ML20205J793

Discusses NRC Insp Repts 50-213/96-12 & 50-213/98-04 on 961102-27 Re Airborne Radioactivity Contamination Event That Occurred in Fuel Transfer Canal & Reactor Cavity in Nov 1996.Notice of Violation Encl

ML20205J793
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/05/1999
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
Shared Package
ML20205J796	List: IR 05000213/1996012 ML20205J793 ML20205J803
References
50-213-96-12, 50-213-98-04, 50-213-98-4, EA-96-472, EA-96-496, EA-96-532, NUDOCS 9904120197
Download: ML20205J793 (6)

See also: IR 05000213/1996012

Text

-e

p M*h y

9, UNITED STATES

[ g NUCLEAR REGULATORY COMMISSION

G j REGloN I

g f '475 ALLENDALE ROAD

KING OF PRUSSIA, PENNSYLVANIA 19406-1415

g ***** g

April 5,1999

EAs96-496

98-472

98-532

Mr. R. A. Mellor, Vice President

Operations and Decommissioning

Connecticut Yankee Atomic Power Company

362 Injun Hollow Road

East Hampton, CT 06424-3099

SUBJECT: NOTICE OF VIOLATION AND EXERCISE OF ENFORCEMENT DISCRETION

(NRC Inspection Report Nos. 50-213/96-12; 98-04; and NRC Historical Review

Team Report)

Dear Mr. Mellor: 4

This refers to: (1) an NRC inspection conducted on November 2-27, 1996, concerning an

airborne. radioactivity contamination event that occurred in the fuel transfer canal and reactor

cavity in November 1996; (2) an NRC inspectica conducted between July 20 and September

11,1998, to review several events that occurred during your implementation of the reactor ,

coolant system (RCS) chemical decontamination; and (3) a special NRC historical review

completed in January 1998 that examined a number of events and operating practices since

1966 that had the potential to impact your radiological site characterization efforts for  !

decommissioning. The three related reports were previously sent to your organization.  !

The issues from the November 1996 event were discussed with you during a predecisional i

enforcement conf erence (conference) at the NNECo training building in Waterford, Connecticut, i

on December 4,1996. Also, the issues frcat the RCS decontamination events were discussed

with you during another conference in the Region I office on December 16,1998, and were

also discussed with members of your staff in a subsequent telephone conversation on

December 18,1998. The issues developed from the historical review were not the subject

of an enforcement conference. Based on the information developed during the inspections and

the information provided at the conference, the violations associated with the November 1996 1 ;

contamination event are being cited. These violations are described in the enclosed Notice of

Violation (Notice) and the circumstances surrounding them are described in detail in the subject Og.

r

~~

inspection report. The violations identified during your implementation of the RCS chemical

decentamination and during tlie historical review are not being ' cited as described further

herein.

9904120197 990405

PDR ADOCK 05000213

G PDR

]

.

Connecticut Yankee Atomic Power 2

Company

With respect to the violations associated with the November 1996 contamination event, which

are described in the enclosed Notice, poor control of radiological activities resulted in a plant

maintenance supervisor and a contractor refueling manager becoming contaminated while

performing activities in the fuel transfer canal. The two individuals, although in the area to

inspect the canal, performed an activity that had not been planned, namely, collecting and

handling highly cor.taminated debris for removal from the area. By handling the highly

cornaminated material, the two workers caused an airborne condition in the canal and refueling

cavity, which caused them to become internally contaminated. The health physics coverage

at the entry point was inadequate in that the two individuals entered this area without being

adequately instructed regarding the radiological conditions that existed and the necessary

precautions to minimize perr annel exposure. Further, sufficient radiological surveys were not

conducted to assess the radiological conditions to which the workers were exposed. The

violations associated with the November 1996 contamination event, which are described in

the Notice, created a substantial potential for exposures in excess of regulatory limits.

Therefore, these violations are classified in the aggregate as a Severity Level lli problem in

accordance with the " General Statement of Policy and Procedure for NRC Enforcement

Actions" (Enforcement Policy), NUREG-1600. *

l

In accordance with the Enforcement Policy, a civil penalty is normally considered for a Severity

Level ill violation or problem. However, I have decided, after consultation with the Director,

Office of Enforcement, to exercise enforcement discretion in accordance with Section Vll.B.6  ;

of the Enforcement Policy and not propose a civil penalty for the violations associated with the j

contamination event. The decision to exercise discretion was made given that (1) the

violations occurred prior to the your decision, in December 1996, to permanently shutdown

the Haddam Neck facility; and (2) you were issued a $650,000 civil penalty on May 12,1997,

to address the performance problems that existed prior to the decision to permanently I

shutdown the facility, and which indicated general ly poor performance over a period of time.

The NRC has concluded that information regarding the reaaon for the cited violations, the

corrective actions taken and planned to correct the violations and prevent recurrence and the l

date when full compliance was achieved is already adequately addressed on the docket in NRC l

Inspection Report Ncs. 50 213/97-01; 97-10; and 98-02, licensee letters dated March 7,

'

1997, and May 30,1997, in response to NRC Confirmatory Action Letter dated March 4,

1997, and Licensee Event Report (LER) 50-213/96-030, dated December 6,1996. Therefore,

you are not required to respond to this letter unless the description therein does not accurately

reflect your corrective actions or your position. In that case, or if you choose to provide l

additional information, you should follow the instructions specified in the enclosed Notice.

With respect to the RCS decontamination events, the related violations occurred in July and l

August 1998 and involved (1) a leak of 1200 gallons of RCS decontamination fiuid; (2) the l

release of highly activated resin into the high pressure safety injection system piping in the

primary auxiliary building and inside containment; and (3) the loss of control of a five-ton floor

block due to improper rigging. At the December 1998 conference, you indicated that you did

not believe that your procedures for the RCS decontamination were inadequate. However, you  ;

acknowledged that your communications and teamwork during the events could hava been

_ _ _ _ _ _ _ _ _

J

'4

.

Connecticut Yankee Atomic Power 3

Company

better, particularly between the plant operators and control room, as well as among other work

- groups. Based on review of the information developed during the inspection and provided at

the conference, the NRC agreed that the procedures for lifting the primary auxiliary building

floor block were adequate. However, the NRC concluded that the procedures for the conduct

of decontamination of the reactor coolant system were not adequate for the control of

radioactivity. These inadequate procedures contributed to the leak of decontamination fluid

and the loss of control of domineralizer resins.

Although the radiological conditions in some areas were changed significantly by these RCS

decontamination events and are expected to cause an increase in the overall dose to workers

during decommissioning, the events did not result in a substantial potential for overexposure

of workers who were in the area at the time of the events. Therefore, the related violation is

classified at Severity Level IV and is being treated as a Non-Cited Violation (NCV), consistent

with Appendix C of the Enforcement Policy. If you contest the violation or severity level of

this NCV, you should follow the instruczions specified in the enclosed Notice.

With respect to the historical issues, although the NRC review found that your conduct of

activities over the last 30 years did not result in any apparent radiation exposure to the public

or env'ironment in excess of limits, violations of NRC requirements were identified. The

violations relate to: (1) inadequate surveys following a 1979 event; (2) an inadequate

procedure for release, for unrestricted use, of materials (i.e., soil, concrete blocks, and debris)

from the Radiation Controlled Areas; (3) failure to adequately evaluate liquid processing

systems that had the potential to become contaminated, including a 1989 event involving

processing of liquid radioactive waste in the Spent Fuel Building; (4) insufficient record keeping

pursuant to 10 CFR 50.75; and (5) inadequate 10 CFR 50.59 evaluations for changes involving

the Rad Waste Processing and 1991 fuel clad degradation.

The violations identified during the historical review could have been considered for

enforcement action; however, I have been authorized, after consultation with the Director,

Office of Enforcement, to exercise enforcement discretion in accordance with Section Vll.B.6

of the Enforcement Policy and not cite these violations. The decision to txercise discretion

was made in consideration of the fact the the Haddam Neck facility is permanently shutdown '

and you were issued a large civil penalty, as already described herein, based on the

performance problems that led to the shutdown. Discretion is appropriate because these

violations were (1) based on activities that occurred prior to your decision to permanently  !

shutdown, and (2) they were not willful. Enforcement action is not necessary in this case to

achieve remedial action because you have already initiated corrective actions for those issues

applicable to current facility conditions, including extensive offsite surveys and remediation

of the areas as necessary. Further, the broad, programmatic corrective actions taken as a i

result of the 1996 airborne contamination event and the 1998 RCS decontamination events

sufficiently address our concerns.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, and

'

your response, if provided, will be placed in the NRC Public Document Room (PDR). To the

_ extent possible, your response should not include any personal privacy, proprietsty, or i

safeguards information so that it can be placed in the PDR without redaction.  ;

.

.

Connecticut Yankee Atomic Power 4

Company

Should you have any questions concerning this letter, please contact Mr. Ronald Bellamy, at

(610) 337-5200.

Sincerely,

ubert J. Miller

Regional Administrator

Docket No. 50-213

License No. DPR-61

Enclosure: Notice of Violation

I *

i

l

,-

.

.

l Connecticut Yankee A %!c Power 5

Company ,

i

cc w/ encl:

D. Davis, Chairman, President and Chief Executive Officer

T. Bennet, Vice President and Chief Financial Officer  ;

K. Heider, Decommissioning Director

G. Bouchard, Unit Director

-

J. Haseltine, Strategic Planning Director

G. van Noordennen, Regulatory Affairs Manager .

J. Ritsher, CYAPCO Counsel

R. Bassilakis, Citizens Awareness Network  !

J. Block, Attorney for CAN

J. Brooks, CT Attorney General Office

f

!

K. Ainsworth, Town of Haddam j

State of Connecticut SLO 1

l

I

i

4

i

o

-

Des

Cennecticut Yankee Atomic Power

Company

DISTRIBUTION:

SECY

CA

PUBLIC

WTravers, EDO

MKnapp, DEDE

FMiraglia, DEDR

JLieberman, OE

HMiller, RI

DDambly, OGC

SCollins, NRR

BSheron, NRR

BKane, NRR

Enforcement Coordinators

Rl, Ril, Rill, RIV

BBeecher, GPA/PA

GCaputo, 01

PLohaus, OSP

HBell, 010

OE:EA File (2) (Also by E-Mail)

NUDOCS

Nuclear Safety Information Center (NSIC)

DScreaci, PAO-RI

NSheehan, PAO-RI

PMcKee, NRR

MMasnick, NRR

Region i Docket Room (with concurrences)

!

!

120044