ML20024H397
| ML20024H397 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/22/1991 |
| From: | Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO. |
| References | |
| NUDOCS 9106030255 | |
| Download: ML20024H397 (2) | |
See also: IR 05000213/1991006
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Docket No. 50-213
Connecticut Yankee Atomic Power Company
ATTN: Mr. E. J. Hroczka
Senior Vice President - Nuclear
Engineering and Operations
P.O. Box 270
Hartford, Connecticut 06141
Gentlemen:
,
Subject:
Inspection No. 50-213/91-06
This refers to your letter dated April 25, 1991, in response to our letter
dated March 19, 1991.
Thank you for informing us of the corrective and preventive actions documented
in your letter. These actions will be exanined during a future inspection of
your licensed-program.
Your cooperation with us is appreciated.
Sincerely,
Original 5:ened By:
Richard R Ke:rnig
James H. Joyner, Chief
Facilities Radiological Safety
and Safeguards Branch
Division of Radiation Safety
and Safeguards
CC:
W. D. Romberg, Vice President, Nuclear Operations
J. P. Stetz, Nuclear Station Director
G. H. Bouchard, Nuclear Unit Director
D. O. Nordouist, Director of Quality Services
R. M. Kacich, Manager, Generation Facilities Licensing
Gerald Garfield, Esquire
K. Abraham, PA0
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Public Document Room (PDR)
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Local Public Document' Room (LPDR)
Nuclear Safety Information Center (NSIC)
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NRC Resident Inspector
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State of Connecticut
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OFFICIAL RECORD COPY
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Region I Docket Room (with concurrencer.)
Management Assistant, CRMA
J. Joyner. DRSS
E. Kelly, DRP
J. Shediosky, SRI, Haddam Neck
W. Raymond, SRI, Millstone
K. Brockman, EDO
R. Arrighi, DRP
E. Wenzinger, DRP
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April 25, 1991
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ML414
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U.S. Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, DC 20$$$
Gentlemen:
Haddam Neck Plant
Response to Notice of Violation
Inspection Report No. 50 213191-05
In'a letter dated March 19,1991,(I) the NRC Staff transmitted the results of
an inspection conducted at the Haddam Neck Plant from February 25 through
March 1,
1991.
In their inspection, the NRC Staff identified one Severity
Level IV violation concerning four instances where Connecticut Yankee Atomic
Power Company (CYAPCO) utilized the TN RAM shipping cask to transport licensed
material to the Barnwell disposal facility without performing the dryness
verification test at the specified vacuum condition, and requested that CYAPC0
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respond to the-Notice of Violation (NOV) within 30 days of the date of the
letter.
In a subsequent discussion with Mr. J. H. Joyner, CYAPC0 was granted
a 2 week extension in responding to the NOV.
Pursuant to the provisions of 10CFR2.201, CYAPC0 hereby provides its response
to the subject Notice 7f Violation in Attachment 1.
If you have any questions regcrding the information contained in this letter,
pleare contact us.
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Very truly yours,
CONNECTICUT YANKEE ATOMIC POWER COMPANY
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E.J.groczka--
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Senior Vice President
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cc:
T. T. Martin, Region 1 Administrator
J. H. Joyner, Chief, f acilities Radiological Safety and Safeguards Branch
A. B. Wang, NRC Project Manager, Haddam Neck Plant
J. T. Shedlosky, Senior Resident inspector, Haddam Neck Plant
(1)
J. H. Joyner letter to E. J. Mrotzka, Inspection No. 50 213/91 06, dated
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March 19, 1991.
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Docket No. 10 113
AQ.9314
Attachment I
daddam Neck Plant
Response to Notice of Violation
Inspection Report No. 50 213/91 06
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April 1991
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U.S. Nuclear Regulatory Connission
A09434/ Attachment 1/Page 1
April 25, 1991
Haddam Neck Plant
Response to Notice of Violation
Inipsetion Report No. 50-&l3/91 01
Description of Violation
During an NRC inspection conducted on February 25 to March 1,1991, a viola-
tion of NRC requirements was identified.
In accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1990), the violation is listed below:
10 CFR 71.12 states, in part, that " . . . a general license is hereby issued
to any licensee of the Commission to transport, or to deliver to a carrier for
transport, licensed material in a package for which a . . . certificate of
compliance . . . has been issued . . . this general license applies only to a
licensee who . . . complies with the terms and conditions of the . . . certif-
icate of compliance, as applicable, and the applicable requirements of Sub-
parts A, G, and H of this part. . . . "
Condition Number 8 of Certificate of
Compliance Number 9233, issued for the TN RAM shipping cask, states, in part,
that
. in
addition
to the
requirements
of
Subpart G of
10 CFR
"
. .
Part 71 . . . the package shall be prepared for shipment and operated in
accordance with the Operating Procedures of Section 7 of the applica-
tion. . . . "
Paragraph 7.1.2.31 of the Operating Procedures contained in the
Safety Analysis Report for the TN RAM shipping cask states, in part, that for
" . . . the cask dryness verification test . . . evacuate the cask cavity
until a stable vacuum of 10, +2,
0 mbar is indicated. . . . *
Contrary to the above, on March 16, March 26, April 3, and April 10 of 1990,
the licensee utilized the TN-RAM shipping cask to transport licensed material
to the Barnwell disposal facility, Barnwell, South Carolina, without perform-
ing the dryness verifit"40n test at the specified vacuum condition.
Specifi-
call,
on each occasion cited above, prior to releasing the cask from the
liceu Je's facility, the dryness verification test was performed, but at a
pressure of 13,15,17, and 15 mbar, respectively, for four shipments.
Root Cause
The root cause of this event was procedure inadequacy resulting from a lack of
clearly stated acceptance criteria in the dryness verification procedure.
This situation was further compounded by the failure of the operator to fully
understand the procedure.
In respense to a similar procedural discrepancy at
the Hillstone Nuclear Power Station on May 7,1990, an independent Corporate
Task Force was assembled to evaluate the adequacy of the dryntss verification
procedure.
Upon completion of its evaluation, the Task Force concluded that
the dryness verification procedure was inadequate in that there was no clearly
stated acceptance criteria in the procedure.
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U.S. Nuclear Regulatory Commission
A09434/ Attachment 1/Page 2
April 25, 1991
Based upon the findings of the Task force, procedure changes were implemented
by Waste Chem Corporation on May 25, 1990, to correct this procedural weak-
ness.
CYAPCO wishes to emphasize that the procedural inadequacy and resulting
violation of the casks certificate of compliance were self-identified at the
Haddam Neck Plant and procedure enhancements were implemented in a timely
manner to correct the discrepancy and preclude any future dryness verification
testing errors.
All of this work was completed well
before the NRC
inspection.
Further, it should be noted that the dryness verification testing
conducted in accordance with the faulted procedure had no adverse effect on
the waste form acceptance at the burial site.
CYAPCO considers a contributing factor to be the overreliance on the expertise
of the contractor, Waste Chem Corporation, regarding the technical adequacy of
the procedure.
Corrective Action
Upon discovery of the discrepancy, Waste Chem Corporation impicmented a
revision to tht. dryness verification procedure on May 25, 1990.
In addition,
CYAPC0 has reviewed its inventory of cask manuals to ensure compliance between
the cask certificate of compliance, cask safety analysis report, and cask user
procedures.
No additional discrepancies were identified.
Corrective Action to Prevent Recurrence
As a result of the Task Force findings, Waste Chem Corporation has initiated a
number of procedural changes and enhanced the training provided to its opera-
tors.
A precautionary note has been added to the procedure that cautions the opera-
tors regarding the interpretation of pressure plateaus in the cask dryness
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verification and the potential that water may still be present in the cask at
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a higher pressure.
Further, any cask user procedures and procedure revisions
supplied by vendors will be verified using the certificate of compliance.
This verification will be completed before new procedures or revised proce-
dures are presented to the Plant Operations Review Committee for approval.
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Date by Which CYAPC0 Exoects to Achieve Fuli Compliance
The changes to the TN RAM procedures were completed on May 25, 1990.
Review of the inventory of vendor cask manuals was completed by CYAPC0 on
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April 5, 1991.
CYAPC0 considers our existing programs and procedures to be adequate and in
full compliance with applicable requirements.
Therefore, we conclude that
there is no programmatic deficiency at the Haddam Neck Plant with respect to
radioactive material handling and transportation.
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