ML20205P771
| ML20205P771 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 11/01/1988 |
| From: | Randazza J Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 0613L-GDW, 613L-GDW, GDW-88-293, MN-88-105, NUDOCS 8811080287 | |
| Download: ML20205P771 (6) | |
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MaineYankee ELI8tf ELECTActf FOR MA:NE StNCE 1972 EDISON DRIVE e AUGUSTA, MAINE 04330.(207) 623 352,)
November 1, 1988 MN-88-105 GDH-88-293 i
Region I UNITED STATES NUCLEAR REGULATORY COMMISSION 475 Allendale Road King of Prussia PA 19406 Attention:
Mr. William T. Russell, Regional Administrator
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) Systematic Assessment of Licensee Performant.e (SALP)
Report No. 50-309/87-99 Gentlemen:
Subject:
Response to 1987 SALP Report This letter provides Maine Yankee's response to Reference (b).
Each area evaluated in the report is addressed separately below.
Plant Operations (1)
He are pleased that our excellent rating in this.rea has been sustained i
during the last SALP period. We will continue tt.trive to maintain our I
rating and to improve our performance in this arts.
Radiation Controls (3) l We do not believe that our performance in this..rea is accurately reflected in the rating and request reconsideration based on the following:
Maine Yankee's radiation control program over its sixteen years of operation i
l has been above average.
He have never had a single case of personnel exposure above th?
I regulatory limit, nor has any individual exceeded 5 Rem in any year since 1974, far better than the industry average.
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l Only approximately 0.57 of our employees and contractors with recorded exposures have ever exceeded 3 Rem in a year.
Our average personnel exposure over the sixteen years has been balow l
the industry average.
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Oe MaincYankee UNITED STATES NUCLEAR REGULATORY COMMISSION MN-88-105 Attention: Mr. William T. Russell Page Two He have never had a radiation release in excess of regulatory limits, nor have we had an incident of off site contamination.
The cose commitment (person-rem) to the public has been less than one hundred thousandth (10) of background.
Since 1980, the Maine Yankee Radiation Protection program has been rated as a 2.
The SALP report for the period ending January 31, 1987 noted some weaknesses but also noted the following:
"The licensee has initiated a number of program, policy and procedure upgrades during tnis assessment period to improve the Radiological Contr31s Program".
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"The Radiological Controls Improvement Program has been introduced to identify, track, analyze and resolve radiological incidents."
"There is evidence of corporate and site management involvement (in radiological controls) including frequent meetings, use of feedback and tracking mechanisms, assessment of activities, etc. with very tight control at all levels."
"The licensee has been conducting an effective program for liquid and gaseous effluent control."
"There was significant progress in radwaste volume reduction activities in 1986 including a 47% volume decrease...."
"The licensee's ALARA program is well documented and effective at all levels of the organization. Actual exposure of 92 man-rem (for 1986) reflects good controls in thl: area."
"In summary, although there were many areas of strength and no major programmatic deficiencies observed in this functional area, there were several areas where improvemer.'.s could be realized." (SALP Report 85-98, p. 15).
Prior to that SALP report, we had embarked on a program to improve our performance in this area. Among the initiatives taken were the following:
The onsite and offsite training provided to Maine Yankee radiological controls personnel increased.
The Radiological Controls Section Head was assigned to the INPO staff for fifteen months.
This permits us an excellent opportunity to effect continued performance improvements in the radiological controls area by having witnessed first-hand good practices at other facilities.
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MaineYankee UNITED STATES NUCLEAR REGULATORY COMMISSION MN-88-105 Attention: Mr. William T. Russell Page Three Maine Yankee has implemented a policy of hiring only college graduates as Radiation Controls Technicians. Although this program may have resulted in a reduction of the level of experience of our technicians in the short rur-we believe that, in the longer term, the improved professionalism and level of competence of our technicians will enhance the overall quality of our radiation controls program.
He a'.so believe u t this policy leads the industry and is consistent with the Commission's desire to hi e college graduates wherever possible.
Extensive capital improvements were made to the Radiological Controls Acce;s control area and facilities to enhance overall access control and tc improve the working area for the radiological controls staff.
The Radtologict) Controls Improvement Program has continued to be effective in identifying, analyzing, trading, and resolving radiological incidents.
This, coupled with the Radiological Controls Performance Assessment Program (PAP), continues ta identify areas where performance can be and has been improved.
The current SALP report indicates that the radiation control program exhibited some weaknesses during the last outage but was good during normal operations. He agree with this assessment but we do not agree that a category 3 appropri*tely ref?ects performance for the entire SALP period.
The 198.' refueling outage occurred during the beginning of the SALP period and lasted for approximately two renths, or about ten percent of the 4Qhteen-month SALP pitriod. During the outage, in an effort to improve plant i
safety and reitehtitty, we undertook more radiation work than may have been appropriate from a strict radiation controls standpoint.
From a performance standpoint, we continued to achieve excellent results from our radiation controls program.
The man-rem for these jobs were comparable to ilmilar jobs at other facilities.
I As recognized in the SALP report Maine Yankee agressively responded to NRC concerns with sound corrective actions. During the outage, when the NRC
- nspector pointed out several areas where ont program controls could be improved, we instituted prompt and effective corrective actions including suspension of significant radiological work until all workers were briefed on radiological conditions. Other longer term improvements to our radiation controls program, as mentionel in your reoort, were implemented soon after the last outage.
Thase included significant enhancements in our radiation controls outage planning.
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MaineYankee UNITED STATES NUCLEAR REGULATORY COPFISSION MN-88-105 Attention: Mr. H1111am T. Russell Page Four As noted in the report, one individual reported concerns to the NRC instead of reporting them first to his employer or to Maine Yankee.
These concerns were investigated by the NRC.
No violations of regulatory requirements were identified.
The performance of the radiological controls program was rated as "generally good" (P. 16) for the majority of the SALP evaluation period during routine operations. Also, performance in '.his area was determined to be improving near the close of the assessment period.
This is consistent with NRC's assessrrent, as documented in SALP, of Maine Yankec's performance in radiological controls for the past eight years, except for the observations of performance durin1 the 1987 refueling outage.
He believe that the performance of our radiciogical controls program during the two-month 1987 refueling outage is being given disproportionate weight compared to our historic performance and thet during the remainder of the period.
He believe that our record in Radiation Frotection is one of constantly striving for improvement and learning from our past experiences, rather than a record of declining performance.
For the reasons stated above, we regt'est that the rating in this area be reconsidered.
He plan to assess the effectiveness of our Radiation Controls Program during this refueling outage and discuss our findings with you as recommended by the report.
The assessment will be in addition to the normal Performance Assessment Program (PAP),
Maintenance and Surveillance (1)
Haine Yankee is pleased with the improvements noted in this area and plan to continue to work for further improvements.
Maine Yankee is pleased with the continued ee ellence noted in this area.
He plan to continue to strive for improvement in this area.
Security (2)
Maine Yankee was not aware, prior to the receipt of the SALP report, that the NRC approved security plan was no longer considered adequate b,y the Staff.
He plan to work with the Staff to identify specific areas of concern and to propose appropriate improvements to the Security Plan.
MaineYankee UNITED STATES NUCLEAR REGULATORf COMMISSION MN-88-105 Attention: Mr. Hilliam T. Russtil Page Five Maine Yankee has made and is planning further enhancements to the tecurity program in response to the NRC's RER inspection and will work with the Staff to resolve any residual concerns they may have in this area.
Engineering an_d Technical Support (2)
Maine Yankee has met with the Staff to discuss our ongoing initiatives with regard to off-site power.
He understand that this meeting resolved the Staff's concerns in this area, pending further technical review of the capacitor bank installation.
Nonetheless, we are investigating further reliability enhancements in this area.
Safety Assessment / Quality Verification (2)
Maine Yankee plans to review audit activities to assure comprehensive program t
evaluations are adequate as recommended by the Staff.
Please feel free to contact me if you should have any questions or need any additional information.
Very truly yours, MAINE YANKEE
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John B. Randazza President SDE:MLJ c: Mr. Richard H. Hossman Mr. Patrick M.
Sears Mr. Cornellus F. Holden 0613L-G0W l
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