IR 05000213/1997009
| ML20203E688 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 02/17/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203E548 | List: |
| References | |
| 50-213-97-09, 50-213-97-9, NUDOCS 9802270108 | |
| Download: ML20203E688 (23) | |
Text
- -
-. -.
... -
-.
.
.
..
.. -
. -
.~
.
-
- -.
.....
__
.
.
y Notice of Violation 2-
,
inspector at the facility that is the subject of this Notice, within 30 days of the date of the '
,
letter transmitting this Notice of Violation (Notice)..
Dated at King of Prussia, PA this 9th day of February,1998-i
^\\
-1 i
,
.l
I e
)
,
f a
f J
d L
t
-
9902270108I990217 PDR ADOCK 05000213 G
.
.
..
-
__
_
_
_
=.,-._
..
. _ _.,. _
__.
_
.-
-.._-
__. ~.....
_
__
_._ _._
. -_.
_
.
.
U.S. NUCLEAR REGULATORY COMM!SSION
REGION I
Docket No.:
50 213 Licensi No.:
DPR 61 Report No.:
50 213/97 09 Licensen:
Connecticut Yankee Atomic Power Company
,
362 Injun Hollow Road E. Hampton, CT 06424 3099
~ Facility:
Haddam Neck Station Location:
Ha Jdam, Connecticut Dates:
October 12,1997 - January 12,1998 Inspectors:
William Raymond, Senior Resident inspector Edward King, Security inspector Paul Frechette, Security inspector Joseph Nick, Radiation Specialist
,
'
.
l
- Approved by:
Ronald R. Bellamy, Chief, Decommissioning and Laboratory Branch
'
Division of Nuclear Materials Safety
!
,
.
e.
y w
.v-w w.--
v-r
---
w-y
,ww,r w
-
w-
-r
- -
T'
Y--7
-
--.
_--
-
- - - _- -
-
-
--
_
_
-..
-
-
.
.
.
,
EXECUTIVE SUMMARY
.
Haddam Neck Station
,
NRC Inspection Report No. 50 213/97-09 j
This integrated inspection reviewed decommissioning operations and planning, and included aspects of engineering, maintenance, and plant support. The report covers a three month period of resident inspection, and the results of announced inspections by regionalinspectors in the areas of physical securL/ and offsite surveys.
- Qs.commisaloriina Operations and Maintenance:
A Operator performance was good to monitor the status of operating plant equipment and those systems in a lay up condition. Operators perforraed well to monitor the spent fuel, and to respond to offnormal conditions. Maintenance and test personnel completed routine surveillance of plant equipment well, responded to degraded conditions and initiated actions to complete troubleshooting and repairs. Good work controls u e noted, including pre job briefs, Lontrol of tagouts, and adherence to work packages, foont Fuel Safety:
.
Engineering provided offective support to plant operations and decommissioning planning.
A good regard for spent fuel safety was noted in the actions to address beyond dnign basis events for the spent fuel pool. Fuel handling activities were conducted in a safe and deliberate manner. Preparations were thorough, and adhtrence to procedures and periodic checks wera good to assure safe handling and compliance with license requirements.
The licensee showed good performance to identify and evaluate an old design deficiency in the spent fuel building ventilation system. One violation of NRC requirements was identified, and an open item will track long term actions to correct the design deficiency.
An open inspection item will track NRC review of the adequacy of licensee actions to classify the spent 'Juel pool cooling and support systems.
Decommissionir.a Plannina:
Good performance was noted la the planning and support activities to prepare for decommissioning. The artifact removal project was well planned and implemented, with
'
good preparations and mockup trainio, thorough pre-job briefings, and excellent controls for activities in progress.
Plant Support and Radioloalcal Controls:
Licensee radiation surveys and controls in the past were not adequate to assure contaminated blocks and other plant materials were properly released from the site.
Licensee activities this period were adequate to identify offsite areas that had received blocks and other plant related materials, and to conduct a follow-up survey and assessment at each location. Licensee surveys were thorough to assess the present radiological conditions. An open item will track NRC review of the licensee actions to il t
_ -__._ _ _
_-. _ _ _. _ _ _
.. _. _ _ _ _ _
. _ _. _. _ ___
_ _
__
i
.
.
,
identify and survey offsite areas that received blocks and other potentially contaminated
.
equipment, recover contaminated materiait for proper disposal as radwaste, remediate the offsite areas, and complete an assessment of past radiological conditions and dose consequences at the locations where plant related radioactivity was found. NRC review of present and past radiological conditions at offsite areas continued at the end of the inspection.
Good performance was noted in the condur:t and evaluation of an emergency drill using new imolementing prc.cedures for the proposed defueled emergoney plan. The licensee maintained an adequate security program. Management support was evident, and audits were thorough and in-depth. Alarm station operetors were knowledgeable of thur duties and responsibilities. Security equipment was tested and maintained in accordance with the
,
physical security plan, and security training was performed in accordance with the training and qualification plan. An open inspection item will track licensee actions to address a repetitive security equipment failure, iii
..-.
-
.
.
_
-
- -
.
.
.
.b
-.. _.
7-
.
- --
. - - -
_ -
_ -. -. - -. _
-. - -. -.
,
,
.
.
-
TABLE OF CONTENTS
'
.
i
~
EXECUTIVE SUMM ARY............................................. 61 -
-
TABLE O F CO NTE NT S............................................... iv.
.
H E PO R T D ETAI LS '................................................. 1
-
Summ ary of Pla nt St atu s............................................ 1
'
'
l. Decommissionina Ooerations and Maintenance.......,.................. 1
,
Conduct of Operations and Maintenance
.............................
l 01.1 - Ooeratina Activities and Status of Operatina Systems.............. 1
-
01.2 Maintenance and Surveillance Activities........................ 2
.
i 01.3 Conclusions for Decommissionina Operations and Maintenance
........
ll. Soent Fuel Sa % tv............................................... 4 E1 Conduct of Engineering......................................... 4
'
E1,1 Enaineerina Suonort for Decommissionina.....,,................ 4
,
+
.E1.2 Soent Fuel Pool Activities - Fuel Shuf fle -........................ 5 E1.3 SFB Ventilation Cesian Deficiency (URI 97-09-01. VIO 97-09 02)...... 7 E1.4 Safety Classification of Soent Ful Suonort Svstems (URI 97-03-03)...
,
,
E8 Miscellaneous Engineering Issues................................. 11 E8.1 Review of LERs and Telechonic Notifications
....................
ill. Decommissionina Suncort Activities................................. 12
'
E2 Engineering Support of Decommissioning Activities............,,..... 12 E2.1 RCS Artif act Removal..................,................. 12
.
..
IV. Plant Sunoort and Radioloalcal Controls............................... 13 R1
- Radiological Surveys and Contamination Control...................... 13 R1.1 Offsite Radiation Survevs for Contaminated Blocks (URI 97-09 04)...... -13
,
P1 Conduct of EP Activities....................................... 19
- P1.1 Defueled Emeraenev Plannina Drill........................... 19
.
S1 Conduct of Security and Safeguards Activities....................... 20
- S2 L - Status of Security Facilities and Equipment.......................... 22 i
.
S2.1 Loss of Security Eaulomant (IFl 97-09-05)
......................
,
d.
r_ -
,
.
b
'
- --.-
. ~
-
., -.
.-
-
._ __
_ _.. - _ _ _.. _... _ _ _ _
.. _. ~. _ _ _..
_ _ _
... _. _. _ _.-
..._.._._
.
.-
.
'
S3 Security and Safeguards Procedures and Documentation................ 23
.
S4 Security and Safeguards Staff Knowledge and Performance............,,, 24
.S5 Security and Safeguards Staff Training and Qualifications
............,..25 S6 Security Organization and Administration........................... 25
'
S7 Quality Assurance in Security and Safeguards Activities
................26
S7.1 Audits (IFl 9 7-0 9 -0 6 ).................................... 2 6
S8 M!scellaneous Security and Safety issues,,,....................... 27 S8.1 Vehicle Barrier System (VBS) (T12515/132).................... 27 S8.2 yehicle Barrier System (VBS)
..............................27
,
S8.3 Bomb Bla st Analvsis..................................... 2 8
,
S8.4 Procedural Controls..................................... 28 V. M anaaeme nt Meetino s........................................... 2 9 X1 Exit Me eting Summ a ry...................................... i. 2 9
,
X2 Review of Updated Final Safety Analysis Report (UFSAR)................ 29 l
i l
,
b I
.
V J
,,,,,
r
_,,.
- - - _
-
,
n
,, -.
.
.,
- - -. ~
. - - -. - -., _ -... _ - _ -. _. -..
-. - - -.. -
.
...
-
a
.
.-
'
.
REPORT DETAILS
..
SAHDmarv of Plant Status
?
- The Haddam Neck plant conditions remained stable with the spent fuel safely stored in the
i
~ soent fuel pool. There were no significant changes in the plant systems not required to support spent fuel cooling. The licensee completed a maintensnce and design change
activity to remove an artifact from piping attached to the res:: tor coolant system as part of the planning for decommissioning activities,
,
i
- NRC inspections during the period included the reviews by the resident inspector of post
j operating activities, and the preparations for decommissioning. A specialinspection was conducted of the artifact removal utivities, and the surveys offsite to identify and remove i
contaminated blocks.
. NRC activities at the site included plant tours by Ronald Bellamy, Chief of the
Decommissioning and Laboratory Branch on October 27,1997. NRC personnel attended a i
meeting of the Community Decommissioning Advisory Committee on November 18, and E
December 16,1997.
I L
The licensee submitted the Post Shutdown Decommissioning Activities Report on August 22,1997, which initiated a 90 day period for the NRC staff to obtain public comments and
,
to determine whether the report met the submittal requirements of 10 CFR 50.82. The
l-NRC held a public meeting on October 27,1997 to obtain public comment on the PGDAR
[
and the decommissioning process.
.
LDenommianloninn_Oneiationn3fMLMalt!tepar%4
!
Conduct of Operations and Maintenance'
f
[
01.1 Ooeratina Activities and Status of Operatina Systems a.
Insoection Scope (71707,62706)
- .
'
Using Inspection Procedure 71707, the inspector conducted periodic reviewr, of
- plant status and ongoing decommissioning operations. The purpose of this I
inspection was to review the licensee activities to maintain the plant in the defueled condition, and to prepare for decommissioning activities.
b-Observations and Findinas Operating activities during this period included those operations needed to maintain -
stable plant conditions with the reactor defueled, to maintain adequate level in the
. spent fuel pool (SFP), and to assure adequate cooling of the spont fuel. The apont
'
l
- 2
"
.
Topical headings such as 01, M8, etc., are used in accordance with.
r.
. the NRC standardized reactor. inspection report outline.
Individual reports are not expected to address all outline topics.
,
c;
_
l
.
...,.,,. -, _.,,. _
- - - -
.. -.
-
,,me
-. -
..
d
-
- -=
- - - -. - - - _ -. - - - -. -
-
- _
-
.
.
,
,
fuel cooling and support systems were operated as needed to cool the spent fuel.
'
The normal and emergency electric distribution systom remained in service.
Operator actions were reviewed during periodic plant tours to determine whether
,
operating activities were consistent with the procedures in effect, includiq.he
'
alarm response procedures. Operator responses to off normal conditions were consistent with the applicable procedures.
The inspector observed eperator actions for several activities during tne period, and reviewed operator adherence to procedures. The operating activities included the water transfer from the primary drain tank to the borated waste storage tank per
'
NOP 2.14 7; and, the activities to drain the refueling water storage tank per NOP 2.1418 to reduce tritium leakage into the ground.
The inspector reviewed the licensee's control of the physical configuration of the plant. Licensee actions to issue and/or remove tags under the following clearances were reviewed: 96 846,97 394,961097,and 97-0450. This review included the implementation of the tagging process during the conduct of work activities, and
,
the control of systems removed from service due to plans to decommission the plant. No performance problems were noted Soent Fuel Coolina The inspector reviewed licensee activities to assure compliancu with Technical
.
l Specifications (TS) TS 3.9.11, SFP Water Level; and, TS 3.9.15, SFP Cooling.
There were no activities during this period involving the movement of heavy loads over the pool. The licensee conducted routine surveillance of the SFP and building, which included the tours by the operators once each shift per SUR 5.108.
The spent fuel pool cooling system (SFPCS) remained operating per normal operating procedures (NOP) 2.101. The SFPCS operated with at least one heat exchanger and one pump aligned to the pool. The R spent fuel pool heat exchanger remained in service with acceptable and improved hydraulic fouling resistance
achieved through periodic cleaning. The licensee maintained pool temperature below the TS 3.9.15 limit of 150 F. The service water (SW) side of the SFP cooling system was maintained using either the normal SW piping, O1.2 Maintenance and Surveillance Activities a.
Inspection Scoce Using Inspection Procedure 71707,61726 and 62707, the inspector conducted periodic reviews of plant status and ongoing maintenance and surveillance. The inspector reviewed licensee activities to test, troubleshoot and repair plant equipment, and to address emerging conditions.
_
_
_
-
-
_ _ _ _ _ _
.
.
b.
Observations and Findinas During the inspection period, the inspector observed licensee activities to maintain and test plant equipment necessary to support the SFP and SFPCS, and to assure the operability of support systems, such as the service water, process and effluent radiation monitoring, fuel oil, fire protection, ventilation, AC and DC electrical distribution, and the emergency diesel generator systems. During periods of degraded equipment performance, the inspector observed licensee actions to correct the problems, to implement compensatory measures, and to implement the requirements of action statements prescribed by the technical specifications and the technical requirements manual. The inspector reviewed the licensee activities to test and inspect the spent fuel building cranes and other support equipment needed to move fuelin the spent fuel poolin October,1997.
The inspector reviewed portions of the following work activities:
test and repair of the emergency diesel generators (fuel filters, starting air)
test and restoration of halon fire suppression system
cleaning the 8 SFP heat exchanger and improved hydraulic resistance
testing the spent fuel building ventilation system
operations and maintenance support of SFP activities - fuel shuffle
operations and maintenance support of RCS artifact removal
installation and test of the new hypochlorite storage tanks
The inspector verified licensee actions to meet the required action statement for the following requirements during periods of degraded equipment performance: TS 3.3.3.3 for the seismic monitor; TS 3.3.3.7 and 3.3.3.8 for the radiation monitoring systems; and fire protection technical requirements manual (TRM) II.1 for the fire detection syct.ums and the control room halon actuation system. No inadequacies were noted in the licensee responses to the degraded equipment conditions, in particular, the November 3 response te the inoperable fire detection system was prompt and thorough to assure conformance with the TRM requirements. The licensee completed the root cause evaluation (RCE) for the inadvertent halon actuation (IFl 97-05 01) by engineering memorandum CY-TS 97-0550 dated September 17,1997. The licensee returned the control room halon system to service on November 7,1997 following corrective actions to address the issues in
'
the RCE. NRC review of this area continued at the end of the inspection.
Maintenance personnel provide good support to operations in response to emerging conditions and following several events, such as the December 23 leak in the house heating steem line to the spent fuel and the euxiliary feedwater buildings. Operator and maintenance staff actions were good to isolate the affected line (closed valve HS 216), and to establish interim heating in the SFB and to monitor building temperatures. Further actions to address the degraded steam lines were in prograss at the end of this inspection.
l
.._
-
_
.
-
.
01.3. Conclusions for Decommissionina Operations and Maintenance Operator performance was good to monitor the status of operating plant equipment, and those systerns in a lay up condition. Operators showed good regard for plant procedures. Operators performed well to monitor the SFP and the SFPCS, and to responc to offnormal events and conditions. Maintenance and test personnel completed routine surveillances of plant equipment well, responded to degraded conditions, and initiated actions to complete troubleshooting and repairs. Good work controls were noted, including pre job briefs, control of tegouts, and adherence to work packages, j
11. Spent Fuel Safety E1 Conduct of Engineering E1.1 Enaineerina Support for Decommissionina a.
Inspection Scone (37801)
The inspector reviewed the conduct of engineering activities this period that supported shutdown operations, decommissioning planning, and spent fuel safety, b.
Observations and Findinas Engineering provided effative support to address issues important to shutdown operations and decommissioning planning, in support of spent fuel safety, engineering: (1) identified and assessed anomalous operation of the spent fuel building ventilation system (see Section E1.3 below); (ii) monitored the hydraulic resistance and supported successful cleaning of the B SFP heat exchanger to reduce fouling: (iii) completed a safety evaluation to redefine the Technical Specification 3.9.15 bases for current spent fuel pool decay heat loads, and restored operability of the B heat exchanger; and, (iv) prepared the design changes to begin constructirn in mid December of Phase 1 of the nuclear island, which willinstall the intermediate and spray cooling loops for the spent fuel heat exchangers and eliminate the reliance on the service water system.
SFP Calculations The licensee completed additional analyses of the safety of the fuel stored in the spent fuel pool, and showed good regard for plant safety by analyzing events considereJ beyond the design basis of the plant. By letter dated September 26, 199/ (CY 97-066),the licensee submitted for NRC review the results of an assessment of a loss of all water in the spent fuel pool. This assessment included calculation SFP 97-01606-MY(licensee vendor Report Hi-971705). The calculations established that after optimizing the geometry of the fuel stored in the pool and for the assumed decay heat loads, the zircaloy-clad fuel assembly temperatures would remain below the temperature that could result in cladding ignition assuming a complete loss of pool water. The condition was reached for the
.
.
- - -
_ _... _ _ _. _ __._ _____._ __._ _
___. _ _
_. _. _ _ _ _ _ _ _ _
-
.
,
- decay heat loads on October 1,1997 for an assumed clad ignition temperature of 650 degrees F, and on January 1,1998 for a clad temperature of 569 degrees F.
The licensee'also performed a calculation (by the Radiological Assessment Branch)-
,
for. scatter shine from uncovered fuelin the pool. The analytical results were submitted to the NRC by letter dated 12/18/97in support of the defueled Emergency Plan, in further support of spent fuel safety, the licensee improved the modeling of the SFB ventilation system flows and integrated this work with the thermal hydraulic
_
models used as part of pool heatup calculations. The licensee conducted testing to
,
validate the ventilaticn system modeling. This analysis supported the evaluation of the maximum temperature _of the pool water that would be reached on loss of cooling, and an assessment of the stresses on the concrete structure around the pool. Assessments completed in support of operations and decommissioning
activities appeared technically sound and adec;uately documented. NRC review of the proposed defuel emergency plan and the bases for reducing the offsite planning bases contin'.'ed at the end of the inspection.
.
Sigiys of Corrective Actions for Escalated Enforcement Licensee engineering and staff continued several projects during period to support decommissioning and to address program weaknesses that were the subject of previous NRC enforcement. The licensee revised the process to upgrade the UFSAR and issued new sections internally. The licensee revised the schedule to update the UFSAR and plans to submit a revised UFSAR to the NRC in January 1998, c.
Conclusions for Enaineerina Sunoort i
Engineering provided effective support to plant operations and decommissioning i
l planning during the period. A good regard for spent fuel safety was noted in the actions to address beyond design basis e vents for the spent fuel pool.
E1.2 Soent Fuel Pool Activities - Fuel Shuffle l
a.
Insoection Scone (60710,70705)
f The purpose of this inspection was to verify the adequacy of licensee preparations l
and controls to caduct fuel shuffle activities.
l b.
Qt wations and Findinos l
The spent fuel activities were conducted during the period of October 14-23,1997.
.The shuffle was conducted to optimize the geometry of the zircoloy clad fuel stored
. in the pool to preclude a fire in the pool for postulated beyond design base events.
The inspector reviewed li ensee preparations and procedures to conduct the fuel
_
movement. The review included the actions to implement the Technical
-
Specifications 3.9 and 4.9 requirements for administrative control of fuel handling L
!-
..%..,
-,__,
-m
_.--,.m.__
.. -
,
.-
-,, _. - -, -..
,
_ _ _ _ _ -. _. _, _. _.
.. -.., _., _ _....
-
_.
.
.
operations. The inspector assessed the adequacy of spent fuel activities through observation, interviews, and record reviews.
The principle procedure that provided overall direction and control of fueling activities was SNM 1.4 5,"in Plant Transfer of Fuel Assemblies in the Spent Fuel Pool." The licensee had detailed instructions for fuel handling, transfer, and spent fuel pool verification, end for the operation and testing of support systemc. Clear lines of responsibilities and communication were established (Operations Manager memorendum ODM 97 200), along with shif t manning requirements and the qualifications of personnel, instructions were providad for the initial and periodic check of equipment. Abnormal Operating Procedures were provided for loss of inventory (AOP 3.2 59), and fuel handling accidents (AOP 3.2 63). The licensee provided a technically adequate set of instructions and administrative controls for refueling activities. The QA organization provided oversight and surveillance of the verification of the inventory (SIP CY-P-97 093). Other items coveted in the NRC raview included:
verification that the fuel shuffle pattern in SNM 1.4-5 to optimize fuel
gnometry met the analysis assumptions (per Hoitec Analysis Hi 971730, as modshed by Holtec Engineering men.arandum dated 9/19/97)
licensee preparations and completion of action items per engineering
memorandum CY JDH 97 009 the conduct of pre job briefs (WCM 2.18) and the adequacy of procedure
adherence implementation of TS 3.9 LCOs and SURs, including daily checks (SNM 1.4-
5) and control of SFP boron concentration (SUR 5.319A)
the comple+ ion of crane inspections and pieventive maintenance (WCM 2.2-
9, AWO 972073 for calibref.un of load cell, PMP 9.5 255)
the control of SFB ventilation (tagging controls per Clearance #970394)and
the completion of ventilation testing per SUR 5.7-162 qualification and training of personnel (Master-Lee ML-TRN-001, and CY OJT
Guide SFH-OP J)
the adequacy of health physics coverage and adherence to RWP 227
the adequacy of housekeeping and FME controls (WCM 2.2 5)
One discrepancy in maintaining the FME log was identified by NRC review on 10/14/97. No loss of material occurred and licensee follow-up actions were good (ACR 97-869). The licensee identified an interference problem with the coupon tree. Fuel movement was stopped while the tree was moved to a new location (ACR 97-901).
i
_.
.
c.
Conclusiorg Fuel handling activities were conducted in a safe and deliberate manner.
Preparations were thorough, and adherence to procedures, administrative controls, end periodic checks were good to assure safs handling and compliance with license requacments. Engineering support of spent fuel pool activities (by technical programs in particular) was excellent to assure proper comp'etion of the fuel shuffle.
E1.3 SFB Ventilation Desion Deficieltev (URI 97 09-01. VIO 97-09 02)
a.
Inspection Scope (92702,37700)
The purpose of this inspection was to complete the NRC review of the spent fuel building design defic %ncy reported by the licensee in 10 CFR 50.72 Events 32812 and 33026. This issue was described in inspection item URI 97 05 03.
Reaulatorv Reauirements Technical Specification 3.9.12 requires the Fuel Storage Building Air Cleanup System be OPERABLE and in operation during operations involving movement of fuel within the storage pool or crane operation with loads c,ver the storage pool.
With the Fuel Storage Building Air Cleanup System INOPERABLE, the TS ACTION is to suspend all operation with loads over the fuel storage pool.
UFSAR Section 9.4.2.2 states that the design flow rate of the spent fuel building exhaust f an exceeds the supply fan capacity to maintain a negative pressure in the spent fuel building. The design flow rates of the exhaust fan is 13,000 cfm, and 12,000 cfm for the supply fan.1000 cfm inleakage was assumad to maintain the SFB negative during fue; movement.
Positive Buildino Pressure and Fjow Less Than Desian During testing on August 25,1997 during startup of the SFB supply fan, a slightly positive pressure was observed in the SFB (ACR 97-680). This issue was reported to the NRC as LER 97-16 p;r 50.73(a)(2)(ii) as operation in a condition outside the design basis. The August testing was conducted at the request of the engineering organization as part of the corrective actions to reverify the licensing and design basis of the plant.
Follow up testing of the SFB ventilation system on October 3, ;997 to investigate the causes for the event reported in LER 97-16 identified that the SFB exhaust fan was not operating in accordance with the 13,000 cfm design flow. The SFB exhaust fan exhausted 11,500 cfm when it was operated with one primary auxiliary buite ng (PAB) purge fan operating; the SFB fan only exhausted 6,500 cfm when two PAB purge fans were operated (ACR 97 810). The licensee reported this event as LER 97-18 per 50.73(a)(2)(ii) as operation in a condition outside the design basi _ _ _ _ _ _ _ _
. _. _.._ _ _.__ _ _ _ _ _ _ _. _ - _ _ _
_ _ _ _
_
<
.
,
,.
Causes
,
The inadequate SFB exhaust f an flow rate was attributed to back pressure from the operating PAB f ans which discharge into a common ventilation duct work in the flow path to the plant stack. The higher PAB f an back pr.asure was caused by PAB
,
f an modifications in 1974 which installed higher capacity fans. Ventilation system
'
changes made per plant design change requests (PDCRs) 116,149 and 163
'
replaced the original primary auxiliary building purge fans with new fans having a higher capacity of 52,000 ofm. Stone and Webster Design Specification WLC-4 and Calculations CY SW M 0025,0021, and 0490 described the modifications.
The 1974 modification was not adequately designeu or tested to preclude the unintended impact on the SFB f an performance, j
TS surveillance 4.9.12.a.3. requires that the Fuel Storage Building Air Cleanup System be tested for operability, and that the system flowrate be 4,000 cubic feet
!
per minute (cfm) +/10%. This flow rate is obtained with the SFB ventilation
,
system operation in the " bypass" mode with the charcoal filter in use following a postulated accident during fuel movement. This test was conducted periodically in the past as a prerequisite to moving fuel, and the flow requirements were met. The testing conducted to meet TS 4.9.12.a.3 would not have detected this desian j
deficiency or the interaction between the PAB and SFB supply fans.
!
.
An exception to this conclusion was previously addressed by the NRC in inspection
'
item eel 97-11-03, in that matter, the 4000 cfm flow rate was not aways maintained due to inadequacies in the test method which did not prop ( Iv account for the configuration of the operating containment purge f ans. Based on. o review of
i the circumstances surrounding that matter, the inspector determined the licensee would not necessarily have identified the present design deficiency as a result of the j
follow-up to the testing issue.
<
f Ooerability Imoact The design discrepancy did not impact the operability of the SFB ventilation system
'
during periods when the system was reqaired to be operable. Licensee procedure
'
controls ensured the SFB supply f ans were shutdown and tagged out when aligning
the SFB ventilation system through the charcoal filter in preparation for moving fuel
,
- in the spent fuel pool (procedure NOP 2.15-3), and following an accident resulting
!
in high activity in the SF build;nc (AOP 3.2 3). During fuel moves between February 6 - February 28,1995 and May 27 June 14,1993, NRC inspections confirmed negative pressures were maintained in the SF building when the licensee was
,
,
moving fuel in the storage pool. Thus, the Technical Specification 3.9.12 were met during fuel moves in the SFP for the period reviewed by this inspection.
Eggective Actions Taken or Planned j
.
i The corrective actions taken included a continuation of the administrative controls in place to ensure the supply fan was not operated when activities occurred with a
,
potential for generating a :ource term in the spent fuel pool. These controls were
-,.,-.
--
,
-.
- -.
- -
. -- - -
.
.
- -
.
_
.
also in effect during the October 1997 work in the spent fuel pool. Additional corrective actions under consideration include replacement of the SFB exhaust f an with one having a higher capacity, or evaluating system perfonnance with lower exhaust flow, and modifying the supply flow as needed to rnalatain negative
'
pressures with both f ans operating. The licensee actions will be followed by an inspection item for review the adequacy of the corrective actions (URI 97-09-01).
Findir1gg The SFB ventilation system design discrepancy was significant because conditions existed which could have impscted the performance of a safety system used to mitigate a design basis event. The TS bases states that the SFB ventilation system is required to be operable to mitigate a postulated accident in the spent fuel pool by providing for a filtered, elevated release.
However, past licensee evaluations completed per SEP Topic XV 20 (IPSAR Section 4.33.1) noted that the SFB ventilation system was not single f ailure proof. The NRC requested the licensee to either demonstrate the consequences of a fuel handling accident were acceptable without taking credit for the ventilation system (i.e., assume an unfiltered ground level release), or propose corrective actions to address the design issues. The licensee demonstrated by a revised fuel handling enalysis that the consequences of a fuel handling acciJent were acceptable without crediting the SFB ventilation system. The NRC found this acceptable by letter LS05-8311-005 dated November 3,1U83. This information was previously considered in the NRC evaluation of finding eel 96-11-03.
The licensee reported this matter per 10 CFR 50.73(a)(2)(ii)in LERs 97-16 and 9718. The licensee's safety assessment considered the effects of system performance relative to a potential unmonitored release path, and on spent fuel pool cooling as related to assumptions for the time for fuei cecay prior to discharge following reactor shutdown and credit for evaporative losses assured by ventilation flow above the pool.
The SFB ventilation system design deficiency was another historical example of the types of issues cited in the May 1997 escalated enforcement action. Licensee actions this period to identify, investigate and address the issue were thorough and appropriate. The failure to adequately control and maintain the facility design was a violation of 10 CFR 50, Appendix B, Criterion lli (VIO 97-09-02). Based on the above findings, inspection Item URI 97-05-03is considered closed, c.
Conclusions The licensee discovered a long standing design discrepancy associated with the spent fuel building ventilation system. The deficiency was caused by weaknesses in the design control process during a 1974 plant mcdification. Although the deficiency was a concern because it involved a system important to plant safety, it did not adversely affect safety because of administrative controls in place during spent fuel pool activities. Further, the weaknesses in the modification process
...
_- _ - _ _ - _
_ - ~ _ -. __ --- -. - - _ _.- - --. __- _._._. -_ -_.. -.
- -
-
.
,
.
causing the deficiency were similar to the concerns addressed in the escalated enforcement action riescribed in the NRC letter dated May 12,1997; actions have alrr ady been taken to improve the programmatic control of plant design changes.
-
Licensee actions during this period to investigate spent fuel building ventilation systom design and performance, and to identify and address this issue, were
"
thorough and appropriate.
'
E1.4 Safety Classification of Soent Fuel Sucogn3vstems (URI 97 09-03)
a.
Insoection Scoce (37801,37700)
Tha purpose of this inspection was to review the licensee actions to classify the spent fuel cooling and associated support systems.
b.
Observations and Findinas
'
i The licensee presented for NRC review a draf t design change document (DCR CY-
,
9702'4) that would reclassify the QA categories for the spent fuel cooling system, service water system, and emergency diesel generators. Specifically,if approved by the licensee, the DCR would: (1) classify the SFPCS as pressure boundary only
,
QA Category 1, and declassify the active functions as not safety related, non-QA Category I and not seismic Class 1; (iin reclassify the emergency diesel generators and their supporting systems from safety related QA Category I to non-QA, and from seismic to non seismic; :i) reclassify portions of the service water system
'
(SWS) fre.m safety-related QA Category I to non-QA, and from seismic to non-seismic; and, (iv) remove the requirements for redundancy and separation from the above systems.
The inspector provided NRC comments on the draft DCR and expressed concerns that the propcsed actions did not recognize the safety significance of the active cooling mode of the SFPCS (and associated emegency power and heat removal
systems), and the importance of these systems to spent fuel safety. This matter was discussed with the Engineering Director, the Manager of Licensing and the Unit Director. The inspector also discussed the criteria under which this action would require prior review and approval by NRC. The licensee acknowledged the inspector's comments, but stated his position for declassifying the above systems, and that the basis for that action would be better addresseo in a revision to DCR 97023, c.
ponclusions The engineering evaluations in a draft design document to address the quality classificatio1 of the sptinl fuel support systems was not adequate to establish the bases for the proposed declassifications. An open inspection item will track NRC review of the adequacy of actions to classify the SFPCS and support systems
(URl 97 09 03).
.
m..
.
--,
-,
m
...-. __ - -
-
.
_ - -.
...
-.
-. -.- -_ -.
. - -- -.-_--.
~--.-
_ _ -,
--
'
-
.
f
-
E8 Miscellaneous Engineering leeues E8.1 Review of LERs and Telsohonic Notifications
,
!
a.
Inspection Scone (g2700,90712)
'
The purpose of this inspection was to review prompt reports and licensee event reports (LERs) to verify the requirements of 10 CFR 50.72 and 50.73 were met.
b.
Observations and Findinat The following event reports were found to be acceptable. The references in parentheses refer to the sections of this report that describe further NRC review of the event. The LJRs listed below are considered closed.
'
LER 9716, Spent Fuel Building Positive Pressure (Section E3)
- LER 9717, Plant Radioactivity In the Landfill (Inspections 97 08,97 10)
LER 9718, Spent Fuel Vent tation Flow Low (Section E3)
-
LER 97 21, Contaminated Material Offsite (Section R1.1)
LERs 9719 and 97 20 were issued during this period and under NRC review.
The inspector reviewed licensee actions to make prompt notifications to the NRC per 10 CFR 50,72, including those made on: November 4 for Event 33211 (main transformer oil spill), November 24 for Event 33305 (contaminated concrete i
blocks), December 2 for Event 33342 (contaminated soll and b;ocks offsite),
December 4 for Event 33346 (oil spillin discharge canal), and December 29 for Event 33481 (oil spillin the dbcharge canal). Except as noted below, the inspector had no further comments in this area.
'
The inspector reviewed licensee actions to respond to the oil spill events and to cleanup or recover the oil. The November 4 event occurred when the licensee was draining the oil from the main transformer in an attempt to reduce hazards at the site. The spill occurred when the oil reservoir tank on the transformer became over pressurized and failed due to a faulty pressure gage. The spill occurred after a large amount of oil had already been rernoved. The draining was stopped pending a review of the event, which included a root cause evaluation. The December ob spills in the discharge canal were contained by booms and cleaned up. The oil was released when service water pumps were stopped and started after oil had accumulated in the upper pump columns due to a faulty solenoid valve in the oilers for the pump upper bearings. This condition was masked during plant operations because of the small amount of oil that was accumulated and released, and by the operation of multiple service water and circulating water pumps. Actions were in progress by the maintenance staff st the conclusion of the inspection to replace the faulty solenoid valves. No violation) of NRC requirements were identified.
-
.
,
..%+---,._w.-.-
s
,
,_..,m
,-
3,
.,
_
,.
.--#
,- - = +
w
+
r v-
---
+~
-e ecv
---
- * -w-
-r w a -
-
. - __.. - _..
- --
- - -. _ _ - - -. - _. - - - -
--
.'
'
.
i
til. D+:-:r.. ' '--h Sam Activities
!,
E2 Engineering Support of Decommissioning Activities E2.1 RCS Artifact Removal
,
i a.
Inspection Scope (71707,62706,37801)
,
The purpose of this inspection was to reviev! the operational and engineering
,
support for the RCS artifact removal project, inspection 9710 also provided NRC observation of this activity, with a focus on radiation protection controls in
particular.
b.
Observations and Findinas t
Prior to dismantling the Haddam Neck reactor coolant system (RCS), the licensee plans to decontaminate the reactor and attached piping using a chemical cleaning process to reduce the radioactive source term and help keep worker doses as low
'
as reasonably achievable. The licensee elected to perform testing on a
-
representative sample (artifact) of RCS pipe in order to determine the effectiveness
,
I of proposed decontamination fluids.
A section o' reactor letdown piping was selected for removal which was determined
to be representative of the RCS piping and replace it with another section of pipe
"
with an isolation valve. The licensee removed a section of line 3" CH 2501R 170, which was schedule 160 pipe. Thu pipe section was replaced with schedule 40
pipe with additional isolation valve (LD V-414) and drain valve (LD V 413) and flanges to accommodate a future decommissioning booster pump. The process to
'
remove and ship the artifact included the development of special procedures,
.
erecting mockup stands, leak checking valve LD200, installing a freeze seal on the i
cut line to provida a second isolation barrier, installing a " hot tap", draining and j
venting the system, cutting and sectionalizing the artif act, installing the new pipe and valves, and hydrotesting the new boundary.
NRC inspection included review, observation, and/or consideration of the following licensee activities during the conduct of the artifact removal project:
I
'
project design per DCN DCY-01-0214 97,DCR CY 97009
safety evaluation per SY EV 97-0061
artifact removal per SPL 10.7 380
artif act removal and health physics pre job br.iefings
hot top installation per VP 820 (TES 2 001 N)
freeze sealing per VP-819 (TES 20-013-N)
leak test of LD MOV 200 per ST 11.7 210
radiological controls per RWP 4 (Various Job Steps)
hydrostatic testing per ENG 1.7 65 (AWO 97 3027)
PORC review and approval of project plan and procedures
temporary rigging per engineering memorandum CY TS 97 524
!
.
u.
-
_
-
_ ___.__,_ ______._ _._
.
, __z
.
_ _ _ _ _. _ _. _ _..
._
- _ _ __ _ _ _ _ __ _ _._ ___ ____ _._
.
,
-
'
replacement pipe welding per VP 821 to 826
NRC review identified no major deficiencies in the project plan and procedures.
Several NRC comments on artif act removal procedures were provided to the licensee that would enhance the process. The inspector also provided comments on the licensso plans to drain sections of line 3" CH 2501R 170 prior to cutting the artifact.
.
A Region i Senior Radiation Specialist and the Senior Resident inspector provided round the clock coverage to review the conduct of the work and the adequacy of the worker radiological protection. The licensee successfully controlled radiological hazards for work completed on November 22 and 23 to remove a 6 foot section of pipe from the reactor letdown line. The work included installing a freeze seal, draining and cutting a 3 inch diameter section of letdown line that had contact exterior dose rates of 1000 1200 mrem /hr and internal contamination of 40 Rad /hr. The licensee installed a replacement spool piece to restore the integrity of l
,
the letdown line. Post welding hydrostatic testing was completed satisf actorily on
'
November 25,1997.
c.
Conclusions
<
Overall good performance was noted in the planning and support for activities in
,
preparation for Decommissioning. The artif act removal project was well planned and implemented, with good preparations and mockup training, thorough pre job briefings, and excellent controls of activities in progress.
IV. Plant Suonort and Radioloalcal Controis R1 Radiological Surveys and Contamination Control R1.1 Offsite Radiation Surveys for Contaminated Blocks (URI 97 09 04)
a.
Insoection Scope (83726)
The purpose of this inspection was to observe the licensee conduct radiation and contamination surveys at private residences and properties located offsite that had received cement blocks from the Haddam Neck plant in the past. The surveys
,
began in November 1997, and continued at the conclusion of the inspection in January 1998. The purpose of the inspection was to determine whether the licensee effectively controlled radioactive materials and contamination, and performed adequate surveys and monitoring.
A representative from the State of Connecticut Department of Environmental Protection (DEP) also observed the surveys and conducted independent measurements. The NRC and DEP cbtained split soil samples for independent analysis as needed. The NRC soil analyses were in progress at the conclusion of this inspection and will be reported at a later date.
- - - -. -
_ _ _ -. _, - - _ _.
- _ -
.-
-.
.
.
b.
Observations and Findinas Backnround As part of the decommissioning pr..:ess, the licensee's historier w :N w.v identified that material from radiologically suspect areas of the Ac 4 %t b x.
released off site. Specifically, based on interviews with plant wc+.M r.WM Me14 the material from the plant, the licensee identified that workers ton p;,a alon of solid cement blocks following the demolition of a wallin 1975. The blocks were used as a shield wall around a former cask wash down pad that presently is the location of Bus 10. The licensee estimated that 5130 blocks were used in the wall. The blocks measure 4" X 8" X 16". The number of blocks was estimated based on the " footprint"lef t from the shield wall that measured 2 feet thick by 10 feet high by 76 feet long. The inspector independently confirmed this estimate.
in the early 1970s, the cask pad was used for temporcry storage of contaminated fil.ars, resin liners and trash. At least one liner leaked, which contained water and f ailed after freezing. The leakage spread contaminated water around the storage area which contacted the blocks. Once tFe failed liner began to dry, airborne radioactivity was identified in the area.
After abandoning use of the cask pad as a storage area, the licensee becan a process to survey the blocks tn separate the contaminated ones from those unaffected by the contamination, and to release for free use those that were unaffected. Plant workers were allowed to take blocks directly from the partiallv constructed shield wall, and to frisk the blocks for free release. When interviewed in 1997, most workers did not remember the type of survey Instrument (s), or what release criteria, was used. While workers stated they checked the blocks for radioactivity, it was not certain every worker checked each block. Health physics technicians helped some workers check blocks for contamination. Some workers, who were qualified in radiological controls, took turns frisking blocks during work shif ts, separating blocks to be removed into piles for each worker. The workers
!
loaded blocks into a truck at the end of a shift and removed them from the site.
I Based on ertries in a security gate log, the process of frisking and taking possession of blocks occurred over the period of September to November,1975.
Several workers took many truck loads of blocks. The blocks were used extensively around the owner properties to build a garage, walkways, ramps, retalning walls, and landscaping borders. Some blocks were used inside the home (cellar).
Despite past attempts to reduce the contaminat'on during the construction of Bus 10, residual radioactivity prompted the licensee to install a % inch lead plate on top
of the cask pad and under the Bus 10 pad. NRC inspections in 1997 (reference
,
(
Inspection 97 08) showed that the pad had significant residual contamination,
'
which continues to leach out of the pad area, resulting in minor levels of smearable contamination and fixed radiation levels up to 6 mrem /hr in the asphalt seams around Bus 10. The Bus 10 area has been selected by the licensee for expedited
.
.
.
'
remediation due to the plans to use Bus 10 for the long term support of the nuclear aland as part of decommissioning.
Of f site Investigations The offsite surveys began with the identification of locations where blocks had been taken. These areas were identified based on direct contact with property owners by plant personnel, and based on public response to publicity and media reports on the issue. The licensee obtained from plant records a security gate log from the 1975 period that identified when blocks (and other plant material) were removed from the site. Some of the plant workers who received the blocks in 1975 still worked at the plant, and were able to identify other locations where blocks might also be found.
Areas to be investigated were assigned to a matrix to positively identify the area for follow up and to develop information on the time and circumstances under which the blocks were received, in some caves, the blocks were in the possession of the
.
original owner and were in the same place on the property where the blocks were placed in 1975;in some cases, the blocks had been moved to different locations on the property, or taken to another property, or were given to other people; and, in some cases, the original pronerty where the blocks were taken in 1975 had been sold to other owners, investigation and survey of the blocks was dependent upon the approval of the present property owners. All of the above circumstances made immediste identification of the location of the blocks difficult, and delayed the prompt surveys of the material. Unique location numbers were assicned to each area investigated, with areas of fsite assigned a code in the '96xx" series. The NRC findings reported herein use the licensee numbering and identification codes. The locations surveyed to date are identified in the " Initial Results" section below.
Survey Plan and Method The inspector accompanied the licensee on a walk down of the subject properties to identify the areas potentially affected by plant related materials. The results of the site walk down were used to develop a specific survey plan for blocks and soils in the "affected areas" at each location.
The licensee surveyed the properties using a combination of several techniques, depending on site specific circumstances. Very sensitive gamma survey instruments were used to provide radiation scans and dose rate measurements on the blocks and over the affected area of the property. The instruments were calibrated, and were source checked on the day of the survey. The radiation measurements were also taken over areas known to contain only indigenous material to establish background radiation levels on the property. The inspector verified that the instruments used were within the calibration interval.
For blocks that had smearable contamination, the licensee took pre and post-remediation soll samples beneath blocks. Soil samples were split with the NRC and the State of Connecticut. The NRC samples were analyzed at the NRC Radiation Laboratory in King of Prussia, Pennsylvani. - - -
-
-
.-.
.
_
-
.
.
,
.
The survey instrumentation used was capable of detecting environmentellevels of radiation. The gamma scans were conducted with Eberline E600 survey instruments with SPA 3 sodium iodide (NAll probes. The gamma scans were supplemented with fixed point exposure rate measurements using E600 instruments with HP 300 Geiger Mueller probes, insitu scans using a gamma spectroscopy instrument were completed as needed to further investigate areas showing elevated radiation levels. The licensee used the Exploranium Model GR130 gamma spectrometer. The Exploranium differentiated between naturally t.ccurring radiolaotopes (such as K 40), and those resulting from power plant operations, notably Cs 137 and Co 60.
The inspector ooserved the technicians and monitored the scans while in progress to assure the surveys were conducted consistently using good scanning techniques.
The inspector observed the survey instruments as the technicians scanned the site and took the readings. The inspector independently confirmed the survey instrument readings. The surveys were completed in a careful and deliberate manner. The inapoctor also conducted independent measurements with an NRC survey instrument (Ludlum Model 19 micro R meter, serial number 033512, calibration due 4/17/98). The results from independent instruments correlated well.
Contamination and Elevated Radiation Levels identified Offsite On November 18,1997, the property owner for Lecation 9624 returned four cement blocks which were surveyed at the site. Yhe licensee identified detectable fixed contamination on three of the four blocks. Fixed contamination levels ranged from 20 to 300 corrected counts per minute using an RM 14 detector with HP 260 probe; there was no removable contamination. Based on these results, the licensee expedited plans to visit the property of two plant workers having a large number of blocks. The intention was to survey all blocks, and return any contaminated blocks to the site.
On November 26, the licensee and a representative from the DEP completed radiological surveys at two residences, designated as Survey Locations 9624 and 9629. Of 120 blocks received at location 9624, the licensee identified 4 blocks that had contact dose rates in the range of 0.25 to 1.0 mR/ hour; other blocks had detectable levels of fixed contamination, and one block had smearable contamination of 3000 dpm/100 cm. Similarly, at Location 9629, of an estimated
200 blocks received, about 70 were accessible to survey. Two blocks had plant related radioactivity, with one block having contact dose rates of 0.3 mR/hr. In situ gamma spectroscopy measurements conducted by the licensee and the DEP representative identified Cs-137 at both sites and Co-60 at one site.
Similarly, surveys conducted at Location 9632 on November 29 30 identified contaminated blocks. The highest readings on one block were about 0.6 mrem /hr (600 R contact and 90 R/hr at 30 cm). Of an estimated 436 blocks at this location, 59 were identified as contaminated. Smearable contamination was identified on one block at 2000 dpm/100cm2, and soil contamination in the areas below some blocks was identified. Six soll samples were taken for further analysis
i
.
.,
arid split with the NRC and DEP. Insitu Gamma scans by CY and the DEP identified CS 137 in all of the contaminated soil samples, and Co 60 in some locations. The 59 blocks were loaded into drums for transport back to Haddam Neck as a radwaste shipment.
The licensee's preliminary assessment for Locations 9624,9629 and 9632, based on estimated occupancy times and exposure rates at 30 centimeters from the blocks to be Icos than 25 micro R/hr above background, was that there was no significant radiation dose to the public for the present radiological conditions, independent NRC assessments based on licensee and NRC data confirmed this conclusion.
Action Plan Developed for Exoedited lmolementation The licensee developed and implemented an Action Plan on November 26 to identify the locations of all concrete blocks released from the site, characterize the radiological concerns, remediate the sites, and bring back to Haddam Neck all concrete blocks. Licensee assessments were in progress to evaluate the impact for the worst case exposure rates in 1975. The plan included an extensive follow up for further investigation and remediation at each site, since the preliminary surveys only checked blocks that were immediately accessible. In severallocations, many blocks were not fully accessible on all sides (part of a wall, buried in walkway, etc)
and could not be completely surveyed.
Initial surveys showed that contamination from the blocks migrated into the soils, but had been stabilized over time as it was trapped in the ground. The initial efforts to survey the blocks and remove the contaminated ones disturbed the soil and destablilized the residual activity, making it capable of transport again until full remediation had occurred. The potential for destabilizing the imbedded material identified a need to prioritize the work to first conduct surveys to assure no health and safety concerns were present, and to defer remediation activities until a mitigation plan at each site was established and organized to assure the material was removed in a manner that minimized the spread of contamination.
The licensee, NRC and DEP developed screening criteria on December 1 to differentiate which blocks require prompt removal, and which could wait for later remediation. The criteria will vary at each site depending on the level of activity, block location and occupancy factors. Advanced survey teams visited each site to assess radiological hazards. The teams conducted scans with micro R meters. For any area witn radiation levels greater than twice background, additional measurements were taken to better characterize the radiological hazards. The licensee evaluated any blocks above 50 R/hr on contact by taking smears, labeling the block, taking dose rates at 30 cm and 1 m, and performing a dose assessment.
The licensee identified for immediate remediation any area that met the following criteria: (1) greater than 0.5 mrem /hr above background on contact; (ii) greater than 10 mrem /yr; or (iii) greater than 3000 dpm smearable with potential for public exposure considering occupancy factor. - __
-. _ -
.
'
The licensee instructed the property owners, if contamination were identified, to not move the blocks, and to control access to blocks. If radiation levels were above the criteria, a remediation team was dispatched for prompt removal of unsafe levels or to establish controls as required, if radioactivity was below the criteria, nothing was done until a deliberate remediation effort could be planned addressing the specific site circumstances. The licensee contracted with a construction company to be part of the remediation effort at each site, so that reconstruction could be completed immediately following block removal and remediation. At the conclusion of the inspection, the contractor had been hired, and actions were in progress to provide radworker training for the contractor workers.
Initial Results As of the end of this inspection period on January 12,1998, the licensee had 55 locations of fsite that potentially had blocks from the site of the type used to construct the shield wall. The licensee completed surveys at 32 of these locations, and found positive indications of plant related radioactivity at 11 locations. Of the 5130 blocks initially released from the site,4583 blocks had been located and 4295 partial surveys (accessib!e sides) had been completed. Of 132 blocks with positive indications,6 had contamination above the screening criteria. A total of 142 blocks were returned to the site.
Plant related radioactivity was identified at 11 locations offsite. Actions were completed to partially remediate blocks at five locations. NRC review of all sites continued at the conclusion of the inspection.
Preliminerv Dose Assessment The licensee used the gamma surveys results to perform a preliminary dose assessment from the plant related material at each location with positive indications above the s:roening criteria. The dose assessment considered the potential whole body dose, and accounted for occupancy f actors at the location. Based on the present day direct radiation measurements (the maximum contact dose rate measured to date was between 1 to 2 mR/hr), there was no unacceptable whole body dose rates identified. Since the above results correspond to dose rates after 23 years of decay, the licensee follow up assessment of these locations continued at the conclusion of this inspection.
Reoortabilltv Adverse condition reports (ACRs) 971011 and 971022 were written in response to the initial discovery of contaminated blocks at offsite locations. The licensee analysis described in ACR 971022 concluded that the findings indicated a programmatic breakdown of radiological controls when the blocks (and soils and other materists) were released from the site in 1975 and 1986 periods. The licensee also reported this matter to the NRC per 10 CFR 50.73(a)(2)(1)(B)in LER 97-21. The LER also reported the licensee's determination per 10 CFR 20,2203(a)(3)(ii)that the materials identified offsite constituted concentrations of
__
. - - - - _ _ _ - _. _ _
_ - _ _ _ _ - _ -.
- - - _. - - _
- -. _ _
_ _
. _ - -. _ _ -.
-
.
,
j
'
!
materialin an unrestricted area in excess of 10 times the limits established in Part 20. The inspector reviewed the licensee's corrective actions as described in the LER to assure uncontrolled licensed materialis properly dispositioned (addressed further below) and to assure that present radiological practices address past weaknesses in the control of contaminated materials.
NRC review of the licensee activities offsite and the completion of independent NRC analysis of the offsite areas remained in progress at the conclusion of the inspection. Additional NRC reviews of similar concerns in the control of radioactive materials was reported in inspections 97 07,97 08 and 9710.
This matter is considered unresolved pending the completion of the licensee actions to identify and recover alllocations with concrete blocks. Specifically, the item is oper pending completion of actions to (l) locate all blocks; (ii) complete assessment and characterization surveys of materials on blocks; (iii) complete plans to rec'over
'
the blocks; (iv) assessment of past radiation levels and contamination at offsite properties and assessment of historical dose consequences; (v) development and implementation of remediation plan at each site, which addresses potential
'
migration of radwaste; and (vil final NRC evaluation of the release of material.
(URI 97 09 04),
c.
Conclusions Licensee radiation surveys and controls in the past were not adequate to assure contaminated blocks and other plant materials were properly released from the site.
Licensee activities this period were adequate to identify offsite areas that had received blocks and other plant related materials, and to conduct a follow up survey and assessment at each location. Licensee surveys of offsite areas were thorough to assess the present radiological conditions. An open item will track NRC review of the licensee actions to identify and survey offsite areas that received blocks and other potentially contaminated equipment, recover contaminated materials for proper disposal as radwaste, remediate the offsite areas, and complete an assessment of past radiological conditions and dose consequences at the locations where plant related radioactivity was found. NRC review of licensee actions to assess and remediate the offsite areas continued at the end of the inspection.
P1 Conduct of EP Activities
!
P1.1 Defueled Emeroency Plannino Drill a.
inspection Scope Using Inspection Procedure 82301, the inspector reviewed the licensee's conduct and evaluation of the defue'ed emergency preparedness drill.
-
.
_
_
.
.
... -
_ _. _ -.
. - _ _
_.
-
- - -..
___ -
_ _ - _ _ _.
-- -.
-
.
,
.
b.
Qbservations and Findinas On December 3, the NRC observed the licensee conduct a combined functional drill.
The inspector reviewed activation and augmentation of the emergency response organizations and the activities within the emergency response f acilities. Specific activities evaluated included those in the control room, and the technical support center (TSC).
The simulated accident scenario was a breach in the spent fuel transfer canal, complicated by damage to a spent fuel element and the partialloss of water levelin j
the spent fuel pool. A simulated release of radioactive gas to the environment
,
occurred. An Alert emergency was properly declared by the Operations Shif t Manager and the TSC was activated in a timely manner with adequate numbers of support staff needed to perform all emergency plan functions.
Overall, the performance by licensee drill players and evaluators was very good.
The licensee demonstrated that the defueled emergency plan and procedures worked through the fu fillment of several drill objectives, and that the o! ant staff was capable of implementing them. Performance strengths included the ability to recognize and classify emergency action levels, to assess degraded plant conditions and implement appropriate corrective measures, and to assess plant and site radiological conditions. Areas for improvement were identified, which included the need to enhance the communication of radiological data and emergency status information; to improve the selection, operation and use of some equipment; to control and track onsite response teams; and, the need to address procedure weaknesses and inconsistencies. The licensee exercise critique on December 4 was thorough and self critical. NRC observations were consistent with licensee evaluations.
The licensee conducted another combined functional drill during the period (December 16) using different players to provide additional training on the new plan procedures. The licensee wrote ACR 971044 to track implementation of the corrective actions. NRC review of the defueled Emergency Plan continued at the conclusion of this inspection,
<
c.
Conclusions Good performance was noted in the conduct and evaluation of a drill using new implementing procedures for the defueled emergency plan.
S1 Conduct of Security and Safeguards Activities a.
Insoection Scone (81700)
Determine whether the conduct of security and safeguards activities met the licensee's commitments in the NRC approved security plan (the Plan) and NRC regulatory requirements. Areas inspected were: access authorization program;
. _.
-
-.. -
_.
.
-
-_~-_- -.-. __-_., - --
__- -
_-.-- - -
-
.
,
-
I slarm stations; communications; protected area access control of personnel, packages and material, and sehicles.
>
b.
Observations and Findinas
,
Alarm Stations. The inspectors observed operations in both the Central Alarm Station (CAS), and the Secondary Alarm Station (SAS). This observation included alarm response, post turnover, as well as interviews with the operators. The alarm stations were equipped with appropriate alarms, surveillance and communications capabilities and were continuously manned by knowledgeable operators so that no single act could remove the plant capability for detecting a threat and calling for assistance. The systems in the alarm stations were sufficiently diverse and independent. The CAS did not contain any operational activities that could interfere
<
with the execution of the detection, assessment and response functions.
.
Communications. Both the Alarm Stations were capable of maintaining continuous intercommunications, communications with each security force member (SFM) on duty, and were capable of calling for assistance from both on and offsite organizations.
Protected Area (PA) Access Control of Personnel and Hand Carried Packagan. The inspectors observed operations at the personnel access portal a numt or of times during the course of the inspection. Positive controls were in place to ensure only authorized individuals were granted access to the PA. All personnel and hand carried items entering the PA were properly searched and the last SFM controlling access was in a position to perform this function effectively.
PA Access Control of Material. The inspectors observed material processing in the warehouse. The licensee had positive control measures for materials entering the PA. Materials entering the PA were identified, searched and authorized by the licensee. Materials entering the PA via the warehouse were searched by properly trained and qualified individuals.
PA Access Control of Vehicles. The inspectors observed security force operations at the vehicle entry point including verification of vehicle authorization and performance of vehicle searches prior to entry into the PA. The active land vehicle barrier was operated in accordance with Plan commitments. The inspectors concluded that vehicles were being controlled and maintained in accordance with the Plan and applicable procedures, c.
Conclusions The licensee was conducting its security and safeguards activities in a manner that protected public health and safety and that the program, and that this portion of the program, as implemented, met the licensee's commitments and NRC requirements.
l
-.
-
--
- -. - -.
. - - - -
.-
. -
- _. _ _. _ _ __ _ _. _ _
, _ _ _ _.. _. _ _
_ _ _. _ __ _ _ _
l
$
i
e
,
!
i
,
-
,
'
S2 Statue of Sewrity Foollities and Equipment
!
a.
Innoection Scoon (81700)
.
Areas inspected were: testing, maintenance and compensatoly measures; PA detection and assessment sids; personnel and package search equipment and l
'
vehicle barrier systems.
l b.
Observations and Findinat
-
i
Testina, Maintenance and Comoensatory Measures. The inspectors reviewed testing and maintenance records for security related equipment and found that documentation was on file to demonstrate that the licensee was testing and i
maintaining systems and equipment as committed to in the Plan. A priority status was being assigned to each work request and repairs were normally being
'
,
- completed within the same day a work request necessitating compensatory
,
measures was generated. The inspectors reviewed security event logs and maintenance work requests generated over the last year. These records indicated
>
_
that the need for compensatory measures was extremely minimal. When
'
l necessary, the licensee amployed compensatory measures. These compensatory I
measures did not reduce the effectiveness of the security system as it existed prior l
to the need for compensatory measures.
PA Detection and Assessment Aids. The inspectors observed licensee performance testing of several Intrusion Detection System (IDS) zones. All zones of the IDS that l
were tested generated appropriate alarms. The tests were performed in accordance with established testing procedures and were functional and effective. The inspectors observed camera coverage, in the CAS and SAS, of the entire perimeter, while it was being walked down. The camera coverage and overlap was very good.
The licensee's assessment side were functional and effective, Personnel and Packane Search Eaulomant. The inspectors observed both the i
routine use and the daily performance test of the licensee's personnel and package
search equipment. All search equipment was observed to perform its intended -
function, c.
Conclusions The licensee's security facilities and equipment were determined to be well
-
maintained and reliable and were able to meet the licensee's commitments and NRC requirements.
-
-
. _..,_.. _ _ _. _.. _ _ _ _ _., _ _, _
.
.
..
_
....
. ~
-
_ - -
-
-
_ - - _ - -
_ -.. - _. -
.
_
. -. _ - --
-
.
.
S2.1 Loss of Security Eauloment flFl 97 09 05)
!
a.
insoection Scone (71750)
The inspector reviewed the licensee response to a loss of security equipment on December 31,1997.
b.
Observations and Findinat The plant experienced a loss of security equipment at 9:52 p.m. on December 31, 1997, which affected the ability to monitor the status of plant security. The licensee implemented security procedure SCP 1.818 and established compensatory measures per the procedure by 9:54 p.m., which included the posting of security personnel. There was no loss of security effectiveness. The inspector reviewed the licensee's response and found it to be in accordance with the procedure. The security system failures were described in adverse conditlon report (ACR) 98 02.
Plant support personnel responded to the site to investigate the status of security equipment and the cause of the failures. Compensatory measures remained in effect until repairs an:t testing were completed at 3:26 a.m. on January 1,1998.
The inspector identified no inadequacies ir' the licensee's response to degraded conditions on December 31. However, the inspector noted this was a repeat event involving the loss of security equipment on June 13,1997 (Inspection C703, ACRs 97 299 to 301), indicating that the corrective actions for the June event were not effective. This matter is considered open pending the NRC review of the licensee's actions to identify and resolve the causes of the recurrent security equipment f allures (IFl 97 09 05),
c.
Conclusiong Equipment f ailure resulted in the loss of security equipment on December 31. The security force response was good to set up and maintain compensatory measures.
The response by support personnel was timely and effective to restore equipment functions. Past corrective actions were insufficient to preclude a recurrent f ailure.
.
Security and Safeguards Procedures and Documentation a.
Insoection Scone (81700)
Areas inspected were: security program plans, implementing procedores and security event logs, b.
Observations and Findinas Sigtdy Proaram Plans. The inspectors verified that selected changes to the Plan est u ated with the Vehicle Barrier System (VBS), as implemented, did not. decrease thr ef fectiveness of the Plan. Discussions with the licensee indicated that a plan
,
.
.
. - -
-
.-.
-
...
.
. - - - -. -
_-_. -
- -
- _ -. -.. - - -
-_
_.
- - -. -
-..
I*
l
-
revision to reflect the decommissioning state was submitted in accordance with the provisions of 10 CFR 50.54(p) and the plan was currently being reviewed by NRC.
Securitvffgaram Procedures. Review of selected implementing procedures associated with testing and maintenance and surveillance of personnel search equipment determined the procedures were consistent with the Plan commitments, and were properly implemented.
Security Event loos. The inspectors reviewed the Security Event Log for the previous twelve months. Based on this review, and discussion with security management,it was determined that the licensee appropriately analyzed, tracked, resolved and documented safeguards events.
c.
Conclusions Security and safeguards procedures and documentation were being properly implemented. Event Logs were being properly maintained, and effectively used to analyze, track, and resolve safcguards events.
S4 Security and Safeguards Staff Knowledge and Performance a.
insoection Scooe (81700)
Areas inspected were security staff requisite knowledge and capabilities to accomplish their assigned functions, b.
Obcervations and Findinas Security Force Reaulsite Knowledoe. The inspectors observed a number of SFM's in the performance of their routine duties. These observations included alarm station operations, personnel and package access control searches, and FA patrols, in addition, interviews were conducted with SFMs and security management.
Finally, tralning records were reviewed (see So). Based on all of the above activities, it was determined that the SFMs were knowledgeable of their responsibilities and duties, and could effectively carry out their assignments.
Response Capabilities. The inspectors reviewed the licensee's response strategies, response drills and critiques and evaluated feedback to the training department for lessons learned.
c.
Conclusions The SFMs adequately demonstrated that they have the requisite knowledge necessary to effectively implement the duties and responsibilities associated with their position.
.
.
.
..
.
- - - -. - - - - - -.- - -.
.
. -. -
- - _.
_
.
.
,
i
'
j
SS Securfty and Safeguards Staff Training and Qualifications
,
l
,
I a.
Inanection Scone (81700)
Areas inspected were security training and qualifications and training recordt.
'
b.
Observations and Findinas Security Trainina and Qualifications. The inspectors reviewed training records of i
ten SFMs. This review indicated that the security force was being trained in i
accordance with the approved Training and Qualification (T&O) plan, j
Trainina Records. The inspectors' review of training records determined that the records were accurate and contained sufficient information to determine the current
>
,
qualifications of the individual.
,
!
c.
Conclusions t
e Security force personnel were being tralned in accordance with the requirements of
'
the NRC approved T&Q plan. Training records were being properly maintained.
.
Based upon the findings documented in paragraph S4, the inspectors determined
,
that the training was effective and provided the security force with the requisite
-
information needed to effectively implement tiie Plan.
'
'
SS Security Organlaation and Administration a.
Inanection Scone (81700)
!
Areas inspected were management support, effectiveness and staffing levels.
.
b.
Observations arid Findinas
+
,
Manaaement Suonort. The inspectors reviewed various program enhancements -
,
made since the last program inspection to determine the level of management support. These enhancements included the allocation of resources for the following
activities:
Acquisition of a new breathelyser
-
Replacement of CCTV monitors and amplifiers in CAS/SAS
-
Issued purchase order to Sandia National Lab to review decommissioning
-
activities Complete CAS upgradn -
l
-
Management Effectiveness. The inspectors reviewed the management organizational structure and reporting chain. Security management position in the
'
organlaational structure provides a means for making senior management aware of programmatic needs. The positive response of senior management to requests for
- equipment, training and resources in general has contributed to the effective administration of the security program.
,_
h
,,
--,---.-.-.,------2-.c.n-,.-n,---...~.,n
,~.,. ~, ~,..., - - - -,,, -,,,,
m,
-..-
-
-
.
.
Staffino levels. The inspectors verified that the total number of trained SFMs immediately available on shif t meets the requirements specified in the Plan
'
c.
Conclusiong The level of management support was adequate to ensure effective implementation of the security program, and was evidenced by adequate staffing levels and cont;nued resource allocation to improved training and equipment to enhance effective implementation of the security program.
Quality Assurance in Security and Safeguards Activhles S7.1 Audits (IFl 97 09 06)
a.
Insocction Scoce (81700)
Areas inspected were the licensee's Quality Assurance (QA) report of the NRC-requited security program audit to determine if the licensee's commitments as contained in the Plan were being satisfied, b.
Observations and Findinas The inspectors reviewed the 1997 QA audit of the recurity program, conducted June 2 20,1997,(Audit No. CY 97 A06 03). The audit was found to have been conducted in accordance with the Plan. To enhance the effectiveness of the audit, the audit team included an independent technical specialist.
The security audit report identified six ACRs and two observations. One ACR involved the effectiveness of corrective actions to address Preventative MaintenarcA issues identified in a previous audit. As of this inspection, this issue has not tieen properly resolved and will be reviewed during a subsequent inspection (IFl 97 09 06). Two ACRs were related to security procedure compliance issues, one ACR was related to the alarm station operator's understanding of the functions of an emergency trip button located in the SAS, and the remaining two ACRS were related to the contract security force's failure to comply with Bid Specification requirements and the licensee's f ailure to ensure that cont;ols for the vehicle barrier configuration and security keys were consistent with Plan commitments. The inspectors determined that the findings were not indicative of programmatic weaknesses, and the observations would enhance program effectiveness. The inspectors determined, based on discussions with security management and a review of the responses to the findings that, in general, the corrective actions were effective, c.
Conclusions The review concluded that the audits were comprehensive in scope and depth, that the findings were reported to the appropriate levels of management, and that the audit program was being properly administere. _-
.. -
_ _ -..--.
- -. _ -
-
- _.
-
_.
-
- -
.
<
.
,
t i
Miscellaneous Security and Safety issues
'
!
S8.1 Vehicle Barrier System (VBS) (T12515/132)
General
'
On August 1,1994, the NRC amended 10 CFR Part 73, " Physical Protection of Plants and Materials," to modify the design basis threat for radiological sabotage to
'
include the use of a land vehicle by adversaries for transporting personnel and their
'
hand carried equipment to the proximity of vital areas and to include the use of a land vehicle bomb. The amendments required reactor licensees to install vehicle control measures, including vehicle barrier systems (VBSs), to protect against the malevolent use of a land vehicle. Regulatory Guide 5.68 and NUREG/CR 6190were issued in August 1994 to provide guidance acceptabl6 to the NRC by which the licensees could meet the requirements of the amended regulations.
,
A letter dated February 29,1996 from the 1%nsee to the NRC forwarded Revision
,
i 30 to its physical security plan that detailed the actions implemented to meet the requirements of 10 CFR 73.55 (c)(7),(8), and (9) and the design goals of the
" Design Basis Land Vehicle" and " Design Basis Land Vehicle Bomb." A NRC May 15,1996, letter advised the licensee that the changes submitted had been reviewed and were determined to be consistent with the provisions of 10 CFR 50.54(p) and were acceptable for inclusion in the NRC approved security plan.
This inspection, conducted in accordance with NRC Inspection Manual Temporary Instruction 2515/132," Malevolent Use of Vehicles at Nuclear Power Plants," dated January 18,1996, assessed the implementation of the licensee's vehicle control measures, including vehicle barrier systems, to determine if they were commensurate with regulatory requirements and the licensee's physical security plan.
S8.2 Vehicle Barrier System (VBS)
,
a.
inspection Scone The inspectors reviewed documentation that described the VBS and physically inspected the as built VBS to verify it was consistent with the licensee's summary description submitted to the NRC.
b.
Observations and Findinas The inspectors' walkdown of the VBS and review of the VBS summary description
.
disclosed that the as built VBS was consistent with the summary description and
'
mot or exceeded the specifications in NUP.EG/CR 6190.
,
l
- _ _ _
,__
_
_,
..
__ _
,
'.
.
,
,
2B
c.
Conclusion The inspectors determined that there were no discrepancies in the as bu'ilt VSS or the VBS kummary description.
SB.3 Domb Blast Analysis a.
Insoection Scope The inspectors reviewed the licensee's documentation of the bomb blast analysis and verified actual standoff distances provided by the as built VBS.
b.
Observations and Findinas The inspectors' review of the licensee's documentation of the bomb blast analysis determined that it was consistent with the summary description submitted to the NRC. The inspectors also verified that the actual standoff distances provided by their as built VBS wers consistent with the ininimum standoff distances calculated L
using NUREG/CR 0* 90. The standoff distances were verified by review of scaled drawings and actual field measurements, c.
Conclusion No discrepanctes were noted in the documentation of bomb blast analysis or actual standoff dirtances provided by the as built VBS.
SB.4 Procedural Controls a.
insoection Scope The inspectors reviewed applicable procedures to ensure that they had been revised to include the VBS.
b.
Observations and Findinas The inspectors reviewed the licensee's procedures for VBS access control measures, surveillance and compensatory measures The procedures contained effective controls to provide passage through the VBS, provide adequate surveillance and inspection of the VBS, and provide adequate compensation for any degradation of the VBS.
c.
Conclusions The inspectors' review of the procedures applicable to the VBS disclosed no discrepancie...
__.
-
_-
-
. _ - -
- -. _ _ _ _
-
.-_.. _. -._ _ - - _._- -.._ -. - _ -...-
.
.
-
V. Manacament Meetinap, X1 Exit Meeting Summary The inspector asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
The inspector met with licensee representatives at the conclusion of the security inspection on December 12,1997. At that time, the purpose and scope of the security irupection were reviewed, and the preliminary findings were presented. The licensee acknowledged the preliminary inspection findings.
The inspector presented a summary of the inspection results in a meeting with the Unit
'
Director at the conclusion of this inspection period on January 15,1998. The licensee acknowledged the findings presented.
e X2 Review of Updated Final Safety Analysis Report (UFSAR)
.
A recent discovcry of a licensee operating its facility in a manner contrary to the UFSAR
'
description highlighted La need for a special focused review that compares plant practices, procedures, and parameters to the UFSAR description. Since the UFSAR does not
'
specifically include security program requirements, the inspectors compared licensee activities to the NRC approved physical security plan, which is the applicable document.
While performing the inspection discussed in this report, the inspectors reviewed the licensees Plan commitments related to Protected Area barriers. The inspectors determined, based on discussions with security supervision, procedural reviews and observations, that the Protected Area barriers weia effective, properly maintained and satisfied the seguirements of the Plan.
.
, -,., - - -
n
-.n,.-----.
-
,
,
, - -
-n
,
.. _.. _
_. _ _.
.
_.
_ _ _ _. _. _ _ _ _ _ _.
_ _ _.. _.
-_
_
.
.
,
,
]
PARTIAL LIST OF PERSONS CONTACTED
'
Licensee
,
"
Russell Mellor, Vice President Operations and Decommissioning Gary Bouchard, Unit Director John Haseltine, Engineering Director Doug Heffernan, Maintenance Manager Gerry Walg, Operations Manager James Pandolfo, Security Manager
<
Richard Sexton, Radiation Protection Manager Noah Fetherston, Decommissioning Project Manager Edward Mullarkey, Assistant Decommissioning Project Manager Gerry van Noordonnen, Nuclear Ucensing Manager Connecticut Deoartment of Environmental Protection Michael E. Firsick, Radiation Control Physicist Gary McCahill, Radiation Control Physicist Denny Galloway, Supervisor, Bureau of Air Management
.
J
i
l
-
,
.. _,
.-,
_. _.
_
-,
,- _ _ _... _ _. _ _
. _ ___ _. _ __.
_ _ _ _ __
.-_ _._-.._. _.-.. _ _ _. _ _
.
.
,
,
'
,
.
'
INSPECTION PROCEDURES USED
~
IP 37700:
Design Changes and Modifications
'
IP 37801:
Safety Reviews, Design Changes, and Mods IP 62706:
Maintenance Activities
,
IP 71707:
Plant Operations
.
IP 71750:
Plant Support
IP 81700:
Conduct of Security and Safeguards Activities
,
IP 82301:
Defueled Emergency Preparedness Drill
IP 83726:
Control of Radioactive Materials and Contamination, Surveys and Monitoring i
IP 90712:
In Office Review of Written Reports of Non Routine Events at Power Reactor Facilities i
IP 92700:
Onsite Follow up of Written Reports of Nonroutine Events at Power Reactor
j Facilities
,
'
IP 92702 Fol!ow up Corrective Actions for Violations
'
i ITEMS OPEN, CLOSED, AND DISCUSSED QQAD
.
.
97 09 01 URI Resolution of SFB Ventilation Design Deficiency
-
97 09-02 VIO Inadequate SFB Ventilation Design Controls 97 09 03 URI Adequacy of OA Reclassification of SFPCS l
97 09 04 URI Offsite Radiation Surveys for Contaminated Blocks 97 09 05 lFl Loss of Security Equipment 97 09 06 IFl Final Resolution of Audit Corrective Actions
'
,
Closed
97 05 03 URI Spent Fuel Building Ventilation Design Deficiencies 97 16 01 LER Spent Fuel Building Positive Pressure i
97 17 01 LER Plant Radioactivity in the Landfill
' 97 18 01 LER Spent Fuel Ventilation Flow Low 97 21 01 LER Contaminated Material Offsite piscussed 97 05 01 IFl Corrective Actions for Halon Actuation
_..,
., -.. _
_.._,..,,_._..._,..m.
,,.,
.,
c
.. ~.,,,..,,w
,.,
_.,_.,,._,m-y,-,.,
-_- _ _.. _ _.,,.
-.,,
,w,
.,.,e.. _.
. -
_ - -
-. -. - -.. _.. -.. -. _ _ - - -_
.-.. - - _.- - - - - - -....-
!
'
e
,
- LIST OF ACRONYMS USED
!
ACR Adverse Condition Report AEOD Office for Analysis and Evaluation of Operational Data ANN Annunciator Response Pecedure AOP Abnormal Operating Procedure CFR Code of Federal Regulations l
CAMP Corrective Maintenance Procedure CYAPCo Connecticut Yankee Atomic Power Company EDG Emergency Diesel Generator EOP Emergency Operating Procedure i
Fahrenheit
gnm gallons per minute
'
Inspection Report
LDB
Licensing and Design Basis
LER
Licensee Event Report
Normal Operating Procedure
'
Notice of Violation
NRC
Nuclear Regulatory Commission
NSO
Nuclear Side Operator
NUSCO
Northeast Utilities Service Company
-
Public Document Room
Preventive Maintenance Procedure
Plant Operations Review Committee
.
Post Shutdown Decommissioning Activities Report
Quality Assurance
OC
Quality Control
Radiction Protection Manager
Radiation Work Permits
Refueling Water Storage Tank
Special Test Procedure
_,
SUR
Surveillance Procedure
Technical Requirement Manual
TS
Tecnnical Specification
Updated Final Safety Analysis Report
WCM
Work Control Manual
l
V
,
y-
r
vrre----.,.
-_, - - - - -, _ -, - -.
m,-
.,,,,--y_,y.7,,--rwa---6----
m
<,+.,-
ww
-,w- - - -.. -
m
r<--.m
m
n
.
.---t+----
-
-ae.-