ML20205J793
| 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: |
| 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
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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KING OF PRUSSIA, PENNSYLVANIA 19406-1415
April 5,1999
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:
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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
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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
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enforcement conf erence (conference) at the NNECo training building in Waterford, Connecticut,
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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
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contamination event are being cited. These violations are described in the enclosed Notice of
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Violation (Notice) and the circumstances surrounding them are described in detail in the subject
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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
ADOCK 05000213
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Connecticut Yankee Atomic Power
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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.
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
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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
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
date when full compliance was achieved is already adequately addressed on the docket in NRC
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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
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
August 1998 and involved (1) a leak of 1200 gallons of RCS decontamination fiuid; (2) the
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
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Connecticut Yankee Atomic Power
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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
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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
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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
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_ extent possible, your response should not include any personal privacy, proprietsty, or
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safeguards information so that it can be placed in the PDR without redaction.
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Connecticut Yankee Atomic Power
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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
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Connecticut Yankee A %!c Power
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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
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J. Haseltine, Strategic Planning Director
G. van Noordennen, Regulatory Affairs Manager
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J. Ritsher, CYAPCO Counsel
R. Bassilakis, Citizens Awareness Network
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J. Block, Attorney for CAN
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J. Brooks, CT Attorney General Office
K. Ainsworth, Town of Haddam
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State of Connecticut SLO
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Des
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Cennecticut Yankee Atomic Power
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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)
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120044