ML20137U621

Ack Receipt of 961125 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-213/96-07

ML20137U621
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/09/1997
From:	Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Feigenbaum T CONNECTICUT YANKEE ATOMIC POWER CO.
References
NUDOCS 9704170050
Download: ML20137U621 (2)

See also: IR 05000213/1996007

Text

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April 9, 1997

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Mr. Ted C. Feigenbaum

Executive Vice President and Chief Nuclear Officer i

. c/o R. A. Mellor, Director l

Site Operations and Decommissioning ,

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Connecticut Yankee Atomic Power Company I

362 injun Hollow Road l

East Hampton, CT 06424-3099

SUBJECT: INSPECTION REPORT NO. 50 213/96-07 (REPLY) ,

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{ Dear Mr. Feigenbaum: j

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i This letter refers to your November 25,1996 correspondence, in response to our l

October 23,1996 letter. I

Thank you for informing us of the corrective and preventive actions documented in your

letter. These actions will be examined during a future inspection of your licensed program.

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Your cooperation with us is appreciated. l

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j Sincerely, j

ORIGINAL SIGNED BY:

l Richard R. Keimig, Chief

l Emergency Preparedness and Safeguards Branch

, Division of Reactor Safety

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Docket No. 50-213

9704170050 970409

PDR ADOCK 05000213

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Mr. Ted C. Feigenbaum 2

cc:

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

G. van Noordennen, Manager, Nuclear Licensing

R. Johannes, Director - Nuclear Training

J. Smith, Manager, Operator Training

W. Meinert, Nuclear Engineer

R. Bassilakis, C tizens Awareness Network

J. Block, Attorney for CAN

J. Brooks, CT Attorney General Office

M. DeBold, Town of Haddam

State of Connecticut SLO

Distribution:

Region I Docket Room (with concurrences)

PUBLIC

Nuclear Safety Information Center (NSIC)

NRC Resident inspector

J. Rogge, DRP

M. Conner, DRP

C. O'Daniell, DRP

W. Axelson, DRA

W. Dean, OEDO

S. Weiss, NRR, DRPM, PDND

M. Fairtile, PM, NRR

R. Jones, NRR

M. Callahan, OCA

W. Travers, SPO

R. Correia, NRR

D. Taylor, NRR

D. Screnci, PAO, ORA

Inspection Program Branch, NRR (IPAS)

DRS File

DOCUMENT NAME: G:\EP&SB\ LUSHER \HN9607. REP

Ta receive a copy of th6s document. Indicate in the box: "C" = CopyMJhthout attachment / enclosure *E' = Copy with attachment / enclosure *N" = No copy

0FFICE RI/DRS (s j l5 Rl/DRS / ._

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NAME JLusher,f//f- RKeimif"

DATE 04/09/7f '" 04/f /97 04/ /97 04/ /97 04/ /97

0FFICIAL RECORD COPY

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, FILE No. 632 11/25 '96 16:56 ID:tE UTILITIES EXEC OFFICE 860 66; TA1 PAGE 2

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CONNECTICUT YANKEE ATOMIC POWER COMPANY  !

HADDAM NECK PLANT

362 INJUN HOLLOW ROAD e EAST HAMPToN. CT OC424-3tXD

November 25,1996

pocket No. 50-213

B16045

Re: 10CFR50.47(b)

10CFR50, Appendix E

U. S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, DC 20555

Haddam Nock Plant

Emergency Proparodness Exercise

NRC Insooction Reoort No. 50-213/96-07

The purpose of this lettor is for Connecticut Yankee Atomic Power Company

(CYAPCO) to provide a description of additional corrective measures CYAPCO has

taken or plans to tako related to the Haddam Nock Plant (HNP) smorgency

preparedness exercise conducted on August 14,1996.

CYAPCO takes very seriously the recent weaknessos which were the subject of the

inspection report. CYAPCO has reviewed the NRC findings, and the results of its own

assessmonts of the causos which contributed to this event. Based on that review,

CYAPCO has dovolopod the correctivo actions discussed in Attachment 1. Many of the

corrective actions will be implemented in the short-term and all of the corrective actions

will be completed by March 31, 1997. CYAPCO will also demonstrate in 1997, the

offectiveness of the correctivo actions. Note that the corrective actions may be revised,

as appropriate, if the joint owners decide to permanently coase power operation of the

HNP.

In Inspection Report No. 50-213/96-07,Wtwo weaknesses were observed:

1) Failure to recognize the need for an Alert declaration early in the exercise

(which consoquently was promptod by the controller) and confusion with

the use of emergency level action tables prior to the declaration of the

Gonoral Emergency; and

(1) NRC letter from J. T. Wiggins to T. C. Feigenbaum, 'NRC-Evaluated Emergency

Preparedness Exercise - Haddam Neck Plant; NRC Inspection Report

No. 50-213/96-07," dated October 23,1996.

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,, '. FILE tb. 632 11/25 '96 16:57 ID:NE UTILITIES EXEC OFFICE 860 665 3581 PAGE 3

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U. S. Nuclear Regulatory Commission i

816045/Page 2  :

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2) Failure to implement protective actions for the SERO [ site emergency  ;

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response organization) at the Emergency Operations Facility and site

personnel, and consider protective action recommendations beyond the

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- 10 mile emergency planning zone, based upon the dose projections used

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in support of those protective actions.

A description of the additional corrective measures taken or planned and a schedule for

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completing those actions is provided in Attachment 1. These additional corrective l

measures will also be discussed at the pre-decisional enforcement conference .

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scheduled for December 4,1996. l

- An extension to submit the letter by November 25,1996 was granted by the NRC Staff

in a teleconference on 14ovember 22,1996.

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l If you should have any questions, please contact Mr. G. P. van Noordennen at

i- (860)267-3938.

Very truly yours, .

CONNECTICUT YANKEE ATOMIC POWER COMPANY

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Bruce D. Kenyon %

President and Chief Executive Officer

i cc- H. J. Miller, red on i 1 Administrator

i S. Dembek, NRC Project Manager, Haddam Neck Plant

W. J. Raymond, Senior Resident inspector, Haddam Neck Plant

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, Mr. Kevin T. A. McCarthy, Director i

Monitoring and Radiation Division  !

Department of Environmental Protection

79 Elm Street

, P. O. Box 6066

i Hartford, Connecticut 06102-5066

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., '. FILE No. 632 li d 'G6 16:57 ID:NE UTILITIES EXEC OFFICE 860 665 3581 PfE 4

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Docket Nos. 50-213  ;

B16045 i

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Attachment 1

Haddam Neck Plant

NRC-Evaluated Emergency Preparedness Exercise

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NRC Inspection Report No. 50-213/96-07  ;

Corrective Actions

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November 1996

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l FILE tb. 632 11 4 5 '96 16:58 ID:NE UTILITIES EXEC OFFICE 860 665 3581 PME 5

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, U. S. Nuclear Regulatory Commission

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B16045/ Attachment 1/Page 1

Haddam Neck Plant

NRC-Evaluated Emergency Preparedness Exercise

NRC Inspection Report No. 50-213/96-07

Corrective Actions

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l ITEM 1 )

Restatement Of Weakness:

The facilities were staffed and activated in a prompt manner. Adequate direction and

control were observed at all of the facilities. The initial classification of the simulated

event was not recognized by the SCR SM [ Simulator Control Room Shift Manager) who

had to be prompted by the lead contro!!or at that facility. The SAE [ Site Area

Emergency] and GE [ General Emergency] classifications were correct and timely.

However, missing the Alert classification and the discussions on the SAE and GE

declarations are considered an Exercise Weakness.

(NRC Inspection Report No. 50 213/96-07 eel 50-213/96 007-01, Section P4.c, Page 10)

Reason For The Weakness

The emergency planning change management process did not ensure familiarity with

the SERO (site emergency response organization) classification methodology.

Emergency responders involved in making classifications have not received the

training necessary to consistently classify postulated events. The use of the EAL

(emergency action level) clarification process has been weak and ineffective.

Non-existent self assessment and an ineffective corrective action process allowed this

condition to exist.

Corrective Stoos That Have Been Taken And The Results Achieved

2 hi order to clarify the'ourrent EALs,' a review'of industry experience with the NUMARC ~

EALs was undertaken'to determine how the EAL classification process *should be;

revised.j The results of this review will be used in CYAPCO's SERO training program

' and in the corrective actions discussed below.

Corrective Stoos That Will Been Taken To Avoid Further Deviations

The following corrective steps (and their completion dates) are being implemented:

1. Condud a SERO job' task analysis' to determine the most' capable"ahd ; ?

effective- positionsfin _ the ergerbt;cn to . make EAL Lclassifications.

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(January 1997)" l

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U. S. Nuclear Regulatory Commission

B16045/ Attachment 1/Page 2

2. Conduct an analysis of simulator utilization as a training and evaluation

tool to improve EAL classification skills. (January 1997)

3. Train those members of the SERO that classify events using the EAL

tables, include bases information and clarifications in the lesson plans.

(January 1997) /j not D& / p/P A#@E

. 4. Periodically review the EAL tables to incorporate clarifications and future

< enhancements. (Annually)

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5. Establish an emergency planning self assessment program and evaluate

the effectiveness of the self assessment program approximately six

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months after its implementation. (January 1997 and July 1997)

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Date When Corrective Action Will Be Completed

The corrective actions will be completed by July 1997.

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ITEM 2

Restatement Of Weakness:

The PAR [ Protective Action Recommendation) was given to the State of Connecticut

within 15 minutes of the GE [ General Emergency). However, the basis for the PAR and

the fact that there was not any consideration of protective actions beyond the 10 mile

EPZ [ Emergency Planning Zone) is considered an Exercise Weakness.

(NRC Inspection Report No. 50 213/96-07, eel 50-213/96-007-02, Section P4.c, Page 10)

Eg.gson For The Weakness

The existing PAR process, unlike industry norm was: overly complex, open to individual

intwpretation and judgment, not clearly linked to plant conditions, and confusing to

State of Connecticut decision makers. As a result, CYAPCO was unable to effect good

training. Non-existent self assessment and an ineffective corrective action process

allowed this condition to exist.

Corrective Steps That Have Been Taken And The Results Achieved

Corrective actions are still in the process of being implemented, as discussed below.

Corrective Steps That Will Been Taken To Avold Further Deviations

The following corrective steps (and their completion dates) are being implemented:

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U. S. Nuclear Regu!atory Commission

D16045/ Attachment 1/Page 3

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1. Include the Connecticut Department of Environmental Protection (DEP)

personnelin the redesign of the PAR process. (December 1996)

2. Redesign the communication interfaces with State of Connecticut DEP

personnel. (December 1996) AI ' gygs

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3. Design appropriate training materials.Tanuary 1997)

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4. Verify effective SERO (site emergency response organization)

expectations regarding procedure utilization and compliance.

(January 1997)

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5. Establish an emergency planning self assessment program and evaluate

the effectiveness of the self assessment program approximately six

months after its implementation. (January 1997 and July 1997)

! Date When Corrective Action Will Be Completed

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The corrective actions will be completed by July 1997.

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