie. Avoo MP1,2,L3] POSL, hvDL OF Avoit Et.sutTL TutoogH THC A4.AieA <been/aJare/L Te Twc JoBMsk LEA 6Ct. B. Qassification: D Noncon:pliance I - Violation of D Noncompliance II - Violation of D Deficiency l Recommendation} rocr. Famd't Dt 74 h 3 ' 546 ALA'LA AEAI'do )
Epo* A?.a D. :al, ?t-: 5, ?:ocedure s3
., 4: *
~* Rev. 6
' ' Dste 1/86 Page B/3-15 Health Physics Audit Tinding Torm
- Part 1: Documentation and Identification of Responsible Supervisor A. Tinding
Description:
Tinding Number: } l % - 17 Rt Assess twc rtesgoosh6.4T'ics Foet Ano useor hP Aud) tee:
' CY, & tiP2, MP3, locaw Avt,w.ttng Fo<i. vio' mons oF /kARA Cont / tots. fiP1,2,&3 , POSL, NL"DL Coas',atiz. smptemts.nAnou of SemG LoJR. LluGu EurottedMeni roog yg B. Classification: D Noncompliance I - Violation of D Noncompliance II - Violation of D Deficiency c~
3 Recommendation \ f * f**C- '**k's '" M MA A *4i$ f? 4' J R& pear S& coo.3 3.2.$ C. Immediate Actions Taken (if reouired) and Priority of Corrective Actions:
- 1. Immediate Actions Taken D D If yes, detail actions below:
(NOTE: A Nonce =pliance I Y N requires a Yes)
- 2. Corrective Actions ?:iority:
C Wi hin I verking day : Short-term days Erlong-ter= - months C . m .- .. Due by: 4 fi s'!8') fiate YM Ani:.te: 82 f84. [% Late
- 3. 74- '# r 'Ivpe and Resce=sibili:v:
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Rev. 6 Date 1/86 Page B/3-15 Health Physics Audit Pinding Porm
- Part 1: Documentation and Identification of Responsibic Supervisor A. Finding
Description:
Finding Number: N % ~O R4 Assess twe sssu Aub ry fB oF s.oog4E/ts e,JofAAoS. DETMm'u'vy Auditee: CY, h tiP2, MP3, Paovioswtt>cte.co uomen MPI,, &3 , POSL, NUD.a. E st , c,u%ues i sp(6n<yluj P4s%s/4Mrics, enersons or PCdN"'*")o<a ,Nu, RAS
%n me rwo os For moahmeiwt Twd t+JMG6C of k>LKeds. cooi.
B. Classification: C Noncompliance I - Violation of D "# "** ^ #" 5 5 * * * " " - D Noncompliance II - Violation of D Deficiency p m,., g m ,,; laRecommendation) Ftper seen'w 3.24 C. Immediate Actions Taken (if recuired) and Priority of Corrective Actions:
- 1. Immediate Actions Taken D F If yes, detail actions below:
(NOTE: A Noncompliance I Y N requires a Yes)
- 2. Corrective Actions ?:iority:
D Within 2 verhing day 0 Short-term days Y 1ong-ter= - nonths C J f ? f n = nue 37: y6r/m w/2/k(6 - - n/d de/utterive Anni >~ ' sue h Art Sz .e Antto: Date Tb "iist derstm,Les I. Findirr Irre and Resuensibili v: O E.P. 2 Non-E.P. Responsible Supr.: f)!A ron ru'es AAA/LA E t-l H I. Achsceledre=e :: rEA. C.#7 ivstruiem
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- 2. Dzze cf Cc=er:ive A:-ic s:
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l L - - - - - - _ _ - - - _ - - - - - ._
_6, . .. Rev. 8 Date 1/86 Page B/3-15 Health Physics Audit Tinding Term
- Part 1: Documentation and Identification of Responsible Supervisor A. Finding
Description:
Tinding Number: ll-2G - SG - 14 Gaveo49tt Foe cQvAuteuj 6ysu445 Auditee: CQMP1,11P2, MP3, Provide m obiu9 pDerou 5 y sl o b ,aidrida Fott T?fAc%) dygosurcs, rg/ ,)MP1,2,&31 AcTuS POSL, NUDL
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[2 Recommendation) i rtv 5dedoo 3. 2. 7 At4(zg g 7t3,33g] C. Immediate Actions Taken (if reouired) and Priority of Corrective Actions:
- 1. Immediate Actions Taken D R If yes, detail actions below:
(NOTE: A Noncompliance I Y N requires a Yes)
- 2. Corrective Actions Priority: '
2 Within I werking day O Short-te:m days V Long-te== - conths ResPoeJ54 Eu_cu_..m Ar w Due by: d <nterive Acn'oa bag 6ere Nf s i fB7 Late MMM Ani:. tor Late o /4 B4 To 24 Dememot s
- 3. Findi r *frue and ResOe:sibili:v:
E.P. 3'Xen-I.?. Responsible Supr.: A Pc rwi' s Amu,'s x 61 I. A:hnowledrement: PH 6<ir inreasicac c.s.c.se-o,a ue m ec. ears d/u /sc 5_z :.c: Ee::es ::::ivb ' Lzte Mb rah ~
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- 2. Dzze c! C =e: ive A:-iens:
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- EI?I?.IN CE : Ccrporate JOJ.A Et=uti, ?cr: 5, Procedure 63
.'4 . Rev. B Date 1/86 Page B/3-15 Health Pnysics Audit Tinding Torm
- Part 1: Documentation and Identification of Responsible Supervisor A. Finding
Description:
Tinding Number: //- 2la- 6(o lf luvCsricprt p t vu er P&<te 4 vest TLD W . P't. Auditee: r CX ,] MPl . MP2, MP3, Rosvos For Avua Pdttsou-44m WA/Lisoor of MD P6AwTs to otwert. #Juc toso. Psa,ars , MP1,2,L3,' POSL, NUDL g j B. Classification: D Noncompliance I - Violation of D Noncompliance II - Violation of D Deficiency
}or Fut2.7mett be re, s
( 2 Recommendation) e Rzro/Lt Ed e rdsi) 3.3 set M 4 @ 8dC s C. _Immediate Actions Taken (if recuired) and Priority of Corrective Actions:
- 1. Immediate Actions Taken D B* If yes, detail actions below:
(NOTE: A Nonco:pliance I Y N . requires a Yes) I
- 2. . Corrective Actions Priority: -
0 Withi: I working day 0 Short-ter: days W Long-ter= " co=ths
^
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g April 22, 1987 NE-87-RA-312( TO: h A. S J n, W. G. FROM: c rath, R. . Crandall (Ext. 3754) (Ext. 5863)
SUBJECT:
ALARA Program Appraisal
REFERENCE:
- 1) NE-86-RA-1229, Same Subject, M. R. Bellman, etc.
to S. E. Scace, dated December 18, 1986
- 2) HP-87-165, D. B. Miller to R. C. Rodgers, dated March 17, 1987
- 3) MP-102-74, S. E. Scace to R. C. Rodgers, '
The attached are responses to recommendations concerning the ALARA Program contained in the reference. The items addressed are applicable to the RAB ALARA Section responsibilities. Station responses are provided in References 2 and 3 also attached. The attached defines an action plan and schedule for carrying out recommendation responses. Please contact us with any questions. RNM/rdo '~ RAC3.37 Attachments cc: D. B. Miller S. E. Scace E. A. DeBarba J. P. Kanqiley F. C. Rothen H. W. Siegrist R. K. Doherty D.W. Fitts " J.O. Powell S. M. Turowski ROUTE TO: R. T. Harris R. C. Rodgers R. A. Crandall S. M. Torf J. G. McHugh OS70 REV. 3-83
Attachment
- 1. Recommendation 11-26-86-1 Goals which have been established do not reflect the actual work planned and often are not communicated to the workers.
Resoonse The goals development process has been revised to more closely reflect the actual work. These goals will be established with input from line supervisors who will be held accountable for performance against those goals. The goal setting process along with other measures of estimated exposure (INPO Guideline Based Targets) will be formalized in a Corporate ALARA Program procedure. A draft of this procedure will be available for review by Juna 15, 1987.
- 2. Recommendation 11-26-86-2 Communication of the RAB's function should be improved.
Response
As a result of ALARA Service Redesign, the method of reviewing and monitoring projects during the design and construction phase is being modified. A corporate ALARA procedure will be issued to describe this new methodology and will define the responsibilities of the RAB and the unit ALARA will define coordinators concerning design phase reviews and monitoring of projects. The draft of this procedure will be available for comment by June 15, 1987. Additionally, other major RAB functions are being addressed as part of service redesign. For example, RAB's role during outages and in the goal setting process will be better defined through either procedures or improved communications with the station. 3.& Findings 11-26-86-3 and 11-26-86-4 4. ALARA Design Installation Review implementation problems.
Response
Revisions to the project ALARA review and monitoring process is addressed in the response to #2 above. , 1
- 5. Recommendation 11-26-86-5 l Standardization of ALARA Coordinators function.
- i. i.
Response-J Response to this issue is-the responsibility of station management. See MP and CY' responses. RAB will reevaluate RWP coding with-considerations of interactions with PMMS.
- 6. Recommendation 11-26-86-6 Establishment of department ALARA coordinators.
Response
Response to this issue is the responsibility of station management. See MP and CY responses.
"7 . Finding- 11-26-86-7 Deficiencies in ALARA Training.
Response
The Nuclear Training Department has the action to develop a discipline specific training program. RAB along with the stations and Generation Engineering and Construction, will provide support for the development of this program. The program will be initiated in time for the MP-1, 1987 outage to address initially construction supervision. It will be expanded to address other job classifications in late , 1987-1988.
- 8. Recommendation ll-26-86-8 Define responsibilities for job procedure reviews.
Response
Corporate ALARA procedure #5, "ALARA Job Reviews" will be revised to be more applicable to repair type jobs and clearly assign responsibilities. A draft of this procedure revision will be available for review by June 15, 1987.
- 9. Recommendation 11-26-86-9 ,
Improve communication of ALARA controls.
Response
a Response on this issue is the responsibility of station mangement. See MP response. 1G. Recommendation 11-26-86-10 Define responsibility for pre-job briefing.
t.> .-
.+
Response
. Response on this issue is the responsibility of station management. It will be addressed in the rewrite of ALARA Procedure #5Las!the responsibity of job supervisor. Station HP will assist on all.hi-rad area jobs.
-11. Recommendation.ll-26-86-11 Re-emphasize audits of ALARA controls.
Response
Station Responsibility. See CY and MP responses.
.12. Recommendation'll-26-86-12 Responsibilities and use of stop work authority.
Response
Station Responsibility. See CY and MP respones.
- 13. Recommendation 11-26-86-13
Response
Station Responsibility. See CY and MP responses.
- 14. Recommendation 11-26-86-14
. Provide guidance, tracking, and action level for exposure equalization.
Response
Guidelines for exposure equalization will be defined in draft form for the Millstone Unit #1. outage, if it is decided that current controls are not adequate.
- 15. Recommendation 11-26-86-15 Use permanent TLD results for comparisons of NU plants to" other plants.
Response
Permanent TLD results are used by NU as input to NUREG-0713 for comparison to other plants and therefore, there is no 1 inconsistencies in the basis for comparison. Annual totals based on TLD's and PIC's are typically within 10% of each other.
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~
URANCH June 3, 1987 NE-87-RA-512 i TO: S. E. Scace, D. B. Miller,'R.mC n Rodgers WesdL - - U. /J. dk M.R. Bellman, W. G. Collins FROM: (Ext. 5279) (Ext. 5472)
SUBJECT:
ALARA Appraisal Response Evaluation
REFERENCES:
- 1) NE-86-RA-1229, ALARA Program Appraisal, M. R. Bellman /W. G. Collins to S. E. Scace, R, H. Graves, R. C. Rodgers, dated December 18, 1986
- 2) HP-87-16 5, CY Response , D. B. Miller to R. C.
Rodgers, dated March 17, 1987
- 3) NE-87-RA-312, RAB Response, R. N. McGrath/R. A.
Crandall to M. R. Bellman /W. G. Collins, dated April 22, 1987
- 4) NE-87-RA-372, RAB Response, R. A. Crandall to M. R. Bellman /W. G. Collins, dated April 22, 1987
- 5) MP-10274, Millstone Response, S. E. Scace to R. C.
Rodgers, dated April 28, 1987 1.0 Introduction In November 1986, an appraisal of the ALARA program was conducted at both Millstone and Connecticut Yankee. Reference 1 detailed the,two findings and 13 recommendations,
"~
identified during the appraisal. l Responses (References 2 through 5) have been received from ' Connecticut Yankee (CY), Millstone (MP) and the Radiological Assessment Branch (RAB). A E, a result of our review of these l responses,_three of the fifteen items have_bmE_n closad-with i no further action required. Of the remaining open items, the responses and proposed Corrective Actions for nine_of a the items were acceptable. A further response or ~ clarification is requested for three of the items. The Corrective Action commitment for several of the findings was for the development of a draft procedure. Since issuance of a draft procedure for review would not complete the corrective actions, a final completion due date will be requested upon issuance of the draft procedures. T OS70 REV,3 83
The following-i.s a summary of the status of each finding. This'it followed by a discussion of each of the items. ( 2.0 Finding Status Summary Lead Due Date Responsibility Action Required Finding No. Status Issue a draft procedure ( 11-26-86-1 Open 6/15/87 RAB 11-26-86-2 Open 6/15/87 RAB 11-26-86-3 Open 6/15/87 RAB 11-26-86-4 Open' 6/15/87 RAB 11-26-86-5 Open 9/30/87 RAB Evaluate use of PMMS codes Standardize RWP coding Open 6/1/87 MP plus other commitments 11-26-86-6 Open 6/30/87 MP & CY ,. ,A further response is
~~ requested 11-26-86-7 Open 7/31/87 RAB Plans for further ALARA training will be evaluated Issue a draft procedure 11-26-86-8 Open 6/15/87 RAB A further response is i
11-26-86-9
~ ' '
Open 6/30/87 MP - requested Issue a draft procedure 11-26-86-10 Open 6/15/87 RAB 11-26-86-11 Closed - - 11-26-86-12 Closed - - A further response is ! 11-26-86-13 open 6/30/b7 MP,CY, & RAB requested 6/15/87 RAB Evaluate questionnaire 11-26-86-14 Open and determine further action 11-26-86-15 Closed - - 3.0 Finding Response Evaluation I 11-26-86-1, ALARA Goals: ) RAB has committed to formalizing the goal setting process in a Corporate ALARA Procedure. A draft of the procedure will be available for review by June 15, 1987. This item remains open. it 11-26-86-2, Communication of RAB's Functions: RAB has committed to the issuance of a draft Corporate ALARA Procedure which will define RAB's responsibilities during the design phase of a project. This draft procedure will be available for review by June 15, 1987. Concerning RAB's , functions during an outage, the commitment to address this issue during Service Redesign is acceptable. Memo NC-87-RA-361, dated April 15, 1987, was an example of )' progress in this area. The memo established a schedule of meetings with the Station Services Superintendents "to determine their outage support needs and protocol for RAB's site presence...". This finding remains open.
I l . 1 11-26-86-3 and 11-26-86-4, ALARA Desigr. Review Process (including RAB's involvement, change control, and installation review): The RAB commitment to issue a draft Corporate ALARA Procedure to address new methodology for review and monitoring of projects by June 15, 1987 is aceptable. Note that the Millstone response suggested that changes may be required at the NEO Procedure level. R. A. Crandall agreed that the need for NEO Procedure changes will be evaluated once the methodology has been established. These two items remain open. 11-26-86-5, Standardization of Unit ALARA Coordinator Functions: The CY response to this finding is acceptable. The CY recommendation that the PMMS codes be evaluated for use in the RWP system was accepted by RAB. R. A. Crandall offered a verbal commitment to complete this evaluation by September 30, 1987. The MP response was also acceptable with commitment to standardize the coding of RWPs by June 1, 1987, to standardize the allocation of departmental exposure goals by May 1, 1987, and to standardize outage and annual reports by May 1, 1987. The additional commitment to utilize all ALARA Coordinators during one unit's outage should also be effective. 11-26-86-6, Consider establishing Departmental ALARA Coordinators: The CY response accepted the concept of a " Project Coordinator". Will the responsibilities of this coordinator be specified in a formalized procedure? Will any specialized training be provided? If so, when? The MP response focused on the use of the existing project staff, i.e., PDCR engineering staff and assistant supervisors. The response stated the need for more training and procedural guidance but offered no commitments. What procedures will be revised? What training will be offered? When will these items be completed? A further response to this finding by both MP and CY is requested by June 30, 1987. This finding remains open. a
_a_ 11-26-86-7, ALARA Trainina: As specified in the RAB response, an ALARA Awareness Training Program has been initiated for Construction Supervision. Per a disucussion with L. A. Chatfield, Manager, Nuclear Training, the schedule for expanding this training to other job classifications will be discussed during an upcoming Training Program Control Committee (TPCC) meeting in June. This finding remains open. Plans for further ALARA training will be evaluated by the auditors by July 31, 1987. 11-26-86-8, Job Procedure ALARA reviews RAB has committed to revising ALARA Procedure #5 with a draft of the procedure available for review by June 15, 1987. It was noted that there was disagreement between the CY and MP responses on this recommendation. CY maintains i that only the Job Supervisor has the expertise to review the procedures. Millstone suggested that PORC should be inolved in the decision of which procedures need the review. RAB has committed to evaluating the station responses during the ALARA procedure revision process. This finding remains , open. l 11-26-86-9, Communication of ALARA Controls: This finding was directed to MP only. The MP response stated:
"The present method of communicating ALARA controls via the Job Supervisors and posting controls at the work site is valid. The failure of the current system is in not making the Job Supervisor accountable for failure to inform his personnel of those controls and ensuring they are in effect.
The responsible supervisor for the job must be well defined, his responsibilities specified by procedure and a deficiency / audit program has to monitor his performance and provide for correction of deficiencies." While we agree with the response, further information is required. What changes are going to be made to correct the
" failure of the current system"? Where will the responsible a
supervisors for the job be defined? In what procedure will the Job Supervisor's responsibilities be specified? ALARA Procedure # 5 or a station procedure? What Deficiency / Audit program will monitor the Job Supervisor's performance and provide for correction of deficiencies? This finding remains open and a further response to this finding, by MP is requested by June 30, 1987.
1 " l 26-86-10, Pre-Job Briefings: l RAB's commitment to address the responsibilities for pre-job L briefing. in the rewrite of ALARA Procedure # 5 is acceptable. As in the response to 11-26-86-8, this procedure draft should be available for review by June 15, 1987. . Note that the MP response.did not specifically commit to having Station Health Physics involved in the pre-job brief for all High Radiation Arca jobs as mentioned by CY and RAB. This should be clarified in ALARA Procedure # 5. This finding remains open. 11-26-86-11, ALARA Control Audits: All responses were acceptable. This finding is closed. RAB should consider adding references to the station procedures which address ALARA control audi.ts in. ALARA Procedure # 5. 11-26-86-12, Stop Work Orders and Lower-Level Enforcement Tools: The responses.to this' finding were acceptable and the finding is closed. 11-26-86-13, Determining the number and type of workers on a job: The responses have all seemed to agree that an excessive man-loading problem exists. However, no specific corrective actions have been specified. A further response to this finding by MP, CY, and RAB is requested by June 30, 1987. 11-26-86-14, Exposure Equalization: The RAB response to this finding stated:
" Guidelines for exposure equalization will be defined in draft form for the MP Unit #1 outage, if it is decided that current controls are not adequate."
R. A. Crandall has indicated that a questionnaire would be submitted to the Station Superintendents and Vice Presidents with a response requested by June 1, 1987. The results from
-this questionnaire should indicate if further controls are deemed necessary by-upper management. R. A. Crandall offered a June 15, 1987 commitment to evaluate the a questionnaire results and determine further action, if any.
This finding remains open. u___________ _ _ J
11-26-86-15, Use of Permanent TLD versus PIC results for Person-Rem comparisons: The responses to this finding were acceptable and the finding is_c,losed. 4.0 Attachments 4.1 CY Response, HP-87-16 5 4.2 RAB Response, NE-87-RA-312 4.3 RAB Response, NE-87-RA-372 4.4 MP Response, MP-10274 MRB/WGC:rdo HWS 5.2 Attachments cc: E. J. Mroczka (w/o Attachments) L. A. Chatfield W. D. Romberg " " R. A. Ctandall~ C. F. Sears
" H. W. Siegrist (w/o Attachments)
R. T. Harris
" " R. K. Doherty E. A. DeBarba D. W. Fitts "
J. P. Kangley S. M. Turowski " B. L..Granados J.O. Powell H. E. Clow [
Page No. 1 MILLS 7DNE 12/14/87 ALARA APPRAISAL FINDINGS FINDING SEVERITY APPRAISAL DATE DUE DATE CORPICTIVE DATE CIOSED CATEGORY ACTION TAKEN 11-26-86-1 RECOMMENDATION 17 11/15/87 / / / / 11-26-86-2 RECOMMENDATION 17 11/15/87 / / / / 11-26-86-3 NONCOMP-II 17 11/15/87 / / / / 11-26-86-4 RECOMMENDATION 17 11/15/87 / / / / 11-26-86-5 RECOMMENDATION 17 06/01/87 06/03/87 09/04/87 11-26-86-6 R
' RECOMMENDATION 17 06/30/87 10/19/87 10/19/87 11-26-86-7 NONCOMP-II 17 07/31/87 10/19/87 10/19/87 11-26-86-8 RECOMMENDATION 17 11/15/87 / / / /
11-26-86-9 RECOMMENDATION 17 11/15/87 / / / / 11-26-86-10 RECOMMENDATION 17 11/15/87 / / / / 11-26-86-11 RECOMMENDATION 17 04/15/87 06/03/87 09/04/87 11-26-86-12 RECOMMENDATION 17 04/15/87 06/03/87 09/04/87 11-26-86-13 RECOMMENDATION 17 06/30/87 10/19/87 10/19/87 11-26-86-14 RECOMMENDATION 17 06/15/87 08/31/87 09/04/87 11-26-86-15 RECOMMENDATION 17 04/15/87 06/03/87 09/04/87 Findings 1, 2, 4, 8, and 10 are waiting for final approval of ALARA Procedures 4, 5, and 9 before closecut. Although final closecut has not occurred, most of the recommendations were implemented in 1987.
l Docket No. 50-336 B12777 { i I l 4 4 i Attachment 5 , Millstone Nuclear Power Station, Unit No. 2 l Additional Information for Forty-Year Operating License Extension l l l l 8 December 1987 l . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ i
iOO
. ' ."s. , .
b~ NORTHEAST UTILITIES tal C0fessECTCff LNpsf asso.U.S. CO - REVIEWED BY g 1 ...-.um.'""" --
.o .. . . co R. A. C.
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L L J .. u.. ..s..a Co-- 1. L H. I g_
.E.1 M I -'
g ;,n e l -- March 4, 1987 tL NE-87-RA-177 R.C.R.~ ?Mu p R.T.H.
~
C. F. S. TO: S. E. Scace ' ' kAb Tiegrist FROM: H.W. (Ext. 3591)
SUBJECT:
Trend Analysis of Millstone Health Physics Audit Results
REFERENCE:
- 1. Memo (NE-86-RA-185), H. W. Siegrist to W. D.
Romberg, " Trend Analysis of Millstone Health Physics Audit Results", dated February 14, 1986
- 2. Memo (NE-86-RA-1229), M. R. Bellman, W. G.
Collins, and C. A. Flory to S . E. Scace, R.H. Graves, and R. C. Rodgers, "ALARA Program Appraisal", dated December 18, 1986 Audits of Millstone Station's Health Physics Program are conducted by the NUSCo Radiological Assessment Branch (RAB) in accordance with NU's ALARA Program Procedure #3. An analysis of the findings, resulting from the audit program, has been conducted to identify any trends which may be useful in improving the Health Physics Program. A trend analysis report is attached. The attached trend analysis report updates the last trend analysis report (see reference 1) which considered audit data from 1980-1985. The objective of this analysis is to identify any continuing trends based on findings over the last four years, 1983-1986. The following conclusions are made based on the trend analysis report. o Overall Millstone Station's Health Physics program has been effective in maintaining compliance with Federal Regulations, Technical Specifications, and implementing procedures. o The total number of Audit Violations has decreased and this decrease is reflected in all audit categories. This trend could be continued with further emphasis on the categories of Area Posting, RWPs, and Radioactive Material Control. OS70 REV.3 63 041
i44 , , o- 'There are no continuing negative' trends identified for
. violations which are the responsibility of the Health Physics Department. For non-HP violations there are two continuing
. negative trends -- worker control and use of dosimetry and control of locked high radiation areas.
o There are two areas of weaknesses identified in the' NRC SALP in which there are no continuing negative trends - the ALARA and Radwaste Programs. A recent ALARA Appraisal. (see ! reference 2) ' indicates a weakness in the ALARA Program. o More emphasis on control of High Radiation Areas-(e.g., proper posting of areas, ensuring that workers close locked high radiation area doors during and upon completion of work) could eliminate the potential for NRC Severity Level IV or ' higher type violations. HWS/ CAP /rdo HWS El.28 Attachments cc: E. J. Mroczka C. F. Sears W. D. Romberg R. T. Harris J.P. Kangley B. L. Granados ROUTE TO: R. C. Rodgers I. L. Haas W. G . Collins M.-R. Bellman C.A. Flory RAB File
w* *,
- NUSCO RAQ1 Health Physics Audit Findings 1986TrendhAnalysisReport for Millstone
- 1. TOTAL VIOLATIONS,AND AUDIT MAN-HOURS TRENDS Total violations and onsite audit man-hours are plotted in Figure 1 for each year from 1981 to 1986. Violations include non-compliance and deficiency findings but not recommendations.
From Figure 1, the fluctuation of total violations indicates a positive trend toward a reduction in Audit Violations. The onsite audit manhours represent only those hours spent in actual audit investigation at the station. It does not include hours spent in preparation for the audits or follow-up of audit findings. The fluctuation in audit manhours is directly related to the length of refueling outages. The audit procedure, requiring monthly audits, increases the audit frequency to weekly during outages because of the increased HP activity during those time periods. There were outages for seven months of 1983, three months of 1984, four months of 1985, and three months of 1986. Because of Unit Three startup, the number of audit man-hours in 1986 were greater than in 1984.
- 2. DISTRIBUTION OF HP VIOLATIONS FINDINGS Figure 2 shows the distribution of those violations for which the Health Physics Department has responsibility. About half of the HP violations occurred in three categories -- Area Posting, External Exposure Control, and RWPs. Findings in 1986 show a movement away from this distribution with six findings distributed in six different categories. The six categories were RWPs, Dosimetry, Area Contamination Control, Radioactive Material Control, Internal Dosimetry, and Radioactive Shipments.
Although a large percentage of the HP violations for the years 1983-1986 are in three categories, this does not imply programmatic weaknecses within the categories. These categories are frequently audited because the programs in these categories are broadly applied and easily observable. The distribution of HP findings responsibilities for the years 1983-1986 are as follows: I s Unit # HP Findings 1 17 2 24 3 0* l Station 28 Audits of Unit 3 commenced in December 1985. l L ___- _.
4 1 , 4
- 3. RECURRENT HP VIOLATIONS For the four year period 1983-1986 the HP violations findings were analyzed to identify recurrent violations. Three recurrent violations were identified. A recurrent violation, for the purposes of this report, is defined as three or more ~
findings.
- 1. There were three failures by HP to enter a worker's available exposure on an RWP. The failures occurred in February 1986, December 1985, and May 1984.
- 2. There were eighteen cases where HP either failed to or improperly posted an area. The most recent case was in March 1985. This is not a current trend as indicated by the date of the most recent violation. Also, radiological posting is the most heavily audited HP practice; the absence of recent findings is a positive indication of an improved program.
- 3. There were four failures to tag bags of radioactive material, the most recent in May 1984. As in the category of radiological posting, the category of radioactive material control is heavily audited. The absence of recent findings is a positive indication of an imoroved program.
In the opinion of the auditors, none of the above recurrent violations can be construed as a trend toward decreasing HP Program effectiveness.
- 4. DISTRIBUTION OF NON-HP VIOLATIONS Figure 3 shows the distribution of violations which were not the responsibility of the Health Physics Deoartment. The Non-HP Violations also indicates the trend in violation The distribution of findings reduction in all categories.
among the categories has remained the same for both three year periods and f or 1986. As was the case in HP findings, the categories with a large percentage of findings (radioactive material control, RWPs, and area posting) are those which were most heavily audited. The distribution of non-HP findings responsibilities are as follows: Unit i HP Findinas e 1 16 2 16 3 1* Station 10
- Audits of Unit 3 commenced in December 1985.
/
4
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=
3 ! ; - ( l \
/
r 5, RECURRENT NON-HP VIOLATIONS >7 There were eight recurrent (three or more findiwp) non-HP ' violations in the four year period 1983-1986. '/ ' ,
/ ,
- 1. There were five cases of verkers without dosimstry, the '
most recent in May 1986. This type of viblation appears to stem from poor worker attitude on dosimetry. Wor ker s , . are of ten observed not rai.ntainlag positive control of dosimetry and wearing dosimetry 'e.n improper,'nd. locatirch on the body. This is a continuing negative tre (
- 2. There were four findinas concerning locked bigh radiation areas, the most recent in November 1986. Tris type of finding is a significant concern becante! it identifies a lack of control over areas where perraanel could receive ,'
substantial expostres. The trend for this type of finding appears to be a continual one. 'This violation type is a violation c5 technical specifications.
- 3. There were five findings for worker failure to initial an RWP, the most recent iq February 1986. Ihr;other violations occurred in October 1985, May 1983, 'tay 1984, and November 1983.
- 4. There were four findings on improper use of protective ,
clothing, the most recent in June 1985. The other violations occurred in August 1984, June 1984, and January 1984.
- 5. There were five findings concerning movbE radiological postings, the most recent in June 1965. ,The other violations occurred in March 1985, February 1982, March f 1984, and October 1983. ,
- 6. There were three findings for leaving r.b d ioa c tive materials outside of the RCA, the most recent in January 1986. The other violations were both in May 1984.
- 7. There were three findings for failure to have HP tag ,
radioactive material, the most recent in June 1984. The < other violations were in May 1984 and September 1983." The last two types of violations have a commob f actor in
- that workers f ailed to inform HP concerning handling of radioactive material.i ,
As stated above, worker use and control of dosimetry and < control of locked high radiation areas are continuino negative trends in non-HP violations. Ia the opinion of the auditors, none of the other recurrent non-HP violations can, be construed as a trend toward decreasing HP Program effectiveness. > w 1- - -
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- 6. COMPARISC# F FINDINGS ?q[NetC SEVERI'r ASSES, j
] l d[ Table i indicates both, the nlidit findc.ns alatsific$tions and
, .I 7
S
/ NRC se'verD,y claske s f or 19D rabough' 3 9% . Most"ef the ;
^ audit. viol'at' ions VHe l gf relative %.y mihor safety significance 1 4 (Severity Level V). #
fhe NRC SevcMity Level I\ type 4 violations in 1984 and 1985 involve impr'eperly posted Hig'n y ' ,j'
/ Radidtion Aread or open and, unoccupied " Locked
- High '
l } '[ Radia: 1,cr pro 5s. Golocked kaJh Radiaticn Area doors were ,
'- also subjec'ts 'of NRC ,ihspection Severity Level IV violatiche at Millstone in Juns 19 8 5 69(JJAnuary/198 9 6. One audit violation in'1986 is judged to'orua Sg,rerity Level IV, because ~it ir.volved a signiLicaiN management problem p~ involving poten'tial for personnel overexposure. The audit violation was f a/d eficiency finding for inadequate management ;l I
b y J. control over the , Unit 2 solid radwaste stor age room.
, i
/ Ti t other LfL6 Level IV audit violation was for a delibrate j
atthmbt by a werker to bypass a locked high radiation, area ga te . ' It was an indication of a " worker attitude problem with ,
/ j ppt rtial /et'41.qnificant degradation of the radiolo'gical 7
( I
/1 safety program / This /7?ola tion as rapeated in February I pS377a ve'ry d".gnificant r e' cur r e n c e . Although this repeat
< ,t/clation ocor: red af ti5.tr the reporting tine period, it needs to be.hiqFJighted bechuse it is a continuation of a Level IV
/, vic3ation, Continuation o2 Level IV vic'lations cut us at
' risk'for higher severity leve>. iiolations. 7:0CFR2, Apperdix l l
f, l'II notes that the severity level af a violation may be increased "if the circumstances surroun?iag the natter
' involve careless disregard of the requirements. . ." .
7T Ar e a ti_c ?. NRC Concern The NRC in its SALP for the ;:eilod itarch 1985 throvgh May 1986,ogave Radiological Coitrols e rating of three, the loweit rating. Therecuere three urers of concern whien
& caus4d NRR to give.the lowqst+ rating. These areas of, concern were the ALARA Progedd. ' Rrdwarte Program, and control of high 1 radiation areas. 0L'these three, on1p control of locked high radiation breas was identified as a centinuing negative trend in this repsrt. ' There were no recurr ent RA? audit violation
) fiadings in the categories of ALARA Procedures and Radwaste Sbipments for the four year period 19 8 3 - 19 'd 5 .
Ascause of the NRd concerns the two categories of ALARA Procedyrea and Radwaite Shipments have received increased audit attentionf n 1936 and will be audited more intensively f in 1902. For Radwaste Shipments there was only onetriolation finding
- in 1986. For ALARL Prd:pdure s there were two, vio2ation findings in 1986. Thefe were also eleven 1 I
reconn endations made in the category of ALA7A Procedures as a
, 'resul! of,a special ALARA Appraisal conducted in November 1986.' (spe RAB memo NE-86-RA-1229.) The significance of "this appraisal is that the ALARA Protjram hss been identified am an area of concern despite the absence of any trends in audit Tic ation findings.
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Table 1 Audit violation Severity Audit Program Violation ' Categories
- Non-Compliance I Non-Comoliance II Deficiency 1 36 6 1983 0 27 5 1984 11 3 1985 1 2 6 5 1986 Violations categorized according to NRC severity. levels *
- Severity Class I II III IV V 1983 - - -
1 42 1984 - - ~ 4 28 1985 - - - 1 14 1986 - - - 2 11 i
*The violation categories listed are from the " Northeast Utilities Corporate Management Program for Monitoring Occupational Exposures As Low As Reasonably ~ Achievable",
Part B, Procedure #3, " Audits of the Stations' Health Physics Programs".
- 1) Non-Compliance I - Violation of Federal Regulations, Technical' Specifications or By-Product Material license.
- 2) Non-Compliance II - Violation of station procedures or station orders, Corporate ALARA program.
- 3) Deficiency - No apparent violations, but a lack of approved wr itten procedures , wr itten documentat ion , etc . ,
to show compliance with 10CFR, Technical Specifications, Station Procedure or Corporate ALARA Program. k
**NRC Severity Levels are detailed in 10CFR2. 1 l
The number of violations assigned to the various Severity Classes in not official. Categorization is for informtion f only, and is subject to the interpretation of the auditor. Class IV violations typically involved the potential entry, l or the entry of a worker into either an improperly posted ! High Rapiation Area, or a High Radiation Area that lacked J such a posting, where a worker could potentially receive an ( exposure in excess of the limits of 10CFR20.101. Class V violations typically involved situations that had minor safety or environmental significance (i.e., failure of a worker to initial a RWP, inconsistent area postings, procedural discrepancies, etc.) L - -----------______________i}}