IR 05000213/1999001
| ML20207G187 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/21/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207G179 | List: |
| References | |
| 50-213-99-01, 50-213-99-1, NUDOCS 9906110057 | |
| Download: ML20207G187 (55) | |
Text
{{#Wiki_filter:0- ' ., , ,. + , ., U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No.: 50-213 License No.: DPR-61
- Report No.:
50-213/99-01 Licensee: Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, CT 06141-0270 Facility: Haddam Neck Station Location: Haddam, Connecticut Dates: January 19,1998 - April 19,1999 Inspectors: Lonny Eckert, Radiation Specialist ' Joseph Furia, Senior Radiation Specialist Craig Gordon, Senior Health Physicist j
Thomas Kenny, Senior Operations Engineer , ' Marie Miller, Senior Health Physicist l Joseph Nick, Decommissioning Health Physicist John Wray, Decommissioning Health Physicist Approved by: Ronald Bellamy, Chief, Decommissioning and Laboratory Branch Division of Nuclear Materials Safety j l " 9906110057 990521 PDR ADOCK 05000313 O PDR
..,. . . .. _ ._. _ _ . , . . . . EXECUTIVE SUMMARY Haddam Neck Station NRC Inspection Report No. 50-213/99-01 This routine inspection included aspects of licensee activities in preparation for dismantlement and decommissioning of the facility. The report covers a three-month period of inspection by regional NRC personnel, and includes reviews and assessments of spent fuel safety, engineering and plant support activities, and management effectiveness.
Spent Fuel Safety: Current management of routine decommissioning activities was effective. The proposed organizational transition to the Decommissioning Operations Contractor (DOC) appears adequate. Close NRC review of this area is warranted as near-term changes occur. The licensee had provided an acceptable environment for employees to communicate safety concems to management and ensure that problems receive appropriate attention.
No concems were identified with the current CY organization and qualifications of personnel.
CY staff included in the transition team were competent to ensure project management control when the DOC activities are initiated. Good effort was shown to develop and establish the training program which conformed to decommissioning activities. Should DOC training specifications change after the contract is in place, further NRC review of this area will be needed.
The certified fuel handler program closely replicated an initial operator and requalification program for reactor / senior reactor operators. The prcgram was based on the system approach to training (SAT) and contained the necessary elements to ensure the handling, storage and cooling of nuclear fuel was performed in a manner consistent with ensuring the health and safety of the public. There is ample personnel qualified for safe fuel handling.
The inspector reviewed the certified fuel handler program and determined the program used the SAT process to build the program for developing and retraining certified fuel handlers. The NRC has determined that all the commitments relative to Haddam Neck listed in CAL No.1-97-010, dated March 7,1997, have been met.
Engineerina and Support Activities: The licensee is taking appropriate corrective action in response to the NU audit findings regarding records management.
The licensee did not recognize that a supplement dated January 18,1999, requested an accelerometer instrument measurement range that differed from the original license amendment request dated June 2,1998. As a result, the supplement did not provide a description of or the basis for the revised measurement range.
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r' . > r . , , . Subsequently, by letter dated March 9,1999, the licensee transmitted a description of and the basis for the revised instrument measuring range of the Triaxial Servo Accelerometer. Since the licensee updated this information in a timely manner, there was no violation of regulatory requirements.
Plant Support and Radiological Controls: ' The_ licensee applied good radiological controls for decommissioning activities. Radiological controls for decommissioning work were well planned and Radiation Protection personnel maintained close oversight of work. The licensee established and was implementing effective radioactive effluent and radiation protection controls for the Bus-10 removal project.
An effective program for the processing of plant liquids, collection and processing of solid radioactive waste, and the transportation of radioactive meterials has been established and maintained. Problems encountered during the processing of the Reactor Coolant System (RCS) decon wastes are being appropriately addressed. Components and systems needed for the continued collection and processing of radioactive waste appear to be in appropriate condition.
An effective training program has been established for the training of plant personnel involved in the transport of radioactive materials and the disposal of solid radioactive waste.
A generally effective program for the identification and tracking of issues related to the solid radwaste program has been implemented. Identified deficiencies are tracked until resolution, with the corrective actions appropriately verified. Some problems with the classification of self-identified deficiencies and the timely implementation of corrective actions were identified by the - licensee's audits.
The licensee established, implemented, and maintained an effective program with respect to , electronic calibrations, radiological calibrations, system reliability, and tracking and trending.
The licensee established, implemented, and maintained an effective quality assurance program for the radioactive effluent control program with respect to audit scope and depth, audit team experience, and response to audit findings.
The inspector determined that the licensee is making adequate progress to address NRC identified violations and unresolved items.
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- . , . TABLE OF CONTENTS EXECUTIVE SUMMARY............................. ...................11 l TABLE OF CONTENTS...................................................... iv R E PORT D ETAI LS....................................................... 1 Summary of Facility Activities.............................................. 1 I. Decommissionina Operations........................................... 1
Cond uct of 0perations.............................................. 1 O1.1 Oraanization. Manaaement. and Controls............................ 1 01.2 Oraanization. Staffina. Qualifications. and Trainina.................... 2
Operator Training and Qualification................................... 4 05.1 ' Certified Fuel Handlers Proaram................... ................4
Miscellaneous issues.......................................... 6 08.1 (Closed) VIO 98-0 3-0 2.......................................... 6 08.2 Confirmatory Action Letter (CAL) of March 7.1997................... 6 11. Decontamination Suncort Activities.................... .................7 M8 Miscellaneous issues............................................... 7 M8.1 (Closedi lFl 98-01 -0 2........................................... 7 E1 Engineering Support for Decommissioning............................... 7 E1.1 Enaineerina Procedures and Documentation.......................... 7 E8 Miscellaneous Engineering issues...... ..............................9 E8.1 ' Status of Previous insoection Items................................ 9 111. Plant Support and Radioloalcal Controls................................. 10 R1 Radiological Surveys and Controls.................................... 10 R1.1 Radioloaical Controls......................................... 10 R1.2 Radioloaical Surveys........................................... 10 R1.3 Radioloaical and Effluent Controls for the Bus-10 Removal Project.......
R1.4 Radioactive Waste and Transoortation............................. 12 ,
I R2 Status of RP&C Facilities and Equipment............................... 15 R2.1 Calibration of Effluent / Process Radiation Monitorina Systems (RMS)....... 15 iv .
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, R5 Staff Training and Qualification in RP&C............................... 16 l R7 Quality Assurance in RP&C Activities..................... ............17 l R7.1 Quality Assurance in Radwaste and Transoortation..................
R7.2 Quality Assurance in the Radioactive Effluents Proaram.............
! R8 Miscellaneous Radiation Protection issues............................. 18 R8.1 Status of Previous Radiation Protection items....................... 18 l IV. Manaaement Meetinas.................................................. 23 X1 Exit Meeting Summary............................................... 23 l l X2 Other Significant Management Meetings................................ 23 PARTIAL LIST OF PERSONS CONTACTED.................................. 25 INSPECTION PROCEDURES USED.......................................... 25 ITEMS OPEN, CLOSED, AND DISCUSSED..................................... 26
i LIST OF ACRONYMS USED................................................ 27 l [ l ! I l l l V
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. , .. O REPORT DETAILS Summary of Facility Activities The plant was maintained in a permanently shutdown condition during this inspection period.
The licensee continued priority activities to prepare the plant and supporting functions for tumover to a decommissioning operations contractor (DOC). These activities included spent fuel cooling system modifications, processing of resins from the reactor coolant system (RCS) decontamination, radiological remediation of the Bus 10 area, and site radiological characterization.
1. Decommissionina Operations ! l -
Conduct of Operations 01.1 Oraanization. Manaaement. and Controls Management Systems a.
Insoection Scoos (36801) , Interviews were held with licensee site managemerit and supervisors to ascertain how decommissioning activities were managed and controlled. The licensee's methodology for providing information to employees, identifying and resolving employee / safety concems was assessed.
b.
Observations and Findinos The primary focus of the inspector interviews was to review the licensee's readiness for award of the DOC to a private contractor, followed by implementation strategies once the contract is in place. Discussions were also held about the process used to evaluate and resolve employee safety concems brought to management's attention.
Meetings were held at the beginning and end of each day between site management and department heads to plan and review work activities in the areas of operations, maintenance, engineering, radiation controls, and training. The inspectors attended several meetings throughout the inspection period and observed good interaction among licensee staff during each meeting. Management of routine decommissioning activities was effective as evidenced by status reports from senior staff that key site projects were being maintained.
Although current programs were in place and functional, senior licensee representatives indicated that significant program and organization changes were expected after the DOC was approved. The inspectors reviewed essential elements of the current organization and discussed transition plans with licensee management. The licensee also described expectations of the DOC organization to NRC staff during the management meeting held on March 10,1999. A transition team is established which includes several managers continuing functional responsibilities to assist in the
. . - , , transition. There were no immediate concems with their ability to implement various aspects of the DOC. However, licensee management was informed that implementation to ensure safety after the DOC is initiated will rWve careful NRC evaluation, particularly for reductions in program areas. The licensee smsed to keep NRC apprised of DOC negotiations and the arrangements to complete ble transition.
The CY Concems Program was developed specifically to handle plant safety and labor relations issues raised by employees while the site undergoes decommissioning.
According to the October 1998 policy statement from licensee representatives R. Mellor and D. Davis, employees have the opportunity to pursue different means for raising concems while protecting their confidentiality. The licensee has selected, trained, and assigned certain individuals to the Concems Program office, and included pictures and telephone numbers of those representatives in posters located throughout the site.
Employees are encouraged to contact the designated Concems Program peer representatives with their problems without fear of reprisal. Direct mail, special drop boxes, and a 24-hour toll-free "AlertLine" were also available but received only minimal use. The Concems Program Manager indicated these methods would be emphasized to employees, with emphasis on the AlertLine, which could provide good support to the Concems Program as long as employees understand its availability and how to access it.
Concems Program office casework was reviewed, discussed with the Concems Program Manager, and found to be adequately handled. Communication and feedback to the individuals raising concems were intermittent during evaluations. It was found that the licensee had provided an acceptable environment for employees to communicate safety concems and ensure that problems were addressed within a reasonable time by the appropriate level of management.
c.
Conclusions Current management of routine decommissioning activities was effective. The proposed organizational transition to the DOC appears adequate. Close NRC review of this area is warranted as near-term changes occur. The licensee had provided an acceptable . environment for employees to communicate safety concems to management and ensure I that problems receive appropriate attention.
01.2 Oraanization. Staffina. Qualifications. and Trainina a.
Insoection Scope (36801) The licensee's present organization and staffing plan were reviewed and compared with the transition plan expected to take effect after DOC implementation. A review was performed of the training program to qualify individuals in health physics practices and emergency planning, general employee training (GET) including the orientation program for new hires, and requalification of current employees.
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Observations and Findinas The inspector met with the Decommissioning Director who described management oversight of the existing decommissioning organization. Specific areas discussed were the relationship between the operations, decommissioning, and strategic planning areas and how each group was expected to implement their respective responsibilities following DOC approval.
The inspectors noted that considerable changes will occur in functional responsibilities as the licensee progresses from CY to DOC staff. The licensee expects to maintain senior CY staff members who have been involved in different aspects of decommissioning activities since final shutdown, and take advantage of their program ' familiarity throughout transition to the DOC. Specific assignments could not be discussed because DOC contract negotiations were under review by the licensee. From interviews and the licensee's presentation at the March 10,1999, management meeting, it appears that the CY staff included in the transition team are competent to ensure project management control when the DOC activities are initiated and changes in assigned areas take effect. As noted above, this area will be reevaluated after final DOC approval.
The licensee's training program to qualify personnel involved in radiation safety activities and assigned to the decommissioning emergency response organization (DERO), and indoctrination training including GET were evaluated.
Discussions were held with the Training Supervisor and training instructors who provided training lesson plans, examination materials, and attendance records for site personnel.
In-plant health physicist technicians received classroom instruction followed by a practical factors demonstration in which employees must demonstrate survey and contamination control techniques in mock-ups staged by instructors. A hands-on session was observed by the inspectors and found effective by incorporation of performance-based training concepts. Student proficiency and student / instructor interaction were noted throughout the session.
Changes in scope of the Emergency Plan (EP) resulted in reductions of designated emergency response personnel needed for the DERO. Program framework and basic operation for implementing emergency planning was discussed with the Emergency Planning Coordinator. The EP training was recently developed and successfully demonstrated by the DERO during the 1998 exercise of the CY Emergency Plan.
GET provided to employees was primarily computer-based and adequate to satisfy initial GET. Performance-based GET was under development and will be reviewed when completed. Although there were no concems identified with current training program implementation, licensee representatives were unable to provide information whether the established program would continue after the DOC is in place due io confidentiality of the DOC negotiations.
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Conclusions l [ No concerns were identified with the current CY organization and qualifications of [ personnel. CY staff included in the transition team were competent to ensure project l management control when the DOC activities are initiated. Good effort was shown to l develop and establish the training program which conformed to decommissioning l activities. Should DOC training specifications change after the contract is in place, l further NRC review of this area will be needed.
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Operator Training and Qualification 05.1 Certified Fuel Handlers Proaram a.
Insoection Scooe (41500) On December 5,1996, the licensee ceased reactor operations and subsequently removed the fuel from the reactor. in May 1997, the licensee submitted two applications to change Technical Specifications (TS) to replace the operator licensing program with a certified fuel handler (CFH) program. The NRC issued the TS change on March 27, 1998, allowing the use of a CFH program. This inspection reviewed the program to ensure the necessary qualified personnel were in place to safely monitor the structures, systems, and components (SSCs) that support spent fuel cooling, and control irradiated fuel and other radioactive components within the spent fuel pool.
b.
Observations and Findinas The inspector reviewed the training program that consisted of four parts. The program was patterned after the operator training program using the systems approach to training (SAT) as described in 10 CFR 55.4. Each part of the program is described as follows: The Shift Managers Training Program (ADM 1.1-300) - The inspector determined the program contained the necessary elements to select and train candidates in supervisory skills necessary to direct operations to ensure the handling, storage and cooling of nuclear fuel are performed in a manner consistent with ensuring the health and safety of the public.
The Certified Fuel Handler (CFH) Initial Training Program (ADM 1.1-301) . The inspector determined the program contained the necessary elements to select and train candidates in the skills necessary to ensure the handling, storage and cooling of nuclear fuel are performed in a manner consistent with ensuring the health and safety of the public.
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The Equipment Operator (EO) Training Program (ADM1.1-303)
The inspector determined the program contained the necessary elements to select and train candidates in the operation of SSCs to ensure the cooling of nuclear fuelis performed in a manner consistent with ensuring the health and safety of the public.
All of the above programs consisted of comprehensive training that required passing a written examination, five job performance measures and an oral examination, all with a grade of 80% to complete the training. The programs also used qualification cards to record the on-the-job training requirements required to qualify the candidate for the position desired.
The Certified Fuel Handler Requalification Training Program (ADM 1.1-302) . The inspector determined the program contained the necessary elements to provided periodic training, with examinations corresponding to the initial qualification training. This training is scheduled during shift rotation periods designated by the training coordinator. A yearly operating test consisting of five job performance measures (JPMs) and one crew drill scenario is required. The program also requires an open reference biennial written examination. This program applies to both the CFHs and EOs.
By virtue of their past operational qualifications, the senior reactor operators were " grand-fathered" by the license to be qualified CFHs. The inspector reviewed the training documents for a candidate that was trained to become a CFH using the above program ADM 1.1-301. The inspector concluded that the candidate was trained in accordance with the program and is now on shift.
The licensee currently has personnel qualified for the following positions: Shift Manager /CFH (6), CFH (3), EO (13). The inspector concluded this was ample to provide coverage to all shi ts.
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Conclusions The certified fuel handler program closely replicated an initial operator and requalification program for reactor / senior reactor operators. The program was based on the SAT and contained the necessary elements to ensure the handling, storage and cooling of nuclear fuel were performed in a manner consistent with ensuring the health and safety of the public. There is ample personnel qualified for safe fuel handling.
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Miscellaneous issues 08.1 (Closed) VIO 98-03-0.2 l Several valving errors discussed in report 50-213/98-03 were examples of a failure to L follow operating and maintenance procedures. These errors contributed to the failure of I properly implementing administrative controls and procedures that assured system ' configuration control, and were contrary to TS 6.8.1. The inspector reviewed procedure CY-00084, " Work Stand Down Valve Operations / Tagging," that was conducted to inform personnel of the tagging problems.' Corrective actions included: first-line supervisor l training briefings given to all supervisors describing the responsibilities with respect to plant tagging; comprehensive training of personnel on the tagging process based on a ! newly written procedure IS-024, " Plant Tagging;" and a substantial revision to procedure WCM 2.4-1, " Equipment Tagging".
! l Based on the above reviews and discussions with plant personnel, the inspector concluded that the licensee stopped work and retrained responsible personnel on methods to ensure safe'.y to persons and equipment through proper equipment tagging.
The training also reaffirmed the necessity for system configuration control. This item is closed.
l 08.2 Confirmatory Action Letter (CAL) of March 7.1997 l The nine items for the CAL were closed in NRC Combined Inspection Report Nos.
] 50-245;336;423/99-02 (Millstone).
^ t CAL ltems 1,6,7 and 8 were applicable to Haddam Neck (HN) as well as item 9 discussed below.
CAL ltem 9 was applicable to HN " Complete specific reviews of the HN LORT (licensed operator requalification training) program by April 4,1997."
The inspector reviewed the licensee's evaluation regarding the LORT program and noted 35 discrepancies were identified. The inspector determined the discrepancies found were corrected by the licensee, except for those that could not be corrected due to the plant being shutdown and defueled. The inspector confirmed that the LORT program - was in effect until the TS change in March 1998 when the fuel handler program began.
As described above there are no longer licensed operators at Haddam Neck, therefore, there is no LORT program. The inspector reviewed the CFH program and determined [ the program used the SAT process to build the program for developing and retraining , CFHs.
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Based on the above discussion this item is closed.
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r- , , . . . , I II. Decontamination Support Activities M8 Miscellaneous issues M8.1 (Closed) IFl 98-01-02 During a review of maintenance rule requirements for the systems necessary to cool and maintain the spent fuel pool, the inspector noted the base plates and hangers on systems that support spent fuel cooling were not included in the maintenance rule program. - The inspector reviewed documents of system piping and supports, including base plates, and verified that they are now part of the maintenance rule program. This item is closed.
E1 Engineering Support for Decommissioning Ei.1 Enaineerino Procedures and Documentation Records Retention of Desian Calculations a.
Insoection Scooe (37801) Licensee Condition Report CR 99-0055 was examined and cognizant personnel interviewed.
b.
Observations and Findinas An audit conducted by Northeast Utilities Service Company in May 1998 found that some original CY calculations prepared by the Nuclear Engineering Department of Northeast Utilities (NU) were not submitted to Nuclear Document Services in accordance with applicable procedures. As a result, some of these records are not located at the Haddam Neck site as required by Design Change Manual, Chapter 5. This violation is of minor safety significance and is not subject to formal enforcement action.
The licensee was reviewing their records to determine which calculations needed to be transferred to the Haddam Neck site. Licensee personnel were assigned to verify that the records contained the latest revision of applicable calculations, and to update the computer database and files.
c.
Conclusions
The licensee is taking appropriate corrective action in response to the NU audit findings regarding records management.
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' , , ) . . . Technical Specification Chance for Seismic Monitorino Instrumentation ,
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Insoection Scope (37801) The inspector examined the documentation presented to the Plant Operational Review Committee (PORC) for approval of a proposed change to the Technical Requirements l Manual (TRM) to support a TS amendment request to relocate seismic monitoring requirements from TS to the TRM.
b.
Observations and Findinos l l ' The TRM change was presented to PORC for approval on January 14,1999. The PORC approved the change, which was transmitted to the NRC on January 18,1999, as a supplement to a license amendment application dated June 2,1998.
' The June 2,1998, application requested that TS 3/4.3.3.3 and associated tables be relocated to the TRM. In addition, the June 2 app!! cation requested a correction of a typographical error in the measurement rango of the Triaxial Servo Accelerometer. The licensee stated that it would correct the measurement range to read "i 0.5g".
t in response to an NRC letter dated December 3,1998, the licensee supplemented its application by letter dated January 18,1999. The supplement included a revised page from the TRM, approved by the PORC, which listed the Triaxial Servo Accelerometer measurement range as "O to 0.5g".
However, the January 18 supplement did not contain a description of the change illustrated on the TRM page, and did not contain a basis for revising the measurement range from "i 0.5g", as originally requested in the June 2,1998, application, to "O to 0.5g." In order to receive consideration,'a license amendment application must meet the requirement of 10 CFR 50.90 to fully describe the changes desired.
' The minutes of the PCRC meeting of January 14,1999, which approved the TRM change were not available at the time of the inspection (February 9 - 10,1999).
However, licensee personnel reported that the basis for the change in the measurement range was presented to the PORC during the meeting. The licensee explained that procedure AOP 3.2-5, " Natural Disasters", is used to interpret the Triaxial Servo Accelerometer indication. Attachment 2, page 3 of that procedure contains graphs used to determine if the instrument indication exceeds the design parameters for an earthquake. The graphs record plots of acceleration amplitude vs. frequency in the three orthogonal directions. Only positive values are used for acceleration amplitude.
.Therefore, an instrument measurement range that includes only positive vslues is consistent with the data interpretation procedure. The licensee stated that the i magnitude of the range was sufficient to determine whether the design basis earthquake acceleration had been exceeded.
i The licensee stated that it intended to submit a revised supplement which will fully
j describe and provide the basis for the desired change.
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Conclusions The licensee did not recognize that its supplement dated January 18,1999, requested an accelerometer instrument measurement range that differed from the original license amendment request dated June 2,1998. As a result, the supplement did not provide a description of or the basis for the revised measurement range.
] i Subsequently, by letter dated March 9,1999, the licensee transmitted a description of and the basis for the revised instrument measuring range of the Triaxial Servo Accelerometer. Since the licensee updated this information in a timely manner, there was no violation of regulatory requirements.
E8 Miscellaneous Engineering issues E8.1 Ststus of Previous Inspection items (Closed) Violation 98-03-05: Licensino Basis Discrepancies. The licensee responded to the notice of violation by letter dated September 21,1998. The cause of the violation was personnel error by the person who developed the May 30,1997, letter to the NRC for a license amendment application. That person inserted additional information regarding Spent Fuel Pool (SFP) makeup feed capabilities into the letter after the Lead Functional Manager had approved the letter. As a result, the incorrect information was transmitted to the NRC without the appropriate review.
l The licensee discovered the error and reported it by letter dated July 30,1998. The individual who inserted the erroneous information is no longer working at the Haddam Neck plant. In addition, the Licensing Manager reviewed the violation with Licensing j Department staff and reinforced the requirements to follow the existing process for ' developing outgoing correspondence. This item is closed.
(Closed) Unresolved item 98-03-03: Spent Fuel Buildina Seismic Analyses. The licensee received additional information from Stevens & Associates which completed their seismic analysis of the spent fuel building structure and yard crane. The licensee completed an evaluation of the seismic design basis for the SFP building and yard crane by memo dated September 30,1998 (CYDE-98-0277). The licensee concluded that when load redistribution from the braces to the frame of the yard crane structure are appropriately considered, the SFP building and yard crane meet Standard Review Plan 3.8.4 criteria and are in compliance with the seismic design and licensing basis for the structures. Based on review of this iterr, NRC determined there was no violation of regulatory requirements. This item is closed.
.. . - . . . Ill. Plant Suonort and Radioloalcal Controls R1 Radiological Surveys and Controls R1.1 Radioloaical Controls a.
Inspection Scooe (83750) The inspectors toured the radiologically controlled area (RCA) and discussed specific radiological controls with radiation protection (RP) supervisors and RP technicians. The inspectors also reviewed radiological controls implemented for the routine activities including radiation work permits (RWPs), the Radiological Safety Reviews, and associated radiological surveys.
b.
Observations and Findinas The inspectors toured various areas within the RCA, including the primary auxiliary building (PAB), the containment building, and outside areas in the RCA. Appropriate controls were observed for Radiation Areas (ras) and High Radiation Areas (HRAs). Postings and barriers were effectively placed to notify workers regarding changes in radiation levels.' Appropriate controls were noted to prevent the spread of radioactive contamination. The inspectors noted that workers were taking the proper precautions for radiation protection as required by the licensee's staff. During tours, good radiological housekeeping and good worker awareness of radiological hazards were noted. The inspectors observed the staging of equipment and noted that areas were staged for good contamination controls and radioactive waste management.
c.
Conclusions Radiological controls for decommissioning work were well planned and RP personnel maintained close oversight of work.
R1.2 Radio!Mical Surveys a.
Inspection Scooe (83750) The purpose of this inspection was to continue the review of licensee contamination surveys at off-site properties that received or may have received material from the Haddam Neck plant in the past. The inspector review included off-site observations, confirmatory sampling, and selected review of characterization survey data.
b.
Observations and Findinas Unresolved item (URI) 97-09-04 concemed NRC review of the licensee actions to survey off-site areas that received soils, concrete blocks and other potentially contaminated equipment and materials for the HN plant and to recover contaminated materials for proper disposal. NRC inspection activity has continued throughout 1998 and included
. . . . . . extensive observations by the inspectors, and confirmatory sampling by both the Connecticut Department of Environmental Protection and the NRC.
During this inspection, the inspector noted good technique for scanning surface areas and in the collection of surface soil samples. The licensee maintains good control and tracking of survey data and soil samples. The licensee also improved coordination between the State of CT and NRC with regard to assuring properties were ready for final status surveys and confirmatory samples. Soil samples were collected from off-site properties and were split with the licensee for analysis by gamma spectroscopy at the NRC Region i Radiation Measurement Laboratory in King of Prussia, Pennsylvania.
Through comparison of results, the inspector determined that the measurements have demonstrated good agreement.
Also, see section R8.1 of this Report for further discussion regarding this issue. This item will be further.eviewed after completion of the licensee's bounding radiation dose assessment for potential exposure scenarios to members of the public for the offsite I dose locations. (IFl 99-01-01) c.
Conclusions Licensee activities this period continued to be good with regard to conduct of characterization and final status surveys at off-site locations that had received potentially contaminated material. The NRC will continue to review the licensee's survey results.
R1.3 Badioloaical and Effluent Controls for the Bus-10 Removal Proiect a.
Insoection Scope (83750) The licensee identified, during their early site characterization activities, a former radioactive waste cask wash-down and temporary storage pad. This concrete pad was used in the early 1970s and had been abandoned without remediation. To limit the spread of contamination and lower radiation dose rates until eventual site decommissioning, one layer of lead and concrete had been applied. An electrical bus (Bus-10) was erected over the concrete pad. This project involved the removal of the electrical bus, the concrete and lead shield layers, and the concrete pad and evacuation of several feet of soil below the surface.
The inspection consisted of: (1) a tour around the Bus-10 pad containment tent and observation of related work activities through the tent windows; (2) review of licensee technical support documents CY-HP-0029, "HEPA Units Environmental Release Evaluation" and CY-HP-0033, * Bus-10 Removal Project - Containment Environmental j Release Evaluation; and (3) review of air sample results from Bus-10 work.
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Observations and Findinas i The licensee had completed concrete scabbling work to uncover lead sheeting placed under the Bus-10 pad and had removed a few of the lead sheets at the time of the inspection.
The licensee's technical support documents concluded that all credible failure modes of the Bus-10 containment tent and supporting High Efficiency Particulate Air (HEPA) units were well bounded by a spent resin fire, the current limiting accident analysis. No discrepancies were noted pertaining to these analyses.
At the time of the inspection, workers were required to wear respirators for industrial hygiene purposes (to minimize / preclude lead inhalation). HEPA effluent air filter sample results were less than the lower limit of detection.' Conditions had the potential to change as more of the lead sheeting was removed and more concrete was pulverized and removed. Two HEPA filtration units and a powerful HEPA vacuum were being used as engineering controls for this work.
c.
Conclusions The licensee established and was implementing effective radioactive effluent and radiation protection controls for the Bus-10 removal project.
R1.4 Radioactive Waste and Transoortation a.
inspection Scone (86750) A review of the licensee's program for the collection, processing and shipment of radioactive waste and transportation of radioactive materials was conducted. Focus areas of inspection included verification of compliance with the following regulatory requirements: 10 CFR 20.1906 Procedures for receiving and opening packages
1 , 10 CFR 20, Appendix G Requirements for transfers of low-level radioactive waste intended for disposal at licensed land disposal facilities and manifests 10 CFR 61.55 Waste classification 10 CFR 61.56 Waste characteristics 10 CFR 71.12 Generallicense: NRC-approved package 10 CFR 71, Subpart H Quality Assurance 49 CFR 172, Subpart C Shipping Papers
F , . . . . l ,49 CFR 172, Subpart D Marking 49 CFR 172, Subpart E Labeling 49 CFR 172, Subpart F Placarding 49 CFR 172, Subpart G Emergency Response Information i 49 CFR 173, Subpart I Class 7 (Radioactive) Materials The inspection was accomplished by direct observation of radwaste and transportation - ! activities; review of selected procedures, shipping documents and records; and discussions with cognizant plant personnel.
Additionally, a review of current waste processing equipment availability, and projected licensee decommissioning needs was conducted to verify the continued ability of the facility to properly collect, process and dispose of radioactive waste, b.
Observations and Findinas Reactor Coolant System l Since the facility shutdown, the most significant radiological waste evolution was the ! decontamination of the RCS. The process required the utilization of the three existing j primary letdown ion exchangers, plus the additional use of the fuel pool ion exchanger.
! During this process, the initial charges of resin in these four vessels became depleted I and were discharged to the spent resin tank (SRT). The decontamination process then , continued with new charges in each of the four lon exchangers. During this work, the l retention screen on the fuel pool !on exchanger was damaged, so that the ion exchanger cannot be utilized further. The second charge of resins remain in the ion exchangers.
l In December 1998, the first batch of spent resins from the RCS decon project were sluiced to a high density polyethylene liner in a shed located in the spent resin building.
During initial dewatering of this liner, it was observed that portions of the liner intemals - appeared damaged. Subsequent efforts to dewater the liner resulted in resin beads being observed in the dewatering return line to the SRT, possibly indicating damage to the liner's dewatering laterals. Since the licensee had purchased five additional liners of the same type for this project, these were returned to the manufacturer for inspection.
l Further, the licensee was negotiating with the vendor, who also operates a waste , j-disposal facility, to take the existing liner with wet resins, process it to an acceptable l waste form at the vendor's facilities, and then dispose of it as originally planned.
RCS clean-up is currently accomplished through the utilization of a portable filtration system located in the containment, with suction directly from the reactor cavity. The letdown ion exchangers remain unavailable, as they continue to hold spent resins from the RCS decon project.
I e L i
] , , . . .. l One significant issue yet to be resolved is the drain-down of the RCS. The Reactor Water Storage Tank (RWST) was previously identified as leaking, and has been emptied and removed from service. This tank would normally receive the cavity water during a drain-down in normal operations. A number of other options are being investigated, however no final decision on how to collect and process the RCS water inventory has been made yet.
Floor Drain Collector System During the RCS decon, a spill of decontamination solution occurred in the PAB, potentially contaminating the floor drain system with chemicals utilized in the ' decontamination process. Subsequently, the licensee sampled the floor drains and building sumps, and ascertained that levels of these chemicals were sufficiently low to resume use of the floor drains and building sumps, however, they are awaiting , confirmation of these results with the State of Connecticut. As a consequence, the normal floor drain processing system is not in use, including the vendor supplied four-vessel domineralizer system. New water inputs, primarily ground water intrusion into the pipe trench, are directed to the aerated drain tanks, then to the boron recovery system, where it is processed through the boron recovery lon exchanger, prior to release.
Solid Radioactive Waste Responsibility for the collection, processing and transport of solid radioactive waste is with the radioactive materials handling group. Current waste streams include spent RCS decon resin, sump sludge and dry active waste (DAW). Processing of RCS decon resin is currently suspended, as described above. Additional resin inputs, especially from the continued use of the vendor-supplied domineralizer system for the processing of floor drain water, are not currently being made. DAW is collected and packaged in the radwaste reduction facilit/, Also located in this facility is a liner partially filled with sump sludge, and the designated storage area for high activity (greater than 100 millirem per hour) trash.
Scaling factors for hard to detect radionuclides are determined on a biennial basis for most waste streams. Specific batch scaling factors have been determined for the RCS decon resins located in the SRT, and another set of scaling factors will be determined for the four remaining charges of decon resin, currently located in the ion exchangers, once they are transferred to the SRT. A comparison of the scaling factors determined for the first load of RCS decon resins to the previously utilized letdown domineralizer resins indicates that while three isotopes have changed by greater than an order of magnitude, these are radionuclides that were only present in trace amounts during operations, or were listed at their minimum detectable activity levels. The three isotopes are technicium-99, niobium-94 and neptunium-237. Technicium is one of the limiting isotopes for disposal site operation, niobium is a specifically listed isotope in Table 1 of 10 CFR 61.55, and neptunium is an alpha emitter. None of these isotopes is present in any significant quantity; however, and the scaling factors for this waste stream have been revised to reflect these current values.
1 I
. . s . . Randomly selected shipping manifests were reviewed for compliance with the applicable portions of 10 CFR Parts 20, 61 and 71, and 49 CFR. No discrepancies were identified, and all shipments of radioactive waste were accepted at the low-level radioactive waste disposal facility.
Tours of the RCA were conducted, with specific focus on the material condition of those components, systems and areas where radioactive waste collection and processing occurs. As noted above, several systems are permanently or temporarily out-of-service.
Permanently out-of-service components include the RWST and the fuel pool ion exchanger. Temporarily out-of-service components include the vendor supplied floor drain domineralizer skid. Systems located in the PAB, waste and gas building and containment were inspected and appeared to be in appropriate material condition, and able to continue to perform their intended function.
c.
Conclusions ' An effective program for the processing of plant liquids, collection and processing of solid radioactive waste, and the transportation of radioactive materials has been established and maintained. Problems encountered during the processing of the RCS decon wastes are being appropriately addressed. Components and systems needed for the continued collection and processing of radioactive waste appear to be in appropriate condition.
R2 Status of RP&C Facilities and Equipment R2.1 Calibration of Effluent / Process Radiation Monitorina Systems (RMS) a.
Insoection Scone (84750) The inspector reviewed the most recent calibration results for the following effluent / process RMS.
Main Stack Noble Gas Radiation Monitor (R-14A);
. Main Stack Wide Range Noble Gas Radiation Monitor (R-14B); - ' Radioactive l_iquid Effluent Radiation Monitor (R-18);
Spent Fuel Pool Radiation Monitor (R-19); and
Test Tank Effluent Radiation Monitor (R-22).
- The inspector also reviewed Dioctyl Phthlate (DOP) testing results for the main stack noble gas monitor R-14A sample line.
l ! b.
Findinos and Observations Electronic alignment and radiological calibration results for the RMS were found to be within the licensee's acceptance criteria. Linearity tests were appropriate. Secondary calibrations validated primary calibrations. Tracking and trending efforts were also good.
. . . . . NRC Inspection Report No. 50-213/98-03 identified a violation pertaining to an inadequate main stack rate monitor calibration procedure. The main stack and liquid effluent flow rate meter calibration results were found to be within the licensee's acceptance criteria. During the conduct of this inspection, main stack sample line DOP testing methodology and results were reviewed. No inadequacies were noted pertaining to DOP testing methodology of the main stack noble gas monitor R-14A sample line.
These tests were key actions needed to address the violation pertaining to discrepancies in the measurement of main stack effluents as described in NRC Inspection Report No.
50-213/98-03. Corrective actions pertaining to Notice of Violation (NOV) 50-213/98-03-06 have been placed in the licensee's corrective action program. In accordance with the revised enforcement policy (Federal Register: Feb 9,1999, Volume 64, Number 26, Pages 6388-6391), NOV 98-03-06 is closed.
NRC Inspection Report No. 50-213/98-03 also had described an unresolved item (URI 98-03-07) to track completion of licensee long term actions and to evaluate any dose impact from the stack effluent pathway. This item remains open pending further review.
c.
Conclusions The licensee established, implemented, and maintained an effective program with respect to electronic calibrations, radiological calibrations, system reliability, and tracking and trending.
R5 Staff Training and Qualification in RP&C a.
Insoection Scope (86750) The program of initial and continuing training for workers who handle radioactive materials received or being shipped, in accordance with 49 CFR 172, Subpart H, and for workers who handle, generate, process or ship radioactive waste in accordance with NRC IE Bulletin 79-19 was evaluated. Specific requirements reviewed included: proper identification of all hazardous material (hazmat) employees covered under - 49 CFR 172.702(a) testing program for identified hazmat employees -
content of hazmat training, including function-specific training
l triennial requalification training -
certification of training - This inspection was accomplished by a review of course outlines and lesson plans, verification that all appropriate licensee personnel are included in these training
programs, and discussions with cognizant licensee personnel.
,
, , . . . l b.
Observations and Findinas General radworker training includes generic information for workers who handle radioactive materials throughout the facility. All packaging and shipping of radioactive materialis handled through the radioactive waste materials group of the health physics department. Each member of this staff is provided regular training on the requirements of proper radioactive materials transport and radwaste disposal. The most recent training in this area was conducted by a contractor in May 1998. Additional contractor-provided training is scheduled for February 1999. Some problems were encountered regarding the certification of training records for hazmat employees, as required in 49 CFR 172.704(d)(5). This issue was resolved prior to the close of the inspection period.
c.
Conclusions An effective training program has been established for the training of plant personnel involved in the transport of radioactive materials and the disposal of solid radioactive waste.
R7 Quality Assurance in RP&C Activities I l R7.1 Quality Assurance in Radwaste and Transportation a.
Inspection Scope (86750) The program for the evaluation of performance in radwaste and transportation activities was reviewed to determine if the program met the requirements set forth in 10 CFR and 49 CFR. Quality Assurance (QA) audits, self-assessments and the tracking, trending and resolution of deficiencies was reviewed.
, l l The inspector reviewed audits, surveillances and appraisals previously completed or currently ongoing, and discussed the results of these reviews with cognizant personnel.
b.
Observations and Findinas l An audit of the radwaste/ process control program (PCP) was performed by the CY l Oversight organization during the last half of 1998 (Audit CY-98-A07-01). Seven conditions adverse to quality were identified via this audit and documented as Adverse Condition Reports (ACRs). Subsequent audits conducted by oversight have identified some deficiencies in the ACR process in general, that have also been reflected in the ACRs identified in the PCP audit. These issues include proper classification of the ACRs with regards to significance, and submission of timely responses and corrective actions.
An additional self-assessment was performed internally by members of the radiological engineering staff in the first quarter of 1998 (HPA 98-015). No additional self-assessments have been performed in this area.
( l
A B - . . c.
Conclusions A generally effective program for the identification and tracking of issues related to the solid radweste program has been implemented. Identified deficiencies are tracked until resolution, with the corrective actions appropriately verified. Problems with the classification of issues and the timely implementation of corrective actions have been internally identified.
R7.2 Quality Assurance in the Radioactive Effluents Proaram l a.
Insoection Scope (84750) The, insoection consisted of (1) a review of the 1997 QA audit; (2) a review of surveillances; and (3) a review of responses to ACRs 99-0157 and 99-0171.
b.
Observations and Findinos The 1997 QA audit covered most aspects of the radioactive effluents control program.
Audit team members had a good mix of relevant experience. Responses to audit findings were reasonable. Surveillances helped provide a more performance-based review of the radioactive effluents control program. Several surveillances reviewed activities pertaining to RMS calibration and planned radioactive effluent releases. No significant issues were identified.
l Licensee response to the above-noted ACRs was reasonable and timely. These particular issues were identified and corrective actions were initiated soon enough to preclude them from having regulatory significance.
c.
Conclusions The licensee established, implemented, and maintained an effective QA program for the radioactive effluent control program with respect to audit scope and depth, audit team experience, and response to audit findings.
R8 Miscellaneous Radiation Protection issues R8.1 Status of Previous Radiation Protection items a.
Inspection Scope (71801) i l The purpose of this inspection was to review licensee corrective actions in response to l violations and unresolved items that were identified during the early phase of the i i licensee's site characterization program.
.- . , . . . ! b.
Observations and Findinos The inspector reviewed documentation packages that had been prepared by the licensee to support closure of several RP issues as identified below.
(Closed) Unresolved item 97-08-03: Establishment of 10 CFR 50.75(a) Proaram. Since July 1990, NRC required, through 10 CFR 50.75(g), that licensees maintain records of spills or unusual occurrences that result in significant contamination remaining after remediation efforts in an identified location for a safe and effective decommissioning of the facility. On June 30,1997, the licensee identified that the 10 CFR 50.75(g) decommissioning records file did not contain all the required information. Subsequently, the licensee undertook an extensive historical review to recreate this file, in conjunction with on-site scoping and site characterization. The adequacy of the licensee's decommissioning record file was previously evaluated as part of the NRC's Historical Assessment Report, issued March 26,1998. This item has been resolved by the licensee's current site characterization program; however, it is considered a violation of 10 CFR 50.75(g). Enforcement discretion was exercised in accordance with Section Vll.B.6 of the NRC Enforcement Policy and the violation was not cited as detailed in an NRC letter sent to CYAPCo dated April 5,1999. (NCV 50-213/99 01-02) (Closed) Unresolved item 97-08-05): IE Bulletin 80-10 Samolina and Assessment. This item concemed evaluation of former contamination events that were identified by the licensee's site characterization program. IE Bulletin 80-10 provided guidance to licensees relative to inadvertent release of material as a result of cross contamination or system interfaces. The licensee developed an IE Bulletin 80-10 task force in August 1997, to evaluate spills and unmonitored releases from non-radioactive floor and storm drains. The licensee conducted safety evaluations in accordance with the NRC guidance and evaluated past discharges that were not monitored. A dose assessment was also completed for a 1989 event, which involved a release from the spent fuel building to the lowland area outside the protected area. The inspector reviewed the licensee's revised sampling program and concluded that it met the intent of IE Bulletin 80-10. The dose impact from some of the former spills was previously evaluated as part of the NRC's Historical Site Assessment Report, issued in March 1998. Although dose limits to the public were not exceeded, there was a failure to adequately evaluate systems that had the potential to become contaminated. This item has been resolved and is a violation of TS 6.11, Radiation Protection Program, for failure to follow procedures to control contamination. Enforcement discretion was exercised in accordance with Section Vll.B.6 of the NRC Enforcement Policy and the violation was not cited as detailed in an NRC letter sent to CYAPCo dated April 5,1999. (NCV 50-213/99-01-03) (Closed) Unresolved item 97-08-06: Rsview of Gaseous Effluents from 1979. This item concerned the adequacy of the licensee's stack effluent release report for 1979 and the adequacy of its effluent monitoring capabilities for unplanned conditions. The gaseous effluent monitors were not designed for a vaporized steam release that resulted from a degasifier event in 1979. To account for the vaporized steam portion of the release in the 1979 semi-annual gaseous effluent report, in 1980 the licensee calculated a dose
. . . .. l based on stack sampling data and on-site survey data for localized contamination.
During the NRC Historical Site Assessment, the NRC determined that the licensee's dose assessment did not follow regulatory guidance for particulate contamination over the skin of the whole body. No exposure limits were exceeded. This item has been
resolved and is a violation of 10 CFR Part 20 for failure to adequately evaluate doses l from an unplanned effluent release. Enforcement discretion was exercised in accordance with Section Vll.B.6 of the NRC Enforcement Policy and the violation was not cited as detailed in an NRC letter sent to CYAPCo dated April 5,1999. (NCV 50-l 213/9941-04) l (Closed) Unresolved item 97-08-07: Review of Onsite Surveys from 1979 and 1980.
This item concerned the adequacy of the licensee's contamination monitoring program
during the 1979 and 1980 time period when the facility experienced operational events , that resulted in on-site contamination. The adequacy of the licensee's surveys following ! plant events was previously evaluated as part of the NRC's Historical Assessment Report, issued March 26,1998. Although dose limits to the public were not exceeded, there was a failure to adequately survey or evaluate on-site areas for radioactive l contamination. This item has been resolved and is a violation of 10 CFR Part 20 for l failure to adequately evaluate or survey areas for radiation following unplanned airbome l and liquid releases. Enforcement discretion was exercised in accordance with Section Vll.B.6 of the NRC Enforcement Policy and the violation was not cited as detailed in NRC letter to CYAPCo dated April 5,1999. (NCV 50-213/994145) (Closed) Unresolved item 97-09-04: Assessment of Doses from Past R ! :::: of Contaminated Concrete Blocks and Other Materials. This item involved the licensee's
corrective actions with respect to off-site characterization activities following the identification of contaminated shield blocks and other materials that were released / removed from the restricted area from the site in the 1975 through 1986 periods. The licensee has conducted extensive characterization, remediation, and final j status surveys for a majority of the properties with identified CYAPCo materials.
Although remediation and final status surveys have not been completed for all properties, the licensee completed a bounding radiation dose assessment for potential exposure scenarios to members of the public from the contaminated materials that were i ! released from the facility. The licensee reported that the bounding doses were less than 100 mrem per year, which is the current exposure limit for a member of the public. The NRC requested that the dose assessments be submitted to NRC for a final review. This l item is resolved based on information to date and is a violation of TS 6.11, Radiation l Protection Program, for failure to adequately survey materials being released from the radiological restricted area. Enforcement discretion was exercised in accordance with Section Vll.B.6 of the NRC Enforcement Policy and the violation was not cited as l detailed in NRC letter to CYAPCo dated April 5,1999. (NCV 50-213/994146) ' (Closed) Unresolved item 98-05-01: Dose Assessments. This item involved reviewing l the final dose assessment of two licensee personnel who received an internal uptake of l radioactive material on September 30,1998. The inspector reviewed Internal Dose Assessment reports IDA# 98-003 and IDA# 98-010 for technicians A and B dated
February 11,1999, and February 17,1999, respectively. The licensee's dose i
t
" .. . - . . assessment was thorough and complete. It accounted for transuranics based on an alpha analysis of a fecal sample collected one day post exposure. The analysis also included Pu-241, a pure beta emitter. The inspector noted that an adequate number of bioassay samples were collected in a timely manner following the exposure, permitting a detailed analytical approach to accurately assessing the technician's intemal exposure.
The licensee evaluated the exposures varying the particle size, inhalation to ingestion fraction, and magnitude of uptake of radionuclides to determine the best fit of all available data. Other information from lapel air samples, smear surveys, personnel contamination surveys, Whole Body Count data, urinalysis results, and fecal sample results were used in the analysis. The final exposure was determined to be 0.03 Rem Committed Effective Dose Equivalent (CEDE) and 4.7 Rem Bone Dose for technician A and 0.016 Rem (CEDE) and 2.6 Rem Bone Dose for technician B. These dose assessments are based on an inhalation fraction of 0.1 and an ingestion fraction of 0.9.
The inspector reviewed the NRC Form 5 Equivalent records for each individual to ensure that the personnel records were updated as required. No discrepancies were identified.
The inspector reviewed in detail the methodology of the Dose Assessments and had no concems. The final determined exposures for each technician is less than the applicable annual exposure limits in10 CFR 20.1201 (5 Rem CEDE and 50 Rem bone dose). In addition, the inspector reviewed the licensee's correc+ive actions regarding the omission of Pu-241 from dose assessments of internal uptakes during Transfer Canal work in November 1996. This action is documented in a licensee intemal report (ATS 9900367).
Increases in previously calculated intemal exposures ranged from 11 to 18 percent.
The inspector verified that Updated Radiation Exposure Records were completed for all affected individuals and that the licensee plans to contact each person to explain the change in their official dose record. The dose record updates were completed on April 15,1999. The inspector had no further questions in this matter. This item is closed.
(Closed) Unresolved item 98-05-02): Intemal Uotake. The inspector reviewed the details involving the intemal exposure of two technicians on September 30,1998. Based on interviews, the inspector determined that knowledge of the radiological hazards in the residual heat removal (RHR) pit were known by the RP staff prior to the entry on the aftemoon of September 30,1998. However, the licensee failed to use respiratory protection and a Specification-2 RWP, which were required for entries into areas with greater than 1000 dpm/100 cm* alpha contamination. This represents a failure to follow procedure RPM 2.1-10, Revision 1, Radiation Work Permits. The licensee self-identified this discrepancy and has strengthened its RWP review practices. The inspector reviewed a random number of jobs involving high contamination and determined that the failure to use a Specification-2 RWP and provide respiratory protection was an isolated event. Therefore, this Severity Level IV violation is being treated as a Non-Cited Violation in accordance with Appendix C of the NRC Enforcement Policy. This violation is recorded in the licensee's corrective action program as ACR 98-0852. (NCV 99 01-07) j (Closed) LER 97-19: Compensatory Samolina Freauency Exceeded with Radiation System Monitorina System inoperable. Sampling of gaseous effluents and service water effluents were not initiated within the applicable TS time frame of 12 hours. The cause of this LER was personnel error. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy.
, . . . . . This violation has been corrected and was placed in the licensee's corrective action program as ACR 97-0508. (NCV 50-213/99-01-08) l (Closed) VIO 50-213/98-03-06: Stack Flow and Radiation Monitors. The licensee has calibrated the main stack flow meter (see Section R2.1). The licensee has placed relevant corrective actions into their tracking system. The other corrective actions were described in a letter from CY to the NRC dated September 21,1998. This item is closed.
(Closed) LER 99-01: Main Stack Radiation Monitor R-14A Pressure Compensatina Sianal Not Calibrated. The licensee identified that the pressure transducer for RMS 14A had not been calibrated. The licensee identified this issue in the course of resolving discrepancies related to NOV 50-213/98-03-06 (see Section R2.1) This issue is considered to be an additional example of NOV 50-213/98-03-06 and is not being cited individually. No additional response to NOV 50-213/98-03-06 is required. Corrective actions specific to this issue have already been completed.
(Closed) Unresolved item 98-03-02: Failure to Follow Procedures for Confiauration Control. This item was last discussed in Inspection Report 98-06 where mispositioned sample system valves resulted in the cross-connection of the "A" and "B" Recycle Test Tanks (RTT) during an authorized release of "B" RTT. The licensee's response was provided in a Root Cause Investigation to ACR 98-0952 entitled "lNADVERTENT TRANSFER OF LIQUID RADWASTE FROM "B" RTT TO "A" RTT", dated 10/19/98 (re:11-19-98). The licensee restricted all liquid releases until certain identified actions, including changes to operations and chemistry procedures, walk-down of the waste test tank (WTT) and RTT system, and certain valves were locked close, were completed. The inspector verified that corrective actions were completed as required. The Root Cause Investigation appeared to be comprehensive and addressed safety issues.
The inspector reviewed the liquid waste discharges from the RTT following authorization from licensee management to resume liquid releases. On January 25,1999, it was determined that a chemistry sample of the tank to be discharged following chemical addition and 24-hours of recirculation could not be obtained. An investigation determined that following use of NOP 2.14-23 Rev 1, " Adding Chemicals to Recycle Test Tanks", air j had entered the system and air bound the Recycle Test Pump (RTP ID. No.117-1 A). A ' Temporary Change No. 98-158 was used (apparently for the first time) where air was used to flush water out of the chemical addition tubing to prevent freezing. When the RTP became air bound, no water was re-circulated. Since this also meant that there was no motive force present to complete a liquid release, the inspector concluded that there was no safety significance to this event.
However, the following anomalies were identified. A Condition Report was not prepared for this event until February 2,1999, and after two additional chemical additions occurred. Procedure NOP 2.14-23 did not address the consequences of moding too much air when flushing the chemical addition tubing and the consequences of air binding I the RTP. In addition, a precaution to prevent recurrence of this event was electronically mailed to al, operators prior to the next chemical addition but a Temporary Procedure Change was not prepared for the procedure. The inspector discussed these program
r . . - . . , enhancement issues with the licensee and acknowledged that corrective actions appear to have been effective to prevent recurrence in that information was included in the next revision to NOP 2.14-23 scheduled for PORC that week and interviews with a number of operators confirmed that they were aware of this event. In addition, the inspector observed chemistry and operations personnel on February 4,1999, obtaining a sample from the RTT after chemical addition and 24 hour recirculation. System line-up was determined with hands on verification and independent re-verification. The sample was obtained safely and in accordance with procedures. Communication between chemistry and operations was very good. The inspector identified no further issues.
The corrective actions discussed in Root Cause Investigation ACR 98-0952 appear to have been effective in that subsequent releases from the RTT have occurred without incident. The inspector had no further questions in this area. This item is closed.
I c.
Conclusions The inspector determined that the licensee is making adequate progress to address l NRC identified violations and unresolved items.
IV. Manacement Meetinas . X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management periodically during the inspection, and during a meeting with Mr. R. Mellor and others at the l conclusion of the inspection on April 19,1999. The licensee acknowledged the findings l presented by the inspector. The inspector reviewed with the licensee whether any materials ' examined during the inspection should be considered proprietary. No proprietary information was identified.
X2 Other Significant Management Meetings On March 10,1999, James Wiggins, NRC Region l Deputy Regional Administrator, other NRC 'i Regional Management and staff, and Tom Fredrichs, Project Manager, representing the Office of Nuclear Reactor Regulation met with Mr. Don Davis, Chairman, President and Chief Executive Officer and Russ Mellor, Vice-President, Operations and Decommissioning and members of his staff. The licensee had requested the meeting to discuss the status of the Haddam Neck facility and CY's transition plans for a DOC. Readiness self-assessments for each department and mid-course self-assessments were outlined as some of the tools that CY expects to use during the transition period. Copies of the licensee's presentation are attached l (Attachment 1).
On April 5,1999, CY announced a fixed price contract with Bechtel Power Corporation to ! decommission the Haddam Neck facility. CY expects the transition to Bechtel over the next 6
- months. Decommissioning activities will continue during this transition. The contract also includes options beyond site dismantlement including: operation of the spent fuel pool;
l
[[ ~. .. l.
- . .. I i l' ~ implementation of a dry storage facility at CY; attemate waste management plans if low-level radioactive waste disposal facilities close; re-powering with a gas-fired electric generating plant on a portion of the Haddam Neck site; and determining the impact of a lower site release criteria.
NRC Region I plans to inspect the transition plans and implementation activities over the next s.
l-several months.
{.. l ! I.
l . !
.
! 24-i !. ..
( ' - - i. - , W , . . . PARTIAL LIST OF PERSONS CONTACTED E. Bingham, Engineering R. Brown, Emergency Plan Coordinator
- G. Bouchard, Unit Director J. Bourassa, Manager, Connecticut Yankee Oversight
- M. Cavanaugh, Communications Director D. Davis, President, Chairman, and Chief Executive Officer R. Haight, Radioactive Materials Handling Supervisor K. Hamer, Chemistry Manager
- J. Hasettine, Strategic Planning Director P. Hollenbeck, Site Characterization Supervisor D. Heffernan, Maintenance Manager
- K. Heider, Decommissioning Director R. Lewis, Training Instructor.
- R. Mellor, Vice President Operations and Decommissioning
- R. Mitchell, Operations and Maintenance Manager
- G. van Noordonnen, Nuclear Licensing W. Peterson, Concerns Program Manager S. Racz, Training Supervisor W. Rodgers, Training Instructor
- R. Sexton, Radiation Protection Manager W. Symczack, Engineering J. Tarzia, HP/ Chemistry Technical Support G. Waig, Operations Manager
- Denotes attendance at the exit meeting held on April ig,199g.
INSPECTION PROCEDURES USED . IP 36801: Organization, Management and Cost Controls IP 37801: Safety Reviews, Design Changes, and Modifications at PSRs IP 41500: Training and Qualification Effectiveness IP 71801: Decommissioning Performance and Status Review ~ IP 83750: Occupation Radiation Exposure Controls , IP 84750: Radweste Treatment, and Effluent & Environmental Monitoring l lP 86750: Solid Radioactive Waste & Transportation of Radioactive Waste
, . .. . . .. .. . . .. . ._
_ . . I.
g 's - . , . ITEMS OPEN, CLOSED, AND DISCUSSED .QD80 9941-01 IFl ' Dose Assessment fo60ffsite Locations 99-01-02 NCV Establishment c! O CFR 50.75(g) Program 99-01-03 NCV IE Bulletin 80-10 Sampling and Assessment 99-01-04 NCV - Review of Gaseous Emuents from 1979 99-01-05 NCV Review of Onsite Surveys from 1979 and 1980 ' 9941-06 NCV Assessment of Doses from Past Releases of Contaminated Concrete Blocks and Other Materials - 99-01-07 NCV ' Intemal Uptake 99-01-08 NCV Compensatory Sampling Frequency Exceeded with Radiation System Monitoring System inoperable Closed 97-19 LER Compensatory Sampling Frequency Exceeded with Radiation System Monitoring System inoperable 97-08-03 URI Establishment of 10 CFR 50.75(g) Program 97-08-05 URI IE Bulletin 80-10 Sampling and Assessment 97-08-06 URI Review of Gaseous Emuents from 1979 97 03 07 URI Review of Onsite Surveys from 1979 and 1980 97-06-04 URI - Assessment of Doses from Past Releases of Contaminated Concrete Blocks and Other Materials 98-01-02.
IFl Maintenance Rule. 98-03-02 VIO Failure to Control Plant Configuration 98-03-03 URI Spent Fuel Building Seismic Design Basis 98-03-05 VIO Licensing Basis Discrepancies 98-03-06 VIO Stack Flow and Radiation Monitors 98-05-01 URI Dose Assessments 98-05-02 URI intomal Uptake 99-01-02 NCV Establishment of 10 CFR 50.75(g) Program 99-01-03 NCV IE Bulletin 80-10 Sampling and Assessment 99-01-04 NCV Review of Gaseous Emuents from 1979 i 99-01-05 NCV Review of Onsite Surveys from 1979 and 1980 ' 99-01-06 NCV Assessment of Doses from Past Releases of Contaminated Concrete i Blocks and Other Materials l 99-01-07 NCV Intemal Uptake j 99-01-08 NCV Compensatory Sampling Frequency Exceeded with Radiation System i Monitoring System inoperable 99-01 LER Main Stack Radiation Monitor R-14A Pressure Compensating Signal Not , Calibrated ) Discussed 98-03-07 URI RMS 14 Long Term Action
, . . _.__ _.___-_.-m.-___-___
r . . + ., .. LIST OF ACRONYMS USED ACR Adverse Condition Report ALARA As Low As is Reasonably Achievable CAL Confirmatory Action Letter CDE Committed Dose Equivalent CEDE ' Committed Effective Dose Equivalent CFH Certified Fuel Handler CFR Code O Federal Regulations f CYAPCo Connecticui Yankee Atomic Power Company DAW Dry Active Weste DERO Decommissioning Emergency Response Organization DEP.
Department of Environmental Protection DOC Decommissioning Operations Contractor DOP Dioctyl Phthalate EO Equipment Operator EP Emergency Plan. GET.
General Employee Training HEPA, High Efficiency Particulate HN Haddam Neck HP Health Physics HRA High Radiation Area - lFI inspection Followup item IR-
Inspection Report
JPM Job Performance Measures mrem millirem LER Licensing Event Report LORT Licensed Operator Requalification Training NOV Notice of Violation NRC Nuclear Regulatory Commission ' NU Northeast Utilities PAB Primary Auxiliary Building PCP Process Control Program PDR Public Document Room PORC. Plant Operation Review Committee QA Quality Assurance i RA Radiation Area RCA Radiological Controlled Area RCS Reactor Coolant System RHR Residual Heat Fsemoval. RMS Radiation Monitoring System RP Radiation Protection RP&C Radiological Protection and Chemistry RTP Recycle Test Pump. RTT Recycle Test Tank RWPs Radiation Work Permits RWST Reactor Water Storage Tank -
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