ML20055F606

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Forwards Final SALP Rept 50-213/88-99 for 880801-900215. Evaluation of 900619 SALP Comments Resulted in No Changes to SALP Ratings & SALP Rept Not Modified
ML20055F606
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 07/09/1990
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Mroczka E
CONNECTICUT YANKEE ATOMIC POWER CO.
Shared Package
ML20055F607 List:
References
NUDOCS 9007180151
Download: ML20055F606 (5)


See also: IR 05000213/1988099

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Docket No. 50-213

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Connecticut Yankee ~ Atomic Power Company

ATTN:: Mr. Edward J. Mroczka

Senior Vice President - Nuclear

Engineering and Operations Group

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P.0; Box 270

Hartford, Connecticut

06141-0270

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. Gentlemen:

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Subject:. Systematic Assessment of Licensee Performance (SALP) Report

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50-213/88-99

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.This forwards the Hadda'n Neck Plant SALP final report for the period from

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August 1, 1988 through February 15,.1990.. The initial SALP report was

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-forwarded to you by our-April 26, 1990 letter. On May 10, 1990, we discussed

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the SALP with you'and.your -staff. We have reviewed your written . comments -

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, dated June 19,.1990, and herewith transmit the final SALP report.

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Our evaluation of your SALP comments resulted in no changes to.the SALP

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ratings, and we did not modify the SALP report. -We appreciate your-thorough

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review ~of the SALP report.

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We appreciate your comments on the SALP and the. discussion of your plans for-

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_ improving performance. Thank you for your cooperation.

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S.i ncerely.

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Original Signed By:

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Thomas T. Martin

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Thomas T. Martin

Regional Administrator

Enclosures:-

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NRC Region.I' Letter', T.T. Martin to E,J. Mroczka, dated April 26, 1990

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2.

SALP Management Meeting Attendees

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Connecticut Yankee Atomic Power Company Letter, E.J. Mroczka to NRC

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Document-Control Desk, dated June 19 -1990

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Systematic Assessment of Licensee Performance Report 50-213/88-99.

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OFFICIAL RECORD COPY

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Connecticut Yankee Atomic Power Company

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ec w/encis:

W. D. Romberg, Vice President, Nuclear Operations

E. A. DeBarba, Nuclear Station Director, Haddam Neck Plant

G. H. Bouchard, Nuclear Unit Director, Haddam Neck Plant

D. O. Nordquist, Manager, Quality Assurance

R. M. Kacich, Manager, Generation Facilities Licensing

S. E. Scace, Nuclear. Station Director, Millstone

Gerald Garfield, Esquire

Chairman Carr

Commissioner Rogers

Commissioner Curtiss

Commissioner Remick

Vandana Mathur, McGraw-Hill Publications (2 copies)

Art McGuire, Construction Industry Litigation Reporter (2 copies)

Public Document Room (PDR)

Local Public Document Room (LPDR)

-Nuclear Safety Information Center (NSIC)

NRC Senior Resident Inspector

State of Connecticus

Institute of Nuclear Power Operations

K. Abraham, RI (25 copies)

bec w/ enc 15:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1)

J. Taylor, EDO

J. Caldwell

EDO

T. Martin, RI

D. Holody, ES

M. Knapp, DRSS

,

W. Hodges, DRS

W. Kane, DRP

J. Wiggins, DRP

DRP Section Chief

A. Wang, PM, NRR/PD I-4

W.,Raymond, SRI, Millstone

A. Asars, DRP-

Management Meeting Attendees

DRP Wishlist Coordinators

RI:DRP

RI:DRP

RI:DRP

RI:DRP

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  • Shediosky
  • Haverkamp
  • Wenzinger
  • Kane

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  • See attached concurrence sheet

OFFICIAL RECORD COPY

LTR HN SALP - 0002.0.0

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Connecticut Yankee Atomic Power Company

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cc w/encis:

W. D. Romberg, Vice President, Nuclear Operations

E. A. DeBarba,. Nuclear Station Director, Haddam Neck Plant

G. H. Bouchard, Nuclear Unit Director, Haddam Neck Plant

D. O. Nordquist, Manager, Quality Assurance

R. M. Kacich, Manager, Generation Facilities Licensing

S. E. Scace, Nuclear. Station Director, Millstone

Gerald Garfield, Esquire

Chairman Carr

Commissioner Roberts

Commissioner Rogers

Commissioner Curtiss

Commissioner Remick

Vandana Mathur, McGraw-Hill Publications (2 copies)

Art McGuire, Construction Industry Litigation Repc.ter (2 copies)

Public Document Room (PDR)

Local Public Document Room (LPDR).

Nuclear Safety Information Center (NSIC)

NRC Senior Resident Inspector

State of Connecticut

'.nstitute of Nuclear Power Operations

K. Abraham, RI (25 copies)

bec w/encis:

Region ! Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1)

J. Taylor, EDO

J. Caldwell, EDO

T. Martin, RI

D. Holody, ES

M. Knapp, DRSS

W. Hodges, DRS

W. Kane, DRP

J. Wiggins, DRP

DRP Section Chief

A. Wang, PM, NRR/PD I-4

W. Raymond, SRI, Millstone

A. Asars, DRP

Management Meeting Attendees

DRP Wishlist Coordinators

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0FFICIAL RECORD COPY

LTR HN SALP - 0002.0.0

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UNITED STATES

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NUCLEAR RESULATORY C00ASAISSN)N

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KING OF PRUSSIA. PENN8YLVANIA 19406

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Docket No. 50-213

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Northeast Nuclear Energy Company

ATTN: Mr. Edward J. Mroczka

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Senior Vice President, Nuclear

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Engineering and Operations

P.O. Box 270

Hartford, Connecticut

06101-0270

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Gentlemen:

Subject: Systematic Assessment of Licensee Performance (SALP) Initial Report

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Number 50-213/88-99 (August 1, 1988 - February 15,1990)

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The enclosed report transmits the initial results of the Connecticut Yankee

Atomic Power Company Haddam Neck Plant SALP Board Meeting conducted on April 2,

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1990. We will contact you soon to schedule a meeting to discuss the evaluation.

At the meeting, please be prepared to discuss the assessments and any plans you

have to improve performance.

You may provide written comments within 30 days

of the meeting.

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Following our meeting, your written response (if deemed necessary), the final

SALP report and a summary of our findings and planned actions will be placed in

the NRC Public Document Room.

Yout cooperation is appreciated.

Sincerely,

Q:N

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Thomas T. Martin

Regional Administrator

Enclosure: NRC Region I SALP Report 50-213/88-99

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ENCLOSURE 2

NRC/ CONNECTICUT YANKEE ATOMIC POWER COMPANY MANAGEMENT MEETING

MAY 10, 1990

NAME

TITLE

NRC Region I

R. F. Burnett

Acting Deputy Regional Administrator

'J. T. Wiggins

Deputy Director, Division of Reactor Projects (DRP)

E. C. Wenzinger

Chief, Projects Branch No. 4, DRP

J. T. Shediosky

Senior. Resident Inspector, Haddam Neck Plant

A. A. Asars

Resident Inspector. Haddam Neck Plant

A. E. Vegel

Reactor Engineer, DRP

NRC Nuclear Reactor Regulation (NRR)

A. B. Wang

Project Manager. Project Directorate I-4

Connecticut Yankee Atomic Power Company

W. B. Ellis

Chairman and Chief Executive Officer

B.'M. Fox

President

J. F. Opeka

Executive Vice President - Nuclear Engineering and

Operations

W.-D. Romberg

Vice President - Nuclear Operations

C. F. Sears

Vice President - Nuclear and Environmental

Engineering

R. P. Werner

Vice President - Generation Engineering and

Construction

E. A. DeBarba

Nuclear Station Director - Haddam Neck Plant

G. H. Bouchard

Nuclear Unit Director - Haddam Neck Plant

Northeast Utilities Service Company

G. L. Johnson

Director - Generation Engineering and Design

Department

D. O. Nordquist

Director - Quality Services

R. M. Kacich

Manager - Generation Facilities Licensing

R. C. Rodgers

Manager - Radiological Assessment Branch and

Chairman of the Nuclear Review Board

L. J. Keezing

Corporate Communications

E. P. Perkins

Licensing Engineer

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ENCII)SURE 3

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General Offices e Seiden Street. Berlin, Connecticut

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P.O. BOX 270

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HARTFORD, CONNECTICUT 061410270

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June 19, 1990

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Docket No. 50-213

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B13548

Re:

SALP

U.S. Nuclear Regulatory Commission

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Attention: Document Control Desk

Washington, DC 20555

Gentlemen:

Haddam Neck Plant

Systematic Assessment of Licensee Performance (SALP)

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in a letter dated April 26,1990,II) the NRC Staff forwarded to Connecticut

Yankee Atomic Power Company (CYAPCO) the SALP Board Report for the 18 month

period ending February 15, 1990 for the Haddam Neck Plant.

Subsequent to

receipt of the SALP Board Report, a meeting was held on May 10, 1990.

The purpose of this letter is to respond to and comment on the findings of the

SALP Board with particular emphasis on the Board recommendations for the

individual evaluation categories.

Attachment No. I to this letter contains

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CYAPCO's response to each of the Board's recommendations for the Haddam Neck

Pl ant.

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In reviewing the SALP report, CYAFC0 finds it encouraging that the NRC Staff

considers the overall performance reflected by this appraisal to be at a

sustained high level in spite of some major challenges during the current

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refueling outage.

Given the very positive SALP evaluation, CYAPC0 recognizes

the importance of striving to improve and, as such, will continue to pursue-

positive initiatives in all areas including the following:

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implementation of STS (format) Tech. Specs.

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Containment Integrity

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Contractor Control

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Security

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ALARA

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Procedure Compliance

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Housekeeping

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Self Identification of Potential Problems and Prompt Corrective

Action

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Root Cause Investigation

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T.

T.

Martin letter to

E.

J.

Mroczka,

"SALP Initial

Report No.

50-213/88-99," dated April 26, 1990.

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U.S. Nuclear Regulatory Commission

B13548/Page 2

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June 19, 1990

With respect to the issues of corporate support of ALARA that you raised

during the May 10, 1990 meeting, we wish to emphasize our willingness to work

with you to bring these to resolution. We agree with your proposal to address

these issues as part of the "mid SALP" process.

CYAPC0 proposes that we meet

with the NRC Staff during the third quarter of 1990 to discuss these items to

facilitate resolution by the "mid SALP" meeting in the fall.

Lastly, we wish to state our support of the 'mid SALP" meeting concept in the

belief that this will further enhance communication between our respective

organizations. We look forward to a continuation of constructive dialogue at

all levels of CYAPC0 and the NRC Staff.

If you have any questions, please

contact us.

Very truly yours,

CONNECTICUT YANKEE ATOMIC POWER COMPANY

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E. J. Mp6cfka

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Senior Vice President

cc:

T. T. Martin, Region I Administrator

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A. B. Wang, NRC Project Manager, Haddam Neck Plant

J. T. Shediosky, Senior Resident Inspector, Haddam Neck Plant

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Qp_qket No. 50-Ela

B13548

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Attachment No. 1

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Connecticut Yankee Atomic Power Company

Haddam Neck Plant

Response to SALP Report

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June 1990

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Attachment No. 1

B13548/Page 1

June 19, 1990

Functional Area:

PLANT OPERATIONS

Board Recommendation: None

Response: None

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Attachment No. 1

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B13548/Page 2

June 19, 1990

Egnetional Area:

RADIOLOGICAL CONTROLS

Board _Recomendation: Within six months, meet with NRC to discuss the plan for

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long term corporate support of health physics.

Responte:

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Corporate A MR&.Jupanti

The personnel and the responsibility for operational and outage engineering

ALARA assessments was transferred from the corporate office to the site,

health physics department in 1988.

The Corporate Radiological Assessment-

Branch retains.the project management function for the major Exposure

Reduction Initiatives Program.

This includes, for the Haddam Neck Plant,

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eight short-term and eight long-term initiatives.

All of the short-term

initiatives were completed over the 1987+1989 time period.

The remaining

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long term initiatives which are being evaluated / pursued include chemical.

decontamination of the RCS, longer fuel cycles (Zr conversion), primary

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chemistry controls (high ph, GEZIP for PWRs, ultrafine filters in RCS let-

down), and corporate administrative annual and lifetime exposure guidelines.

These are proactive initiatives and are considered to be state of the art.

CYAPC0 will continue to look for effective ALARA initiatives to further reduce

man-rem.

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Corporate Appraisals of The Site Radiolocical Protection Procram

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Corporate staff in the Radiological Assessment Branch was reduced in 1988 due

to the transfer of personnel to the site.

In addition, due to unrelated job

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transfers of the individuals performing the appraisal function, replacements

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had to be obtained.

This resulted in the 1989 Appraisal Program being reduced

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in scope when compared to 1988.

In 1989, an appraisal was conducted in the

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radiation exposure module and the associated functions in the training and

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equipment modules.

The Appraisal Program will be optimized in 1990 to match

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available resources and at the same time allow for an effective program.

At

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this time, an appraisal of the ALARA module and the associated functions in

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the training and equipment modules is scheduled for June-July 1990.

Overall Corporate Suonort

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NRC Staff should note that corporate radiological technical support of the

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site programs in chemistry, health physics, engineering and operations, are an

integral part of these programs.

Many of the examples cited in the SALP

Report included Corporate Radiological Assessment Branch involvement.

This

will continue.

In addition, major health physics projects undertaken by the

Corporate Radiological Assessment Branch are:

implementation of a new Harshaw

personnel TLD system in January 1990, and development of the third generation

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of computerized health physics records *.ystems scheduled for service in early

1991.

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B1354C/Page 3

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June-19; 1990-

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Proposed Neeting

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As discussed. in the cover letter, CYAPC0 proposes that a meeting with the NRC

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Staff be scheduled for the third quarter of 1990'to discuss these issues.

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B13548/Page 4

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June 19, 1990-

Functional Are.g: MAINTENANCE / SURVEILLANCE

Board Recommendation:

None

Response: None

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Attachment No. 1

B13548/Page 5

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June 19, 1990

Functional Area:

EMERGENCY PREPAREDNESS

Board Recommendation: None

EtDknit: None

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Attachment No. 1

B13548/Page 6

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June 19, 1990

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funglign61_Atp: SECURITY

Spitd Recomendation:

None

FaapSDit:

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.}ecurity Events

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As noted in the NRC Staff's SALP report, the Haddam Neck Plant Security

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Department has taken a very aggressive approach to determine each event's root

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cause.

In all incidents, a root cause was determined and corrective actions,

both short term and long term, were implemented.

Long term corrective actions included a number of items such as reevaluating

security officer hiring practices to ensure only the most qualified and

appropriate personnel are recruited as Security Officers; reevaluating the

Security Officer Training Program; having a psychologist evaluate the behavior

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and attitude of Security Force personnel and offer recommendations on improve-

ments; and continuing the aggressive self-assessment program recently intro-

duced.-

The atove items, as well as crntrolling the turnover rate, as addressed below,

should ensure that Security personnel at the Haddam Neck Plant are highly

qualified, dedicated, and professional employees committed to excellence.

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Contractor Force Attrition

It is recognized that a high attrition rate of security force personnel could

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impact performance.

In an effort to stabilize the attrition rate at Haddam

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Neck, a number of items have been initiated.

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A psychologist was brought on board to review current behavior and

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attitude of security department personnel.

The psychologist's

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recommendations have been reviewed and an implementation plan was

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developed,

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A shift differential pay program to assist in retaining security

officers and also assist in keeping senior security officers on

backshifts is currently under review,

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We are revising our practices in order to recruit more qualified

security personnel.

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Retirement plans have been offered to security officers,

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Additional employee support programs are being considered for con-

tract security personnel.

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Attachment No. 1

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B13548/Page 7

. June 19, 1990

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Labor relations and interpersonal relations training will be provid-

ed to security supervisors.

Continued review of the attrition rate at Haddam Neck is essential and will

remain a top priority.

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Attachment No. 1

~B13548/Page 8

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June 19, 1990

Functional Area:

ENGINEERING / TECHNICAL SUPPORT.

Board Recommendation:

None

Response: None

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Attachment No. 1

B13548/Page 9

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Jane 19, 1990

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Functional Area:

SAFETY ASSESSMENT / QUALITY VERIFICATION

Board RecommendatiOD:

None

RefDonse:

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in the report, the NRC Staff mentioned that several licensing submittals were

untimely during the SALP 3eriod. However, the Staff went on to attribute this

situation to an overly amaitious work schedule.

CYAFC0 wishes to document our

general agreement with that perspective and also offer some additional infor-

mation.

We believe that the " timeliness" issue is principally related to the conver-

sion of the Haddam Neck Plant technical specifications to the Standard Tech-

nical Specification format.

Although there was no official schedule estab-

lished, some informal submittal target dates were extended for a variety of

reasons.

This was a very ambitious project requiring extensive resource

investments during a time when there were many other active projects, as the

Staff's report alluded.

CYAPC0 believes that since the STS format conversion

is now complete, along with many other issues resolved during this SALP

period, timeliness of submittals will be maintained at a higher level.

Measures remain in place to monitor our performance in this regard,

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