NRC NEWS

U. S. NUCLEAR REGULATORY COMMISSION

Office of Public Affairs Telephone: 301/415-8200

Washington, DC 20555-001 E-mail: opa@nrc.gov

 

No. 96-109 FOR IMMEDIATE RELEASE

 (Thursday, August 1, 1996)

 NRC STAFF ISSUES HADDAM NECK INSPECTION REPORT

 The Nuclear Regulatory Commission staff has issued a letter and

final report on a special NRC team inspection of engineering and

licensing activities at Northeast Utilities' Haddam Neck nuclear station

in Connecticut.

 The team concluded that weaknesses exist in the process that

ensures that the plant is maintained in conformance with its licensing

bases. In addition, the team found weaknesses in the plant's internal

process to identify, evaluate and correct problems. Specifically, the

team found that:

 --Engineering calculations and analyses relied on to assure the

adequacy of the design of key safety systems, such as station batteries,

emergency diesel generators, containment air recirculation system and

service water system, were incomplete or incorrect.

 --Sections of the plant's Updated Final Safety Analysis Report were

in error and changes to the report had not been properly evaluated. This

document describes a facility's design and operating limits, and provides

a safety analysis of its structures, systems and components. 

 A predecisional enforcement conference will be scheduled at a later

date to discuss significant deficiencies and apparent violations of nRC

requirements identified during the team's inspection. The decision to

hold the predecisional enforcement conference does not mean that the NRC

has determined that a violation has occurred or that enforcement action

will be taken. Rather, the purpose is to discuss apparent violations,

their causes and safety significance; to provide the licensee an

opportunity to point out any errors that may have been made in the NRC

inspection report; and to enable the licensee to outline its proposed

corrective actions. No decision on the apparent violations will be made

at this conference. Those decisions will be made by senior NRC officials

at a later time.

 When the conference is held it will be open to public observation.

 ####

Attachment: Ltr to NU

EDITORS: A copy of the executive summary of the inspection report is

available upon request from the NRC's Office of Public Affairs. The

summary and full inspection report have been posted on the Internet at

this address: http://www.nrc.gov/OPA/reports.

.

 July 31, 1996
Mr. Ted C. Feigenbaum

Executive Vice President and 

 Chief Nuclear Officer

Northeast Utilities Service Company

c/o Mr. Terry L. Harpster

P. O. Box 128

Waterford, CT 06385

Dear Mr. Feigenbaum:

SUBJECT: SPECIAL INSPECTION OF ENGINEERING AND LICENSING ACTIVITIES AT

 HADDAM NECK (NRC INSPECTION REPORT 50-213/96-201)

On April 26, 1996, the NRC completed a special inspection by the Office

of Nuclear Reactor Regulation at your Haddam Neck Station, located in

Haddam, Connecticut. The enclosed report presents the results of that

inspection.

The special inspection team concluded that weaknesses exist in the

implementation of the configuration management and corrective action

processes. Configuration management is the integrated management process

utilized to ensure (1) that the plant's physical and functional

characteristics are maintained in conformance with the plant's designand licensing-bases; (2) that operating, training, modification, and

maintenance processes are consistent with the conditions prescribed by

the design- and licensing-bases; and (3) that the plant is operated and

maintained within these conditions. For the configuration management

program to be effective, design- and licensing-basis information must be

readily available in properly controlled documents, utilized in

conjunction with the generation of engineering analyses, and updated to

ensure that it remains current. 

The team identified a number of significant deficiencies in the

engineering calculations and analyses relied upon to ensure the adequacy

of the design of key safety systems at Haddam Neck. In some cases,

design-basis calculations and analyses were not sufficient to confirm

that the safety system functional requirements would be met. Some of

these errors were longstanding, while others were recently introduced

during modifications to the facility. Deficiencies were identified in

the calculations and analyses supporting the station batteries, emergency

diesel generators (EDGs), containment air recirculation (CAR) system,

service water (SW) system, and in the combination of systems and

components needed to support the emergency core cooling system (ECCS)

transfer from the injection phase to sump recirculation. These

deficiencies revealed significant weaknesses in the defense-in-depth

principles that the NRC relies upon to ensure that nuclear power plant

operation does not jeopardize the health and safety of the public. The

team concluded that weaknesses in your configuration management processes

and a lack of technical rigor, thoroughness, and attention to detail in

the design process, either contributed to or directly caused the

identified errors. In addition, design control measures such as

supervisory reviews, independent design reviews, and reviews by oversight

committees did not identify these deficiencies. 

The team identified several errors in the Updated Final Safety Analyses

Report (UFSAR). Although quality assurance audits had identified UFSAR

discrepancies in the past, evaluations were not conducted to determine

the causes of these discrepancies and the programmatic implications. 

While not having a direct impact on safe plant operation, the identified

errors reflected a programmatic weakness in the process for maintaining

the accuracy and consistency of the information in the UFSAR. The team

also found some instances where commitments to the NRC were not met. 
These instances indicated weaknesses in the corrective action processes,

as well as the processes utilized to track, maintain, and evaluate

changes to commitments. 

An effective corrective action process promptly identifies, evaluates

significance, tracks, and resolves conditions adverse to quality,

especially with regard to determination of the cause of the condition and

elimination of both problem recurrence and occurrence of similar

problems. The team found several instances involving the failure to

identify, evaluate, and correct conditions adverse to quality, and some

instances in which planned corrective actions were not promptly

initiated. In some instances, the delays in initiating planned

corrective actions were significant because the actions included the

evaluation of the potential generic implications of these issues for

other plant systems and equipment.

The team observed inconsistencies in the implementation of the adverse

condition report (ACR) process and found that, in general, the threshold

used by the plant engineering staff to prepare an ACR reflected the

potential for an operability concern, rather than the potential for an

adverse condition. The high threshold led to delays in informing

operations of the issues and conducting operability evaluations. 

Although the ACR process is relatively new, the inspection record

indicates that similar implementation problems existed in the previous

process.

The team found that self-assessments, quality assurance audits, and

third-party reviews were generally effective in identifying issues and

conditions adverse to quality. However, line management's responses to

findings and recommendations from these processes were often inadequate. 

In several cases, planned actions in response to audit findings were not

entered into the formal tracking system or acted upon for long periods. 

In addition, findings from third-party audits were not entered into the

formal corrective action tracking mechanisms; consequently, management

lacked the means to adequately monitor corrective actions in response to

those findings.

As a result of these findings, the team concluded that station management

has not yet been successful in establishing a comprehensive corrective

action

program, and further, has not provided sufficient oversight to ensure

that the program is being effectively implemented.

The team found process issues at Haddam Neck which are similar to some of

those identified at Millstone 1, as documented in the Event Response Team

Report, dated February 22, 1996, that is commonly referred to as ACR

7007. As discussed above, the team found that calculations did not exist

to support some of the design-bases and the administrative control

programs at Haddam Neck have not maintained an accurate UFSAR. In

addition, licensee management oversight did not identify and address the

patterns of corrective action program implementation problems, as

discussed above. Finally, ACR 7007 states that a "general lack of

understanding and appreciation for the relationship between 10 CFR 50,

design-bases, licensing-bases, industry codes, and NU's administrative

programs" existed. The team observed instances that demonstrated a

similar lack of understanding by the licensee's staff at Haddam Neck. 

Apparent violations of NRC's requirements were identified during this

inspection and are being considered for escalated enforcement action in

accordance with the "General Statement of Policy and Procedure for NRC

Enforcement Actions" (Enforcement Policy), NUREG-1600. Accordingly, no

Notice of Violation is presently being issued for these inspection

findings. In addition, please be advised that the number and
characterization of apparent violations described in the enclosed

inspection report may change as a result of further NRC review.

We will contact you to schedule a predecisional enforcement conference to

discuss these apparent violations. The enforcement conference will be

scheduled approximately 3 weeks following issuance of this inspection

report. A predecisional enforcement conference does not mean the NRC

has determined that a violation has occurred or that enforcement actions

will be taken. This conference is being held to obtain information to

enable the NRC to make an enforcement decision, such as a common

understanding of the facts, root causes, missed opportunities to identify

the apparent violations sooner, correction actions, significance of the

issues and the need for lasting and effective corrective action. In

addition, this is an opportunity for you to point out any errors in our

inspection report and for you to provide any information concerning your

perspectives on (1) the severity of the violations, (2) the application

of the factors that the NRC considers when it determines the amount of a

civil penalty that may be assessed in accordance with Section VI.B.2 of

the Enforcement Policy, and (3) any other application of the Enforcement

Policy to this case, including the exercise of discretion in accordance

with Section VII.

You will be advised by separate correspondence of the results of our

deliberations on this matter. No response regarding these apparent

violations is required at this time.

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

of this letter and its enclosure will be placed in the NRC Public

Document Room. 

As discussed in the enclosed inspection report, some of the issues were

still under review at the end of the inspection. My letter to you dated

July 24, 1996, and subsequent NRC onsite technical review, addressed two

of the unresolved items in this inspection report. These issues were

related to the recently identified problems that lead to the plant

shutdown on July 23, 1996. Resolution of these open items and related

matters will be the subject of separate correspondence.

Should you have any questions concerning this inspection, please contact

the NRC Project Manager, Mr. S. Dembek, or the inspection team manager,

Mr. M. Virgilio. Messrs. Dembek and Virgilio can be reached at (301)

415-1455 and (301) 415-3226, respectively.

 Sincerely,

 Original signed by:

 William T. Russell, Director

 Office of Nuclear Reactor Regulation

Docket No.: 50-213

License No.: DPR-61

Enclosure: 

Inspection Report No. 50-213/96-201

cc w/enclosure:

W. J. Baranowski, Act. Director, Nuc. Qual. and Assess. Services

A. M. Callendrello, Licensing Manager - Haddam Neck

L. M. Cuoco, Senior Nuclear Counsel

E. A. DeBarba, Vice President, Nuclear Technical Services

J. J. LaPlatney, Haddam Neck Unit Director

D. B. Miller, Senior Vice President, Nuclear Safety and Oversight
N. S. Reynolds, Esquire

F. C. Rothen, Vice President, Maintenance Services

S. E. Scace, Vice President - Reengineering

J. F. Smith, Manager, Operator Training

W. D. Meinert, Nuclear Engineer

State of Connecticut SLO