CY-97-017, Forwards Supplemental Response to Submitted in Response to Confirmatory Action Ltr

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Forwards Supplemental Response to Submitted in Response to Confirmatory Action Ltr
ML20137C889
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 03/20/1997
From: Feigenbaum T
CONNECTICUT YANKEE ATOMIC POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CAL, CY-97-017, CY-97-17, NUDOCS 9703250157
Download: ML20137C889 (5)


Text

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1 CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD . EAST HAMPTON, CT 06424-3009 March 20,1997 Docket No. 50-213 CY-97-017 l 1

Re: 10CFR20 1 ,

U. S. Nuclear Regulatory Commission '

Attention: Document Control Desk Washington, DC 20555 i

Haddam Neck Plant Supolemental Response To Confirmatory Action Letter 4 The purpose of this letter is for the Connecticut Yankee Atomic Power Company l (CYAPCO) to supplement the response to the Nuclear Regulatory Commission's (NRC)

Confirmatory Action Letter, dated March 4,19970 ) provided by letter dated March 7,  !

1997.(2) Attachment 1 to this letter provides information cn the actions CYAPCO is taking in the on-going investigation to determine the extent of radioactive material that may have been inappropriately released offsite.

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CYAPCO acknowledges, as stated in the NRC's Confirmatory Action Letter, that none  ;

of the actions discussed in Attachment 1 precludes CYAPCO from taking action as necessary to ensure the health and safety of workers and the public, protect the .

) environment, and comply with applicable regulatory requirements.

Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C. 2232, CYAPCO will:

1) Notify the NRC Region I Administrator immediately in writing if CYAPCO's understanding differs from that set forth in the NRC's Confirmatory Action Letter;
2) Notify the NRC Region I Administrator if for any reason CYAPCO cannot complete the actions within the specified schedule and advise the NRC Region I (1) NRC Letter from H. L. Miller to T. C. Feigenbaum, " Confirmatory Action Letter,"

dated March 4,1997.

(2) T. C. Feigenbaum Letter to U. S. Nuclear Reguls4ory Commission, "Haddam , <

Neck Plant Response to Confirmatory Action Letter," dated March 7,1997. i !

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U. S. Nuc!rr Regulatory Commission CY-97-017/Page 2 Administrator in writing of CYAPCO's modified schedule in advance of the change; and

3) Notify the NRC Region I Administrator in writing when CYAPCO has completed I the actions addressed in the NRC's Confirmatory Action Letter.

If you should have any questions, please contact Mr. G. P. van Noordennen at '

(860)267-3938.  !

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY FOR: T. C. Feigenbaum Executive Vice President and Chief Nuclear Officer BY: t/

J. J. ldPlatfey  !

Haddam Neck Unit irector cc: H. J. Miller, NRC Region i Administrator M. B. Fairtile, NRC Project Manager, Haddam Neck Plant W. J. Raymond, NRC Senior Resident inspector, Haddam Neck Plant K. T. A. McCarthy, Director, CT DEP Monitoring and Radiation Division Subscribed and sworn to before me this 20* day of March,1997 h,

Date Commission Expires: *~ 7 23 2*/

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. . l Docket No. 50-213 I CY-97-017 l l

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Attachment 1 ,

l Haddam Neck Plant j l

Supplemental Response To Confirmatory Action Letter March,1997

U. S. Nucle:r Regulatory Commission CY-97-017/ Attachment 1/Page 1 Haddam Neck Plant Supplemental Response To Confirmatory Action Letter Action Plan to determine the extent of radioactive material that may be have been inanoropriatelv released offsite CYAPCO has engaged the services of an experienced individual to act as our Survey Plan Manager. He will develop a comprehensive action plan to identify the extent to which radioactivo material may have been inappropriately released from the Radiologically Controlled Area (RCA). The performance of the action plan elements will be complete no !ater than September 30,1997. We will provide a report of this survey effort upon its completion. A copy of the action plan will be provided to the Senior Resident Inspector.

Action Plan Elements Although still under development, the action plan will contain the following elements:

1. Identify survey locations
2. Identify items to be surveyed
3. Establish procedures to govern the performance of the surveys
4. Determine resources required to complete the action plan i
5. Communicate the action plan issues and status  !

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6. Identify programmatic deficiencies
7. Establish milestones and estimated completion dates.

Conduct of Radioloalcal Surveys j To ensure the action plan surveys are performed appropriately, the following actions )

will be taken.

1. The Survey Plan Manager will communicate the standards and expectations regarding the performance of surveys to the health physics technicians. j I
2. Health physics technicians performing the surveys will review and sign their j acknowledgment of all procedures governing tne release of material from the RCA.

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i U. S. Nuclaar Regulatory Commission 4

{ CY-97-017/ Attachment 1/Page 2 1 3. CYAPCO will ensure that the surveys are being properly conducted through

periodic assessments and management oversight.

l 4. CYAPCO supervision will review all survey documentation for accuracy and

' j completeness. '

On-Goina Activities

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While the action plan is being developed, CYAPCO will continue to identify the extent to j which radioactive - material may have been inappropriately released. Initial  !

assessments indicate that material released from the RCA falls into one of three categories: 1) the material remains at the Haddam Neck Plant, 2) the material is sent to  !

a Northeast Utilities facility, and 3) the material is sent to a another licensed or j unlicensed facility. Currently, we are polling the station to determine what items may  !

have been inadequately surveyed to ensure we focus our surveys on those items identified. l The following outlines the ongoing measures to address the three categories listed above:

1. Material remaining at the Haddam Neck Plant l The corrective actions described in the letter of March 7,1997 include performing non-RCA surveys both inside and outside the protected area and performing surveys of all material exiting the protected area until the non-RCA surveys are completed.
2. Material sent to a Northeast Utilities Facility All Northeast Utilities facilities that contain material that may have been released by the Haddam Neck Plant are being identified and will be surveyed as appropriate.
3. Material sent to a licensed or unlicensed facility 1996 contracts, security records and purchase orders are.being reviewed to identify vendors whose work included the unconditional release of material from a contaminated area. Material identified through this process will be evaluated to determine additional locations that require follow-up confirmation surveys.

The determination for follow-up surve~ys will be based on an evaluation that includes the following types of considerations:

e the material had a high risk potential for being inadequately surveyed (e.g.,

( use processes, chemical and physical form); or e contamination shielding may have occurred due to geometry and/or material properties .

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