ML20207L071

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Discusses Concerns Re ALARA Program Expressed During 880722 Insp.Encl Figure 1 Depicts Exposure Performance Since Coming on-line in 1972 & Figure 2 Shows Annual Exposure Data Below Industry Average for Most Yrs Since 1973
ML20207L071
Person / Time
Site: Maine Yankee
Issue date: 08/11/1988
From: Randazza J
Maine Yankee
To: Russell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
MN-88-82, NUDOCS 8810170167
Download: ML20207L071 (5)


Text

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EttABLE ttECTHCTf FCe VANE SNCF 19?2 EDISON DRIVE. AUGUSTA. MAINE 04330. GOD 622 668 August 11, 1988 HN-88-82 Region I United States Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Attention: Mr. H1111am T. Russell, Regional Administrator

References:

(a)

License No. DPR-36 (Docket No. 50-309)

Subject:

Maine Yankee ALARA Gentlemen:

During the exit interview for Mr. Nimitz's recent inspection at Maine Yankee on July 22, 1988, Mr. Nimitz expressed concern regarding Maine Yankee's ALARA Program. The purpose of this letter is to anplify several points which we made during that meeting.

The first point of assessment of any program should be the quality of the program's output - the results.

In Figure 1, we depict Maine Yankee's exposure performance since it came on line in 1972.

For comparison, we also include the average for all PWRs, and the average for a grouping of plants of Haine Yankee's vintage.

These results are a running average for personnes exposure, and show that Maine Yankee's performance has been 130 to 200 man-Rem below the industry average over its sixteen year history.

Figure 2 shows the annual exposure data for Haine Yankee is significantly below the industry average for most years since 1973.

It is principally in the last four years that Maine Yankee has had a higher than average exposure, higher than our customary perforn.ance.

However, this higher exposure is not in and of itself, indicative of an inadequate ALARA program.

Nor does it reflect a diminished attention given to radiation protection.

Rather, it is due to extraordinary activitits performed to enhance the safety and reliability of the plant. Some of those activities u e listed in Table #1. He believe the radiation exposure for each of the listed activities was not excessive considering the work performed.

Please note that if these extraordinary contributions to dose are discounted, our recent average exposure is well below the industry average.

While it is our objective to minimize radiation exposure, we balance that against an overriding objective of enhancing public safety.

Much of the work we do to enhance safety and reliability goes beyond regulatory requirements but involves some additional exposure.

This work ranges from periodic containment inspections, to expanded non-destructive testing programs, to

'1 plant design changes. He believe thest efforts not only enhance public safety, but may also reduce radiation exposure in the longer term. He are f

genuinely concerned that a myopic preoccupation with minimizing immediate h

exposure may be detrimental on both counts.

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United States Nuclear Regulatory Commission Page Two At'tention: Mr. H1111am T. Russell MN-88-82 While we believt our ALARA program has been reasonably effective, we realize that it can be improved and will continue to seek better and more dose efficient ways to conduct our activities.

If clarification on some of the above would be of benefit to you, please feel free to contact me personally.

Very truly yours.

MAINE YANKEE r

w John 8. Randazza President GDH/bjp

Enclosure:

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$bhib. E!: 0 o.

o, Table 1 e

1984 Refueling Outage Non routine activities performed to Actual ensure plant reliability, safety, Exposure and oerformance Man-Rem feedwater Piping Modification 40 Thermal Shield Repair 138 79-02 Pipe Support Hodifications 49

$/G Moisture Separator Replacement 22.9 Repacking RCS Loop Stop Valves 17.7 RCS Loops 2 & 3 Insulation Replacement 12.2 RCS Loops 1, 2, & 3 RTD Replacement 10.1 S/G Thermal Sleeve Replacement 26 Appendix R Modifications 21.3 S/G Sludge Lancing 18.2 CEA Extension Shift Repair LB TOTAL 365.20 Man-Rem 1984 TOTAL 845 Man-Rem 1985 Refueling Outage Non routine activities performed to Actual ensure plant reliability, safety, Exposure and oerformance Man-Rem RCP Motor Replacement 20.7 RCP Oil Collection System Installation 38.4 S/G Sludge Lancing 12.1 PITS Modification 12.6 PCC Piping Modification 10.6 RCP's Seal Replacement 1L2 TOTAL 126.10 Man-Rem 1985 TOTAL 633 Man-Rem l

1987 Refueling Outage l

l Non routine activities performed to Actual ensure plant reliability, safety.

Exposure l

AnLperformance Man-Rem S/G Chemical Cleaning 30.2 S/G Oryer Replacement 46.2 RCP Impeller Replacement 53.6 S/G Sludge Lancing 21.0 RCP Motor Replacement 20.4 RCP's Seal Replacement 30.8 RCS RTO Repair 12.JI TOTAL 215.00 Man Rem 1987 TOTAL 690 Man-Rem 0333L-G0H

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Figure 2

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COLLECTIVE RADIATION EXPOSURE

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PWRS 1

1000 900 800 aLO 73 74 75 76 77 78 79 80 81 82 8

84 85 86 87 YEAR

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