IR 05000213/1996004
| ML20129D780 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/18/1996 |
| From: | Rogge J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Feigenbaum T NORTHEAST UTILITIES SERVICE CO. |
| References | |
| NUDOCS 9609300188 | |
| Download: ML20129D780 (3) | |
Text
SUBJECT:
NRC INSPECTION REPORT 50-213/96-04
Dear Mr. Felgenbaum:
This letter refers to your August 24,1996 correspondence, in response to our July 22, 1996 letter.
Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your license program.
Your cooperation with us is appreciated.
Sincerely, ORIGINAL SIGNED BY:
John F. Rogge, Chief Projects Branch 8 M0111 Division of Reactor Projects i
Docket No. 50-213 cc:
B. D. Kenyon, President - Nuclear Group D. B. Miller Jr., Senior Vice President - Nuclear Safety and Oversight E. A. DeBarba, Vice President - Nuclear Technical Services F. C. Rothen, Vice President - Nuclear Work Services S. E. Scace, Vice President - Nuclear Reengineering Implementation J. J. LaPlatney, Haddam Neck Unit Director L. M. Cuoco, Senior Nuclear Counsel A. M. Callendrello, Licensing Manager - Haddam Neck H. F. Haynes, Director - Nuclear Training J. F. Smith, Manager, Operator Training N. S. Reynolds, Esquire h
[t I W. D. Meinert, Nuclear Engineer 9609300188 960918 PDR ADOCK 05000213 G
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Mr. T. C. Feigenbaum
cc w/cv of licensee response ltr:
State of Connecticut SLO l
D. Screnci, PAO NRC Resident inspector i
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Mr. T. C. Feigenbaum
Distribution:
J. Rogge, DRP M. Conner, DRP D. Bearde, DRP Nuclear Safety Information Center (NSIC)
PUBLIC Region 1 Docket Room (with concurrences)
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DOCUMENT NAME: G:\\ BRANCH 8\\HN\\96-04.RPY To recahre a copy of this document, Indicate in the bos: "C" = Copy without attachment / enclosure
- E" = Copy with attachment / enclosure
- N" = No copy 0FFICE RI/DRP l
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NAME WJRAYMOND 4f'
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DATE 08/ /96 0F/g,h/96
0FFICIAL RECORD COPY
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P P.O. Box 270 Hartford, CT 06 41-0270 (203) 665-5000 A[G 2 l l996 Docket No. 50-213 B15 8 5.5.
Re:
10CFR2.201 U.
S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Haddam Neck Plant Reply to a Notice of Violation NRC Inspection Report No. 50-213/96-04 In a letter dated July 22, 1996,# the NRC Staff transmitted to Connecticut Yankee Atomic Power Company (CYAPCO) Inspection Report No.
50-213/96-04.
As discussed in the report, the NRC Staff cited CYAPCO
'otice of for a Notice of Violation, Severity Level IV and a N
Deviation.
In its letter, the NRC Staff requested that CYAPCO respond to the Notice of Violation and Notice of Deviation within 30 days of the letter.
Pursuant to 10CFR2.201, Attachment 1 hereby provides CYAPCO's response to the subject Notice of Violation.
Attachment 2 hereby provides CYAPCO's response to the subject Notice of Deviation.
l The following are CYAPCO's commitments made within this letter.
Othec statements within this letter are provided as information only.
B15855-1:
An approved safety evaluation and a change to the UFSAR is being processed to make the licensing basis documents consistent, specifying that fuel within the spent fuel pool will be moved with 7 feet minimum of submergence. This UFSAR change will be processed by December 31, 1996 and be i
included in Revision 10 to the UFSAR.
B15855-2:
A comprehensive review of the safety evaluation which was performed to initiate this fuel transfer evolution will be completed.
This review will be completed by October 31, 1996.
(1)
John F.
Rogge letter to T.
C.
Feigenbaum,
"NRC Integrated
Inspection Report
50-213/96-04
and Notices of Violation and
Deviation", dated July 22, 1996.
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B15855/Page 2
B15855-3:
ACM 2.2-9 " Control of Crane Operations" is being revised to
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include physical qualification of the crane operators. The
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Maintenance Department will revise the OJT
(On-The-Job-
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Training)
Guide
to
require
verification
of
physical
qualifications.
These
changes
will
be
completed
by
September 30, 1996.
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B15855-4:
WCM
2.2-7,
"PAB/ Pipe Trench Floor Block Lif ting Procedure"
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is being revised to designate the use of standard rigging
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components instead of the lift rig when lif ting the floor
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blocks.
This revision will be completed by October 31,
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1996.
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If you should have any questions on the information contained herein,
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please contact Mr.
E.
P.
Perkins, Jr. at (860) 267-3938.
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Very truly yours,
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CONNECTICUT YANKEE ATOMIC POWER COMPANY
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Executive V ce President and
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Chief Nuclear Officer
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H. J. Miller, Region I Administrator
S. Dembek, NRC Project Manager, Haddam Neck Plant
W. J. Raymond, Senior Resident Inspector, Haddam Neck Plant
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Docket No. 50-213
B15855
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Attachment 1
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Haddam Neck Plant
Reply to a Notice of Violation
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NRC Inspection Report No. 96-04
August 1996
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Attachment 1
Haddam Neck Plant
Reply to a Notice of Violation
NRC Inspection Report No. 96-04
Restatamant of Violation
10 CFR 50.59 states that the licensee may change the facility as
described in the final safety analysis report,
provided the
licensee
maintains
a
written
safety
evaluation
(SE)
which
provides the basis for the dete:mination that the change does not
involve an unreviewed safety question (USQ).
The Updated Final
Safety Analysis Report
(UFSAR}
Sections
15.5.2.2
and
9.1.4.2
states that the spent fuel hancing equipment assures a minimum of
eight feet submergence during fuel movement in the pool.
Section 9.1.4.2 states that the fuel handling and transfer system
consists
of
equipment
and
tools
necessary
for
performing
refueling operations in a safe and efficient manner, including
the transferring of fuel assemblies to the spent fuel pit.
Contrary to the above, no written SE or an inadequate SE was
maintained, in that
1.
The licensee conducted refueling activities prior to May 1,
1996, with a fuel handling tool providing less than eight
feet of fuel submergence.
This condition was a defacto
change
to
the
facility as
described
in. UFSAR Section
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15.5.2.2 and
9.1. 4. 2,
for which the licensee had no SE or
documented basis to show that the change was not a USQ.
2.
The licensee modified the fuel handling tool for the North
Spent Fuel Building crane on May 2 by adding a sling to
increase the length of the hoist-tool configuration by one
foot. The SE dated May
2,
1996 for the sling modification
was inadequate, in that it did not address the effeet of the
change
on
the
normal
operation
of
the
fuel
handling
equipment for the safe handling and storage of spent fuel.
The
modified
fuel
handling
tool,
in
part,
caused
an
irradiated fuel assembly suspended from the spent fuel
building hoist to be incapable of safe storage for 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />.
This is a Severity Level IV Violation (Supplement I).
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Issue 1
By letter dated August
4,
1989, Connecticut Yankee Atomic Power
Company
(CYAPCO)
submitted a proposed revision to technical
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U.
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B15855/ Attachment 1/Page 2
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specification 3.9.11, which changed the required level of 21 feet
of water over the top of irradiated fuel assemblies in the fuel
pool to 20 feet.*
Specifically, this change was requested to
remove a concern over corrosion of the sluice gate air cylinder
which was submerged in horated water with the water level at 21
feet.
The
submittal's
finding
of
No
Significant
Hazards
addressed the radiation concern from the lowered level and stated
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that it was well within the requirements of Regulatory Guide 1.25,
Revision 2.
The pool level was lowered following receipt
of the approved license amendment.
The effective water level was
now approximately 20 feet above stored fuel assemblies and 7 feet
above the top of fuel during transit. The processing of this
technical
specification change
did not
specifically address
impact on the UFSAR.
Subsequent
revisions of the company
procedure, which guided changes to the technical specifications,
required documentation of whether the proposed change would
affect information in the UFSAR.
Fuel transfer activities have
been conducted since 1990
in accordan'ce with the technical
specifications, but contrary to the condition described in the
No safety evaluation was performed to incorporate the
pool level change into the UFSAR.
On May 1,
1996, while a fuel assembly move was being planned, the
responsible engineers inquired as to whether the move would
maintain the UFSAR required height of 8 feet of water over the
top of the assembly during transit.
Measurements were made to
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determine the actual minimum depth.
The fuel pool level was
consistent with the current technical specifications, maintaining
the submerged value of 20 feet for the racked assembly.
However,
the pool level above the assembly was measured to be less than
the 8 feet specified in the UFSAR.
An Adverse Condition Report
(ACR) was written identifying this discrepancy.
The focus of the
action taken was to perform a safety evaluation to add a sling
extension to tge fuel handling crane hook to assure that
current
and future fuel transfers occurred with the UFSAR stated 8 feet
of submergence.
1.
Raamon for the Violation
This violation stated that a defacto change to the facility
as described in the UFSAR had been made without a critten
safety evaluation.
The reason for the violation vas an
inadequate
process
for
changing
the
Tecanical
Specifications, in that it did not require a review of the
(2)
E.
J.
Mroczka letter to the U.
S. Nuclear Regulatory
Commission, " Proposed Revision to Technical Specifications Sections 3.6.2, 3.9.11 and 3.9.12 of the Revised Technical
Specifications" dated August 4,
1989.
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U.
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B15855/ Attachment 1/page 3
UFSAR for potential associated changes.
Subsequent changes
to operational procedures governing fuel transfer in the
fuel pool did not identify that a UFSAR revision and a
supporting safety evaluation were required.
The processing
of the related proposed technical specification change did
not address potential impact on the UFSAR.
While technical specification section 3.9.11 had been approved in 1990, with
a water depth of 20 feet rather than the previous value of
feet,
the
inconsistency
between
licensing
basis
documentation continued to exist.
It is not clear why the
difference between the actual plant configuration, including
the crane, the spent fuel handling tool, and spent fuel pool
water level and the discussion within the Updated Final
Safety Analysis Report
(UFSAR)
continued to exist.
In
addition, the specific technical basis for the eight feet of
submergence stated in UFSAR Sections 9.1.*
2 and 15.5.2.2 of
the UFSAR is not specifically identified since the analyses
addressed
only
the
total
subme'rgence
requirements
of
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UFSAR Section 9.1.4.2 states, "The handling and transfer of
all irradiated fuel assemblies and control rod clusters are
performed under water to provide continuous cooling and the
necessary radiation protection for personnel.
During all
handling
operations
the
design
of
the
equipment
and
structures result in handling of assemblies under a minimum
of 8 fe st of water."
It has been demonstrated that with
less than the stated eight feet of submergence, adequate
radiation protection and cooling has been maintained.
This
discrepancy was discovered through a questioning attitude,
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and then proper administrative actions were taken to address
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the concern.
2.
CQIIActive Steps
that have been taken and the resui 3
achieved
The corrective action taken at the time of the recognition
of the discrepancy was to comply with the more conservative
requirements of the UFSAR.
Engineering personnel performed
a safety evaluation and installed a sling between the crane
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hook and the spent fuel handling tool bale to allow transfer
of the fuel assembly, while maintaining the UFSAR specified
value of 8 feet of water cover.
When it was discovered that
the normal operation of the crane was adversely impacted by
the sling extension,
a subsequent safety evaluation was
performed which demonstrated the acceptability of moving
fuel with a minimum of 7 feet of submergence.
This safety
evaluation was approved based upon detailed radiological
surveys.
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B15855/ Attachment 1/Page 4
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The corrective action needed to address the condition which
existed at the time of the technical specification change,
i.e.,
inadequate
routing
sheets which did not
clearly
require
an assessment
of
the
impact
of
any technical
specification
change
on
the
had
already
been
corrected
through
modification
of
the
procedure
which
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directs
technical
specification
changes.
The
current
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version
of
the
procedure
for
proposed
technical
specification changes includes a cover sheet that requires a
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review for potential changes to the UFSAR.
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3.
Corrective
Steps
that will be
taken
to avoid
further
Violations
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An approved safety evaluation and a change to the UFSAR is
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being processed to make
the
licensing basis
documents
consistent, specifying that fuel within the spent fuel pool
will be moved with 7 feet minimum of submergence. This UFSAR
change will
be processed by December
31,
1996 and be
included in Revision 10 to the UFSAR. (Commitment B15855-1)
This action addresses the differences between the plant
configuration and that described within the UFSAR and will
be included in the next UFSAR revision.
This change will
also be documented as part of the Configuration Management
Program.
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The generic issue of assuring that changes made to the
technical specifications are incorporated into all licensing
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basis documents is being addressed by the Configuration
Management Program which is scheduled for completion in
December
1997.
This
program
involves
an
extensive
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reconstruction and documentation of the licensing and design
basis for the Haddam Neck Plant.
4.
DAte when full en=nliance will be achieved
Full. compliance was met on May 29, 1996.
Issue 2
Background
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As part of
the
fuel
assembly transfer evolution,
a
safety
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evaluation was performed to allow a sling extension to be used to
assure. that the minimum submergence of 8 feet was maintained.
This safety evaluation focused on the use of
a sling and
concluded it did not introduce an unreviewed safety question.
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U. S.-Nuclear Regulatory Commission
B15855/ Attachment 1/Page 5
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However,
it did not give sufficient attention to the actual
mechanical and electrical operation of the crane.
When the crane
lift mechanism would not reset,
an investigation into crane
operation was conducted.
An adverse condition report and a root
cause investigation was performed.
This investigation identified
the concern that the safety evaluation did not address the
possible impact of the use of the sling on the operation of the
crane.
Corrective actions were issued to address mechanical,
electrical, and documentation aspects of crane operation.
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1.
Reason for the Violation
The violation addresses a concern over the adequacy of
safety evaluations performed by CYAPCO personnel.
The focus
of the safety evaluation was how to facilitate the fuel
assembly transfer using an extension device which would
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assure that the minimum submergence was maintained rather
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than a comprehensive look at the overall fuel transfer
process.
Inadequate knowledge of the crane travel and reset
mechanisms led to suspension of the fuel assembly in an
unsecured condition.
The root cause investigation, while
focusing on the mechanical operation of the crane,
did
identify the fact that the safety evaluation did not address
the possible impact of the use of the sling on the operation
of the crane.
This investigation determined that the root cause of the
inability of the hoist to move in the upward direction was
due to the crane not traveling down far enough to reset the
gear limit switch.
The crane has a geared limit switch that
is activated when the crane is in the full up position.
This limit switch does not reset until the crane has
traveled downward 15 inches.
This fact was unknown by
CYAPCO until measured on May 28, 1996, after the event in
question.
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Lack of indexing between the rack cell and the fuel assembly
used to assist the operator in the aligning of the fuel
assembly with the storage cell was considered a contributing
cause.
Indexing could not accurately be performed until the
completion of the Spent Fuel Pool Rerack so that final as-
built positions of the racks are known.
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During this event, the crane and load cell of the crane
operated as designed and the crane was being operated
ccriectly.
The environmental conditions (clarity, lighting,
etc.) were determined to be acceptable.
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U.
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B15855/ Attachment 1/Page 6
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2.
Corrective Steps that have been taken and the results
achieved
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The corrective action taken at the time of the event was to
remove the space sling that was between the crane !.cok and
the spent fuel handling tool bale.
A separate safety
evaluation
was
completed
and
approved
based
upon
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radiological
surveys demonstrating
the acceptability of
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moving fuel with a minimum of 7 feet of submergence.
The
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fuel assembly was transferred to safe storage following
removal of the extension sling.
3.
Corrective
Steps
that will
be
taken to avoid
further
violations
A comprehensive review of the safety evaluation prepared to
initiate this fuel transfer evolution will be performed.
This review will be completed by October 31, 1996.
(Commitment B15855-2)
4.
Date when full en=nliance will be achieved
Full compliance was met on May 29, 1996.
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Docket No. 50-213
B15855
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Attachment 2
Haddam Neck Plant
Reply to a Notice of Deviation
NRC Inspection Report No. 96-04
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August 1996
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Attachment 2
Haddam Neck Plant
Reply to a Notice of Deviation
NRC Inspection Report No. 96-04
Restatement of Deviation
Technical evaluation report section
2.1.4,
" Crane Operator Training,"
stated that the licensee took no exceptions to Guideline 3 of ANSI
B30.2-1976Property "ANSI code" (as page type) with input value "ANSI</br></br>B30.2-1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. with respect to operator training and qualifications.
By
letters dated July 20, 1981 and April 16, 1982, the licensee took no
exceptions to the standard.
Guideline 3 stated that crane operators
should be trained and qualified in accordance with Chapter 2-3 of ANSI
B30.2-1976Property "ANSI code" (as page type) with input value "ANSI</br></br>B30.2-1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., " Overhead and Gantry Cranes."
Technical evaluation report section
2.1.5,
"Special Lift ' Devices,"
stated that the licensee performs visual inspections prior to use and
is developing a systematic program of NDE inspections of critical
welds over a 10-year period.
By letter dated June 29,
1984, the
licensee stated that lifting devices are visually inspected prior to
each refueling or use, and that nondestructive testing will be done on
the lifting devices on a ten-year cycle.
One identified special lift
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device was the primary auxiliary building hook block lift rig.
Contrary
to
the
above,
the
licensee
failed
to
implement
two
commitments regarding control of heavy loads, in that
1.
On May 23, 1996, the licensee identified that an individual was
not physically qualified to the standards of chapter 2-3 of ANSI
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B30.2-1976 even though recorded as a qualified crane operator.
Further, the physical examinations performed or crane operators
did not specifically identify physical qualifica ion standards of
ANSI B30.2-1976 section 2-3.1.2.
2.
On April
9,
1996,
the licensee identified that the primary
auxiliary building hook block lift ring was not included in
procedure PNP 9.5-131,
"Special Lif ting Device Inspection and/or
Load Testing" revision
6.
The primary auxiliary building hook
block lift rig had not undergone any 10-year NDE inspection.
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Nuclear Regulatory Commission
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B15855/ Attachment 2/Page 2
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Item i
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1.
Reason For The Deviation
The reason for the deviation was that CYAPCO did not effectively
track or control commitments related to crane operator medical
requirements.
2.
Corrective Steps That Have Been Taken And The Results Achieved
Crane operators were evaluated for medical compliance to ANSI
B30.2-1976Property "ANSI code" (as page type) with input value "ANSI</br></br>B30.2-1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Eight people were
found not to be physically
qualified and removed from crane operator duties.
The Medical
Department established a data base to identify those Northeast
Utilities employees that are crane operators.
Examinations will
be given every other year.
3.
Corrective steps That Will Be Taken To Avoid Further Deviations
WCM
2.2-9
" Control of Crane Operations" is being revised to
include
physical
qualification of
the
crane
operators.
The
Maintenance Department will revise the OJT (On-The-Job-Training)
Guide to require verification of physical qualifications.
These
changes will be completed by September
30,
1996.
(Commitment
B15855-3)
The
generic
issue
of
commitment
identification
and control
process is being evaluated and documented by the Configuration
Management Program.
This is a comprehensive review of the design
and licensing bases of the Haddam Neck Plant and is scheduled for
completion by December 1997.
4.
Date When corrective Action Will Be Completed.
CYAPCO is currently in full compliance since all designated crane
operators meet the physical qualifications of ANSI B30.201976.
The changes being made to Procedure WCM 2.2-9 " Control of Crane
operations" will assure continued compliance.
Item 2
1.
Reason For The Deviation
The reason for the deviation was that CYAPCO did not effectively
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track or control commitments related to inspection of special
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lifting devices prior to use.
It
is not
clear that
the
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B15855/ Attachment 2/Page 3
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commitment
was
initially
captured
and
incorporated
into
a
controlled document.
Additionally, there was a lack of attention
to detail in the procedure change process as well as in the
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procedure review and use process prior to performing work.
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2.
corrective steps That Have Been Taken And The Results Achieved
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The PAB floor slab lift rig has been tagged " Caution - Do Not
Use."
Dedicated standard rigging components will be used for
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future lifts which conform to ANSI B30.9 per MA9.5-30.
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3.
Corrective Steps That Will Be Taken To Avoid Further Deviations
The
commitment
identification and
control
process
is
being
,
evaluated
and
documented
with
the
Configuration
Management
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Program.
This is a comprehensive review of the design and
licensing bases of the Haddam Neck Plant and is scheduled for
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completion by December 1997.
Specific attention has been given to procedures which address
inspection of special lifting devices.
WCM
2.2-7,
"PAB/ Pipe
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Trench Floor Block Lifting
Procedure"
is
being
revised
to
designate the use of standard rigging components instead of the
lift rig when lif ting the floor blocks.
This revision will be
completed by October 31, 1996. (Commitment B15855-4)
The old lift rigs will be removed from service.
4.
Date When Corrective Action Will Be Comoleted.
CYAPCO is currently in full compliance.
The other special
lifting devices are in full compliance with NUREG-0612.
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