IR 05000213/1997008
| ML20199G150 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/29/1998 |
| From: | Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Desiree Davis, Mellor R CONNECTICUT YANKEE ATOMIC POWER CO. |
| References | |
| 50-213-97-08, 50-213-97-8, NUDOCS 9802040223 | |
| Download: ML20199G150 (3) | |
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e January 29, 1998
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Mr. Don K. Davis, Chairman, Chief EyedUtive Officer and President clo R. A. Mellor, Vice President Operations and Decommissioning Connecticut Yankee Atomic Power Company 362 Injun Hollow Road East Hampton, CT 06424 3099
Dear Mr. Davis:
SUBJECT: NRC INSPECTION REPORT NO. 50 213/97 08 AND NOTICE OF VIOLATION This refers to your December 5,1997, correspondence in response to our letter, dated October 29,1997, regarding violations that were identified duriN an inspection of licensed activities at Haddam Neck. This correspondence dealt with an NitC Inspection conducted at the station and the associated violations identified. The violations involved f ailure to follow radiation protection procedures and failure to perform adequate surveys.
We have reviewed this matter in accordance with NRC Inspection Manual Procedure 92904, " Plant Support". We concur with your assessment of the root cause and consider the actions you have taken to be acceptable. We will further review the effectiveness of these actions in a future inspection.
We appreciate your cooperation.
Sincerely, ORIGINAL SIGNED BY:
John R. White, Chief Radiation Safety Branch Division of Reactor Safety Docket No. 50 213 License No. DPR 61 9002040223 900129 i
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Mr. Don i ' cc w/cy of licensee ltr:' * * ' ' ' ' ' '
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R. Bassitckis, Citizens Awareness Network J. Block, Attorney for CAN J. Brooks, CT Attorney General Office M. DeBold, Town of Haddam State of Connecticut SLO
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8. Kenyon, President and Chief Executive Officer D. Goebel Vice President - Nuclear Oversight F. Rothen, Vice President Nuclear Work Services D. Amerine, Vice President, Nuclear Engineering and Support L. Cuocs, Senior Nuclear Counsel G. van Noordonnen, Manager, Nuclear Licensing R. Johannes, Director - Nuclear Training
) J. Smith, Manager, Operator Tralning W. Meinert, Nuclear Engineer
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Mr. Don Distribution: W/Cy of lic, ltr Region i Docket Room (with concurrences)
PUBLIC Nuclear Safety informetion Cente (NSIC)
NRC Resident inspector J. White, DRS
J. Nick, DNMS
.R. Bellamy, DNMS DOCDESK Inspection Piogram Branch, NRR (IPAS)
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DATE 1/1998 14498
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OFFICIAL RECORD COPY
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!* CONNECTICUT YANKEE AT O M I C POWER COMPANY Yh HADDAM NECK PLANT 362 INJUN HOLLOW ROAD e EAST HAMPToN. CT 06424-3099
December 5,1997 Docket No. 50-213 CY-97-120 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)
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NRC Integrated Insoection Reoort No 50-213/97-08 In a letter dated October 29,1997,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 thr. 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 internal exposure cor"ols, the contamination control program, training of personnel relative to 49 CFR f 2 Subpart H, plans and activities associated with radiological characterization of the site for decommissioning planning purposes, and HNP sction on '
commitments to the NRC relative to NRC Confirmatory Action Letter (CAL) No. 1-97-007, '
dated March 4,1997.*
The inspection identifiec' wo violations. The first violation involved three examples of failure to foi;ow radiation p atection 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 peraonnel.
, (1) J. R. White (NRC) to T. C. Feigenbaum (CYAPCO), "NRC Inspection Report
" 50-213/97-08," dated October 29,1997.
(2) H. L. Miller (NRC) to T. C. Feigenbaum (CYAPCO), " Confirmatory Action Letter ,
No.1-97-007," daMd March 4,1997.
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CY-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 prasents the current implementation status
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of the corrective actions.
(APCO considers these vietations very serious and it committed to implement and
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i wmpleta the corrective actions to improve HNP performance. We will continue to keep the NRC Staff infermed of our progress in these areas.
Attachment 2 presents CYAFCO's commitments made within this letter and the attachrnents. Other statements within this le+ter are provided for informatinn only, If there are any questions regarding this submittal, please contact g
Mr. G. P. van Nesordennen at (860) 267-3938.
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t Very truly yours, S
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CONNECTICUT YANKEE ATOMIC POWER COMPANY
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9 JL RussM. Mellor Lk
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- Vice President - Operations and Decommiscioning Attachments
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cc: H. J. Miller, NRC Region i Adniinistrator
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J. R. White, Chief, Radiation Safety Branch M. B. Fairtile, NRC Senior Project Managei, Haddam Neck Plant W. J. Raymond, NRC Senior Resident inspecto., Haddam Neck Plant D. Galloway, Acting Director, CT DEP Monitoring and Radiation Division
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Docket Number SQ-213
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- Haddam Neck' Plant
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Reply to a Notice of Violation NRC inspection Report No. 50-213/97-08
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December 1997
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U. S. Nuclear Regulatory Commission
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CY-97-120/ Attachment 1/Page 1
' estatement of Violation
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During NRC inspections conducted during the period July 3 through September 19,1997, violations of NRC requirements were identifieo. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30,1995) the violations are listed below.-
A. Technical 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 Drsonnel 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, u .s5, an individual, working on radiation work permit (RWP) 1950603, " Primary Steam Generator Nozzle Cover Installation and Removal," from 4:34 p.m. to 6:56 p.m., received a facial
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contamination cnd was not sent to be whole-body-counted.
2. Radiation Protection procedure NUC RPM 5.1.2, "PostMg 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 sym! of 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
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 regulations in this part and are reasonable under the circumstances to evaluate concerdrations or quantities of radioactive material.
Contrary to the above, surveys of material placed in the licensee's landfill area, located approximately [0.25] 0.75 railes southeast of the Haddam Neck station were inadequate
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CY-97-120/ Attachment 1/Page 2 to detect and evaluate radioactive materials deposited at some unknown time at the location. Such surveys were necesswy 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 soli at the landfill rsnged from about 0.31 pCl/g to 4.3 pCl/g at the location, Cs-137 ranged from 0.17 pCi/g to 34.8 pCl/g at the location, and material (e.g., fabric, brick) at the location exhibited radivactive contamination that ranged from 400-600 corrected counts per minute (ccpm) (i.e.,
approximately 4,000 - 6,000 dpm assuming a 10 % detectur efficiency).
This is a Severity Level IV violation (Supplement IV).
A. RADIATION PROTECTION PROCEDURES Reasons For The Violation
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Three examples pertaining to radiation protection procedure vioiations are identified in the subject Notice of Violation (NOV) as documented in Reference 1. Reasons for these violations are identified below. .
Examole 1-Contaminated Personnel Survev 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 contar,.5ation was initialiy detected by a Personnel Contamination Monitor (PCM)
and confirmeo using a frisker. The fricker 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 ut 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 require 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
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CY-97-120/ 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 reconstructed after the fact, based voon interviews with the contaminated individual and station personnel. The Health Physics technician involved with releasing the contaminated individual from 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 echnician's suoervisor is still employed at CY and has been interviewed as part of the ongoing internal investigation of this event. This investigation will be completed by the end of December 1997. Preliminary results of the internal investigation conclude that th" following shortcomings existed in the Health Physics department in February 1995:
. Programmatic inadequacies which allowed the technician to improperly assess the
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situation.
. Insufficient management oversight of the technician's actions.
Examples 2 and 3-Postina of Radiological Control & Ras
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 zene 6 control point, was used to store cement shields useo for radioactive
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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 Culvert Area on September 19, 1997 the NEC 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. Thase areas were not posted as required by Radiation Protection Procedure NUC RPM 5.1.2,
" Posting of Radiological Controlled Areas", Revision 1 which conseauently resulted in the subject violation.
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 surnyed 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 chang lng radiological status of the area.
Corrective Steps That Have Been Taken And The Results Achievnd The three examples cited above pertain to the failure to comply with radiation protection 1 procedures and in turn fa"ure to cornply with the requirements of 10 CFR 20 " Standards for Protection Against Radiation". Immediate corrective steps that have been taken to or _.
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CY-97-120/ Attachment 1/Page 4 improve the radiation protection program relevant to personnel contamination controls include the following:
. A programmatic review of procedures and methods utilized to respond to personnel contamination events was performed.
. Applicable procedures were revised.
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. Detailed training of Health Physics techrilcians and staff was conducted.
. Senior Station Management conducted training sessons 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. Conteminated material identified
as a result of the suvey was removed or the area was properly posted in 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 sea l ant and resurveyed.
The results of the survey were below regulatory requirements for posting.
. The culvert area was sarveyed, loose debris was removed, the area was covered with asphalt sealer and posted as a radioactive materials area. In addition, the one open culvert was surveyed and found to be internally contaminated. The culvert was covered and subsequently pested as internally contaminated and requires Health Physics approval to access.
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. Health Physics technicians were instructed to maintain a heightened awareness for removable contaminatior. that can accumulate in cracks, crevices and other areas act 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 rad!ation protection procedures as they pertain to personnel contamination events.
- Phase I 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. Phasc 11 of the RPIP pertains to performance of procedure upgrades. This phase in;ludes procedural upgrades for RPM 2.7-3, " Contaminated
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CY-97-120/ Attachment 1/Page 5 Personnel Survey and Decontamination". The RPIP is defined in a !stter from T. C. Feigenbaum (CYAPCO) to H. J. Miller (NRC), dated May 30, 1997.* ,
Training of personnel with respect to new procedures or major procedure revisions resulting from the RPIP will be performed.
The following corrective steps will be taken to improve control of rem,vable contaminated ,
material in 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). Ths 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 i 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.
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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 has allowed the HNP W
to move forward with decommissioning and perform artifact removal of a reactor coolant auxiliary system pipe section for testing cf decontamination methods.
Date When Full Compliance Will Be Achieved CYAPCO is presently in full compliance with 10 CFR 20.1902 " Posting" requN ments.
B. SURVEYS Reasons For The Violation The reason for this violation is that CYAPCO failed, in the past, to perform adequate and compreheneive surveys of construction debris, cuch as fill and rubble, in accordance with the requirements of 10 CFR 9.1501 " Surveys and Monitoring" The purpose of these (3) T. C. Feigenbaum (CYAPCO) to H. J. Miller (NRC) " Response to Confirmatory Action Letter, RadL, tion improvement Protection Program" dated May 30,1997.
(4) H. J. Millar (NRC) to T. C. Feigenbaum (CYAPCO) " Confirmatory Action Letter i Supplement" dated November 17,1997.
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CY-97-120/Attachraent 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 being performed in support of HNP 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
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personnel to perform adequate and comprehcnsive 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, including instrument sensitivity, pooriv dd.ad survey criteria and
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techniques, and poorly defined standards for surveying volur .tric 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 personnel involved in assessing material for release was performed. This training included use of radiation measuring devices, obtaining representative samples for survey and interpreting data iom surveys.
. A review wrs conducted, as part of the historical site assessment, of other events which may have led to the release of radioactive material, in ecder to assess the likelihood of additional similar occurrences.
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. 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 curvey 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 (CYAPCO)
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 Tahen To Avoid Further Violations
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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
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requiremer.ts and industry standards for contamination control. This effort will result in
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improved consistency between procedures, improved procedure clarity, and well validated procedure stepe.
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. Feigenb um (CYAPCO) to H.1 Miller (NRC) " Supplemental Response to ,
i Confirn atory Action Letter" dated September 30,1997.
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Docket Number 50-213 CY-97-120 -
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Attachment 2 Haddam' Neck Plant.
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CYAPCO Commitments -
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A , NRC Inspection Report No. 50-213/97-08'
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CY-97-120/Attechment 2/Page 1 The following are new CYAPCO's commitments made within this ietter and attachments.
Other statements within this letter are provided for information only.
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CY-97-120-01 - Intemal investigation of the contamination event will be completed by the end of December 1997.
CY-97-120 02 Outdoor RCA acphalt areas will be covered with an asphalt sealer,
. 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 RCA yard is performed periodically. This effort will be complete by the end of 1997.
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