CY-97-011, Submits Discussion of How Plant Will Undertake & Complete Actions Delineated in NRC Confirmatory Actions Ltr,

Submits Discussion of How Plant Will Undertake & Complete Actions Delineated in NRC Confirmatory Actions Ltr,

ML20136F870
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/07/1997
From:	Feigenbaum T CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CAL, CY-97-011, CY-97-11, NUDOCS 9703170092
Download: ML20136F870 (9)

Text

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CONNECTICUT YANKEE ATOMIC POWER COMPANY H ADDAM NECK PLANT 362 INJUN HOLLO", ROAD e EAST HAMPTON, CT 06424-3009 March 7,1997 Docket No. 50-213 CY-97-011 Re: 10CFR20 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Haddam Neck Plant Resoonse To Confirmatorv Action Letter The purpose of this letter is for the Connecticut Yankee Atomic Power Company l (CYAPCO) to discuss how the Haddam Neck Plant (HNP) will undertake and complete  ;

the actions delineated in the NRC's Confirmatory Action Letter, dated March 4,1997.0 ) l Attachment 1 to this letter provides the detailed actions that CYAPCO has or will be implementing. l l

CYAPCO acknowledges, as stated in the NRC's Confirmatory Action Letter, that none  !

of the actions discussed in Attachment 1 precludes CYAPCO from taking action as l

necessary to ensure the health and safety of workers and the public, protect the l environment, and comply with applicable regulatory requirements.

Pursuant to Section 182 of the Atomic Energy Act,42 U.S.C. 2232, CYAPCO will:  !

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1) Notify the NRC Region i Administrator immediately in writing if CYAPCO's l understanding differs from that set forth in the NRC's Confirmatory Action Letter;

2) Notify the NRC Region l Administrator if for any reason CYAPCO cannot complete the actions within the specified schedule and advise the NRC Region I Administrator in writing of CYAPCO's modified schedule in advance of the ,

change; and l l

3) Notify the NRC Region I Administrator in writin6 when CYAPCO has completed the actions addressed in the NRC's Confirmatory Action Letter.

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NRCMarch dated Letter from 4,1997. H. L. Miller to T. C. Feigenbaum, " Confirma -

9703170092 9703o7 PDR ADOCK 050oo213 UEEEElElE,EMl$$!!l Q PDR e

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U. S. Nuclear Regulatory Commission CY-97-011/Page 2

-If .you should have any questions, please contact Mr. G. P. van Noordennen at (860) 267-3938.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY 4

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1. f T. C. Feigestiaum Executive Vice President and Chief Nuclear Officer cc: H. J. Miller, NRC Region I Administrator i M. B. Fairtile, NRC Project Manager, Haddam Neck Plant l W. J. Raymond, NRC Senior Resident inspector, Haddam Neck Plant K. T. A. McCarthy, Director, CT DEP Monitoring and Radiation Division Subscribed and sworn to before me this 7* day of March,1997 Wo ns m, ER wiA i.

Date Commission Expires: 7/97,/2003

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.< 1 l' Docket No. 50-213 CY-97-011

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l Attachment 1

. Haddam Neck Plant Response To Confirmatory Action Letter March 7,1997

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i U. S. Nuclear Regulatory Commission 1

CY 97-011/ Attachment 1/Page 1 i

. l Action item 1 I By March 7,1997, CYAPCO will identify, in writing, specific compensatory measures that CYAPCO will put in place to assure sufficient management, control, and oversight of ongoing or planned activities that require radiological controls.

Response

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CYAPCO has instituted the ] interim corrective actions:

1. Work performed in the Radiological Controlled Area (RCA) will be restricted only to that work which is considered essential and this requires the approval of a site Director or Officer.

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2. The Health Physics Supervisor will be notified 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of any  !

radiological work. A detailed description of the work scope will be provided to l the Health Physics Staff. The Health Physics Supervisor will review the work to: l 1

- Assess the radiological risk associated with the work;

• Determine the radiological controls;

• Determine job coverage and personnel monitoring requirements for each work activity; and

- Exceptions to the 24-hour notification requirement must be approved by a site Director or Officer.

3. A Specific Radiation Work Permit (RWP) is required when any of the following ,

conditions exist: i

- Radiological conditions are unknown and may change; l

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- Expected dose per worker is greater than 10 mrem;

- Expected exposure accumulation for the job is greater than ,

0.05 person-rem; l l

• Work area dose rates are greater than 100 mr/hr; 2

• General area contamination levels are greater than 50,000 dpm/100 cm beta / gamma;

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h^ U. S. Nuclear Regulatory. Commission

, CY 97-011/ Attachment 1/Page 2 General area contamination levels are greater than 20 dpm/100 cm alpha; Work that has the potential to generate airborne contamination;

• Any breach of contaminated systems; and l! *- Complex radiological conditions are involved with the work.

The following additional controls will be required for work activities that require a Specific RWP:

Individuals involved in the work activity and their work supervisor (s) will attend a pre-job briefing. Health Physics supervision and the assigned Health Physics Technician will also attend the pre job briefing. The attending supervisors must agree to the work scope.

A dedicated Health Physics Technician (i.e., no other assigned responsibilities) will be assigned responsibility for the radiological monitoring requirements associated with the work evolution.

4. The following senior management controls of work activities has . been implemented:

1. Backshift And Weekend Work A. The only backshift and weekend work that may be performed is that which is in direct support of the operations shift-B. The Unit Director or Officer must approve any work conducted underitem A; C. Any work performed on backshift or on weekends must have appropriate supervisory and/or managerial support on-site; and D.- The formal 6-week look ahead scheduling process and the tracking of schedule adherence have been reinstituted.

U. S. Nuclear R gulatory Commission CY-97-011/ Attachment 1/Page 3

11. Restrict in Of Work in The RCA 1 Until the long term corrective actions discussed in the February 5,1997 management meetingU ) are implemented, no work will be performed in i the below listed areas except for routine operator rounds without approval of a site Director or Officer. Prior to approval, the director or officer will verify the need to perform the work at this time and will verify that the job is adequately planned and prepared.

A. Spent Fuel Pool; B. Reactor Cavity; C. Any Technical Specification Locked High Radiation Area, which l currently consists of the following: l

- Residual Heat Removal Cubicle;

• Primary Auxiliary Building Pipe Trench;

- lon Exchange Pipe Trench

- Spent Resin Facility; l

- Containment Loops Areas; l

• Regenerative Heat Exchanger Area; I

- Pressurizer Spray Valve Area; and

- Drumming Room Demineralizer Area, and 1

D. Any area where alpha contamination levels are greater than i 20 dpm/100 cm .

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l (1) NRC Letter from J. R. White to T. C. Feigenbaum, " Management Meeting (Reference NRC Inspection Report No. 50-213/96-12)," dated February 25,1997.

U. S. Nuclear Rsgulatory Commission CY-97-011/ Attachment 1/Page 4

5. CYAPCO has initiated an investigation of the recent event involving contaminated material being released offsite and returned to a vendor's facility.

This investigation will determine the cause(s) of this event and the corrective actions that are appropriate. Based on the potentiel conditions that may exist, j

CYAPCO has taken certain initial actions. As more is learned about this event, .

CYAPCO may determine that some of these initial actions are not needed or may _ determine that other actions be implemented as appropriate. Prior to reducing or stopping any of these initial actions, CYAPCO will:

• Ensure that the root causes are thoroughly understood and that the appropriate controls are in place; and

• Notify the NRC in writing and provide the bases for the changes. I When the investigation is complete, CYAPCO will provide the NRC Staff with an  !

update which will include the final determination of appropriate corrective and compensatory actions.

The following describes the initial methods for release of material and the j non-RCA surveys to be performed.

Inside The RCA J I

Until the procedures used to control the release of material from the RCA have been reviewed and verified to be adequate, Health Physics will survey all material leaving the RCA via the Small Articles Monitor (SAM).

Approval from a site Director or Officer is required for the release of material that can not be surveyed via the SAM (i.e., items too large for the SAM).

Inside The Protected Area Until a comprehensive survey of the non RCA portions of the Protected Area has been completed, Health Physics will control all equipment '

leaving the Protected Area. Security personnel have been stationed at the HNP Protective Area egress point who will notify Health Physics when equipment is exiting the Protected Area. The Health Physics department will then conduct appropriate surveys prior to release. Personnel and their personal property, (i.e., notebooks, briefcases, etc.) are exempt from this process.

Health Physics will re-perform the routine surveys of non-RCA areas. In addition, Health Physics will perform walk-through inspections of non-RCA areas inside the Protected Area (i.e., tool cribs, rigging storage areas, Maintenance Shop, instrumentation and Control work areas, etc.) and survey tools and equipment on a sampling basis.

U. S. NucIcar Regulatory Commission CY-97-011/ Attachment 1/Page 5 Outside The Protected Area Health Physics will perform walk-though inspections of the Warehouse, ,

Emergency Operating Facility (EOF), Information Center and Primary Access Building and will survey equipment (i.e., test equipment, plant

, components, hand tools, etc.) on a sampling basis.

Until this survey of the Warehouse has been completed, all material leaving the Warehouse and going offsite will be surveyed. l

6. Management will assess the performance of the program and personnel in j controlling radiological work at the HNP. This will be performed through direct observation of work, review of related Adverse Condition Reports (ACRs), and oversight reports.

7. Nuclear Oversight will continue to evaluate the performance of radiation protection activities and will monitor the effectiveness of the compensatory 1

actions. The results of these assessments will be provided to Health Physics and plant management. I Action item 2 By March 31,1997, CYAPCO will engage the services of an independent assessor to assess the quality and performance of the radiological control program and its 4

implementation.

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Response

CYAPCO commits to engage the services of an independent assessor to assess the quality and performance of the radiological control program and its implementation.

This information will be provided on or before March 31,1997.

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U. S. Nuclear Regulatory Commission CY-97-011/ Attachment 1/Page 6 Action item 3 By May 30,1997, based on input from the independent assessment, CYAPCO will:

i (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 the radiological control program; and (3) Submit a plan and schedule to the Regional Administrator, NRC Region I, for the implementation of improvements in the radiological control program.

Response

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. This information will be provided on or before May 30,1997.

Action item 4 Prior to eliminating any interim compensatory measures (as committed in response to Item 1, above), CYAPCO will meet with the Regional Administrator, NRC Region I for the purpose of describing program implementation and performance improvements achieved or planned.

Response

CYAPCO will comply with item 4.