IR 05000213/1998002

Insp Rept 50-213/98-02 on 980316-20 & 25-27.No Violations Noted.Major Areas Inspected:Radiological Control Programs

ML20247C010
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247C007	List: IR 05000213/1998002 ML20247C001
References
50-213-98-02, 50-213-98-2, NUDOCS 9805110197
Download: ML20247C010 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REGION l Docket No: 50-213 License No: DPR-61 i

Report No: 50-213/98-02 Licensee: Connecticut Yankee Atomic Power Company Facility: Haddam Neck Station Location: Haddam, Connecticut Dates: Onsite - March 16-20 and 25-27,1998 In office - Through April 27,1998 Inspectors: Ronald L. Nimitz, CHP, Sr. Radiation Specialist William J. Raymond, Sr. Resident inspector Haddam Neck Station Approved by: John R. White, Chief Radiation Safety Branch Division of Reactor Safety 9805110197 980505 PDR ADOCK 05000213 G PDR

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EXECUTIVE SUMMARY Haddam Neck Station NRC Inspection Report No. 50-213/98-02 This inspection was an inspection of the radiological controls program at the Connecticut

- Yankee Atomic Power Station, Haddam, Connecticut. The principal focus of the inspection was the review of the adequacy and implementation of licensee actions on commitments to the NRC relative to NRC Confirmatory Action Letter (CAL) No. 1-97-007, dated

- March 4,199 The CAL was issued as a result of radiological controls problems experienced by the licensee in late 1996 and early 1997 including a November 2,1996, reactor cavity airborne radioactivity event (Reference NRC Inspection Report No. 50-213/96-12),

programmatic deficiencies associated with calibration of effluent monitoring systems (Reference NRC inspection Report No. 50-213/97-02),and problems associated with release of contaminated material to an unrestricted area (Reference NRC Inspection Report No. 50-213/97-01).

The licensee's March 7,1997 response to the CAL identified the compensatory measures put in place to assure sufficient management, control, and oversight of ongoing or planned activities that required radiological controls. The licensee's May 30,1997, response to the CAL outlined its plans to provide for an independent review of the radiation protection program, development of a Radiation Protection improvement Plan (RPlP). The plan was established to provide overall program improvement and effectiveness reviews using a

- three phase approach (i.e., Phases I,11, and Ill).

The Phase I items were those items considered to have some potential risk of affecting I public or worker health and safety or compliance with regulations. The Phase il items were those items associated with general program enhancement and were identified as items necessary to implement the program to fully meet or exceed industry radiation protection good practices. Phase ill program efforts involved ongoing review and evaluation of the program and its performance and assessment efforts to ensure that the program was capable of effectively supporting primary system chamical decontaminatio !

The inspector reviewed the licensee's implementation of its commitments documented in i'

the CAL including associated corrective actions and program improvement initiatives. In particular, during this inspection, the inspector selectively reviewed the adequacy and j implementation of the licensee's Phase ll corrective actions outlined in its Radiation Protection improvement Plan matri Plant Suooort Conclusions

< The licensee implemented the commitments outlined to the NRC in its May 30, 1997, response to Confirmatory Action Letter (CAL) No. 1-97-00 The licensee implemented Phase ll of its Radiation Protection Improvement Plan and was implementing Phase lli of the RPIP.

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The licensee implemented effective radiological controls for repair of the refueling water storage tank (RWST). Management and supervisor oversight of this activity was good. No violations were identified.

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Report Details PLANT SUPPORT R1 Radiological Protection and Chemistry Controls l l l R1.1 Review of Licensee Radiological Controls for Repair of the Refuelina Water Storaae Tank l Insoection Scope The inspector reviewed the licensee's radiological controls for repair of a leak in the refueling water storage tank. The licensee initiated repair of the tank in January 1998 and completed the repair using a spray sealant on February 13,1998. The inspector reviewed the planning and preparation for the task and selectively reviewed applicable radiological controls documentation for the task including, radiation work permits, radiological surveys, access control records, training L records, personnel monitoring and occupational radiation exposure records, and

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whole body count results. The inspector interviewed cognizant individuals involved with planning and performance of the tas Observations and Findinos i No deficiencies or program weaknesses were identified. There was a good level of l management and supervisory oversight of this activity. The licensee's management i and staff were particularly sensitive to potential transuranic contamination since the task required personnel entry into the contaminated tan .

Qualified radiological contrcls personnel were assigned job coverage for the activity, special procedures were developed and approved for the activity, and personnel were provided training and briefings. The licensee performed appropriate i radiological surveys of the activity and used respiratory protection and engineering controls to minimize the potential for personnelintake of radioactive materia Personnel provided with respiratory protective equipment were trained and qualified

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in accordance with the licensee's respiratory protection program. No unexpected radiological conditions were encountere The work activity received a detailed ALARA review for planning purposes, an ALARA exposure controls checklist was developed, and accrued occupational radiation exposure compared favorably to pre-job estimate The inspectors' review of post work activity radiological survey data and personnel monitoring information indicated that no significant airborne radioactivity was

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generated; no significant external radiation exposure of personnel was sustained; no personnel contaminations occurred; and based on whole body counting, no intakes of airborne radioactivity resulted.

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2 Conclusions The licensee implemented effective radiological controls for repair of the RWS j Management and supervisory oversight of this activity was good. No violations I were identifie R8 Miscellaneous Matters R8.1 Confirmatory Action Letter Backaround and insoection Scoce (92703. 92904)

in late 1996 and early 1997, the licensee experienced several radiological controls problems attributable to weaknesses in managing and controlling radiological activities at the Haddam Neck Station. These included a November 2,1996, reactor cavity airborne radioactivity event (Reference NRC Inspection Report N /96-12), programmatic deficiencies associated with calibration of effluent monitoring systems (Reference NRC Inspection Report No. 50-213/97-02), and l problems associated with release of contaminated material to an unrestricted area j (Reference NRC Inspection Report No. 50 213/97-01). As a result of these I problems, the NRC issued Confirmatory Action Letter (CAL) No. 1 -97-007, on March 4,1997, to confirm the licensee's actions and commitments to ioentify and effectively resolve weaknesses and deficiencies in the implementation of its i radiological controls progra The licensee's May 30,1997, letter to the NRC, in response to the CAL, outlined plans to provide for an independent review of the radiation protection program, develop a Radiation Protection Improvement Plan (RPIP), and implement corrective actions in three phases. The licensee developed a comprehensive matrix of program improvement items, identified through independent assessments, and quality assurance and self-assessment programs. The improvement items were tracked, controlled, and assigned to the three Phases of the RPI The Phase I items were those items considered to have some potential risk of affecting public or worker health and safety or compliance with regulations. The Phase ll items were those items associated with general program enhancement and were identified as items necessary to implement the program to fully meet or exceed industry radiation protection good practices. Phase lll program efforts involved ongoing review and evaluation of the program and its performance and assessment efforts to ensure that the program was capable of effectively supporting primary system chemical decontaminatio The inspector reviewed the licensee's implementation of its commitments documented in the CAL, including associated corrective actions and program improvement initiatives. In particular, during this inspection, the inspector selectively reviewed the adequacy and implementation of the licensee's Phase 11 corrective actions outlined in its Radiation Protection Improvement Plan matrix. The inspector independently reviewed and evaluated ongoing radiological controls at the station, selectively reviewed applicable quality assurance reviews of radiological controls performance and practices, interviewed workers at the station, and toured the radiological controlled areas.

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b. Observations and Findinas The following observations were made relative to implementation of CAL No.1-97-007 dated March 4,199 CAL ltem By March 7,1997, identify, in writing, specific compensatory measures that will be put in place to assure sufficient management, control, and oversight of ongoing or planned activities that require radic!ogical control NRC Findinas (ltem 1)

This matter was previously reviewed during NRC Inspection No. 50-213/97-06, dated August 12,1997. At that time, it was determined that the licensee provided a letter (CY-97-011) dated March 7,1997, that identified, in writing, the compensatory measures put in place to assure sufficient management, control, and oversight of ongoing or planned activities that required radiological control The licensee's implementation of its compensatory measures were periodically reviewed and found to have been implemented. (Reference NRC Inspection Report Nos. 50 213/97-06:50-213/97-10)

This item is complet CAL ltem By March 31,1997, engage the services of an independent assessor to assess the quality and performance of the radiological control program and its implementatio NRC Findinas (ltem 2)

This matter was previously reviewed during NRC Inspection No. 50-213/97-06, l

dated August 12,1997. At that time, it was determined that the licensee provided a letter (CY-97-011) dated March 7,1997,that identified, that the services of an independent assessor would be engaged by March 31,1997. The licensee subsequently provided a March 27,1997, supplemental response (CY-97-033) to the CAL which indicated that the independent assessor was engaged to assess the l quality and performance of the radiological control program and its implementation at the Haddam Neck Plan The licensee subsequently provided to the NRC the independent assessor's report of the Independent Assessment of the Haddam Neck Radiological Controls Program, dated June 13,1997 (CY-97-033).

This item is complete.

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.QAL Item L By May 30,1997, based on input from the independent assessment, (1) identify problems, determine root causes, and develop broad-based and specific corrective actions; (2) identify performance measures that may be used to determine the effectiveness of radiological control programs; and (3) submit a plan and schedule i to the Regional Administrator, NRC Region I, for the implementation of l improvements in the radiological control program NRC Findinas (Item 3)

This matter was previously reviewed during NRC Inspection No. 00-213/97 06, dated August 12,1997. At that time, the licensee submitted a letter (CY-97-011)

dated March 7,1997, that identified, that the information identified in CAL ltem 3 would be submitted by May 30,199 The licensee subsequently submitted a letter (CY-97-049) dated May 30,1997, which provided the Radiation Protection improvement Plan (RPIP). The letter provided a description of problems and root causes and a plan to develop corrective actions including improvement initiatives and effectiveness measurements. The plan was established to provide overall program improvement and effectiveness reviews using a three phase approach (i.e., Phases I, ll, and lil). The items identified were incorporated into a matrix for tracking and closure purposes. There were a total of approximately 400 corrective action and improvement initiatives included in the licensee's RPIP corrective action matrix.

l The Phase I items were those items considered to have some potential risk of affecting public or worker health and safety or compliance with regulations. There were approximately 190 Phase I items. By letter dated September 10,1997, the licensee indicated that it had completed Phase 1 of its Radiation Protection improvement Pla The licensee's implementation of its compensatory measures and its Phase I radiological controls program improvement items were previously reviewed, in part, l during NRC Inspection Nos. 50-213/97-06,97-08, and 97-10. During those inspections, the inspector determined that the licensee was implementing its commitments to the NRC and that the improvements outlined in Phase I of the plan l were completed. (Reference NRC Inspection 50-213/97-10, dated January 14, 1998).

The Phase ll items were those items associated with general program enhancement !

and were identified as items necessary to implement the program to fully meet or exceed industry radiation protection good practices. By letter dated March 9,1998, j the licensee indicated it had completed Phase il of its Radiation Protection l

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During this inspection, the inspector selectively reviewed the approximately 170 Phase 11 items, including applicable procedure and program changes, and determined that the licensee implemented Phase 11 of its Radiation Protection Improvement Plan (RPIP) as described in its May 30,1997, letter to the NRC. The licensee also implemented the associated initiatives and corrective actions as described in its l RPIP including 1) enhancement of the definition of the radiological controls i

organization including management expectations, 2) enhancement of the quality of radiological cor.trols program procedures,3) enhancement of the self-assessment program,4) s //crts to increase the accountability of site personnel in the area of radiological controls and,5) provision of enhanced training and qualification of l radiological controls personne Based on this inspection, the licensee implemented Phase ll of its RPI Phase lli program efforts involved review and evaluation of the program and its performance in order to ensure that the program was maintained and capable of effectively supporting primary system chemical decontamination. Specific

, corrective actions to be taken during Phase ill included validation of prograra

! improvements and modification of staffing 'evels to support the system decontamination, strengthening of the exer 1pt and technician training programs, and continuation of program effectiveness reviews. As of the date of this inspection, there were approximately 27 Phase lll items. The Phase ill items were also included t

in a matrix for review and tracking and were being implemented by the license Based on the above, NRC concluded that the licensee completed activities that were sufficient to warrant closure of this ite CAL ltem_4L Prior to eliminating any interim compensatory measures (as committed in response to item 1, above), the licensee is to meet with the Regional Administrator, NRC Region I for the purpose of describing program implementation and performance improvements achieved or planne NRC Findinos (Item 4)

This matter was previously reviewed during NRC Inspection No. 50-213/97-00, dated August 12,1997. The licensee had submitted a letter (CY-97-011) dated

March 7,1997, that identified, in writing, the compensatory measures put in place i to assure sufficient management, control, and oversight of ongoing or planned activities that required radiological controls. and that the licensee will comply with

! the commitment.

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The inspector noted the following management meetings were he!d with the

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license On October 31,1997, the NRC Region i Deputy Regional Administrator and other NRC personnel met with the licensee (Reference NRC Inspection N /97-10, dated January 14,1998) to discuss among other matters,

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the licensee's overall radiological controls program including the status of the I CAL. The licensee also presented the rest.its of its Performance Measures l Progra !

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On March 11,1998, members of NRC management and staff met with the licensee (Reference NRC Meeting Summary No. 98-14, dated April 16,1998)

to discuss decontamination of the reactor system, the design for the spent fuel island and concept, and the justification for safety system

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reclassification at the Haddam neck plant. Also discussed was the status of the radiation protection program including the completion of the Phase I and Phase ll program improvements. The meeting was open to the public, i l

The inspector noted that the licensee continued to implement interim corrective actions as outlined in its March 7,1997, letter to the NRC and has described, in management meetings with the NRC, program implementation and performance improvements achieved or planne This item is complet i

, Conclusion The licensee completed commitments specified by the Confirmatory Action Lette VI. Meetinas X1 Exit Meeting The inspectors presented the inspection results to members of licensee management at the conclusion of the onsite portion of the inspection on March 27,1998. The licensee acknowledged the findings presented.

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PARTIAL LIST OF PERSONS CONTACTED Licensee R. Mellor, Director Site Operations and Decommissioning G. Bouchard, Work Services Director R. Gault, Radiation Protection Supervisor l G. van Noordennen, Licensing Manager R. Sexton, Radiation Protection Manager L. Rayburn-Silvia, Health Physicist M. Sweeney, Radiation Protection Services Supervisor J. Warnock, Quality Assurance Manager i i

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l W. Raymond, Senior Resident inspectnr, Haddam Neck Station t

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INSPECTION PROCEDURES USED I l

lP 71707: Plant Operetions I IP 92703: Followup of Confirmatory Action Letters IP 92904: Follow-up - Plant Support l

ITEMS OPEN, CLOSED, AND DISCUSSED Open None Discussed l None I Closed None l

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LIST OF ACRONYMS ALARA As Low As is Reasonably Achievable f

CAL Confirmatory Action Letter CFR Code of Federal Regulations NRC Nuclear Regulatory Commission QA Quality Assurance RPIP Radiation protection Improvement Plan RP&C Radiological Protection & Chemistry RWST Refueling Water Storage Tank

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