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{{Adams | |||
| number = ML20205J793 | |||
| issue date = 04/05/1999 | |||
| title = 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 | |||
| author name = Miller H | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = Mellor R | |||
| addressee affiliation = CONNECTICUT YANKEE ATOMIC POWER CO. | |||
| docket = 05000213 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-213-96-12, 50-213-98-04, 50-213-98-4, EA-96-472, EA-96-496, EA-96-532, NUDOCS 9904120197 | |||
| package number = ML20205J796 | |||
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | |||
| page count = 6 | |||
}} | |||
See also: [[see also::IR 05000213/1996012]] | |||
=Text= | |||
{{#Wiki_filter:-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 | |||
EAs 96-496 | |||
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 | |||
; | |||
}} |
Latest revision as of 02:37, 20 December 2021
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
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
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