CY-97-049, Forwards Rev 0 to Cyap Haddam Neck Plant Radiation Protection Improvement Plan, in Response to CAL 1-97-07
| ML20148G912 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/30/1997 |
| From: | Feigenbaum T CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20148G915 | List: |
| References | |
| CAL-1-97-07, CAL-1-97-7, CY-97-049, CY-97-49, NUDOCS 9706060299 | |
| Download: ML20148G912 (7) | |
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CONNECTICUT YANKEE ATO MIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD e EAST HAMPTON, CT 06424-3099 May 30,1997 Docket No. 50-213 CY-97-049 Re: CAL No. 1-97-007 Mr. H. J. Miller Regional Administrator, NRC Region i U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Haddam Neck Plant Respon::e to Confirmatory Action Letter, Radiation Projection Imorovement Plan Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C. 2232 and N
Confirmatory Action Letter (CAL) dated March 4,1997, the Connecticut Yankee Atomic Power Company (CYAPCO) is forwarding the Radiation Protection Improvement Plan. A commitment of the CAL requires that by May 30, 1997, based on input from the independent assessment (Millennium Report),
CYAPCO will: (1) identify problems, determine root causes, 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 to the Regional Administrator, Region I, for the implementation of improvements in the radiological control program.
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An independent assessment of CYAPCO's Radiation Protection Program was conducted by Millennium Services, Inc. The executive summary of this report is provided as Enclosure 1.
The independent assessment has been reviewed by CYAPCO and we concur with the root causes and significant issues requiring resolution. Improvement initiatives to resolve these issues are identified in the Radiation Protection improvement Plan (Enclosure 2). The actions associated with the initiatives are prioritized and implernentation will be accomplished using a phased approach.
The phases are defined based on potential risk to the public and workers, need to support plant activities, and the time necessary to thoroughly implement and j
evaluate the actions.
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W Nuclear Regulatory Commission letter to Mr. Ted C. Feigenbaum " Confirmatory Action Letter" dated j
March 4,1997.
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U.' S. Nuclear Regulatory Commission CY-97-049/Page 2 '
A general description of the phases and their commitment dates are as follows:
CY-97-049 Phase I includes identified deficiencies which have a potential risk of affecting public or worker health and safety or compliance with federal regulations. Items associated with Phase I of the Radiation Protection improvement Plan are j
expected to be completed by July 31,1997.
1 CY-97-049-02 Phase ll actions are required to implement the program to fully i
meet or exceed standard industry radiation protection good practices. Items associated with Phase ll of the Radiation
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Protection Improvement Plan are expected to be completed by September 30,1997.
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l CY-97-049-03 Phase ill actions are necessary for the program to support primary system chemical decontamination. Items associated l
with Phase ill of the Radiation Protection improvement Plan are expected to be completed by December 31,1997.
CYAPCO will notify the NRC in writing when each of these phases have been completed or if additional time is needed to complete each phase.
i Please contact Mr. G. P. van Noordennen at (860) 267-3938 if you have any -
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questions or need additional information.
Very truly yours, 5
L CONNECTICUT YANKE ATOMIC POWER COMPANY h & M /s 4-
'Ted. C. Feigenbauny ' d Chief Nuclear Officer Executive Vice Prersident an Subscribed and sworn to before me this 0* day of May,1997 a h 0 Raukka.
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' Date Commission Expires: 1 99 l
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l U. S. Nuclear Regulatory Commission l
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Enclosures l
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M. B. Fairtile, NRC Project Manager, Haddam Neck Plant W. J. Raymond, NRC Senior Resident inspector, Haddam Neck Plant K. T. A. McCarthy, Director, CT DEP Monitoring and Radiation Division l
NRC Document Control Desk i
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Millennium Services, Inc.
independent Assessment of the
. Radiological Controls Program at the Haddam Neck Plant Executive Summary
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May 1997 1
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h-U. S. Nuclear Regulatory Commission /CY-97-049/Page 1 EXECUTIVE
SUMMARY
An independent assessment of the Connecticut Yankee Atomic Power Company's 11addam Neck nuclear station Radiation Protection Program was conducted by Millennium Services, Inc. The assessment period spanned the months of March and April,1997. The assessment was in response to a Confirmatory Action letter (CAL) issued by the Nuclear Regulatory commission following radiological incidents that had occurred during the period of November 1996 to February 1997. The liaddam Neck plant has been shutdown since mid-1996 and all fuel has been offloaded and is stored in the spent fuel building. Northeast Utilities has announced that the facility will be decommissioned. Presently, the plant continues to be governed by the operating license and the Technical Specifications.
The assessment was conducted by llealth Physicists with extensive experience in the management and evaluation of radiation protection programs, including two Certified Health Physicists, and a former Nuclear Regulatory Commission inspector. The performance based assessment was structured using the basic elements contained in Guideline INPO 91-014, Revision 1, Guidelines for Radiological Controls at Nuclear Power Stations, and the Management Oversight Risk Tree (MORT) method described in NUREG-0855.
The assessment focused on the elements of an operational health physics program.
Emphasis was placed on the organizational structure, including responsibilities, authorities, and accountabilities. Program documents, including station procedures, that I
define the management structure were evaluated and compared against field practices.
Observations and data reviews of methods used to define the radiological hazard, communicate that hazard, establish radiological control requirements, and monitor exposures were evaluated. The assessment included the station work control process and its interface with the Health Physics Department and support services such as instrument calibration, dosimetry processing, and training.
The assessment report contains findings, conclusions, and recommendations for each of the program elements. The conclusions and recommendations of the individual program elements identify several programmatic issues. Specifically, the lack of:
Clear definition of responsibilities, authorities, and accountabilities for program elements; i
Program documents that describe management structure, program commitments, and methods to meet those commitments;
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U. S. Nuclear Regulatory Commission /CY-97-049/Page 2 Rigorous standards for execution and documentation of field health physics activities, including surveys, postings, RWPs; Sufficient self assessment by the Radiation Protection Department to identify and correct problems and to reinforce strong performance; Ability to hold people accountab!c; and Integration of radiological protection into station work procedures and programs.
The most significant recommendations involve:
Development and staffing of a functional organization; Development of controlling program document and reorganization of procedures; Delineation of challenging performance standards; and e
Implementation of processes to monitor and reinforce expectations in the field.
Preliminary findings have been presented to the recently hired Health Physics Manager.
The manager has commenced several activities in support of the recommendations of this assessment, including the development of a mission statement for the organization and a l
functional organization. These efforts are consistent with the critical needs identified in this assessment.
It is the opinion of the assessment team that the existing organizational structure and resources are capable of supporting the limited activities presently challenging the Health Physics Program. The limited activities planned for the near future afford the opportunity i
to methodically implement the changes necessary to effectively execute the organization's mission in support of the decommissioning project.
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