CY-98-037, Informs NRC That All Required Actions of CAL Have Been Completed.Util Requests That CAL & Any & All Restrictions or Requirements Imposed by CAL Be Rescinded.Summary of Actions Taken Listed

Informs NRC That All Required Actions of CAL Have Been Completed.Util Requests That CAL & Any & All Restrictions or Requirements Imposed by CAL Be Rescinded.Summary of Actions Taken Listed

ML20217P462
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/31/1998
From:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CAL-1-97-07, CAL-1-97-7, CY-98-037, CY-98-37, NUDOCS 9804100103
Download: ML20217P462 (5)

Text

. e CONNECTICUT YANKEE ATOMIC POWER COMPANY C HADDAM NECK PLANT 362 INJUN HOLLOW ROAD e EAST HAMPTON, CT 06424-3099 March 31,1998 Docket No. 50-213 CY-98-037 Re: CAL No. 1-97-007 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Haddam Neck Plant Response to Confirmatory Action Letter Completion of Commitments for Confirmatory Action Letter in March 1997, the NRC issued a Confirmatory Action Letter (CAL)', later supplemented on 2

November 17, 1997 , requesting four separate actions: (1) establish interim compensatory measures, (2) conduct an independent assessment of radiological control programs and their implementation, (3) submit a performance improvement plan identifying problems, root causes

, and corrective actions, and (4) meet with the Regional Administrator prior to eliminating any interim compensatory measures.

The purpose of this letter is to inform the NRC Staff that all required actions of the CAL have been completed. Connecticut Yankee Atomic Power Company (CYAPCO) respectively requests that the CAL and any and all restrictions or requirements imposed by it be rescinded. Our summary of those actions taken in response to the CAL is presented below.

1. Compensatory Measures 3

In our lettet dated March 7,1997, specific compensatory measures were identified to assure sufficient management, control, and oversight of ongoing or planned activities requiring radiological controls. Additionally, commitments were made to respond to the remaining three actions according to the timeline agreed to by the NRC and CYAPCO.

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' USNRC Letter from 11. J. Miller to T. C. Feigenbaum," Confirmatory Action Letter," dated March 4,1997.

2 I USNRC Letter from H. J. Miller to T. C. Feigenbaum, " Confirmatory Action Letter, Supplement" dated November 17,1997.

' CYAPCO Letter CY-97-01i from T. C. Feigenbaum to the NRC," Response to Ctnf.-matory Action Letter," ab 0

dated March 7,1997. g 9804100103 980331 3 /

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U.S. Nuclear Regulitory Commission  !

CY-98-037/Page 2 )

i In our letter dated November 13,1997', a revised list of administrative controls that constituted j compensatory measures was submitted to replace the similar controls described in the March 7, j 1997 letter. These changes provided enhancements facilitated by procedural and staffing l improvements made since the previous controls were implemented. A supplement to the CAL was subsequently issued by the NRC on November 17, 1997 which endorsed these proposed changes to the administrative controls. As appropriate, these administrative controls have since been proceduralized into the Radiation Protection Program. Based on the fact that we continued to perform routine activities in the RCA and completed several radiologically challenging projects successfully, these administrative controls adequately provided the compensatory measures required by the CAI..

5 In our letter dated March 20,1997, an action plan was presented to determine the extent of radioactive material that may have been inappropriately released from the site. Specifically, an experienced individual was engaged to act as th: Survey Plan Manager who was responsible for development of a comprehensive action plan. Performance of the action plan was expected to be complete by September 30,1997.

6 In our letter dated Octok .7,1997, the results of the CYAPCO investigation of radioactive material that may have been inappropriately released off-site was provided as documented in the

" Unrestricted Release Ccnfirmatory Survey Program," dated September 29,1997.

2. Indeoendent Assessor In our letter dated March 27, 1997', the NRC was informed that CYAPCO had hired an independent party, Millennium Services, Inc., to assess the quality and performance of the radiological control program and its implementation.

3. Performance Imorovement Plan ,

8 In our letter dated May 30, 1997 , the Radiation Protection Improvement Plan (RPIP) was submitted. This plan, to be conducted in three separate phases, identified specific improvement initiatives to resolve the root causes and significant issues identified by the independent assessment conducted by Millenium Services, Inc. This letter also provided an executive summary of the final report prepared by Millenium Services, Inc.

• CYAPCO Letter CY-97-124 from T. C. Feigenbaum to the NRC," Updated Response to Confirmatory Action Letter," dated November 13,1997.

' CYAPCO Letter CY-97-017 from T. C. Feigenbaum to the NRC," Supplemental Response to Confirmatory Action Letter," dated March 201997.

• CYAPCO Letter CY-97-094 from T. C. Feigenbaum to the NRC, " Supplemental Response to Confirmatory Action Letter," dated October 17,1997.

' CYAPCO Letter CY-97-033 from T. C. Feigenbaum to the NRC," Supplemental Response to Confirmatory Action Letter," dated March 27,1997.

• CYAPCO Letter CY-97-049 from T. C. Feigenbaum to H. J. Miller," Response to Confirmatory Action Letter, Radiation Protection improvement Plan," dated May 30,1997.

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U.S. Nucle r Reguletory Commission CY-98-037/Page 3

.Our letter, dated June 13, 1997', forwarded Millenium Service's complete independent assessment of the Radiological Control Program at the Haddam Neck Plant (final report dated May 1997).

In our letter dated July 31,1997", the NRC was notified of additional time needed to complete Phase I of the RPIP from July 31,1997 to August 31,1997.

In our letter dated September 10,1997", notification of completion of Phase I of the RPIP was provided. Phase I identified and corrected deficiencies which had a potential risk of affecting public or worker health and safety, or compliance with federal regulations. In Inspection Report 97-10", the NRC reviewed the implementation of Phase I and concluded that overall quality, monitoring, and review of Phase I program improvement items was considered good.

In our letter dated December 23,1997", a status of the implementation of Phase II of the RPIP was provided, noting that significant progress had been made. This letter also provided notification that completion of Phase II would be extended to March 1,1998. The schedule extension and progress report on completion of certain activities also redefined the scope of Phase III, since all remaining improvement initiatives were being completed as part of Phase II.

In our letter dated March 9,1998", notification was provided that Phase II of the RPIP had been completed on February 27,1998. Phase II of the RPIP included actions required to implement a  ;

program that fully meets or exceeds standard industry radiation protection good practices. With the completion of Phase II, the program is capable of supporting Reactor Coolant System (RCS) decontamination and subsequent decommissioning activities.

Phase III of ths RPIP is ongoing and is expected to completed by June 30,1998. Phase III is the effectiveness verification element of the RPIP. This phase will verify the effectiveness of i program improvements and performance while the station performs radiological activities associated with RCS decontamination and other decommissioning activities.

4. Meetine with the Region Administrator On September 18-19,1997, Mr. William Axelson, Deputy Regional Administrator and Mr. John l White, Chief of the Radiation Safety Branch met with CYAPCO management to discuss

' CYAPCO Letter CY-97-067 from T. C. Feigenbaum to the NRC," Independent Assessment of the Radiological Controls Program," dated June 13,1997.

" CYAPCO Letter CY-97-078 from T. C. Feigenbaum to the NRC, " Response to Cr.firmatory Action Letter, Radiation Protection Plan Implementation," dated July 31,1997.

" CYAPCO Letter CY-97-092 from T. C. Feigenbaum to the NRC, " Response to Confirmatory Action Letter, Completion of Radiation Protection Improvement Plan - Phase I," dated September 10,1997.

12 USNRC Letter from J. R. White to D. K. Davis,"NRC Inspection Report 50-213/97-10," dated January 14, 1998.

" CYAPCO Letter CY-97-118 from R. A. Mellor to the NRC," Response to Confirmatory Action Letter, Radiation Protection improvement Plan Status" dated December 23,1997.

" CYAPCO Letter CY-98-014 kom R. A. Mellor to the NRC," Response to Confirmatory Action Letter, Completion of Radiation Protection 1:nprovement Plan - Phase 11" dated March 9,1998.

U.S. Nucle:r Regul tory Commission CY-98-037/Page 4

, progress on the RPIP and the status of off-site surveys. (see Inspection Report 97-05)"

On October 31, 1997, a management meetut m. the NRC was held to discuss the overall status of RPIP efforts. In attendance for the NRt ..xe Mr. William Axelson, Deputy Regional Administrator and Mr. John White, Chief of the Radiation Safety Branch (see Inspection Report 97-10)"

On March 11,1998, a management meeting with the NRC was held to discuss decommissioning work activities, including the current status of the RPIP implementation and recent completion of Phase II of the RPIP. In attendance for NRC management were Mr. John White, Chief of the Radiation Safety Branch and Dr. Ron Bellamy, Chief of the Decommissioning and Laboratory Branch.

Summary / Conclusion In summary, all requirements of the CAL have been met. We respectfully request that the restrictions imposed by the CAL be rescinded.

There are no new commitments within this letter. If the NRC Staff should have any questions regarding this submittal, please contact Mr. G. P. van Noordennen at (860) 267-3938.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY r 4

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(% N R. A. Mellor Vice President - Operctions and Decommissioning i

Subscribed and sworn to before me this 3/31 day of /%el ,1998 '

& pa s,l l. van YodN%e~

l Date Commission Expires: ///3//sm A

" USNRC Letter from R. J. Conte to T. C. Feigenbaum,"NRC Integrated Inspection Report 50-213/97-05," dated November 26,1997.

USNRC Letter from J. R. White to D. K. Davis,"NRC Inspection Report 50-213/97-10," dated January 14, 1998.

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l U.S. Nucle:r Regulatsry Commission 1

CY-98-037/Page 5 i

cc: II. J. Miller, NRC Region I Administrator R. Bellamy, NRC Region I, Decommissioning and Laboratory Branch Chief J. R. White, NRC Region I, Radiation Safety Branch Chief ,

T. L. Fredrichs, NRC 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,

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