ML20148F541
| ML20148F541 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/19/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20148F403 | List: |
| References | |
| NUDOCS 8801260277 | |
| Download: ML20148F541 (7) | |
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SUPPLEMENTAL SAFETY LYALLATION BY THE OFFICE OF NUCLEAR REACTOR REGULA SUPPOP. TING AMENDMENT NO. 33,10 FACIL11Y CTEFATING LIC_ENSE NO. DPR-61 CONNECTICD1 YAhKEE ATOMit F0WER COPPANY HADDAM NECK PLANT 000kCT hC. 50-?13 1.0 ALARA MEASURES In addition to the ALARA measures described in the SER (June 5,1987) the licensee is actively seeking new methods to reduce total person-rem dose. The licensee's Exposure Reduction Initiative Program, which was implemented in 1986, contains many such short-and The thirteen short-long-tem initiatives to reduce personr.el dose.
tem initiatives which are part of this program are scheduled to be achieved in the 1987-1988 time frame. These short-terin ALARA initia-tives include increased worker ALARA awareness (through ALARA train-ing and use of ALARA postings throughout the plant), optimization of rad-worker efficiency, eq'lipment decontaminallon, and a cobalt The seven long-tenn initiatives in this program l
reduction program.
have a completion date in the early 19,90'd. These ALARA initiatives
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include full syst>.4 (including fuel) decontamination, improved primary side coolant water chemistry contiois (such as constant, high pH levels) to lower primary side dose rates, improved secondary side l-chemistry to reduce steam generator maintenance, use of non.:obalt material alternatives, longer fuel cycles, and use of advanced 1
robotics techniques to minimite worker time spent in radiation areas.
Implementation of the projects described in the Exposure Reduction Initiative Program should result in lower overall dose rates and lower collective deses at Haddam Neck, g2260277eso339 ADOCK 05000213 p
l e
A high percentage of repetitive maintenance jobs (e.g., steam genera-tormaintenance)requiringlargeworkforcesinhighradiationfields has been one of the major contributors to the high annual doses at Haddam Neck in past years. Through the use of a computer code on plant comMnent availability and maintainability, the licensee is now beginning to determine the root causes of the equipment / component problems resulting in high doses at Haddam Neck. By identifying the generic problems behind these equipment / component problems and then through the use of preventive maintenance, the licensee hopes to eliminate many of the repetitive equipment malfunctions / breakdowns before they occur. The selective use of preventive maintenance, along with the use of shielding, decontamination, remote maintenance, and better use of personnel resources (higher productivity and experience level, smaller work force), should result in collective annual doses at Haddam Neck which are comparable to the PWR industry average.
In addition to the doses accrued during plant operation, doses will result from plant decomissioning at the end of plant life. The licensee states that any increase in tendency for corrosion product buildup during the extended plant life period will be ecmpensated for by improved chemistry contrei and other ALARA measures to actually lower primary side dose rates with time.
In addition, NURIG/CR-0130, "Technology, Safety, and Cost of Decommissioning a Reference PWR,"
states that the inventory of activation products and the resultant radioactivity in the reactor vessel and internals will not increase significantly in the period of extended operation. Therefore, the
i extended operating time should not have a measurable adverse effect on occupational doses resulting from plant deconsnissioning.
As stated above, the licensee instituted an ALARA program in 1977 and The licensee's an Exposure Reduction Initiative Program in 1986.
Radiation Protection /ALARA Program has been recognized by the staff as adequate overall in the Systematic Assessment of Licensee Perfor-mance (SALP) from 1979 to 1987 (Category 2 average rating). CYAPCO's consnitment to state-of-the-art ALARA is contained in the Corporate Standardized Health Physics Procedures, the Corporate ALARA Program and the Standardized Training Program for the Haddam Neck site which identifies the health physics organization. There is routine manage-ment involvement in station ALARA concerns. Station ALARA goals are directly related to goals established by the corporate Radiological l
Assessment Branch. Corporate supplies health physics supervisors to the plant to assist ud oversee the station health physics staff Worker involvement in minimizing doses is encouraged during outages.
through worker initiatives and worker input to ALARA feedback re-The licensee should continue to encourage worker and contrac-ports.
tor awareness at the grass roots level of ALARA by making dose I
reduction an integrO part of design, installation, and maintenance at Haddam Neck.
2.0 DOSE ASSESSMENT The staff has audited the licensee's dose assessment from 1974 through 1987 against the criteria of SRP Section 12.3.' CYAPC0 expects that the 771 person-rem cumulative dose (1974 to 1987) will be reduced for the extended three years due to (1) extensive use of
system decontamination; (2) improved primary and secondary side chemistry; and (3) advanced ALARA techniques such as robotics which should minimize worker time in radiation areas. Dose allowance for crud build-up will be offset by dose savings from a centinually improving ALARA program.
It is expected that state-of-the-art technologies will be in use including some robotics, enhanced chemis-try control and modern decontamination processes. The licensee l
l plants to meet this dose goal through implementation of both the short and long-tem dose reduction initiatives described above. With the increased ALARA awareness shown by the corporate health physics group in recent years, and successful implementation of the dose reduction initiatives, the licensee should be able to realize this dose goal for Haddam Neck within the next few years. The licensee has projected a three-year averaged dose goal of 525 person-rems / year to be realized by Haddam Neck by 1990.
3.0 CONCLUSION
On the basis of the staff's review of the 'icensee's ALARA program and information presented at the meeting held with the licensee, the staff believes that the licensee is making real progress towards establishing an effective ALARA program at Haddam Neck. The licensee's new Exposure Reduction Initiative Program, including the three-year average dose goal, is consistent with the guidelines of Regulatory Guide 8.8 for ensuring that occupational radiation doses will be maintained ALARA and in compliance with 10 CFR Part 20 requirements. The staff also believes that the licensee's recent attempts to identify the root causes of the plant's equipment / component problems will result in a reduction in the maintenance related doses
at Haddam Neck. The staff will follow the progress of the ALARA program at Millstone Unit No. 2 to ensure that improvements in this program and in the annual collective doses continue to be made.
3.1.3 Environmental Impacts - Occupational Exposures The staff has evaluated the licensee's dose assessment for the years 2004 to 2007 (the additional years during which Haddam Neck would operate), and compared it with current Haddam neck and overall industry occupational dose experience. The average cumulative occupational dose for Haddam Neck over the five year period covering 1983-1987 has been 1,027 person-rem per year, which is high compared to the current five year average of 560 person-rem dose per unit per year for operating PWRs in the United States.
(The high doses were due to steam generator outages and poor primary side chemistry controlswhichwerelaborextensive).
In 1986, the licensee estab-lished a new Exposure Reduction Initiative Program. Part of this program involved the establishment of a three-year averaged cumula-tive dose goal for Haddam Neck of 525 person-rems / year.
(This three-year averaged dose will be revised downwards on an annual basis as Haddam Neck improves its performance.) The licensee expects the three-year averagedcumulative dose for Haddam Neck to reach this goal by 1990. The licensee hopes to accomplish this through continued implementation of ALARA measures, as well as through the achievement of thirteen short-term and seven long-term exposure reduction initia-l tives. The thirteen short-term initiatives have a scheduled achieve-ment date of 1987-1988. The initiatives include increased ALARA awareness, optimization of construction work efficiency, equipment
decontamination, and a cobalt reduction program. The six long-term initiatives in this program have a completion date in the early 1990's. These ALARA initiatives include full system (including fuel) decontamination, improved primary and secondary side chemistry controls, longer fuel cycles, and use of advanced robotics techniques to minimize worker time spent in radiation areas. By reducing the annual occupational exposure at Haddam Neck through the use of these ALARA measures, the licensee estimates that the additional dose contribution from operating the extra few years beyond the existing license will be less than 2000 person-rems. This is roughly equiva-lent to the five-year dose from a typical U.S. PWR.
Additional occupational exposures will result from decomissioning of Haddam Neck, although these doses will be incurred with or without the license extension period. Any increased tendency in corrosion product buildup during the period of extension will be compensated for by improved chemistry controls and other ALARA measures to actually lower primary side dose rates with time. Consequently, the extended operating time should have no measurable adverse effect on decomissioning dose requirements.
The staff concludes that the licensee's occupational dose assessment is acceptable, and their Radiation Protection Progran is adeouate to l
ensure that occupational radiation exposures will be traintained ALARA l
and in continued compliance with the requirements of 10 CFR Part 20.
The licensee's new Exposure Reduction Initiative Program, including the three-year averaged dose goal, is in compliance with the guide-l lines of Regulatory Guide 8.8 for ensuring that occupational l
radiation exposures will be maintained ALARA and in compliance with 10 CFR Part 20 requirements. The licensee's recent attempts to identify the root causes of the plant's equipment / component problems should result in a reduction in the maintenance related exposures at Haddam Neck.
For these reasons, the staff finds the licensee's dose assessment to be acceptable.
Principal Contributcr:
J. Minns
-Dated: January 19, 1988 l
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