CY-97-120, Forwards Response to Violations Noted in Insp Rept 50-213/97-08.Corrective Actions:Conducted Detailed Training of Health Physics Technicians & Staff

Forwards Response to Violations Noted in Insp Rept 50-213/97-08.Corrective Actions:Conducted Detailed Training of Health Physics Technicians & Staff

ML20203E459
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/05/1997
From:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-213-97-08, 50-213-97-8, CY-97-120, NUDOCS 9712170068
Download: ML20203E459 (12)

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CONNECTICUT YANKEE ATOMIC POWER COMPANY

< HADDAM NECK PLANT '

362 INJUN HOLLOW HoAD e EAST HAMPToN. CT 06424-3009 December 5,1997 Docket No. 50-213 CY-97-120 Ra: 10 CFR 2.201 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Haddam Neck Plant Repiy to a Notice of Violation (NOV)

NRC Intemated Insoection Reoort No. 50-213/97-08

!n a letter dated October 29,1C97,W the NRC staff transmitted a report documenting the results of an NRC inspection which was conducted during the period July 3,1997 and August 11 through September 19, 1997 at the Connecticut Yankee Atomic Power Company's (CYAPCO) Haddam Neck Plant (HNP). Areas reviewed by the NRC during this time period included the applied radiological controls program, including extemal and intemal exposure controls, the contamination control program, training of personnel relative to 49 CFR 172 Subpart H, plans and activities associated with radiological characterization of the site for decommissioning planning purposes, and HNP action on commitments to the NRC relative to NRC Confirmatory Action Letter (CAL) No.1-97-007, dated March 4,1997.*

The inspection identified two violations. The first violation involved three examples of failure to follow radiation protection procedures, and was identified by the NRC. The second violation involved failure to perform adequate radiological surveys of material deposited in the HNP site landfill, and was identified by HNP personnel.

9712170068 971205 PDR ADOCK 05000213 G PDR (1) J. R. White (NRC) to T. C. Feigenbaum (CYAPCO), "NRC Inspection Report 50-213/97-08," dated October 20,1997.

(2) H. L. Miller (NRC) to T. C. Feigenbaum (CYAPCO), " Confirmatory Action Letter No.1-97-007," dated March 4,1997.

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U. S. Nucle:r Regulatory Commission C%97-120/ Page 2 Pursuant to the requirements of 10 CFR 2.201, Attachment 1 provides the CYAPCO response to the Notice of Violation (NOV) and presents the current implementation status of the corrective actions.

CYAPCO considers these violations 'tery serious and is committed to implement and complete the corrective actions to improve HNP performance. We will continue to keep the NRC Staff informed of our piogress in these areas.

Attachment 2 presents CYAPCO's commitments made within this letter and the attachments. Other statements within this letter are provided for information only, if there are any questions regarding this submittal, please contact Mr. G. P. van Noordonnen at (860) 267-3938.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY ub 4 /

RussblA._, Mellor T Vice President - Operations and Decommissioning Attachments cc: H. J. Miller, NRC Region i Administrator J. R. White, Chief, Radiation Safety Branch M. B. Fairtile, NRC Senior Project Manager, Haddam Neck Plant W. J. Raymond, NRC Senior Resident inspector, Haddam Neck Plant D. Galloway, Acting Director, CT DEP Monitoring and radiation Division I

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t QQCket Number 50-213 CY-97-120 Attachment i Haddam Neck Plant Reply to a Notice of Violation NRC Inspection Report No. 50-213/97-08 December 1997

t U. S.. Nucle:r Regul tory Commission .

.CY 97-120/ Attachment 1/Page 1 l Restatement of Violation During NRC inspections conducted during the period July 3 through September 19,1997, j violations of NRC requirements were identified. In accordance with the " General i Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381-June 30,1995) the violations are listed below.  !

A. Techniv. Specification 6.11, Radiation Protection Program, requires that procedures  :

for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20 and be adhered to for all operations involving personnel radiation exposure.

1. Radiation protection procedure RPM 2.7-3 " Contaminated Personnel Survey and Decontamination," Revision 9, requires that a person with facial contamination be sent to be whole-body-counted.

Contrary to the above on February 22,1995, an individual, working on radiation work permit (RWP) 1950603, " Primary Steam Generator Nozzle Cover 1 Installation and Removal," from 4:34 p.m. to 6:56 p.m., received a facial contamination and was not sent to be whole-body-counted.

2. Radiation Protect;0n procedure NUC RPM 5.1.2 " Posting of Radiological Controlled Areas," Revision 1, specifies in Attachment 2 that contaminated areas (i.e., any area where the removable contamination is greater than or equal to 1,000 dpm/100 cm') be posted with signs bearing the radiation caution symbol and the words " Caution Radioactive Material".

Contrary to the above:

a. On September 11, 1997, an area at the base of the Bus 10 concrete pad exhibited removable contamination of about 4,000 dpm/100 cm' and was not posted as required.

b. On September 19, 1997, an area known as the Culvert Area exhibited 2 2 removable contamination of about (4,000 dpm/100 cm ] 11,000 dpm/100cm and was not posted as required.

This is a Severity Level IV violation (Supplement IV).

B.10 CFR 20.1501 requires that the licensee make, or cause to be made surveys that may be necessary to comply with the regula?,'ons in this part and are reasonable under the circumstances to evaluate concentrations or quantities of radioactive material.

Contrary to the above, surveys of material placed in the licensee's landfill area, located aoproximately [0.25] 0.75 miles southeast of the Haddam Neck station were inadequate

U. S.. Nucle:r Regul: tory Commission l

-CV-97-120/ Attachment 1/Page 2 l to detect and evaluate radioactive materials deposited at some unknown time at the location. Such surveys were necessary and reasonable to comply with the requirements of 10 CFR 20.1801,10 CFR 20.1802,10 CFR 20.1902, and 10 CFR 20.1302.

Specifically, Co-60 activity in isolated spots of soil at the landfill ranged frorn about 0.31 pCl/g to 4.3 pCi/g at the location, Cs 137 ranged from 0.17 pCilg to 34.8 pCl/g at the l location, and material (e.g., fabric, brick) at the location exhibited radioactive contamination that ranged from 400-600 corrected counts per minute (ccpm) (i.e., l approximately 4,000 - 6,000 dpm assuming a 10 % detector efficiency).

This is a Severity Level IV violation (Supplement IV).

A, RADIATION PROTEC'flON PROCEDURES Reasons For The Violation Three examples pertaining to radiation protection procedure violations are identified in the 4

subject Notice of Violation (NOV) as documented in Reference 1. Reasons for these violations are identified below.

Example 1-Contaminated Pettonnel Survey and Decontamination This radiation protection procedure violation pertains to a worker contamination event which occurred on February 22,1995 where, during the course of work on the primary steam generator nozzle cover installation and removal, an individual was contaminated.

The contamination was initially detected by a Personnel Contamination Monitor (PCM) and confirmed using a frisker. The frisker reading, as documented on the personnel contamination report, was 200 corrected counts per minute (ccpm). The subject individual was decontaminated and frisked again by the HP Technician. The results indicated that the level was less than 100 ccpm. The individual was allowed by a Health Physics technician to leave the site, bypassing the PCM at the Radiological Control Area (RCA) exit.

Upon exiting the Protected Area, the contaminated individual activated the portal monitor alarm. Health Physics responded to the alarm. Based upon the results of the post decontamination frisk, the Health Physics technician allowed the contaminated individual to pass through the portal monitor without receiving any additional frisk, or whole-body-count. Although procedural guidance contained in RPM 2.7-3 " Contaminated Personnel Survey and Decontamination" Revision 9, requires a person with facial contamination to be whole-body-counted, the Health Physics technician did not requ;re the worker to obtain a whole-body count due to a non-conservative interpretation of the procedural

, requirements to initiate a whole-body-count in cases of facial contamination.

The contaminated individual requested a whole-body-count the next morning, February 23,1995, and was shown to have an initial uptake of 262 nCi (Co-60). The subsequent i

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U. S.. Nucle:r Regul: tory Commission CY 97120/ Attachment 1/Page 3 dose assessment determined the uptake resulted in 11 mrem. The actions of the Health Physics technician and the contaminated individual as stated above, were r ;onstructed after the fact, based upon interviews with the contaminated individual and station personnel. The Health Physics technician involved with releasing the contaminated individual f/om the HNP site was terminated from employment in the early part of 1997 and as such, was not consulted with respect to the facts of this event. However, the technician's supervisor is still employed at CY and has been interviewed as part of the i ongoing internal investigation of this event. This investigation will be completed by the end of December 1997. Preliminary results of the internalinvestigation conclude that the following shortcomings existed in the Health Physics department in February 1995:

• Programmatic inadequacies which allowed the technician to improperly assess the situation.

. Insufficient management oversight of the technician's actions.

Examples 2 and 3-PottIDg_of Radiological Control Areas The area where the Bus 10 concrete pad currently exists was previously used for a radioactive waste storage area. The area known as the culvert area, located behind the zone 6 control point, was used to store cement shields used for radioactive material storage (e.g., resin liners). While performing inspections of the area adjacent to the base of the Bus 10 concrete pad on September 11,1997 and the Culven Area on September 19, 1997 the NRC inspector requested that surveys be performed. The  ;

results of these surveys identified removable contamination which upon further inspection exhibited readings of approximately 4,000 and 11,000 dpm/100cm respectively. These areas were not posted as required by Radiation Protection Procedure NUC RPM 5.1.2,

" Posting of Radiological Controlled Areas", Revision 1 which consequently resulted in the j subject violation.

l An investigation was performed by Health Physics personnel in order to establish the reason for failure to post these areas. The results of this investigation indicated that the outdoor RCA areas, including the Bus 10 area, were routinely surveyed in accordance with the frequency specified in the Health Physics Survey Matrix. The culvert area was not routinely accessed by personnel or surveyed. Based upon the composition and layout of the RCA yard, and taking into account the activities that have taken place there throughout the life of the plant, the thoroughness of the surveys was not adequate to properly assess the potentially changing radiological status of the area.

Corrective Steps That Have Been Taken And The Results Achieved l

The three examples cited above pertain to the failure to comply with radiation protection l procedures and in turn failure to comply with the requirements of 10 CFR 20 Standards

for Protection Against Radiation". Immediate corrective steps that have been taken to l

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v. U 'aclear Regulatory Commissicn s CY 97 10/ Attachment 1/Page 4 I

N@ c (ne radiation protection program relevant to personnel contamination controls  :

. Juds the following

l e A programmatic review of procedures and methods utilized to respond to personnel contamination events was performe..

• Applicable procedures were revised, e Detailed training of Health Physics technicians and staff was conducted.

• Senior Station Management conducted training sessions in August of 1997 for all plant employees that stressed management's expectations regarding strict  ;

compliance and personnel accountability, immediate corrective steps that have been taken to ensure that HNP radiation protection procedures relevant to posting requirements are complied with include the following:

. A detailed survey of the RCA yard was performed. Contaminated material identified ,

as a result of the survey was removed or the area was properly posted ~,n accordance with procedures and cleaned-up shortly thereafter.

• The base of the Bus 10 concrete pad, identified as the source of the removable  ;

contamination, was cleaned and then sealed with an asphalt sealant and resurveyed.

The results of the survey were below regulatory requirements for posting.

. The culvert area was surveyed, loose debris was removed, the area was covered with asphalt sealer and posted as a radoactive materials area. In addition, the one open culvert was surveyed and found to be intemally contaminated. The culvert was covered and subsequently posted as internally contaminated and requires Health Physics approval to access. r

. Health Physics technicians were instructed to maintain a heightened awareness for i removable contamination that can accumulate in cracks, crevices and other areas not routinely accessed in the outdoor RCA areas.

Corrective Steps That Will Be Taken To Avoid Further Violations The following corrective actions will be taken to improve compliance with radiation protection procedures as they pertain to personnel contamination events.

. Phase 1 of the Radiation Protection improvement Program (RPIP) identified deficiencies which have a potential of affecting health and safety or regulatory compliance. Phase I improvements were completed on August 31,1997 and have been implemented. Phase ll of the RPIP pertains to performance of procedure upgrades. This phase includes procedural upgrades for RPM 2/i-3, " Contaminated e-,- -s -~,,-.,-.w- w ---e ---,--~n, + - - - -, - - - - < - - - , ---n, ., - -- , - - - - - - . , - - - ---,,--w-r ,

U. S. Nucle:r Regul: tory Commission

.CY-97-120/ Attachment 1/Page 5 Personnel Survey and Decontamination". The RPIP is define- in a letter from T. C. Feigenbaum (CYAPCO) to H. J. Miller (NRC), dated Ma: 1 1997.*

l Training of personnel with respect to new prtcedures or major proceow. revisions I resulting from the RPIP will be performed.

The following corrective steps will be taken to improve control of removable contaminated materialin outdoor RCA's in an effort to ensure compliance with posting requirements are maintained.

. We will perform a thorough sealing of all outdoor RCA asphalt areas, as soon as weather allows (Spring 1998). This is expected to minimize the presence of removable material located in outdoor RCA areas.

• The Health Physics Survey Matrix will be revised to segment the RCA yard into discrete zones so that a thorough survey of all of the RCA yard is performed periodically. This will ensure that removable contaminated material is identified and properly dispositioned.

The results achieved, due to the implementation of the corrective actions taken to date, indicate an improvement in compliance with Health Physics procedures. One indicator of this is that the total number of adverse condition reports affecting the Health Physics organization, has increased due to site-wide sensitivity to adverse conditions. In addition, the improved performance of the Health Physics organization as documented in Nuclear Oversight Group audits and recognized by the NRC as noted in a letter from H. J. Miller (NRC) to T. C. Feigenbaum (CYAPCO) dated November 17,1997 W has allowed the HNP to move forward with decomrnissioning and perform artifact removal of a reactor coolant auxiliary system pipe section for testing of decontamination methods.

l Date When Full Compilance Will Be Achieved CYAPCO is presently in full compliance with 10 CFR 20.1902

• Posting" requirements.

B. SURVEYS Reasons For The Violation t

The reason for this violation is that CYAPCO failed, in the past, to perform adequate and comprehensive surveys of construction debris, such as fill and rubble, in accordance with the requirements of 10 CFR 20.1501 " Surveys and Monitoring". The purpose of these (3) T. C. Feigenbaum (CYAPCO) to H. J. Miller (NRC)

• Response to Confirmatory l Action Letter, Radiation Improvement Protection Program" dated May 30,1997.

l (4) H. J. Miller (NRC) to T. C. Feigenbaum (CYAPCO) " Confirmatory Action Letter Supplement" dabd November 17,1997.

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U. S, Nucle r Regul: tory Commission

. CY-97-120/ Attachment 1/Page 6  !

. surveys is to assess the radiation levels, concentrations or quantities of radioactive material, and potential radiological hazard associated with material to be released from ,

the station.

As part of the ongoing site characterization program brdng performed in support of HNP l decommissioning, CYAPCO personnel, upon surveying of the land fill area, identified low levels of plant related contamination in construction debris which was believed to have been deposited during the late 1980's. This situation prompted a review of the procedures and methods employed at the time to preclude the release of contaminated material outside of the RCA. The results of this review indicated that inadequate survey techniques and control methods were employed in the past to assess any contamination associated with the construction debris.

Considering the above, the apparent cause of the violation, was the failure of HNP personnel to perform adequate and comprehensive surveys of construction debris in order to fully assess contamination levels prior to transportation to the land fill area.

Although the exact cause is uncertain, it is believed this event was caused by a combination of factors, includirg instrument sensitivity, poorly defined survey criteria and techniques, and poorly defined standards for surveying volumetric material.

Corrective Steps That Have Been Taken And The Results Achieved The contamination detected in the site land fill area was discovered during site characterization conducted in July of 1997 and performed in support of HNP decommissioning. Corrective steps that have been taken to prevent unauthorized access to the material include enclosing the area with a fence in order to restrict access and posting the area. As such, a Radiation Work Permit (RWP) is required to access the area, a radiation protection technician will oversee access to the area, and frisking will be required to egress the area. In addition, pre-job briefs are provided to review conditions and controls. Controls are commensurate with the planned activity. Keys to the gate for the area are controlled by the Radiation Protection Supervisor.

Corrective actions taken and the results achieved to preclude the release of contaminated material offsite or to an unrestricted area include the following:

. Training of Radiation Protection perst involved in assessing material for release was performed. This training included use of radiation measuring devices, obtaining representative samples for survey and interpreting data from surveys.

. A review was conducted, as part of the historical site assessment, of other events which may have led to the release of radioactive materia!, in order to assess the likelihood of additional similar occurrences.

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.CY-97-120/ Attachment 1/Page 7 ,

e Detectors were employed at the control point with greater sensitivity than those

-previously utilized, to perform surveys of potentially contaminated materials for [

release.

• Procedures pertaining to release of potentially contaminated materials (including bulk materials) were revised in order to provide clarity and consistency between procedures.

• A confirmatory survey program was performed in order to assess the extent to which ,

plant equipment and tools may have been inappropriately released from the RCA. .

The results of this survey, as documented in letter from T. C. Feigenbaum (CYAPC0) to H.J. Miller (NRC) dated September 30, 1997,* indicate that there is a low >

probability for significant contaminated material to have been inappropriately released from HNP.

Corrective Steps That Will Be Taken To Avoid Further Violations Corrective steps that will be taken to avoid further violations include additional RPIP upgrades and enhancements to procedures, and programs. As part-of the RPIP, (Reference 3) a rigorous review and upgrade of Health Physics and Radiation Protection programs and procedures was performed. Phase I of the RPIP identified deficiencies which have a potential of affecting health and safety or regulatory compliance. Phase I improvements were completed on August 31,1997 and have been implemented. Phase ,

ll of the RPIP includes actions deemed necessary to complete procedure upgrades and implementation of standard industry radiation protection good practices. This effort is ongoing.

The RPIP identified the need to upgrade the Radiological Protection Manual (RPM) through the development of a radiation protection plan and implementing procedures.

Procedures and other controls set forth comprehensive instructions to ensure potentially radioactive material is evaluated and dispositioned and meet or exceed NRC requirements and industry standards for contamination control. This effort will result in improved consistency between procedures, improved procedure clarity, and well validated procedure steps.

Date When Full Compliance Will Be Achieved CYAPCO is presently in full compliance with the requirements of 10 CFR 20.1501 with respect to performing surveys to evaluate the concentrations or quantities of radioactive materials to be released from the site.

(5) T. C. Feigenbaum (CYAPCO) to H. J. Miller (NRC) " Supplemental Response to Confirmatory Action Letter" dated September 30,1997.

- Docket Number 50-213  ;

CY.97-120 4

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r Attachment 2  :

Haddam Neck Plant CYAPCO Commitments t

NRC Inspection Report No. 50-213/97-08 t

December 1997 ,

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U. S Nucle:r Regul: tory Commission

.CY-97-120/ Attachment 2/Page 1 The following are new CYAPCO's commitments made within this letter and attachments.

Other statements within this letter are provided for information only, CY-97-120-01 Internalinvestigation of the contamination event will be completed by the end of December 1997.

CY-97-120-02 Outdoor RCA asphalt areas will be covered with an asphalt secler, as soon as weather will allow (Spring 1998).

CY-97-120-03 The Health Physics Survey Matrix will be revised to segment the RCA yard into discrete zones so that a thorough survey of all of the l RCA yard is performed periodically. This effort will be complete by 1 the end of 1997.  ;

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