IR 05000213/1996011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp 50-213/96-11.Exam of Actions Will Be Done During Future Insp

ML20136F150
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	03/07/1997
From:	Rogge J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Feigenbaum T NORTHEAST UTILITIES SERVICE CO.
References
NUDOCS 9703140009
Download: ML20136F150 (2)

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e March 7, 1997

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Mr. Ted Executive Vice President and Chief Nuclear Officer Northeast Utilities Service Company c/o Mr. Terry L. Harpster P.O. Box 128 Waterford, CT 06385 SUBJECT: INSPECTION REPORT NO. 50-213/96-11 AND NOTICE OF VIOLATION

Dear Mr. Feigenbaum:

This letter refers to your February 13,1997 correspondence, in response to our

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December 24,1996 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 licensed program.

Your cooperation with us is appreciated.

Sincerely,

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Original Signed By:

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John F. Rogge, Chief l

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Projects Branch 8

, Division of Reactor Projects j Docket No. 50-213

cc: w/o cv of Licensee's Resoonse Letter B. D. Kenyon, President - Nuclear Group D. M. Goebel Vice President - Nuclear Oversight J. K. Thayer, Vice President - Recovery Officer, Nuclear Engineering and Support F. C. Rothen, Vice President - Work Services J. J. LaPlatney, Haddam Neck Unit Director )

L. M. Cuoco, Senior Nuclear Counsel '

, G. P. van Noordennen, Manager, Nuclear Licensing H. F. Haynes, Director - Nuclear Training

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J. F. Smith, Manager, Operator Training cc: w/cv of Licensee's Response Letter  !

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R. Bassilakis, Citizens Awareness Network gQ \

J. M. Block, Attorney for CAN y J. P. Brooks, CT Attorney Gencrals Office  %,g State of Connecticut SLO /

9703140009 970307 PDR ADOCK 05000213 '

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Distribution w/cv of Licensee Resoonse Letter Region I Docket Room (with concurrences)

l Nuclear Safety Information Center (NSIC)

PUBLIC l

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NRC Resident inspector i D. Screnci, PAO J. Rogge, DRP M. Conner, DRP C. O'Daniell, DRP

W. Dean, OEDO i

M. Callahan, OCA P. McKee, NRR/PD l-4

. M. Fairtile, NRR S. Dembek, NRR

! R. Jones, NRR R. Correia, NRR

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D. Taylor, NRR I inspection Program Branch, NRR (IPAS)

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DOCUMENT NAME: G:\ BRANCH 7\REPLYLTR\HN9611.RPY Ta receive a copy of this docurnent, indicate in the box: "C' = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N* = No copy OFFICE Rl/DRP / /

NAME JRogge/ceo DATE 02/J97 g/197 3/ ' OFFICIAL RECORD COPY l

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CONNECTICUT YANKEE AT O MIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD e EAST HAMPToN. CT 06424-3099 February 13,1997

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Docket No. 50-213 B16121

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10 CFR 2.201

U.S. Nuclear Regulatory Commission ,

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Attention: Document Control Desk s Washington, DC 20555 ,Q j

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Haddam Neck Plant Reply to Notice of Violation NRC Insoection Reoort No. 50-213/96-11

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In a letter dated December 24, 1996,N the NRC transmitted to Connecticut Yankee

. Atomic Power Company (CYAPCO) the report documenting inspections conducted at the Haddam Neck Plant (HNP) from September 17 through September 27, 1996. As discussed in the report, the NRC Staff cited CYAPCO for a violation of the Commission's regulations concerning notifying the NRC Operations Center of a condition outside the design basis. This is a Severity Level IV violation of 10 CFR 50.72(b)(1)(ii).

In its letter, the NRC Staff requested that CYAPCO respond to the notice of violation (NOV) within 30 days of the date of the letter. CYAPCO requested an extension to February 13,1997, which was granted by the NRC Senior Resident inspector. Pursuant to the provisions of 10 CFR 2.201, Attachment 1 hereby provides CYAPCO's response to the subject NOV.

The following are CYAPCO's commitments made within this letter. Other statements within this letter are provided for information only.

B16121-1: The Duty Officers and Operations Shift Managers will review this Notice of Violation forlessons learned.

W R. W. Cooper to T. C. Feigenbaum, "NRC Integrated Inspection Report 50-213/96-11 and Notice of Violation", dated December 24,1996.

1028-3 REV 2 41 7.1 b al i { .

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i U.S. Nuclear Regulatory Commission B16121\Page 2 B16121-2: CYAPCO will write a new procedure to provide guidance in assessing operability. This guidance will include the requirement to conclude that a structure, system or component was inoperable whenever it is determined

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that the equipment was not maintained in such a manner as to assure the design basis. This procedure will be issued by June 30,1997.

B16121-3: CYAPCO will review procedures applicable to root cause and apparent cause determinations, and provide additional guidance, as appropriate, on performing operability /reportability determinations based on information developed in the process of causal determination. This review will be complete by June 30,1997.

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If you should have any questions on the information contained herein, please contact g ,%,

Mr. Gerry van Noordennen at (860) 267-3938. g Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY FOR: T. Executive Vice President and Chief Nuclear Officer BY:

J. J. L/Platrp f Haddam Neck Unit. irector Attachments (1)

cc: H. J. Miller, Region i Administrator Dr. W. D. Travers, Director, Special Projects Office M. B. Fairtile, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Haddam Neck Plant

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l Attachment 1 Haddam Neck Plant l Reply to Notice of Violation l NRC Inspection Report 50-213/96-11

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U.S. Nuclear Regulatory Commission B16121\ Attachment 1\Page 1

. 4 Attachment 1 Haddam Neck Plant Reply to Notice of Violation

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NRC Insoection Reoort No. 96-11 Restatement of Violation During NRC inspections conducted from September 17 - September 27,1996, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG 1600, the violation is listed below:

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A. 10 CFR 50.72(b)(1)(ii) requires that the licensee notify the NRC Operations @

Center within one hour of the discovery of a condition in which the plant operated J outside of its design basis.

Contrary to the above, on September 24, 1996, the B residual heat removal (RHR) pump was determined to have failed on August 19 due to inherent manufacturing defects and marginal design tolerances, which rendered it incapable during past plant operations at power'of performing the long term core recirculation cooling design function following postulated accidents. This condition, constituting past plant operation outside its design basis, was not reported to the NRC Operations Center per 10 CFR 50.72(b)(1)(ii).

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

Reason for the Violation The reason for the violation is that the threshold for inoperability and reportability was non-conservative, CYAPCO had concluded that the equipment was capable of meeting its design basis function and, therefore, did not meet the reporting criteria of 10 CFR 50.72. This conclusion was based in large part on the successful operation of the

. pump through August 19, 1996. CYAPCO had determined that the pump was inoperable for a period of time before discovery after the end of the cycle, but had been operable previously. However, this argument is not conservative since it is based on a detailed evaluation utilizing significant engineering judgment. The pump had not been maintained in a manner to meet its design basis. Therefore, past inoperability should have been concluded and notification made in accordance with 10 CFR 50.72.

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U.S. Nuclear Regulatory Commission B16121\ Attachment 1\Page 2 Corrective Steps Taken and Results Achieved

CYAPCO reported this condition to the NRC Operations Center per 10 CFR 4 50.72(b)(1)(li) on February 12,1997. This event was discussed by the management I

. review team (MRT). The MRT determined that the Operations Shift Managers and Duty i Officers should review this Notice of Violation as a lesson learned until such time as the l long term corrective actions are implemented,

Corrective Steps to Prevent Future Violations The Duty Officers and Operations Shift Managers will review this Notice of Violation for lessons learned,

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i CYAPCO will write a new procedure to provide guidance in assessing operability. This guidance will include the requirement to conclude that a structure, system or component Q was inoperable whenever it is determined that the equipment was not maintained in such J

. a manner as to assure the design basis. This procedure will be issued by June 30,1997.

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CYAPCO will review procedures applicable to root cause and apparent cause determinations, and provide additional guidance, as appropriate, on performing operability /reportability determinations based on information developed in the process of causal determination. This review will be complete by June 30,1997.

1 Date When Full Comoliance Will be Achieved

Full compliance with 10CFR50.72 was achieved on February 12,1997 when CYAPCO reported this condition to the NRC Operations Center per 10CFR50.72(b)(1)(ii).

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