CY-98-151, Responds to NRC Re Violations Noted in Insp Rept 50-213/98-03.Corrective Actions:Root Cause Team Has Determined That Shift Managers Initial Reportability Decision Was Not Correct

Responds to NRC Re Violations Noted in Insp Rept 50-213/98-03.Corrective Actions:Root Cause Team Has Determined That Shift Managers Initial Reportability Decision Was Not Correct

ML20153F736
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/21/1998
From:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-213-98-03, 50-213-98-3, CY-98-151, NUDOCS 9809290224
Download: ML20153F736 (13)

Text

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. , 1 CONNECTICUT YANKEE ATOMIC POWER COMPANY l

HADDAM NECK PLANT I 362 INJUN HOLLOW ROAD EAST HAMPTON, CT 06424-3099 i l

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September 21,1998 Docket No. 50-213 l CY-98-151 Re: 10 CFR 2.201 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Haddam Neck Plant l Reply to a Notice of Violation (NOV) i NRC Intearated Inspection Report No. 50-213/98-03 The purpora of this letter is for Connecticut Yankee Atomic Power Company (CYAPCO) to reply to the notice of violations contained in NRC Inspection Report 98-03W. The violations involved the failure to classify an event in accordance with the emergency actions levels following an inadvertent release of radiocctive liquid; the failure to control the plant configuration during valve manipulations or tagging activities, resulting in plant events; the failure to properly calibrate the stack flow instruments used in the stack effluent pathway; and, the failure to provide complete information in support of a license amendment application.

Attachment 1 to this letter restates the cited violations and provides the required CYAPCO responses. As requested by the NRC's letter of August 21,1998, CYAPCO has included in the responses to violations B and C, a discussion on our actions taken to address the underlying causes of the plant configuration control and human performance issues, and our plans and schedule to provide an independent verification that the plant procedures for demonstrating compliance with technical specification surveillance requirements are acceptable.

f Attachment 2 presents CYAPCO's commitments made within this letter. Other statements within this letter are provided for information only.

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(1) Mark C. Roberts letter to R. A. Mellor, "NRC Integrated Inspection Report 50-213/98-03," dated August 21,1998.

- 'c_i 9809290224 980921 PDR ADUCK 0500o213 G PDR

U. S. Nucl:ar Regul . tory Commission CY-98-151/ Page 2 If there are any questions regarding this submitta'l, please contact Mr. G. P. van Noordennen at (860) 267-3938.

l Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY l

• h wva ..

Russe . Mellor \

Vice Presi e'nt - Operations and Decommissioning ,

Attachments 1

cc: H. J. Miller, Region l Administrator T. L. Fredrichs, Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident inspector, Haddam Neck Plant E. Wilds, Director, CT DEP Monitoring and Radiation Division i

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1 Docket Number 50-213 CY-98-151 Attachment 1  !

I Haddam Neck Plant Reply to Notice of Violations NRC Insoection Reoort No. 50-213/98-03 i

September 1998

U. S. Nucisar Regulatory Commission

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CY-98-151/ Attachment 1/Page 1 Restatement of Violation During an NRC inspection conducted on April 14 - August 13,1998, violations of NRC l requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"(Enforcement Policy), NUREG-1600, the violations are listed below.

A. 10 CFR 50.54(q) states, 'n aart, a licensee shall follow and maintain in effect emergency plans which mm the standards in 10 CFR 50.47(b) and the requirements in Appendix E of this part.

I l The Licensee's Emergency Plan, Section 6, Emergency Plan implementing ,

l Procedures (EPIP) 1.5-1, Revision 31, Emergency Assessment Using EAL  !

! Tables, under Section 6.2 and EAL OU1, Unplanned Release, requires, in part, l the declaration of an Unusual Event, for liquid discharges in which total activity

[ exceeds 1000 microcuries.

l Contrary to the above, following the unplanned release of about 800 gallons of water containing approximately 2200 microcuries of radioactivity from the "A" waste test tank on June 20,1998, the licensee failed to declare an Unusual l Event.

l This is a Severity Level IV violation (Supplement IV).  :

B. Technical Specification 6.8.1 requires that written procedures and/or l administrative policies be established, implemented and maintained covering the activities as recommended in Appendix A of Regulatory Guide 1.33. Regulatory 1 Guide 1.33 requires that procedures be established governing plant operations and work controls.

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j. 1. Procedure NOP 2.14-15B, Revision 4, requires that valve WD-V-133A be i closed during the discharge of the "B" Waste test tank (WTT).

Contrary to the above, on June 20,1998, valve WD-V-133A was open l during the discharge from the "B" WTT, resulting in the inadvertent

release of 800 gallons of water from the "A" WTT.

2. Work Control Manual (WCM) 2.4-1, Equipment Tagging, Revision 9,

requires in Step 1.6.1 that components be aligned and tagged in L accordance with the tagging sheet. Procedure NOP 2.0-8, Independent Verification, Revision 0, requires in Step 6.1 that the independent verifier verify that the tagged component is in the correct position.

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i CY-98-151/ Attachment 1/Page 2 1 i

l Contrary to the above: (a) The tagging sheet for Clearance 980200 l required that valves SI-928 and SI-929 be red tagged and independently verified closed. On July 14,1998, valves SI-928 and SI-929 were found open, and, (b) The tagging sheet for Clearance 980229 required that valve PW-V-108A be red tagged and independently verified closed. On July 7,1998, PW-V-108A was found open. The mispositioning of i PW-V-108A resulted in the inadvertent spray of workers and equipment in the Spent Fuel Building on July 7,1998.

3. Procedure NOP 2.7-1 requires that valve LD-V-238 be full open to place the reactor coolant system (RCS) letdown post filter in service.

Contrary to the above, on July 27,1998, LD-V-238 was found less than l full open, which caused a partial flow blockage in the letdown line and ,

contributed to the pressure transient and vibrations during the RCS l decontamination.

This is a Severity Level IV violation (Supplement IV). I C. Technical Specifications 3/4.3.3.8 requires that the stack flow monitor be calibrated and operable. Technical Specification Section 1.4 defines the Channel Calibration, which states, in part, "The Channel calibration shall ermmpass the entire channel including the sensors and alarm,..."

Contrary to the above, on June 5,1998, the NRC determined that, since about 1974, a sensor (pitot tube) of the main stack flow rate monitor (FT-1101) was not included for the channel calibration. The stack flow instrument was historically inoperable (LER 98-05).

This is a Severity Level IV violation (Supplement IV).

D. 10 CFR 50.9(a) requires that the information provided by a licensee to the Commission be complete and accurate in all material respects. ,

Contrary to the above, on July 20,1998, the licensee identified an error made in an application to amend License DPR-61. The application made by letter CY-97-006 dated May 30,1997, stated that following a loss of normal power, limited makeup water to the fuel pool could be provided by gravity feed from a tank. The tank had insufficient inventory to provide gravity feed of makeup water to the fuel pool at the time of the May 30,1997 application, or any time thereafter, and was abandoned on October 9,1997.

This is a Severity Level IV violation (Supplement IV).

1 U. S. Nucisar Regulatory Commission CY-98-151/ Attachment 1/Page 3 Reason For The Violation (Violation A)

On Saturday June 20,1998, CYAPCO personnel reviewed the discharge from the "A" WTT for reportability. A review of the Emergency Action Level (EAL) tables indicated that the event was reportable as an Unusual Event if the Effluent Monitors are in Alarm or if there is an unplanned, unmonitored or uncontrolled offsite release and DELTA-TWO posture code limits as determined from Emergency Plan implementing Procedures (EPIP) were exceeded. CYAPCO personnel then reviewed EPIP 1.5-1,

" Emergency Assessment Using EAL Tables" and EPIP 1.5-1 A, "Non-Emergency Event Assessment." Both tanks had been sampled and analyzed prior to the discharge in accordance with our National Pollutant Discharge Elimination System (NPDES) permit.

All parameters for both tanks were within NPDES permitted limits and the Haddam Neck Plant Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM). CYAPCO personnel determined that the release was not unplanned since CYAPCO had already issued internal permits to discharge both tanks. Based on this reasoning. CYAPCO initially concluded that this event was not reportable to the NRC as an Unusual Event.

On Monday, June 22,1998, senior management conducted a further investigation of the event. Because a portion of the "A" WTT was inadvertently discharged simultaneously with the discharge from the "B" WTT, which is not the normal practice, senior management concluded that the event was not planned to occur in that fashion and, thus, was an " unplanned" release. This determination was made even though the water in the "A" WTT met all NPDES and REMODCM discharge criteria and was ready for discharge. This event was reportable as an " Unusual Event" per the EAL tables since the discharge was unplanned and the total radioactivity released (excluding Tritium and dissolved gases) exceeded 1000 microcuries. It should be noted that the internal permit limits for releases for these two tanks were 36,000 microcuries and 13,000 microcuries for the "A" WTT and "B" WTT, respectively. The discharge from the ~

"A" WIT was calculated to be 2,250 microcuries, which exceeded the " Unusual Event" activity limits, but was within routino discharge parameters for radioactivity.

The root cause of this event was unclear and potentially conflicting guidance in governing procedures and supporting documents, in particular the word " unplanned" and the definition of Unusual Event in addition, there was evidence of a lack of questioning attitude by management personnel contacted on Saturday by the personnel working on shift.

Corrective Steps That Have Been Taken and the Results Achieved (Violation A)

The following actions have been taken as a result of the above violation:

The root cause team has determined that the Shift Manager's initial reportability decision was not correct. CYAPCO is sharing the lessons learned from this event with the other Shift Managers and Director of Site Emergency Operations (DSEOs). In

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. 1 U. S. Nuclxr R:gulatory Commission I CY-98-151/ Attachment 1/Page 4 j addition, the on call DSEO is available, via pager, to the Shift Managers to provide j assistance, if requested, in making their reporting decisions. The on call DSEOs have been given a controlled copy of EPIP 1.5-1 and 1.5-1 A to assist them if they are contacted by the shift manager concerning event reportability. Note, that when CYAPCO implements the Defueled Emergency Plan, this support will continue to be available to the Shift Managers and will be provided by the Emergency Director (s).

Corrective Steps That Will Be Taken To Avoid Further Violations (Violation A) ,

I The following actions will be taken as a result of the above violation to prevent I

recurrence:

Reporting procedures will be reviewed and revised, as appropriate, to ensure clear guidance is provided. These improvements will be completed by December 15,1998 (CY-98-121-04).  :

Date When Full Compliance Will Be Achieved (Violation A)

CYAPCO is currently in full compliance with 10 CFR 50.47(b) and the requirements in Appendix E of this part. 1 Reason For The Violation (Violation B)

Violation B discusses the need for CYAPCO to develop procedures that govern plant operations and work controls. The NRC cited in this violation three examples whereby required steps in various procedures were not complied with. CYAPCO has performed root cause analyses for each of the cited examples which resulted in identifying causes and implementing extensive corrective actions. CYAPCO has found that for two of the three issues the strong underlying theme was personnel error.

In the first example cited by the NRC, the "A" WTT pump discharge isolation to the Aerated Drain Tank (ADT) header and river should have been closed, but was found to be partially open. The cause of this event was personnel error in that people working in the area of this valve were unaware of plant conditions and the significance of evolutions in progress. One of these individuals accidentally bumped valve WD-V-133A, which caused the valve to open slightly. This bumping allowed water from the "A" WTT to be inadvertently released. Contributing to inis event was the failure of the shift to notice the change in the evolutions in progress.

In the second example cited by the NRC, CYAPCO failed to isolate valves on the safety injection line (SI-V-928 and SI-V-929) and on the primary water makeup line to the spent fuel pool (PW-V-108B). PW-V-108B needed to be isolated to provide system isolation to support installation of an approved modification. Two personnel errors were identified during these examples. The first personnel error was the failure of the initial

U. S. Nuclur Regulatory Commission CY-98-151/ Attachment 1/Page 5 operator to properly position the valve (s). The second personnel error was the failure of the second operator to adequately independently verify the position of the valve (s).

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In the third example cited, letdown valve LD-V-238 was required to be fully open, but

, was found to be not fully open. This valve is locally manipulated by an operator via a reach rod. In this particular situation, the valve was found to have been moved from its closed position to a partially open position. The operator in question was unaware of the number of turns required to fully open this valve, and in this particular situation, the operator turned the handwheel in the open direction until it would no longer move. The operator believed the valve was fully open. However, due to the materiel condition of the valve, and the operator being unaware of the number of turns required to open this valve, the valve was not fully opened.

As noted in our August 3,1998, meeting with the NRC and in subsequent discussions, CYAPCO is concerned about the recent configuration control and human performance  !

problems. CYAPCO is:

• Reinforcing how a proper independent verification of valve position is done; e instituting a peer check of critical configuration changes; l

e Performing an evaluation and change out, as necessary, of blocking devices to ensure devices on critical valves or breakers provide the greatest amount of protection against inadvertent movement; i

e Developing a document showing the number of valve turns needed to open r,. ; lose i critical valves, excluding 90 degree ball valves; e Assigning dedicated operators or placing physical barriers to preclude inadvertent valve bumping during certain evolutions.

Our investigations of Violations A and B as well as other events during the reactor  !

coolant system decontamination have identified improvements necessary in organizational structure, teamwork, communication and materiel condition. These i improvements are being combined with the lessons learned from the decontamination by plant departments to establish overall corrective actions. CYAPCO has announced the appointment of Mr. Ken Heider as Decommissioning Director. Mr. Heider's first objective will be to work with plant management to establish an organizational structure that will meet the future needs and resolve the identified weaknesses in the areas of organizational structure, communication and teamwork. A review of materiel conditions

'of equipment and structures needed for the remainder of the decommissioning is being undertaken to identify, prioritize and implement the improvements.

U. S. Nucinar Regulatory Commission CY-98-151/ Attachment 1/Page 6 Corrective Steps That Have Been Taken and the Results Achieved (Violation B)

The following actions have been taken as a result of the above violation:

A dedicated Operator or physical barriers are currently used, as appropriate, to preclude inadvertent valve bumping during liquid discharges.

CYAPCO has revised the procedure on independent verification to clarify expectations and ensure operators perform tagging and verification functions independently, in addition, CYAPCO has counseled the individuals involved in the mispositioning of the safety injection valves and primary water valve. All operators responsible for tagging and independent verification as well as job supervisors, contact persons or designees attended work stand down training on valve operations and tagging.

The mispositioning of the primary water valve occurred late in the midnight shift. The individuals who made the error were on their first day of work after time eff. CYAPCO has reminded managers and supervisors to ensure that people under their control are not fatigued. Individuals were reminded to advise their supervisors if they are fatigued. l

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Letdown valve ;.D-V-238 is locally manipulated by an operator via a reach rod.

CYAPCO has developed a list of purification system valves where reach rods are utilized and determined the number of valve turns required to open or close these valves.

Corrective Steps That Will Be Taken To Avoid Further Violations (Violation B)

The following actions will be taken as a result of the above violation:

Operations is evaluating critical configuration changes and systems that should have peer checks. Peer checks are reviews that are performed with two individuals. The peer individual will review the activities performed and ensure they are consistent with procedures and objectives. We are currently performing peer checks based on the judgment of the Shift Managers. The process of peer checks will be formalized and will  !

be fully instituted by December 1,1998 (CY-98-151-01).

CYAPCO has installed blocking devices on critical valves to protect against inadvertent movement. As other valves are identified for future plant evolutions, blocking devices will be installed as appropriate. By December 15,1998, an Operations Department instruction will be implemented to address the use of blocking devices on critical valves to protect against inadvertent movement (CY-98-151-02).

CYAPCO has developed a list of purification system valves where reach rods are utilized. This list provides the number of turns needed to turn the valve handwheel from full open to full closed. CYAPCO is in the process of developing a document which will

. l U. S. Nuclerr Regulatory Commission CY-98-151/ Attachment 1/Page 7 list nuclear island critical system manual valves, excluding 90 degree ball valves, and the number of valve turns required to open or close these valves. This list will be completed by December 15,1998 (CY-98-151-03).

Date When Full Compliance Will Be Achieved (Violation B)

CYAPCO is currently in full compliance.

l Reason For The Violation (Violation C) i i Flow element FE-1101 is a pitot-venturi located in the ductwork on the Primary Auxiliary.

Building (PAB) roof which runs to the plant stack. This flow element is part of an instrument channel that indicates and records the total flow to the stack on a panel in the PAB and is required by the Technical Specifications. The pitot-venturiis part of the ,

l original plant design. It is capable of measuring flows from 0 CFM to 87,108 CFM. The i pitot-venturi amplifies the differential pressure between the static and total pressure that would be otherwise observed if using a standard pitot-static tube. This characteristic is

desirable in low flow conditions. The amplification factor makes it necessary to use j vendor provided data to determine the velocity from the amplified differential pressure.

A graph is located at the PAB panel which is based on the vendor data and allows volumetric flow rate to be determined based on the pressure indicated on flow indicator

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HIC-1101. The pitot-venturi does not average the entire flow through the duct. 1 Therefore, it is positioned within the duct at a point that is representative of the average j flow through the duct. A review of the surveillance procedure which calibrates this l instrument channel revealed that the procedure does not require performance of a L periodic verification of the calibration curve of the pitot - venturi flow element.

The apparent causes for the inadequacies of total stack flow channel F-1101 are as follows

! First, the original installation was based on lower flow rates than are present today.

This is a result of the 1974 modification which replaced the PAB/ Purge Fans with larger

units. The second cause is that the velocity to differential pressure relationship of the pitot - venturi has not been periodically re-verified. Finally, CYAPCO personnel had an l

inadequate understanding of system design, operational and calibration requirements for this system. l l

Corrective Steps That Have Been Taken and the Results Achieved (Violation C) i l

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The immediate corrective action was to declare the F-1101 channel out of service and develop a means of estimating flow every four hours as required by the Technical

- Specification Table 3.3-10.

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CY-98-151/ Attachment 1/Page 8 l On May 22,1998, flow data was collected to determine the velocity profile and total flow at FE-1101 with one and two PAB/ Purge Fan operation. This information has been used to evaluate channel F-1101.

Since July 10,1998, temporary instruments have been used to measure total stack flow every four hours. This method of measuring flow will be used until the long term solution is implemented. l Corrective Steps That Will Be Taken To Avoid Further Violations (Violation C)

The existing flow element FE-1101 will be recalibrated or replaced so that total stack flow is accurately displayed on the PAB panel (CY-98-089-02).

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Historical release data will be reviewed and the impact of using default flow values will j be assessed. This review will also incorporate any findings that are made regarding l isokinetic flow and particulate plate - out in the sample lines of the radiation monitoring system. The results of this review will be forwarded in a supplemental LER (CY-98-089-01).

The Oversight organization is verifying all portions of License Amendment 125 (i.e.,

conversion to Standard Technical Specification format and definitions) that remain in effect as amended by License Amendment 193 (i.e., defueled Technical j Specifications). To accomplish this effort, CYAPCO will use the Oversight organization to verify that for each technical specification surveillance requirement that the existing procedure (s) adequately perform (s) the activity required by the technical specifications (CY-98-151-04).

Date When Full Compliance Will Be Achieved (Violation C)

Corrective actions associated with the above will be completed by January 31,1999.

Reason For The Violation (Violation D)

The preparation of the license amendment submittal letter for the defueled technical specifications contained the statement that " limited make-up water to the fuel pool could be provided by gravity feed". The limited capability was available by gravity feed only if the refueling water storage tank (RWST) was nearly full. Lower water levels in the spent fuel pool would allow more of the water in the RWST to gravity feed. While this gravity feed capability was a feasible alternative through a valve alignment, the primary method of transfer during a loss of normal power was repowering the primary water pumps and using the normal makeup source or pumping water from the RWST using the purification pump. Another " backup" source was and still is river water via a diesel engine driven pump in the fire water system.

U. S. Nuclecr Regulatory Commission CY-98-151/ Attachment 1/Page 9 The cause of the violation was a personnel error on the part of the individual who l

developed the letter to the NRC. The individual who developed this letter to the NRC inserted this statement in an attempt to show that multiple fuel pool makeup capabilities l were provided to compensate for evaporative losses during an extended loss of offsite l

power event. CYAPCO should not have included this statement about gravity feeding  ;

from the RWST in our May 30,1997 letter to the NRC. l l

The normal makeup source is the Primary Water Storage Tank using primary water l pumps. Current backup sources include 1) use of a gasoline engine driven pump that supplies water from the seismic Demineralized Water Storage Tank and 2) river water via the fire water system using a diesel driven pump.

l The plant procedure for processing outgoing correspondence with regulatory agencies i requires the Licensing Coordinator to work with the Lead Functional Manager to develop the correspondence and resolve comments. The Lead Functional Manager is, {

q by procedure, technically responsible for the accuracy of the letter. In this case, the additional statement regarding the ability to gravity feed make-up water to the spent fuel pool was inserted after the Lead Functional Manager had approved the letter.

Corrective Steps That Have Been Taken and the Results Achieved (Violation D)

CYAPCO submitted a letter to the NRC on July 30,1998Nwhich provided clarifying information on the spent fuel pool makeup capability at the Haddam Neck Plant. In addition, the individual who developed the May 30,1997, letter to the NRC that contained the incorrect information is no longer working at the Haddam Neck Plant.

I The Licensing Manager reviewed this violation with the Licensing Department staff and reinforced the requirements to follow the existing process for developing outgoing l correspondence.

Corrective Steps That Will Be Taken To Avoid Further Violations (Violation D)

None Date When Full Compliance Will Be Achieved (Violation D)

CYAPCO is currently in full compliance with 10CFR50.9(a).

- (1) CYAPCO letter CY-98-127 to U.S. Nuclear Regulatory Commission, "Information on Spent Fuel Pool Makeup Capability," dated July 30,1998, s r- ye m- -yi g -- --- ,em, es*

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Attachment 2  !

Haddam Neck Plant

- Identification of Commitments 1

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L September 1998 l

t U. S. Nucle r Regulatory Commission CY-98-151/ Attachment 2/Page 1 l

The following are the commitments contained within this letter. Other statements contained within this letter are provided for information only.

CY-98-i21-04 Reporting procedures will be reviewed and revised, as appropriate, to ensure clear guidance is provided. These improvements will be completed by December 15,1998.

CY-98-151-01 The process of peer checks will be fully implemented by December 1,1998.

CY-98-151-02 By December 15,1998, an Operations Department Instruction will be developed to address the issue of blocking devices on critical i valves to protect against inadvertent movement. l I

CY-98-151-03 CYAPCO is in the process of developing a document which will list l nuclear island critical system manual valves, excluding 90 degree ball valves, and the number of valve turns required to open or close I these valves. This list will be completed by December 15,1998.

l CY-98-089-02 The existing flow element FE-1101 will be recalibrated or replaced so that total stack flow is accurately displayed on the PAB panel by January 31,1999.

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CY-98-089-01 Historical release data will be reviewed and the impact of using default flow values will be assessed. This review will also incorporate any findings that are made regarding isokinetic flow and particulate plate - out in the sample lines of the radiation monitoring system. The results of this review will be forwarded in a

, supplemental LER.

CY-98-151-04 The Oversight organization is verifying all portions of License Amendment 125 that remain in effect as amended by License Amendment 193. CYAPCO has begun to independently verify that i

plant procedures address the surveillance requirements using l Amendment 193 of the Technical Specifications as the basis. This

! will be completed by November 30,1998.

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