IR 05000029/1999001

Insp Rept 50-029/99-01 on 990101-0411.No Violations Noted. Major Areas Inspected:Cold Weather Preparations for Spent Fuel Pool,Radiological Controls & self-assessment & Auditing & Corrective Actions for Decommissioning Activities

ML20206R341
Person / Time
Site:	Yankee Rowe
Issue date:	05/05/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206R329	List: IR 05000029/1999001 ML20206R322
References
50-029-99-01, 50-29-99-1, NUDOCS 9905200088
Download: ML20206R341 (39)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket N License N DPR-03 Report N /99-01 Licensee: Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398 Facility Name: Yankee Nuclear Power Station Location: Rowe, Massachusetts Dates: January 1 - April 11,1999 Inspector: J. Nick, Radiation Specialist, Region i Approved by: Ronald R. Bellamy, Chief Decommissioning and Laboratory Branch Division of Nuclear Materials Safety, RI

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EXECUTIVE SUMMARY Yankee Facility l

NRC Inspection Report No. 50-29/99-01 j l

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Inspections were conducted to determine whether the decommissioning activities carried out at the l Yankee (Rowe) facility were conducted safely and in accordance with NRC requirements. This report covers a three-month period of inspection. Areas reviewed included cold weather j preparations for the spent fuel pool, radiological controls, and self-assessment, auditing and l corrective actions for decommissioning sctivities, in general, there were effective programs for protecting the safety of workers during dismantlement and decommissioning activitie The licensee had provided good controls for radiation exposure and very good controls for radioactive materials and contamination, surveys and monitoring during decommissioning work {

activities. No violations or significant safety concems were identifie J

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The licensee performed very good quality assurance audits in various areas of decommissioning work. The inspector noted that the quality assurance auditors were identifying many items that the line organization could reasonably have been expected to identify. The licensee implemented a i condition report system that should allow employees to report conditions adverse to safety or )

quality. Although the new reporting system should help in identifying problems, the inspector noted l that there was no formal self-assessment process to identify issues before they become a bigger !

problem. The Nuclear Safety Assessment Review Committee continued to provide excellent {

oversight and assessment comments to the licensee's managemen !

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Effective procedures and processes to protect the safety of the spent fuel during extreme cold weather were implemented by the licensee. A broken distillate line on the radwaste processing skid was attributed to freezing conditions and the licensee implemented effective corrective actions to prevent recurrence. The licensee's self-audit for Information Notice 98-02, " Nuclear Power Plant Cold Weather Problems and Protective Measures," was adequate. The inspector noted several upgrades to the spent fuel pool building that will enhance protection from extreme cold weathe l

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REPORT DETAILS 01 Summary Of Facility Operations l l

On October 12,1995, the NRC served Memorandum and Order CLl-95-14 to Yankee Atomic '

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Electric Company (YAEC) conceming activities at the Yankee Nuclear Power Station (NPS) in Rowe, Massachusetts. The Order states, in part, that "the NRC's approval of the Yankee NPS Decommissioning Plan cannot be accorded further legal effect, pending an (adjudicatory] hearing j opportunity," and, that in accordance with the pre-1993 interpretation of the decommissioning j regulations, "the Commission expects YAEC not to conduct any further ' major' dismantling or i decommissioning activities until final approval of its [ decommissioning] plan after completion of the l hearing process." Subsequently, the Commission issued an Order (CLI-96-9), dated October 18, >

1996, which granted YAEC's Motion for Summary Disposition in a hearing convened to determine l whether the decommissioning plan should be approved. Since YAEC had originally submitted the 1 decommissioning plan before the Commission amended its decommissioning regulations, and the i decommissioning plan was approved by the NRC in February 1995, YAEC had been given approval {

to conduct decommissioning activities at the Yankee site per a letter from the NRC (reference ;

correspondence, dated October 28,1996, from Mr. Morton Fairtile to Mr. James Kay). I During the decommissioning process, the licensee removed the major primary components from the plant including the pressurizer, four steam generators, and the reactor vessel. Other '

decommissioning work performed included asbestos abatement, tank removals, piping and conduit l removal, removal of the waste evaporator, and removal of the secondary side equipment (turbine, electrical generator, other components, and piping). The licensee also completed relocation of the control room and modifications to allow operation of the spent fuel pool building (SFPB) without dependency on other buildings (spent fuel poolisland concept). When all decommissioning work is completed, the licensee plans to return the site to a " green field" condition with no structures standing on the sit }

O2 Operations O Facility Tours The inspector toured most of the radiological controlled areas (RCAs) outside the vapor j containment including the primary auxiliary building (PAB), the service building, the radioactive waste processing (compactor) building, the potentially contaminated area (PCA) storage building (a storage / staging area for potentially contaminated equipment and materials), the PCA warehouse attached to the radwaste processing building, and the SFPB. The PAB and the compactor building l had been completely cleared of equipment, conduit, and piping. Decontamination and removal of !

pipe penetrations and pipe chases were complete. Underground /underfloor piping was dug up and removed. Posting and labeling of radioactive materials continued to be excellent. All radiation areas (ras) and high radiation areas (HRAs) were posted and barricaded as required. There were i no locked HRAs in use at the site during the period of this inspection. Areas that were turned over 4 for the final survey process were maintained through administrative controls to prevent re- ,

contamination. The PCA warehouse had a significant number of storage boxes filled with mixed l

hazardous waste. The material was staged in the warehouse while the licensee was negotiating with a disposal facility to accept the hazardous waste. There were also numerous storage / transport ;

containers (cargo-vans) staged in areas around the controlled are t

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Areas inside the vapor containment (VC) were also toured by the inspector. Most of the piping and conduit had been removed in the VC. All ras were posted as required. Housekeeping in contaminated areas was very good. Areas that had previously presented a challenge due to work conditions continued to show improvement since the last period of inspection. Contamination control was evident by the use of " step-off pads", personnel monitoring equipment (friskers), and contaminated area postings at the boundaries. No significant safety or NRC regulatory concems were noted by the inspector during tours of the facilit .2 Current Activities l Most mechanical and structural components have been removed from areas in the VC. Workers continued the chipping and removal of conciete in the shield tank cavity. Decontamination work l was continuing in the VC in the reactor cavity and loop areas. Asbestos abatement on building l surfaces continued in the loop areas of the VC. Modifications to the SFPB and an upgrade to the l

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yard area crane had been completed to allow the handling of spent fuel cask The licensee was experiencing delays in their decommissioning schedule due to the identification of PCBs in the paint on many metal surfaces. Many painted surfaces inside and cutside the VC contained PCBs. Pieces of painted metal were temporarily stored in cargo vans end storage boxes at the site while the licensee worked with the Environmental Protection Agency (EPA) regarding removal and disposal methods for the contaminated pain Other work planned for 1999 includes completion of the items mentioned above. Also, dives in the spent fuel pool are planned to remove the fuel up-ender and other miscellaneous equipment to make more room in the pool for spent fuel transfer casks. The final site survey project was continuing in various buildings and was slated to be completed in the year 2000 The licensee planned to complete final surveys in the turbine building and the safe shutdown building so these buildings would be available for dismantlement. The licensee had not made any final decisions regarding which buildings would be dismantled in 199 Occupational safety awareness was evident among the workers at the site. The use of protective l equipment and safety processes were observed in all areas. The inspector noted that the site had l recently passed a significant record for occupational safety. Site employees had worked over two l

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million hours without a lost time accident. The number of recordable and minor injuries in 1998 was not significan R1 Plant Support - Radiological Protection and Chemistry (RP&C) Controls R Exoosure Control Insoection Scope (83750)

The inspector reviewed the controls for radiation exposure through observation of work activities, tours of the facility, interviews v!ith personnel, and a review of licensee document l Qbservations and Findinas A significant portion of the radiological source term (not including spent fuel) had been removed from the Yankee facility. Average area dose rates were typically under 5 miliirem per hour in most areas. There were only three areas at the site still designated as HRAs (dose rates in excess of 100 millirem per hour). Two of the areas were in the vicinity of the Radwaste Warehouse where l radioactive material was temporarily stored prior to transportation to a disposal or processing j facility. The third area was a sump area in the building used for decontamination processes that !

contained high levels of residual contamination from previous activities. Also, a transient area was I controlled as an exclusionary (locked) HRA when a source was used in the instrument calibration facility.

Due to the reduced source term, the total occupational radiation dose to workers was also lower than in previous years. The tot &l occupational radiation exposure to workers during 1908 was 4.6 person-rem. For comparison purposes, the total radiation dose to workers was approximately 96 person-rem in 1995 and 65 person-rem in 1997. Conclusions l

The licensee had provided good controls for radiation exposure. No violations of NRC regulations l and no safety concems were note l R1.2 Control of Radioactive Materials and Contamination. Surveys and Monitorina 4 Insoection Scope (83750)

The inspector reviewed the controls for radioactive materials and contamination, surveys and monitoring through observation of work activities, tours of the facility, interviews with personnel and a review of licensee documents, Observations and Findinas The inspector verified that there was an adequate supply of radiation survey and monitoring equipment. All equipment checked by the inspector was operable and within the current calibration period. Portal monitors and frisking instruments were located throughout the facility for use by workers as they left radioactive materials areas or contaminated areas. Current radiological sunteys of various work locations were reviewed by the inspector. The surveys contained detailed information regarding current radiological dose rates and hazards in the work areas. Surveys were posted at the main control point for the RCA and at the VC control point. Appropriate licensee management personnel had reviewed the radiological surveys.

Radiological housekeeping was good throughout the plant with appropriate controls established to minimize the spread of contamination. Pbsting of radioactive material areas and labeling of radioactive materials was excellent. Continued good performance was noted by the inspector as a result of major efforts by the licensee's radiation protection staff to keep items labele . Conclusions The licensee provided very good controls for radioactive materia!s and contamination, surveys and monitoring during decommissioning work activities. No violations or significant safety concems were identifie >

R8 Miscellaneous issues R Self-Assessment. Auditina. and Corrective Actions insoection Scope (40801)

The inspector reviewed the effectiveness of licensee controls in identifying, resolving, and q preventing issues that degrade safety or the quality of decommissioning through interviews with j personnel and a review of licensee document I Observations and Findinas The inspector reviewed the audits performed by the Quality Assurance (QA) group. The QA audits ] '

documented the review of various areas including radiation protection, corrective actions, radioactive waste, emergency preparedness, personnel training, final status survey, control of special nuclear material, plant operations, adherence to technical specifications, environmental monitoring, and implementation of the offsite dose calculation manual. The audits were performed

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by qualified personnelin the QA group. Recommendations, deficiencies, and opportunities for improvement were noted in most areas. The inspector found that the audits were very good quality i and brought management attention to very relevant areas of the program. A selected review of the l responses to the audits showed that deficiencies were reviewed and corrective actions were implemented in a timely manner. However, the inspector noted that the QA group was identifying l some issues that should have been identified by the line organizations during the implementation of i the decommissioning pla l The licensee's staff implemented a new corrective action tracking system, called the condition report program, in March 1999. The process was designed to identify, evaluate, disposition, correct, and track to completion any adverse condition. Any employee could initiate a condition report regarding a concem, problem, or unacceptable condition. The program was not intended to include employee concems or minor repairs addressed by a maintenance request. All reports were to be discussed by a management review team to determine the significance of the problem, review the immediate corrective actions taken, determine the need for additional corrective actions, and determine if the problem was reportable to regulatory agencies.

The inspector reviewed the radiological occurrence reports (RORs) that were generated by the radiation protection group during the last year. There were four RORs generated in 1998. Three of the RORs were written to document workers who disassembled high efficiency particulate (HEPA)

vacuum cleaners without clearance by the radiation protection group. The separate incidents occurred over a nine-month period. This is a problem due to the unknown radiological conditions that could be generated by the contaminated contents of the HEPA vacuums. Although the

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individuals or the work areas were not significantly contaminated, these incidents had the potential for unplanned radiation exposures. The inspector reviewed the corrective actions for the incidents and verified that they had been implemented, The actions should prevent a similar recurrence of the proble ,c The inspector discussed the self-assessments performed by the licensee's staff with site management. Tours (surveillance) of the facility and work-in-progress were documented by various managers and supervisors and included tours done on night and evening shifts. The documentation of problems and good practices was considered a benefit to the organizatio However, the inspector noted that there was no formal self-assessment program to identify and correct adverse conditions / problems before they became bigger problems. The licensee's manaoement stated that the new condition report program would allow workers to identify some problems before they became bigger issue The licensee also received feedback from the Nuclear Safety Assessment Review (NSAR)

Committee. The NSAR Committee evaluated the effectiveness of various activities performed at the site to provide safety of the spent fuel. Members of the NSAR Committee were experienced nuclear professionals who were outside the operating organization. The NSAR Committee met four times in 1998 to provide feedback to the site management. The inspector reviewed the minutes from the last meeting held in 1998 and determined that the NSAR Committee asked very good questions and provided excellent comments to the licensee's staf .Qonclusions The licensee performed very good QA audits in various areas of decommissioning work. QA auditors were identifying many items that the line organization should reasonably have been expected to identify. This was considered a weakness in self-identification and corrective actio The licensee implemented a condition report system that should allow employees to report conditions adverse to safety or quality. Although the new reporting system should help in identifying ,

problems, the inspector noted that there was no formal self-assessment process to identify issues before they become a bigger problem. The NSAR Committee continued to provide excellent oversight and assessment comments to the licensee's managemen R8.2 Cold Weather Preoarations Insoection Scooe (71714)

The inspector reviewed the licensee's program to protect safety-related systems against extreme cold weather through tours of the facility, interviews with personnel and a review of licensee documents, Observations and Findinas The inspector reviewed the licensee's procedures for protecting the spent fuel pool systems from extreme cold weather. Procedure No. OP-2115, " Warm or Cold Weather Operation," provided instructions for preparing the plant for cold weather operation. The licensee implemented this procedure in October to prepare the plant systems for winter weather. The procedure included a

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checklist to ensure that all items were reviewed / implemented. Procedure No. OP-5751, " Freeze l Protection Inspection," provided direction for the inspection of freeze protection equipment to ensure it was operable. The inspector found that the procedures provided adequate direction to workers to provide protective measures against freezing. In addition, the operators had inspection items on the operator log sheet to require examination of the equipment during the tour of the facility on each shif i The inspector reviewed the adequacy of the cold weather program and determined that it had provided for the safety of the spent fuel pool systems through the coldest part of the winter. No reports were generated to indicate the failure of any systems with the exception of a frozen line on the radwaste processing skid. Although the skid was not used for the spent fuel cooling, it was used to process radioactive water. The line had frozen and burst when an outer door was left ajar during l cold weather conditions. The small amount of slightly radioactive water that leaked was contained within the processing area containment. No water was released to the environment. The inspector l reviewed the corrective actions implemented by the licensee's staff and found that they were adequate to prevent a recurrence. No violations or significant safety concerns were identified.

The licensee had performed an internal assessment for compliance with a recent NRC Information Notice (IN). NRC IN No. 98-02, " Nuclear Power Plant Cold Weather Problems and Protective Measures" was written to ensure that power plants addressed potential common-cause failure l mechanisms of safety-related systems from extreme cold weather. The licensee performed a l review of previously implemented corrective actions and the applicability for decommissioning.

Some actions were still applicable and the corrective actions were incorporated in the existing procedures mentioned above. No other corrective actions were determined to be necessary. The inspector found that the self-assessment was appropriate and provided an adequate review of the potential problems from extreme cold weathe l The licensee had also implemented some recent upgrades to the spent fuel pool building (SFPB) to help maintain moderate temperatures. These upgrades included more insulation on the SFPB walls and new electrical space heaters. Conclusions Effective procedures and processes to protect the safety of the spent fuel du-ing extreme cold weather were implemented by the licensee. A broken distillate line on the radwaste processing skid was attributed to freezing conditions and the licensee implemented effective corrective actions to prevent recurrence. The licensee's self-audit for Information Notice 98-02, " Nuclear Power Plant Cold Weather Problems and Protective Measures", was adequate. The inspector noted several upgrades to the SFPB that will enhance protection from extreme cold weathe ~

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IV. Mananoment Meetings X1 Exit Meeting Summary The inspector met with the licensee representatives denoted below at the conclusion of the on-site inspection on March 18,1999 and via a telephone conference on May 3,1999. The inspector summarized the purpose, scope, and findings of the inspection. The licensee representatives acknowledged the inspection finding X2 Management Meeting Summary LI:ensee representatives met with the NRC staff in Rockville, Maryland on April 7,1999 to discuss proposed changes to the Yankee Nuclear Power Station Security Plan and other process simplification efforts. The NRC staff was briefed regarding the licensee's plans to implement pilot programs for corrective actions, quality assurance, and security processes. Other programs would be integrated to eliminate redundancies and simplify responsibilities. The licensee's staff restated their commitment for safe storage of the spent nuclear fuel and to maintain the safety focus consistent with the risk involved with these activities. A copy of the licensee's hand-outs are included as an attachment to this repor ,

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PARTIAL LIST OF PERSONS CONTACTED q l

M. Atkins, Licensing

G. Babineau, Support

W. Blackadar, Radiation Protection Engineer E. Cummings, Lead Engineer C. Ellis, Radiological Engineer R. Grippardi, Quality Ascurance Supervisor

E. Heath, Radiation Protection and Chemistry Manager

S. Litchfield, Health and Safety Supervisor S. Mullet, Radiation Protection Technician

D. Reid, Site Manager

M. Terrel, Assistant Site Manager

F. Williams, Plant Superintendent

R. Yetter, Final Status Survey Manager

Denotes those individuals participating in the exit briefing held on Mr.rch 18,1999 LIST OF ACRONYMS EPA Environmental Protection Agency HEPA High Efficiency Particulate i HRA High Radiation Area  !

IN information Notice NPS Nuclear Power Station NSAR Nuclear Gafety Assessment Review PAB Primary Auxiliary Building PCA Potentially Contaminated Area '

QA Quality Assurance RA Radiation Area RCA Radiological Controlled Area ROR Radiological Occurrence Report RP&C Radiological Protection & Chemistry SFPB Spent Fuel Pool Building VC Vapor Containment YAEC Yankee Atomic Energy Company

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INSPECTION PROCEDURES USED lP 40801: Self-Assessment, Auditing, and Corrective Action IP 71714: Cold Weather Preparations IP 83750: Occupational Radiation Exposure ITEMS OPENED, CLOSED, AND DISCUSSED Ooened NONE Closed NONE Discussed NONE I

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