IR 05000213/1998001

Insp Rept 50-213/98-01 on 980113-0413.Violations Noted.Major Areas Inspected:Decommissioning Support Activities,Spent Fuel Safety,Plant Support & Radiological Controls & Facility Mgt & Control

ML20216C631
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/13/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216C577	List: IR 05000213/1998001 ML20216C573
References
50-213-98-01, 50-213-98-1, NUDOCS 9805190362
Download: ML20216C631 (46)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-213 License No.: DPR-61 l

l Report No.: 50-213/98-01 Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, CT 06141-0270 Facility: Haddam Neck Station I

Location: Haddam, Connecticut Dates: January 13 - April 13,1998 Inspectors: William J. Raymond, Senior Resident inspector Joseph Nick, Decommissioning Health Physicist Ronald L. Nimitz, CHP, Senior Radiation Specialist Approved by: Marie T. Miller, Chief Decommissioning and Laboratory Branch Division of Nuclear Materials Safety 9805190362 780513 PDR ADOCK 05000213 G PDR

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EXECUTIVE SUMMARY Haddam Neck Station NRC Inspection Report No. 50-213/98-01 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a three-month period of resident l inspection; in addition, it includes the results of announced inspections by regional

! inspectors in the area of site characterizatio Decommissionino Suncort Activities:

Operations and maintenance support was good to monitor the status of operating plant equipment, to test and maintain equipment, and to address emerging condition Exceptions to good performance included personnel errors during tagging activities and testing the diesel fuel oil pump. Degraded equipment conditions resulted in the discharge of minor quantities of oil, and flooding in the lower level of the screenhouse. The flooding was due to past weaknesses in the modification process, and a lack of detail in the maintenance procedure. Actions this period were good to address degraded conditions, i

Although procedures and controls for freeze protection were adequate, the failure of house heating steam lines, the loss of freeze protection for a tank containing radioactivity, anc'

several administrative and material discrepancies, raise concerns for the adequacy of fnieze protection for systems important to safe storage of fuel and radioactive liquids. An inspection follow-up item will track actions to address this area. The licensee established c program to met the requirements of 10 CFR 50.65 during plant operations, and was redefining the program for decommissioning. The progress of this effort was proceeding at an acceptable pace. Maintenance support for decommissioning was generally effective to assure the continued availability of systems important to safe fuel storag Scent Fuel Safety:

Generally acceptable engineering support was noted in the modifications to provide new cooling systems for the spent fuel pool, and to replace outdated seismic monitoring matruments. Areas for improvement included the designation of quality assurance indicators for systems that support spent fuel cooling, and the application of appropriate QA controls for SFP-related modifications. An NRC identified violation indicated continued weaknesses in licensee 10 CFR 50.59 reviews and process to maintain the licensing basi The licensee took actions as described in the June 11,1997 response to the escalated enforcement action to address weaknesses in engineering, emergency preparedness, operational problems and the corrective action program. NRC review of this area to determine the effectiveness of the corrective actions continued at the end of this inspection perio ii i

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Plant Suppo;t and Radioloalcal Controls:

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The licensee provided good radiological controls for the RWST work and general plant activities. The site characterization work performed for the unidentified buried objects was appropriate with excellent radiological controls. Response by the licensee's staff after the i

' identification of a potential problem with the air sample filters was also very appropriate and will be further reviewed by the NRC staff after follow-up corrective actions are completed.

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Good performance was noted in the conduct of routine security measures. Equipment

failure challenged normal security functions on March 6. The security force response was good to set up and maintain compensatory measures. Past corrective actions were insufficient to prevent recurrent events. Good performance was noted in the conduct and evaluation of a drill using new implementing procedures for the defueled emergency pla Facility Manaaement and Control: l l

NRC tours identified a locked maintenance shop door, a condition contrary to safety l requirements. Licensee follow-up actions were appropriate. Actions to staff key positions during periods of severe weather and the control of overtime was reasonable to assure personnel remained fit for duty. Licensee plans to assure adequate staffing during union negotiations were acceptabl <

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REPORT DETAILS Summarv of Facility Activities The Haddam Neck plant conditions remained stable with the spent fuel safely stored in the spent fuel pool. There were no significant changes in the plant systems required to support spent fuel cooling. The licensee continued to work on design modifications to install a new cooling system for the spent fuel pool heat exchangers as part of phase 1 of the nuclear islan The licensee announced management changes in January 1998, which resulted in the organizational realignment of Connecticut Yankee Atomic Power Company and separation from Northeast Utilities. Mr. Russ Mellor was formerly the Site Director, and was appointed Vice President, Site Operations and Decommissioning. Mr. Donald K. Davis was appointed Chairman, President, Chief Executive Officer of CYAPC Special NRC inspections included the review of the plans for characterization and remediation of onsite and offsite areas affected by plant radioactivity, the onsite investigation of buried objects, and the activities to leak seal the refueling water storage tank. On March 11,1998, NRC Region I and HQ representatives met with licensee management in a public forum at the site to discuss the preparations for decommissionin The licensee described the process to decontaminate the reactor coolant system scheduled in June 1998, the design of the spent fuel island, the use of 10 CFR 50.59 for system safety re-classification, and the status of the completion of phase 2 of the Radiological Protection Improvement Progra NRC site visits included plant tours by Ronald Bellamy, Chief of the Decommissioning and Laboratory Branch on March 10-11,1998. NRC personnel attended meetings of the Community Occommissioning Advisory Committee on February 7 and March 10,199 . Decommissionina Suonort Activities 01 Conduct of Operations'

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01.1 Ooeratina Activities and Soent Fuel Coolina Insoection Scone (71707,62706)

The purposo was to review plant status and licensee activities to maintain the plant in the defueled conditio b, Observations and Findinas The licensee maintained stable plant conditions, and adequate level and cooling for the spent fuel pool (SFP). The licensee operated plant equipment necessary to

Topical headings such as 01 M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outline topic .

2 support the SFP, and assured the operability of support systems. The inspectors verified licensee compliance with Technical Specifications (TS) TS 3.9.11, SFP Water Level; and, TS 3.9.15, SFP Cooling. The licensee maintained pool temperature below the TS 3.9.15 limit of 150 The spent fuel pool cooling system (SFPCS) remained operating per procedure (NOP) 2.10-1, with the B spent fuel pool heat exchanger in service. Heat exchanger fouling remained acceptable through periodic cleaning. The secondary side of the SFPCS was cooled using the service water (SW) system. Operators shifted to using the B SFP cooling pump as the preferred after routine testing showed that the "A" pump motor currents had trended higher. The "A" pump remained operable and available to the operators (reference engineering evaluation CY-TS 98-0027 dated January 15,1998). The licensee's engineering assessment was acceptable and the conclusions were technically justifie The licensee conducted routine surveillance of the SFP and building per Surveillance Procedure (SUR) 5.1-08. Operator actions observed during periodic plant tours were consistent with the procedures. Compensatory measures were taken as needed, such as during off normal conditions for the fire protection and radiation monitoring systems. Operator responses to off normal conditions were consistent the alarm response procedures. Operators activities during March and April were good to monitor flooding of the Connecticut River per Abnormal Operating Procedure (AOP) 3.2-2 Confiauration Control The inspectors reviewed the licensee control of the plant configuration. This review included the implementation of the tagging, and the restoration of systems removed from service following maintenance. One licensee-identified performance problem concerned the improper tagging of the Kinney pumps and filters in the intake structure (Adverse Condition Report (ACR)98-191). The error did not impact SFP safety and this event was an exception to generally good performance since there were no similar issues in the last year. However, past NRC concerns in this area indicate the need for continued licensee attention to assure safe tagging practice .2 Maintenance and Surveillance Activities Insoection Scone (71707. 61726. 62707)

The purpose was to conduct periodic reviews of plant status and ongoing maintenance and surveillanc Observations and Findinas

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The inspectors reviewed licensee activities to test, troubleshoot and repair plant equipment. The licensee maintained and tested plant equipment necessary to support the SFP, and to assure the operability of support systems. The licensee implemented compensatory measures and the action statements in the TSs and the

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technical requirements manual during periods of degraded equipment performance (e.g., for work on RM 14A, and smoke detector SDT-A-1-2). The inspection l included reviews of the following activities: I

SW pump solenoid valve replacement (oil leakage)

test of the emergency diesel generators and fuel transfer pumps

EG-2B starting problem (zero speed relay iciture)

test of the new seismic monitor (SUP 5.2-67/68- Section E1.1)

test and cleaning the "B" SFP heat exchanger  ;

test and maintenance of freeze protection circuits (Section O2.1) l

investigat!on and repair of a frozen liquid radweste line  !

investigation of leaky penetrations in the intake building

coating the refueling water storage tank (RWST) with a leak sealant (SPL 10.5-227)

l Surveillance testing was conducted well to demonstrate continued operability of I

SFP support systems. One exception to generally good performance was the failure to return the EG-2B fuel oil transfer switch to the " auto" position following testing ;

(reference ACR 98-227). Licensee actions were appropriate to assess the '

, operability impact (EG-2B remained operable), and addresa corrective action ;

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l Maintenance personnel provide good support !n response to emergirig conditions, i such as the investigation of a leaky injector oc the diesel fire pump (ACR 98-250), 4 l and the actions to mitigate screenhouse inleau, : during periods of high river conditions (ACRs98-249,251). The follow-up at %a flooding event by maintenance personnel was good to investigate the cause of the inleakage, which included a lack of detailin the maintenance prof edure for the pressure maintenance pump (reference AWO 97-4593) and the roor implementation in 1995 of a plant modification (PDCR 1007). Licensee actbns were in progress at the conclusion of

! the inspection to assure maintenance pr)cedures adequately addressed sealing all penetrations in the lower level of screenhouse, i

( Oil Sheen on Discharae Canal

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On several occasions during recent months, the licensee identified a substance on the waters in the discharge canal (reference ACRs 97-1035,97-1090,9f 71 98-109,98-190 and 98-278). Each event involved about a cup of oil (or othu substance) and was captured by an oil boom and recovered. Although oil was identified in some events, the exact nature of the substance for other events was l not clear even after sampling and chemical analysis. On one occasion, the licensee i reported that sampling identified No. 6 fuel oil, which was not used at the site. One l

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source of oil was caused by leakage through the solenoid operated valves for the SW pump oilers. The licensee addressed SW pump operability during the troubleshooting and repairs (reference operations memorandum ODM 98-018 dated January 14,1998). Licensee actions wars acceptable to minimize the impact on the environment, to make event notifications, to investigate each occurrence, and take corrective actions. However, despite extensive investigations, the exact

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nature and cause of some events remained unknown. Licensee reviews in this area continued at the end of the inspection perio In the past, when the licensee notified offsite authorities about oil spills per the Nuclear Pollution Discharge Elimination System permit, the matter was reported to the NRC per 10 CFR 50.72(b)(2Hvi) as events related to protection of the environment for which a notification to another government agency was planne The NRC issued NUREG 1022, Revision 1 in January 1998, which clarified the NRC reporting guidance for 50.72 and 50.73. Under the new guidance, the NRC no longer expects the licensee to report minor oil spills. The licensee implemented the new guidance during this inspection perio RWST Repair The licensee completed work on February 13,1998, using procedure SPL 10.5-227 to seal the bottom of the RWST. The temporary leak repair was accomplished by applying a sealant (InstaCote ML) to cover the tank bottom and about two feet of

the side wall. The licensee intends to return the RWST to service to allow draining of the reactor cavity when decommissioning activities resume. The licensee provided information in response to NRC reviews to show the sealant was suitable for the intended application relative to chemical and physical propertie The licensee drained the RWST and decontaminated the tank floor in preparation for the repair Despite the efforts, significant beta, gamma and alpha contamination remained in the tank. Licensee radiological controls were successful to minimize worker exposure, prevent inadvertent contamination, and minimize potential environmental releases. NRC health physics specialists and the resident inspector reviewed the licensee preparations for the job and the plans to provide worker radiological protection. The inspectors observed the activities to repair the tank and to implement radiological controls. This matter is further discussed in Section R of this report and Inspection 98-0 .3 Conclusions for Decommissionina Operations and Maintenance i

Operators' performance was good to monitor the status of operating plant l

equipment, and to monitor the SFP. Operators showed good regard for plant ;

procedures and responded well to off normal conditions. Maintenance personnel ]

performed well to test and maintain equipment, and to address emerging degraded conditions. Exceptions to good performance included a personnel error during tagging activities and testing the diesel fuel oil pump. Degraded equipment !

conditions resulted in recurrent discharges of minor quantities of oil and flooding in ;

the lower level of the screenhouse. The flooding problems were due to a lack of detail in the maintenance procedure and past weaknesses in the modification 3

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process. Licensee performance this period was good to repair the RWST, to I investigate degraded conditions and take appropriate corrective action ;

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02 Operational Status of Facilities and Equipment O2.1 Cold Weather Preoarations (IFl 98-01-011 Insoection Scope (71714)

The puroose was to review licensee actions to assure plant systems were protected from freezin Observations and Findinas The licensee implemented a progiam to assure systems were protected from cold weather. Plant design features ir cluded area heating for buildings and heat traced circuits for process piping and tanks. The licensee used administrative controls to assure the freeze protection circuits were maintained and operating. Maintenance personnel used preventative maintenance procedure (PMP) 9.9-146 to verify the condition of insulation and test heat trace circuits. The tests included a current test and setpoint verification on the 23 heat trace panels listed in Attachment 12.1. The checks were completed in the September - October,1997 period, along with preventative maintenance work on the house heating boilers. The inspectors reviewed the PMP 9.9-146 inspections for the following heat trace panels: HET-HT-WD-2B (automated work order AWO 97-342), HET-HT-DWST (AWO 97-377), and HET HT-TANK (AWO 96-8488). No inadequacies in the test methods or results were identifie The operators checked heat trace panels and circuits weekly per operations department instruction ODI 146, and the daily operator round sheet (SUR 5.1-08).

The cold weather checkt were completed as required, based on a sampling review of the ODI-146 surveillances for the period from 1/4/98 through 2/1/98, and by review of the operator logs during the inspection. Similarly, maintenance personnel identified and repaired freeze protection circuit deficiencies identified during the periodic inspections. However, not all deficiencies were corrected, as evidenced by trouble report (TR) tags still hung on some plant equipment (e.g., TR 06CYO32343 for 5 heat circuits which did not indicate amperage when checked in January 1998). Some outstanding TRs were up to three years ol Despite the preparations, licensee actions were not sufficient to preclude several problems that occurred during the period: leaks developed in the house heating steam pipes supplying building heat for three areas (the spent fuel building, auxiliary feedwater area, and the waste disposal building - ACR 98-199); a condensate storage tank sample valve partially froze (ACR 98-001); and, the suction line for the waste evaporator feed pumps froze (ACR 98-191). These issues were reviewed by plant management and corrective actions were taken to address each discrepanc De-eneraized Freeze Protection Panel The licensee discovered on March 11,1998, that a blown fuse in the control circuit for panel HT-WD-PNL-2A caused the loss of freeze protection for the aerated drains

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holdup tank (Tk 61-1 A) and the waste evaporator feed pumps (ACR 97-191). The event was significant because the 75,000 gallons inventory of radioactive water in the tank could have leaked had freeze conditions caused the pump suction line to fail. Radiation measurements showed that the sludge in the tank bottom caused contact dose rates up to 1.6 R/hr on the tank exterior (reference radiation work permit (RWP) #17). Since the tank is located inside the tank farm, any leakage would be contained by the shield walls surrounding the tank. The follow-up by operations, maintenance and engineering personnel was good to investigate the affected piping, restore freeze protection (the fuse was replaced), and assure integrity of the line prior to processing water from the tank on March 1 Licensee review identified several discrepancies, including the adequacy of status l

Indication on some heat trace circuits and the operator failure to use all available indication. For example, the front door of panel HT-WD-PNL-2A has a " power available" indication as well as individual ammeters for the 38 heat trace circuits powered by the panel; however, the logs did not require the operator to check this indication periodically. The licensee planned to revise the logs to assurn all heat trace indications were fully utilized. Other discrepancies noted by licensee review of ACR 98-191 included: heat trace circuit deficiencies identified by the operators in the Fall of 1997 (ACR 97-892) have not been resolved; and, heat trace circuit modifications started in 1994 have not been comp!eted or turned over to operations (trouble reports filed in 1994 and 1996 are still outstanding). The licensee assigned a Significance Level "C" to ACR 98-191, which indicates that the staff will perform a root cause evaluatio Leaks in Steam Suoolv Pioino The leaks in house heating steam (HHS) lines caused the licensee to isolate the normal heating supply to the affected buildings, and tc install temporary heating (10 KW electric heaters). The combination of electric heaters and area surveillances was adequate to maintain temperatures inside the spent fuel building (SFB) above freezing throughout the cold season. The licensee initially planned to use a bypass jumper around the failed line inside the rickwell to reestablish HHS to the SF *

However, no bypass was used and the licensee deferred further action for the SFB pending the installation of a new heating steam for the nuclear island (a package boiler in the outside enclosure on the southeast side of the SFB).

Temporary electric heaters were also used for the loss of heat in the waste disposal building on March 13,1998. Other long standin0 defi.ciencies included leaks in (and isolation of) the HHS supplies to the spent resin storage facility (since 1996) and the primary auxiliary building upper level supply fan heating coil (since 1993).

The inspectors verified the adequacy of the compensatory measures, particularly in the SFB, during periodic tours throughout the inspection period. While the temporary heating measures were adequate, the site area experienced unusually mild weather conditions for the winter of 1997-1998,and the freeze protection measures might have been challenged under more severe winter conditions. The

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inspector discussed this concern during periodic meetings with the Unit Director and

- during a meeting on March 1 Potential for Drainina the Soent Fuel Pool On February 20,1998, the licensee provided a voluntary response to IE Bulletin 94-01. The licensee identified one credible freeze event scenario which could produce a piping failure that would drain the SFP down to a level 13 feet above the top of the fuel. The event would occur in portions of the SFP purification system that communicate with the SFP and the outdoors. Heat tracing and insulation of those portions of the lines outdoors were preventative measures that would preclude the freeze event. The licensee response stated that..."the heat traced circuit contains an ammeter that is monitored every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and indicates if a loss of electric current exists."

On March 26,1998, the licensee issued ACR 98-239 after an engineering review identified problems with the administrative controls for monitoring the status of the heat trace circuit on the purification line: the associated ammeters were not clearly

- marked to indicate which ones were associated with the purification line. An ammeter reading of zero might not necessarily indicate a failed heat trace circuit since the low reading could be due to a lack of demand on the specific circui Thus, the operator checks could not assure that the heat trace circuit for the purification line remained functional. In respone, the licensee planned to specifically identify the ammeter associated with the critical line, improve round sheet details on what to check on the heat trace panels,'and ensure the instructions in the round sheet to check the subject line were " protected" steps to assure the ;

NRC commitment remained satisfie l The licensee plans for the spent ft.al island include replacing the existing SFP purification loop with piping that is completely indoors, thereby eliminating the potential drain down of the pool due to freeze concerns. The NRC previously reviewed the licensee's controls to preclude the type of concerns identified in IE Bulletin 94-01 in Inspection 97-05. A review of the actions to address the outdoor portions of the purification system, and the remainder of the actions in response to IE Bulletin 94-01, was in progress at the conclusion on this inspectio Actions Needed to Address 7 . e Protection issues in summary, the deficiencies in administrative controls, freeze protection measures and building heating, if left uncorrected, could compromise the integrity of systems relied upon to control radioactive materials and protect the SFP from drainin During the exit meeting on April 15, the Unit Director noted the inspector's concerns, and stated a plan and schedule would be developed to address deficient conditions prior to the start of the 1998-1999 heating season. The plan would address the deficiencies referenced above, together with an assessment of the HHS

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lines in the spent fuel building that will be used with the new boiler for the nuclear island. This matter will be followed in subsequent NRC inspections (IFI 98-01-01).

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8 Conclusions The licensee procedures and controls were adequate to protect important plant systems, including the SFP and systems containing radioactive fluids, from freezin However, the failuro of HHS lines, the loss of freeze protection for a tank containing radioactivity, and the existence of administrative and material discrepancies, raise concerns for the adequacy of freeze protect'on for systems important to safe storage of fuel and radioactive liquids. An inspection followup item will track licensee actions to address this are .2 Maintenance Proaram Inspection Scone (62801)

The purpose was to review the effectiveness of the licensee program to maintain adequate material and structural integrity of structures, system and components (SSCs) important to safe decommissionin Observations and Findinas The licensee continued to use the production maintenance management system (PMMS) and the Work Control Manual (WCM) for the conduct of maintenance and surveillance on SSCs important to safe storage of fuel and plant decommissioning. '

The implementing procedures of the WCM provided the mechanisms to identify material discrepancies, evaluate and troubleshoot discrepancies for repair, conduct preventive and corrective maintenance, and to schedule and track completion of test and repair activities. During routine inspection tours in the plant, the inspectors '

noted that the licensee used the TR system to identify discrepancies and generated work orders to correct problems. There was an apparent low threshold for identifying deficiencies: the inspectors did not identify deficiencies not already addressed in the licensee's corrective action syste The licensee used key performance indicators to track the efficiency of the planning and scheduling process, and to track the backlog of outstanding work. The licensee has made progress in reducing a maintenance backlog, which was at greater than 3OOO ltems on 1/1/97, and was down to 1030 items on 1/12/98. The backlog was high, in part, because it contained outstanding surveillance and maintenance work items for activities that were scheduled for plant operations and the refueling outage, but which were no longer required for a plant in decommissioning. The backlog was reduced as engineering completed the reviews to categorize the plant systems for decommissioning (using the categories in ENG 1.7-156 of operable, available, lay-up and abandoned), and then administratively closing the corrective and preventive maintenance packages for work no longer neede The prioritization scheme for work to be done during decommissioning continues to be defined by WCM 2.1-1. The inspectors reviewed on a sampling basis the list of outstanding work orders for several plant systems, including the diesel fire pump, service water, demineralized water, and SFPCSs. This review showed that no

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outstanding corrective maintenance work orders that would impact system availability to support the nuclear island. Most outstanding work orders were for tests, calibrations, or preventive maintenance checks waiting to be schedule Except for the diesel fire pump, there were no repetitive maintenance issues or patterns that would indicate a problem in maintenance practices; and, the diesel fire pump required repetitive corrective maintenance for operational anomalies or problems noted while starting - the licensee has classified the system to be in category a(1) for the maintenance rule program monitoring and corrective actio Examples of minor maintenance deficiencies were disclosed by events involving freeze and flood protection, as described in Sections 01.1 and O2.1. The deficiencies appear to be related to past program weaknesses for which corrective actions have already been take Conclusions Maintenance support for decommissioning was generally effective to assure the continued availability of systems important to safe fuel storage. The work identification and PMMS processes were generally effective to correct plant material deficiencies. The licensee appropriately prioritized the resolution of discrepancies to support safe fuel storage. There was a high backlog of outstanding work items from the power operations phase; however, progress was being made with existing limited resources to reduce the backlog as decommissioning continues. Areas for improvement include the maintenance of freeze protection and flood protection measure i O2.3 Maintenance Rule imolementation (IFl 98-01-02) Inspection Scope (62706)

The purpose was to review the implementation of the maintenance rul Observations and Findinas initial Proaram The licensee developed a program to meet 10CFR50.65 while the plant was in power operations, and thus had programs in place to categorize SSCs, monitor the j SSCs against established goals, and evaluate performance of maintenance to i prevent failures of SSCs. Initially,11 systems for power operations had j performance that did not meet established goals and were considered for classification in the category of (a)(1) requiring enhanced monitoring and evaluatio .The licensee developed appropriate corrective action plans for the systems prior to ;

the plant shutdown in 199 '

The licensee applied the maintenance rule to structures through ENG 1.7-147,

" Condition monitoring of Maintenance Rule in Scope Structures", which established baseline conditions based on plant system walkdowns conducted in the 1996. The

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licensee has established a program to complete follow-up walkdowns, with portions done periodically. However, the inspectors noted one discrepancy in how the monitoring program was applied to system pipe supports, which were not included in the structure surveillances. The concern was that base plates for hangers or ,

supports on systems important to safe fuel storage should be monitored to assure that no long term degradation occurs that would adversely affect seismic qualification. The inspectors completed a walkdown of plant systems that support safe fuel storage and noted that most piping supports use welded attachments, and only a few base plate concrete anchors exists. The licensee acknowledged the comment and wrote ACR 98-083 to assure base plates are addresse Proaram Chanoes'for Decommissionina Although CY issued a letter to the NRC on December 6,1996 certifying the permanent cessation of operations, the ma'intenance rule as described in 10 CFR 50.65 applies to those structures, SSCs associated with the storage, control and maintenance of the SFP. The licensee began a series of reviews in 1997 to revise the maintenance program for the list of systems operating in a permanently l

shutdown plant: Phase 1 of the scoping review was completed per EDI 3.46; phase 2 was completed per EDI 3.47; and, the licensee issued the Decommissioning ;

Nuclear Island - Maintenance Rule Manual dated 10/15/97. Based on the 1997 reviews, the licensee concluded that three systems remained in the category of (a)(1) and required monitoring because performance had not met established goals

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(due to maintenance related functional failures as defined in Section 6.2.10 of EDI 3.51): the radiation monitoring, service water, and fire protection systems. The licenseo developed appropriate corrective action plans for these systems and issued i periodic assessment report As of this inspection, the licensee was in the process of performing the third review of plant systems to define which SSCs were covered by the Rule. The scoping reviews were based on the plant system reclassifications, new updated final safety analysis report (UFSAR) and new licensing-design bases for the decommissioning state of the plant. By memorandum CY-TS-98-096,the licensee issued the charter of the reconstituted expert panel and defined the objectives to complete SSC

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scoping, select SSCs important to wet fuel storage, select performance criteria, set goals and monitoring plans, and reinstitute periodic assessment reports. This work was expected to be completed in April 1998. The inspectors will review the maintenance rule implementation upon completion of licensee actions to' revise the program for decommissioning (IFl 98 01-02).

c. Conclusiong The licensee had e.stablished a program to met the requirements of 10 CFR 50.65 during the operations phase of the plant, and was in the process of redefining the program based on the decommissioning status. The progress of this effort was proceeding at an acceptable pace, based on the development of the new licensing design basis and system reclassifications.

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11 I The licensee had implemented SSC monitoring as required by 10CFR50.65(a)(1)and monitored the performance and condition of SSCs against established goals. The program required the implementation of appropriate corrective actions when performance of the SSC did not meet the established goals (e.g., actions taken for the radiation monitoring system (RMS) and diesel generator (DG) fire pumps systems). One area for improvement was the need to assure base plates on systems that support spent fuel cooling were inspected and included in the maintenance rule program. An inspection followup item will track licensee actions to address this are . Soent Fuel Safety E1 Engineering Support of Decommissioning Activities E Facility Modifications (URI 98-01-03 VIO 98-01-04) Insoection Scope (37801. 60851. 60853,37700)

The purpose was to review modification activities that supported spent fuel safet Observations and Findinag The plant modifications listed below were reviewed to verify that: the design

- change activities were implemented in accordance with the licensee controls on the Design Control Manual (DCM) and procedures DCM 1.3-1 and 1.7-1; the safety review process was conducted in accordance with 10 CFR 50.59 and administrative control procedure (ACP) 1.2-2.42; the design control program for procurement and vendor activities was appropriately implemented; and, that onsite construction and fabrication activities were conducted in accordance with the associated DCRs and work package New SFP Coolina Loons

DCR-97015, Spent Fuel Island Phase 1 - Electrical Equipment installation

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DCR-97016, Spent Fuel Island Phase 1 - Engineered Supports and Piping

DCR-97017, Spent Fuel Island Phase 1 - Mechanical Equipment installation

• DCR-97018, Spent Fuel Island Phase 1 - Instrumentation Installation

• DCR-97023, Classification of SFP Support Systems  ;

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DCRs-97015,016,017 and 018 were implemented to install new equipment for the l spent fuel island that would eliminate reliance on the service water, and consolidate SFP support systems. The modifications included the installation of new SFP heat exchanger cooling loops (comprised of redundant intermediate cooling and redundant spray cooling subsystems); new motor control centers MCC-2A and MCC-2B; SFP level and temperature instrumentation; and, the installation of new i radiation monitors (relocating the steam generator blowdown monitors to the spent fuel building). The intermediate cooling (IC) system consists of two closed cooling loops which will pump demineralized water through either of the existing SFP heat l l

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exchangers to the tube side of the cooling coils in the spray coolers, located on the l roof of the spent fuel building truck bay. The cooled water from the cooling coils flows by gravity to the IC surge tanks. The spray cooling (SC) system pumps demineralized water from two spray surge tanks to the spray headers in the spray coolers. Heat would be transferred to the outside air by evaporation on the outside ;

surface of the spray cooler coils; residual water will gravity drain to the spray cooler j surge tank The new IC and SC systems will provide several design enhancemente over the SW system. The licensee used Type 304 stainless steel as the material of construction, which provides significant margins in material strength for the system design parameters of 150 psig and 150 degrees F. The separate and redundant motor control centers eliminate a design vulnerability in the existing (original plant) SFPCS (reference inspection item 96-11-07). The IC and SC systems are composed of two i

100% capacity subsystems. A single subsystem was designed to maintain the SFP i below 125 degree F under design basis outdoor ambient conditions, and below 110 I degrees F for nominal ambient conditions. The use of demineralized water in the SC and IC loops will eliminate the plant vulnerability to microbiologically influenced corrosion (MIC), which was a problem in the SW syste The licensee obtained new vendor supplied, skid-mounted mechanical equipment that was installed in the SFB truck bay and on top of the SFB lower roo Interconnected piping was fabricated and assembled onsite. During this inspection period, the licensee had completed the installation of the major components and skids, which were located and anchored in place. Work to install the piping and conduit runs continued at the end of the inspection. The inspectors verified that the general appearance of skid welds and field welds was good, and that component lay-out, piping interconnections and configuration, skid and MCC anchorages, and pipe support details were as described by the design package One deficiency being addressed by the licensee at the end of the period concemed the initial procurement and installation of the SFP modifications as non-OA i equipment. The early modification activity was based on the licensee's initial conclusions regarding the safety classification of the SFPCS (reference Inspection item 97-09-03). None of the work completed to date affected the existing (operating) SFPCSs. The licensee was finalizing a separate DCR for connecting the new equipment to the installed plant systems. To address the quality of the SFP modifications, the licensee stated that DCR 97-010 was being processed to change the non-QA status to SFPQA, and a nonconformance report (NCR) would be generated to resolve the issues stemming from the initial quality designators for DCRs97-015 through 018. The resolution of the quality issues will be reviewed on a subsequent inspection (URI 98 01-03).

During inspections in January,1998, the licensee described the approach to system classifications as provided in draft DCR 97-023. Initially, the licensee proposed to declassify the categories for the spent fuel coodng system, service water system, and emergency diesel generators from QA ta n',n-QA. Following NRC reviews, the licensee revised the DCR to (1) define the pressure boundary portions of the SFPCS

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necessary to maintain water inventory within the SFP as QA Category I; (ii)

reclassify active functions of the SFPCS (forced flow) to SFPQA; (iii) reclassify the remaining portions of the SW system from QA Category I to SFPOA; (iv) reclassify the emergency diesel generators and the support systems from QA Category I to SFPQA, and eliminate the requirement for automatic > . art and load sequencing; and, (v) remove the requirements for the maintenance of train redundancy and separation within the above systems, although backups for major active mechanical components would be maintained. The licensee established a graded QA program for equipment which performs the important function of maintaining spent fuel cooling, and defined the requirem.ents for SFPQA in ACP 1.2-2-86, " Spent Fuel Pool Quality Assurance Program".

As part of the basis in DCR 97-023 to declassify the SFPCS, the licensee developed a strategy that would cool the pool through evaporative cooling by opening the SFB doors and a roof hatch. Licensee calculations showed this strategy would limit pool te.nperature to 170 degrees F. While the strategy would limit the thermal transient and preserve margins to concrete structural limits, that objective would be achieved as a trade off for the safety objective to preserve spent fuel building filtration, closure and source term confinement. This matter requires furthsr NRC revie NRC review of the licensee's classifications for the SFP and support system (DCR 97-023) as well as the installation of the SFP modifications (design change process and physical work) continued at the conclusion of the inspection. Inspection item 97-09-03 will continue to track NRC review of the adequacy of actions to classify the SFPCS and support system New Seismic Monitorina System GMS)

DCR-97019, Replacement and Upgrade of Seismic Monitoring System DCR-97019 was implemented to replace the inoperable and outdated seismic monitoring equipment (reference inspection 97-05, Section M1.1). Although partially functional, the original seismic monitor was inoperable per the TSs (TS 3.3.3.3 entered July 8,1997) and rould not be repaired because of outdated equipment and the lack of spare parts for the non-functional SMR-102 Playback System. As part of the DCR 97-019 changes, the following components were replaced with new components (reference AWO 98-293):the DCA 300 Digital Cassette Accelerograph; the RSA-50 Response Spectrum Analyzer; and, the SMR-102 Playback System. Portions of the original equipment, the SSA-300 Triaxial Servo Accelerometer and the SWP 300 Seismic Warning Panel, remained installed and were used with the new syste The new components consisted of a GSR-12 Strong Motion Recorder (without sensor). Data analysis, plotting and alarm systems were provided with a laptop computet and printer. All new components were bolted into the 19 inch racks that housed the old equipment. The SSA 302 accelerometer remained installed in the cable vault and was connected to the GSR-12. The new components performed all the functions and data analysis of the old equipment (response spectra

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accelerations), plus provided the calculated cumulative absolute velocities to assist in a seismic event analysis. The inspectors reviewed the design change package, and the installation and testing of the new equipment, which was made functional (but not operable) on March 5,1998. The design package identified the procedure changes and training to be completed. Upon completion of the modifications and testing, the licensee was prepared to return the new seismic modification system to service. NRC review identified the following discrepanc The licensee completed a 10 CFR 50.59 applicability review for the seismic monitoring system replacement and upgrade in accordance with the requirements of ACP 1.2-2.42. This evaluation incorrectf / concluded that the proposed change did ;

not require a change to the operating license or TSs, as shown by the "NO" !

response to Question 4 of screening form. However, that conclusion was not supported by the basis for the ;6sponse, which Indicated that the system 1 components currently in TS Tables 3.3-5 and 4.3-4 will require revision. Since the changes to the SMS did not change the function of the system or the required surveillances, the licensee concluded that the changes to the TSs could be made at a later time, and proposed to issue a TS Clarification to document the modification ,

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UFSAR Section 3.7.4 describes the seismic monitoring instrumentation at Haddam Neck, which includes the RSA-50 response spectrum analyzer. TS 3.3.3.3 requires the instrumentation listed in TS 3.3-5 to be operable "at all times"; operability is not contingent upon the reactor operational mode. The inspectors informed that licensee that, since the DCR 97-019 modifications changed the physical systems as described in the specifications, literal compliance with the TSs could not be achieved as described in Amendment No.- 125 issued on April 26 1990. The licensee should have processed a proposed TS change in parallel with the development of the DCR 97-019 modifications. The failure to recognize that modifications which changed the facility as described in TS Table 3.3 5 required prior NRC approval was an example of an inadequate safety evaluation, and a violation of 10 CFR 50.59 (VIO 98-01-04). The inadequate 50.59 review placed the plant in violation of TS 3.3.3 with the new seismic monitcring equipment installed. The licensee issued ACR 98-208 on March D ' 998 in response to the NRC findings and to address the untimely development of a TS change reques Some mitigating factors were apparent for this issue. The newly installed components added functionality to the SMS, which had remained inoperable since July 8,1997 due to failed equipraent (reference CY letter CY-97-08 dated August 14,1997). Further, the licensee had planned to revise the TSs in a future submittal to the NRC. Proposed TS change request PTSCR C~4-97 was written in September 1997, but was not processed. Instead, on October 22,1997 the TS 3.3-5 changes were added to a larger package of proposed revisions in PTSCR C-3 97, which would have moved the SMS requirements to the technical requirements manual, as suggested by Generic Letter 95-10. Based on the above, and since the SMS provided an alarm function only, the safety ignificance of the specific violation was lo . i I

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The licensee reviewed the 50.59 screening for DCR 97-019 and concluded that the i

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newly revised process, if followed correctly, would have precluded the violatio Thus, no new programmatic concerns were identified. Nonetheless, the above findings are examples of continued weaknesses in the 50.59 screening process and the process to maintain the licensing basis.

l Conclusiqns Generally acceptable engineering support was noted in the modifications to provide new cooling systems for the SFP, and to replace outdated seismic monitoring i instruments. Areas for improvement included the designation of quality assurance j indicators for systems that support spent fuel cooling, and the application of appropriate GA controls for SFP-related modifications. An NRC identified violation indicated continued weaknesses in licensee 10 CFR 50.59 reviews and the process

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to maintain the licensing basis, a l 1 E8 Miscellaneous Engineering issues l E Review of LERs and Teleohonic Notifications

. a. Insoection Scope (92700. 90712)

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The purpose was to review prompt reports and licensee event reports (LERs) to verify the requirements of 10 CFR 50.72 and 50.73 were me b. Observations and Findinos LER 97-19, Compensatory Sampling Frequency Exceeded With Radiation Monitoring Systems Inoperable - (Adequacy of compensatory actions was described in IR 50-213/97-01, Section R2.1) Event period from 2/6/97 to 7/1/97, not reviewed until 7/28/9 Determined reportable on 8/8/97, but not reported until 11/17/97. Although timeliness of reporting the issue is a concem, the evaluation and corrective actions are acceptabl LER 97-20 Radioactive Effluent Dose Calculations Not Performed Within Required Frequency - Similar to LER 97-19; procedure, personnel training, and improved surveillance tracking were revised to improve adherence to required frequencies in effluent / chemistry program. Review and actions are acceptabl Conclusions l Licensee reporting of events was generally acceptable. The LERs listed above are closed.

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'E Enforcement Follow-uo - Manaaement Desian and Corrective Actions Insoection Sea,c.#2702)

The purpose was to continue the review of the licensee corrective actions for the enforcement action issued on May 12,1997. This review also covered the licensee actions committed to in response to the NRC Request for Information under 10 CFR

50.54(f), which addressed many issues similar to those subject to the enforcement j actio l l

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' Observations and Findinos i

The NRC issued a Notice of Violation and Proposed imposition of Civil Penalty based l on numerous inspections to review several facets of Haddam Neck performanc i The inspections included a special team inspection which iocused on engineering and licensing performance (96-201); a special Augmented Inspection Team (AIT) ,

inspection of the reactor vessel nitrogen intrusion event in September 1996 (96-80); !

an emergency preparedness (EP) inspection to reviaw the conduct of the emergency l exercise in August 1996 (96-07); and several resident inspections (95-27,96-06, !

96-08, and 98-11).

( The violations were grouped into broad categories that included inadequacies in- !

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engineering programs and practices; operational deficiencies, including inadequate procedures and the failure to follow procedures; inadequate implementation of the EP program; and, numerous deficiencies in the corrective action program. The

, licensee responded to the enforcement action by letter dated June 11,1997 (CY-l 97-059), and supplemented the response by letter dated September 30,1997 (CY-

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97-93) to describe the corrective actions taken and the schedule for completing the

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actions to prevent recurrence. The review of actions taken to address specific issues cited in the May 12,1997 escalated enforcement is described in Attachment A of this report. NRC review of licensee corrective actions to address programmatic deficiencies were described in inspections 97-03 and 97-05, and are discussed further below.

i Enaineerina Proarams and Practices l 'In the June 11,1997 response, the licensee described the actions to address i

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weaknesses in the processes for safety evaluations, UFSAR updates, safety classification, instrument setpoints and procurement engineering. The corrective actions addressed the common causes for the process deficiencies by upgrading the licensing and basis (LDB) Information, the design control process, the configuration management process, resource management, training, and by setting new management standards and expectations. These actions supplemented those described in the licensee letters dated June 28,1996, September 13,1996, February 6,1997, and in the December 24,1997 response to the NRC's Request for Information under 10 CFR 50.54(f). The licensee developed a configuration management plan (CMP), which initially addressed erm er operations, and then was revised to address decommissioning.

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The objective of the CMP was to provide assurance that the plant would be decommissioned in accordance with the terms and conditions of the operating license. The CMP issued initially in May 1996 and revised periodically thereafter, l together with the Decommissioning Project Manual, issued in May 1997, provided L for the following to meet the objectives:

Identified 13,500 licensing commitments, with 2080 applicable to

! decommissioning. A commitments database was created and used to verify plant design, procedures, programs and processes were as reflected in the

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license. The licensee used department instruction LDI 2.02, Defueled Condition Commitment Screening, to assure future implementation of the l licensing commitments, and identified procedure steps to be protected as l commitments. The action to change the associated procedures was in progress and was tracked as a key performance indicator (KPI). As of April l 1,1998, there were 1333 commitments remaining to be verified. The l licensee stated this action would be completed by July,199 *

For the structures, SSCs required to support the defueled condition, the defueled licensing and design basis was identified and verified. The desig basis review included design changes, design basis documentation packages, l calculations, drawings, specifications, and vendor information. The l verification of the plant configuration included walkdowns of the plant, and a j review of operating, maintenance, and surveillance procedure *

The UFSAR Chapter 15 accident analyses and TSs were revised to identify SSCs required to support the defueled condition. This included the development of new calculations for the SFP heatup (SFP-97-1575-DY), fuel l handling accidents (XX-XXX-60-RA), and a dose assessment of a postulated l resin fire (CYRESIN-01578-RY). The accident analysis results were l

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submitted the NRC per 10 CFR 50.90 by letter dated May 30,1997 in support of the Defueled Operating License and TSs. NRC review of the 3 proposed defueled TSs continued at the end of this inspectio I

• The revised accident analyses also supported propoced revisions to the physical security plan described in a letter to the NRC dated May 30,1997 (CY 97-039), and proposed revisions to the EP plan, described in a letter to the NRC dated May 30,1997 (CY 97-047). The latter reference also was a ;

request for an exemption from 10 CFR 50.54(q) for offsite response as part of emergency planning. NRC review of the proposed security and emergency plans was in progress at the end of this inspection, and included an independent analysis of the SFP heatup calculations to determine the susceptibility of the pool to a postulated zircaloy fir * The Design Control Manual was issued on September 12,1997 with

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revisions to ensure the engineering processes maintain configuration control and preserve the LD8 and licensing commitments. The program addresses policies, design change activities, decommissioning work packages, design inputs and design verification, calculations, specifications, drawing control

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and vendor interfaces. The revised program contained linkages to assure that once one document was changed, all other corresponding documents were changed or subsequently updated. The licensee implemented several design change records under the new manual. NRC review of several DCRs (97-015,016,017,018 and 019)is descrited in Section E1.1 of this report, and remained in progress at the end of this inspectio *

The licensee issued Revision 7 to NTM-7.202, Nuclear Training Manual on Octob;r 6,1997 to assure quality and consistency in the implementation of training and qualification of engineering support personnel. The training program covered topics in LDB, UFSAR, safety evaluations, MEPL classifications, and corrective actions and root cause determinations. NRC review of the revised process and training for conducting safety evaluations per 10 CFR 50.59 was previously described in Inspection 97-0 *

The UFSAR was revised to correct deficiencies applicable to SSCs and programs required to support the defueled condition. The revised UFSAR, Change No. 30, was submitted to the NRC by letter dated January 26, 1998 (NL/CY-98-011). NRC review of the UFSAR was in progress at the end of this inspectio *

The defueled condition licensing and design bases was reformatted in a new-Design Basis Document issued on 2/12/98. The spent fuel storage LDB described the systems (13) and programs needed to support safe storage of the fuel. The licensee completed an independent review of the LDBD, as described in the XWest Group report, " Independent Third Party Review of the Defueled Licensing and Design Basis at Connecticut Yankee Atomic Power Company," dated October 16,1997. The open issues for the independent review were being resolved, and were scheduled to be j

completed by June 1998. NRC review of the LDB was in progress at the !

end of this inspectio In summary, the NRC review confirmed that licensee had taken the actions committed to in his response to the May 1997 enforcement action and the 10 CFR 50.54(f) letter. In the December 24,1997 !stter, the licensee described the actions that were still in progress to address the management issues described in the May 1997 enforcement and the 50.54 (f) actions. The licensee planned to provide a final response to the 10 CFR 50.54(f) issues in the third quarter of 1998. Several

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discrepancies noted recently ndicate some weaknesses in the licensee actions to improve station practices and programs (discrepancy in the DCR for the seismic monitor, discrepancies related to the declassification of systems for the nuclear island). However, NRC review remains in progress to verify the adequacy of the new programs and process, and confirm the effectiveness of the corrective actions j to address past performance weaknesse !

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Operations Procedures and Practices - Violations from Nitroaen Intrusion Event The corrective actions to address the causas for violations stemming from the nitrogen intrusion event were based on the Independent Review Team report dated !

l October 23,1996. The corrective actions were described in the December 4,1996 )

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enforcement conference and addressed weaknesses in the broad areas of deficient {

material conditions, inadequate procedures, operator performance and management j

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performance. Licensee actions were taken prior to the resumption of core offlood I l

activities. NRC review of these corrective actions were taken in November 1996 to verify the licensee plans and preparations to offload the core (reference Inspection 97-11, Sections 01.3, O2.1, O3.1, and 05.2).

l For long term corrective actions, the licensee took additional actions in the areas of plant procedures and personnel performance. The licensee addressed personnel .j performance station wide through the development of standards and core values at !

the department level. This action was completed in June 1997. Subsequant NRC concerns with personnel performance deficiencies were described in Inspections 97-01 and 97-03. In response to NRC findings and the results of the trend report for the first two quarters of 1997, the licensee completed a common cause evaluation to determine the underlying reasons for personnel errors (Inspection 97-05, Section 04.1) and monitored performance as a KPl. The Common Cause Report for ACR 97-0444, dated September 5,1997, recommended four corrective actions to address weaknesses in work practices, communications, supervisory methods an written documents. The recommendations included the communication of the lessons learned, a re-emphasis on the STAR process as a self-checking tool, and the

! use of the work observation program. The work observation process was initiated in the Fall of 1997, and achieved a 100% level of participation in the Spring of 1998. Some improvement in the rates of personnel errors were noted in the 3rd j and 4th quarters of 1997 which continued in an improved trend plant-wide, but l several departments continued to need attention (e.g., operations and chemistry).

The NRC follow-up of this concern continued at the end of the inspectio ,

After upgrading procedures in the Fall of 1996 to complete core offload, the license continued to take actions to rewrite procedures to reflect the decommissioning

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status of the plant. Additional NRC concerns in this area were identified (Inspection l

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ltem 97-05-02)regarding the need to eliminate references to power operations in currently active operations emergency and abnormal operating procedures. In response, the licensee developed a listing of procedures in each category needing revision, and initiated periodic trend r'. ports to show progress. The effort is scheduled to be completed in June,1998. Inspection item 97-OS-02 remains open and will track NRC concerns in this are Emeraency Preparedness Proaram Licensee actions to address EP program deficiencies were previously reviewed and found satisfactory (reference Inspection 97-03). This included actions to train personnel and improve making event classifications (Item 96-07-01), and to improve the development of protective action recommendations and providing them to

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offsite authorities (Item 96-07-02). The licensee installed a dedicated telephone line from the Director of Site Operations to the Connecticut emergency operations center (Item 96-07-04), and tested this link during a Millstone emergency plan exercise on June 19,199 Finally, the licensee addressed the exercise weakness in the staging and deployment of extra staff (Item 96-07-03). The actions to correct this deficiency was demonstrated to be effective as noted in the conduct of the training drills (reference Inspection 97-09 and Section P1.1 below). The final NRC review will be completed during the inspection of the DERO exercise scheduled for August 199 The licensee implemented corrective actions as described in the June 11,1996 lette Corrective Action Proaram The programmatic causes of the deficiencies the corrective actions program (CAP)

were identified in the Common Cause Study issued in December 1996, and discussed in the Enforcement Conference on December 4,1996. The licensee implemented changes to improve the CAP, as described in inspections 97-03 and 97-05. Following the implementation of the program changes, the licensee completed the following actions as defined the June 11,1997 response letter:

.The licensee completed an independent assessment of the CAP, which was issued in a contractor's " Independent Review" report dated November 25, 199 *

The licensee completed a bench marking of the Haddam Neck program against plants with high NRC assessment ratings that were determined to have a good corrective action program. The bench marking analysis was issued in memorandum CYCA 97-0071 dated December 11,199 The licensee implemented changes and recommendations made as a result of the above efforts, which were reflected in an ACR upgrade process described in memorandum CYCA 98-002 dated January 19,1998. Licensee action to address the recommendations were in progress at the conclusion of this inspection and the items designated Priority 1 and Priority 2 were scheduled to be completed by the second quader of 199 Routine inspector observations of the CAP demonstrated that the licensee implemented actions committed to the June 11,1997 response. The improvements in the Haddam Neck CAP were evident in the administration of the ACR process, which provided for timely identification, review, assessment for significance, and follow-up of adverse conditions. ACRs records were well organized and readily retrievable. The past ACRs were trended, with assessments described in the quarterly trend reports. The inspectors noted generally good performance by the Management Review Team (MRT) to assess deficiencies, assign appropriate corrective actions, and to track performance and the adequacy of

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corrective actions. The KPis provided an effective tool for management to identify and track performance trend While generalimprovement has been noted, there were examples of repetitive events, which suggest that corrective actions were not always timely or effectiv Examples include repeat events involving security equipment failures, problems with effluent releases, and human performance errors. There were examples of significant adverse conditions, as evident in the two recent events classified by the licensee as level B. Finally, there were a relatively large number of ACRs assessed as Level C, which are indicative of deficiencies in HN processes and procedure NRC review of this area continued at the end of the inspection perio Conclusions This inspection verified that the licensee took actions as described in the June 11, 1997 response to address weaknesses in engineering, EP operational problems and the CAP. - NRC review of this area to determine the effectiveness of the co.rrective actions continued at the end of this inspection perio E8.3 Status of Previous Insoection items (Ocen) Unresolved item 97-05-04: SFP Leakage. This item was open pending the licensee development and NRC review, of a leakage monitoring program for the spent fuel pit. The licensee monitored SFP leakage via routine samples of water collected in the standpipe on the southeast corner of the pool. The water samples were analyzed and trended. The licensee concluded that, while some anomalies in boron and cesium ratios occurred, the water collected from the standpipe was leakage from the SFP. The amount collected varied considerably depending on the season, and ranged from nothing to several thousand milliters per month. The recent sample in April 1997 collected 3300 mi from the standpipe, which was more than the amount collected for all of 1997 (reference ACR 98-266). Licensee review i of the status of the SFP liner continued at the end of this inspection period. This l item remains open pending the completion of the licensee's assessment of the SFP ,

and subsequent review by the NR '

111. Plant Suonort and Radioloalcal Controls R1 Radiological Surveys and Contamination Control R1.1 Offsite Radiation Survevs and Remediation Planning

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i Insoection Scooe (83726)

'The purpose was to continue the review of licensee radiation and contamination surveys at private residences and properties located offsite that had received cement blocks or other material from Haddam Neck plant in the past. The inspectors reviewed the planning for remediation of offsite locations with j radioactive material.

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Observations and Findinas l

. Inspection item 97-09-04 was open pending NRC review of the licensee actions to identify and survey offsite areas that received soils, concrete blocks and other potentially contaminated equipment from the plant, and to recover contaminated i materials for proper disposal as radwaste. Inspections 97-09 and 97-10 describe past NRC reviews in this area and describe the approach taken to investigate offsite areas, establish a scoping survey plan and method, and to expedite removal of I

material with plant related radioactivity. The methods continued in use during the -

present inspection. Additional NRC reviews of similar concerns in the control of radioactive materials was reported in inspections 97-07 and 97-0 The following activities occurred during this inspection period to verify that licensee effectively controlled radioactive materials, and performed adequate survey (1) Soil samples obtained from publicly accessible areas on site and from offsite properties were split with the licensee and analyzed at the NRC Radiation Laboratory in King of Prussia, Pennsylvania. The results from three locations are provided in Table I of this report. The data did not show any licensed related material at any of the areas, and the NRC and licensee results compared favorabl (2) The NRC Radiation Laboratory in King of Prussia, Pennsylvania also completed an analysis of potable water samples obtained from private residences in the Haddam Neck area. The analysis results did not show any plant related activit (3) The licensee continued to survey materials and equipment located offsite in an effort to identify material that may have been released with residual radioactive contamination. The surveys were being performed in accordance with the licensee's radiological survey action plan. As of April 7,1998, the

licensee had curveyed approximately 50 of the 90 total offsite locations with potential radioactive material. Of the 50 locations surveyed,13 locations were identified with positive radioactive contamination. The surveys included 4611 concrete blocks at various locations.132 blocks were found to have some low levels of radioactive contamination and 142 blocks had been returned to the licensee's sit (4) The licensee recognized the need to expand the offsite surveys to include miscellaneous plant related materials in addition to the blocks. A letter was issued to present and former plant workers on February 3,1998 to request assistance to identify and complete a radiological assessment of surplus !

equipment and materials released from the site. As responses to the request l were received, the property locations were added to the tracking system for review and evaluation. This work continued at the end of the inspectio (5) The licensee prepared a generic remediation plan and specific plans for each affected location. The inspectors discussed general technical issues with the I

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licensee's staff during the preparation of the generic remediation pla However, the remediation of the offsite areas remained an unresolved item pending the NRC review of the final generic remediation plans, observation !

of remediation work, and inspection of the site sampling processe s NRC and representatives from the Connecticut Department of Environmental l Protection (DEP) reviewed licensee remediation plans during meetings e.nJ/or l l telephone conferences on January 20, February 11, March 3 and March 25, l 1998. The items discussed included remediation plans, instrumentation, survey methods, and minimum levels of detection. The NRC also  !

commented on proposed remediation plans for Locations 9608 and 962 f i

(6) On March 24, the NRC issued a letter to CY providing feedback on the draft i remediation plans, and listing criteria NRC found acceptable for remediatio The NRC endorsed the environmentallower limit of detection (LLDs)

recognized in the license, but upheld the position that if any party identified the presence of licensed radioactive materials, the licensee would have to treat the material as radioactive waste and dispose of it at an approved l waste disposal site. The NRC requested the licensee to respond within 30 {

days to submit final plans and schedules for offsite remediatio j NRC review of all sites was in progress at the conclusion of the inspection. Item 97-09-04 remains unresolved pending the completion of the licensee actions to identify and recover all locations with concrete block Conclusions Licensee activities this period were good 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 thorough to assecs the present radiological conditions. NRC review of licensee actions to assess and remediate the offsite areas continued at the end c,/ the inspectio R1.2 Radiolooical Contro!s (URI 98-01-05) Insoection Scone (83750) l The inspectors toured the radiological controlled area, reviewed radiological controls for the work on the RWST, observed the characterization work for the onsite buried objects, and noted the licensee's identification and corrective actions associated l

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with potentially inappropriate air sample filter )

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l 24 l Findinas and Observations Radioloaical Controls-General The inspectors found the radiological controls; including posting and labeling of radioactive materials, contamination coritrols, barriers for high radiation areas, information regarding dose rates in work areas, and access control to radioactive materials; were generally very goo b.2 Characterization Work for Onsite Burig.d Objects Through the investigation process for identification of potentially contaminated l- areas of the site, the licensee's staff interviewed former and present workers

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regarding their knowledge of areas that may have been contaminated in the past.

! The interviews revealed there were unconfirmed stories regarding the burial of l radioactive waste drums on the east side of the protected area (pal of the site, across from the Fuel Building and the Radwsste Reduction Facility in the vicinity of l two storage tanks.

l l As a follow-up to the unconfirmed information, the licensee procured the services of L a vendor to perform ground penetrating radar (GPR) readings in the suspected area.

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' The vendor performed the readings on at least two separate occasions and found some evidence of three buried objects in the suspected area. However, the radar results were not conclusive, so the licensee performed limited characterization surveys of the are Based on the radar results, three locations were selected for radiation measurements, hand drilling, and soil analys'is for radioactive content. The l licensee's site characterization team performed the work in the area with hand tools

! and were extremely careful to minimize the spread of potential contamination. Only ,

minor fluctuations in the background radiation levels were observed as the measurements were taken at various depths in the newly dug holes down to a maximum depth of approximately 6 feet. There were no objects found except for some hard, rock-like areas. Soll sample analysis indicated minor radioactive

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contamination that was consistent with known spills in the area in the past. The

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licensee concluded there was no immediate risk to the environmsnt from any buried

! objects due to leaks or degradation because the amounts of radioactive material and dose rate measurements were 10w. Although the results were not conclusive that drums were buried in the area, the licensee's staff planned to add the potential for buried objects in their site characterization file so that the area would be assassed again during the site remediatio The inspectors noted that the licensee's staff reacted appropriately to the unconfirmed informatica and gathered important information for the final remediation of the site. The measurements and dose rate readings taken were adequate to characterize the area for future site remediation. Excellent radiological controls were taken to prevent the spread of potential contamination during the characterization vor .

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25 i b.3 RWST Work l

In December 1997, the licensee completed the removal of 300,000 gallons of water j from the RWST so that repairs could be made to the tank floor. The dewatering '

project involved some deccntamination of the tank floor and a robot was used to I

scrub and vacuum the tank floor. The robot also had a video camera so the work could be observed , remotely and a radiation detector to obtain dose rate informatio The total dose for the tank dewatering was 0.367 Person-Rem.

l The inspectors observed the planning for the repair of the RWST floor. The l

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planning included all major work groups and included a walkdown of the job prior to fne start of work. Most steps of the job were discussed in very good detail and many things were changed based on input from workers. However, the inspectors noted that the planning did not include an actual practice of the job (run-through)

outside the tank with mock-ups. This could have helped identify a few more problems that developed during the actual work in the tank. Not all equiprnent was j

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tested prior to the start of work, and problems were experienced with the applicators that may have been identified in test runs.

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l E A pre-job briefing was held immediately prior to start of work in the tank on )

l- February 12,'1998. Radiological and occupational safety items were reviewed with j j people working on the job. The pre-job briefing was very detailed and had good a participation from all work groups. A high level of management support was i evident by the attendance of the Unit Director Radiological conditions were l presented with ample opportunity for questions or discussion. Information was i current and included the latest radiological survey data from the pre-work surveys ano previous entries into the RWST. Some minor changes resulted from the j discussion Radiological controls during the work were observed by the inspectors on February 12 and 13,1998. Overall, the controls were very successful with minimal contamination of workers. Dose to workers was monitored and maintained as low as reasonably achievable. Radiation protection technicians adequately supported the workers with dose rate measurements, contamination surveys of people and

, items, assistance to workers at step-off pads, hot particle controls, exposure j monitoring, respiratory protection (supplied air hoods were used), bioassay, and

!- contamination controls. Although the total dose (0.658 Person-Rem) for the job was higher than estimated (0.275 Person-Rem), this was due to work taking longer than expected. There were many reasons the job took longer than expected, I including items not identified in the planning process and problems encountered with equipment. Engineered controls were used successfully to minimize the release of radioactive materials to the environment, but several minor items were

! raised as a concern by the inspectors that the licensee's staff had not identifie These items included the condition of the HEPA discharge hose, the use of a quantitative measurement to verify positive flow into the tank at the manhole, and DOP test dates not posted on the HEPA unit ,

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! 26 The Scensee's staff held a post-job critique that included all the major work groups involved with the job. Although this particular work may not be performed again, p

' the areas for improvement may be applie.d to other jobs in the future. Some areas l

1 for improvement included communications, planning / preparation, safety, procedure adequacy, training, use of mock-ups, radiological controls, and total exposure higher than estimate b.4 Air Samole Filters in February 1998, the licensee's staff identified that the air sample filters used for personnel air sampling and area air sampling were specified with a 3 micron membrane hole size (Gelman 3000T). A smaller membrane hole size, ranging from 0.3 to 0.5 micron, is typical for collection and monitoring of airborne radioactive particulate. The licensee's staff contacted the manufacturer (Gelman Sciences) to ,

obtain more information regarding the physical characteristics (retention capability j

and self adsorption). The manufacturer's technical representatives stated that the filter was made for filtration of particles in water, not air. The manufacturer further stated that, although the water filters had been used by other customers in the past for airborne particulate sampling, there were no specifications for this type of filter for use in the collection of airborne particulat i L The filters were believed to have been used approximately 10 years for general area

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and personnel air sampling. A search of historical records did not produce any l l

documentation or technical review on the use of the water filters. The licensee's staff determined that the use of the filters for air sampling was an adverse condition

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since there was no documentation of the retention efficiency. An ACR was written l describing the situation. The ACR included immediate (initial) corrective actions

! taken after the situation was identified and long term (follow-up) corrective action recommendation The immediate corrective actions included a review of ali work in progress for areas with potential airborne radioactivity to ensure that the air sampling was not currently in use, issuance of a standing order to all health physics technicians to stop the use of the Gelman 3000T filters until further notice, initiation of a technical

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review to determine the appropriate use of the Gelman 3000T filters, verification of the health physics procedure regarding use of other air sample filters, and arrangements for an expedited delivery of air sample filters from Millstone that had j been verified to be acceptable for airborne particulat Recommended follow-up corrective actions included a determination of the retention capabilities of the Gelman 3000T filter for collection of airborne particulate and an assessment of the impact on using the Gelman 3000T filters for the collection of general and personnel air samples over the past ten year The licensee's staff initiated a laboratory analysis of the retention capabilities of the

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Gelman 3000T filter for the collection of airborne particulate. After the analysis is complete, a historical review will be conducted to assess the need for changes to internal dose assessments and assignments ,made from air sample result _

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The inspectors noted that the potential problem with the air sample filters was an example of good self-identification by the licensee's staff. However, the use of the air sample filters for airborne particulate without documented specifications extended over a very long period of time (about ten years) without being identifie The inspectors found that the use of the adverse condition reporting system was appropriate and will allow the licensee's staff to track the corrective actions through completion. This is an unresolved item pending the results of the laboratory analysis and licensee's review of the previous dose assessments. (URI 98-01-05) Conclusions The licensee provided good radiological controls for the RWST work and general plant activities. The site characterization work performed for the unidentified buried objects was appropriate with excellent radiological controls. Response by the licensee's staff after the identification of a potential problem with the air sample filters was also appropriate and will be further reviewed by the NRC staff after l follow-up corrective actions are completed.

l S1 Conduct of Security and Safeguards Activities l

S Review of Security Activities Inspection Scope (81700)

l The purpose was to determine whether the conduct of security activities met the licensee commitments in the areas of: vital area access control; security lighting; and, PA access control of personnel, packages and material, and vehicles, b. Observations and Findinas The inspectors observed operations at the personnel access portal at various times during the inspection. Positive controls were in place to ensure only authorized individuals were granted access to the PA. The inspectors observed security force operations at the vehicle entry point including verification of authorization and performance of vehicle searches prior to entry into the PA. All personnel, materials k and hand carried items entering the PA were properly searche i The inspectors observed the authorization and access control for plant vital areas,

! including the use of compensatory measures during periods of off normal l conditions. Positive controls were in place to ensure only authorized individuals were granted access to the vital area.

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E Security Liahtina l During a tour of the PA during backshift hours, the inspectors questioned the adequacy of security lighting, particularly in an area north of the containment building. In response, the licensee completed a security lighting survey on March ,

29,1998. The results showed all areas exceeded the acceptance criteria of 0.2 ft j i

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candleu, with the exception of one location on the north end of the PA; the licensee added additionallighting. The area initially questioned by the inspectors was acceptabl Conclusions The licensee conducted security activities in a manner that protected public health and safety and met the licensee's commitment S1.2 Loss of Security Eauioment Inspection Scoce (71750)

The purpose was to review the licensee response to a loss of security equipment on March 6,199 Observations and Findinas The plant experienced a loss of security equipment at 8:38 a.m. on March 6,1998, which affected the ability to monitor the status of plant security. The licensee

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implemented security procedure SCP 1.8-18 and established compensatory measures. There was no loss of security effectiveness. The licensee's response was in accordance with the procedure. The security system failures were described in ACR 98-170. 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 and testing were completed at 2:44 a.m. on March 7,199 Inspection item 97-09-05 identified NRC concerns regarding licensee's actions to identify and resolve the causes of the recurrent security equipment failures, due to the repetitive failure of the same security equipment on December 31,1997 and on Juna 13,1997 (Inspection 97-09 and ACR 98-M, and Inspection 97-03 and ACRs97-299 to 301). The repeat failures showed tom .he corrective actions for the past events were not effective. Licensee investigations following the latest failure identified a suspect component that would have caused the past events. Repairs were completed and security equipment subsequently performed satisfactorily, inspection item 97-09-05 will remain open pending the NRC review of the adequacy of licensee actions to resolve this issu ! Conclusiqng EqH,, ment failure challenged normal security functions on March 6. The security

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fo/c J respon9e was good to set up and maintain compensatory measures. Past cwective actions were insufficient to prevent recurrent event {

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P *.' Conduct of EP Activities P Defueled Emeraency Plannino Drill Insoection Scoce The purpose was to review the licensee's conduct and evaluation of the defueled EP drill.

i Observations and Findinas On March 25, the NRC observed the licensee conduct a combined functional dril l The inspectors reviewed activation and augmentation of the emergency response c7anizations and the activities within the emergency response facilities. Specific ,

=ti rities evaluated included those in the control room, and the technical support i cen2er (TSC). The simulated scenario concerned a postulated resin spill and fir'e, ;

v,;th the outdoor release of the radioactive source term. An Alert emergency was properly declared by the Operations Shift Manager and the TSC was activated in a timely manner with adequate numbers of support staff needed to perform emergency plan function Overall, the performance by licensee drill players and evaluators was very goo l The licensee demonstrated that the defueled emergency plan and procedures !

worked through the fulfillment of several drill objectives, and that the plant 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. The licensee i exercise critique on March 26 was thorough and self-critical. NRC observations '

were consistent with licensee evaluations. The drill objectives were me c. Conclusiom Good performance wa,s noted in the conduct and evaluation of a drill using new implementing procedures for the defueled emergency pla IV. Facility Manaaement and Control F6 Facility Organization and Administration F Continaency Staffino Plans - Union Neootiations Inspection Scope (36801,92709)

The purpose was to review the licensee plans to assure acuate staffing during periods of union negotiations and during adverse site conditions caused by severe weathe \

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30 Observations and Findinas Union Neootiation Continaency Plans (IP 92709)

Plant security officers are represented by the United Plant Guard Workers of America (UPGWA) Union, Local 538. The UPGWA contract expired on January 31, t 998. The International Brotherhood.of Electrical Workers (IBEW) Union, Local 455, ,

represented plant workers. The IBEW contract expired on December 31,199 Prior to expiration, the licensee and the IBEW union agreed to extend the existing contract, initially until February 28,1998, and then to March 14,199 The licensee and Burns International Security Services prepared plans to promote ratification of a new contracts, and to implement contingency measures in the event of a job action. The inspectors reviewed the licensee's plans to meet the minimum shift complement for security and plant operating staff requirements. The licensee kept the resident inspector informed of the contract negotiations and the planning status.' The plans assured there would be an adequate number of guards and workers on each shift to meet lice;nse conditions for operator, fire brigade and support staffing, and to implement the security plan. No inadequacies were identified regarding the contingency plan A new one year contract was ratified by the UPGWA union on January 23,199 Following two agreements to extend the existing contract by one week during ongoing negotiations, the IBEW Local Union 455 ratified a new contract on March 12,1998. The new contract expires on February 28,199 Continaency Staffina Durina Adverse Site Conditions The inspectors reviewed the licensee plans and actions to assure adequate station manning during periods when storms or severe weather created adverse conditions at the site. The. review also considered staffing by the security force, and the measures to assure continued fitness for duty during periods of excessive overtim Licensee controls during the period of interest were provided in procedures emergency plan implementing procedure (EPIP) 1.5-56, Severe Weather or Loss of Above Ground EDG Fuel Tank, and NGP 1.09, Station Work Hours, on the use and control of overtime. Because of the limitations provided by single site access road (Injun Hollow Road), the licensee's plan in the event of conditions that limit site access, was to assemble extra staff at the site with provisions for food and rest through the duration of the event. Thus, double the normal shift complement would be brought to the site to staff all the required minimum shift positions for operators, guards, and technicians. The staff would be split into two shifts and placed on rotating four hour shifts. The four hour break periods would be spent at the Energy Information Center, where accommodations had been established for sleeping, hot meals and recreatio The inspectors reviewed implementation of the contingency measures for three times when storms threatened the site on 3/13/93,1/8/95, and 1/8/98. The work

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hours for the onsite contingency staff required the use of extensive overtime. The overtime was reviewed and approved in accordance with the NGP 1.09 requirements'(e.g., the January 12,1996 approval of excess overtime for security personnel). The licensee controls rely on the communication between supervisors j and workers to assure respon:,e personnel remain olert after excessive work hour The licensee stated that personnel could adjust work schedules when the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> l break period did not provide sufficient rest.

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l Conclusions l

Licensee actions to provide onsite staffing of key positions during periods of severe l weather met the procedure requirements. The control and use of overtims during l adverse conditions was reasonable to assure responso personnel remained fit for .

duty. Licensee plans to assure adequate staffing during periods of union negotiations were adequate. No violations were identifie F8 Miscellaneous Management issues i

F Industrial Safety issue-Maintenance Shoo Emeraency Earess l

l- Insoection Scope (93001)

l The purpose was to review licensee industrial safety practices regarding emergency egress from the maintenance sho Observations and FindiDGE During a routine tour of the facility on March 18, the inspector identified an industrial safety concern. The inspector entered the maintenance shop by the west doors, but found that emergency egress by the south door was blocked when the door would not open by activating the " crash" bar. Subsequent investigation found that the south door would not open because a partially concealed dead bolt was ;

used to secure the door and was installed through the door Jam from the right side

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of the frame. The door had been locked by maintenance workers as part of the l

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l practice to secure the shop at the end of each day by locking the west and south

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entries. The south door had been locked at about 4:40 p.m., but the west door

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was still open since a maintenance engineer was in his shop office and intended to lock the west door when he left (at about 5:00).

i Upon notification by the inspector on March 18, operations personnel removed the dead bolt from the south door and stored it in the control room to prevent inadvertent use. Plant operators noted that the use of the dead bolt for the south door was a long standing practice. When laterviewed by the inspector, the operators could not recall the use of other similar door lock arrangements at the site. The licensee issued ACR 98-209 to identify this deficiency and implement corrective actions.

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During a follow-up review of the maintenance shop on March 19, the inspector noted that a motorized roll up door adjacent to the south personnel door was energized and would have operated to allow emergency egress. The licensee safety l engineer reviewed the south door arrangement on March 19 and concluded the '

concealed dead bolt did not meet the of the Occupational Safety and Health Administration Standard 1910.36(b)(4), Means of Egres The licensee conducted a walkdown of the shop to assure all exits complied with I the OSHA requirements. This review identified other deficiencies, such as in the marking of exits. As long term corrective action, the licensee planned a walkdown of buildings on site to assure no other locked doors existed (none were identified),

i and to verify compliance with other OSHA requirements. This review was in j

progress at the conclusion of this inspection.

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V. Manaaement Meetinas b t

X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on April 15,1998. The licensee acknowledged the findings

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presented. The inspector asked the licensee whether any materials examined during the

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PARTIAL LIST OF PERSONS CONTACTED Licensee Russell Mellor, Vice President, Operations and Decon, aissioning Gary Bouchard, Unit Director Doug Heffernan, Maintenance Manager Gerry Waig, Operations Manager James Pandolfo, Security Manager Richard Sexton, Radiation Protection Manager i Gerry van Noordennen, Nuclear Licensing i i

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INSPECTION PROCEDURES USED IP 36801: Organization, Management & Cost Control

IP 37700

Design Changes and Modifications l IP 37801: Safety Reviews, Design Changes, and Modifications at PSRs IP 60851: Design Control of ISFSI Components l lP 60853: On-Site Fabrication of Components and Construciton of an ISFSI l lP 61726: Surveillance Observation

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' IP 62706: Maintenance Rule IP 62707: - Maintenance Observation IP 62801: Maintenance and Surveillance at Permanently Shutdown Heactors IP 71707: Operational Safety Verification

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IP 71714: Cold Weather Preparations IP 71750: Plant Support Activities

IP 81700: Physical Security Assessment PSRs IP 83726: Control of Radioactive Materials and Contamination, Surveys and Monitoring IP 83750: Occupational Radiation Exposure IP 90712: In-Office Review of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92700: Onsite Follow-up of Written Reports of Nonrcutine Events at Power Reactor Facilities IP 92702: Follow-up on Corrective Actions for Violations and Deviations IP 92709: Licensee Strike Contingency Plans IP 93001: OSHA Interface Activities ITEMS OPEN, CLOSED, AND DISCUSSED Open 98-01-01 IFl Address Deficiencies for Freeze Protection 98-01-02 IFl Follow Maintenance Rule Program Revision 98-01-03 URI Disposition of Quality Attributes for SFP lsland 98-01-04 VIO Failure to Revise TSs for Seismic monitor System 98-01-05 URI Follow Actions for Sample Filter Paper Closed per Attachment A '

Discussed 96-07-01 96-07-02 96-07-03 96-07-04 96-11-07 97-05-02 URI Procedures for Decommissioning Operations 97-05-04 URI SFP Leakage

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97-09-03 URI Adequacy of QA Reclassification of SFPCS 97-09-04 URI Survey and Remediation of Offsite Locations 97-09-05 IFl Loss of Security Equipment i

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LIST OF ACRONYMS USED ACP Administrative Control Procedure ACR Adverse Condition Heport AOP Abnormal Operating Procedure CAP Corrective Action Plan CMP Configuration Management Plan CFR Code of Federal Regulations CYAPCo Connecticut Yankee Atomic Power Company DCM )

Design Change Manual '

DCR Design Change Request DEP Department of Environmental Protection EDG- Emergency Diesel Generator EP Emergency Preparedness j

EPIP Emergency Plan implementing Procedure i F Fahrenheit GPR Ground Penetrating Radar HHS House Heating System IBEW International Brotherhood of Electrical Workers IC Intermediate Cooling IR- Inspection Report KPl Key Performance Indicator LDB Licensing and Design Basis LER Licensee Event Report LLD Lower Limits of Detection MIC Microbiologically influenced Corrosion MRT

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Management Review Team .i NOP Normal Operating Procedure i NOV Notice of Violation NRC Nuclear Regulatory Commission PA Protected Area PDR Public Document Room PMMS Production Maintenance Management System PM Preventive Maintenance Procedure OA Quality Assurance RMS Radiation Monitoring System RWPs Radiation Work Permits

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RWST Refueling Water Storage Tank SC Spray Cooling SFB Spent Fuel Building .

SFP Spent Fuel Pool SFPCS Spent Fuel Pool Cooling System SMS Seismic Monitoring System SSC Structures, System and Components SUR Surveillance Procedure SW Service Water TR Trouble Report TS Technical Specification

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l TSC Technical Support Center UFSAR Updated Final Safety Analysis Report WCM Work Control Manual i

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ATTACHMENT 1 FOLLOW-UP OF ESCALATED ENFORCEMENT ITEMS The NRC issued a Notice of Violation and Proposed imposition of Civil Penalty based on numerous inspections to review several facets of Haddam Neck performance. The violations were grouped into broad categories that included inadequacies in engineering programs and practices; operational deficiencies, including inadequate procedures and the l failure to follow procedures for the nitrogen intrusion event; inadequate implementation of the emergency preparedness program; and, numerous deficiencies in the corrective action program. The NRC review of licensee actions to address weaknesses in the major process and program areas is described in Section E8.2 of this report. The NRC review of actions to address specific violations is summarized below. For each item discussed, the violation (VIO) number referenced in the May 12,1997 Notice is listed, along with the original inspection report item number (if applicable) in parenthese Violation issues No Longer Applicable to Decommissioning Violations Related to inadequate Engineering Some of the 1997 enforcement action issues concerned aspects of plant operation that were important only for continued reactor operation, or plant operation at powe Following the certification to the NRC on December 5,1996 of the decision to permanently !

shutdown the plant and cease operations, the corrective actions (plant modifications) for l'

these violationc were no longer appropriate. The items listeo below are close . _VIO 01072 (IR 96-08-02): Uncertainties for Wide Range Nuclear Instruments VIO 01082 (IR 95-27): Inadequate testing for LPSI Flow  ; VIO 01182 (IR 96-201-11): Inadequate EOP Changes for RCS Head Vents  ! VIO 01022 (IR 96-201-33): Inadequate NPSH Calculations for HPSI VIO 02032 (IR 96-08-03): Inoperable CAR Fans - SW Waterhammer VIO 02012 (IR 96-08-11): Inoperable ECCS Flow Path - RHR Pump NPSH VIO 02022 (IR 96-08-10): Inoperable ECCS Flow Path - Sump Screens VIO 01032 (IR 96-201-32): RWST Level Uncertainties - Recirculation Phase VIO 01052 (IR 96-201-28): Inadequate EDG Load Calculation l

10. VIO 01092 (lR 96-201-29): Inadequate CAR System Flow Test l

11. VIO 01102 (IR 96-201-27): Incorrect Pressure in FRV Calculation '

12. VIO 01122 (IR 96-201-28): Inadequate EDG Load Calculation 13. VIO 01132 (IR 96-201-28): Inadequate EDG Load Calculation i 14. VIO 01142 (IR 96-201-07): Inadequate Design Basis SW Flow Instrumentation  !

15. VIO 01152 (IR 96-201-26): LOCA Impacts on Mechanical Components  !

16. VIO 01172 (IR 96-201-30): Inadequate EOP for Transfer To Sump Recirculation 17. VIO 01192 (IR 90-11-06): Inadequate PAB Flood Protection for RHR Pumps 18. VIO 01012 (IR 96-201-21): Battery Load Calculation - LOCA Loads 1 Violations Associated with inadequate Corrective Actions Some of the enforcement issues concerned inadequate corrective actions that applied to systems not required in the defueled mode. Following the certificatis 7 to the NRC on December 5,1996 of the decision to permanently shutdown the plant and cease

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operations, the corrective actions for these violations were no longer appropriate. The items listed below are closed. NRC review of this area continued at the end of the inspection perio . VIO 01372 (IR 96-201-09):RWSTinstrument Uncertainties for EOP Decision Points 2. VIO 01382 (IR 96-201-16): RWST Level Instrument Classification 3. VIO 01412 (IR 96-201-17): Inadequate Corrective Actions for LPSI Flow 4. VIO 01422 (IR 96-201-06): Inadequate Test for Degraded Grid Voltage Protection 5. VIO 01432 (IR 96-08-10): Inadequate Evaluation of Sump screen Mesh Size 6. VIO 01442 (IR 96-201-15): Corrective Actions for CAR Fan Flow Post LOCA Il Violations Associated with Emergency Preparedness 1. VIO 96-07-01: Failure to Make Event Classification 2. VIO 96-07-02: Inadequate Protective Action Recommendation

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