ML20154J999

Requests NRC Take Immediate Action to Revoke Util License to Operate Haddam Neck Nuclear Power Station Pursuant to 10CFR2.206

ML20154J999
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/11/1998
From:	Bassilakis R CITIZENS AWARENESS NETWORK
To:	Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20154J966	List: ML20154J964 ML20154J976 ML20154J986 ML20154J999
References
2.206, DD-99-01, DD-99-1, NUDOCS 9810160069
Download: ML20154J999 (5)

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1. MA: Box 83 Shelbume Faus, MA 01370/ 80 Davenport RD, Rowe, MA PE 413 338-8781C768 l CT: 54 Old Tumpike Road, Haddam, CT 06438 P/F: 860-345-2187 VT: CIO Box 566 Putney,VT 05346 P!F: 802 387 2648/2667

.. l NH: 7 Evans Road, Madbury NH 03820 P/F 603-742 4261 NY: 924 met Ave., Syracuse, NY 13203 P/F 316 472-6478/ 7923

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m. . .m w,m, ,w g. ,y m n m x September 11,1998 Mr. Leonard J. Callan Executive Director of Operations U.S. Nuclear Regulatory Commission Washington, DC 20555 .

RE: Request Nuclear Regulatory Commission (NRC) revoke Connecticut Yankee Atomic Power Co.'s (CYAPCo's) license to operate its Haddam Neck Nuclear Power Station in Haddam, Connecticut, pursuant to 10 C.F.R. 2.206. If NRC does not revoke CYAPCo's license to operate, Citizens Awareness Network (CAN) requests suspension of CYAPCo's licensee. In either case, CAN requests an informal hearing.

I In_troduction:

By this letter, CAN requests, pursuant to 10 C.F.R. 2.203, that your agency take immediate action to revoke CYAPCo's licehse to operate the Haddam Neck Nuclear Power Station in Haddam, Coqnecticut. The reason for this request is that CYAPCo continues to demonstrate incompetence in creating and maintaining a safe work environment and an effective well-trained staff. This systemic incompetence has been repeatedly demonstrated both in incidents before Haddam Neck's closure and during decommissioning activities. CYAPCo jeopardizes the health and safety of workers at the Haddam Neck reactor and the public in the surrounding communities because of CYAPCo's inability to conduct decommissioning activities in a safe and controlled manner.

Should NRC refuse to revoke CYAPCo's license to operate the Haddam Neck reactor, CAN requests that CYAPCo's license be suspended until such a time when CYAPCo's management can demonstrate a competent and retrained work force, and a commitment to a defense in depth approach to decommissioning.

Petitioners additionally request an informal public hearing on the petition to be held in the vicinity of the site. The basis for this request is that CYAPCo is not conducting its decommissioning activities in accordance with the PSDAR and therefore is posing an undue risk to public health.

Il BACKGROUND:'

9810160069 981007

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CYAPCo announced on December 4,1996, that the Haddam Neck ' reactor would permanently shutdown. In August 1997, CYAPCo submitted its PSDAR and committed to a rapid dismantlement of its Haddam Neck site.

CYAPCo operated its entire life with some back up safety systems that would not have functioned properly. In the months prior to shutdown, NRC detennined that Haddam.

Neck's Emergency Core Cooling System and Containment Air Recirculation Fans would, in all likelihood, have failed if needed in an emergency. Over Labor Day weekend in 1996, workers inadvertently displaced water from the reactor vessel, which equilibrated in time to avoid the disabling of the Residual Heat Removal (RHR) system. Should the sole remaining RHR pump have failed, core boiling would have occurred in 52 minutes.

This lack of defense in depth also existed in the managing, planning and carrying out of radiological work. CYAPCo's poor radiation protection program lead to worker exposures and the release of contaminated materials from the site.

e in November 1996, two workers were exposed externally and internally with transuranics, while inspecting the fuel transfer canal.

e in late February 1997, CYAPCo returned radioactively contaminated video equipment to a venderin New York.

4 e CYAPCo historically permitted radioactive materials (concrete blocks, soil, tools, and other materials) to be taken offsite by workers and dispersed throughout communities.

Because of these events and others such as long-standing discrepancies in the calibration of radiation monitors, on March 4,1997, the NRC issued a ConSnatory Action Letter (CAL), restricting radiological work. The CAL halted all decommissioning activities until such time as CYAPCo demonstrated that it had retrained its workforce and understood the root causes for its incompetence and lack of compliance with NRC regulations and procedures. CYAPCo was required to overcome the systemic mismanagement that undermined safe operation of the reactor and its decommissioning. NRC lifted the CAL on May 5,1997 on the basis that CYAPCo had met NRC's requirements for an effective radiation protection program.

Since the lifting of the CAL however, a series of incidences have occurred which taken together raise serious questions as to CYAPCo's ability to protect worker and public health and safety and the environment. Although the institution of the CAL forced CYAPCo to improve its radiological control program, systemic mismanagement and incompetence prevail at the reactor.

1. On 6/20/98, 800 gallons of radioactive liquid was inadvertently released into the Connecticut River from a waste test tank. Valves serving as environmental barriers were susceptible to accidental manipulation. This event went unreported to the NRC for

'wo days. The root cause analysis for this event had an expected completion date of

. 7/27/98. (Daily Event Report, Event Number 34422) 1

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" 2. On 7/7/98, 350 gallons of demineralized water was inadvertently spilled, spraying workers, in the spent fuel pool building. A mispositioned valve (left open even though independently verified as closed) caused this. The event occurred while workers were making modifications to the spent fuel pool cooling /make-up system. (Moming Report, i

MR Number 1-98-0036)

3. On 7/27/98, approximately 1,000 gallons of highly radioactively contaminated water leaked into plant floor drains. A mispositioned valve (closed instead of opened) during chemical decontamination caused a 200 lb pressure relief valve to lift repeatedly and pipes to violently shake. Licensee tried three times in rapid sequence to get a flow through the system when the third attempt resulted in several line breaks including a broken vpive. (Daily Event Report, Event Number 34579; Preliminary Notification of Event or Unusual Occurrence PNO-1-98-033 and Update PN1-98-033; and Morning Report, MR Number 1-98-0040) .

4. On 8/10/98, during the filtering of the chemical decontamination liquid, the

demineralizer structurally failed causing resin beads to travel down stream. The post filter mesh did not trap the resin beads as designed because the post filter mesh screen apparently disintegrated due to incompatibility with decontamination chemicals.

The dose rates of pipes downstream where resin beads lodged are now 1-2 rem per hour (50 -100 times normal rates). Ironically, chemical decontamination activities conducted by CYAPCo caused the contamination of this piping.

5. CYAPCo never completed their root cause analysis for the first event (800 gallons into the river) prior to commencing similar work. Since root cause analyses are intended to identify problem areas so that repeat mistakes are avoided and exposures are limited, CYAPCo's disregard of these analyses undermines defense in depth.

This series of events demonstrate an inability on the licensee's part to follow NRC rules and regulations - a systemic problem at CY. What it demonstrates is a peculiar lack of commitment to a safety conscious work environment. Although these errors in judgement and procedural failure did not lead to the contamination of workers, we can assume that the lack of worker contamination was accidental on the licensee's part. The licensee has demonstrated numerous valve manipulation errors; multiple personnel errors; non-rigorous engineering; and non-conservative and unsafe decision making.

CYAPCo's PSDAR proposed to conduct the decommissioning activities under 10 CFR Part

50. Since the primary threat at the site is from irradiated fuel stored in the irradiated fuel pool, the regulations and requirements contained in 10 CFR Part 72 are more appropriate protection for the public and plant workers. Had CYAPCo pursued decommissioning under a 10 CFR Part 72 license, the problems encountered to date (as well as the future) may have been identified and prevented. The NRC.should gi.ve serious consideration to requiring CYAPCo to conduct its decommissioning activities under 10 CFR Part 72 to insure safety of the workers, public and the environment.

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CAN, in a letter to Dr. Jackson dated July 7*,1998, requested that the NRC immediately intervene to delay the chemical decontamination of the irradiated p*rimary piping do to rudimentary deficiencies displayed by the licensee in their June 20 inadvertent release into the river and the imminent dangers posed by the chemical decontamination process. The NRC did not delay the chemical decontamination procedure, which resulted in at least two serious events. The NRC has yet to respond to CAN's letter.

The Union of Concemed Scientists, in letters to Hubert J. Miller dated July 29* and 30*,

1998, requested that the NRC take immediate actions to ensure that the public and plant workers are protected during decommissioning activities at Haddam Neck. Randolf Blough responded to the UCS letter stating that the NRC would " closely observe activities" at Haddam Neck. As demonstrated by CYAPCo and described above, NRC's observation is not enough to prevent mishaps at the reactor.

ill ABOUT THE PETITIONERS:

Citizens Awareness Network is a non-profit, public interest group with members located in i

proximity to the Yankee Rowe reactor in MA, the Vermont Yankee reactor in VT, the Haddam Neck and the Millstone reactors in CT, the Nine Mile Point and Fitzpatrick reactors in NY, and the Seabrook reactor in NH. We are concerned with the entire nuclear fuel cycle from the mining of uranium, the standard operation of nuclear power stations to the siting of rad-waste facilities. CAN represents citizens in Northeast impacted communities that experience the economic, environmental, and health consequences of the uranium fuel cycle. Since 1991, CAN participated in a variety of NRC proceedings including, hearings on reactor embrittlement and decommissioning, rulemakings, workshops, ASLAB proceedings, and adjudicatory hearings. <

IV CONCLUSION:

For the foregoing reasons, petitionem ask the United States Nuclear Regulatory Commission to grant the petition by immediately commencing enforcement action, as detailed above, against CYAPCo.

Dated: This 11* Day of Septe ber,1998 4 Res mitt : 7 W}

I Rosemary a ilakis Deborah Katz

.} Researcher President Citizens Awareness Network Citizens Awareness Network 54 Old Tumpike Road P.O Box 83

Haddam, CT 06438 Shelbume Fant,, MA 01370

t I. 860-345-2157 413-339-5781 e

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