B12278, Forwards Response to Questions from 871210 Meeting Re 861124 Application to Extend License DPR-61 to 40 Yrs from Date of Issuance.Including Chronology of ALARA Programs for Haddam Neck & Millstone & Yearly ALARA Repts for Haddam Neck

Forwards Response to Questions from 871210 Meeting Re 861124 Application to Extend License DPR-61 to 40 Yrs from Date of Issuance.Including Chronology of ALARA Programs for Haddam Neck & Millstone & Yearly ALARA Repts for Haddam Neck

ML20238C356
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	12/23/1987
From:	Mroczka E, Werner R CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20238C358	List: B12278, Forwards Response to Questions from 871210 Meeting Re 861124 Application to Extend License DPR-61 to 40 Yrs from Date of Issuance.Including Chronology of ALARA Programs for Haddam Neck & Millstone & Yearly ALARA Repts for Haddam Neck ML20238C367 ML20238C373 ML20238C375 ML20238C382
References
B12278, NUDOCS 8712300216
Download: ML20238C356 (104)

Text

_ _ _ _ _

CONNECTICUT YANKEE ATO MIC POWER COMPANY B E R L I N. CONNECTICUT P.O. DOX 270

• HARTFORD, CONNECTICUT 06141-0270 December 23, 1987 TELEPHONE Docket No. 50-213 B12278 Re: 10CFR50.51 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Haddam Neck Plant l Additional Information on Eorty-Year Operatina License Amendment By letter dated November 24, 1986, Connecticut Yankee Atomic Power Company (CYAPCO) requested an amendment to the Haddam F.~:k Facility Operating License in order to extend the duration of tne license to 40 years from the date of issuance of the operating license.

On December 10, 1987, the NRC Staff, CYAPCO, and the Northeast Nuclear Energy Company met to discuss questions that the Staff had raised on worker radiation exposure. Tnese questions were submitted to CYAPCO at the December 10, 1987 meeting. As re-quested by the NRC Staff at the December 10 meeting, CYAPCO hereby formally submits the responses to these questions (Attach-ment 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-the-art technology to reduce man-rem. Examples of these are the use of robotics in steam generator tube plugging and

1. J. F. Opeka letter to C. I. Grimes, "Haddam Neck Plant, Proposed Amendment to Facility Operating License, Extension of Facility Operating License," dated November 24, 1986.

gool wa=8a malha P

y

U. S. Nuclear Regulatory Commission B12778/Page 2 December 23, 1987 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, and 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. 1 recirculation syst2m piping in 1985; and both recircula-tion 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 l

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 enn-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 deals with the utilization of three-year average goals and annual ALARA budgets, similar to cash budgets. The second prong is a number of exposurc 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 reduc- l tion initiatives is to reduce rad-area work, to increase rad-worker efficiency, and to reduce area dose rates. The short-term 4 and long-term initiatives that were developed are described in I greater detail in the response to Question 6 in Attachment 1. )

Thr 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 addition to the three-year average goals we have established a process of setting up an outage expo-sure goal 30 to 60 days prior to the start of the outage. This requires that all outage work be identified early in the process s and a man-rem estimate be established sufficiently in advance to l

U. S. Nuclear Regulatory Commission B12778/Page 3 December 23, 1987 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 identify-ing man-rem jobs early and evaluating their need and scope.

The man-rem history of NU is provided on pages 8 and 10 of . 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 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 all four units being in an outage.

A better way to trend this data is to look at three-year averag-es, which is done on page 7, 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 nation with the lowest man-rem exposure. 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 as appropriate, especially for Millstone Unit No. 3. The 1990 three-year average goals are as follows:

Millstone Unit No. 1 - 580 man-rem; Millstone Unit No. 2 and Haddam Neck - 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 experience to date has 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 1-5, Attachment 3, shows the significant amount of exposures that have been avoided through our ALARA programs. Many of the state-of-the-art tech-niques used by NU since the early 1980s have resulted in the savings of thousands of man-rem at our sites. In the case of Haddam Neck, some examples are provided on pages 2-5, Attach-ment 3. Hundreds of man-rem were avoided in every outage from

U. S. Nuclear Regulatory Commission B12778/Page 4 December 23, 1987 1980 through 1987. A similar view is obtained when you view the data for Millstone Unit No. 2. In particular, the use of chemi-cal decontamination of the steam generator channel heads and loop area shielding for steam generator work has resulted in 1,400 man-rem savings during the 1985 outage and about 130 man-rem during the 1986 outage. 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 with 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 Haddam Neck Forty-Year Operating License Amendment in December 1987. By this letter we are also request-ing the NRC Staff to expedite their review of the Millstone Unit No. 1 Forty-Year Operating License Amendment to enable issuance in February of 1988.

Please contact us if you have any questions.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY h ~r-_

E. J. Mr^pczka u Senior Vice President

- + wm By: R. P. Werner .

Senior Vice President l Attachments cc: W. T. Russell, Region I Administrator.

A. B. Wang, NRC Project Manager, Hadda.n Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant i

i l

Docket No. 50-213 B12778 Attachment 1  ;

Haddam Neck Plant Additional Information for Forty-Year Operating License Extension k

December 1987 l

1 l

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B12278/Page 1 HADDAM NECK PLANT LICENSE EXTENSION:

Question No. 1 The staff notes that Haddam Neck 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 CYAPCO provide a more detailed breakdown of the annual occupational exposures for Haddam Neck for every year from 1978 to the present. As part of this breakdown, CYAPCO 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). CYAPCO should provide its definition of "special maintenance" work and, for each job listed, should state whether this work was classified as being a special mainte-nance job.

No. 1 Reply CYAPCO's chronology of achievements in the ALARA area were described in the cover letter. However, a detailed break-down of the annual occupational exposures from jobs that expended more than 10 man-rem for the Haddam Neck Plant for every year from 1980 to the present is given on the follow-ing tables.

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 break-down of exposures, was not instituted until 1979.

i 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 the following tables. However, in general, special mainte- l nance work is defined as any non-routine work. '

l I

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2 i

OUESTION NO.1

~

HADDAM NECK, CYAPCO JOBS GREA TER THAN 10 MAN-REM

'1980' Actual Actual-Job Manhours Man-rem Refueling 4,036.60 124.433 Electrical Penetration' Replacement 19,630.00 104.011 Steam Generator Eddy Current Testing 1,522 52.188 Reactor Head + Press. RCS Vents 3,553- 44.074 ReactorVessel 151 (Internals Studs Nozzles) _1,437 26.039  :

Fire Detection Modifications 2,649.00 - 19.900 Steam Generator Secondary .757.23 14.420.

Inspection / Lancing Anchor Bolts & Seismic Supports 3,834.26 ~ 44.480 J TMI Modifications 3,194.00 -30.235 151 (Ex-cluding Vessel) 719.75' 22.869 RC Pump Seal Inspection 514.00 10.029 Health Physics Coverage 9,460.00 89.371 1 Decon Containment 8,788.13 -36.633 Staging Erection Removal 3,150.28 20.914 Decon RCA & Radwaste Bldg. 23,738.43- 15.956 Radwaste Processing. 4,031.80 13.698 Cavity Seal Plate 309.68 12.722 Rx Operation & Surveillance 1,267.77 12.011 Material Transfer (Cort.) 1,381.37 11.452

• Special Maintenance Jobs

a 3

l QUESTION NO.1

~ (

HADDAM NECK, CYAPCO JOBS GREATER THAN 10 MAN-REM 1981 1

i Actual . Actual i J

J Manhours Man-rem i Refueling 5,045.51 144.126 Steam Generator ECT 2,198 130.577 )

Steam Generator Tube Plugging 298 38.475 _j S/G Tube Pull Attempt 408 46.852 1 Safety Related Cable Replacement 3,153.24 - 81.786 151 1,447.33 41.582 RC Pump Seals (3 pumps) 1,648.33 36.705 S/G Secondary inspection 953.65 23.501 Valve Repair & Maintenance 889.020 16.438 .)

I

• Less Than 2" Piping Support 560.66 11.639 Health Physics Coverage -

93.743 Radwaste Processing 9,299.7 50.541 Operations Blanket -

37.656 Decon Containment 4,392.73 29.405 Venting & Valving 1,124.49 20.231  ;

Administration Blanket -

10.351 1

1

• Special Maintenance Jobs j

1 I

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i

. _ _ _ _ - _ _ _ _ _ . _ ____.____._____.__m__-__

4- i QUESTION NO.1 HADDAM NECK, CYAPCO JOBS GREATER THAN 10 MAN-REM 4

1983 i

Actual Actual '

Job Manhours Man rem Refueling 3,409.64 61.956 Steam Generator ECT 1,984.79 117.033 Steam Generator Tube Plugging 1,625.16 176.615 Seismic Support Mods. 10,119.93 167.820 Head Area Cable Supports 8,985.08 128.849 151- 2,699.08 76.903 CRD Repair 2,542.00 71.862 Valve Repair / Maintenance 2,159.96 39.409

' Steam Generator Inspection / Maintenance 2,256.90 40.809 l

• 3,463.39 25.108 Reactor Cavity Pool Seal l.oop Stop Valve Repair 317.40 13.589 Containment Sump Decon & Pump Repair 241.76 10.475 Radwaste Processing -

47.005 Venting & Valving -

34.197  !

Decon Containment -

29.960 Decon RCA -

27.046 j i

)

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• Special Maintenance Jobs i

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i- -5' QUESTION NO.1 HADDAM NECK, CYAPCO JOBS GREATER THANJO MAN-REM 1984

. Actual Actual JJ Manhours Man rem Refueling 2,568.87 72.455 Steam Generator ECT 71,835.06 182.223 S/G Tube Plugging 547.72 67.059 S/G Tube Pull 543.27 47.755 Valve Repair / Maintenance 2,185.01 55.832 S/G Manway Handling Device 1,323.05 51.447 Coffer Dam Install./ Cavity Seal Repair - 1,974.04 50.396 151 1,294.86 38.920 RC Pump Seal Repair 1,048.55 31.466 ,

S/G Secondary inspect./ Maintenance 768.88 26.407 Transfer Canal Drain Line Mods. 237.53 16.493 Control Rod Drive Replacement 224.36 13.345 Replace Insulation - Seal Failure -

68.727 Radwaste Processing -

54.802 Venting & Valving -

39.448 Decon/. Containment -

24.083 S/G #1 Wrench Retrieved -

24.166 Pump Water /Decon - Seal Failure -

11.817 HP Job Coverage & Surveys -

11.050 f

• Special Maintenance Jobs I

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OUESTION NO.1-HADDAM NECK, CYAPCO JOBS GREATER THAN 10 MAN-REM ,

1986 Actual Actual 8-Manhours M an-rem -

Job-2,635.69 80.808 Refueling 1,861.84 99.935 Steam Generator ECT 5/G Tube Plugging 1,827.38 7.1.551

• 444.68 40.496 5/G Tube Removal 10,094.28 115.495 Primary Chemical Decon.

4,801.72 160.620

• RCS RTD Replacement 7,699.44 111.631 Safety Related Piping -

• 3,505.97 54.227 Cavity Seal Replacement

• Valve Motor Oper. Replacement 1,202.11 54.215 1,868.89 38.370 151 5/G Secondary inspect./Maint. 1,064.68 32.949 RC Pump Seal Repairs 1,262.56 31.268 Inadequate Core Cooling Mods. 2,996.33 29.257 Appendix R. Modifications 1,888.75 28.257 Cavity Drain Line Replacement 686.83 21.195

• RTD Study 417.64 11.476 Health Physics Blankets

- 78.742

- 68.489 Radvvaste Blankets Valve Repair / Maintenance

- 52.940 Insulation Handling - 51.565 >

Operations Blanket

- 46.948

- 15.548 Administration Blanket 1986 5/G Repair Outage 415.63 10.505 ECT Tube Plugging 1,071.30 95.920

-)

Special Maintenance Jobs

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Attachment 1 B12278/Page 7 l

1 Question No. 2 i

For those jobs described on the previous page that are of a i repetitious nature, i

a. Provide a table listing each of these jcbs along with the corresponding exposures expended for each of the ,

years from 1978 to present (similar in format to the 1 table on Page 5 of the 1986 Refueling and Maintenance Outage ALARA Report).

1

b. Describe the measures that CYAPCO has taken to elimi-nate or reduce the frequency of performing these jobs, or parts of these jobs;

c. Describe the measures that CYAPCO has taken to reduce -

exposures received from performing these jobs. For l

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 i reducing exposures related to these jobs.

l l d. If these jobs are being performed on the same or similar equipment or components, identify the compo-nents, the nature of the work (repair, maintenance, or replacement), and what is being done to avoid repeti-tion.

i l

No. 2 Reply 1

a. Jobs of a repetitious nature along with the corre-sponding exposures for each of the years from 1980 to {

present include refueling, inservice inspection (ISI), I reactor coolant pump (RCP) seal repairs and steam generator repairs. These are listed along with their corresponding exposures on the following pages.

b. CYAPCO has taken the following measures to eliminate or reduce the frequency of performing these jobs:

1 1 o Refueling - CYAPCO intends to convert from stain-less steel cladding to zircaloy cladding thus I allowing the operational cycle to be extended to 18 months.

o RCP Seal Repairs - CYAPCO is taking the following actions regarding RCP seal repairs:

Performing one possible seal change-out per outage and motor preventative maintenance,

Attachment 1 B32278/Page 8 Evaluating an upgraded seal package, Evaluating shortening the RCP motor shaft to make seal removal and installation easier, and Upgrading seal handling devices.

o S/G Repairs - Please see our response to question 3.

In addition, CYAPCO intends to more equally distribute the inservice inspection over the 10 year period.

c. The measures that CYAPCC has taken to reduce exposures received from these repetitive jobs are described on the following pages. Most of our efforts to reduce exposures have been successful as is shown on pages 57-61, Attachment 2, and pages 1-6, Attachment 3.

However, a description of why certain efforts have been unsuccessful in reducing exposures related to those jobs where yearly exposures have increased or remained the same over the last several years is given in the outage ALARA reports. The 1985 ALARA report was provided to the NRC Staff at the December 10, 1987 meeting. The ALARA reports for 1983, 1984 and 1986 are provided in Attachment 4.

d. CYAPCO utilizes a plant maintenance management system (PMMS) to determine which jobs are being performed on the saine or similar equipment or components each year.

' Recommendations and corrective actions are taken as a result of that review to reduce radiation exposure. The measures that are being implemented to reduce the RCP seal repairs wcre initiated through this process.

9 HADDAM NECK, CYAPCO EXPOSURE TRENDS FOR REPETITIVE JOBS l

EXPENDING MORE THAN 10 PERSON-REM Provided below are some examples of repetitive work anda discussion of the ALARA controls.

1. Refuelino - Thisjob includes reactor disassembly, fuelshuffle, and reactorreassembly Year 1980 1981 1983 1984 1986 Person-Rem 124.433 144.176 61.956 72.455 80.808 Exposure Controls 1980

1. Personnel shields in cavity

2. Water shelding in transfer canal

3. Lead Blanket on head shroud

4. Flush core deluge

5. Portable ventilation in cavity

6. Shield Spent Fuel Building Handling Bridge

7. Cavity Decon

8. Pre-use cleanup of cavity water

9. Stud cleaning machines

10. Refuel Equipment DeconTent 1981 As above, plus:

1. Temporary reactor vessel head shield

2. Shielded cavity seal plate

3. Shielded manipulator crane bridge

4. Shielding for CRD shaft repair 1983 As above, plus:

1. Underwater cavity filtration / vacuum system

2. Core exit thermocouple area shields

10 l

)

1984 l Asabove l I

1986 As above, plus: 1

1. Replaced cavity seal Discussion '

Exposures have generally trended downward excepting increases in 1984 and 1986.

Reasons:  !

1984 - Unexpected problems with Reactor Vessel stud detensioning. Improper ,

installation of Reactor Head Shield.

1986 - Overrun due to the following activities beincj performed out of sequence and requiring repetition: Reactor Head electrical disassembly; Stud Tensioning, and I Reactor Head reassembly.

2. Steam GeneratorInspection and Repair i

1986 ,

l Year 1980 1981 1983 1984 1986 1987*

Repa r Outage -

ECT- 0.035 0.025 0.025 0.012 0.006 1.3 0.004 Rem / Tube

{

Plugging- 2.044 0.770 0.402 0.645 0.587 0.355 0.049  !

Rem / Plug i l Manway 9.060 5.865 4.699 5.977 5.039 4.633 4.615 Removal /

I i l Replacement '

Rem S/G Sludge 10.192 12.571 8.253 7.865 9.790 N/A 5.970 Lancing

• Preliminary /Not Published Information Exposure Controls 1980 i 1. Shielded container for diaphragm storage

2. Lead sheet on platform grating / skirt drain lines

3. 5/G ventilation system

11 r 7J w

\A.

!l I

' -p  : <

t\

Exposure Controls (Cont'd.) o 4

1980 i ._

.y

) ,- 1

4. Automatic indexing eddy current and profilometry probes  ;

5. Jumper briefing-4

6. Shielded eddy current booth

' %]v Ji;p  : t?

7. Communications from skirt to low rad area 1981 1 t.

"%  ?

g As above, plus: y 'h '

1. Hydrogen peroxide flush of RCS '

!l

2. - Hydrolaze of channel head 'i

3. Experience or mockup training required forjumpers.

K [-

4. Eddy current readout in low dose rate area -

p ' ,b t .i 1983. +

l l-As above, plus:

1. New steam generator mock-up

2. Decon skirt and skirt floor below grating '

1984 i ]

As above, plus: *

1. More automation of ECT/ Profilometry equipment

2. Shield manway openings during ECT platform support

3. Used mechanical tube plugging in lieu of explosive 1 1986 I i c )

As above,plus: 6 *

1. Improved robotic arm utilized for ECT !4

2. CCTV monitor used for Health Physics coverage '.

t ,

E. Additional contamination controls utilized \

4. Chemical Decontamination of two (2) Steam Generators performed 1986 Tube Repair Outaae As above, except:

9,,

1. Tube plug control station in low dose area '

2. Chemical Decontamination not performed 4 l

[

iy

. - - _ _ _ _ _ _ - _ _ _ _ ___ _- a

r 12 t

L98.1 As above, plus:

1. Probe pusher located outside of skirt

2. Tube plugging performed using robot arm ,

3. All control stations moved outside of containment Discussion Trends are generally downward with dramatic improvements in 1986 and 1987. An  ;

exception is due to the following: '

i 1986 Sludge Lancing -Increased man-hours required to complete sludge lante,'

operations.

j Note: ECT durin Therefore,g all 1986 setuptube repair outage and removal performed was averaged overon a only much2smaller tubes.

number of tubes. -

3. Reactor Coolant PumplSealRepair '

Year 1980 1981 1983 198L,1986 1987 Rem / Pump 10.609 9.536 8.855 10.480 10.422 9.520 Seals 1 3 1 3 3 4 i .!

Exposure Controls f

1980 i

1. Shielded platform

2. Deconned seals upon removal, repaired in low dose area 1981 l As above, plus:

{

1. Near steam generator secondary side full of water

2. Increased contamination controls f 1983 As above I 1984 i

As above, plus:

1. Further increased leakage / contamination control

2. Video tape training of past RCP rebuild utilized l

13 3

l i

u 1986 i

As above, plus: '

1. Nearby honpots shahied

2. Personnel traffic restricted ini work area

3. CCTV monitor used for HcMth Physics coverage Discussion Werd was downward unti81984when exposure returned to 1980 levels. Re asons:

,1!!8F Crud burst on shutdc>wn deposited in pump seal area and increased area dose rates by 66%. '

1j!!11'rhgiter than previous man-hours spent rebuilding pump seals.

4: Inservice Inspet: tion l ear h 1980.., ,

981 1983 1984 1986 Man-Rem 22. N 3 , s 41.582 76.903 38.920 38.370 Exposure Con trop 1980 t

1. Shielded hot spots where practical

2. Flushed regenerative heat exchanger l

1981 As above,plus:

{

1. Use skyjacker in lieu of stagmg '

2. Use mirrors for steam generator, pressu.rizer inspections

3. Sc< ease contamination control 19M As above, plus..

l l 1. Use dedicated ISI HP Technician

2. Set up test equipment in low dose area where possible 1984 l

As above, plus:

1. Use experienced workers

2. Tagging of valves and snubbers

14 1986 As above, plus:

1. Remove snubbers to low dose area for testing

2. Radiography perforrned in early morning hours when possible Discussion Workscope from year-to-year is generally not comparable.1983 was a high scope year.1984 and 1986 workscope is comparable and exposure showed a comparable effectiveness of ALARA controls.

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Attachment 1 B12278/Page 15 1 Question No. 3. -

i Describe the steps that CYAPCO 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' CYAPCO has taken l 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 CYAPCO l plans to take to - reduce steam generator work related exposures.

b. Identify and describe CYAPCO'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. Identify and describe the steps that CYAPCO has taken I to minimize the need for steam generator repairs.. For i example, describe any changes in ' water chemistry I

control made to . minimize steam generator ~ tube corro-sion. Have condenser tube leaks contributed to degra-dation of the steam generator tubes, and, if so, _ what-has been done to alleviate this' problem?

d. Describe CYAPCO's plans and time schedule to replace the steam generators at' Haddam Neck. Describe what l steps will be takt.n to ensure that CYAPCO will not have the same recurring problems with the'new steam' genera-tors.

e. State what jobs other than steam generator related work are large contributors to the annual dose at Haddam i Neck on a repetitive basis. What efforts have been made to minimize the-exposures related to these jobs.

No. 3 Reolv

a. CYAPCO has specifically used the following to reduce exposures:

Automation '

Robotics Mock-up Training Video Taping Equipment Entry

= ________ -

l 1

Attachment 1  !

B12278/Page 16 l Data Acquisition Station Outside Containment Analyst Training The above inspection practices are periodically reas-sessed 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 was previously discussed on pages 10-12, Attachment 1.

Recent changes that CYAPCO has employed are listed on page 36, Attachment 2.

b. As identified on pages 16, 17, 18, 35, 36, 37, 38, and 40, Attachment 2, CYAPCO has effectively used shielding and inspection practices, chemical decontamination and substantial chemistry improvements to lower man-rem exposure. The success of these efforts is detailed on pages 35 and 58, Attachment 2 and pages 2-5, Attachment 3.

c. Based on experience, it is estimated that the total steam generator man-rem exposure in 1988 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 Haddam Neck over the next two years is shown on page 40, Attachment 2 and is estimated to remain approximately the same in the future. In an effort to minimize the need for steam generator repairs, CYAPCO has completed the replacement of all copper bearing alloys, retubing of the main condenser and has instituted additional primary and secondary water chemistry controls. These chemistry controls are detailed on pages 16, 19-25, and 37, Attachment 2. In addition to efforts that CYAPCO 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. CYAPCO presently does not plan to replace the Haddam Neck 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.

e. Please see our reply to question 2.

)

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Attachment 1 B12278/Page 17 I

Question No. 4 Provide CYAPCO's time frame for meeting this goal, and describe the specific steps that CYAPCO will take to reduce I exposures at Haddam Neck to 500 person-rems per year or less. Assuming that this annual goal of 500 person-rems is for an outage year, 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 Haddam Neck. 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 Haddam Neck for the 1987 through 1989 time period has been set at 629 man-rem.

The 1990s and beyond 3-year average goal for Haddam Neck has been set at S25 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 Haddam Neck Superintendent as part of the overall Management Planning and Performance Evaluation Program (MPPR). This is the 1 Northeast Utilities version of management by objectives (MBO). The Vice President of Nuclear Operations has estab- ]

lished 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 Haddam Neck was assigned to the Unit Superintendent as part of his MPPR goal. The Unit Superin-i tendent in turn apportions the annual man-rem budget by i 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 budget without prior

Attachment 1 B12278/Page 18 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 bel expended in finding' alternatives -to proposing the variance.

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B12278/Page 19 Question No. 5 l

Describe CYAPCO's criteria for performing ALARA reviews over l the. time period 1978 through the present. If the criteria is - the same as for Millstone 2, merely state that' is the case. In particular, state CYAPCO'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 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 would result in even lower overall exposures. Describe CYAPCO's procedures for evaluating and implementing post-job review ALARA recommendations which may result in ' lower future exposures for performing repetitive jobs.

No. 5 Reolv The criteria for performing ALARA review is ' the same for Millstone Unit No. 2 and 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 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 activi-ties for which reviews are not performed).

For jobs which are expected to result in greater than 1- but less than 5 man-rem,~a less detailed ALARA review for ALARA controls is performed by a plant Health Ihysics technician.

Concerning the CYAPCO 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 outage are issued by plant management as a controlled routing requiring

Attachment 1 B12278/Page 20 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.

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~1 Attachment 1 B12278/Page 21 j Ouestion No. 6 Provide any_ additional information that CYAPCO thinks is relevant for the staff to reach a . favorable conclusion regarding the license extension at - this time, rather than deferring consideration of CYAPCO's request to allow CYAPCO .

additional time to identify root causes of, correct, and- j reduce occupational exposures at Haddam Neck. j l

No. 6 ReDiv N As was discussed during the December 10, 1987. meeting and in I response to previous questions, CYAPCO .is aware of the ,

identified root. causes of high . occupational exposures at l Haddam Neck. This information is being used in conjunction with the new Exposure Reduction Program to reduce exposure'. j Examples of significant occupation exposure savings are provided on pages 57-61, Attachment 2 and pages 1-5, Attachment 3.

The Exposure Reduction Program described in the cover letter, consists of a 3-year average goal process and exposure reduction initiatives (ERI). These- ERIs' are described here in detail.

The purpose of the initiatives is to reduce work in radia-tion 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. 1 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 obcerved 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.

Most of the short-term initiatives can be immediately implemented, however, some of the short-term initiatives and 1

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1 Attachment 1 B12278/Page 22 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 quali-tatively evaluated. In the case of Haddam Neck' and g Millstone Unit No. 2, it appears that it- is necessary to evaluate all the proposed ERIs to enhance the chances of achievement of the 1990 goal. In the case of Millstone Unit No. 1, only the short-term initiatives, if shown to be cost

. beneficial, will be needed to lower exposures to the 1990 ,

l goal. In general, because of the overlapping man-rem j paybacks and 3-year average goal, an exact estimate of the man-rem reduction is not possible. However, on an annual basis as the different ERIs are implemented, a better j estimate of their effectiveness in reducing man-rem'will be i determined. I A brief description of each short-term ERI now follows with a status as of November, 1987.

I CYAPCO believes that the information provided in this letter l l 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 i the pending license amendment which will provide a substan-tial savings to our ratepayers over the remaining life of the plant.

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Attachment 1 B12278/Page 22 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 quali-tatively evaluated. In tha case of Haddam Neck and Millstone Unit No. 2, it appears that it is necessary to evaluate all the proposed ERIs to enhance the chances of achievement of the 1990 goal. In the case of Millstone Unit No. 1, enly the short-term initiatives, if shown to be cost 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 estimate of the man-rem reduction is not possible. However, on an annual basis 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 November, 1987.

CYAPCO believes that the information provised 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 substan-tial savings to our ratepayers over the remaining life of the plant, i

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23 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 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 1  !

GEZIP - MP-1 ST #8 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 j Lona-Term Initiatives l

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 i

LT #4 Primary chemistry controls - CY, MP-2, MP-3 LT #5 Robotics- All units LT #6 Steam gerierator replacement - MP-2 i LT #7 Cobalt material alternatives - All units

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l SHORT-TERM INITIATIVES l

ST1 Increase ALARA Awareness ' Allunits 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 Cancellation / Scope Reduction All 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 jcsbs through an i 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 i inspections, etc., to minimize number of required personnelin area. j Consider sliding / variable requirements depending on dose rates.

Status: Under evaluation

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25 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.

Status: Underevaluation 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 performed in 1987 at CY. - A 5/G channel head decon has been determined to be not cost-effective for MP-2 for the 1988 outage because of reduced workscope and  !

the use of robotics.

ST6 CET Grayloc Flanaes & Rx Head Stud Tensioners Unit- CY 1 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 198 '7.

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 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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i ST10 ALARA Installa tion Reviews - EarIV Staae Units- All.

ALARA installation reviews are currently performed within a'few days to1

' weeks that time.-of actual work However, performance.

there They should is merit to performing suchcontinue reviews atto least be up(dated at

.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.

Cobalt Reduction Units- All

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ST11 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 replacement were put on the list for the 1987 outage.

ST13 Hydroaen Water Chemistry Unit - MP-1 Feasibility testing was done in 1987. Results are being evaluated.

i Attachment 1 B12278/Page 27 Ouestion No. 7 Provide a copy of the ALARA program appraisal' conducted by the corporate staff of Northeast Utilities (NU) of the Millstone ano Connecticut Yankee sites. The report describ-ing the finding is dated - December 18, 1986. Include the

" Outage ALARA Reports" for 1983, 1984, 1986, and 1987.

No. 7 Reolv Attachment 5 provides a copy of the November 1986 AIARA Program Appraisal. Also attached are status reports dated April 22, 1987, June 3, 1987, and December 14, .1987. In addition, as requested the Trend Analysis Report for the Health Physics Audit Results in 1986 is attached.

As stated previously, Attachment 4 provides a copy of the Outage ALARA Reports for 1983, 1984, and 1986. The 1987 Outage ALARA Report is not yet available, i

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Docket No. 50-213 )

B12778 l Attachinent 2 Haddam Neck Plant Additional Information for Forty-Year Operating License Extension i

December 1987

DOCKET NOS. 50-213 50-336 NORTHEAST UTILITIES MILLSTONE NUCLEAR POWER STATION UNIT NO. 2 l HADDAM NECK PLANT FORTY-YEAR OPERATING LICENSE AMENDMENT i

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DECEMBER 10, 1987 l

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k PURPOSE

1. RESPOND TO NRC STAFF QUESTIONS ON OCCUPATIONAL EXPOSURE AT MILLSTONE UNIT NO. 2 AND CONNECTICUT YANKEE.

2. REACH A FAVORABLE CONCLUSION TO ALLOW NRC STAFF ISSUANCE OF THE CONNECTICUT YANKEE AND MILLSTONE UNIT NO. 2 FORTY-YEAR LICENSE AMENDMENTS IN DECEMBER 1987.

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l CFS - ] M Q/87 l l

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NU PARTICIPANTS 1

o DR. C. F. SEARS -

VICEPRESIDENT,NUCLEARLAND ENVIRONMENTAL ENGINEERING o DR. R. C. RODGERS -

MANAGER,' RADIO!"SICAL ASSESSMENT-BRANCH' o J. W XLISIEWICZ -

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 1

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CFS - 12/10/87-  ;)

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AGENDA J 1. .NU Management - Overview C. F. Sears

2. A! ARA O'verview. -- Where Are We Now- R. C. Rodgers Where' Are We Going Exposure Reduction Plan Exposure Goals / Budgets Station implementation Of Goals - F. R. Dacimo

' 3. Exposure Reduction Initiatives - R. C. Rodgers i

4 Chemistry and -

Inspection / Repair J. W. Klisiewicz -

Material Controls- Decontamination Chemistry Primary / Secondary 5/G Replacement Exposure Data 1980-1989 R. C. Rodgers

5. Greater Than 10 Man-Rem Jobs - MP-2 F. R. Da cimo 6.. Repetitive Jobs -

ALARA Data / Efforts F. R. Dacimo/

(Refuel, S/G,151, RCP)

Station System /Compontent Tracking

7. Station ALARAImplementation ALARA Review Process F. R.- Dacimo/

Post Job Reviews E. A. DeBarba .

8. ALARA Screening in 15AP G. P. van Noordennen

9. Additionalinformation on ALARA Savings R. C. Rodgers i

10. Summary C. F. Sears CFS i 12/10/87.

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FORTY-YEAR-0PERATING LICENSE AMENDMENTS REDUCTION 0F:0 OCCUPATIONAL 1 EXPOSURE:AT-NU-

MANAGEMENT-0VERVIEW o lMPORTANCE:

-o ATITUDE CHANGES i

o PHYSICAL CHANGES o EFFECTIVENESS OF ALARA'G0ALS 1

i CFS - 12/10/87-

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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 APPROVAL OF THE FORTY-YEAR OL AMENDMENT LOWERS COST TO OUR CUSTOMERS t

i cEs - 12/10/87

NU ALARA PROGRAM CHRONOLOGY-ACHIEVEMENT e ALARA part of routine operation Since Plant Start-up e Formal ALARA program initiated 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 5/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

.

• 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

• MP-1 GEZIP 1987

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1982 .1f/34 916 686- 1,209 -

1983-1985 912- 590 1,310 -

1984-1986 1,009 .554 937 -

-1985-1987 871 511 957 -

1986-1988 900 347 592 168 1987-1989 596 447 '484 298 1988-1990 - - .

1990 + goals 525 580 525 250 INPO Goal 350-450 '700 350-450 350-450 (Ann. Avg.)

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. EXPOSURE REDUCTION PLAN Achieve Culture Change e Worker exposure reduction is same as reducing risk to publich health and safety e ALARA is mandatory e Exposure reduction is integral part of design, installation, and maintenance e Exposure reduction is everyone's job - not just that of H.P.

Evaluate and Implement Exposure Reduction Initiatives e Reduce rad area work e increase rad worker efficiency e Reduce area dose rates Person-Rem Goals e Use three-year average goals vs. annual goals e Outage exposure goal set thirty to sixty days prior to start of outage

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-i ALARA IMPLEMENTATION AT MILLSTONE UNIT 2 ACP 6.02, MAINTENANCE OF OCCUPATIONAL RADIATION EXPOSURE ALARA.

)

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.

l STATION THROUGH A SYSTEMATIC PROGRAM 0F PLANNING. WORK-SIGNIFICANT PART OF STATION, UNIT AND DEPARTMENT l G0ALS; BASED ON CORPORATE-G0ALS.

EXPOSURE REDUCTION PROGRAMS (4 ITEMS) l VIGOROUS APPLICATION OF PERMANENT AND TEMPORARY i SHIELDING DURING OUTAGES (ACP6.10)

ALARA COORDINATOR INVOLVEMENT WITH' APPLICABLE UNIT DEPARTMENTS BEFORE AND DURING REFUEL OUTAGES UNDER ACP6.02 Esp - 12/10/87_

4 W

EXPOSURE REDUCTIONINITIATIVES e Short-Term initiatives . To be achieved in.1987-1988

• Long Terminitiatives - To be achieved by the early 1990's l

J l

_J

~~,

Ma EXPOSURE REDUCTION INITIATIVE!

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 ST #5 Decontamina' tion - CY, MP-1, MP-2 ST #6 CET Grayloc flanges &' reactor head stud tensioners - CY ST #7 Pecmanent neutron shield - MP-2 ST #8 GEZIP - MP-1 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 b

LT #3. Steam generator inspection / plugging criteria - CY, HP-2, MP-3 LT #4 Primary chemistry conrols - CY, HP-2, MP-3 LT #5 Robotics - All units LT #6 Steam generator replacement - MP-2 L1 #7 Cobalt material alternatives - All units l

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R P o o o o

MATERIALS AND CHEMISTRY ALARA INITIATIVES

1. HIGHER PRIMARY COOLANT PH: ALL PWRS PRINCIPLE /0BJECTIVES:

-T0INCREASETHESOLUBILITYOFFUELDEp0 SITS

- TO MAINTAIN CLEAN FUEL SURFACES

- REDUCTION OF ACTIVITY TRANSPORT

- MINIMlZE SG CHANNEL HEAD DOSE RATES 4 STATUS: TARGET

- TRIAL RUN AT MP3 FOR CYCLE 2 1988/89

- IF SUCCESSFUt., ASSESS FOR APPLICATION AT CY AND MP2 1990/91 i

nJL- 12/10/87_

, 2. HYDR 0 GEN PER0XIDE INJECTION DURING SHUTDOWN: ALL:PWRS' PRINCIPLE /0BJECTIVE:

i

- TO INCREASE SOLUBIL1TY OF.CoS8/C060 AT AN APPR0PRIATE-TIME FOR MAX; COOLANT CLEANUP

- REDUCE. FUEL POOL DOSE RATES STATUS: TARGET

- APPLIED FOR MANY YEARS AT CY-

- BEING ASSESSED FOR APPLICATION TO MP2 AND.MP3 1988.

JWK-- 12/30/.8Z

3. PARTI AL SYSTEM DECONTAMINATION: ALL STATIONS' PRINCIPLE /0BJECTIVE:

-- TO CHEMICALLY REMOVE RADIONUCLIDES FROM' SPECIFIC SYSTEM SURFACES PRIOR T0 INSPECTION AND/0R REPAlR WORK.

- REDUCE WORKER DOSE RATES

STATUS: TARGET

--UTILIZED AT CY AND MP2 ON SG' CHANNEL HEADS -1983/85/86

- UTILIZED AT MP1 ON REACTOR RECIRC.,

REACTOR WATER CLEANUP, AND IN LOWER VESSEL ANNULUS 1984/87-

- CONSIDERED ON A CASE BY CASE' BASIS FOR EACH OUTAGE . FUTURE L

JWK - 12/10/87_

?

y

- i 4.- FULL SYSTEM DECONTAMINATION: 'ALL PWRS t

PRINCIPLE /0BJECTIVE:

- TO CHEMICALLY-REMOVE RADIONUCLIDES FROM THE ENTlRE..

. PRIMARY SYSTEM (S) AND1 VESSEL (WITH OR WITHOUT FUEL lN PLACE),

- A REDUCTION IN WORKER DOSE RATES:lN GENERAL AND/0R FOR MAJOR REPAlR OR REPLACEMENT.(E.G. SG REPLACEMENT)

-STATUS: TARGET-

- AD H0C UTILITY COMMITTEE FORMED TO ESTABLISH A PROGRAM FOR PWRS COMMITTEE HAS NU REPRESENTAT10N AND NRC INVOLVEMENT

- PROGRAM TO BE DEFINED EARLY 1988

- PROCESSES QUALIFIED AND EVALUATIONS-COMPLETED FOR GENERIC USE EARLY 1989 i

JWK - 12/lD/3Z l

1

5. COBALT SOURCE REMOVAL: ALL STATIONS PRINCIPLE /0BJECTIVES

- TO REPLACE Co CONTAINING COMPONENT MATERIALS WITH ALTERNATIVE ALLOYS

- TO SPECIFY LOW Co CONTENT FOR MAJOR CONTRIBUTION COMPONENT MATERIALS (E.G. SG TUBING)

- REDUCE Co CONTENT IN COOLANT WATER AND COMPARABLE REDUCTION IN WORKER DOSE RATES STATUS: TARGET

/

- PROJECT ASSIGNEMENT IN PLACE TO REPLACE SPECIFIC Co CONTAINING VALVE SEATING ALLOYS (STELLITE) WITH ALTERNATIVES 1988/89/90/91 l

- STELLITE REPLACED WITH T420SS IN FW REGULATOR VALVES AT MP1 1986

- LOW Co CONSIDERED FOR IMPROVED SG TUBING AT MP2 1987

- STUDY TO BE PERFORMED ON EFFECTIVENESS OF REPLACING OTHER IN CORE Co CONTAINING COMPONENTS (E.G. CONTROL R0D DRIVES, GRID SPACERS) 1988/89 Jwy - 12/10/87

6. SURFACE PASSIVATION PROCESSES:- ALL STATIONS.

PRINCIPLE /0BJECTIVE

- T0 CHEMICALLY-(OR ELECTR0 CHEMICALLY)-TREAT-COOLANT COMPONENT. SURFACES IN ORDER TO REDUCE RADIONUCLIDES RETENTION ON METAL AND/0R OX1DE STATUS TARGET

- GEZIP (ZN. INJECTION) TESTED AND IMPLEMENTED AT MP1 1987.

- STATE OF THE ART IN ELECTROPOLISHING AND/0R HIGH TEMPERATURE (STEAM / AIR)

SURFACE TREATMENTS BEING FOLLOWED. ON-G0ING

- hK - 12/10/87 .

-- I

7. HYDROGEN COOLANT CHEMISTRY:- gg PRINCIPLE /0BJECTIVE:

TO CONTINUOUSLY INJECT H2 INTO THE FEEDWATER IN ORDER TO LOWER THE ELECTRODE POTENTIAL OF SS AND INCONEL COMPONENTS TO PREVENT AND/0R MITIGATE IGSCC

-A REDUCTION IN BOTH REPAIRS AND INSPECTIONS WITH SUBSEQUENT DECREASES'IN PERSONNEL EXPOSURE q

STATUS:- TARGET

- H 2WC TESTED AT MPl. 1987

- IMPLEMENTATION AT MP1 NOW BEING ASSESSED 1988/89-Jwx - 12/10/87-

MILLSTONE 2 STEAM GENERATOR CHANNEL HEAD DECONTAMINATION EXPERIENCES I

AUGUST 1983 o OZ0X-A PROCESS AVERAGE VALUES l INITIAL (R/HR) POST DECON (R/HR) POST HYDRO (R/HR) E 18 10.5 6 3.0 MAY 1985 o DlLUTE CITROX PROCESS AVERAGE VALUES INITIAL (R/HR) POST DECON (R/HR) POST HYDRO (R/HR) E 14 4 3 4.6 OCTOBER 1986 o 0Z0X-A PROCESS AVERAGE VALUES INITIAL (R/HR) POST DECON (R/HR) POST HYDRO (R/HR) E 11 5 5 2.2 i

JWK - 12/10/87 {

~

. _ . . . . _ _ _ . . .. ..E MILLSTONE =2 STEAM GENERATOR-INSPECTION PRACTICES NOVEMBER 1986 o SM4 o FOUR STEAM GENERATOR PLENUMS IN' PARALLEL o' STEAM GENERATOR DECONTAMINATION o MOCKUP TRAINING o VIDE 0 TAPING PROBE ENTRY o SHIELDED STEAM GENERATOR MANWAY DOORS o DATA ACQUISITION OUTSIDE CONTAINMENT JANUARY 1988 o GENESIS ARM (ZERO ENTRY) o NO TUBESHEET TEMPLATES i

o 4WD PROBE PUSHER o ANALYST TRAINING o MOCK UP TRAINING o FOUR STEAM GENERATOR PLENUMS IN PARALLEL o FINANCIAL INCENTIVE / PENALTY CLAUSE REGARDING MAN-REM EXPOSURE

_JWK - 12/10/87 j

MILLSTONE 2

SUMMARY

OF STEAM GENERATOR-CHEMISTRY E1CLE PARAMETER LlulI 5. S Z 3*

CHLORIDE. LESS THAN 20 PPB 57. 29 :23 1 SODIUM LESS THAN 20 PPB 26' 15 13 l' l

CAT. COND. LESS THAN .8 US 1.5. 1.1 '0.6 0.1 ,

• END OF CYCLE 8: JANUARY 1988 l

i JWK - 12/10/87

l MILLSTONE 2 w#

ESTIMATED NUMBERS OF STEAM ^ TUBE REPAlR EXISTING INDICATIONS L CICLE BECOMING Je 40% OTHER TOTALS E0C8* (1/88) 350 30 380 E0C9 70 20 90 E0C10 70 15 85 E0Cll 70 15 85 E0Cl2 60 10 70 E0Cl3 60 10 70

• END OF CYCLE 8 I

JFK - 12/10/87

h L MILLSTONE 2 STEAM GENERATOR IMPROVEMENTS ON-GOING EVALUATION OF FOLLOWING DESIGN CONSIDERATIONS:

o' ALLOY 690-(LOW COBALT) -

o FERRITIC SUPPORT SYSTEMS o ENHANCED BLOW' DOWN RATE' o

ELECTRO POLISHING OF CHANNEL HEAD CLADDING o

INSTALLATION OF FlXTURES ON DIVIDER PLATES TO FACILITAT SHlELDING INSTALLATION

. o MORE/ LARGER HAND HOLDS AND MANWAYS o

SEALED DIVIDER PLATES TO FACILITATE CHANNEL HEAD DECONTAMINATION o IMPROVEMENTS IN N0ZZLE DAM DESIGN

.i 1

l l

1 RK - 12/10/87

\

{

l MILLSTONE 1  !

DECONTAMINATION EXPERIENCES 3

APRIL 1985 o CAN DECON PROCESS o RECIRCULATION SYSTEM i

AVERAGE VALUES INITIAL (MR/HR) FINAL (MR/HR) E 238 11 1 5.8 SEPTEMBER 1987 o LOMI PROCESS o RECIRCULATION SYSTEM AVERAGE VALUES INITIAL (MR/HR FINAL (MR/HR) E 285 77 3.7 o REACTOR WATER CLEANUP SYSTEM '

AVERAGE VALES INITIAL (MR/HR) FINAL-(MR/HR) E 155 57 2.7 JWK - 12/10/87

MILLSTONE 1

SUMMARY

OF REACTOR AND FEEDWATER CHEMISTRY )

EXCLE l PARAMETER LJBH n p*  ;

1 REACTOR WATER CHLORIDE LESS THAN 20 PPB 5 5 FEEDWATER OXYGEN LESS THAN 200 PPB 20 20

• CYCLE 12 STARTUP AUGUST 1987 l

JK - 12/10/87 l

i

MILLSTONE 3 i STEAM GENERATO8 INSPECTION PRACTICES NOVEMBER 1987 1 o SM10 o NO TUBESHEET TEMPLATES o 4WD PROBE PUSHER o VENDOR REVIEW 0F BASELINE DATA l 0 TWO STEAM GENERATORS IN PARALLEL o ANALYST TRAINING l

l 1

JWK - 12/10/87

)

_--_____-___D

)

l MILLSTONE 3 l

SUMMARY

OF STEAM GENERATOR CHEMISTRY l

PARAMETER LIE 11 CYCLE 1 1

CHLORIDE LESS THAN 20 PPB 5 S0DIUM LESS THAN 20 PPB 11 CAT. COND. LESS THAN 0.8 US 0.4 3.x - 12/10/87

-i

CONNECTICUT YANKEE STEAM GENERATOR CHANNEL HEAD DECONTAMINATION EXPERIENCE JANUARY 1986 o CAN DECON PROCESS o ONLY STEAM GENERATORS 1 AND 3 AVERAGE VALUES INITIAL (R/HR) (POST DECON (R/HR) POST HYDRO (R/HR) DE 27 5 6 4.5 m - 12/10/87

i

~ . 36-I wl CONNECTICUT YANKEE- l STEAM GENERATOR INSPECTION PRACTICES- s JANUARY 1986 o SM10 (REMOTELY 0PERATED ROBOTIC ARM) p

' i o NO TUBESHEET TEMPL'ATES o 4WD PROBE PUSHER.(MINIMlZED NUMBER OF PROBE.CH,ANGES DUE-

.T0 PROBE WEAR / BREAKAGE) .

o VENDOR REVIEW 0F 1984 lNSPECTION RESULTS o MOCK UP TRAINING-p.i:"

o TWO STEAM GENERATORS.lN PARALLEL "lig y

AUGUST 1987 J

' il .

o SM10 (UPGRADED) o NO TUBESHEET TEMPLATES o 4WD PROBE PUSHER o VENDOR REVIEW 0F 1986 INSPECTION.RESULTS o ANALYST TRAINING o MOCK UP TRAINING i o TWO STEAM GENERATORS IN PARALLEL 1

o CUT H0LE IN STEAM GENERATOR SKlRT .(T00K ADVANTAGE. OF EXTRA. SHIELDING) o TUBE MARKING FORM SM10 awx - 12/10/87-L'.1

l J

CONNECTICUT YANKEE 1

SUMMARY

OF STEAM GENERATOR CHEMISTRY l

. CELE PARAMETER LUiLI n J2 J3 g l l

CHLORIDE LESS THAN 20 PPB 56 28 10 10 SODIUM LESS THAN 20 PPB 68 7 7 6 CAT. COND. LESS THAN 0.8 US 1.2 0.5 0.4 0.3 i

i l

I m - 12/l028Z 1 .

.. . .. .. . .. . . . ~

CONNECTICUT YANKEE 1987 STEAM GENERATOR INSPECTION RESULTS A TOTAL OF 353 TUBES PLUGGED:

289 FOR PWSCC AND ROLL TRANSITION CRACKING; 64 FOR OTHER REASONS (E.G. PITTING)

SAMPLE OF TUBES WITH PLUGGABLE INDICATIONS IN 1987, WHEN COMPARED T0 1986 RESULTS, REVEALED THAT ESSENTIALLY ALL INDICATIONS WERE PRESENT IN 1986 l

l DATA REDUCTION STiLL 1)NDERWAY i

PRESENT CONCLUSION. 1987 DEFECTS REPRESENT OLD NOT NEW INDICATIONS, WITH MINIMAL DEFECT PROGRESSION RATES l

l I

l l 1 l

JFK - 12/10/ 87

.J

r

_39_ T .

MP2 SIG EXPOSURE HISTORY Outage Total For S/G S/G Year Outage j roiects Total % 5/G 1980 486 ECT 49 63 13 %

l Tube Plugging (2) 8 Sec. Side Inspection 6 1981 82 1689 ECT 155 1098 65 %

Nozzle Dams 296 Plug (1492) 584-

Tube Sample 56-Sec. Side inspection 7 1983 84 1989 ECT 148 1289 64 %

Sludge Lanc. 67 Decon 130

! Sample 26 1 Tube Sleeving (2022) 572 l Plug (386) 61 i Tube Repair 57

! Radiography 13

' Nozzle Dam 208 Sec. Side inspec. 8 1985 1547 Sleeve (2926) 526 1026 66 %

ECT 198 i Decon 58 Chem Clean. 96 i

Tube Sample 17 Lanc.& Radio 13 ea.

Nozzle Dams 46 Plug (132) 13

, 1985 127 N/A RCP Moto."

i

1986 872 Plug (56), Sleeve (226) 138 351 40 %

Nozzle Dam 92 l ECT 50

' Sludge Lanc. 16 Decon 47 l Radiography 8

!1987 82 Plugs (162),5feeves (-1) 60 60 73 %

TubeLeak I

1988 544 ECT 60 267 49 %

! Plugging 67 Radiography 8 Tube Pull 10 Sec. Side inspec. 25 Nozzle Dams 60 5/G Platfrm/5tage 22 Misc. Support 15 1989 562 ECT 60 252 45%

Plugging 30 Radiography 11 Sec. Side inspec. 30 Nozzle Dam 84 5/G Platfrm/ stage 22 Misc. Suoport 15

CY SIG Exposure' History Outage Outage Exposure .. - % 5/G

_ leal Total Steam Generator Prolects 5/G Total Exposure 1980 1005 ECT 52 74 7.4 Tube Plugging (4) 8 Sec. Side (Lance /inspec.) '14 1981 878 ECT 130 238 27 Tube Plugging (50)- 38 Tube Pull Attempt.'

47 Sec. Side 23 1983 1260 ECT 117 335 27 Tube Plugging (440) 177 Sec. Side 41 1984 1108 ECT 182 348~ 31 Tube Plugging (104) 67 Tube Removal . -48 Sec. Side 51 1986 1506 Chemical Decon. 115 361 24 (Refuel) ECT 100 Tube Plugging (122) 72 Tube Removal 41 Sec. Side 33 1986 106 ECT 10 106 100 (July) Tube Plugging (248) 95 Sec. Side 14 1987 638 ECT 61 122 19 (11/24/87) Tube Plugging (706) 47 Sec. Side 14 1989 716 151-5G4 Welds 5 118 16 ECT 59 Tube Plugging 45 Sec. 5 luge Lance 13 l

l l

___-__-_--__-_--A

QUESTION NO.1 MP-2 JOBS GREATER THAN 10 MAN-REM 1980

. Actual Acu'tal-N. Manhours Mari-Rem Refueling 7467.79 100.410 Steam Generator Eddy 3546.00 49.300 Current Testing NRC IE Bulletin 79-02 7405.22 51.150 Reactor Head Cable Project 9185.00 36.900 Reactor Coolant Pumps 642.83 20.020 (4) Seal Replacement ISI Program 1106.45 20.150 Reactor Head Vent 3510.75 15.945 Modification CEDM Guide Cone insp. 104.70 18.670 and Repair RCP Oil Collection System 1210.00 10.820 Health Physics Blanket 7600.15 31.590

• Special Maintenance Jobs m---_--__-- --- - _ - - . - - . - - _ _ - - - - _ . - _ _ _ _ _ - - . - - J

_ QUESTION NO.1 MP-2 JOBS GREATER THAN 10 MAN-REM 1982 Actual Acu.tal M Manhours - M a n'-Rem Refueling

• 5978.71 84.400

• Steam Generator Eddy 12341.80 154.555 Current Testing (ECT)

• Steam Generator Nozzle 5290.42 296.280 Dam Modifications

• Steam GeneratorTube 8960.25 584.185 Plugging

• Steam GeneratorTube 247.37 55.710 Sample l

• Incore Instrument 2872.25 31.550 Modification Class 1 In-Service inspection 1281.00 34.520 (ISI) ,

• Replacement of "C" 1803.85 11.355 Charging Pump

• Health Physics Blanket 16734.30 69.450 Operations Blanket 1767.79- 21.520

• NRC IE Bulletins 79-02 and 22414.92 223.160 7914 (Hangers)

• l

• Special Maintenance Jobs i

l I

QUESTION NO.1 MP-2 JOBS GREATER THAN 10 MAN-REM 1983-1984 Job Actual Acdial

- Manhours ManIRem Refueling 10134.75 77.215

• Steam Generator Eddy 11340.33 355.765 Current Testing (ECT)

• 5 team 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 Generator Tube 982.42 13.020 Radiography

• Steam Generator Tube 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

• RC5 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 Seals 1885.92 14.545 Replacement NNECO Personnel Blankets 40125.67 168.525 Contractor Personnel 4345.33 16.775 Blankets Radwaste Work and 130.17 21.390 Personnel Blankets

• Special Maintenance Jobs U

J 1

l

j l

QUESTION NO.1 MP-2 JOBS GREATER THAN 10 MAN-REM 1985 Job Actual Acy"tal

- Manhours Man-Rem i 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 (ISI)

• 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 Instrument Stalk 610.50 17.595 Repairs Trash & Laundry Pick-up 816.92 12.840 NNECO Personnel Blankets 597.84 52.700

• Special Maintenance Jobs i

-- - 4

a QUESTION NO.1 MP-2 JOBS GREATER THAN 10 MAN-REM 1986 Actual AcuI'al N - Manhours t

Mari. Rem Refueling 4034.25 -82.220

• Steam GeneratorTube 4317,92 ~ .137.830-Sleeving and Pluging Steam Generator Nozzle 607.00 92.265 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 Class 1 In-Service inspection 2305.33 61.285 (151)

Corrective Maintenance 2602.58. 33.475 Preventative Maintenance 1693.33 31.065

• Appendiv."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 Component inspections for 843.91 10.090 E EO Qualifications NNECO Personnel Blankets 1616.75 24.265

• Special Maintenance Jobs-

MILLSTONE UNIT 2 EXPOSURE TRENDS FOR REPETITIVE JOBS 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 j 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. l.ocat shielding

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 1986 As above plus:

1. A new cleaner was used for post-refuel stud hole cleaning

< m

y Reactor Coolant Pump Seal Repairs Year 1980 1981 82 1983 84 1985 1986 Person Rem 20.7 5.6 13.8 13.6 IS 3 Seals 4 1 2 2 S Exposure Controls 1980

1. The RTD connectors were modified to facilitate removal and replacement

2. The seats 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 i, Ai above plus:

1. Shielding was installed between the "B" RCP seal area and the pressurizer i auxiliary spray line 1985 Asabove 1986 Asabove 1 j I

I u- . _ _ -

j

l Class 1 Inservice Inspection s 1

-Year 1980 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

3. CCTV was used for reactor vessel 151 1981 82 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. RCS piping was prepared and inspected with water level above the centerline.

This saved about 6 person-rem l

2. A new RCP rotating device allowed inspection of the flywheel without having to l 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 w

Steam Generator insp:ction & 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 lancing.

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 -

l: Plug Repair - -

56.7 - -

j Radiography - -

13.0 13 7.5 l Tube Sample -

55.7 26.4 16.5 -

Sludge Lancing ~ - -

66.8 13 _16.1 l Chem. Cleaning - - -

96 -

' Sec. Side inspec. 6 7 8 - -

iTotal 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

2. CCTV used for remote observation

3. Shielded waiting areas were constructed. These saved about 40 person-rem 1983-84 i As above plus:

j

1. The channel heads were chemically decontaminated (DF = 3). Exposure savings l are estimated as follows:

]

Task Loop Area Shielding Decontamination ECT 61 30 Plug Repair 11.1 260 Tube Sample 5.7 130 l

1

Steam 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 sNelded

5. The decontamination skid was shielded

6. Auto, mated tube plugging equipment was tried but didn't work well, thus requmng 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 I hot leg

4. New honing machine didn't cause high contamination exposure problems as 4 prior model did j

5. New robo +., 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 s!ceving. Using ROSA 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 Sludge Lancing 3 -

Radiography 4.2 -

_____--_-___w

L .

l 1- . 51-

-)

i ALARA IMPLEMENTATION AT' MILLSTONE U' NIT'2 ACP 6.02, MAINTENANCE OF OCCUPATIONAL RADIATION EXPOSURE ALARA T0 PROVIDE THE METHOD, ESTABLISH,THE AUTHORITY AND DELINEATE RESPONSIBILITIES TO ENSURE THAT ALARA-EXPOSURE CONTROLS ARE EXERCISED AND DOCUMENTED ON i 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 i

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 l I

l FRD - 12/10/87 -)

I l

b ...

)

ALARA REVIEW PROCESS ,

1. PERFORMANCE OF' WORK ACP 6.02 l

lF' EST) MATED EXPOSURE BETWEEN 1-5 MAN / REM, UNIT ~

EVALUAiES THE NEED FOR AN ALARA' INSTALLATION: REVIEWS.

IF ESTIMATED EXPOSURE GREATER THAN 5 MAtuREM, AN ALARA . INSTALLATION REVIEW IS. IMPLEMENTED BY JOB TASK LEADER ON SF847 AND 848.

t

11. DESIGN CHANGES-- ACP-GA-3.10 IF ESTIMATED EXPOSURE MORE THAN.1 MAN / REM, APPLICABLE SECTIONS OF SF338 ARE REVIEWED.

1 I

q EJw - 12!1DL82 l1 i

L ..

4

' \L <

7 q ROUTINE MANAGEMENT INVOLVEMENT IN ALARA CONCERNS 3 OUTAGE ALARA REPORT PROMULGATED ~BY ACP6.13 (SEE:

EXAMPLE)

FORMAL STATION RESPONSE TO ALARA OUTAGE REPORT-RECOMMENDATIONS (SEE EXAMPLE)

STATION SERVICES SUPERINTENDENT'(H. HAYNES) INVOLVED; W1TH CORPORATE EXPOSURE REDUCTION INITIATIVES STATION G0ALS DIRECTLY RELATED TO G0ALS ESTABLISHED BY CORPORATE RADIOLOGICAL ASSESSMENT BRANCH INCREASED ALARA STAFF ASSIGNED FOR OUTAGES INCREASED ALARA AWARENESS DURINGLOUTAGES:

ADMINISTRATION LETTER, OUTAGE MEETINGS, VISUAL AIDS, ETC.

- I SIGNIFICANT EMPHASIS ON TEMPORARY AND PERMANENT l

SHIELDING'(NON-REGENERATIVE HEAT EXCHANGER, STEAM GENERATOR PLATFORM SHIELDING CAPABILITIES, ETC.)-

1 DAILY STATUS REPORT (sEE EXAMPLE)

I fm _ _12/10/87 L m

EXPOSURE REDUCTION PROGRAMS 1

MOCK UPS PHOTO BOOKS / COMPLETE VIDE 0 DOCUMENTATION OF CONTAINMENT DURING 1988 REFUEL OUTAGE DURING 1988 REFUEL OUTAGE CHEMICAL DECONTAMINATION CONTAINMENT DECONTAMINATION i

l FRD -12/10/87

_ _ _ - -- _ --_D

D N

A S

N O

I T

A C

I E F L I U

D D E O H M C

S T N

N A O L I P Y

G TA L E O T A R P L N I

U Y A O T S D E N T S O M O I E P L I

H EL T X S I T P O E T B E

M M P E G

A I L L R A D I D O N U A E F O B V T G G I

A S A T E S D R N N A S L E E I

G I P N A C E E L W S U E I R N U O T C P R U T

DS N N L C C X E O 0 R I EE L A 0 E T S 1 E

HI O P S / A E T W CD F M G S D M R A O SU I N L N / R P T E I A A T L U F S H L K O N E D L O T A N G L E N G N A 1 A A M N E N N N N R R A T P O G O OI I E R S R M I I A I I

TE T A P U R T G S X R L A Q E U E AE R E A A C E P O R U N O LI T - - - - - - - -

AG C VN A EE F o o c  ;

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 H R O A TT W T ET T I MA T F N GY O A P NT E U A I E D R Q S KF E U I

N A 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 Y R 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 O O N O I T D C O C S - - A -

R P E M P I o o

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I MILLSTONE UNIT 2 1

EXPOSURE SAVINGS THRU' ALARA (man-rem) 1981 82

$hKd Waiting Areas 40-1983 84 l Task Channel Head Decon Loop Area Shieldina ECT 30 61 Plug Repair 200 11 Tube Sample 130 5.7 1985 Task Channel Head Decon Loop Area Shieldina Sleeving 1200 120 l Plugging 82 2 Radiography 37 4.5 Tube Sarnple 55 4.5 1986 Task Channel H.ead Decon Loop Area Shieldina Plugging & Sleeeving 57.3 28 ECT 12.5 1.5 Sludge Lancing -

3 Radiography -

4.2 e a

Haddam Neck (Connecticut Yankee) 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. Using robotic equipment for steam generator (secondary side inspection (ECT) 86

6. Shielding used for cavity seal 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 modifications 10 l

1 I

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u_ . _. . ___ . _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ .__ __ - _-

A

I MILLSTONE UNIT 1 i

1984 Exposure Savings Realized by'ALARA Controls Estimated Savings ALARA Control (Person Rem)

1. Flush concentrator prior to repair. 5.0 l

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' conce ntrator.

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. Chemicaldecontamination 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

+ a

1 MILLSTONE UNITj 1985 Exposure Savings Realized by ALARA Controls Estimated Savings ALAR A Control' (Person-Rem)

1. Fuel pool " rust ring" decontamination for LPRM 19.8 and control rod blade disposal.

2. Replacemen_t of the refueling mast take up cable. 31.2

3. Shielding for hanger work 2 L . .. .

w

MILLSTONE UNIT 1 1986 Exposure Savings Itealized by ALARA Controls Estimated Savings ALARA Control (Person-Rem) s'

1. Improved material logistics for turbine 5 building roof repairs.

2. Shielding for hanger work 3

3. Decontamination 10 I

l

_ 3 --_ --=--- - =m 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 APPROVAL OF THE FORTY-YEAR OL AMENDMENT LOWERS COST TO OUR CUSTOMERS i

CFJi__ _12/J0/87

Docket No. 50-213 B12778 Attachment 3 Haddam Neck Plant Additional Information for Forty-Year Operating License Extension December 1987

_ _ _ _ _ _ . _ i

l '- '

l  ;

MILLSTONE UNIT 2 l EXPOSURE SAVINGS THRU' ALARA(man-rem)- .

1' l 1981-1982 Shie!ded Waiting Areas 40 l

l 1983-1984 Task Channel Head Decon Loop Area Shieldina ECT 30 61 Plug Repair 200 11 Tube Sample 130 5.7 '

1985 '

Task Channel Head Decon Loop Area Shieldino- l 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 l Task Channel Head Decon loop Area Shieldina l

l Plugging & Sleeving 57.3 28 ECT .12.5 1.5 Sludge Lancing . -

3 Radiography -

4.2 4

2 HADDAM NECK (CONNECTICUT YANKEE) 1981 Exposure Savings Realized by ALARA Controls' Estimated Savings ALARA Control (Person Rem)

1. Reactor Vessel Head Shield, Cavity Seal Plate 25 Shield, Used Personnel Shields during Refueling j

2. Steam Generator in Wet Layup during RCP Seal Work - 28

3. Shield Loop Bypass Line during RCP Seal, Secondary 7 5/G, Valve Packing

4. Steam Generator Manway Shields 8 n.

k

(' A

3 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 Shiefding during ECT Probe Changes 9

7. Shielding of Manways during ECT 13 l

l l

l L .J

4 HADDAM NECK (CONNECTICUT YANKEE) 1984 Exposure Savings Realized by ALARA Controls i

Estimated Savings ALARA Control (Person Rem) l lt

1. S/G Manway Shielding during ECT Probe Changes 9

[

2. Reactor Head Shield during Core Exit Therm. Sleeve 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 Levelin Reactor Vessel during Refueling l

'I HADDAM NECK (CONNECTICUT YANKEE) ,

1987 Exposure Savings Realized by ALARA Controls <

(Preliminary information for SIG Projects Only)

Estimated .

Savings l

ALARA Control (Person Rem) 1

1. Use of Robotic Equipment for S/G ECT 86

2. Use of Robotic Equipment of 5/G Tube Plugging 380

3. Locating ECT Probe Pusher Outside S/G/ Skirts 21 i

l l

Docket No. 50-213 E12778

-l l

Attachment 4 Haddam Neck Plant Additional Information for Forty-Year Operating License Extension l

l 1

December 1987 I

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