ML20217J392
| 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: |
| 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:
2. NRC Inspection Report No. 50-213/97-03
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Mr. Ted C. Feigenbaum
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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. 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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- E' = Copy with attachment /enclosup *N* = No copy
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