ML20217J392

Forwards Insp Rept 50-213/97-03 on 970408-0707 & 0805 & Nov. Violations Re Failure to Take Timely CA from August 1996 - March 1997 on Potential for Water Hammer on Svc Water Supply to Spent Fuel Pool Sys

ML20217J392
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/09/1997
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Feigenbaum T, Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
Shared Package
ML20217J396	List: ML20217J392 ML20217J398
References
50-213-97-03, 50-213-97-3, EA-97-366, NUDOCS 9710210066
Download: ML20217J392 (5)

See also: IR 05000213/1997003

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October 9,1997

EA 97 366

Mr. Ted C. Feigenbaum

Executive Vice President and Chief Nuclear Officer

c/o R. A. Mellor, Director

Site Operations end Decommissioning

Connecticut Yankee Atomic Power Company

362 Injun Hollow Road

East Hampton, CT 06424-3099

SUBJECT:

NRC INTEGRATED INSPECTION REPORT 50 213/97-03, NOTICE OF

VIOLATION, AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Feigenbaum:

The enclosed report documents the results of an NRC inspection completed on July 7,

1997 at Connecticut Yankee Atomic Power Company, and the results of the

teleconference and final exit summary between Mr. Russell Mellor of your staff and

Messrs. Richard Conte and William Raymond of the NRC staff on August 5,1997. During

the period covered by this inspection, the Haddam Neck staff continued to maintain safe

storage of the spent nuclear fuel as actions were taken to address degraded conditions in

the spent fuel pool cooling system. In general, plant engineering provided timely and

effective support to shutdown operations during the period to address severalissues

important to fuel pool cooling and for transitioning to the decommissioning mode.

At the final exit meeting, your organization was given a choice to discuss certain

significant violations identified in this inspection at an enforcement conference. The NRC

Staff did not believe an enforcement conference was necessary for the NRC to make an

enforcement decision on these issues, it is our understanding from Mr. Mellor that your

organization opted not to have the conference in summary, these violations were:

1.

Failure to take timely conective action from August 1996 to March 1997 on the

potential for water hammer on the service water supply to the spent fuel pool

system.

2.

Failure to take timely and adequate corrective actions on similar events in November

1996 and May 1997 involving repetitive procedural nonadherences for operating the

turning gear on the emergency diesel generators.

3.

Inadequate safety evaluation in June 1996 in which a dedicated operator was used

to compensate for feedwater regulating valves that could not perform their intended

design function under certain circumstances.

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Mr. Ted C. Feigenbaum

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In the engineering area, the first violation dealt with the discovery of an old plant design

discrepancy in the service water system creating the potential for postulated water

hammer, which could have affected the operability of the cooling water supply to the spent

fuel pool system following certain design basN events. This discrepancy existed since

1975 and rn!ght have resulted in degraded operation of the spent fuel pool cooling pumps

until corrected by a design chance in March 1997. However, your staff f ailed to take

timely corrective actions to address the operability and reportability aspects of this matter

when the technicalissue was erst identified in August 1996. This is a significent violation

of 10 CFR 50, Appendix B, Criterbn XVI.

In the maintenance area, the second violation of NRC corrective action requirements was

the failure to take timely and adequate actions to address a personnel error and procedure

nonadherence that resulted in the operation of the emergency diesel generator with Jacking

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tools installed in May 1997 (repetition of an event in November 1996). The error in

operation resulted in some minor damage to the engine. The f ailure to take adequate

corrective actions from a November 1996 event did not prevent, in a timely, manner the

May 1997 event and the failure is also a significant violation of 10 CFR 50, Appendix B,

Criterion XVI.

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The first two violations have been categorized in the aggregate as a Severity Levellli

problem in accordar, the " General Statement of Policy and Procedure for NRC

Enforcement Actions, (Enforcement Policy), NUREG 1600. A civil penalty is normally

considered for a Severity Level lli problem. However, after consultation with the Director,

Office of Enforcement and the Deputy Executive Director for Regulatory Effectiveness, the

NRC has decided not to propose a civil penalty in this case. This decision, pursuant to

Section Vll.B.6 of the Enforcement Policy, is based on the NRC having already issued a

significant enforcement action ($650,000 civil penalty) on May 12,1S9),in part for the

inadequacies in your corrective action program that contributed to these and other

violations, in other words, the above violations are additional examples of the performance

problems addressed in the May 1997 enforcement action. However, you should be aware

that future violations associated with shutdown operations and processes may result in the

assessment of additional civil penalties.

While these violations are additional examples of the problem addressed in our May 12,

1997 action, namely, the failure to aggressively pursue problems and to identify and

correct root causes, these recent findings provide additionalinsights into the nature and

scope of the broad performance problems that existed at Haddam Neck, in particular,

these deficiencies highlight the potential vulnerability associated with staff turnover during

transition to the decommissioning phase, as well as the significant challenge that

comprehensive correction of personnel errors presents. We acknowledge it will take some

time to fully correct the fundamental performance problems associated with your corrective

action programs; however, we also note the need for additional action to improve in these

areas and avert a significant impact on future decommisdoning activities. Accordingly, for

de above two violations, you are required to respond to this letter and in your response,

you should follow the instructions in the enclosed Notice. We also request that your

response provide completed or planned corrective actions along with schedules to address:

1) specific actions to reduce human performance errors / problems before and during the

course of decommissioning activities; and,2) the adequacy of staff turnover controls to

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Mr. Ted C. Feigenbaum

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assure conditions adverse to safety and quality are not inadvertently dropped or not ac'ed

upon. The NRC staff will use your response and the success of actions to correct

conditions adverse to quality to determine whether further enforcement action is necessary

to ensure compliance with regulatory requirements.

The third violation concerned the conduct of an inadequate safety evaluation for the period

of plant operations from June 14 to July 22,1996. During that period you used a

dedicated operator to compensate for feedwater regulating valves that could not perform

their intended des:gn function under certain circumstances. This change was considered a

change to facility as described in the updated Final Safety Analysis Report (FSAR); and

was considered an unreviewed safety question because it involved a malfunction of

equipment important to safety of a different type than had been previously analyzed.

Specifically, the dedicated operator could have failed to perform the required actions within

the required time. Your safety evaluation did not adequately address operator acts of

omission or commission. Accordingly, since you did not obtain review and approval from

NRC, this change was a significant violation of 10 CFR 50.59. In accordance with the

Enforcement Policy, violations of 10 CFR 50.59 that result in unrev ewed safety questions

are classified as Severity Level ill violations and, as such, are subject to civil penalties.

However, after consultation with the Director, Office of Enforcement, the NRC has decided

not to issue a Notice of Violation or propose a civil penalty for this case. This decision,

which is consistent with the provisions of Section Vll.B.2 of the Enforcement Policy, is

appropriate because the violation was based on events prior to the plant shutdown, and

we have already taken a significant enforcement action on May 12,1997, for the technical

and safety review program inadequacies that led to this and other violations,

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

and its enclosures will be placed in the NRC Public Document Room (PDR). To the extent

possible, your response should not include and personal privacy, proprietary, or safeguards

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

The responses directed by this letter and the enclosed Notice are nat subject to the

clearance procedures of the Office of Management and Budget as required by the

Paperwork Reduction Act of 1980, Pub. L. No. 96.511.

Sincerely,

Original Signed By:

Hubert J. Miller

Regional Administrator

Docket No. 50-213

License No. DPR-61

Enclosures:

1. Notice of Violation

2. NRC Inspection Report No. 50-213/97-03

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cc w/ encl:

B. Kenyon, President and Chief Executive Officer

D. Goebel Vice President Nuclear Oversight

F. Rothen, Vice President Nuclear Work Services

J. Thayer, Recovery Officer, Nuclear Engineering and Support

L. Cuoco, Senior Nuclear Counsel

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G. van Noordonnen, Manager, Nuclear Licensing

R. Johannes, Director - Nuclear Training

J. Smith, Manager, Operator Training

W. Meinert, Nuclear Engineer

R. Bassilakis, Citizens Awareness Network

J. Block, Attorney for CAN

J. Brooks, CT Attorney Geaeral Office

M. DeBold, Town of Haddam

State of Connecticut SLO

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Mr. Ted C. Feigenbaum

Distribution 'w/ encl:

Region i Docket Room (with concurrences)

PUBLIC

Nuclear Safety information Center (NSIC)

NRC Resident inspector

H. Miller, Regional Administrator

W. Axelson, DRA

R. Conte, DRP

E. Conner, DRP

C. O'Daniell, DRP

D. Holody, EO, RI

Distribution w/enci (VIA E-MAIL):

W. Dean, OEDO

S. Weiss, NRR, DRPM, PDND

M. Fairtile, PM, NRR

M. Callahan, OCA

W. Travers, SPO

R. Correia, NRR

F. Talbot, NRR

- D. Screnci, PAO, ORA

R. Zimmerman, ADPR, NRR

J. Goldberg, OGC

J. Lieberman, OE (OEMAIL)

D. Holody, EO, RI

Inspection Program Branch, NRR (IPAS)

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