ML20035H566
| ML20035H566 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 04/27/1993 |
| From: | Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035H565 | List: |
| References | |
| 50-213-93-03, 50-213-93-3, NUDOCS 9305060002 | |
| Download: ML20035H566 (49) | |
See also: IR 05000213/1993003
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Report No.
50-213/93-03
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License No.
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Licensee:
Connecticut Yankee Atomic Power Company
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P. O. Box 270
Hartford, CT 06141-0270
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Facility:
Haddam Neck Plant
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Location:
Haddam Neck, Connecticut-
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Inspection
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Dates:
February 21,1993 to March 27,1993
Inspectors:
William J.- Raymond, Senior Resident Inspector
Peter J. Habighorst, Resident Inspector
Approved by:
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4/27/93
Lawrence T. Doerflein, Cljief
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Reactor Projects Section No. 4A
Areas Inspected: NRC resident inspection of plant operations, radiological controls,
maintenance, technical support, outage planning and periodic reports.' An inspection
initiative was the review of the loose parts monitoring system.
Results: See Executive Summary
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9305060002 930427
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ADOCK 05000213
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EXECUTIVE SUMMARY
IIADDAM NECK PLANT INSPECTION 93-03
Plant Operations
The inspectors noted safe plant operation during the report period and determined that
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operators performed routine duties very well. Operators also performed well to complete a
plant down power to 60% for a maintenance activity, and in completing a reactor startup.
The inspector noted that improvements in the operator requalification program contributed to
operator proficiency in the conduct of operations outside the control room for postulated fire
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scenarios.
Operator response to a rod drive system malfunction was timely and appropriate in manually
scram the reactor. ' During the ensuing transient, the operators responded very well to isolate
the high pressure steam bypass system to minimize a plant cooldown and avert an unneces-
sary safety injection.
Licensee actions were timely and thorough to prepare for a potential job action by the plant
work force, and to assure adequate staffing and continued safe plant operation during a
blizzard.
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The inspector reviewed the service water system and determined that the system was
properly aligned to provide the intended safety function, and that the system was properly
maintained and tested to assure continued operability.
Maintenance
The inspector determined that the performance by maintenance personnel to correct degraded
equipment conditions during the period was very good. In particular, licensee actions were
appropriate and thorough to troubleshoot and repair control rod position indication and
control problems.
Engineerine and Technical Supnort
CYAPCo identified leaks on the six inch service water supply header to the 'B' emergency
diesel generator. The inspector determined that engineering support was good to pmmptly
characterize the defect and assess the structural integrity of the safety class 3 piping. The
inspector further noted that the licensee provided an acceptable operability determination for
the system while processing a relief request from the ASME code requirement in accordance
with Gencric Letter 90-05.
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The reactor loose parts monitoring system is used at Haddam Neck to monitor vessel noise
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and to assess the potential for loose parts within the reactor. The system was installed as a
licensee initiative in 1987 and there are no regulatory commitments regarding the installation
or use of the system. However, NRC inspection determined that the licensee could improve
the operation and calibration procedures for the system, and the training provided to
instrumentation specialists.
Safety Assessment and Ouality Verification
The inspector reviewed licensee preparations for the refueling outage including: planning and
scheduling; the development of an administrative control procedure; the deferral of certain
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modification and maintenance work; and, actions to address shutdown risk. The licensee's
creation of an outage safety assessment team, and the development of prescriptive shutdown
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safety function requirements are a good initiative. Previously established milestones for
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outage scheduling were delayed. The effectiveness of outage planning and scheduling
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changes will be reviewed during of the upcoming outage starting on May 15,1993. The
inspector determined, based on a review of selected plant modifications that will be deferred,
that reasonable engineering justification exists for postponing the work.
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TABLE OF CONTENTS
1.0
SUMMARY OF FACILITY ACTIVITIES
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2.0
PLANT OPERATIONS (71707,93702,92709 and 71710)
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2.1
Operational Safety Verification . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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2.2
Radiological Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
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2.3
Plant Operations Outside the Control Room
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2.4
Engineered Safety Features System Walkdown
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2.5
Licensee Actions During Blizzard Joshua . . . . . . . . . . . . . . . . . . . . . 6
2.6
Manual Reactor Trip . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.7
Strike Contingency Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2.8
Plant Startup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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2.9
Plant Downpower Due to Noise in 'B' Main Feed Pump . . . . . . . . . .
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2.10 Entry into Technical Specification Limiting Conditions for Operation
During Performance of Surveillances
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3.0
MAINTENANCE AND SURVEILLANCE (61726,62703 and 71707) . . . . . .
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3.1
Maintenance Observation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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3.2
Individual Rod Position Indication . . . . . . . . . . . . . . . . . . . . . . . .
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4.0
ENGINEERING AND TECHNICAL SUPPORT (71707) . . . . . . . . . . . . . .
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4.1
Loose Parts Monitoring System . . . . . . . . . . . . . . . . . . . . . . . . . .
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4.2
Service Leak Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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5.0
SAFETY ASSESSMENT AND QUALITY VERIFICATION (40500,71707,
90712, and 92701) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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5.1
Plant Operations Review Committee . . . . . . . . . . . . . . . . . . . . . . .
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5.2
Review of Written Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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5.3
Cycle 17 Refuel Outage Planning . . . . . . . . . . . . . . . . . . . . . . . . .
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5.4
Nuclear Review Board . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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6.0
M ANAGEMENT MEETINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
6.1
Exit Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
6.2
Management Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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Note: The NRC inspection manual procedure or temporary instruction that was used as
inspection guidance is listed for each applicable report section.
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Attachment I: Presentation Handout for March 17,1993 Management Meeting
Attachment II: Licensee's Affidavit for Requesting the Closed Meeting
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DETAILS
1.0
SUMMARY OF FACILITY ACTIVITIES
The unit operated at full rated power from the start of the inspection period until March 15,
when load was reduced to 60% to remove from service and inspect the 'B' main feedwater
pump motor. A loose motor shroud gasket was identified and removed on March 15. The
plant returned to full power on March 17 following cleaning of main condenser tubes. Full
power operations continued until March 23, when the operator manually scrammed the
reactor in response to a malfunction in the rod control system. The plant shutdown ended a
370 day operation run for Haddam Neck.
After repair of the rod control system and other maintenance work, the reactor was restarted
on March 24 and full power operation resumed on March 26,1993. The plant remained at
full power for the remainder of the period. On March 27, the licensee conducted an
Emergency Plan exercise that involved partial participation by offsite authorities. NRC
review of the exercise is documented in inspection report 50-213/93-02.
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On March 5,1993, CYAPCo management announced the following plant organization
changes, effective March 28,1993: Mr. G. H. Bouchard, Haddam Neck Unit Director was
appointed Northeast Utilities Service Company (NUSCo) Director of Quality Services;
Mr. D. J. Ray, Haddam Neck Nuclear Services Director,was be appointed Unit Director;
Mr. J. J. LaPlatney, Haddam Neck Operations Manager will be promoted to Nuclear
Services Director. CYAPCo cited its continuing efforts to maintain and assure safe and cost
effective operation of the unit, and to provide personnel development opportunities, as the
reasons for the changes.
2.0
PLANT OPERATIONS (71707,93702,92709 and 71710)
The inspectors routinely reviewed plant operations during normal utility working hours, and
portions of backshifts (evening shifts) and deep backshifts (weekend and night shifts).
Inspection coverage was provided for forty hours during backshifts and thirty-two hours
during deep backshifts.
2.1
Operational Safety Verification
This inspection consisted of selective examinations of control room activities, operability
reviews of engineered safety feature systems, plant tours, review of the problem identifica-
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tion systems, and attendance at periodic planning meetings. Control room reviews consisted
of verification of staffing, operator procedural adherence, operator cognizance of control
room alarms, control of technical specification limiting conditions of operation, and electrical
distribution verifications. Administrative control procedure (ACP) 1.0-23, " Operations
Department Shift Staffing Requirements," identifies the minimum staffing requirements.
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During this period, the inspectors noted that the control room staffing during power opera-
tions met these requirements.
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The inspectors reviewed the onsite electrical distribution system to verify proper electrical
lineup of the emergency core cooling pumps and valves, the emergency diesel generators,
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radiation monitors, and various engineered safety feature equipment. The inspectors also
verified valve lineups, position of locked manual valves, power supplies, and flow paths for
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the high pressure safety injection system, the low pressure safety injection system, the
containment air recirculation system, the service water system, and the emergency diesel
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generators. The inspector observed no deficient conditions.
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Log-Keeping and Turnovers
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The inspectors reviewed control room logs, night order logs, plant incident report logs, and
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crew turnover sheets. No discrepancies or unsatisfactory conditions were noted. The
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inspectors observed crew shift turnovers and determined they were satisfactory, with the shift
supervisor controlling the turnover. All members of the crew discussed plant conditions and
evolutions in progress. The information exchanged was accurate. The inspectors also
reviewed control room trouble reports for age, planned action, and operator awareness for
the reason for the trouble report. Most trouble reports reviewed were recent, with few
longstanding items.
At daily planning meetings, the inspector noted discussion on maintenance and surveillance
activities in progress and planned work authorizations. The inspectors conducted periodic
plant tours in the primary auxiliary building, turbine building, and intake structures. Plant
housekeeping was satisfactory.
2.2
Radiological Controls
During routine inspections of the accessible plant areas, the inspectors observed the imple-
mentation of selected portions of the licensee's radiological controls program. The inspector
reviewed utilization and compliance with radiation work permits (RWPs) to ensure that
detailed descriptions of radiological conditions were provided and that personnel adhered to
RWP requirements. The inspectors observed control of access to various radiologically
controlled areas and the use of personnel monitors and frisking methods upon exit from those
areas. The inspector noted posting and control of radiation areas, contaminated areas and hot
spots, and labelling and control of containers holding radioactive materials were in accor-
dance with licensee procedures. The inspector determined that health physics technician
control and monitoring of these activities were good.
2.3
Plant Operations Outside the Control Room
NRC inspection report 50-213/92-80 reviewed the CYAPCo program to meet Appendix R
fire protection requirements. The report expressed a concern that the 10CFR50 Appendix R
operator training program is based not on entire procedures, but rather on specific job
performance measures (JPM's). The JPM's are critical tasks within the procedure. The
NRC's concern was that this form of training does not train operators on an integrated
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response to a particular scenario. CYAPCo responded to this concern by revising the
operator requalification training program to train on the entire abnormal operating procedure
(AOP).
On March 5, the inspector observed operator requalification on AOP 3.2-50, " Plant Opera-
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tions Outside the Control Room." The training simulated operator actions taken in the event
the control room is uninhabitable due to a fire. Three operators are designated to accomplish
actions within AOP 3.2-50, since the remaining portion of the crew is involved with the fire
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brigade to combat the fire. The inspector observed appropriate use of radio communication,
adherence to the procedure, and operator awareness of essential equipment within the
" Operations Outside the Control Room" locker. The post-training critique was frank and
open in discussing the potential procedural deficiencies, and areas for improvement in
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communications and coordination of the operations team. The inspector determined that the
training accomplished the objective to have a coordinated operator response to a particular
simulated fire scenario.
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2.4
Engineered Safety Features System Walkdown
The objective of the inspection was to evaluate licensee control of the service water system.
The inspector evaluated maintenance and surveillance programs and practices for the service
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water system. The inspector also completed a plant walkdown, reviewed applicable plant
information reports, and assessed the adequacy of engineering support for the system.
Surveillance and Maintenance
The inspector reviewed service water system surveillance procedures to verify that technical
specification (TS) surveillance requirements were met. The inspector used the control room
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and auxiliary operator logs during a plant walkdown to verify that system parameters met the
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conditions and values specified in the logs. The inspector also reviewed the calibration of
service water instrumentation, and the outstanding trouble reports and corrective maintenance
requests for the system. The inspector verified that the last completed surveillances were
within the interval for TS surveillance requirements 4.7.3.a.,4.7.3.b.l., and 4.7.3.b.2.
TS 4.7.3.a requires that the licensee verify that manual, power-operated, or automatic valves
servicing safety-related equipment are in the correct position. This must be done once per
month for valves that are not locked or otherwise secured in position. Based on review of
applicable drawings and licensee procedure SUR 5.1-152, " Service Water System Align-
ment," the inspector noted that all major flowpath valves servicing safety-related equipment
are not periodically verified. The licensee stated that his method for meeting the TS was as
described in Section 9.2.1.5 of the Updated Safety Analysis Report (UFSAR), which states
that the service water design basis assumes specific valve positions for a number of valves in
the safety-related portion of the system. UFSAR table 9.2-3 provides a list of valves subject
to periodic verification to meet the TS 4.7.3.a requirement. The inspector verified that SUR
5.1-152 agreed with UFSAR table 9.2-3. CYAPCo's stated that verifying the correct
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positioning of the valves listed in the UFSAR was sufficient to assure the service water
system design basis analyses remained valid. CYAPCo stated that valve positions not
checked were controlled by normal operating procedures. Further, operator actions each
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shift to balance heat exchanger flows provided a functional verification of proper valve
positioning. The inspector concluded that this was acceptable.
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The inspector reviewed shift log entries recorded by the auxiliary and control room opera-
tors. Maintaining the logs satisfies two TS surveillances: monitoring the flowrate for the
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service water effluent radiation monitor; and, recording the number of operating service
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water pumps for use in calculating flow rates for discharge permits. Routine log entries also
verify service water system operability based on requirements beyond those identified in the
TS, such as: service water design temperature (90 degrees Fahrenheit (F)); service water
flow rates to component cooling water heat exchangers; acceptable Adams filter operation;
and, the minimum Connecticut River level needed for service water pump operation.
The inspector reviewed outstanding trouble reports (TRs) and corrective maintenance
requests to determine whether service water system operability was jeopardized due to the
discrepant conditions. Eight TRs and twenty-two corrective maintenance requests were
outstanding on March 16. The oldest TR was approximately one and one half years old.
None of the conditions documented in the TRs jeopardized system operability. The discrep-
ancies included a misaligned spring can, corroded non-safety grade anchor supports, check
valve seat leakage, and a misaligned pin for the pump discharge strainer cover. The licensee
plans to work a majority of the corrective maintenance requests during the next refueling
outage. The planned maintenance includes valve inspections, repairing seat leak-by and
packing leaks, and repairing a motor-operated valve for the residual heat removal heat
exchanger.
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The inspector verified that the licensee performed periodic calibration of selected instrumen-
tation within the system, and that results were satisfactory. The instrumentation selected for
this verification included those used for control room annunciators, and in normal operating
procedures, and abnormal operating procedures. The review included nine instruments that
monitor the following: containment air recirculation outlet temperatures and flowrate, service
water discharge header pressure, auxiliary building service water header pressure, service
water flow to the residual heat removal heat exchangers, and service water pump flow. The
inspector verified the instruments were periodically calibrated with satisfactory results.
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System Walkdown
The inspector walked down accessible areas of the service water system. During the
walkdown, the inspector verified the accuracy of plant drawings against in-plant equipment,
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and noted the condition of valves, instrumentation, and support systems. The inspector
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verified system parameters using auxiliary and control room operator logs, and the installa-
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tion of temporary modifications.
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Various valve label tags were missing. The inspector notified the licensee of the location and
valve number of each discrepancy. The inspector reviewed administrative control procedure
(ACP) 1.0-57, " Plant Labeling Procedure," to evaluate the licensee's program. The program
provides a mechanism for workers to identify labeling deficiencies. The operations depart-
ment is responsible for administration of the program. CYAPCo was in the process of
correcting the valve label deficiencies at the end of the inspection period.
The inspector also noted poor equipment condition on the service water header "Annubar"
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flow instrument lines (FE-433, 435, 437, and 439). The instrument lines were bent and
poorly supported. The licensee was informed by the inspector of this condition, and plans to
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address the deficiencies.
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The inspector did not identify any drawing errors. System parameters were within the
expected range, and good housekeeping was noted around service water components and
support systems.
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Plant Information Reports
The inspector reviewed licensee root cause determinations and corrective actions associated
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with 1992 plant information reports (PIRs) concerning the service water system. Approxi-
mately eight percent of all PIR's issued were related to the service water system. The causes
of the problems documented in the PIRs included design discrepancies, the failure to update
operating curves following a modification, check valve internal wear, fouling of service
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water components, and improper clearance of equipment tags. Corrective actions for these
events included implementing plant design changes, revising operating curves, and revising
administrative control procedures. Two of the events were documented in licensee event
reports (LERs)92-012 and 92-015. The inspector concluded the corrective actions were
acceptable.
Engineering Support
To assess engineering support for the service water system, the inspector reviewed: the
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safety evaluation determinations for AOP 3.2-19, " Loss of All Service Water"; the technical
evaluations for installed temporary modifications; and, the technical basis for the lack of
service water header independence.
To validate the adequacy of safety evaluation determinations, the inspector considered 10
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CFR 50.59, ACP 1.2-6.12, " Safety Evaluations for Station Procedures," ACP 1.2-6.9,
" Safety Evaluations - NEO 3.12," and past revisions to AOP 3.2-19. CYAPCo initiated
written safety evaluations for revisions two and seven of AOP 3.2-19. The basis for the
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safety evaluation determinations was consistent with ACP 1.2-6.12 and ACP 1.2-6.9. The
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inspector concluded that the licensee had an acceptable basis for not developing a full written
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safety evaluation per ACP 1.2-6.12 for the remaining AOP revisions. The inspector
determined the technical evaluations for the four installed temporary modifications provided a
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sufficient description of the change. Also, the safety evaluation conclusions for the tempo-
rary modification were appmpriate.
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The inspector noted that the normal configuration for the service water system is to maintain
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the header cross-connect valve SW-V-102 open, which does not provide for header indepen-
dence. This matter was discussed with CYAPCo engineering personnel. The licensee's
basis for not maintaining header independence was: no separation is provided to the service
water supply to the containment air recirculation fans; the design does not maintain electrical
independence for safety-related motor-operated valves; and, the probability of a pipe rupture
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is low. Additionally, a complete loss of service water does not result in a potential core
melt scenarin, The system design approved by the NRC staff as described in Section 9.2 of
the UFSAR does not require independent service water headers. The TS bases state that the
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service water headers may be tied together by an open service water cross-connect in the
intake structure. The inspector concluded that operation of the service water system without
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header independence is in accordance with the licensing basis, and is appropriate based on a
consideration of the risk to plant safety.
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Conclusion
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The inspector concluded the licensee appropriately maintained the operable status of the
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service water system. Maintenance and surveillance activities were acceptable to maintain
system operability. Minor housekeeping issues existed concerning plant labeling and
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instrument line support. The inspector also determined engineering support was good to
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provide an acceptable system design and to assure the safety function was maintained.
2.5
Licensee Actions During Blizzard Joshua
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The inspector reviewed licensee actions during the period fmm March 12 -13 as Storm
Joshua moved into Southern New England. Licensee plans and actions to assure adequate
shift staffing and the supply of consumables necessary for safe plant operation were also
reviewed. This major snow storm was projected to have 60 mile-per-hour wind speeds at
Haddam Neck. An Unusual Event emergency classification would be declared for sustained
wind speeds in excess of 75 mph.
The licensee's preparations for the storm included around-the-clock staffing by building -
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services personnel who ' worked on snow removal for the site and the plant access road. The
site area was canvassed to secure loose equipment and debris. Additional personnel
necessary to provide relief for security, operations, chemistry and health physics crews were--
called in to the site in advance of the arrival of the storm. Additional craft personnel were
. also called in to assure contingency staffing of the emergency organization. Meal and
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sleeping accommodations were provided for site workers during rest periods. A management
representative was on site throughout the period in the position of the onsite director of site
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The inspector monitored weather and road conditions and plant actions during the period
from March 12 - 15 as Storm Joshua moved through Southern New England. Inspector
reviews during this period focused on the weather conditions experienced at the plant, the
status and implementation of contingency plans and whether any problems were encountered
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meeting the contingencies. The eye of the storm passed through the site area at 3 a.m. on
March 14. Maximum sustained wind speeds reached about 40 mph. Access roads to the
station remained passable during the storm. As area conditions worsened during the evening
of March 13, site management elected to hold the normal midnight to 8 a.m. crew offsite and
to provide shift coverage with the augmented onsite staff. Normal shift staffing resumed
during the subsequent shifts on March 14. The plant remained operating at full power
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throughout the period. Both offsite power and onsite emergency supplies remained available.
No operational problems were encountered,
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No inadequacies were identified in the licensee's response to Storm Joshua. The inspector
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concluded the licensee contingency planning and actions were timely, prudent and effective to
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assure both plant and personnel safety.
2.6
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Event Description
On March 23, at approximately 8:44 a.m., with the unit at full power and while establishing
conditions to perform a flux map, the control room operators observed rod cluster control
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assemblies (RCCAs) 31 and 32 partially insert into the reactor core by approximately 45
steps. RCCA 31 and 32 are in control Bank B (group 8), and are located at the periphery of
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the core. At approximately 9:15 a.m., the licensee initiated actions required by the technical
specifications to align the Bank B RCCA's. During the alignment, RCCA 31 and 32 again
inadvertently inserted into the core by an additional 100 steps. Based on the improper
control rod operation, the operators initiated a manual reactor trip. All safety systems
responded as designed after the reactor trip. However, the high pressure steam dump
(HPSD) control system malfunctioned, resulting in a small unexpected plant cooldown. The
secondary reactor operator took prompt action to isolate the HPSD system and stop plant
cooldown. At 9:55 a.m., CYAPCo informed the NRC Operations Center pursuant to 10 CFR 50.72(b)(2)(ii) of a condition resulting in a manual actuation of the reactor protection
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system.
Operator Response
The inspector was in the control room at approximately 9:00 a.m. At that time, the control
room operators were performing actions within AOP 3.2-23, " Malfunction of the Rod
Control System," and annunciator procedure (ANN) 4.20-20, "NIs PR Channel Deviation."
The specific actions were to place the rod disconnect switch in disconnect for RCCA's 31
and 32, and to adjust the nuclear instrument gains. The operators also appropriately entered
into TS action statement 3.1.3.c.1, which requires the operator to either align all RCCAs
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within the bank to within 24 steps within one hour, or be in a HOT STANDBY condition
within six hours. At 9:15 a.m., the primary operator began to align the unaffected Bank B
RCCA's to within 24 steps of rods 31 and 32. As soon as the operator initiated rod motion,
RCCA 31 and 32 inserted an additional 100 steps into the core.
The senior control operator (SCO) immediately recommended to the shift supervisor that the
reactor be tripped. The shift supervisor acknowledged the recommendation, and ordered a
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reactor trip. Non-involved personnel either left the control room, or did not distract the
control room operators as they implemented the emergency operating procedures. The
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communication between the SCO and the reactor operators (ROs) was precise, and very well
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controlled. The inspector observed excellent implementation of procedures E-0, " Reactor
Trip or Safety Injection," and ES-O.1, " Reactor Trip Response." All RCCA's fully inserted
into the core, and safety systems functioned as required.
The inspector observed very good actions by the secondary plant RO following the trip. The
RO quickly recognized from board indications that an abnormal cooldown was in progress.
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Specifically, pressurizer pressure and level were low at 1820 psig and 25%, respectively,
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and, reactor coolant system average temperature was below the expected post-trip value of
535 degrees F. The RO recognized that no main steam or pressurizer code safeties had
lifted, and that the HPSD was controlling reactor coolant system Tave. The operator isolated
the HPSD by shutting motor-operated valves MS-MOV-520 and MS-MOV-553. The
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cooldown stopped at a RCS Tave of 525 degrees F, and with pressurizer pressure at 1780
psig, and pressurizer level of 17%. The secondary RO's prompt actions stabilized the plant
and avoided the potential complications of a safety injection (pressurizer pressure at 1700
psig) in this case. The plant was stabilized at normal post-trip conditions.
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Corrective Actions
CYAPCo work planners, the outage coordinator, and representatives from each department
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met at 10:30 a.m. to discuss the scope of necessary work activities, and the duration of the
forced outage. The inspector observed good discussions by the group to identify the
cerrective maintenance, preventative maintenance, and surveillances that should be done
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during the outage, beyond that needed to identify the cause for the HPSD and the rod control
system malfunctions.
,
The licensee identified on March 23 that the cause the RCCA insertion was a loose mechani-
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cal arm on the contactor in the power supply to the stationary coils. The details regarding
j
this failure and the licensee's corrective actions are documented in Section 3.1 of this report.
No specific cause was identified for the HPSD control system malfunction. Shortly after the
'
trip operators identified that steam dump temperature control valve TCV-417-B4 was
partially open. However, troubleshooting and calibration of this temperature control valve
and the seven other valves did not identify a circuit malfunction. The valves were stroke
tested and subsequently operated properly.
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The Plant Operations Review Committee (PORC) reviewed the post-trip documentation, root
cause determinations, operator actions, and plant response. Engineering personnel confirmed
that the plant responded as expected. The PORC recommended re-start of the unit based on
identification of the cause of the rod control problem, and will continue to evaluate the
HPSD malfunction by keeping the issue open in a control routing.
The inspector compared the plant response with two partially inserted RCCA's to the
dropped rod analysis described in Section 15.2.6 of the Updated Final Safety Analysis Report
(UFSAR). The review was performed to determine whether the unit response was bounded
by the assumptions in the UFSAR analysis. The analysis assumes only one RCCA fully
inserts into the reactor core, whereas on March 23 two RCCA's partially inserted into the
core. The plant conditions and response were bounded by the seven assumptions in UFSAR
section 15.2.6. No unsafe condition existed, nor were there any challenges to the safety
limits. The inspector did note that AOP 3.2-23 requires the operator to manually trip the
reactor if more than one RCCA fully inserts into the core. The principal reason for this
requirement is to ensure that plant conditions remain bounded by the UFSAR analysis.
Conclusions
The inspector observed the event from the control room and noted that the communication
between control room operators was precise, and well controlled while implementing the
emergency operating procedures. The root cause of the rod control system malfunction was
appropriately identified prior to a plant restart. The plant responded as expected to the
dropped RCCAs, and safety limits were not challenged.
2.7
Strike Contingency Plan
Plant workers are represented by the International Brotherhood of Electrical Workers (IBEW)
Union, Local 457. The three year union contract expired on March 1,1993. Plant workers
continued to work without a contract as negotiations continued. The inspector reviewed the
licensee's plans and actions for responding to a work stoppage in the event of a job action.
j
Licensee planning was formalized six weeks before the expiration date.
The inspector focused on the licensee's plans to meet the minimum shift staffing require-
ments specified in Technical Specification 6.2.2 for operators, fire brigade members, and for
personnel experienced in radiation protection procedures. The inspector also reviewed the
licensee's staffing plan to assure continued performance of surveillance and testing activities
as required by the technical specifications.
The inspector determined that the licensee could staff three operating shifts with exempt
personnel who possessed either senior reactor operator (SRO) licenses or operator licenses,
as required. The licensee also identified those licensed personnel who would first have to
stand watch for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to activate their licenses. These personnel would stand watch in a
training status under the supervision of the operating shift prior to crediting use of their
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licenses to meet the minimum staffing requirements for the watch bill. The shifts would be
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staffed with members of the training department or former operators who had plant specific
knowledge. The licensee also planned to use at least one supervisory control room operator
(with an SRO license) on each shift in auxiliary operator position. This was a good licensee
initiative to assure that in-plant activities would be directed by a supervisor having good
,
familiarity with present plant operating conditions.
.
t
To meet fire protection program requirements, the licensee planned to use a four-person
complement of security shift supervisors, who were fully qualified fire brigade members at
<
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Haddam Neck. The four-person guard contingent together with the duty SCO would staff the
required five-person fire brigade. This brigade would be implemented immediately to staff
the first shift. Arrangements were also made to bring 12 fully qualified fire brigade
personnel from Millstone to the Haddam site during the first shift of contingency staffing.
After completing a 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> training session on CY site specific fire protection features, these
personnel would be available to join the three operating shifts. The licensee had further
,
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plans to qualify additional personnel for fire brigade duty.
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No inadequacies were identified regarding the licensee's plans to staff the operating shift with
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operations, maintenance and I&C personnel. The licensee plans assured an adequate number
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of workers on each shift to safely operate the plant and to meet license conditions. The
licensee's contingency plans also assured adequate numbers of personnel were available to
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implement the emergency plan. A new three year contract was accepted by the union on
'
March 12,1993. The inspector identified no inadequacies in the licensee's contingency
!
plans.
2.8
Plant Startup
The inspector observed control room activities on March 24 to restart the plant in accordance
with procedure NOP 2.1-2, " Reactor Startup " The review was conducted to assure, by
direct observation, that the plant was ready to be restarted in accordance with the technical
specification requirements, and that the approach to criticality was conducted in accordance
with licensee administrative controls. The following observations were made:
Shift staffing met requirements and activities within the control room were well
e
controlled by the shift supervisor. Only personnel directly involved with the restart
were present. Management personnel monitored the restart.
Plant staff provided timely support to the operators as needed to address operational
needs. This included actions by I & C personnel to adjust control rod position
indication. Reactor engineering provided good assistance to complete inverse
multiplication plots during the approach to criticality and by providing prompt updates
to the estimated critical rod position during a period of rapid change in xenon
reactivity worth.
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The following technical specification (TS) requirements were verified to be met
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during the restart: - TS 3.1.3 - shutdown margin and control rod position; TS 3.1.1 -
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moderate temperature; TS 3.4.1 - reactor coolant system and pressurizer operation;
TS 3.5 - operable ECCS systems; TS 3.7.1 - operable auxiliary feedwater systems;
and, TS 3.8 operable normal and emergency power systems.
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The primary plant reactor operator declared the reactor critical at 3:08 p.m. with cor. trol rod
bank 'B' at 70 steps withdrawn. This agreed favorably with the estimated critical position of
97 steps on bank 'B'. The approach to critical was completed in a safe and orderly manner.
The shift supervisor and the supervisory contml room operator maintained good control over
plant staff and operator activities. The main generator was phased to the grid at 7:45 p.m.
l
The unit returned to full rated power on March 25 at approximately 6:45 a.m. No inadequa -
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cies were identified by the inspector during the startup. ,
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2.9
Plant Downpower Due to Noise in 'B' Main Feed Pump
l
On March 15 at 11:10 a.m., CYAPCo commenced a plant load decrease after operators
noted noise from the 'B' main feed pump motor. Plant power was reduced to 60% of rated
to shutdown and inspect the feed pump motor. CYAPCo identified a piece of shroud gasket
material lodged in the feed pump motor air vents. Although most of the gasket material had
.
been removed prior to initial motor operation at the facility as recommended by the vendor,
a small piece had remained undetected until it became loose on March 15.
.
Licensee mechanics removed the gasket material and engineering personnel inspected the
motor for damage. No motor damage occurred and the pump was restarted satisfactorily.
CYAPCo returned the pump to service and the plant reached full rated power on March 17.
,
2.10 Entry into Technical Specification Limiting Conditlom for Operation During
-
Performance of Surveillances
NRC Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection
Manual Sections on Resolution of Degraded and Nonconforming Conditions and Operabili-
ty," was issued to ensure consistency in the application of operability guidance by NRC
personnel. No specific action was required by the licensee in response to the generic letter.
Inspector review of the guidance determined that if the technical specifications (TS) required
that safety equipment be removed from service and rendered incapable of performing its -
intended function, the equipment is inoperable and the limiting conditions for operation
(LCO) must be entered unless the TS explicitly directs otherwise. The inspector noted that
CYAPCo actions do not always conform with the NRC guidance. Specifically, the licensee
does not consistently enter TS LCO's during the performance of operability surveillances that
render the equipment inoperable. An example of this practice was on March 16,1993 when
the shift supervisor logged completion of TS surveillance SUR 5.1-13B, " Auxiliary Feed
Pump P-32-1B Functional Test," at 10:10 a.m. The system was rendered incapable of
L
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performing its safety function since the normally locked open manual discharge valve (FW-
l
V-153) was closed during the test. However, the licensee did not enter the TS LCO
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3.7. L2.a.
!
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The licensee historically has recorded the performance of surveillances in the station log and -
)
has noted the completion time of the test. CYAPCo credits TS LCO references within the
i
surveillance as a measure to ensure operator awareness of TS applicability and allowed
'
outage times. Further, CYAPCo stated that periodic Plant Operations Review Committee
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(PORC) review of surveillance procedures assures that the test can be completed safely and
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in accordance with the TS allowed outage times. ' Routine resident inspection has not
1
identified a condition where performance of a TS surveillance has exceeded the allowed
j
outage time.
I
This general topic was discussed on March 23,1993 during a meeting between the licensee
and the NRC staff. In accordance with the guidance in Generic letter 91-18, the NRC staff
i
will allow the licensee time to review its practices and to make improvements to its proce-
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dures and technical specifications, as needed, to assure that adherence to the guidance will
,
not cause undue disruption to stable plant operation. The licensee agreed to improve
i
operator sensitivity to this issue. The licensee further agreed to inform the staff how plant
procedures will be revised to assure better conformance with the guidance in the future. The
>
!
schedule for this effort is under development. Additionally, the licensee intends to partici-
'
pate in the industry initiative to address the intent of the NRC's guidance. -The inspector had
no further questions regarding this matter at this time. Licensee actions to meet technical
' specification LCOs during surveillance testing is routinely reviewed during resident inspec-
'
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tions.
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3.0
MAINTENANCE AND SURVEILLANCE (61726,62703 and 71707)
i
3.1
Maintenance Observation
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The inspectors observed portions of the followmg maintenance activities for comphance with
procedures, plant technical specifications, and applicable codes and standards. The inspec-
^
. tors verified appropriate quality services division (QSD) involvement, appropriate use of
.
safety tags, acceptable fire prevention controls, and appropriate personnel qualifications. The
'
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inspector also verified the correct return to service of safety _ equipment. Portions of
activities reviewed included:
I'
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e CY 93-03306, High Pressure Steam Dump Calibration
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e CY 93-03302, Steam Dump TLV-417-B4 Positi6ner Replacement
e CY 92-06456, Steam Dump TLV-417-A4 Positioner Replacement
,
. e CY_93-3222, Shutdown Bank.'D' Indication Adjustment
1
o CY 93-2089, Wide Range #2 Spiking
e CY 93-2169, Power Range #3 Isolator ReplacementL
4
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' e CY 93-3264, Control Rod 31 & 32 Malfunction
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e CY 93-1961, Power Range #4 Isolator Replacement
I
e CY 93-3308, Reactor Trip Breaker Closing
CY 93-3264, Control Rod 31 & 32 Contactor Replacement
l
The inspector reviewed licensee actions under CY 93-3264 to investigate and repair a
l
malfunction in the rod control system on March 23. While establishing conditions to
perform a flux map, the operator manually inserted control bank 'B' at 8:45 a.m. This
action resulted in the partial insertion of group 6 rods 31 and 32, causing them to be 45 steps
below the remaining 6 rods in bank 'B'.
After preparing to realign the rods with the bank,
!
the operator attempted to manually insert rods at 9:15 a.m. This action resulted in further
insertion of rods 31 and 32 by another 100 steps. The operator immediately scrammed the
reactor after the second uncontrolled rod motion.
l
Licensee inspection of the rod control system components identified a faulty contactor that
I
was in series with the common power supply to the stationary coils of rods 31 and 32. The
contactor is a Westinghouse Type MM 310, Style 1502677 direct current, single pole,
magnetic contactor. Specifically, two fasteners were loose which allowed the moveable
portion of the main contact to become misaligned with the stationary contact and thereby
interrupt the 125 Vdc power supply to the stationary coils (reference drawing 16103-32121
sheet 16, " Control Rod Sequencing Circuitry VII"). The fasteners were loose in spite of the
,
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presence of lock washers provided to assure the connection remained secure. The fasteners
were re-tightened after replacing the lock washers as a precautionary measure. Additionally,
i
the licensee inspected the remaining contactors used for other coils (stationary, moveable and
,
lift) in the rod control system to assure they were tight. No other loose fasteners were
found. Finally, the licensee intends to add a requirement'to the procedure PMP9.5-2, " Rod
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Control System Preventive Maintenance," to check the fasteners once per operating cycle.
Inspection of this area also included a review of rod control system electrical drawings,
discussions with maintenance personnel, and a review of the components in the rod control
cabinets in the 'A' switchgear room. The inspector verified the licensee's root cause
determination for the control rod malfunction. The failure of the stationary coil contactor to
close as required would allow the control rod to free fall into the reactor until the moveable
coil is energized in the next step of the sequence to move (insert or withdraw) a control rod.
The inspector also reviewed the preventive maintenance performed on the rod control system
per PMP 9.5-2. This review considered the number of components in the rod control
system; the number of checks included in the PM procedure; the recommendations for PM
described in Westinghouse Instruction I.L.10245A for Type MM Contactors; and, the
failure history of control rods and contactors at Haddam Neck, and in the industry.
Although control rod failures have occurred in the past, none were attributable to loose
fasteners. The stationary coil contactor for rods 31 and 32 has not been replaced recently,
and is most likely original equipment for the plant. Based on this review, the inspector
concluded the PMP 9.5-2 was reasonably complete in view of the complexity of the rod
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14
control system. Further, the control rod malfunction on March 23 would not have reason-
ably been prevented. The proposed revision to PMP 9.52 to include a check of the fasteners
4
is a good enhancement to the PM program.
'
The inspector concluded the licensee actions to investigate and repair the rod control system
malfunction were thorough. No inadequacies were identified.
CY 93-3308, Reactor Trip Breaker Closing
The inspector reviewed licensee actions under CY 93-3308 to investigate the 'B' reactor trip
breaker. The breaker would not close reliably during the conduct of routine surveillance
testing on March 24 with the reactor shutdown in operational Mode 3. The licensee
identified the need to adjust the actuating arm for an interlock that prevented latching the
4
main breaker coil in the "after-trip" position. The inspector interviewed maintenance
,
personnel and reviewed the operation of the breaker to verify that the problem could not
prevent the breaker from opening in response to a manual or automatic trip signal. The
inspector noted that the maintenance personnel were very knowledgeable of the breaker and
its operation. No inadequacies were identified regarding the licensee's corrective actions.
'
3.2
Individual Rod Position Indication
On March 7, CYAPCo identified that the individual rod position indication (RPI) for RCCA
30 deviated from the average RPI for the group, and deviated from the group position
4
indication system (group step counters). The position deviation exceeded the TS 3.1.3.2
'
requirement. Spurious RPI deviations occurred six times between March 7 and March 9.
The control room operators entered action statement 3.1.3.2.a. during each occurrence. The
operators either logged out of the TS when the control room annunciator cleared (the RPI
returned to within the allowed band), or requested I&C specialists to perform a rod calibra-
tion pursuant to CMP 8.2-70, " Rod Position Indication System Adjustments at Power." On
March 10, CYAPCo initiated a plant downpower to less than 90% rated to perform trouble-
shooting on control rod 30 circuitry. PIR 93-032 was written to document this issue. The
power reduction was performed as a precaution since the proposed troubleshooting would
remove the main turbine runback feature on a rod drop for five of the RCCA's. The turbine
runback feature is not applicable at less than 90% power. The troubleshooting did not
identify a cause for the periodic RPI deviation.
CYAPCo swapped the signal conditioner drawers for rods 30 and 31 as troubleshooting
'
activities continued on March 16. The inspector verified that the appropriate TS action
statement and troubleshooting precautions were adhered to. By swapping the conditioner
drawers, CYAPCo identified that capacitors and the span adjustment potentiometer had
degraded in the drawer for rod 30. The licensee repaired the components and restored the
rod 30 to an operable status.
_ _ - ..
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NRC inspection report 50-213/88-08 documented deviations between individual RPI and the
average of GPI was a chronic problem. CYAPCo concluded, based on the operating
experiences, that temperature changes in containment, and the control room cause deviations
in the output of the linear variable differential transformers (LVDTs) from which the RPI is
derived. Additionally, secondary output signals are not linear during the course of full rod
motion. The plant process computer is used to adjust the LVDT output signal to reflect
I
expected motion of individual RPI. The correction factors used by the computer were
derived from test data.
The licensee has rebuilt the rod control system signal conditioning circuitry, developed
computer =cdeling to track expected rod position, maintained operator sensitivity, and
i
developed appropriate operability determinations as required. Future actions under consider-
ation to improve individual RPI performance include: an engineering evaluation by project
services engineering under project assignment 89-054; and, the development of a special test
,
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by reactor engineering to quantify and characterize temperature effects on the LVDT and
j
signal conditioning circuitry. The inspector had no further questions regarding licensee
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planned actions at this time.
In summary, the inspector identified no inadequacies in licensee activities to address RPI
deviations during this period. Corrective actions were thorough to address faulty components
l
in the signal conditioning drawer for rod 30. The licensee has taken significant actions in the
l
past to address RPI problems, and plans to address this problem further through special
testing are a good initiative.
4.0
ENGINEERING AND TECIINICAL SUPPORT (71707)
4.1
Loose Parts Monitoring System
The loose parts monitoring (LPM) system continuously monitors reactor vibration using
accelerometers on the reactor vessel. The monitored locations ace designed to detect metal-
like impacts in the reactor as they occur. The system is not listed in the technical specifica-
tions, nor is it described in the UFSAR as a required plant feature. The system was installed
as a licensee initiative in 1987 under plant design change (PDCR) 921, "Imose Parts Monitor
Installation." The LPM was installed following repairs to the reactor internals with the
primary purpose of monitoring performance of the thermal shield during subsequent plant
operations. However, the reactor thermal shield was permanently removed during a
subsequent plant outage. The licensee initially intended that the system design and installa-
tion nieet the requitements of NRC Regulatory Guide 1,133; the systen1 requirements were
subsequently changed to ASME OM 12.
The inspection included a review of the controls for, and the past performance of the LPM
l
system. The inspector reviewed plant information reports (PIRs) and LPM procedures, and
walked down portions of the system. There have been four PIRs issued against the LPM
l
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16
system since 1989. The PIRs described problems with rebooting the software after an alarm,
4
damage to the system due to lightening, and, response to " impact-events."
NUSCo Component Test Services (CTS) provides significant support for the system during
routine system operations and testing. ACP 1.0-58, " Loose Parts Monitoring System,"
provides the CYAPCo controls for use of the system. No specific procedure exists at
Haddam Neck to perform functional tests of the LPM system.
NUSCo CTS provided assistance to CYAPCo in start-up and testing of the LPM system in
February,1992, following the refueling outage. The testing demonstrated that 4 out of 6
accelerometers could detect and record mechanical impacts. Two sensors (#4 and #5) are
considered inoperable by CYAPCo due to unresolved cable penetration deficiencies. The
most recent ' impact-like' event (January 21, 1992) was evaluated by CTS. The event was
registered at channel #3 (upper reactor vessel head). The NUSCo evaluation concluded that
the ' impact' was mechanical noise associated with routine control rod movements.
As part of PDCR 921, CYAPCo intended to update the UFSAR, and to provide on-going
technical training to plant personnel on the LPM system. As of this inspection period, the
LPM system is not described in the UFSAR. The last technical training provided on the
system was in June,1991. No on-going training has been provided to instrumentation and
control (I&C) specialists. When questioned regarding the system status, licensee engineering
acknowledged that the PDCR package was still open and its completion had been given a low
priority.
Conclusion
The inspector noted the LPM system at Haddam Neck is operational and is used to monitor
reactor conditions. NUSCo CTS personnel support calibration, testing and maintenance of
the system. No formal procedure exists to document reproducible calibrations. The PDCR
installing the system is still open and action to update the UFSAR and to train site staff are
'
incomplete. Although there are no regulatory requirements or commitments regarding use of
_
the system, the inspector determined that the licensee could improve the calibration proce-
dures for the LPM, as well as the training provided to instrumenta' ion specialists.
4.2
Service Leak Water
On March 8, CYAPCo identified two pinhole leaks in the six inch service water supply to
the 'B' emergency diesel generator (EG-2B). Leakage points were located at a butt weld
joint approximately ninety degrees apart. CYAPCo identified the leaks while preparing the
surface for ultrasonic wall measurements pursuant to work request CY-92-12463.
CYAPCo initiated non-conformance report 93-016, PIR 93-027, and actions prescribed in
NRC Generic Letter 90-05, " Guidance For Preforming Temporary Non-code Repair of
ASME Code Class 1,2, and 3 Piping." CYAPCo immediately characterized the flaw, and
.
4
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17
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measured the leakage at approximately fifteen drops per minute. NUSCo engineering
j
supported CYAPCo engineering by providing an operability assessment. The assessment
'
concluded that the structural integrity of the piping was acceptable, since: the pin holes were
less than 1/32 of an inch; ultrasonic test results concluded the wall thickness was within
]
87.5% of nominal wall, and estimated wall loss until the refueling outage (starting May 15)
is not expected to reach minimum wall. The inspector noted that isolation of the service
j
water leak would require isolation of one of the two service water headers, resulting in
!
entrance into a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> action statement.
!
}
The inspector concluded that the licensee provided an adequate basis for short-term operabili-
l
ty. CYAPCo is submitting a request for relief from the ASME code in accordance with the
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guidance of NRC Generic Letter 90-05. The acceptability of CYAPCo's request will be the-
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subject of NRC:NRR review.
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5.0
SAFETY ASSESSMENT AND QUALITY VERIFICATION (40500,71707,
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90712, and 92701)
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5.1
Plant Operations Review Committee
i
The inspectors attended several Plant Operations Review Committee (PORC) meetings. The
1
inspectors noted technical specification 6.5 requirements for required attendance wem met.
The meeting agendas included review of procedural changes, proposed changes to the
!
Technical Specifications, Plant Design Change Records, and minutes from previous meet-
j
ings. The inspectors noted the PORC meetings were characterized by frank discussions and
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questioning of the proposed changes. In particular, consideration was given to assum clarity'
i
and consistency among procedures reviewed. Items for which adequate review time was not
'
available were postponed to allow committee members time for further review and comment.
j
Dissenting opinions were encouraged and resolved to the satisfaction of the committee prior
{
to approval. The inspector concluded the committee closely monitored plant performance
and conducted a thorough assessment of plant activities.
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5.2
Review of Written Reports-
4
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The inspector reviewed Monthly Operating Report 93-03 for clarity, accuracy and safety
significance description, and to determine whether further information was' required. The
inspectors also verified that the reporting requirements of TS 6.9 had been met. The
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inspector concluded the report was acceptable.
4'
5.3
Cycle 17 Refuel Outage Planning
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The inspectors evaluated CYAPCo actions related to planning for the cycle 17 refueling
outage. - The refueling outage is currently scheduled to begin on May 15. The inspection
' consisted of discussions with the outage manager, cognizant engineering personnel, planners,
department supervisors, and managers. The inspector attended a refueling outage meeting,
'
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18
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and reviewed administrative control procedure (ACP) 1.0-78, " Outage Planning, Scheduling,
and Implementation." The review focused on CYAPCo shutdown risk initiatives, plant
modifications and the work order deferral processes.
Results
In November,1992 CYAPCo prepared the first administrative procedure to outline methods
for preparation and conduct of scheduled outage. The inspector noted that various terms and
job responsibilities that existed in past outages were now proceduralized. One major change
to the method of outage planning is the ongoing work of shutdown risk management by .
- CYAPCo. At the end of the inspection period, an outage schedule safety num< ment team
was formed. The team consisted of the engineering manager, Instrument & Controls .
Manager, representative from the operations department, the maintenance electrical supervi-
sor, and a NUSCo individual knowledgeable in probabilistic risk assessment.' A major task
of the group was to evaluate all systems out of service (SOS) work activities to verify that
safety function requirements (of ACP 1.0-78, Attachment 12.1) were maintained. The safety
function requirements are for decay heat removal, electrical power availability, reactivity
control, reactor coolant inventory, and containment control. ACP.I.0-78 also details a
process to evaluate emergent work activities during the outage. Each of the emergent .
activities will be evaluated to ensure the safety function requirements are preserved; this
safety assessment will have concurrence from the outage manager.
During the inspection period, the outage manager position was permanently filled by an
experienced senior reactor operator with previous experience in daily planning activities.
The outage manager is a new full-time position within CYAPCo's organization.
On March 25, the inspector observed a monthly outage planning meeting. During the
meeting, the licensee listed the status of action items to resolve prior to the outage. The
licensee also solicited any comments or issues yet to be resolved. Examples of action items
discussed were working hours, impact of changes to administrative control procedures on
retest requirements and station tagging, status of engineering project assignments, and -
various safety equipment outage schedules. Each action item was assigned a responsible
individual for resolution, and provided a commitment date for completion. - It was apparent
to the inspector that action items were over-due from the previously arranged completion
date. . In addition, it appeared that significant outage planning and scheduling milestones were
delayed. The meeting did provide a forum to discuss the delays, their reasons, and the
management expectation for completion of individual iten)s.
On March 10, the inspector observed a meeting to discuss engineering modifications planned
for the refueling outage. The meeting included all discipline organizations. The purpose of
the meeting was to evaluate modifications and determine which will be implemented,
deferred, or removed from consideration. Prior to the meeting, each of the eighty-six (86)
modifications was prioritized as "must do", "need to do", and "want _to do". The prioritiza-
tion was based on either NRC commitments, significant risk of a forced outage, correction of
_ _ _
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19
plant equipment failure or deficiency that impacts plant operation, or improve the operability,
maintainability or design of plant equipment. Approximately twenty-five percent of the
modifications were deferred from implementation during the Cycle 17 refueling outage.
The inspector selected five modifications that had been deferred to understand the why the
change was initiated, the reasons for deferral, why plant safety is not impacted by the
,
deferral, and tracking of the deferral. The modifications specifically reviewed were plant
design change records (PDCRs) 1368, " Replacement In-Core Sump level Transmitter,"
i
1277, " Motor Operator Valve Overload Trip Indication Circuit Modification," and 1354,
" Containment Air Recirculation Fan Service Water Instrumentation," and replacement item
evaluations (RIES) CYOE 93-29 " Replacement of FW-CV-153/184," and CYOE 93-05,
" Loop Stop Valve Operator Replacement." The plant modifications were initiated for a
variety of reasons, including: consolidation of instrumentation; problems with transmitter
calibrations; replacement of a commercially-dedicated item with QA Category I item;
corrective actions proposed in response to a past NRC Information Notice and plant
information report (PIR); problems acquiring spare parts; and, on-going maintenance
,
'
corrective items. Generally, the reasons for deferral included removal of component safety
function due to another plant modification, acceptable component performance, procedural
changes, training awareness, or lack of importance of an instrument based on indication from
other safety-related instrumentation. The tracking of deferred modifications will be main-
tained by each respective system engineering supervisor. The deferred items may be
accomplished during non-outage operations, or scheduled for the next refueling outage.
The inspector concluded that CYAPCo provided reasonable justification to defer plant
modifications. For the specific modifications reviewed, deferral does not impact plant
safety, nor any previous NRC commitments. An appropriate level of oversight exists for the
final decision to perform or not perform the modification during the outage.
The inspector also reviewed CYAPCo's process to reschedule the performance of corrective
and preventive maintenance activities. Principally, licensee personnel determine if the
activity needs to be completed during an outage. Approximately 8 - 10% of previously
planned work activities will not be performed during the refueling cutage. For activities that
could be performed during power operation, CYAPCo has initiated a ' system of the month'
schedule to perform maintenance on systems during power operation. Recent examples
include work on the steam generator blowdown system, fire protection system, steam system
traps, and spent fuel pit heat exchangers. The inspector concluded that the system outages
during power operation were appropriately planned, and had no impact on safety-related
equipment or functions.
On March 15, the inspector reviewed seventeen work orders that have been deferred from
the outage. Based on the individual work scope and CYAPCo reasons, it was apparent that
appropriate justification existed for deferral.
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20
5.4
Nuclear Review Board
..
The inspector observed the meeting of the Connecticut Yankee Nuclear Review Board (NRB)
on March 18. The inspector verified that requirements for a quorum,' discussion items, and-
the approval of the meeting minutes were all satisfied. The inspector noted good probing
i
discussions concerning a proposed technical specification amendment to remove fim
.
protection requirements from the technical specifications. The NRB approved the amend-
' j
ment request contingent upon maintaining the NRB audit role. Good discussion was noted
i
concerning the reporting of fire protection issues, as affected by revised. wording in the
i
license condition.
Three open items carried forward (ICF) were developed during the meeting. The items
concerned a programmatic review of valve operator environmental qualification issues as
'
.
l
described in NRC inspection report 50-213/92-22, verification of proper closure of the 1990
.1
Combined Utility Assessment Team audit findings, and issuance of a document informing the
Executive'Vice-President'- Nuclear of on-going welding practices and program deficiencies.
The deficiencies as highlighted in QSD audit 30201, " Field Welding Control."
t
The NRB chairperson announced to the board that effective May 1,1993, the Vice-President
Nuclear, Engineering Services will be the new board chairman. -The change is intended to
provide a higher level of management participation in the nuclear oversight group. The
current NRB chairperson will be assigned as vice-chairperson, and the current vice-chairper-
son will be assigned as a member.
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6.0
MANAGEMENT MEETINGS
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6.1
Exit Meetings
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During this inspection, the inspector held periodic meetings with station management to '
discuss inspection observations and findings. At the end ,of the inspection period, an exit-
meeting was held on April 6,1993, to summarize the conclusions of the inspection. No
i
_
written material was given to the licensee and no proprietary information related to this
inspection was identified.
In addition to the resident inspector's exit meeting, the following exit meeting was held for
an inspection conducted by Region I based inspectors during this report period.'
- Inspection
Reporting .
Areas
Reoort No.
Dates
Inspector
Inspected
l
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93-02
3/26-29/93
J. Lusher -
EP Exercise
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6.2
Management Meeting
On March 17, 1993, from about 10:30 a.m. to 12:30 p.m., Messrs. John Opeka and
,
Richard Kacich of Northeast Utilities (NU) met with Mr. T. T. Martin, Regional Adminis-
'
trator, and five other NRC Region I managers at the NRC Region I office. The meeting was
held at NU's request to discuss the results of recent NU economic analyses related to
Haddam Neck. Although meetings between NRC and licensees are typically open for public
observation, NRC approved NU's request for a closed meeting, because the meeting
(1) included NU proprietary business information and (2) had no dimet substantive connec-
tion to any specific regulatory decision or action.
Attachment I provides the licensee's non-proprietary presentation materials. Attachment II is
the licensee's affidavit supporting their request for a closed meeting. At the meeting, the
licensee discussed the increasing influence of competitive forces and economic regulation on
the continued operation of nuclear units, briefed NRC management on preliminary results of
the economic analysis for Haddam Neck, and provided their views on associated regulatory
implications. No commitments were made by either NU or NRC, nor were any NRC
positions or decisions provided. In addition to Mr. Martin, NRC Region I attendees included
William Kane, M. Wayne Hodges, Susan Shankman, James Wiggins and Randolph Blough.
.
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ATTACHMENT 1
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NU;
COMPETITIVE FORCES, ECONOMIC
REGULATION, AND THEIR IMPACTS
1
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MARCH 17,1993
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NU;
PURPOSE OF THE MEETING
TO DIALOGUE WITH THE NRC STAFF ABOUT THE INCREASING
INFLUENCE OF COMPETITIVE FORCES AND ECONOMIC REGULATION
ON THE CONTINUED OPERATION OF NUCLEAR POWER. PLANTS
,
TO PRESENT THE PRELIMINARY RESULTS OF THE HADDAM NECK
PLANT ECONOMIC ANALYSIS
PROVIDE PLANT SPECIFIC AND UTILITY SPECIFIC DETAILS ON A
NATIONWIDE PHENOMENON.
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NU
AGENDA
4
WHO ARE NU'S ECONOMIC REGULATORS
NU PRUDENCE HISTORY
PRUDENCE IMPACTS AND TRENDS
NU BUSINESS PLAN (THE " BUDGET GAP")
HADDAM NECK PLANT PRELIMINARY ECONOMIC ANALYSIS RESULTS
IMPLICATIONS FOR AND IMPACT OF NRC
SUMMARY AND CONCLUSIONS
3
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NU
WHO ARE NU's ECONOMIC REGULATORS?
DEPARTMENT OF PUBLIC UTILITY CONTROL (CT)
Connecticut Light & Power Company
DEPARTMENT OF PUBLIC UTILITIES (MASS)
Western Massachusetts Electric Company
PUBLIC UTILITY COMMISSION (NH)
Public Service Company of New Hampshire
FEDERAL ENERGY REGULATORY COMMISSION
Connecticut Light & Power Company
Public Service Company of New Hampshire
.
Connecticut Yankee Atomic Power Company
North Atlantic Energy Corporation
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[NU;
PRUDENCE HISTORY
1980's: COMPLETION OF MAJOR GENERATING CONSTRUCTION
.
PROJECTS
CONSTRUCTION PRUDENCE REVIEWS ACCOMPANIED THOSE
PROJECTS
STANDARD: WAS UTILITY'S CONDUCT REASONABLE?
IMPRUDENCE - A METHOD USED BY ECONOMIC REGULATORS TO
REDUCE CUSTOMER RATES AND THUS SATISFY CONSUMER
INTERESTS
LIMITED OPERATIONAL PRUDENCE CASES DURING THE 1980'S
SHIFT TO OPERATIONAL PRUDENCE IN THE 1990'S
. PRUDENCE EXAMPLES (See Next Page)
5
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<N E,
PRUDENCE CASES
NUCLEAR OPERATING PRUDENCE REVIEWS - MILLSTONE UNITS AND HADDAM NECK
DATE OF
NATURE OF
AMOUNT
UNIT
EVENT
OCCLIRRENCE
AT RISE
RESULT
COMMENTS
M855:
Costs desattowed on ground
Mass. DPU used NOV as basis
Haddam Neck
8-21 84
Pool seal f a4ure
$599.210
that desqq of seat by vender
for fmdmgs. OPU decision
during RFO
(25 days)
and testing by CYAPCO were irnputed reprudence of seat
(RPC)
def.oent; failure of POAC,
vender to CYAPCO and
NRB review p'ocess to
iroprudence of CYAPCO TO
determee whether new seal
WMECO.
desgn introduced new f ailure
rnodes was imprudent.
Not mvestgated in Connecticut.
Connectcut:
Disallowance in both
Fi st Connecticut nuclear
Haddam Neck
j t.3046
14C tecMicians repa nag
5 M S.000
jurisdctens based on tailure
prudence decision.
feed *ater regutaimg vetve
(PPC)
to supervise.
fa to d onnect wer
Mass.130
Massachusetts without
d0W
',
,,jppjng g,g
,
bours (RPC)
inhpendent investigation of
tacts,largeh on basis of
conciusions contained in LER
Connacticut
No disallowance -error
Several dra't decisions found
MJ! stone 2
g.27.o0
Operator irnproper-
$1.334.039
due to inadvertence, not poor
imprudeace; aftee change of
sy performed sur-
(nrC)
tudgment
Commissioners and NRC -
vemance on re. acto,
issuance of Finat Policy
perjec.;en 9ys ,m.
Statement on Possible Sa'ety
impacts of Economic
Pedormance incentives, final
dec'sion found no imprudence
and no disallowance warranted.
No deosea yet in
4
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NE
PRUDENCE CASES
NUCLEAR OPERATING PRUDENCE REVIEWS - MILLSTONE UNITS AND HADDAM NECK
DATE OF
NATURE OF
AMOUNT
L1811
EVENT
OCCURRENCE
AT RISK
RESULT
COMMENTS
This was first time DPUC
Costs at issue disallowed. on
Department hieed esped
Haddam Neck
9-02 09 to
0, mage to fuel rMs
Connectcut:
found dunng refuehn9
$230,000
grounds that CYAPCO acted
consultant to evaluate facts of
845-90
(RFO)
outage after thermat
(direct re?ueimg
imprudentty in f aihng to funy
event Commisson issued split
remove dabris from reacto'
decisen. with Cha rman issumg
shield repaws
costs);
$3.003.000 (RPC)
vessel cady aher thermal
strong dissent. CL&P has
shield repa
appeafed to court.
MassachuseMs:
$5.000.000
Awa:tmg ruling on request for
(PPC)
reconsteraten in
Adversary's case based in large
Damage to traveling
Connectcut.
Full disa!!owance on the
pad on Notco of Velaten
Mittstone 1
10-4 90
screens caused by
$2 g metiion
grounds operators f ailed to
seaweed influx
(APC)
follow p'ocedures and to
communicate property. Not
yet decided in Massachusetts.
Company notified both
Connecticut and MassachuseMs
Operator requahtication
Se milton CLP
Connectcut-
commiss ons that a would not
M,ilstc,e 1
10 1-9 t
termtnated docket
seek to collect replacement
osammation f ailu'es
(NU)
(approximatey
Massachusetts:
pn. , costs rotated to this outage
$5.5 million
not yet resolved
and requested termination of
CL&P)
docket on grounds that training
personnel were engaged in
enhancing traming program and
so could rot be spared to supped
prudence liigation efforts.
7
--
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4
NU
PRUDENCE CASES
NUCLEAR OPERATING PRUDENCE REVIEWS - MILLSTONE UNITS AND HADDAM NECK
DATE OF
HATURE OF
AMOUNT
L!MI
EVENT
OCCURRENCE
AT RISK
RESULT
_ COMMENTS
Recovery of Generaten
$41 m@on
Not yet
The Office of Consumer
ALL
1992
determined
Counsel and Connecticut
utilization ed ustment
i
Industrial Energy Consumers
clause
oppose any recovery by
(GUAC) deferrals
CL&P. CL&P has taken the
posite that the full amount
of the GUAC deferral should
be recovered, subject ony to
such dsallowances as enay
resu!t trorn the pending
Connectcut prudence
dockets.
Performance
Not yet
Not yet
The Office of Consumeer
ALL
1992
Enhancement Program
determined
determined
Counsel and Connecteut
industnat Energy Consumers
(PEP)evponses
have also proposed that rate
recovery of the costs of the
PEP should be $sallowed.
9
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[NU
PRUDENCEIMPACTS
DIVERSION OF RESOURCES
DOCUMENTS TO AND FROM NRC REVIEWED BY MANY OTHER ENTITIES; POTENTIAL FOR
MISINTERPRETATION EXISTS
CRITICAL AND INSIGHTFUL SELF-ASSESSMENT CAN BE USED AS ALLEGED BASIS OF
IMPRUDENCE
NRC DOCUMENTS USED:
NOTICES OF VIOLATION
AUGMENTED INSPECTION TEAM REPORTS
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORTS
INSPECTION REPORTS
NU DOCUMENTS USED:
LICENSEE EVENT REPORTS
RESPONSES TO NOTICES OF VIOLATION
NUCLEAR SAFETY ENGINEERING GROUP REPORTS
ROUTINE CORRESPONDENCE TO NRC
10
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PRUDENCE TRENDS
-COMPLETION OF MAJOR NEW CONSTRUCTION PROJECTS HAVE
SHIFTED FOCUS FROM CONSTRUCTION PRUDENCE TO OPERATIONAL
PRUDENCE
THERE IS PRUDENCE EXPOSURE IF OPERATION IS OTHER THAN 100%
POWER; OUTAGES ONLY WHEN PLANNED AND NOT EXTENDED
INCREASING USE OF DOCUMENTS TO AND FROM THE NRC TO ASSERT
lMPRUDENCE
INCREASING RESOURCES DIVERTED AWAY FROM SAFE AND.
ECONOMICAL PLANT OPERATION
FALLING THRESHOLDS FOR DISALLOWANCE
11
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NU
IMPLICATIONS FOR NRC
'
NRC DOCUMENTS CRITICAL OF LICENSEES ARE BEING USED AS
" PROOF OF IMPRUDENCE" (E.G.: NOVs, AIT REPORTS, SALP REPORTS,
INSPECTION REPORTS)
LICENSEE DOCUMENTS BEING USED AS " ADMISSION OF LIABILITY" BY
LICENSEES (E.G.: LERs, RESPONSES TO NOVs, NUCLEAR SAFETY ENG
GROUP REPORTS)
REINFORCE WITH THE THEME FROM THE 1991 FINAL POLICY
STATEMENT ON POSSIBLE SAFETY IMPACTS OF ECONOMIC
PERFORMANCE INCENTIVES
12
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IMPLICATIONS FOR NRC
FEDERAL REGISTER, VOLUME 56, NO.142
WEDNESDAY, JULY 24,1991
"THE COMMISSION IS ALSO CONCERNED ABOUT STATE PUBLIC UTILITY COMMISSION
RATEMAKING ACTIONS THAT MIGHT BE INTERPRETED AS PENALIZING A UTILITY FOR
IMPROVING ITS OWN PROCEDURES OR METHODS OF OPERATION. FOR EXAMPLE, WHERE
A STATE PUBLIC UTILITY COMMISSION OBSERVES THAT A UTILITY HAS MODIFIED ITS
PROCEDURES FOLLOWING AN INCIDENT, INFERS FROM THE UTILITY'S ACTIONS THAT THE
ORIGINAL PROCEDURES MUST HAVE BEEN INADEQUATE, AND THEN DISALLOWS CERTAIN
COSTS ON THE BASIS OF SUCH ASSUMED INADEQUACIES, THE UTILITY WILL HAVE A
STRONG DISINCENTIVE VOLUNTARILY TO ENHANCE OR IMPROVE ITS OPERATIONS AND
PROCEDURES IN THE FUTURE. SUCH STATE PUBLIC UTILITY COMMISSION ACTION CAN
DISCOURAGE UTILITIES FROM MAKING NEEDED IMPROVEMENTS IN PROCEDURES AND
OPERATIONS AND, THUS, CAN BE DETRIMENTAL TO THE LONG-TERM SAFETY OF
OPERATION."
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[NU
IMPLICATIONS FOR NRC
'
LICENSEE OBLIGATION TO OPERATE SAFELY
NRC MISSION TO PROTECT PUBLIC HEALTH AND SAFETY
NEED TO WORK TOGETHER, AT ARMS' LENGTH, TO ACHIEVE MUTUAL
OBJECTIVE, AT LOWEST POSSIBLE COST
IF NRC AGREES THAT A " CHILLING EFFECT"IS POSSIBLE, AND THE
PUBLIC INTEREST IS BEST SERVED BY NOT DISCLOSING SELF
CRITICAL DOCUMENTS, COMMUNICATE THIS TO THE ECONOMIC
"
REGULATORS
.
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NU;
ROLE OF NRC
MAJOR FACTOR IN WHAT COSTS ARE INCURRED TO SAFELY
GENERATE NUCLEAR POWER
GENERIC ACTIONS
PLANT SPECIFIC DECISIONS
NRC RESPONSE TO INDUSTRYWIDE INITIATIVE
.
NRC INITIATIVE TO ELIMINATE REQUIREMENTS MARGINAL TO SAFETY
ALLOWING LICENSEES TO MANAGE THEIR AFFAIRS, WHILE FULFILLING
,
'
REGULATORY MANDATE
PROMOTE A LEVEL PLAYING FIELD - STRIKING A BALANCE IN
DOCUMENTING STRONG OR ACCEPTABLE LICENSEE PERFORMANCE,
NOT JUST WHAT WARRANTS IMPROVEMENT
,
15
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[NU
ROLE OF NRC - PAST EXAMPLES
HNP - LIC AMENDMENT, USE OF XENON PIN EQUIVALENT TO MONITOR FUEL DAMAGE
HNP - CONTROL ROOM HABITABILITY
HNP/MP3 -THERMO-LAG, APPROVED USE OF TV CAMERAS
HNP/MP1 -ISAP: LICENSE CONDITION AND FRAMEWORK FOR CLOSURE OF ISSUES
MP1 - APPROVAL FOR CORRECTIVE ACTION PLAN FOR APP J TESTING (ILRT)
MP1 -TWOC AND EXPEDITIOUS TREATMENT OF TS CHANGE, MSL RAD MONITOR
MP2 -TIMELY ISSUANCE OF 2 AMENDMENTS SUPPORTING STARTUP (SG REPL)
ESAS CHANGES
FEEDWATER ISOLATION
MP2 - NRC CONCURRENCE THAT SG REPLACEMENT UNDER 50.59 ACCEPTABLE
MP2 - CERTIFICATE OF COMPLIANCE TO ALLOW SG SHIPMENT AND BURIAL (NATION'S
FIRST)
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ROLE OF NRC - PAST EXAMPLES
(CONTINUED)
MP2 - LIC AMENDMENT TO RELAX CONTAINMENT CONCRETE INSPECTION REQUIREMENTS
MP2 - APPROVAL FOR USE OF CE LEAK-BEFORE-BREAK TOPICAL REPORT
RE: NEUTRON SHIELD TANK CONSIDERATIONS
MP3 - APPROVAL OF QUARTERLY SURVEILLANCE TESTING ON ESFAS
MP3 -TWOC AND EXPEDITIOUS TREATMENT OF LICENSE AMENDMENT ON SLCRS
MP3 - EXPEDITIOUS APPROVAL FOR MISSED SURVEILLANCES FOR RTS
BREAKERS AND SNUBBERS
,
MP3 '--EXPEDITIOUS APPROVAL FOR EDG SURVEILLANCE CHANGE
MP3 - CONTAINMENT PRESSURE RELAXATION
APPROPRIATE APPLICATION / IMPLEMENTATION OF GL 91-18:
MP2 - NRC CONCURRENCE WITH OUR OPERABILITY ASSESSMENT OF THE SEISMIC
ANCHORAGE ON THE CONTROL ROOM EMERGENCY VENTILLATION SYSTEM
REFRIGERATION UNITS
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CY -INSPECTION REPORT 92-26 ENDORSES THERMO-LAG ASSESSMENT
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ROLE O= NRC - PENDING/ FUTURE ISSUES
PLANT SPECIFIC ISSUES:
HNP SG TUBE ALTERNATE REPAIR CRITERIA
MP1 REGULATORY GUIDE 1.97
MP1 APPENDIX J EXEMPTIONS (TYPE B&C)
MP1 COMBUSTIBLE GAS CONTROL
MP1 SPLIT BUS LOGIC DESIGN
MP1 HYDROGEN MONITOR
MP1 HARDENED VENT
MP2 SPENT FUEL POOL FUEL ASSEMBLY POISON RODS
MP3 SLCRS
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NU;
ROLE OF NRC - PENDING/ FUTURE ISSUES
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GENERIC ISSUES:
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THERMO-LAG EXEMPTIONS-
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SURVEILLANCE TESTING / LOGGING INTO ACTION STATEMENTS
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MAINTENANCE RULE - REASONABLE INTERPRETATION
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PROCUREMENT ISSUES
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SECURITY - BALANCED / REASONABLE RESPONSE TO WORLD
TRADE CENTER AND TMI EVENTS
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APPENDIX R - BALANCED RESPONSE TO THERMO-LAG RELATED
FINDINGS
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MINIMlZE ADMINISTRATIVE BURDEN ON OVERTIME. LIMITS
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GENERIC LETTER 89-10, SAFETY-RELATED
. MOTOR-OPERATED-VALVE TESTING
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ROLE OF NRC - PENDI\\G/ FUTURE ISSUES
GENERIC ISSUES:
SEISMIC UPGRADE OF PIPING - METHOD TO DEMONSTRATE
SEISMIC ADEQUACY
HNP/MP1: REMAINING ISSUES FROM SEP/ BULLETIN 79-14
UPGRADES
INNOVATIVE CONCEPT IN RESOLVING SEISMIC QUESTIONS BY
RECOGNIZING INHERENT FLEXIBILITY OF BUTT-WELDED PIPING
AND ACTUAL EARTHQUAKE EXPERIENCE DATA
APPLICATION OF NEW SOURCE TERM
MOVEMENT TOWARD RISK-BASED REGULATION
PARTIAL IMPLEMENTATION OF REVISED STS
FREQUENCY OF EMERGENCY PLANNING EXERCISES
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NU;
SUMMARY
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WHAT DOES BEING A MULTI-UNIT UTILITY MEAN?
SOME ECONOMlES OF SCALE / SYNERGIES
PLANT-SPECIFIC ECONOMICS DRIVE THE DECISION TO OPERATE
OR SHUTDOWN
JOINT OWNER ARRANGEMENT COMPARED TO WHOLLY OWNED PLANT
SUBMITTAL SCHEDULE FOR ECONOMIC ANALYSIS RESULTS:
HNP, MP1, MP2 - APRIL 1994
MP3, SEABROOK - APRIL 1995
. ANTICIPATE PERIODIC UPDATES OF ECONOMIC ANALYSES
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NU;
CONCLUSIONS
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NUCLEAR OPTION BECOMING LESS AND LESS OF A REALITY UNLESS
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COSTS ARE MANAGED
PRELIMINARY-RESULTS OF HNP ECONOMIC ANALYSIS DEMONSTRATE
'THE PLANT TO BE AN ECONOMICAL PRODUCER OF ELECTRICITY UNTIL
THE END OF CURRENTLY LICENSED LIFE BASED ON THE PLANT'S
BUDGET AND FORECAST FOR OPERATIONS AND EXPENDITURES
.
WHETHER ASSUMPTIONS CAN BE MET REMAINS TO BE SEEN
SCRUTINY WILL BE INTENSE
-SAFE OPERATION WILL NOT BE COMPROMISED
,
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ATTACHMENT 2.
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I, John F. Opeka, being duly sworn, depose and state as follows:
_
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1.
I am currently the Executive Vice President with Connecticut. Yankee
!
Atomic Power Company (CYAPCO).
. I am filing this affidavit in -
support of NNECO's request that the meeting with members of the
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Staff from Region 1 of the Nuclear Regulatory Commission ("NRC")
~
(Docket No. 50-213), scheduled for. March 17, 1993,.be closed to the
public.
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i
2.
The purpose of the meeting with the -NRC' is ' to discuss CYAPCO's'
l
Economic Analysis for the Haddam Neck Plant.
3.
The Economic Analysis for the Haddam Neck Plant reflects CYAPCO's
!
. projections of costs and returns and the Company's budget estimates,.
i
as well: as other sensitive proprietary information related to the
operation of the power plant.
-
4.
The information contained in the Economic Analysis.is deemed to be
confidential proprietary business iinformation by CYAPC0.
This
!
information is customarily held in strict confidence by CYAPC0 and
is not, to the best of my knowledge and belief, 'available to the
public.
~
lu
5.
Disclosure of the information contained in the Economic Analysis
through the opening of_ the meeting with the NRC could have a severe
- i
detrimental financial impact on the. operationsjof CYAPCO. _ For
example, a member of the public or the press attending the meeting
.
would not have access to all the confidential proprietary business
_
records of CYAPC0; therefore, the observation of the discussion of
i
selected portions of these records could cause such an individual to
acquire an inaccurate' perception of ' the - financial condition of
CYAPC0 -- a perception that could be injurious'to the Company.
In
,
addition, allowing the public to be present for such discussions
could stifle the ability of CYAPCO to discuss fully the Economic
Analysis for fear of widely disseminating other related ' sensitive
financial data.
6.
The development of the proprietary financial information contained ~
L
in ' the Economic Analysis required -a significant expenditure of
resources. Permitting competitors'of CYAPCO to gain access to this
information could have a significant detrimental' impact. on the-
competitive position of the Company because 'others would not be
required to expend the same resou.rces for this information.
.
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7.
The Economic Analysis is clearly confidential proprietary financial
information.
Accordingly, in order to protect this information,
CYAPC0 requests that the meeting with the NRC wherein these
financial matters will be discussed, be closed to the public.
The above seven paragraphs are true and accurate to the best of my knowledge,
information, and belief.
Executed this
/s day of March,1993.
ha RM
VJohn F. Obeka
State of Connecticut
)
)
ss. Berlin
County of Hartford
)
Sworn and subscribed to before me this /L day of March, 1993.
M45
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NbtaryPubgc
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My Commission expires:
%kulu J/. /Wh
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