IR 05000155/1999001
| ML20204F474 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/19/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20204F467 | List: |
| References | |
| 50-155-99-01, 50-155-99-1, NUDOCS 9903250301 | |
| Download: ML20204F474 (25) | |
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l U.S. NUCLEAR REGULATORY COMMISSION
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REGION 111
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j Docket No:
50-155 License No:
DPR-06 i
Report No:
50-155/99001(DNMS)
Licensee:
Consumers Energy Company Facility:
Big Rock Point Nuclear Power Plant Location:
10269 U.S. 31 North Charlevoix, MI 49720 Dates:
January 13,1999 - February 25,1999 Inspectors:
R. J. Leemon, Reactor Decommissioning Inspector R. B. Landsman, Project Engineer P. W. Harris, License Project Manager D. W. Nelson, Radiation Specialist Approved by:
Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety i
9903250301 990319 PDR ADOCK 05000155 G
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EXECUTIVE SUMMARY Big Rock Point Restoration Project NRC Inspection Report 50-155/99001(DNMS)
This routine decommissioning inspection covered aspects of facility management and control, decommissioning support activities, spent fuel safety, and radiological safety.
Overall, major decommissioning activities were properly controlled and were performed e
' in accordance with schedules. Radiological activities were performed with appropriate as-low-as-reasonably-achievable (ALARA) elements included in the plans. The defueled technical specifications (DTS) were implemented, the monitor station was staffed and the control room was left unstaffed. The last electrical load was placed on decommissioning power and the breaker on the 46 KV line to the station substation was permanently opened. After 37 years of service, the 138 KV main transformer was removed from the sito and moved to another substation. The alternate radwaste demineralizer skid became operable. The spent fuel pool (SFP) cooling system was modified and the SPF cooling skids became operable. One significant adverse event
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occurred which resulted in 3 inches of SFP water being siphoned to the SFP surge tank.
Facility Manaaement and Control The transition into the DTS went smoothly on January 29,1999, without any regulatory e
concems.
The licensee adequately justified their conclusions that their planned modification to e
SFP cooling did not represent a change to technical specification requirements, unreviewed safety questions, or conditions contrary to the requirements of 10 CFR 50.59.
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The results of independent self-assessments and third party reviews of Big Rock Point's e
(BRP) activities were well communicated to the BRP management staff and significant items were entered into the corrective action system for tracking and followup, i
The material integrity of systems, structures, and components necessary for the safe e
storage of spent fuel and conduct of safe decommissioning was being maintained, The BRP record retention program was being implemented as required by regulatory e
requirements and industry guidance. Also, records were retrievable, well kept and ery legible.
Changes to procedures were reviewed and approved in accordance with technical e
specifications and regulatory requirements.
Decommissionina Suooort Activities The failure of the main diesel generator to start was properly evaluated as a
. e maintenance preventable functional failure, and categorized as an A-1 item.
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Decommissioning activities are now being conducted from the monitor station and the
control room is now being dismantled.
Spent Fuel Safety
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e The safety of the fuelin the SFP was being maintained.
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e A SFP drain down of 3 inches of water was caused by siphoning the SFP to the SFP surge tank through temporary hoses (TRI-NUKE suction hoses). Failure of the goveming procedure to control the hose alignment constituted a violation of technical l
specification requirements. There were no adverse consequences from the event.
The new attemate SFP_ cooling skid will allow more efficient cooling of the SFP without
the potential for intersystem cross contamination. Eliminating the need for the reactor cooling water system in the plant removes another system from service and allows decommissioning activities to proceed more easily and safely. The safety of the fuel in the SFP is being maintained by this modification.
Radioloalcal Safety Radiological safety activities were being conducted safely and in compliance with e
applicable requirements.
The radiological safety program showed some improvement during the inspection
period. Many of the program enhancements identified in the Radiation Protection and Environment Services Master Plan were achieved.
ALARA reviews were conducted prior to the start of the project to remove and ship
materials from the SFP Those reviewed appeared to be adequately researched and comprehensive in scope.
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Report Details Summary of Plant Activities During the inspection period, equipment not necessary for the safe storage of spent fuel and potentially hazardous components and materials were removed from the facility. Also, additional plant systems were classified as not needed for safe storage of fuel. The defueled
technical specification (DTS), were implemented, the monitor station was staffed and the control room was left unstaffed, the last electrical load was placed on decommissioning power and the breaker on the 46 KV line to the station substation was permanently opened. After 37
' years of service, the 138 KV main transformer was removed from site to take up a continuing i
life in another substation. The alternate radwaste demineralizer skid became operable. The spent fuel pool (SFP) cooling system was modified and the SFP cooling skids became functional. One significant adverse event occurred which resulted in 3 inches of SFP water being siphoned to the SFP surge tank.
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i 1.0 Facility Management and Control l
1.1 General The inspector conducted frequent reviews of ongoing plant activities and attended licensee meetings and reviews addressing these activities, in order to assess overall
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facility management and controls. Specific events and findings are detailed in the l
sections below.
l 1.2 Oraanization. Manaaement. and Cost Controls at Permanentiv Shut Down Reactors I
(36801)
1.2.1 Generai The inspector selectively reviewed the licensee's activities involving overall management l
and control of the decommissioning process. The effectiveness of the licensee's review of regulatory information applicable to the facility was selectively examined.
i The requirements for the onsite staffing complement during the backshift has changed with the implementation of the DTS from 5 persons to 2 persons. No shift staffing problems were noted.
1.3 Safety Reviews. Desian Chanaes. and Modifications at Permanently Shut Down Reactors (37801)
1.3.1 General The inspector examined the licensee's safety review program to ascertain that the program was effective at identifying potential unreviewed safety questions in accordance with 10 CFR 50.59. The activities of the licensee's onsite and offsite safety review committees were evaluated to determine whether they were fulf;lling their respective charters, the requirements of Technical Specification (TS) and the requirements of the quality assurance plan.
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The DTS chenged the plant review committee (PRC) to the safety review committee l
(SRC). The quorum has changed from chairman (plant manager) and 4 members to l
chairman (engineering manager) and 2 members. The requirements for the PRC were I
in the TS. The requirements for the SRC are in CPC-2A, Quality Description for Nuclear Power Plants, Appendix B.
1.3.2' Plant Safety Reviewed Committee and Safety Review Committee Review of Modification and Procedures a.
Inspection Scope (4270_Q)
l The inspector observed several PRC and SRC meeting during this inspection period.
b.
Observations and Findinas l
After implementation of the DTS, the functions of the PRC were conducted by the SRC.
When attending PRC and SRC meetings, the inspector observed that a quorum was present and that the members understood the change to the procedure or plant modification under discussion. The members held challenging discussions on items and at times retumed procedures or modification to the author for more work prior to determining that the change did not create an unreviewed safety question. With the
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changes in DTS, changes were required to plant procedures to ensure that the requirements of the DTS were included in the plant procedure.
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Based on these observations, the inspector determined that there were no required changes to TSs, no Unreviewed Safety Questions identified, and the requirements of
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10 CFR 50.82 were met.
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Conclusion After detailed challenging discussion for modifications to the plant and changes to plant procedures, the PRC and SRC found no unreviewed safety questions during this inspection period.
1.3.3 Monitored Decommissionina Activities The inspector attended licensee meetings where the planning, reviewing, assessing, and scheduling of decommissioning activities were observed. The inspector ascertained that activities were in accordance with licensed requirements and docketed commitments as stated in 10 CFR, TS, DTS, Final Hazards Summary Report, Post-Shutdown Decommissioning Activities Report (PSDAR), and Defueled Emergency Plan (DEP). Decommissioning activities monitored by the inspector were as described in the following sections.
1'3.4 Plant Systems and Comoonents Removed from Service
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Plant systems and components determined not needed for the safe storage of spent fuel and permanently removed from service during this inspection period were:
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e portions of the main condenser portions of the control rod drive system e
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e portions of the service water system portions of main turbine casing o
portions of the picnt electrical system were transferred to the decommissioning e
power system plant station electrical power e
station battery e
a main 138 KV transformer e
138 KV transmission line to plant substation e
46 KV transmission line to plant substation e
portions of plant control room spent fuel pool cooling system o
o reactor cooling water system 1.3.5 Plant Modifications Specific design changes or modifications were reviewed to assess program effectiveness in application. This included a review of written safety evaluations and other records. In addition, a sample of maintenance and r?oair activities was reviewed to ascertain whether the licensee had made changes to the facility without properly c
invoking their safety review process.
Plant modifications that were in progress or completed during the inspection period were:
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e Installation of a decommissioning power system was completed.
Installation of the alternate radwaste demineralizer and filter system was e
completed (process flow rate is about 25 gpm).
Transfer of plant instrumentation required for monitoring the safe storage of
stored spent fuel and monitoring radiological hazards to the monitor station was completed.
The monitor station became operational and is staffed.
- e Planning for dry cask storage of spent fuel.
Planning for chemical decontamination of chromated systems.
- Planning for the SFP clean out project.
- e Condensate pump room dismantlement was completed ahead of schedule and under budget.
Two major criteria used by the licensee for scoping decommissioning activities were
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ennual budgeted money and budgeted person-rem exposure. The inspector had no concems with the scope and status of monitored decommissioning activities. Further, the inspector detennined that no unreviewed safety questions were developed by the above changes, and the changes were within the requirements of 10 CFR 50.82.
1.3.6 Altemate SFP Coolina Skid a.
Inspection Scope The inspector evaluated the design and associated safety review program to ensure against potential unreviewed safety questions during the modification to spent fue! pool (SFP) cooling system. (See Section 3.4 for the design details)
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Observations and Findinas The inspector reviewed the safety evaluation for FC-699, " Alternate Spent Fuel Cooling."
included in this review was an evaluation of the following Engineering Analyses that were performed for this modification:
EA FC-699-01, " Alternate SFP Cooling Skid" EA FC-699-02, " Cooling Skid Ampacity and Voltage Drop Calculations" EA FC-699-03, "SFP Cooling Skid Hydraulic Calculations" EA FC-699-04, " Qualification of Slab at EL 600 ft - 6 ins and SFP Skid an Change" EA FC-600-05, " Calculation of SFP Decay Heat" EA FC-600-06, "SFP Decay Heat Forecast" EA FC-600-07, "SFP Water Piping" EA FC-600-08, " Equivalent Evaluation of Garlock Style 3200 Gasket Material" EA FC-600-09, " Specification 3159M-53 Exception Evaluation" c.
Conclusions The licensee adequately justified their conclusions that their planned modification to the SFP cooling did not represent a change to TS requirements, unreviewed safety questions, or conditions contrary to the requirements of 10 CFR 50.59.
1.3.7 Manaaed Plant Hazard Reductions The primary hazardous material removed from the plant during the inspection period was asbestos, which is a biological hazard. Approximately 75 percent of the asbestos on plant systems has been removed. Small amounts of mercury from plant instrumentation has been removed and an action plan has been established to remove the mercury from the remaining plant instrumentation. The plant developed a colored tape and colored plastic bag system to bag hazardous material at the work site so that
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the hazardous material does not end up in the wrong waste stream.
1.4 Self-Assessment. Auditina. and Corrective Action (40801)
1.4.1 General The licensee's controls for identifying, resolving and preventing issues that degrade safety or quality were examined, including self-assessments, auditing, corrective actions, safety review ccmmittees, root cause evaluations and third party reviews.
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The quality assurance (QA) plan and applicable implementing procedures formed the basis for the inspection. In addition, the procedures were evaluated from the perspective of their adequacy to accomplish the objective of assuring that management and staff are knowledgeable of plant / activity performance and contribute effectively to safety and quality in conduct of important activities.
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i 1.4.2 Indeoendent Assessmeint of BRP Activities
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Inspection Scope (40801)
l The inspectors held a discussion with Nuclear Performance Assessment Department (NPAU) assessors, attended NPAD exit meetings, reviewed NPAD audits and reports, and condition reports written by NPAD. The condition report provides tracking of the l
finding and assigns resources to determine the root cause of the finding so that the root cause can be corrected. The inspector also observed NPAD auditing the licensee. The
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inspector attended third party reviews (independent safety review group (ISRG))
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meetings and a restoration safety review comroittee (RSRC) meeting.
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Observations and Findinas t
The on site leader of NPAD meets with plant management once a month to discuss
NPAD's findings, and answer any questions on the findings. The conditions adverse to quality are also entered into the plant corrective action system to ensure followup.
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The ISRG discussed items with the management staff which they considered safety issues. The ISRG also reviewed the plant plans for the SFP clean out project with plant management and asked challenging questions.
The ISRG and RSRC both met with plant management and discussed the elements of draining 3 inches of water from the SFP (see Section 3.3).. Management assured them that a Level 1 investigation was the correct approach to take to glean the most information to proceed safely with SFP activities.
The RSRC is a third party SRC of three industry experts in the area of decommissioning nuclear power plants. This committee is not required by TSs, but was formed to provide management with oversite and guidance on activities effecting decommissioning activities. The RSRC meets at the site for 3 days about quarterly,
The RSRC methology of operation is as follows: subcommittees discuss items of j
interest with members of the plant staff, the subcommittees report their findings to the i
plant management, the RSRC then obtains commitments from the general site manager to resolve the issue. The RSRC provides a written report to the plant general manager.
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The RSRC report contains action items and items for consideration by plant management. These items are tracked and closed out in a future report.
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Conclurion i
The results of independent self-assessments and third party reviews of BRP's activities were well communicated to the BRP management staff and significant items were entered into the corrective action system for tracking and followup.
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1.5 Decommissionina Performance and Status Review at Permanently Shut Down Reactors (71801)
1.5.1 General Decommissioning, and licensee and contracted workforce conduct of decommissioning
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activities were evaluated to determine if these activities were performed in accordance with licensed requirements and commitments. Control and conduct of facility decommissioning activities were examined to verify the requirements of the license, TS, and DTS, were followed; and the requirements and commitments described in the Updated Final Hazard Summary Report, PSDAR, and DEP were followed. Specific events and findings are detailed in the section below.
1.5.2 Implementation of Defueled Technical Specifications (DTS)
On December 24,1998, the NRC approved the BRP DTSs. After revisions to many plant procedures to ensure that the DTS requirements were included, on January 29, 1999, the licensee implemented the DTS.
The DTS shifted the safety focus from an operating reactor to those structures, systems, components and activities important to the safe storage of spent fuel (ISSSF)
and important to monitoring and control of radiological hazards (IMCRH).
The DTS changed the knowledge requirements of the shift supervisor position. The qualification requirements of the shift supervisor position have changed from the qualifications of a licensed senior reactor operator (SRO) to that of a certified fuel handler (CFH), an individual who is qualified in accordance with BRP NRC approved
" Certified Fuel Handler initial Certification Program."
On February 22,1999, the shift supervisor position was filled by a previous licensed control operator who is a CFH. The minimum staffing for operations without fuel handling is 2 persons. The minimum staffing during fuel handling operations is 4 persons.
The transition into the DTS went smoothly without any regulatoiy concems.
1.5.3 Plant Tours to Evaluate Material Conditions. Housekeepina. and Fire Protection 1.5.3.1 Material Conditions a.
Inspection Scope The inspector conducted plant tours to evaluate the material integrity of SSCs necessary for the safe storage of spent fuel and conduct of safe decommissioning.
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Observations and Findinas After conducting plant tours, the inspector determined the material integrity of SSCs of systems ISSSF was being maintained. The inspector discussed tour observations with plant management. The inspector also observed that plant management was actively monitoring plant material conditions.
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Conclusion The material integrity of SSCs necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained.
1.5.3.2 Housekeeoina
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Inspection Scc.. e The inspector conducted plant tours to observe and assess the status of facility housekeeping. The inspector also assessed whether field conditions would contribute to safe decommissioning or would represent conditions adverse to plant or personnel
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safety, i
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Observations and Findinas The insnector's observations focused on the areas adjacent to and containing SSCs necessary for the safe storage of spent fuel, radiological effluent control, or radiation protection and monitoring. The inspector determined that all areas of the plant were kept clean and free of the accumulation of dismantlement debris. As materialwas
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disassembled, it was placed into metal boxes. Portable cables were routed so as not to cause tripping hazards. General area housekeeping was good with no areas of inspector concem during this period.
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Housekeeping was good during this inspection period.
1.5.3.3 Fire Protection a.
Inspectioi Wooe
The inspector conducted plant tours to observe and assess the storage of combustible and flammable materials. The inspector also determined the presence and effectiveness of the site fire brigade.
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Observations and Findinas The inspector determined that the storage of combustible and flammable materials was within the fire loading limits for transient combustibles and that combustible materials were not accumulating in the plant. The inspector determined that fire fighting equipment and stations were properly maintained, inventoried, and ready for use. The inspector also determined that installed fire detection and suppression systems were effectively maintained, surveillances were performed, and the equipment ' as capable of performing the intended functions.
With the implementation of the DTSs, the plant fire responder's requirements changed from a 5 person sti"Jctural fire brigade to a 3 person incipient fire brigade. The incipient fire brigade members will only fight fires in limited circumstances: when they are able to safely fight in normal clothing, are not required to crawl or take evasive actions to avoid smoke and heat, are not required to wear thermal protective clothing or self-contained
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bratthing apptrctus, and are abla to fight tha fira effsetivsly with portable extinguishers or hand lines flowing up to 125 gpm. Because of the reduction in fire response, when a fire is reported to the monitor station or a fire alarm is received, the Charlevoix Township Fire Department will be called to the site. In the past they were only placed on stand-by.
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Conclusion Control of combustible materials and operation of fire equipment were properly maintained. After implementation of the DTSs, the structural fire brigade was changed to an incipient fire brigade.
1.6 Records Proaram a.
Inspection Scooe (39701)
The inspector reviewed the licensee's implementation of the records program to verify that it was in conformance with regulatory requirements, TSs, and industry guides and standards, b.
Obser lations and Findinas The inspector reviewed the following items related to record retention:
TS Section 6.10, Record Retention CPC-2A, Quality Program Description for Nuclear Power Plants e
ANSI /N45.29-1979, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants e
ASME NQA-1-1997 Edition, Quality Assurance Requirements for Nuclear Facility Applications The inspector conducted a tour of the onsite records storage vault and found that records were stored as required, fire protection was in place, and vault security was being implemented. The inspector also held conversations with record store personnel and determined that the requirements of the record storage program were being implemented.
The inspector had the licensee retrieve the following records from the remote record
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storage facility; e
Flux Level Channel Chart Number 2 Dated 12/8/95 e
Flux Level Channel Chart Number 3 Dated 12/10/96 o
Noble Gas Chart Dated 12/14/95 e
Noble Gas Chart Dated 12/19/96 The original chart records were retrieved in a timely manner, and they were well kept and very legible.
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Conclusion The BRP record retention program was being implemented as required by regulatory requirements and industry guidance. Also, records were retrievable.
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1.7 Plant Procedures a.
Inspection Scope (42700)
The inspector attended PRCs and SRCs and reviewed changes to procedures to determine if the changes to plant procedures were reviewed and approved in accordance with TSs and regulatory requires.
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Observations and Findinas
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The inspector attended PRC and SRC meetings that discussed and reviewed the procedure changes required to align the plant procedures with the DEP and the DTSs.
Technical item, were discussed until the words in the procedure were clear, accurate, and had the same meaning to all members of the committee. Human factors were also considered in the changing of these procedures. Each procedure change was evaluated to determine if an unreviewed safety question was created. None were created.
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Conclusion Changes to procedures were reviewed and approved in accordance with TSs and regulatory requirements.
2.0 Decommissioning Support Activities
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2.1 Maintenance and Surveillance at Permanentiv Shut Down Reactors (62801)
2.1.1 General The inspector evaluated maintenance and surveillance for SSCs potentially affecting the safe storage of spent fuel and reliable operation of radiation monitoring and effluent control equipment. Direct observations, reviews, and interviews of licensee personnel were conducted to assess whether maintenance and surveillance were performed in i
accordance with regulatory requirements and resulted in the safe storage of spent fuel and reliable operation of radiation monitoring and effluent centrol equipment. This included the proper implementation of TS, DTS, and 10 CFR 50, Appendix B requirements, l
2.1.2 Dismantlement Activities (62801)
Dismantlement activities observed or evaluated by the inspector during the period were:
removal of condensate pumps and system piping removal of portions of the control room e
o removal of lower turbine casing
removal of control rod drive system piping i
e removal of the SFP sock filter tank The inspector observed that proper maintenance and health physics survey practices were performed during these activities.
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2.1.3 Maintenance Rule A-1 Cateaorv ltem a.
Inspection Scope (62801)
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The inspector determined that equipment failures are evaluated for the maintenance rule, if the failure was a maintenance preventable functional failure (MPFF), the-
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inspector determined if the failed item was categorized as A-1.
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Observations and Findinas
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- On January 14,1999, while performing surveillance test T7-28, Main Diesel Generator (MDG) Test, the MDG failed to start within the prescribed time limit of 30 seconds.
Investigation determined that the governor control fuel rack linkage was not in the fully reset position. This linkage allows the MDG to receive fuel oil in the starting process.
Condition Report (CR) C-BRP-99-0017 was written. Procedure T7-28 has a step after engine shutdown to reset this linkage, and prior to starting the engine the operator verifies this linkage is reset. The most probable cause for the start failure was the linkage was only partially reset. At the time of the failure the MDG had no operability requirement. The MDG was the previous Emergency Diesel Generator (EDG). It is the i
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same piece of equipment that has been renamed for the decommissioned plant.
The CR was reviewed and this failure to start was determined to be a MPFF. On February 17,1999, the MDG was moved to category A-1. Since the failure to start of the MDG, T7-28 has been run 4 times without problems.
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Conclusion The failure of the MDG to sta t was properly evaluated as a maintenance preventable functional failure, and categotized as an A-1 item.
2.2 Ooerational Safety Verification (71707)
2.2.1 General The inspector conducted frequent reviews of ongoing decommissioning activities.
Specific events and findings are detailed in sections below.
2.2.2 Retirement of Control Room and Activation of the Monitor Station The BRP control room was officially retired on February 12,1999, after more than
37 years of service. Since 1962, licensee shift supervisors, control operators and auxiliary operators have guided the plant through hundreds of start-ups, shutdowns and other activities from the control room. The operators performed the final reactor i
shutdown from the control room on August 29,1997.
A monitor station was built to be the opt..ating control facility in the defueled plant. The
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instrumentation in the monitoring station is two identical computer systems and a fire alarm panel. The only plant equipment operated from the monitor station are the containment vent valves. The information displayed on the computers relates to safe storaga of spent fuel and radiation and process radiation monitors. Alarms received at the monitor station are also received on pagers worn by the operators.
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After implementation of the DTSs, on February 12,1999, the operators staffed the control room for the last time and the last instrument output was transferred to the
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monitor station. The monitor station and the control room had both been staffed for about a week.
The monitor station fits the needs of a decommissioning plant. Additional alarms are in place for monitoring the water level and temperature in the SFP, radioactivity in the SFP ares, and radioactivity in the effluent leaving the plant. The decommissioning power substation is also monitored by the monitor station. These upgraded features allow operation personnel to monitor important plant systems from a remote location in addition to performing routine rounds.
Additional NRC approved certified fuel handling training, and other training qualifies operators to manage the monitoring station, making them monitoring station operators
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(MSOs). Currently, three MSOs will be on duty at all times; with at least one physically in the station. The pervious shift supervisors (SROs) are no longer required under the DTSs. After February 22,1999, they were freed to assist with other decommissioning projects at the plant.
While only one computer is required, two are housed in the monitoring station to track and display the status of plant components. The MSOs also have two pager-type devices that display alarms. These portable " pagers" will inform them of any alarms while they are away from the monitor station performing station rounds.
Decommissioning activities are now being conducted from the monitor station and the control room is now being dismantled.
3.0 Spent Fuel Safety 3.1 General The inspector evaluated the performance or condition of SSCs associated with storage, control, and maintenance of spent fuel in a safe manner.
3.2 Soent Fuel Pool Safety at Permanentiv Shut Down Reactors a.
Inspection Scope (60801)
The inspector evaluated spent fuel and fuel pool safety. Factors considered in the evaluation included SFP heatup rate; SFP instrumentation, alarms, and leakage detection; SFP chemistry and cleanliness control; criticality controls; and SFP operation and power supply. The inspector reviewed station logs and held discussions with the licensee. The inspector also inspected the SFP and SFP support system's valve lineups during plant tours.
b.
Observations and Findinas The inspector reviewed the Auxiliary Operatorlogs'containing SFP parameters and j
locally monitored SFP level and tempersture. The inspector verified the criticality monitor was functioning. The inspector also observed that foreign material controls were being used in and around the SFP.
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Conclusion The safety of the fuelin the SFP was being maintained.
3.3 Siohonino Soent Fuel Pool Lowers Water Level a.
Insoection Scope (60801)
The inspector investigated the circumstances that resulted in the SFP water being siphoned into the SFP surge tank. The inspector reviewed the Defueled Operating Procedure DOP-3, Spent Fuel Pool Operation, and determined that the licensee's procedure did not maintain proper control over temporary hoses to prevent draining the SFP by siphoning.
b.
Observations and Findinas DOP-3, Spent Fuel Pool Operations, Revision 2, Dated 1/27/99, Section 6.9 TRI-NUKE OPERATION did not contain specific steps to use the TRI-NUKE (underwater vacuum filter unit) to vacuum the SFP surge tank. On February 3,1999,3 inches of SFP water was siphoned to the SFP surge tank after vacuuming sludge from the bottom of the surge tank. The TRl-NUKE unit was sitting in the SFP. It had two suction hoses. One suction hose was in the SFP about six feet below tho surface of the pool. The other suction hose was used in the SFP surge tank for vacuuming. The TRI-NUKE pump was
stopped and the hose was left in the SFP surge tank when the crew took a lunch break.
A siphon path was set up from the SFP suction hose and through the TRI-NUKE unit into the other suction hose into the SFP surge tank. The water overflowed the SFP surge tank out the overflow line which is hard piped into the containment clean water radwaste sump.
Within an hour, an auxiliary operator (AO) made his rounds. At the radwaste panel, he determined that the containment clean water radwaste sump had pumped down about 1,000 gallons of water. He contacted the AO assigned to cleaning the SFP surge tank and suggested that a siphon had been established between the SFP and the SFP surge tank. Both AO's went to the SFP and found the SFP level had dropped about 3 inches. An AO tumed on the TRI-NUKE pump and pumped water from the surge tank back into the SFP regaining the 3 inches of water lost, thus terminati, g the siphon event. At all times about 20 feet of water remained above the fuel racks.
Immediate corrective actions taken by the licensee were to stop the surge tank cleaning
- Job, remove the suction hose from the surge tank, and place a caution tag on the TRl-NUKE unit control panel stating, ' Caution siphoning effect may be established when the TRI-NUKE is shut down." A management team met and discussed the event. The management team determined that the CR (C-BRP-99-0034) would be a Level 1 (the highest level of investigation).
F-ollowup corrective action taken by the licensee was to make procedure changes to DOP-3 to include precautions that temporary hoses and piping shall be installed into the
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SFP in a manner that a siphon l' not created.
s This event was identified by the AO making his rounds by evaluating the sump data and concluding that the SFP was siphoning to the surge tank.
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The clsaning of thm SFP surga tank was performed using DOP-3, Ravision 2. Tha
procedure did not contain enough information to prevent draining the SFP by siphoning i
j through temporary hoses.
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The safety significance of the siphon event was small since the siphoning was stopped 1 inch above the SFP lower level alarm and above the procedure and TS low water level
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limit.
. BRP DTSs Section 6.6.1.1 requires that written procedures shall be established and implemented for activities important to the safe storage of spent fuel. These procedures
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shall meet or exceed the requirements of ANSI N18.7-1976, as endorsed by Quality Program Description (CPC-2A).
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CPC-2A, Quality Program Description for Nuclear Power Plants, Section 5.2 requires that procedures incorporate a description of the activity to be accomplished.
Section 5.2.7.e. ties the above requirements to nuclear safety measures (i.e., draining
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the SFP with nuclear fuel stored in the pool). The SFP surge tank was vacuumed on February 3,1999, without the descriptive steps being incorporated into DOP-3, resulting i
in siphoning and lowering toe SFP level 3 inches.
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This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with
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Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective
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action program as Condition Report C-BRP-99-0034. Siphoning 3 inches of water from i
.the SFP to the SFP surge tank is NCV 50-155/99001-01.
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Conclusion i
A SFP drain down of 3 inches of water was cau: ad by sip' ming the SFP to th C i
surge tank s..ough temporary hoses (TRI-NUKE suction hoses). Failure of the i
goveming procedure to control the hose alignment constituted a violation of TS
requirements. There were no aaverse consequences from the event, j
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3.4 Alternate SFP Coolina Skid l
a.
Insoection Scooe The inspection evaluated the change in SFP cooling that would occur with the addition of the new attemate cooling skid and what impact this wnuld have on SFP safety.
b.
Observations and Findinas The purpose of the attemate SFP cooling system is to allow the existing SFP cooling equipment to be isolated from other plant intertracking systems so major components can be dismantled in support of general plant decommissioning activities. The system is designed to support SFP storage until the fuel is removed to storage casks.
The system is being installed on three skids for ease of installation and removal. It is being rented instead of purchased for ease of removal due to construction concerns.
The licensee will be able to ship it back to the supplier even though it is contaminated instead of having to dispose of it as radwaste.
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Th3 n:w systsm will be cooled by tha existing strvice w; tar syst:m, climinating ths need to maintain the existing intermediate reactor cooling water (RCW) system
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connections to the SFP cooling system. The last use of RCW will enable the RCW
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system to be declared inoperable and dismantled in support of general plant decommissioning activities. It should be noted that the original design was intended to utilize an air cooler system. However, as development of the design progressed it became apparent that utilizing a water cooled system wac prudent.
The new equipment consists of two motor driven pumps, two double wall plate and
frame heat exchangers, a bag filter, necessary controls, instrumentation, and
interconnecting valves and piping, it is located inside the sphere where the SFP sock filter was located before it was removed. The equipment is arranged in parallel, so that only one pump and heat exchanger are necessary to remove the full anticipated SFP heat load, with the other pump and heat exchanger in standby. It is designed to
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maintain the SFP below its original design temperature of 98 degrees F. It can be attemately powered by the station backup power to prevent loss of SFP cooling in case of a loss of offsite power.
The new SFP cooling system will draw from the SFP via the existing surge tank. As such, no direct piping connection exists to the suction of the new pumps. The surge tank functions by water from the SFP flowing over a weir into the surge tank. A piping failure would cri!y result in the draining of the surge tank, but the SFP waNr level would not fall below the top of the weir.
The water level at the top of the weir provides approximately 20 feet of water over the top of the fuel assemblies. The new cooling system will return cooled water to the SFP via the existing SFP cooling return line. This line has siphon breaker holes approximately 2 inches below the normal SFP water level, eliminating the potential for
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any new or old piping failure to drain the pool.
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The new control room relocation / monitoring station will provide for SFP temperature and level, indication and alarm. This is an improvement from the existing control room which
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monitored temperature, in addition, a new SFP cooling skid trouble alarm will be m
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o,. ded to alert the operators to conditions such as high temperature, pump trips, high M :r differenual pressure, and high radiation levels in the vicinity of the cooling skid.
Yr.3 operators would be prompted to check the local indications on the skids.
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Conclusions
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The new attemate SFP cooling skid will allow more efficient cooling of the SFP without the potential for intersystem cross contamination. Eliminating the need for the RCW system in the plant removes another system from service and allows decommissioning activities to proceed easier and safer. The safety of the fuelin the SFP is being maintained by this modification.
d 4.0 Radiological Safety 4.1 General The inspector conducted reviews of ongoing activities in order to assess the overall Radiation Protection (RP) program. Specific findings are detailed in the sections below.
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l 4.2 Occupational Radiation Exoosure a.
Insoection Scope (83750)
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The inspection examined and evaluated aspects of the Radiation Protection and Environmental Services (RP&ES) program. The inspection concentrated or: progress made in implementing the RP&ES Master Plan for correcting deficiencies identified in l
the RP&ES program.
b.
Observations and Findinas i
e In Inspection Report 50-155/98008(DNMS) it was noted that several managerial changes had been made in the RP&ES program. One additional managerial change
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was made during the inspection period, a new Radiation Protection Manager (RPM) was i
appointed. Since no additional changes in RP&ES management structure are
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anticipated in the near term, there should now be some stability in a program that has been in flux since the summer of 1998.
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l A review of the new RPM's credentials indicated that the new RPM was well qualified by i
experience and training in the field of reactor health physics to hold the position of RPM.
The RPM's qualifications exceeded those specified in Regulatory Guide 1.8, September l
1975, to hold the position of RPM (Health Physics Manager).
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In Inspection Report 50-155/98005(DNMS), weaknesses in the RP&ES program were
. discussed. In that report it was also noted that a fermal plan, the 'RP&ES Master Plan"
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dated October 20,1998, had been develn ped to address those weaknesses. The Plan also defined the areas in the RP&ES pror ram that needed improvement. The Plan also established milestone dates for each ster in the improvement process and assigned resources, named interfaces with other departments (programs) and defined the risks from not correcting the programmatic weaknesses. During the inspection, the inspector reviewed the latest update of the Plan and interviewed the new and former RPMs to discuss management's progress in implementing the Plan.
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The RP&ES Master Plan is divided into six sections each of which addressed a specific area within the RP&ES program. The sections include personnel safety and environmental services, ALARA planning, RP, radwaste, assessment and technical support, and completed / transferred (incorporated projects. In each section specific actions were identified and each action was designed to either correct a known deficiency or to address a specific area in which improvement was deemed necessary.
The inspector noted the Plan had been updated regularly and each of the specific actions had been assigned an action ID number or had been designated as being completed. A review of the Plan indicated that while approximately 50% of the action items had been completed, many of the cornpleted items had addressed some of the more significant weakness in the RP&ES program.
In the area of Personnel Safety and Environmental Services, a partiallist of actions completed included the development and implementation of a hazardous waste disposition checklist and revising and improving the interface with planning on matters dealing with hazardous waste. Actions that had not been completed included consolidating all mixed waste into one designated building and training station personnel on the new Health and Safety Plan. Progress in this area indicated that the licensee
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was committed to enhancing worker safety and preventing hazardous wastes from being inadvertently being shipped with radioactive waste.
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In the area of ALARA Planning the completed items included but were not limited to establishing a mechanism for separating standard Radiation Work Permit (RWP) dose
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from total station dose to establish general RWP exposures for trending, identifpng areas in the plant that needed additional shielding and inventorying the existing lead.
Some of the actions that still need to be completed include training on those actions that had been completed, establishing a mechanism for coordinating hot spot removal and the installation of shielding with all station groups (ALARA Planning, Scheduling,
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RP&ES, etc.), revising the RWP and ALARA procedures and develop a shielding tracking system. While the completed actions in this area demonstrate management's commitment to improving ALARA planning there continues to be problems with i
coordinating work activities, sticking to work schedules and integrating the ALARA planners into the planning process. As a first step in addressing these problems programmatically RP&ES management scheduled a R&ES self-assessment that would focus on work planning, ALARA planning, th coordination of work activities among all the work groups, and scheduling.
In the area of RP the completed items inclNed but were not limited to the completion of Back-to Basics training for all crafts, revif.ng the survey schedule and revising and improving the survey documentation. Fame actions that still need to be completed included revising procedures to ensure that survey documentation flow path is identified and the process well understood a' d the completion of a RP&ES self-assessment of radworker practices. This ma is one to which management can point to demonstrate that the corrective actions undertaken have been effective in reducing poor radworker practices. The number of poor radworker practices observed by NPAD auditors in the field have declined significantly and the number of poor practices reported in CRs.
However, even wMh these improvements the RP area continues to warrant close management attention. Recent incidents have pointed to problems in RP&ES interdepartmental communications, the flow of information at the restricted area access
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point and the speedy processing of RWPs when radiological conditions change at the work site. RP&ES management was aware of these problems and included an assessment of them in the scheduled RP&ES self-assessment of radworker practices.
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In the area of radwaste almost all of the action items have been completed. The items completed included the development of methodologies to support RWP reviews for waste processing issues and the development of supentisory performance guidelines.
In addition, a Radioactive Waste Transition Plan was developed to streamline the radioactive waste and transportation program and that Plan has been fully implemented.
Items implemented in the Plan included the development of a radwaste QA program, the building of a waste rmessing room, and the development of a radwaste planning and scheduling propMr.. / I of these changes taken collectively point to management's commitment to imprc
.g the radwaste and radwaste transportation program. The success of these changs have been evident in that no transportation incidents involving radioactive or hazardous materials have occurred since the fall of 1998.
Many of the action items in the areas of Assessment and Technical Support and l
Completed / Transferred (incorporated) projects do not relate directly to performance issues in the RP&ES program. Two, however, have direct bearing on improving the program. The two items included creating a RP&ES self-assessment program and
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reviewing and revising RP&ES operating procedures. The creation of a RP&ES self-assessment program was seen as critical to addressing programmatic issues in the RP&ES program. Prior to the Master Plan, the RP&ES program rarely performed formal intemal self-assessments. The assessments that were performed were usually informal and the results not well documented. The inspector noted that RP&ES had begun to perform self-assessments and several were completed prior to the inspection. Those ascessments will be reviewed during future inspections. Another critical action item was the review and revision of RP operations procedures, many of which were outdated, contradictory, ambiguous and overly complex. Problems with inadequate procedures had been identified by the licensee and the NRC as one of the most significant contributors to the problems noted in the RP&ES program. Reviewing and revising the procedures was viewed as one of the most important action items in the RP&ES Master Plan.
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Conclusions Since the beginning of decommissioning, the RP&ES program has had to deal with difficult and ever changing conditions. Many new RP technicians unfamiliar with BRP were hired, inexperienced individuals were promoted to management positions, I
procedures were poorly written and ambiguous, training was marginal and the work
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force changed constantly. When problems were reported they were usually dealt with as stand alone isolated events and NPAD adverse findings were not routinely incorporated into CRs. Many of these problems were brought to management's attention but formal programmatic assessments were seldom performed. Throughout the period, however, the performance indicators indicated that the RP&ES staff was performing their duties professionally and for the most part mistake free. Doses were kept within budget, contamination was kept under control and adverse radworker incidents were kept to a minimum. The problems in the RP&ES program were the result of programmaticissues and not the performance of the RP&ES staff.
The inspector noted that many of the action items in the Master Plan were intended to
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improve the conditions in which the RP&ES staff perform their duties and not as a means to correcting poor RP&ES staff performance. Based on reviews of the RP&ES
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Master Plan and !nterviews with individuals responsible for implementing the Plan, the licensee appea;4d to be making good progress in addressing many of the programmatic
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weaknesses in the RP&ES program. Fullimplementation of the Master Plan should provide a stable managerial environment, well written procedures, an effective planning process and effective programmatic self-assessments.
4.3 Processina and Removal of Materials from the SFP a.
Inspection Scope (83750. 83728)
The inspector reviewed the licensee's progress in planning for the processing and removal of materials (control rod blades, incore detectors, etc.) from the SFP. During
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the inspection the inspectors reviewed the RWP No. B993033, Revision 0, " Processing
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CRBs and incore detectors in SFP/RX vessel for shipping and disposal," the ALARA 4-Review (No.110, dated January 6,1999), and the ALARA Checklist (No.110, dated
January 5,1999. The inspector also discussed the project with members of the ALARA Planning and RP staff.
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Qhgervations and Findinos -
The ALARA RevieN and the RWP properly addressed the anticipated radiological conditions, access control, the use of mock-up training, and contamination control issues. The licensee also generated specific dose goals for all phases of the project
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licensee's controls also addressed RP technician oversight of the evolution. For example, the RWP and ALARA review required RP technicians to be present during the l
movement or removal of material (CRBs, incore detectors, etc.) stored in the SFP. The
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RP controls also addressed radiological survey requirements and the need for contingency plans when the radiological conditions at the work site change significantly
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from those expected. For example, the RWP provides specifi'
'Nctions to those
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present if the general area radiation levels increase by 50 per e r the radiation levels on components exceed removed from the pool exceed 90C.!hr * 30 cm. RP&ES management also indicated during the inspection that the R dans would have stop work authority throughout the project and stop work auti,ority'. wid be discussed and the pre-job briefings. The ALARA review also discussed airborrie control and the need for identifying and controlling hot particles.
As directed by the AMRA Review, the licensee made plans to conduct mock-up training for all phases of the project. That training would include the processing /decon of the shield cask and dry runs of ali of the projects primary work processes. The training would begin immediately before the early March 1999, start of the project. The ALARA l
planner indicated that the RWP and ALARA Review and Checklist were all living documents and changes would be made to the documents based on experiences gained during mock-up training and during work on the project.
l Reviews of the ALARA Checklist and discussions with RP staff indicated that the project l
initial briefing and daily pre-job briefings had been well planned. The material to be covered during the briefings would include RWP requirements, tools, contingencies, dose goals, work goals and access and work control. The licensee also indicated that i
l briefings during the project would be scheduled to be the subject for one of RP&ES's
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self-assessments.
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Conclusions The RP&ES and ALARA planning staff provided effective planning for the SFP material processing and removal project. The RP planning documents provided good radiological controls and identified radiological hold points and contingencies. The material to be covered during mock-up training appeared adequate to ensure that the work crews were familiar with the radiological environment and RP controls at the work i
site, 4.4 Radwaste Treatment. and Effluent and Environmental Monitorina (84750)
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I The inspection included an evaluation of various aspects of licensee activities in the l
areas of waste treatment and effluent and environmental monitoring to ensure that I
radioactive waste treatment systems were being maintained and operated to keep
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onsite and offsite doses Al. ARA; to ensure that the licensee effectively controlled, monitored, and quantified releases of radioactive materials to the environments; and to ensure that required radiological environmental monitoring programs were effectively implemented. No problems were noted in review of these activities.
4.5 Solid Radwaste Manaaement and Transoortation of Radioactive Materials (86750)
The inspection included an evaluation to determine whether the licensee properly processed, packaged, stored, and shipped radioactive materials, in order to assess the potential for safety problems resulting from these activities and from the transportation of radioactive materials. No problems were noted in the evaluation of this area.
4.6 Conclusions i
Radiological safety activities were being conducted safety and in compliance with applicable requirements.
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5.0 Exit Meeting Summary
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The inspector presented the inspection results to members of licensee management at the l
conclusion of the inspection on February 25,1999. The licensee acknowledged the findings.
presented. The inspectors reviewed proprietary information related to the SFP cooling skids.
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None of that information is contained in this report. The licensee did not identify any others of
' the documents or processes reviewed by the inspectors as proprietary.
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.. g PARTIAL LIST OF PERSONS CONTACTED
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Licensee M. Bourassa, Licensing Supervisor L. Darrah, Technical Support & Assessment Superintendent (RP&ES)
G. Debner, Nuclear Engineering Supervisor G. Hausler, Work Control Supervisor
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C. Jurgens, Planning, Maintenance & Construction Manager M. Lesinski, Radiation Protection and Environmental Services Manager (RP&ES)
R. McCaleb, Nuclear Performance Assessment, Site Lead (NPAD)
G.' Petitjean, Senior Engineer L. Potter, Maintenance Supervisor
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l K. Powers, Site General Manager J. Rang, Industry issues G. Rowell, Corrective Action Supervisor G. Szczotka, Manager, Nuclear Performance Assessment Department (NPAD)
W. Trubilowicz, Operations, Cost Engineering & Scheduling Manager M VanAlst, Security Manager R. Wills, Radwaste Superintendent G. Withrow, Engineering & Licensing Manager K. Wooster, Emergency Planning Coordinator E. Zienert, Human Resources & Administrative Department Manager INSPECTION PROCEDURES USED IP 36801:
Organization, Management, and Cost Controls at Permanently Shut Down
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Reactors IP 37801:
- Safety Review, Design Changes, and Modifications at Permanently Shut Down Reactors IP 39701:
Record Program IP 40801:
Self-Assessment, Auditing, Corrective Action IP 42700:
Review of Modifications and Procedures
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IP 60801:
Spent Fuel Pool Safety at Permanently Shut Down Reactors-lP 62801:
Maintenance and Surveillance at Permanently Shut Down Reactors IP 71707:
Operational Safety Veri'ication IP 71801:
Decommissioning Performance and Status Review at Permanently Shut Down Reactors IP 63750:
Occupational Radiation Exposure IP 84750:
Radwaste Treatment, Effluent and Environmental Monitoring
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I IP 86750:
Solid Radwaste Management and Transportation of Radioactive Materials l
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ITEMS OPENED AND CLOSED
.00ened NCV 50-155/99001-01 Siphoning 3 inches of water from the SFP to the SFP surge tank.
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NCV. 50-155/99001-01 Siphoning 3 inches of water from the SFP to the SFP surge tank.
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LIST OF ACRONYMS USED AO-Auxiliary Operator ALARA As-Low-As-Reasonably-Achievable ANSI American National Standards Institute BRP Big Rock Point CFH Certified Fuel Handler CFR Code of Federal Regulations CRs Condition Reports DEP Defueled Emergency Plan DTS'
Defueled Technical Specifications EDG-Emergency Diesel Generator IMCRH Important to Monitoring and Control of Radiological Hazards ISRG Independent Safety Review Group ISSSF Important to Safe Storage of Spent Fuel LER-Licensee Event Report
'MDG Main Diesel Generator MPFF Maintenance Preventable Functional Failure
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MSO Monitor Station Operator NCV-Non-Cited Violation NPAD Nuclear Performance Assessment Department NRC Nuclear Regulatory Cor6 mission PRC Plant Review Committee PSDAR Post-Shutdown Decommissioning Activities Report QA Quality Assurance Radwaste Radioactive Waste RP Radiation Protection RP&ED Radiation Protection and Environmental Services
RPM Radiation Protection Manager RSRC Restoration Safety Review Committee RWP Radiation Work Permit SFP Spent Fuel Pool SRC Safety Review Committee SRO Senior Reactor Operator SSCs
. Systems, Structures and Components TS Technical Specification LICENSEE DOCUMENTS REVIEWED Licensee documents reviewed and utilized during the course of this inspection are specifically identified in the " Report Details" above.
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