IR 05000213/1985009

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-213/85-09

ML20135B409
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	08/30/1985
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
References
NUDOCS 8509110044
Download: ML20135B409 (2)

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AUG 3 01985

J Docket No. 50-213 License No. A05012

, Connecticut Yankee Atomic Power Company

> ATTN: Mr. J. F. Opeka 1 i Senior Vice President - Nuclear  !

Engineering'and Operations Group t i P. O. Box 270 Hartford, Connecticut 06101

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Gentlemen:

Subject: Inspection No. 85-09 '

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This refers to your letter dated July 26, 1985, in response to our letter dated June 24, 1985.

Thank you for informing us of the corrective and preventive actions documented i in your lette These actions will be examined during a future inspection of ,

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Your cooperation with us is appreciated, i

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Sincerely, I

Original Signed By8 ,

I h g i omas Artin, Director l Division of Radiation Safety j and Safeguards e

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i R. Graves, Plant Superintendent

D. O. Nordquist, Manager of Quality Assurance

! R. T. Laudenat, Manager, Generation Facilities Licensing

E. J. Mroczka, Vice President, Nuclear Operations

! Gerald Garfield, Esquire i l Public Document Room (POR)

i Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

j NRC Resident Inspector .

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State of Connecticut .

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0FFICIAL RECORD COPY RL HN 85-09 - 0001. d\ 1 08/29/85 / Y

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CONNECTICUT YANKEE AT OMIC POWE R COMP A N Y ( BERLIN CONNECTICUT P O B OA 270 H ARTFORD CONNECitCUT 06141-o270 T ELE P**ONE roa-as-sooo July 26,1985 Docket No. 50-213 A05012 l l

Mr. Thomas T. Martin, Director Division of Radiation Safety and Safeguards l U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Reference:(1) T. T. Martin letter to J. F. Opeka, dated July 1,198 Gentlemen:

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Haddam Neck Plant Response to I&E Inspection 50-213/85-09 Pursuant to the provisions of the NRC's Rules of Practice (10CFR2), this report is submitted in response to Reference (1) which informed the Connecticut Yankee Atomic Power Company (CYAPCO) of one violation and seven licensee program weaknesses. These items were identified during a special announced inspection at the Hadam Neck Plant from April 8 through April 12, 193 Attached are our responses to Appendices A and Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY 3 %.b h 3. F. Opeka Senior Vice President By: C. F. Sears Vice President

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APPENDIX A RESPONSE TO NOTICE OF VIOLATION

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VIOLATION

" Technical Specification 6.8 requires, in part, that written procedures shall be established, implemented and maintained. Each of these procedures shall be reviewed by the Plant Operating Review Committee (FORC) and approved by the Station Superintendent, prior to implementatio Section 4.3 of Procedure No. QA 1.2-7.1 states that the QA/QC Department is responsible for performing receipt inspections in accordance with the procedur . Contrary to the above, a NUS Solidification System, a system designated as Radwaste QA, was received on site during the period of September-October 1984, and the QA/QC Department did not

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perform receipt inspections on the system in accordance with the

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procedur t Contrary to the above on several occasions during October 1984-March 1985, the licensee has implemented at least one vendor procedure (Procedure No. SS-008, Revision E " Operating Procedure for NUSPSC Radwaste Solidification No. 8921") and the procedure was not reviewed by the PORC, and neither was it approved by the Station Superintendent prior to implementatio This is a Severity Level IV violatio (Supplement V)"

RESPONSE

Item 1 Station procedure ACP 1.2-7.1, " Receipt, Inspection and Identification of Materials, Parts and Components" has been revised via a temporary procedure change (No. 85-73) to clarify the responsibility of personnel authorizing vehicles making deliveries directly into the protected area (vice to the warehouse) to ensure that the appropriate Quality Assurance actions are taken. Since deliveries to the warehouse are adequately addressed by current procedures, this change to ACP 1.2-7.1 will ensure that the Quality Assurance Department will be cognizant of, and receipt inspect as appropriate, all QA-related deliverie ;

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Item 2 NUS procedure No. SS-008, Revision E was PORC reviewed and approved for use by the Station Superintendent on June 3,198 In the future, all procedures of this nature will be reviewed by PORC and approved by the Station Superintendent prior to us .

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APPENDIX B RESPONSES TO LICENSEE PROGRAM WEAKNESSES

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LICENSEE PROGRAM WEAKNESS NO. I

"The quality control program was limited in scope with regard to the requirements of 10 CFR 61.55 and 10 CFR 61.56 (Para. 6)".

RESPONSE Connecticut Yankee is presently evaluating alternatives for upgrading its 10 CFR 61 Quality Control Program. Enhancement of this progran is anticipated to be completed by December 31, 198 LICENSEE PROGRAM WEAKNESS NO. 2

"The site Quality Control Inspectors, providing an independent review of the adherence to shipping and radwaste requirements,' were inadequately trained in shipping and radwaste disposal requirements (Paragraph 4)."

RESPONSE The Connecticut Yankee Quality Assurance training program will be reviewed and revised as needed to upgrade the training of inspectors in radwaste shipping and disposal requirements. Procedural changes needed to implement this upgrade will be completed by October 1, 198 LICENSE PROGRAM WEAKNESS No. 3

" Shipping and radwaste procedures exhibited weakness in thats o ACP No.1.2-13.5 referenced inappropriate sections of RAP 6.3-5 for acceptance criteria for shipping containers (Paragraph 7);

o Tables providing scaling f actors for compliance with 10 CFR 61 were not provided and controlled under RAP No. 6.3-5 (Paragraph 7);

o Records of calculations utilizing dose rate to curie conversion f actors were not 'available for review (Paragraph 7);

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o Current procedures did not establish adequate controls to evoke recharacterization of waste streams upon significant changes in the reactor coolant activity (Paragraph 7)."

RESPONSE o The reference deficiency in ACP No. 1.2-13.5 (Rev. 8) was identified by CYAPCo and corrected on April 8,1985 (the ef fective date of RAP 6.3-5, Rev. 22) by Temporary Procedure Change (TPC)

No. 85-43. The problem was permanently corrected by Revision 9 to ACP 1.?-13.5 on June 7, 198 o fables providing scaling f actors for 10 CFR 61 compliance were incorporated into RAP 6.3-5 in Revision 23 dated June 7, 198 o A file for calculations utilizing dose rate to curie conversion f actors was established by the Connecticut Yankee Radioactive Materials Handling Supervisor on May 1,198 o SUR 5.6-14 was revised (Revision 2) on June 7,1985 to incorporate controls to ensure recharacterization of waste streams upon significant changes in reactor coolant activit o All written procedures related to radioactive waste will be reviewed and revised as necessary to ensure their adequacy. This will be completed by September 1, 198 LICENSEE PROGRAM WEAKNESS NO. 4

" Inactive Radwaste Review Lommittee (Paragraph 3)."

RESPONSE The Radwaste Review Committee held a meeting on May 22, 1985. The current problems f acing Northeast Utilities in the Radwaste area were discussed. The group decided that it would be beneficial to key on the results of the Radioactive Waste Transportation Review Group when their report is made availabl LICENSEE PROGRAM WEAKNESS No. 5

" Lack of site QA involvement in radwaste system modifications (Paragraph 6)."

RESPONSE in addition to the measures delineated in Appendix A, item 1 (of this letter) to ensure QA receipt inspections are performed when appropriate, procedures for use with the NUS Solidification System will be revised to include QA " hold points". These ho1d points will upgrade the level of QA involvement with the solidification syste The procedural revisions discussed above will be completed prior to use of this system and no later than September 1,1985. The solidification unit is currently not on sit .

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" Corporate QA implementing procedures did not reflect the Topical  !

Report Classification of radwaste activities as a Category I area i

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(Paragraph 5)."

RESPONSE Connecticut Yankee QA implementing procedures have been revised (as of June 21, 1985) to specifically address the applicability of the QA

Program to radwaste activities. These procedural revisions were initiated in response to NRC Information Notice #84-50, " Clarification

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of Scope of Quality Assurance Programs for Transport Packages Pursuant

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to 10 CFR 50, Appendix B." ,

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Corporate level (NE&O) procedural guidance for redwaste activities does not exist. This had been identified prior to your inspection through a Corporate QA Audit ( A60425. April 1985). As a result of i that audit, we are evaluating the development of an NEO Procedure for i radwaste activitie i

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t "Radwaste Transportation audit was performed without technical expertise participating in the audit (Paragraph 6)." ! RESPONSE j We agree that persor **1 performing QA audits should have a degree of 1 technical com,etence a the area being audited. This is accomplished l in one of two ways: training the QA auditor or utilizing additional

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will ensure that future QA audits of radweste shipping will utilize technically competent auditors, either by utilizing QA personnel who have received additional training or by supplementing the audit team with individuals with the required expertis !

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