IR 05000213/1996201

Ack Receipt of Requesting Schedule Change for pre-decisional EC Re Plant Insp Repts 50-213/96-201, 50-213/96-06,50-213/96-08.Originally Scheduled EC for 961018 Requested to Be Delayed Until Dec 1996

ML20134G710
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	11/05/1996
From:	Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Feigenbaum T, Harpster T NORTHEAST UTILITIES SERVICE CO.
References
EA-96-001, EA-96-1, EA-96-334, EA-96-337, EA-96-338, EA-96-339, EA-96-340, EA-96-407, EA-96-440, NUDOCS 9611130331
Download: ML20134G710 (6)

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November 5,1996

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EA Nos.96-001, 96-340, 965339 96-33'8, 96 337, 960334 96-407,96-440 Mr. Ted Executive Vice President and Chief Nuclear Officer Northeast Utilities Service Company c/o Mr. Terry L. Harpster P.O. Box 270 Hartford, CT 06141-0270 SUBJECT: ACKNOWLEDGMENT OF OCTOBER 10,1996, LETTER REQUESTING A SCHEDULE CHANGE FOR THE PRE-DECISIONAL ENFORCEMENT l CONFERENCE '

Dear Mc. Feigenbaum:

This is in response to your October 10,1996, letter requesting a schedule change for the pre-decisional enforcement conference related to Haddam Neck Inspections 50-213/96-201, 50-213/96-06, and 50-213/96-08. You requested that this enforcement conference, originally scheduled for October 18,1996, be delayed until December 1996.

Your letter stated that: 1) it has been announced that it is unlikely that Haddam Neck will be returned to power operation; 2) this decision will be finalized by the plant's owners within the next few weeks; 3) the announcement has created a short-term demand on your resources and has a direct bearing on many of the specific issues which are the subject of the conference; and,4) the process of assessing this decision's impact on the corrective abtions necessary is underway. You concluded that rescheduling the enforcement conference until December will enable your staff to present a more complete and meaningful response to the proposed enforcement issues.

As discussed with your staff, we have rescheduled the enforcement conference, for the discussion on apparent violations identified in the three previously mentioned inspection reports, to December 4,1996. The conference will be held in the vicinity of Haddam Neck site and will be open to the public for observation. We willinform you of the location when those arrangements are finalized.

At the conference, you should also be prepared to discuss the apparent violations identified in Inspection Report (IR) 50-213/96-07, involving emergency preparedness exercise weaknesses, and in IR 50-213/96-80, involving the acceptability of your staff's performance between August 22 and September 4,1996, when several events occurred.

The Attachment is a proposed outline for this conference that suggests a method for you f

9611130331 961105 PDR ADOCK 05000213 N

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Mr. T. ; to present the issues in a concise manner and allow maximum discussion of your planned corrective actions. We expect you to particularly focus your discussion of the apparent violations and corrective actions on both the near-term and the long-term operations of

Haddam Neck based on your expected future operating or shutdown plans. The  ;

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Attachment also provides a summary of the apparent violations raised by the Augmented 1 inspection Team (AIT) in IR 50-213/96-80.

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These expectations were discussed betyveen Mr. Van Noordenen of your staff and Mr.

John Rogge on November 4,1996. If you have questions regarding details of the i proposed Enforcement Conference, please contact John Rogge or Monte Conner of my

staff. They can be reached by telephone on (610) 337-5146 (Rogge) or (610) 337-5399

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(Conner).

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Sincerely, Original Signed By:

Richard W. Cooper, ll, Director Division of Reactor Projects Docket No. 50-213 cc w/att:

B. Kenyon, President and Chief Executive Officer - Nuclear Group i D. Goebel Vice President - Nuclear Oversight l J. Thayer, Vice President - Nuclear Engineering and Support Recovery Office  !

F. Rothen, Vice President - Work Services J. LaPlatney, Haddam Neck Unit Director L. Cuoco, Senior Nuclear Counsel J. Van Noordenen, Licensing Manager - Haddam Neck H. Haynes, Director - Training J. Smith, Manager, Operator Training W. Meinert, Nuclear Engineer  !

State of Connecticut SLO

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Mr. T. Distribution w/att: 4 Region 1 Docket Room (with concurrences)  !

H. Miller, RA B. Letts, 01 ,

D. Screnci, PAO J. Wiggins, DRS J. Shannon, DRS l J. Trapp, DRS j J. Durr, SPO j

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J. Rogge, DRP  ;

NRC Resident inspector l M. Conner, DRP D. Bearde, DRP Nuclear Safety Information Center (NSIC)

PUBLIC D. Holody, OE (2)

Distribution w/att (VIA E-MAIL): l M. Virgilio, NRR l W. Dean, OEDO '

P. McKee, NRR/PD l-4 J. Goldberg, OGC S. Dembek, PM, NRR R. Jones, NRR R. Correia, NRR (RPC)

R. Frahm, Jr., NRR (RKF)

Inspection Program Branch, NRR (IPAS)

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DOCUMENT NAME: G:\ BRANCH 8\RESCHENF.HN2 To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = ,

Copy with attachment / enclosure "N" = No cop 4 6b OFFICE Rl/DRP J Rl/DRS ( 6 JiQ/NRR Rl/DRP)//@, l NAME JFROGGE/dbMf JTWIGGINS$f PFMCKEE & pjRWCOQPEfWI DATE 10g/ /96

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1$/5/96 f~ 10/J t /96 ~(dereWg/96 c OFFICIAL RECORD COPY ll

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Attachment >

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SUGGESTED PRESENTATION i

The first part of the presentation should be a brief introduction and review of each apparent violation as identified in the individual inspection reports without going into detailed discussions about the multiple, specific examples listed under each apparent >

violation. This is the opportunity for you to point out any errors in our inspection reports, ;

admit or deny the violation, state the root causes, missed opportunities to identify the >

violation sooner, significance of the issue, and for you to provide any information ,

concerning your perspectives on 1) the severity of the violation, 2) the application of the j factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other j application of the Enforcement Policy, including the exercise of discretion in accordance '

with Section Vll. You may want to provide this as a written handout or slides and then ;

highlight only the significant areas.' The following order is preferred.

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a. IR 50-213/96-201, Specialinspection of Engineering and Licensing Activities; l

b. IR 50-213/96-06, Integrated Resident inspection, I

c. IR 50-213/96-08, Integrated Resident inspection, ,

d. IR 50-213/96-07, NRC-Evaluated Emergency Preparedness Exercise; and, l

e. IR 50-213/96-80, Augmented Inspection Team Rev;ew of August 22 to September i 4,1996 Events.

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The second part of the presentation should be an indepth discussion of the corrective actions to address root causes as they apply to the broader implications related to engineering, licensing and plant operations. These corrective actions should also address l

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both near term actions and those associated with future operation of the unit. The NRC currently views the individual apparent violations grouped as follows; however, you may choose to place the individual violations into other groupings that have similar root causes or corrective actions.

a. Errors in the Design Basis Documents - 96-201-21, 22, 28, 32, 33, 34 and 96-08-02; b. Design errors introduced by Design Changes - 96-201-06, 07,11, 26, 27, 28, 29, 30,36,37;

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c. Inadequate Corrective Actions did not promptly correct or preclude repetition - 96-201-09,14,15,16,17,18,19,20; d. Errors in evaluations required by 10 CFR 50.59 either by failing to have a written Safety Evaluation for changes to the facility or to the description in the Safety Analysis Report - 96-201-02, 03,04, 05; l A1

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e. Failure to update the Final Safety Analysis Report - 96-201-01; f. Equipment that could not perform its intended safety function - 96-06-07 j (Feedwater Isolation During Main Steam Line Break), 96-08-07 (Containment Air <

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! Recirculation Fan Failure), 96-08-10 (Containment SumpJScreen), and 96-08-1'1 (Residual Heat Removal Pumps NPSH); and,

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g. Miscellaneous issues not grouped - 96-201-08 (Vendor Contacts), 96-201-35

! (Nonconformance Evaluations), and 96-08-08 (Appendix J Type B Test of the Fuel 4-Transfer Tube). .

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The third part of the presentation should be an in-depth discussion of the corrective actions ,

[ to address root causes as they apply to the emergency preparedness weaknesses 50-

, 213/96-07-01, Event Classification and EAL performance and 50-213/96-07-02, Protective

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Action Recommendations. The corrective actions should address near term action required j to support refueling and shutdown condition along with those needed to support future l operation of the unit. l

I l The fourth part of the presentation should be an in-depth discussion of the corrective l j actions to address root causes as they apply to the broader plant operational issues which

were identified as a result of the Augmented Inspection Team, inspection Report 50-l 213/96-80. These corrective actions should also address both near term actions and those

! associated with future operation of the unit. The NRC currently views the individual

{ apparent violations could be grouped as follows; however, again you may choose to place ,

the individual violations into other groupings that have similar root causes or corrective )

i actions. I j l a.1 Written procedures and/or administrative policies were not established,

implemented, and maintained to cover the activities as specified in TS 6.8.1 and j invoked by Regulatory Guide 1.33, Appendix A, recommendations:

i j 03.2/M2.1 RCS vent installation lacked adequate procedural guidance and i controls and the vent line was in poor material condition; I

j 03.5 Inadequate procedural guidance for shifting RHR pumps, upper RHR

{ flow limitations, and isolation of heat exchangers;

03.6/04.5 Inadequate operations procedural guidance for verification of an j operable TS required boron injection flow path and the evolution to shift boration flow paths was inadequately performed; 04.2 Inadequate management review and improper performance of the j procedure to return a loop to service with the plant shutdown; i

, 03.4/04.4 RHR purification system operations procedure was inadequate in that i some system alignment steps did not designate personnel sign-offs and an inadequate pre-job brief was held for the first time operator; i l

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l 04.1 Inappropriate removal of the overpressure protection for isolated RCS Loops; and, 03.1/03.3 Instructions for control of a RCS draindown evolution, to fill and vent the charging suction header, and to vent the "B" charging pump were not reviewed by PORC and approved by the Vice-President, a.2 Appropriate procedures were not provided as required by 10 CFR 50, Appendix B, Criterion V. ,

i E2.5 Procedure used to drain the reactor on August 30 and to operate the reactor in a partially filled and vented condition from August 30 -

September 3 was inadequate to minimize shutdown risk because no i reactor vessel level and core exit thermocouple instrumentation were

! required contrary tp 10 CFR 50, Appendix B, Criterion V.

h. Corrective action not established to ensure that conditions adverse to quality, such as failures, deficiencies, and deviations, were promptly identified and corrected per 10 CFR 50, Appendix B, Criterion XVI:

l 04.7 Ineffective identification and correction of nitrogen gas entering the reactor vessel displacinr, reactor coolant system inventory; M 1.1 Several avoidable delays were encountered during the corrective maintenance on the "B" Residual Heat Removat pump; E2.5 Management directive to preclude inadvertent reactor draindown was ineffective to prevent the draining of about 300 gallons of reactor water to the containment sump on Sept' ember 4,1996; and, E7.2 Fragmented and protracted licensee management and technical support response to the nitrogen bubble and degraded RHR subsystem events.

c. Miscellaneous problems not grouped:

03.6 Failure to declare the TS 3.1.2.1 required boration flowpath inoperable due to nitrogen gas introduction between August 28 and September 1,

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04.8 Failure to make a timely report on the accumun.t. ion of nitrogen in the reactor vessel as required by 10 CFR 50.72(b)(2)(iii)(B).

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