ML20210A131
| ML20210A131 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/31/1987 |
| From: | Deacon W BOSTON EDISON CO. |
| To: | |
| Shared Package | |
| ML20210A108 | List: |
| References | |
| NUDOCS 8705050020 | |
| Download: ML20210A131 (5) | |
Text
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0FFICE MEMORANDUM Boston Edison Company 'RMG Control Number To: R. G. Bird From: H. H. Deacon A$
/Wh Record Type A4.08 Date: 4/17/87 Dept. Doc. Non-Safety Related
Subject:
BOSTON EDISON COMPANY RADIOLOGICAL IMPROVEMENT PLAN (RIP)
IMPLEMENTATION PROGRESS FIRST QUARTER 1987 Distribution:
A. L. Oxsen J. E. Howard Dr. T. E. Murley (NRC)
NUORG Section Mgrs. C. White (General Dynamics) M. McBride (NRC)
NUORG Dept. Mgrs. IROC Members (5) c/o H. H. Deacon OCUMENT RIP Implementation Status ELEASE I.
A. Milestone Status i I gS231987 l RIP 7.3.3 (Milestone 3) - Due March 27, 1987 FOR USE 1.
ROL. ST ATION This final program milestone commitment involved several modifications to the process building access control area and is referred to as Phase I to distinguish it from a scope of additionally planned facility modifications not committed in the Radiological Improvement Plan (RIP).
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The scope of Phase I included construction of a new clothing change area, new health physics and chemistry work areas, and installation of several sophisticated portal monitors in a variety of plant locations.
The RIP milestone commitment is complete; however, one clarification is appropriate. During the second week of March 1987, a work scope change was necessary to resolve an H&V air balance problem identified during testing. The scope change required the installation of an additional control cable through a highly contaminated radwaste work area (Sample Sink #4). Currently, cable routing is on hold, while the work area is being decontaminated to reduce personnel exposure.
This work item is being carried on a Bechtel " punch list" to be completed prior to operational turnover. Mr. R. Nimitz (NRC Regional Inspector) was notified of the completion of the milestone on April 13, 1987. Formal NRC review of the milestone will be conducted during a future inspection.
This final RIP milestone completes Boston Edison's submittals of the total 209 program milestones (action items) committed to the NRC in response to the Boston Edison Radiological Improvement Plan (RIP).
Follow-up actions addressing program weaknesses remain to be completed, however, and are summarized in Section I.B.
0705050020 870428 PDR ADOCK 05000293 l R PDR
. Dept. Doc.
. To: R. G. Bird Date: 4/17/87 Page 2
Subject:
BECo RIP IMPLEMENTATION PROGRESS, FIRST QUARTER 1987 B. Radiation Protection Program Weaknesses Boston Edison Company's follow-up and closure of NRC Inspection open items related to RIP milestones, particularly Inspection #86-19, have not been timely, but are now nearing completion. A summary of various program follow items (weaknesses) and their respective completion schedules follow:
Identified Weaknesses
- 1. During the fourth quarter of 1986 (October), NRC Inspection
- 86-19 resulted in 48 BECo action assignments, with particular emphasis focused on program weaknesses, i.e., individual and group accountability, inter-group coordination and communication, and the Station goals program (ALARA); 21 of the action items are still open with final completion currently scheduled for 4/24/87.
Management emphasis has been and continues to be placed on the above programmatic weaknesses primarily Inrough NUORG Department and Section Managers. However, inter-group coordination and communications and accountability weaknesses persist. In an effort to correct these weaknesses, the following actions / methods have been implemented over the past seven months:
i l e Individual and group accountability has been and continues to be emphasized through the following practices:
Corporate, Department, and Section Managers met with the l Radiological Section Manager and agreed to aggressively pursue adherence to radiological requirements.
A Nuclear Mission, Organization, and Policy Manual has been developed and committed to by Managers and Group Leaders. Individual accountability is clearly communicated through the manual's policy statements and
. position descriptions of key management personnel. The manual is currently undergoing final revision for
, issuance as a controlled document.
Managers' and Group Leaders' annual performance evaluations will include ALARA performance indicators against which the employee will be evaluated.
Positive incentives are being offered for good performers (Employee of the Month - parking space).
On April 6, 1987, Managers, Group Leaders and Supervisors began monitoring personnel frisking performance at designated plant ares in accordance with a rotating schedule.
-. Dept. Doc.
. To: R. G. Bird Date: 4/17/87 Page 3
Subject:
BECo RIP IMPLEMENTATION PROGRESS, FIRST QUARTER 1987 e Inter-group communications and coordination meetings provide a forum for resolving radiological concerns and are taking place through the following activities:
- Regular morning and afternoon interdepartmental work status meetings.
- Weekly Operations Organization Manager meetings with the Station Manager.
- Weekly maintenance planning meetings attended by various group coordinators. These meetings produce work status updates, problem resolutions, and appropriate work priority adjustments which enhance inter-group communications, understanding, and work efficiency.
- Radiological coordinators have been assigned full-time to the Maintenance and Construction Management Groups to assist in ALARA planning for routine and special work activities.
e The Station ALARA goals program established group ALARA goals and an exposure budgeting process. Budget reports are issued weekly during outages and monthly during routine operation.
Work groups are now more involved in ALARA planning and monitoring of their exposures. At the present time, all work groups except the Radiological Section are below their allotted exposure goals. Ultimately, however, goal adjustments will be necessary to compensate for plant start-up beyond the original April 1, 1987 exposure budget schedule basis.
- 2. The Radiological Oversight Committee (ROC) in place during the RIP implementation phase identified 26 items for which recommendations were made. Currently, 19 of these items have been closed out by the Radiological Section Manager with the balance scheduled for final completion by 7/1/87.
- 3. An independent auditor's report on RIP implementation resulted in 25 recommendations. Currently, 22 of these items have been closed out by the Radiologleal Section Manager with the balance scheduled for final comple' ion by 4/24/87.
Dept. Doc.
. To: R. G. Bird Date: 4/17/87 Page 4
Subject:
BECo RIP XMPLEMENTAT10N PROGRESS, FIRST QUARTER 1987 II. Management Oversight A. Independent Radiation Protection Oversight Committee (IROC)
- 1. During the first quarter of 1987, the new Independent Radiation Protection Oversight Committee (IROC) was instituted to assist the Senior Vice President-Nuclear in corporate oversight of the PNPS radiation protection program. The new Connittee has replaced the previously-established Radiological Oversight Committee which provided management oversight of the Radiological Improvement Plan during implementation.- The new Committee (IROC) is examining previously-identified weaknesses in the radiation protection program as well as other areas of concern resulting from their ongoing assessments. The new Committee's assessment methods have been successful under similar circumstances at another utility. Direct involvement with key Managers, sub-committee participation with front-line supervision, and direct reporting to the Senior Vice President-Nuclear are the major Committee functional elements.
The previously-identified program weaknesses, particularly the accountability and communications / coordination and ALARA issues, have been and are continuing to be investigated through Committee interviews with key Managers and Group Leaders. Assessment will continue through observations and direct work activity participation with group personnel, beginning with the upcoming April 23-24, 1987 meeting.
- 2. IROC recommendations made to you in their first report, dated 2/25/87, have been dispositioned as follows:
o Regarding IROC's recommendation to strengthen the control of contamination at the controlled area boundary as well as promote adherence to radiological program rules, the Vice President-Nuclear Operations has assigned Managers, Chief Engineers, Group Leaders, and Supervisors to 2-hour frisking observation duties in key plant areas. A rotating schedule is being utilized and will continue until proper, sustained frisking performance is achieved. This action was implemented on April 6, 1987.
e Regarding IROC's recommendation that steps should be taken to identify the major sources of some 200 man-rem exposure which is attributed to routine work in less than 100 MR/hr areas, but not captured by the Radiation Work Permit process, it is suspected that a large portion of this exposure is due to the activity of staging erection and removal. Following initial discussions with the key work groups affected, action was initiated on 3/27/87 to utilize Radiation Work Permits for
" clean" and less than 100 MR/hr staging work areas.
Implementation will begin on April 23, 1987. The Radiological Section Manager is also reviewing past and planned, manpower intensive, work efforts and considering additional alternatives which will capture and allow evaluation of major exposure activities.
Dept. Doc.
,, To: R. G. Bird Date: 4/17/87 Page 5
Subject:
BECo RIP IMPLEMENTATION PROGRESS, FIRST QUARTER 1987 e Regarding IROC's recommendations to develop a definitive Charter for the on-site Radiological Assessor, and that the Assessor should report to an appropriate high level of management, a Charter has been prepared (as of April 7, 1987) for approval by the Senior Vice President-Nuclear. The Charter draft was reviewed by the IROC in a March 31, 1987 Committee meeting and Committee comments were incorporated.
In the proposed Charter, the Radiological Assessor now reports directly to the Senior Vice President-Nuclear, and is available to the IROC members to provide assessment information for areas of concern, as approved by the Senior Vice President-Nuclear.
B. Actions Planned by the RIP Program Manager I will dedicate attention to efforts ongoing which address identified radiation protection program weaknesses. As many open items as possible should be completed within 30 days so that we are prepared for our next radiological inspection.
My priorities will be:
- 1. Close out Inspection #86-19 items.
'2. Close out recommendations pertaining to the RIP program effectiveness submitted by the previous Radiological Oversight Committee (ROC).
- 3. Close out recommendations made by an independent auditor (Westinghouse) pertaining to RIP program milestone implementation.
I am currently working with the Radiological Section Manager to accomplish the above actions and will keep you informed.
WHD: caw
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