IR 05000213/1995027

Discusses Insp Repts 50-213/95-27,50-213/96-06,50-213/96-07, 50-213/96-08,50-213/96-11,50-213/96-80 & 50-213/96-201 on 951121-961122 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $650,000

ML20141D216
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/12/1997
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kenyon B NORTHEAST UTILITIES SERVICE CO.
Shared Package
ML20141D221	List: IR 05000213/1995027 ML20141D262
References
50-213-95-27, 50-213-96-06, 50-213-96-07, 50-213-96-08, 50-213-96-11, 50-213-96-201, 50-213-96-6, 50-213-96-7, 50-213-96-8, 50-213-96-80, EA-96-001, EA-96-1, EA-96-286, EA-96-334, EA-96-337, EA-96-338, EA-96-339, EA-96-340, EA-96-407, EA-96-440, NUDOCS 9705200038
Download: ML20141D216 (8)

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May 12, 1997

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EAs.96-001, 96-286,96-334, 96-337,96-338, 96-339 96-340,96-407,96-440,96-495 l Mr. B. President Nuclear Group i

Northeast Utilities Service Company l Post Office Box 128 Waterford, Connecticut 06385 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTIES

- $650,000 (NRC Inspection Report Nos. 50-213/95-27,96-06,96-07,96-08,96-11,96-80,96-201)

Dear Mr. Kenyon:

From November 21,1995 through November 22,1996, the NRC conducted numerous inspections at the Haddam Neck Plant in Haddam, Connecticut, to review several facets of plant performance. These inspections included a specialteam inspection by NRC headquarters staff focused principally on engineering performance; a special Augmented Inspection Team (AIT) inspection of a reactor vessel nitrogen intrusion event in August-September 1996 that led to lowering of the reactor vessel water level; an emergency preparedness inspection to observe your response during an emergency exercise in August 1996; and numerous resident inspections. All of the related inspection reports were previously sent to your organization.

Numerous violations, as well as several significant regulatory concerns, were identified during these inspections. One specific violation (the low pressure safetyinjection (LPSI) system flow rate being less than assumed in the accident analysis for a considerable period) was discussed at a predecisional enforcement conference in the NRC Region I office on February 12,1996.

Most of the other violations were discussed at a transcribed predecisional enforcement conference at the Millstone training building in Waterford, Connecticut on December 4,1996.

The December conference was open to the public. While the conferences were held to discuss the violations, their causes and your corrective actions, the December conference focused principally on the broader programmatic deficiencies underlying the violations that contributed to the problems at Haddam Neck. The violations related to the resident inspection completed on November 15,1996, were not discussed during the December conference.

However, Mr. T. Feigenbaum of your staff informed Mr. J. Rogge, Region I, on December 16, 1996, that you agreed that another predecisional enforcement conference was not needed to discuss these issues.

The specific violations are described in the enclosed Notice of Violation (NOV) and Proposed Imposition of Civil Penalties (Notice). The violations are grouped into a number of broad categories, namely, numerous longstanding deficiencies in engineering programs and practices, OFFICIAL RECORD COPY g:HADDAMR6.NOV L

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Northeast Utilities Service Company 2 including plant design, design control, and engineering support, some of which led to significant safety equipment being inoperable or degraded for extended periods; numerous operational deficiencies, including inadequate procedures, failure to follow procedures, and inadequate corrective actions, which led to the " nitrogen intrusion" event; and inadequate implementation of the emergency preparedness program during the August 1996 exercise.

The engineering violations, which are set forth in Section I of the enclosed Notice, included the failure to assure that the plant was maintained as designed and specified in the Updated Final Safety Analysis Report (UFSAR); the introduction of additional design errors during design changes as a result of poor engineering; making design changes to the facility without performing adequate safety evaluations, including at least one instance where the change (removal of a flood protection floor block) involved an unreviewed safety question; not identifying or correcting adverse conditions that resulted from poor engineering, or the causes of those conditions; and not updating the UFSAR when required.

In many cases identified, applicable regulatory requirements and design bases were not correctly translated into specifications, drawings, procedures and instructions. Formal design calculations and analyses were, at times, based on incorrect assumptions, and were not sufficient to confirm that the systems would work as intended. These calculations, needed to assure that appropriate safety margins exist, frequently lacked technical rigor, thoroughness, and attention to detail. Overall, there was a generallack of understanding and appreciation for the relationship among NRC requirements, the design basis, the licensing basis, industry codes and standards, and your administrative procedures. Also, in these particular cases, engineering supervisors, independent design reviewers, and oversight i committees generally failed to identify the deficiencies, or related root causes, or when identified, failed to ensure appropriate or comprehensive corrective action. Further, line management's responses to self-assessments, QA audits, and third party reviews were inadequate. A particularly egregious case involved the failure to initiate formal corrective actions for the LPSI design deficiency discussed during the February 1996 enforcement conference. Although you committed to a review of the licensing basis for a number of plant systems to ensure that similar deficiencies, if they existed, were identified and corrected, at the time of the specialinspection team visit in April 1996, appropriate action had not yet been taken to follow-up on this commitment, and the commitment had not even been assigned to anyone for action.

As a result of these significant engineering failures, margins of safety for certain safety related equipment were reduced, at times, for extended periods. In some cases, inadequate engineering led to conditions contrary to technical specifications (TS),in that safety equipment would not perform its intended safety function if needed. For example, inadequate sizing of l pipes from the containment sump to the Residual Heat Removal (RHR) pump suction resulted l in insufficient net positive suction head (NPSH) to support RHR pump operation without relying on containment backpressure. Reliance on containment backpressure was inappropriate

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because it could result in RHR pump cavitation and pump f ailure if the predicted backpressure was not available. The significance of this violation was high, as you acknowledged during the enforcement conference, because the inadequate NPSH could result in the common mode OFFICIAL RECORD COPY g:HADDAMR6.NOV l

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- f ailure of the long-term reactor recirculation function, and increase the projected core damage j frequency as a result of this deficiency. Another example involved the inoperability of the

. recirculation phase flowpath needed to mitigate postulated Loss of Coolant Accidents (LOCA)

because the containment sump screen mesh holes were larger than originally assumed in the

analyses. This deficiency, for which several opportunities existed to identify and correct it

! over the years, could have resulted in the clogging of downstream ECCS components and

rendering them inoperable during an accident. In a third example, all four Containment Air

. Recirculation (CAR) units were inoperable, in that engineering analysis showed that the

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structural limits on the piping for the service water system, a support system for the CAR

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units, would be exceeded due to waterhammer loads. After identifying this deficiency, you shut down the plant on July 22,1996.

In addition to the engineering deficiencies, numerous operational concerns existeo that were identified during the NRC AIT inspection of the inadvertent decrease of reactor vessel water

levelin August and September 1996 while the plant was shutdown. For approximately four days, control room operators were unaware that nitrogen gas was leaking into the reactor vessel, displacing reactor water, and causing reactor water level to decrease to approximately 3 feet below the reactor vessel flange. After they became aware of the leakage, management was slow to appreciate the significance and effectively respond, as described in the Notice.

Further decrease in the water level could have challenged the function of the operating decay

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heat removal system. Several operations procedures failed to provide adequate details, or contained incorrect information, which contributed to both the nitrogen gas intrusion going undetected, and the inadvertent diversion of water from the reactor coolant system (RCS).

Several events were exacerbated by plant operators' failing to follow plant procedures, t conducting activities without procedural guidance, and making inappropriate decisions, such

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as not carefully accounting for the inventory while draining the reactor on August 29, or unisolating a reactor coolant loop on September 1 without taking appropriate boron samples, j A lack of a questioning attitude led to not promptly identifying the nitrogen gas accumulation in the reactor vessel. Further, senior operators did not convey expectations to less experienced field operators during pre-job briefings, which led to inappropriate equipment manipulations that either directly caused or contributed to these events.

The nitrogen intrusion event further revealed other deficiencies at the facility. For example, the timeliness of maintenance activities to restore an inoperable RHR pump to service and to maintain severalisolation valves wasinadequate. Quality parts and vendor specifications were unavailable, and repeated post-maintenance test failures resulted in having only a single RHR pump available for at least 3 weeks. Several isolation valves were in poor material condition and leaked, allowing the nitrogen gas to inadvertently enter the reactor vessel and water from the RCS to be diverted to the containment sump. In addition, although the temporary reactor vent header was significantly degraded, management, over several years, f ailed to provide an ,

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effective response to previous plant staff concerns to improve the temporary vent system.

The poor vent header design allowed nitrogen gas to accumulate in the reactor vessel during the event. Further, the absence of direct indication of reactor vessel water level masked the

. situation. Engineering, operations, and management did not fully evaluate and understand the vulnerabilities introduced by the decision to delay reactor disassembly while reactor waterlevel

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Northeast Utilities Service Company 4 instrumentation was disconnected. In effect, the licensee's support staff and management created conditions that set up the plant and control room operators for this event. Afterwards, management's overall response to the event was neither comprehensive nor timely as noted in Violation ll.D. The related violations are described in Section ll of the enclosed Notice.

With respect to the emergency preparedness activities, during the August 1996 exercise, your staff failed to recognize the need for an Alert declaration early in the exercise, and later, following declaration of a General Emergency, failed to implement appropriate protective actions for onsite personnel, and f ailed to recommend appropriate protective actions for areas outside the 10 mile emergency planning zone, based on the dose projections during the exercise. Overstaffing of key site emergency response organization (SERO) positions with two and three individuals very early in the exercise caused confusion and problems for other individuals initially assigned to the SERO. Due to the overstaffing, it was not possible to determine if the plan could be implemented with minimum staffing as specified in the plan. 1 Two violations were identified as described in the proposal. The staff notes that it does not i normally issue citations for exercise deficiencies. However, the NRC is issuing citations in this ;

case, in'accordance with the enforcement policy, because the exercise revealed recurring !

weaknesses in making protective action recommendations at Haddam Neck, as noted in d Inspection Report 96-07, indicating that effective corrective action had not been taken. A civil penalty is not being issued for these violations. ,

Although the violations described in the enclosed Notice did not result in any actual consequences to public health and safety, these violations and underlying causes demonstrated significant departures from the defense-in-depth principles upon which nuclear power plants are designed, built, and operated, and upon which the NRC relies to ensure nuclear power plant operation does not jeopardize public health and safety. These events and inspection findings revealed significant deficiencies in severs.I facets of the Haddam Neck ,

operation. Many of these violations should have been identified and corrected sooner. In other cases, corrective action was not taken after the violations were identified. Many of the violations were caused by a lack of a questioning attitude by your staff. Also, managers ,

should have conveyed high safety standards to the staff to seek, find, evaluate, and correct problems. This did not occur.

At the enforcement conference, you admitted the violations and you noted that a number of the violations would be applicable even with the reactor in a defueled stage. You also acknowledged that there were significant deficiencies at Haddam Neck that must be fully '

addressed before you could contemplate significant decommissioning efforts at Haddam Neck.

Further, you described a number of corrective actions that had been either taken or planned to address the programmatic weaknesses. Among those actions were the establishment and i communication of specific management expectations; implementation of new plant processes

and programs; assignment of a dedicated manager to implement an effective corrective action i program, and benchmarking the program against other plants. '

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Northeast Utilities Service Company 5 Also during the December 4,1996 conference, you announced that your Board of Directors had approved the decision to permanently shut down and decommission the Haddam Neck facility. Notwithstanding that decision, a number of these issues also apply to the shutdown l condition, as you acknowledged at the conference, and it is imperative that the underlying I flaws in management and staff performance, as already described herein, are corrected.

Management must set high standards and expectations, and see to it that they are met.

Therefore, in consideration of (1) the high regulatory significance that the NRC attaches to )

these violations, (2) the importance of emphasizing the need for effective management and )

oversight during the decommissioning process, as well as effective management and oversight J at your Millstone and Seabrook facilities, and (3) the importance of emphasizing to other reactor licensees the need for effective oversight of their nuclear power plants, I have been authorized, after consultation with the Director, Office of Enforcement, the Executive Director 1 of Operations, and the Commission, to exercise enforcement discretion pursuant to Section Vll.A.1 of the Enforcement Policy and issue the enclosed Notice of Violation and Proposed imposition of Civil Penalties in the cumulative amount of $ 650,000 for the violations discussed above.

This penalty is based on $200,000 for the violations in Parts 1.A-l.C of the Notice I (programmatic engineering violations with a $50,000 civil penalty for each of the three l functional areas in which the related violations are categorized with an additional $50,000 civil )

penalty for violation I.C.1.f because of the failure to have initiated by April 1996, the corrective actions committed to at a February 1996 enforcement conference regarding a design deficiency associated with the LPSI system); $150,000 for the violations in Part I.D ($50,000 penalty for each of three technical specification limiting conditions for operation I violations caused by inadequate engineering); and $300,000 for the violations in Part 11 )

($100,000 for the violations in the Sections ll.A-B, $50,000 for the violation in Section ll.C.

for failure to ensure adequate instrumentation, as well as $150,000 for the violations in Section !!.D for management's failure to take appropriate corrective action - the $150,000 penalty is based on a penalty of $25,000 for each of at least six days that licensee management failed to ensure appropriate instrumentation and recognize and effectively respond to the scope of the event). Classified as Severity Leveilllin Part 111, but not assessed a civil penalty, are the two violations associated with the recurring emergency exercise i weaknesses. Certain other violations identified during the inspections were classified at )

Severity Level IV and are set forth in Section IV of the enclosed Notice. I note that, but for j the decision to shut down the Haddam Neck facility, the penalty may have been higher.

Other matters involving Haddam Neck are currently under review that may result in further I enforcement sanctions. In addition, the NRC is still considering escalated action regarding the Millstone facilities for numerous violations discussed at an enforcement conference on December 5,1996. Enforcement action for these violations will be covered by separate correspondence at a later date.

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Northeast Utilities Service Company 6 You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response will be placed in the NRC Public Document Room (PDR) Your response may, as appropriate, make reference to the materials you provided at the enforcement conference on December 4,1996. To the extent possible, your response should not include any personal orivacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

Should you have any questions concerning this letter, please contact Mr. James Lieberman, Director, Office of Enforcement, at (301) 415-2741.

Sincerely, l

Original Signed by: 1 l

Hubert J. Miller Regional Administrator l

l Docket No. 50-213 j License No. DPR-61 Enclosure: Notice of Violation and Proposed Imposition of Civil Penalties

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Northeast Utilities Service Company 7 cc w/ encl:

T. Feigenbaum, Executive Vice President and Chief Nuclear Officer D. Goebel Vice President - Nuclear Oversight F. Rothen, Vice President - Nuclear Work Services J. Thayer, Recovery Officer, Nuclear Engineering and Support J. LaPlatney, Nuclear Unit Director L. Cuoco, Senior Nuclear Counsel G. van Noordennen, Manager, Nuclear Licensing l 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 General Office M. DeBold, Town of Haddam State of Connecticut SLO l l l

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Northeast Utilities Service Company I DISTRIBUTION:

SECY CA i l

PUBLIC LCallan, EDO HThompson, DEDR EJordan, DEDO j WDean, OEDO JLieberman, OE DNelson, OE HMiller, RI LChandler, OGC JGoldberg, OGC SCollins, NRR FMiraglia, NRR RZimmerman, NRR Enforcement Coordinators RI, Rll, Rlli, RIV BBeecher, GPA/PA GCaputo, 01 DBangart, OSP f!Be!,OlG Dross, AEOD OE:EA File (2) (Also by E-Mail)

NUDOCS Nuclear Safety Information Center (NSIC)

NRC Resident inspector - Haddam Neck

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DScrenci, PAO-R1 NSheehan, PAO-RI ,

LTremper, OC PMcKee, NRR SWeiss, NRR Region i Docket Room (with concurrences)

f7 m .t OFFICE RI: ORA fG ,Rl:DRS V l RI:DRPfV Rl:RC [$ l, RI:RA

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l NAME DHolody/mjc ' 4,eJWiggins RCooppWM BFeweil? ; Hptilfer DATE 01W97 01D/97 01/\1/97 01/vf97 F OJO /97 Y -

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