IR 05000029/1993005
| ML20056F443 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 08/18/1993 |
| From: | Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20056F439 | List: |
| References | |
| 50-029-93-05, 50-29-93-5, NUDOCS 9308270233 | |
| Download: ML20056F443 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
93-05 Docket No.
50-29 Licensee No.
DPR-3 Licensee:
Yankee Atomic Electric Company 580 Main Street Bolton, MA 01740-1398 i
j Facility:
Yankee Nuclear Power Station
Rowe, Massachusetts Inspection Period:
May 10 - July 31,1993
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Inspectors:
Paul W. Harris, Resident Inspector - Vermont Yankee Morton Fairtile, Project Manager i
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Tf/Kf93 Approved by:
p)tugene M. fejly Datd
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D Chief, React 6r Projects Section 3A
Scope: Station activities inspected by the NRC staff this period included: operations, maintenance, engineering and plant support. Twenty-five hours of direct inspection was performed over the four inspection dates of May 10, June 9, and July 19 and 20, of which
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six hours were performed during backshift operations. Interviews and discussions were conducted with members of Yankee Nuclear Power Station management and staff as necessary to support this inspection.
Results: The conduct if maintenance in the vapor container was safe and good performance was demonstrated by control room operators. No violations of NRC requirements were identified. An audit conducted of EDCR 93-302, " Steam Generators and Pressurizer Removal - Component Removal Project 1993" identified no safety concerns.
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i EXECUTIVE SUMMARY I
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I Yankee Nuclear Power Station Report No. 93-05
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Operations j
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Shutdown operations were performed safely and operators were attentive to duty. Operators j
were provided appropriate management directives necessary for the conduct of operations.
l Maintenance
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Systems providing heat removal capability for the spent fuel were well maintained. A review l
of the maintenance backlog identified no concerns.
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Engineering
The safety evaluations for steam generator removal were acceptable. Adequate progmms and
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procedures are in place to ensure that component removal can be safely performed.
Plant Support
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Plant housekeeping and fire protection were commensurate with work in progress. The
conduct of activities within the vapor container assured personnel and plant safety. Good radiological practices, controls, and oversite were observed in the vapor container. Security
implemented timely and effective compensatory actions in response to a security advisory.
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SUMMARY OF FACILITY ACTIVITIES Yankee Rowe Nuclear Power Station has been shut down since October 1,1991, and the reactor defueled since February 15, 1992. The plant has operated under a Possession Only License (POL) since August 5,1992, and has recently received License Amendment No.
148 (dated June 11,1993) which revised the POL and Technical Specifications (TS) to reflect the permanently shutdown and defueled status of the plant.
During this inspection period, the licensee (Yankee) continued preparations for the removal of the four steam generators (SG) and pressurizer. Preparations included asbestos abatement, staging, shield block removal, and polar and jib crane refurbishment.
2.0 OPERATIONS (71707, 93702, 90712)
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2.1 Operational Safety Verification This inspection consisted of direct observation of facility activities, plant tours, and l
operability reviews of systems important to safety. The inspector verified that the facility was operated in accordance with license requirements. Plant operations were observed during regular and backshift hours in the control room (CR), vapor containment (VC), and I
primary access building (PAB).
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Control room and shift manning were in accordance with TS requirements. Operators were cognizant of system status and attentive to duty. The inspector reviewed the shift manning schedule, discussed the use of operator overtime with the Operations Manager, and verified that TS requirements were met. In addition, management directives and policies involving the operation of the plant were understood and implemented by the operators. Plant activities were accurately documented in the control room log and instrument checks were performed and evaluated. The inspector also observed that the instruments monitoring ef5uent release pathways and the spent fuel pool (SFP) cooling system were properly operating and calibrated.
l 2.2 Facility Tours The inspector toured the PAB and verified the status of operable fluid systems. Field inspections confirmed that the SFP cooling, component cooling, and service water systems were operable and that material conditions were consistent with the importance of providing long-term cooling of the spent fuel assemblies located in the SFP. Good material conditions were observed: pipes and valves were free of surface corro: ion, packing leakage was minimal, valve shafts were generously lubricated, and system identi5 cation tags were accurate. The inspector con 5rmed that control room indications correlated with Deld
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System components were readily accessible and no transient or flammable materials were
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found in the areas inspected. Area lighting was acceptable.
During tours of the VC, the inspector observed that component removal activities were performed safely. Plant and contractor personnel demonstrated effective use of personal l
safety devices, such as body harnesses and fall protection during the construction of
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scaffolding, temporary staging, and shield block removal. Tool lanyards, safety tags, and equipment protection devices were in use. In addition, work areas were roped off, l
appropriate informational and warning signs were posted regarding asbestos abatement and radiological conditions, and temporary lighting was provided in areas shielded from house lighting.
3.0 MAINTENANCE (71707)
The inspector reviewed the administrative controls and procedures necessary to maintain operability and reliability of plant systems. This review included Yankee memorandums regarding the safety classification of structures, systems, and components, such as:
" Electrical Power Systems Administrative Requirements for the Permanently Defueled Condition," (August 14,1992) and "YNPS Electrical Power Systems Operability Surveillance and Maintenance Requirements in the Defueled Mode" (July 21,1992). Based on these documents, Yankee determined that there are no longer any safety class 1,2, or electrical structures, systems, or components necessary for operation in the defueled mode.
Portions of the SFP, necessary to maintain pressure boundary integrity, and systems required to provide long-term cooling of the spent fuel assemblies are classified as safety class 3.
Quality assurance and controls are maintained on these systems and certain radiation and fire protection equipment. The documents reviewed were found to be consistent with Defueled TS requirements.
3.1 Maintenance Backlog The inspector reviewed the maintenance backlog as of July 20 and identified no safety concerns with respect to the outstanding maintenance items. The backlog list specifically identifies the safety-related (SR) maintenance requests to assure appropriate management review, and provides a short narrative regarding the status of repair. The majority of outstanding maintenance requests were associated with equipment not necessary for defueled plant operation and/or for general upkeep of site facilities. A licensee representative stated that the backlog process was in review to assure that only equipment necessary for the defueled condition are listed. The inspector considered this an effective measure to assure that SR requests, applicable to the current plant condition, are effectively reviewe.
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l 4.0 ENGINEERING (37001)
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4.1 Steam Generator Removal Program - 10 CFR 50.59 Safety Evaluations
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The purpose of this inspection was to audit the licensee's 10 CFR 50.59 safety evaluations
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supporting the steam generator (SG) component removal program (CRP). The inspectors i
reviewed the procedures governing the administrative controls, preparation, and review of
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j safety evaluations and then audited the safety evaluations specific to steam generator
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i removal. The safety evaluations are contained in the Yankee Rowe Engineering Design
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j Change Request (EDCR)93-302, " Steam Generators and Pressurizer Removal - Component
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Removal Project 1993." The EDCR also contains the design criteria, CRP program i
j description, calculations and drawings. The EDCR was approved by the Plant Operating j
Review Committee on July 16,1993.
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The inspectors concluded that the procedures necessary to implement the safety evaluation
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process were detailed and provided effective programmatic control. Specifically,
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administrative procedures AP-0001, Rev. 25, " Plant Procedures," and AP-0200, Rev.13, l
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" Plant Modifications" appropriately linked the preparation of procedures to TS requirements
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i wd the guidance provided in ANSI N18.7 and Regulation Guide 1.33, Rev. 2. In addition, i
AP 0200 implements detailed requirements and guidance necessary to provide appropriate
control and review of plant modifications.
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Yankee assures the proper use of 10 CFR 50.59 through the implementation of AP-0059, Rev. 3, " Safety Evaluations." This procedure provides guidance for the preparation of safety
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evaluations related to plant modifications and appropriately reflects the permanently shutdown
and defueled condition of the plant. The inspectors found AP-0059 accurate and suf5ciently l
detailed to ensure that the criteria of 10 CFR 50.59 are properly considered. In addition to i
the basic requirements of 10 CFR 50.59, AP-0059 also contains guidance on meeting the
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criteria of the Commission's Staff Requirements Memorandum (SRM) of January 14, 1993.
j AP-0059 references the Generic Environmental Impact Statement (GEIS), NUREG-0586, and
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l serves to keep the environmental impacts of the CRP within the envelope of the GEIS
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analyses. The inspectors also reviewed Yankee Project Procedure (YPP) 32, Rev. O,
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" Guidance for Preparing a Safety Evaluation" and verified that appropriate administrative
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i controls are provided for the decommissioning activities performed prior to NRC approval of
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l the Decommissioning Plan. YPP 32 properly follows the SRM criteria. Overall, the
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inspectors concluded that the procedures reviewed provided acceptable guidance for the preparation of the EDCR 93-302.
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Yankee concluded, as documented in EDCR 93-302, that there is no increase in the l
i consequences or probability of any previously evaluated accident due to the steam generator
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removal program. In addition, Yankee determined that based on the permanently shutdown
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I and defueled condition of the plant the only remaining design basis accident was the fuel
drop accident. The inspectors audited these determinations and identified no safety concerns.
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The new design basis accident was well supported by both assessment and evaluation, and the EDCR was comprehensive and accurate. The inspectors verified that the fuel pool and i
its piping systems and support structures are sufficiently separated from steam generator
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removal activities and an inadvertent steam generator drop. Further, the inspectors verified j
that proper isolation of pool cooling systems and component cooling systems were considered j
in the safety evaluation.
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Yankee evaluated a range of analyzed events. The licensee evaluated consequences of
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dropping a steam generator from a height of 90 feet. Yankee estimated that 7 percent of the l
solid radioactive material inside a dropped SG would have to be released and transported to l
the site boundary before the design basis dose criteria would be exceeded. These criteria are j
the EPA Protective Action Guidelines (PAGs) which are more conservative that 10 CFR Part 100 limits. The licensee adopted a defence-in-depth approach to: first, prevent a drop from occurring and then to mitigate the consequences of a SG drop accident. The prevention
features consist of: crane load testing in excess of the crane 150 ton capacity (a SG weighs l
104 tons); review and evaluation of the load path; QA and inspection programs for crane components; proposed use of experienced crane operators; field supervision by senior i
supervisors during the lifting operations; and, multiple reviews of the new and existing crane i
lift procedures. The accident mitigation features consists of: a load transfer device designed
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to protect steam generator nozzles, protruding manways, and temporary cover plates from impacts caused transporting the SGs; and, an impact limiting pad designed to absorb the energy generated should the SG drop the full 90 feet. The impact limiting pad consists of
l dense foam, ten feet thick, located directly below the vapor container equipment hatch. The l
inspectors reviewed the unanalyzed events listed in the EDCR, the prevention and mitigation
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strategies, and concluded that appropriate measures are in place to maintain a radioactive release from a SG drop below the EPA PAGs.
The licensee stated in the EDCR that no margin of safety, as defined in the bases for any TS requirement, is reduced by the steam generator removal activities. The inspectors verified this assessment and found the conclusion acceptable.
In addition to the safety evaluations performed by the licensee pursuant to 10 CFR 50.59, Yankee included in the EDCR an evaluation related to their conformance with the criteria of the SRM. In summary, Yankee concluded that the component removal activities do not foreclose release of the site for unrestricted access, significantly increase the cost of decommissioning, cause any significant environmental impacts not previously evaluated, nor violate the terms of the existing facility license. The NRC staff in letters to the licensee (dated April 16 and July 15,1992) stated that the NRC had no objection to the licensee's component removal program prior to approval of the Decommissioning Plan, based on Yankee meeting the SRM criteria. The inspectors verified that the SRM criteria were properly evaluated in the EDCR 93-302.
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The inspectors concluded that the safety evaluations for SG removal are acceptable and the adequate programs and procedures are in place to ensure that the steam generators can be safely removed and transported.
5.0 PLANT SUPPORT (71707)
5.1 Radiological Controls During tours within the VC and PAB, the inspector observed good radiological practices and appropriate radiological postings. Workers demonstrated proper donning of anti-contamination clothing and were knowledgeable of the radiation conditions in the work area.
I_ow dose rate radiation areas were posted and appropriately used by personnel to reduce exposure. The radiation protection (RP) staff were observed performing contamination surveys and to properly document results. The lead RP technician was cognizant of VC activities and changing radiological conditions. Continuous airborne monitoring was l
performed in the general areas of the VC and at specific work sites. During scaffolding erection, the inspector observed that power tools were in use and were potentially spreading contamination. This observation was brought to the attention of a VC RP technician, who l
performed additional surveys. No abnormal contamination levels were identified.
Improvements were observed in the area designated for anti-contamination clothing removal and in the field instructions provided for personnel working in contamination areas.
5.2 Security On June 30, Yankee implemented appropriate compensatory measures in response to NRC advisory information regarding the potential for an extemal threat following the bombing of the World Trade Center. Yankee management demonstrated proper regard for plant security by promptly reviewing this event and implementing instructions to the security force. The inspector verified that the compensatory measures were implemented, that perimeter lighting was adequate, and industrial area surveillance cameras were operable. Security officers were knowledgeable and demonstrated a heightened state of awareness while on plant tours.
5.3 Fire Protection and IIousekeeping On July 20, the inspector toured the PAB with an Equipment Operator, in pan, to assess fire prevention and detection equipment and housekeeping conditions. In preparation for this inspection, the inspector reviewed AP-0050, Rev. 6, " Fire Protection Plan," AP-0051, Rev.
5, " Plant Fire Protection," and the Yankee Fire Protection Technical Requirements manual.
In addition, the inspection criteria provided in Yankee procedure AP-0053, Rev.1, " Plant Fire Protection Inspection Program" were used as a guide. The inspector verified that the procedures were pursuant to TS requirements.
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l Overall, the inspector found that fire prevention and detection conditions within the plant l
were acceptable and in accordance with Yankee procedures. Fire loading was consistent with maintenance in progress and combustible materials were properly stored in fire containers. Plant fire extinguishers and suppression equipment were in good material l
condition and emergency lighting was verified operable. Similar observations were also l
made within the VC, however, the inspector observed that the potential for fire was generally l
increased, based on the installation of many temporary electrical boxes and leads necessary l
for component removal. This marginal increase in risk was mitigated by periodic l
housekeeping tours and the use of fire retardant materials for scaffolding erection and
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radiological control areas. In addition, portable fire extinguishers are located within VC and j
adequate communications exist.
5.4 Administration 5.4.1 Preliminary Inspection Findings Meetings were held periodically with Yankee management during this inspection to discuss inspection findings. Preliminary findings were discussed at the conclusion of the inspection with Mr. G. Maret on July 20 and throughout the inspection period with Mr. T. Henderson.
No proprietary information was identified as being included in this report.
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5.4.2 Local Publie Document Room On July 12, the inspector visited the local Public Document Room (LPDR) for the Yankee
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Nuclear Power Station and verified that documents placed on the public docket are readily l
retrievable. Three documents from independent sources were searched and found; the LPDR users guide, updates, and indices were available and in good condition; the microfiche reader / copier was operable; and appropriate instructions were provided to users regarding the
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use of LPDR materials. The 1-800 help hotline for LPDR users was posted and telephone j
communications existed. The LPDR is located at the Greenfield Community College, i
I Greenfield, MA.
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