CY-99-024, Responds to Violations Noted in Insp Rept 50-213/98-06. Corrective Actions:Meetings Were Held with Contractor Mgt, Disciplinary Action Against Worker Was Taken & Notices Alerting Workers to HRA Controls Were Posted

Responds to Violations Noted in Insp Rept 50-213/98-06. Corrective Actions:Meetings Were Held with Contractor Mgt, Disciplinary Action Against Worker Was Taken & Notices Alerting Workers to HRA Controls Were Posted

ML20196K771
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/29/1999
From:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-213-98-06, 50-213-98-6, CY-99-024, CY-99-24, NUDOCS 9904060078
Download: ML20196K771 (17)

Text

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ONNECTICUT YANKEE ATO MIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD e EAST HAMPTON. CT 06424-3099 March 29,1999 Docket No. 50-213 CY-99-024 Re: 10 CFR 2.201 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Haddam Neck Plant Reply to a Notice of Violation (NOV)

NRC Integrated Inspection Reoort No. 50-213/98-06 The purpose of this letter is for Connecticut Yankee Atomic Power Company (CYAPCO) to reply to the notice of violation contained in inspection Report 98-06 W . The violation involved the failure to keep the gates used to control access to high radiation areas in the containment closed and locked.

Attachment 1 restates the cited violation and provides CYAPCO's response.

l The letter transmitting the inspection report stated a concern regarding the i effectiveness of radiation protection program improvements implemented after the #

December 1996 transfer canal incident and Confirmatory Action Letter. CYAPCO does not perceive a relationship between the LHRA violation and the effectiveness of the improvement program. The improvement program included extensive changes in j procedures, training programs, and staff performance expectations, creating a culture /\,gOk i that consistently self-identif;es issues and quickly implements corrective actions. The '

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recently completed chemical decontamination of the reacto: coolant system clearly demonstrated an effective health physics program which involved many significant radiological challenges which were capably resolved. The LHRA violation does not (1) Ronald R. Bellamy letter to R. A. Mellor, "NRC Integrated Inspection Report 50-213/98-06 and Notice of Violation," dated February 26,1999.

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U. S. Nucinr Regul; tory Commission CY-99-024/ Page 2 indicate a failure of the radiation protection improvement program for the following

, reasons:

. The events causing the LHRA gate violation were isolated and were not due to programmatic failures.

. Health Physics technicians quickly discovered the events and CYAPCO took comprehensive and aggressive corrective actions.

. There were no unauthorized entries into the locked high radiation areas or personnel exposure as a result of these events.

There are no additional commitments made in this letter beyond the corrective actions that have already been completed. Other statements in the letter are provided for information only.

If there are any questions regarding this submittal, please contact Mr. G. P. van Noordennen at (860) 267-3938.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY Russebellor i Vice President - Operations and Decommissioning Attachments cc: H. J. Miller,, Region .I Administrator J. Lieberman, Director, Office of Enforcement I, L. Fredrichs, Project Manager, Haddam Neck Plant Dr. R. R. Bellamy, Chief, Decommissioning and Laboratory Branch, Region I E. L. Wilds, Director, CT DEP Monitoring and Radiation Division Subscribed and sworn to before me this 2 f// day of March 1999 b A s s u ) f. %

Date Commission Expires: /2hr[em -

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Docket Number 50-213 CY-99-024 1

l Attachment 1 -

Haddam Neck Plant Reply to Notice of Violation NHQ Intearated Insnectior Reoort No. 50-213/98-06 l

l March 1999 l

U. S. Nuclear Regu!atory Commission CY-99-024/Attachmen,t 1/Page 1 Restatement of the Violation l

The following is the statement of violation as presented in the NRC Integrated Inspection Report 98-06 and Notice of Violation:

l During an NRC inspection conducted on November 3,1998 - January 18, 1999, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcemmt Actions," NUREG-1600, the violation is listed below:  !

Technical Specification 6.12.2 requires, in part, that in addition to the  !

requirements of Specification 6.12.1, areas accessible to personnel with radiation levels greater than 1000 mR/hr at 45 cm [30 cm) from the radiation source shall be provided with locked doors to prevent unauthorized entry and doors shall  !

remain locked except during periods of access by personnel under an approved i RWP.  :

Contraty to the above, on two dates (November 5,1998 and November 30, 1998), two different locked high radiation area doors in the containment building were found unlocked and unattended. j This is a Severity Level IV violation (Supplement IV).

CY9" O's Response The evei.ls of November 1998 involving Locked High Radiation Area (LHRA) gates occurred as generally described in the NRC Integrated Inspection Report 98-06, pages 9 and 10. However, CYAPCO does not agree with the NRC Staff conclusion that t iese events should be dispositioned as a Severity Level IV  !

violation, and believes that such a designation is inconsistent with the enforcement policy which has been in use since July 1998.

The NRC Enforcement Guidance Memorandum EGM 98-006, " Interim Guidance for Severity Level IV Violations," was issued July 27,1998 and became effective upon issuance. l The implementation of the guidance contained in EGM 98-006 resulted in a dramatic reduction in the number of Severity Level IV violations (requiring written response) issued by the NRC. This is shown in the attached graph excerpted from a presentation by the Director, Office of Nuclear Reactor Regulation at the 1999 Regulatory information Conference (Attachment 2).

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' U. S. Nucl=r Regul: tory Commission CY-99-024/ Attachment 1/Page 2 i

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• CYAPCO's position is that these two events should be dispositioned as a Non-Cited Violation (NCV). The reasons are as follows:

. CYAPCO restored compliance immediatel fafter the violation was identified.

• CYAPCO placed the violation into a corrective action program to address recurrence . 1 e The violation was CYAPCO-identified,- the NRC was notified, and involved the isolated actions of specialty contract workers. It did not involve any CYAPCO management. In addition, significant remedial action was taken.

CYAPCO recognizes that the NRC's enforcement decisions are designed to encourage the self-identification and correction of violations and that the disposition of a Severity Level IV violation as an NCV is an exercise of agency discretion. The factors for the exercise of that discretion, CYAPCO suggests,,

are present in this case.

CYAPCO's review of the November 1998 events concluded that the principal j cause of the November 5,1998 event was the inattention and personnel error on the part of a specialty contract worker. Tntining for the worker included CYAPCO expectations for closure and loci ing of the LHRA gates to prevent unauthorized entry. Attachment 3 of this response includes the training material ,

used by CYAPCO for training radiation workers. Notwithstanding the adequacy I of CYAPCO's radiation protection program, including training, the worker failed j to comply with pre-established requirements. I i

With respect to the second event on November 30,1998, the specialty contract l worker apparently closed the LHRA gate in conformance with pre-established l requirements, but did not positively verify (i.e., challenge) the locking of the gate. i As part of the corrective actions, CYAPCO established an additional expectation of challenging / verifying LHRA gate closure and locking upon exiting the High L Radiation Area (HRA).

' As reflected by our corrective actions, the accountability of specialty labor contractors and their employees has been reinforced to assure CYAPCO's ,

expectations for performanca and procedure compliance are met. No further l events occurred during the remainder of this specialty contractor's work at the  !

L. Haddam Neck plant. l

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U. S. Nucle:r R gulatory Commission CY-99-024/ Attachment 1/Page 3 Reason for the Violation On November 5,1998, a Health Physics (HP) technician found a Locked High Radiation Area (LHRA) gate open in the lower annulus of the containment building. This event was documented in an Adverse Condition Report, ACR 98-0943.

- The period of time that the gate was open and unguarded was determined to N very short (approximately five minutes) and no unauthorized entry into a HRA was made during that time period based on a review of personnel working in the containment building at the time. There was no radiation exposure resulting from this event.

CYAPCO determined that the cause of the event was worker inattention and personnel error. It was considered to be an isolated event.-

A second event involving an unlocked HRA gate occurred on November 30, 1998. This event was also documented in an ACR (ACR 98-0987).

- CYAPCO performed an appare nt cause investigation to determine the causes and develop corrective actior,s to prevent a recurrence of the event. The following were determined to be the apparent causal factors:

. The person did not verify that the gate closed and latched after attempting to close the gate upon exit from the High Radiation Area;

. A site wide and consistent definition of how to check or challenge the closure of a LHRA gate was not in place; and

. There was no method to positively verify gate closure and locking, for example, positive closure mechanism, audible alarm, visual alarm, or gate guard.

Inadequate corrective action in response to the first event was also included as a causal factor. CYAPCO notes that broader corrective actions taken as a result of the first event may have minimized the possibility of the second event.

However, the events were sufficiently different that the second event may not have been prevented.

Corrective Steps That Have Been Taken and the Results Achieved

, The following corrective actions were taken by CYAPCO managernent after the first event:

. Meetings were held with contractor management;

. Disciplinary action against the worker was taken (access revoked);

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U. S. Nuclear R:gulttory Commission  :

CY-99-024/ Attachment 1/Page 4 i

e Notices alerting workers to HRA controls were posted;

'. Training on HRA controls was conducted; and

. Increased HP attention was placed on high traffic LHRA gates.

The following corrective actions were taken by CYAPCO management following the second event:

. The responsible contract workers received training and daily briefings regarding CY expectations for LHRA gate closure; e LHRA gate guards were briefed and were posted at high traffic LHRA gates;

• A comprehensive containment radiation survey was performed to determine if any LHRA gates could be eliminated;

. The number of LHRA gates required to support work activities was reduced;  !

. A gate alarm system was installed to service high traffic LHRA gates;

. The site wide Safety Tool Box meeting was used to convey the CY LHRA gate closure / verification expectations to site personnel; and

. Additional management initiatives were implemented to streamline field supervision and enhance communication.

These corrective actions have been effective. There have been no further events involving LHRA gates during the last four months.

I Corrective Steps That Will Be Taken to Avoid Further Violations All corrective actions have been completed. No additional actions are planned.

l Date When Fuli Compliance Will Be Achieved Compliance was restored immediately after the violations were discovered on November 5,1998 and November 30,1998. The Haddam Neck Plant remains in full compliance.

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Attachment 2 Haddam Neck Plant Data on Resoonse Requirsd Severity Level IV Violations (Exceroted from " Regulatory Trends: Current NRR Initiatives: Then. Now and the Future." by Samuel J. Collins. Director. Office of Nuclear Reactor Regulation.1999 Regulatorv Information Conference. March 3.1999) l 1

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