IR 05000213/1986017

Discusses Safety Insp Repts 50-213/86-17 & 50-213/86-22 on 860616-20 & 0722-25 & Forwards Notice of Violation & Proposed Imposition of Civil Penalties.Region I Will Closely Monitor Fire Protection & Radiation Protection Programs

ML20211M314
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/10/1986
From:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO.
Shared Package
ML20211M319	List: IR 05000213/1986017 ML20211M332
References
EA-86-167, NUDOCS 8612170113
Download: ML20211M314 (5)

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h6 DEC 101986 Docket No. 50-213 License No. DPR-61 EA 86-167 Connecticut Yankee Atomic Power Company ATTN: Mr. J. F. Opeka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06101 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (Inspection Report Nos. 50-213/86-17; 50-213/86-22)

This refers to the NRC safety inspections conducted on June 16-20 and July 22-25, 1986 of activities authorized by NRC License No. DPR-61 at the Haddam Neck Nuclear Power Plant. During the inspections, violations of NRC require-ments were identified and the reports of the inspections were forwarded to you on August 1 and August 19, 1986. The first inspection was conoucted to review implementation of the requirements set forth in Appendix R to 10 CFR Part 50

, for assuring the safe shutdown capability of the plant in the event of a fir The second inspection was conducted to review implementation of the radiation protection program, and in particular, the circumstances associated with an occupational whole body radiation exposure in excess of the regulatory limit received by one of your workers during the third calendar quarter of 1986. The unplanned radiation exposure was identified by a member of your staff and re-ported to the NRC. On September 3, 1986, enforcement conferences were held with Mr. E. Mroczka and other members of your staff to discuss the violations associated with both programs, the causes, and your corrective action The violations associated with the radiation protection program and the fire protection program are being transmitted together via this letter to emphasize the NRC belief that the violations are, in part, symptomatic of the same underlying problem. Specifically, the NRC believes there is a need for (1)

( greater corporate involvement in providing guidance, support and oversight of

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site activities, and (2) more effective interface between corporate and site personne With regard to the radiation protection program, the violations are of signiff-cant concern to the NRC because they involved performance deficiencies and inattention to detail at several levels within the organizatio For example, the individual who received the overexposure, while performing maintenance on a steam generator during a recent outage, performed work on the steam generator without having read or initialled the associated Radiation Work Permit as CERTIFIED MAIL RETURN RECEIPT REQUESTED OFFICIAL RECORD COPY CP PKG HADDAM NECK REV 4 - 0001. e61210 12/05/86 PDR ADOCK 05000213 O PDR

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Connecticut Yankee Atomic -2-Power Company required. While performing those activities, which included four half-body entries into the generator channel head, where radiation levels were between 20 and 30 R/hr, Senior Health Physics (HP) technicians failed to provide adequate control and direct surveillance of work activitie Further, site management apparently did not adequately verify the qualifications of this HP technician and other HP technicians to assure that they understood their duties, including expected techniques for control of work activities and calculation of stay times in radiation fields with high gradients, nor did site management provide sufficient periodic surveillance of technician activities to verify proper performance or to identify and correct performance deficiencie In addition to these deficiencies by site personnel, the history of radiation protection problems at Haddam Neck suggests that corporate personnel have not been sufficiently involved or effective in providing guidance, support and oversight of site activitie In this instance, our discussions at the enforcement conference clearly indicated that neither the site nor corporate staff had sufficiently analyzed the event to establish its causes or to de-velop appropriate corrective actions. The historical inadequacies in corporate staff oversight of site activities are most recently evidenced by this inci-dent, by the Severity Level IV transportation violations identified earlier this year and discussed during a June 18, 1986 enforcement conference, and by a Severity Level III violation involving a near overexposure in October,1984 to an individual who was also performing work on a steam generator during the previous outag These deficiencies at various organizational levels demonstrate that (1) work-ers and HP personnel must have a better understanding of their roles and of HP practices and procedures, and must pay greater attention to detail in perform-ing their duties; (2) site management must be accountable for appropriately assessing personnel qualifications to perform tasks before they are assigned, and for providing periodic direct surveillance of personnel performance to ensure that the radiation protection program is properly implemented; (3)

corporate personnel must become more aggressively involved in providing sup-port, guidance and oversight of site radiation protection activities; and (4)

the interface between site and corporate personnel must improve to assure that activities at the site are conducted safely and that performance deficiencies

.are identified, appropriately analyzed for cause, and resolved in a timely and effective manne The need for enhanced corporate performance and more effective corporate / site interface was also evident to the NRC during the inspection of the fire pro-tection program. For examcle, in calculating the amount of water needed to safely shut down the reactor in the event of the loss of the atmospheric dump valves due to a fire, a faulty assumption was made concerning the piping con-figuration, and a corporate reviewer did not detect the error. As a result, the calculated amount was lower than tne amount actually neede In addition, test results of the Halon system installed in the control room for fire protec-tion purposes were not adequately analyzed and reviewed by corporate engineers in that, although the tests showed that under certain conditions the system would not provide the concentration of Halon committed to in a letter to the NRC, this deficiency was not identified and correcte OFFICIAL RECORD COPY CP PKG HADDAM NECK REV 4 - 0002. /05/86

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Connecticut Yankee Atomic -3-Power Company To emphasize the need for improved performance by, and more effective interface between, site and corporate personnel, I have been authorized, after consulta-tion with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of Fifty Thousand Dollars ($50,000) for the violations described in Section I of the enclosed Notice. Although Violation I.A involving the exposure in excess of the regulatory limit could itself be classified at Severity Level III in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986),

the violations set forth in Section I have been categorized in the aggregate as a Severity Level III problem to focus on the underlying deficiencies. The base civil penalty for a Severity Level III violation or problem is $50,00 Although the NRC recognizes that you identified and reported the exposure, any mitigation of the civil penalty amount is considered inappropriate in view of the previous radiation protection problems identified in the past two years, in particular, the near overexposure in October 1984. In addition, even though you took disciplinary actions against the two senior HP technicians, we do not consider your corrective action to be prompt and extensive since neither the site nor corporate staff had sufficiently analyzed the event in a timely manner to establish its causes or to develop other appropriate corrective actions. The fire protection violations, which are set forth in Section II of the Notice, are of lesser significance and have been classified at Severity Level IV or Nonetheless, we view the causes of these violations as serious and require additional management attention to assure similar violations do not occu In addition to the proposed civil penalties, Region I plans to closely monitor both the fire protection and radiation protection programs at Haddam Nec Further, during the next refueling outage, Region I will conduct a comprehen-sive appraisal of the radiation protection program to better understand the nature and extent of the program deficiencies. The appraisal will include, but not be limited to, assessments of (1) the effectiveness of the training program in preparing workers and HP personnel to perform their tasks; (2) the clarity and specificity of radiation protection procedures used to assist workers and HP personnel; (3) the level of involvement by supervisors and managers in verifying qualifications of HP personnel and in monitoring personnel perfor-mance; and (4) the relationship between corporate and site HP personnel, in-cluding the effectiveness of corporate HP personnel in providing guidance, support and oversight of site activities, and in identifying performance deficiencies, analyzing their causes, and assuring timely and effective corrective actio In your response to the enclosed Notice, which you are required to respond to using the instructions specified therein, you should document the specific actions taken and any additional action you plan to improve performance by, and interface between, site and corporate personnel. After reviewing your response to the Notice, including your proposed corrective actions, the NRC will deter-mine whether further enforcement action is necessary to ensure compliance with NRC regulatory requirement OFFICIAL RECORD COPY CP PKG HADDAM NECK REV 4 - 0003. /05/86

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Connecticut Yankee Atomic -4-Power Company In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, PL 96-51 Sincerel Thomas E. Murley Regional Administrator Enclosure: Notice of Violation and Proposed Imposition of Civil Penalties cc:

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 Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of Connecticut

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OFFICIAL RECORD COPY CP PKG HADDAM NECK REV 4 - 0004. /05/86

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Connecticut Yankee Atomic -5-Power Company bec w/ enc 1:

' Region I Docket Room (with concurrences)

SECY CA J. Taylor, IE J. Axelrad, IE T. Murley, RI H. Denton, NRR D. Holody, RI J. Lieberman, OGC V. Stello, EDO J. Sniezek, DED/ROGR Enforcement Directors RII-III Enforcement Officers RIV-RV F. Ingram, PA J. Crooks, AE0D B. Hayes, 01 S. Connelly, OIA D. Nussbaumer, OSP IE/ES File IE/EA File EDP Rdg File DCS Office of State Programs

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