IR 05000213/2005001
| ML052170161 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 08/05/2005 |
| From: | Pangburn G Division of Nuclear Materials Safety I |
| To: | Norton W Connecticut Yankee Atomic Power Co |
| References | |
| 1-2004-032, EA-05-081 IR-05-001 | |
| Download: ML052170161 (23) | |
Text
UNITED STATES ust 5, 2005
SUBJECT:
NRC INSPECTION 05000213/2005001, OFFICE OF INVESTIGATIONS REPORT NO. 1-2004-032 AND NOTICE OF VIOLATION
Dear Mr. Norton:
On March 24, 2005, we completed our on-site inspection activities for an integrated inspection at your Haddam Neck reactor facility of activities authorized by the above listed NRC license.
We discussed our findings with Mr. R. Benner and others of your staff on May 19, 2005, and discussed our disposition of an apparent violation involving radiation protection procedures with you on July 20, 2005. The enclosed report presents the results of this inspection.
During this inspection period, we inspected your operations, maintenance, engineering, and plant support programs, including Independent Spent Fuel Storage Installation (ISFSI)
operations, security, operational health physics, effluent monitoring, radioactive waste management, and transportation. The inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors. We also evaluated preparations for transition to the revised Technical Specifications related to the unloaded Spent Fuel Pool. We considered the programs to be generally adequate.
Also related to this inspection was an investigation completed by the NRCs Office of Investigations (OI) on March 25, 2005. The purpose of the investigation was to determine whether contract employees willfully violated a high radiation area procedure at your facility.
Based on its investigation, OI concluded that a contract foreman willfully violated a posted high radiation area procedure on July 8, 2004, when he directed his work crew to remove a contaminated component from a posted high radiation area (HRA) without Health Physics Department (HP) personnel present as required. The contract foreman was aware that an HP representative needed to be present before any material was moved outside the posted HRA, but proceeded without knowing whether the HP representative was present.
Based on the results of this investigation, the NRC has determined that a violation of NRC requirements occurred and was evaluated in accordance with the NRC Enforcement Policy.
Specifically, the violation involved a failure to adhere to radiation exposure procedures on July 8, 2004. With careless disregard a contractor foreman directed a work crew to remove a stop valve from a posted high radiation area and place it into a sea land container for shipment
Mr. Connecticut Yankee Atomic Power Company offsite, without the presence of HP in accordance with the requirements of the Radiation Protection Program, Technical Specification 6.6.1. Because the safety significance of the violation was low, and there was no actual increased occupational worker radiation exposures, the violation has been classified at Severity Level IV. The NRC considered whether it was appropriate to issue a Non-Cited Violation (NCV), in accordance with Section VI.A.8 of the NRC Enforcement Policy. The NRC considered that you self-identified the violation, took effective corrective actions to resolve the issue and prevent recurrence. However, because the violation was willful and involved a first-line supervisor, the NRC has decided to cite this violation in the enclosed Notice of Violation (Notice) as a Severity Level IV violation consistent with the NRC Enforcement Policy. The circumstances surrounding it are described in more detail in Section R1.1 of the enclosed inspection report.
Two additional Severity Level IV violations were identified as a result of the inspection. One violation involved a failure to install and secure closure devices on a U.S. Department of Transportation Specification 7A, Type A Transfer Cask in accordance with the requirements of 10 CFR 71.87. Because of the low safety significance of this violation, it has been classified at Severity Level IV. Although the violation is not repetitive as a result of inadequate corrective actions, is not willful, and once aware of the violation, was placed in your corrective action program and corrected in a timely manner, the NRC decided to cite this violation in the enclosed Notice, consistent with Section VI.A.8 of the NRC Enforcement Policy, because it was not self-identified. The circumstances surrounding it are described in detail in Section R1.2 of the enclosed inspection report.
The other violation involved a failure to follow procedure SNM 1.4-5 during an attempt to move a Fuel Assembly Sized (FAS) can of Greater Than Class C (GTCC) waste to the Transportable Storage Canister (TSC) as required by 10 CFR 50, Appendix B, Criterion V.
Because of the low safety significance the violation has been classified at Severity Level IV.
This violation is being treated as a NCV, consistent with Section VI.A.8 of the NRC Enforcement Policy, because the violation was self-identified, was placed into your corrective action program and corrected in a timely manner, and was not repetitive nor willful. The NCV is described in detail in Section 01.2 of the enclosed inspection report.
The NRC has concluded that information regarding the reasons for these violations, the corrective actions taken and planned to correct the violations and prevent recurrence, are already adequately addressed in this inspection report. Therefore, you are not required to respond to these violations unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
If you contest these violations or the significance of these violations, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; and the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Mr. Connecticut Yankee Atomic Power Company We appreciate your cooperation with us during this inspection.
Sincerely,
/RA/
George Pangburn, Director Division of Nuclear Material Safety
Enclosures:
1. Inspection Report No. 05000213/2005001 2. Notice of Violation
REGION I==
INSPECTION REPORT Inspection No. 05000213/2005001 Docket Nos. 50-213 & 72-039 License No. DPR-61 Licensee: Connecticut Yankee Atomic Power Company (CYAPCO)
Location: P. O. Box 270 Hartford, CT 06141-0270 Inspection Dates: January 01, 2005 through March 31, 2005 Inspectors: Marjorie McLaughlin, Health Physicist Decommissioning Branch (DB)
Division of Nuclear Materials Safety (DNMS), Region I Laurie Kauffman, Health Physicist DB, DNMS, Region I Approved By: Marie Miller, Chief DB, DNMS, Region I
EXECUTIVE SUMMARY Connecticut Yankee Atomic Power Company NRC Inspection Report No. 05000213/2005001 This integrated inspection report includes aspects of decommissioning activities regarding dismantlement and decommissioning of the facility. The report covers a three-month period of announced safety inspections conducted by three regional staff. The report details reviews and assessments of recent organization changes and spent fuel pool safety including operations of the Independent Spent Fuel Storage Facility. The report also covers plant support activities related to radiation protection, security and safeguards, and radioactive waste management and transportation, including self assessment and quality assurance.
Decommissioning Operations The licensees site organizations were adequately staffed and qualified to support ongoing decontamination, demolition, decommissioning, radioactive waste transportation, and spent fuel activities such as fuel transfer, cask loading, and fuel pool clean-up activities. No safety concerns were identified.
The licensee is generally in compliance with procedures related to Dry Cask Storage of spent nuclear fuel. One procedure violation was identified for failure to stop work and make required notifications when an abnormal condition occurred during movement of Greater Than Class C waste. This is a Severity Level IV violation. Because the Technical Specification (TS) non-compliance was licensee-identified, of low safety significance, entered into the corrective action program, and adequate corrective actions were taken to prevent recurrence, NRC considered this issue as a Non-Cited Violation (NCV), consistent with Section VI.A.8 of the NRC Enforcement Policy.
Plant Support The licensees radiation control program was generally adequate for job planning and preparation, control of radioactive material, surveys and monitoring. In one instance, the licensee failed to adhere to high radiation area procedures in accordance with the requirements of the Radiation Protection Program, Technical Specification 6.6.1. With careless disregard, a contractor foreman directed a work crew to remove a stop valve from a posted high radiation area and place it into a sea land container for shipment offsite, without the presence of Health Physics. This violation has been classified at Severity Level IV violation consistent with the NRC Enforcement Policy.
The licensees implementation of the solid radioactive waste management and radioactive waste transportation programs was generally adequate. Based on the reviewed shipments and field observations, radioactive waste was adequately characterized, classified, stored, packaged, and shipped with one exception. The licensee failed to properly install and secure the primary and secondary lids, and ensure gaskets were free of defects on a US DOT 7A, Type A shipping cask in accordance with NRC regulations. Because this event was of low safety significance, but was not self-identified, it is being cited as a Severity Level IV violation consistent with Section VI.A.8 of the NRC Enforcement Policy.
ii
The licensee maintained an adequate program to identify safety concerns, programmatic weaknesses, and areas of declining performance.
The licensee effectively implemented the security program and was in compliance with the NRC-approved security plans, regulatory requirements, and commitments in response to Orders dated May 23, 2002, October 16, 2002, and August 18, 2004.
The Radioactive Effluent Release Program was adequate and was implemented within the scope of the Radiological Environmental Monitoring Offsite Dose Calculation Manual (REMODCM) and TS.
iii
REPORT DETAILS Summary of Facility Activities The plant was maintained in a permanently shutdown condition during this inspection period.
The transfer of spent fuel to the onsite Independent Spent Fuel Storage Installation (ISFSI) was completed. The ISFSI is fully operational. Dismantlement of steam generator loop skirts and removal of concrete cribbing and rubble in the loop areas of containment were in progress.
Characterization and Final Status Surveys (FSS) were ongoing.
I. Decommissioning Operations O1 Conduct of Operations O1.1 Organization and Management a. Scope (Inspection Procedure (IP) 36801)
The inspector reviewed the Connecticut Yankee (CY) Decommissioning Project Organization changes to determine whether the licensee and contractor organization, staffing, and qualifications were in accordance with regulatory requirements.
b. Observations and Findings The licensee made several changes within the CY Decommissioning Project Organization. A new position, Director of Project Support/ Engineering Manager, was created to integrate Engineering, Planning and Scheduling, and Document Control. Mr. Matthew Marston was assigned to this new position. Concurrently, Mr. Joseph Bourassa was assigned as the Director of Nuclear Safety and Regulatory Affairs and also reports to the President of CY. This position oversees Radiation Protection, Spent Fuel Pool (SFP) projects, Quality Assurance, and Regulatory Affairs. The individuals have extensive decommissioning experience.
Another new position, Manager of Management Oversight, was created to integrate and coordinate the significant decommissioning project activities, such as Operations, Maintenance, and ISFSI activities, and to incorporate SFP projects, including fuel transfer, cask loading, and fuel pool clean-up activities. This position was also created to affect consistency and improve communications within the groups. In addition, the organization under the Decommissioning Manager, have been expanded to incorporate three major projects: Ground Water Source Term Removal, Containment Removal, and Fuel Building Removal. Each project is led by a project manager (PM) and each PM utilizes resources from other organizational areas to plan and implement decommissioning activities.
Effective February 28, 2005, Mr. Harvey Farr was assigned as the Radiation Protection Manager (RPM). The RPM reports to the Director of Nuclear Safety and Regulatory Affairs.
The inspector reviewed the individuals qualifications, including educational background and work history. The inspector noted that this change was made in accordance with Technical Specification (TS) Section 6.3.1.1 for the position of RPM.
Enclosure
c. Conclusion The licensees site organizations were adequately staffed and qualified to support ongoing decontamination, demolition, decommissioning, radioactive waste transportation, and spent fuel activities such as fuel transfer, cask loading, and fuel pool clean-up activities. No safety concerns were identified.
O1.2 Operation of Independent Spent Fuel Storage Installation a. Scope (IP 60855)
The inspector evaluated whether requirements of the Part 72 general license, the Part 50 license, and related regulatory requirements for the NAC International Multi-Purpose Canister (NAC-MPC) Dry Cask Storage System were being met.
b. Observations and Findings The inspector performed performance observations of the following activities: welding of the Transportable Storage Canisters (TSC) port and structural lid; security of Fuel in Transit; placement of the final TSC into the SFP; placement of Greater Than Class C (GTCC) waste in the Fuel Assembly Sized Canisters (FAS cans) from the SFP into the TSC, and the associated post-incident briefing. The inspector noted that personnel performance was adequate with one exception. Procedure SNM 1.4-5 was used to move a FAS can of GTCC waste to the TSC.
SNM 1.4-5 requires work stoppage and contact of the Control Room upon any abnormal condition. Contrary to the procedural precaution step, when the FAS can could not be raised after hitting an FME lid on the TSC, the authorized workers attempted to lower and raise the FAS can three times prior to making any notifications. The licensee conducted a thorough investigation and developed a recovery plan after the incident. In addition, the licensee conducted barrier analysis and wrote a condition report (CR).
Based on the above observation, the inspector determined that the licensees failure to follow SNM 1.4-5 during transfer of GTCC was a violation of 10 CFR 50, Appendix B, Criterion V.
However, because of the low safety significance and the timeliness and effectiveness of licensee corrective actions, the violation is being considered a Non-Cited Violation (NCV)
consistent with Section VI.A.8 of the NRC Enforcement Policy. (NCV 50-213/05-01-01)
The inspector reviewed records related to temperature and radiation monitoring conducted at the ISFSI pad. The inspector held discussions with licensee representatives on records management and the storage of records at two separate locations, and on transition plans for organization changes for ISFSI after March 30, 2005.
c. Conclusions The licensee is generally in compliance with procedures related to Dry Cask Storage of spent nuclear fuel. One procedure violation was identified for failure to stop work and make required notifications when an abnormal condition occurred during movement of GTCC waste. This is a Severity Level IV violation. Because the TS non-compliance was licensee-identified, of low Enclosure
safety significance, entered into the corrective action program, and adequate corrective actions were taken to prevent recurrence, NRC considered this issue as an NCV, consistent with Section VI.A.8 of the NRC Enforcement Policy.
II. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Occupational Radiation Exposure a. Scope (IP 83750)
The licensees occupational radiation safety program was inspected and evaluated against regulatory requirements. Planning and preparation for radiation work was evaluated by reviewing selected active work orders and their associated Radiation Safety Reviews (RSRs),
and attending pre-job briefings. Actual performance and Radiation Protection (RP) coverage of these jobs was observed and assessed for exposure and contamination controls, survey adequacy, and As Low As Is Reasonably Achievable (ALARA). The Radiation Controlled Area (RCA) was inspected for adequacy of postings. The ALARA Program, station exposure performance for 2004 and 2005-to-date, and radiation exposure controls for active jobs were reviewed against regulatory requirements and licensee procedures. The inspector also conducted a follow-up review of the licensees Radiation Control Program against TS 6.6.1 regarding a CR (CR-04-0891) related to a foreman not following posted high radiation procedures.
b. Observations and Findings The inspector evaluated the RSRs and the Radiation Work Permits (RWPs) for Spent Fuel Pool Vacuuming, loading and welding shut the TSCs, and for the cut-out and removal of a 4" primary drain line. The RSRs included direction for exposure and contamination control, dress-out requirements, expected radiological conditions, and exposure estimates. For each activity, the licensee had created a specific RWP with exposure and contamination setpoints. The inspector attended the RP pre-job briefings for SFP vacuuming and for cut-out and removal of the 4" primary drain line. Briefings covered the information in the RSRs and in the RWPs and outlined the work activities that were to take place. The licensee met the requirements for work planning and preparation.
The inspector observed RP technician coverage of welding of the lid on a TSC within a High Radiation Area (HRA), and the subsequent stack-up of the TSC. Positive RP coverage of the workers in the HRA was maintained using a combination of direct observation from outside the posted area and remote monitoring via a camera. The inspector reviewed surveys of the HRA and verified boundary postings. Workers were observed wearing the appropriate dosimetry, and the RP technicians obtained frequent updates of the accumulated exposure. The RP technicians were using appropriate survey equipment, that the inspector verified had been calibrated. No findings of safety significance were identified. The inspector also verified RP Enclosure
postings within the RCA, including the Containment Building, the Spent Fuel Island, and the yard area.
On July 8, 2004, a contract foreman violated a high radiation area procedure, when he directed his work crew to breach a high radiation area boundary, without prior health physics (HP)
authorization. A stop valve, which was the source of the high radiation area, was removed from a posted high radiation area in the foyer area of the containment building and placed into a sea land container for shipment offsite. Upon identifying that the stop valve had been moved across the high radiation area boundary without proper authorization, the HP cleared the work area after the stop value was safely loaded into the container. The licensee immediately suspended work in the foyer area, entered the issue into their corrective action program (CR-04-0891, dated July 8, 2004), and initiated a root cause investigation. The licensee also notified the NRC RI staff of the CR and work stoppage.
The contractor foreman believed he had the authority to move the valve, based on an earlier conversation with the HP. However, he did not actually get a response from the HP stating that the valve could be moved. Based on their investigation, the licensee determined that there were procedural violations caused by a mis-communication between the contract foreman and HP staff. The licensee suspended the foremans RCA access for approximately nine months.
As part of the corrective actions, all workers were retrained on high radiation area procedures and the responsibility of workers and job supervisors, and to stop work if not being conducted safely and in compliance with station procedures.
Based on the above findings, the inspector determined that the licensees failure to adhere to radiation exposure procedures, i.e. movement of a high dose rate component from a posted high radiation area without prior HP approval, is not consistent with the requirements of the Radiation Protection Program, TS 6.6.1. Because the safety significance of the violation was low, and there was no actual increased occupational worker radiation exposures, the violation has been classified at Severity Level IV. Because the violation was willful and involved a first-line supervisor, the NRC has decided to cite this violation consistent with the NRC Enforcement Policy. (VIO 50-213/05-01-02)
c. Conclusions The licensees radiation control program was generally adequate for job planning and preparation, control of radioactive material, surveys and monitoring. In one instance, the licensee failed to adhere to high radiation area procedures in accordance with the requirements of the Radiation Protection Program, T S 6.6.1. With careless disregard, a contractor foreman directed a work crew to remove a stop valve from a posted high radiation area and place it into a sea land container for shipment offsite, without the presence of Health Physics. This violation has been classified at Severity Level IV violation consistent with the NRC Enforcement Policy.
Enclosure
R1.2 Solid Radioactive Waste Management and Transportation of Radioactive Materials a. Scope (IP 86750)
The solid radioactive waste management and radioactive waste transportation programs were evaluated to determine the licensees ability to process, characterize, and transport radioactive waste and material in accordance with NRC and United States Department of Transportation (US DOT) regulations. Selected Low Specific Activity (LSA) radioactive waste shipments from November 2004 through March 2005, including spent resin, primary piping, and dry active waste (DAW), were reviewed. The inspector evaluated two deficiencies identified by the Duratek burial facility in Tennessee regarding an exclusive use shipment, CY Shipment Number 2005-0179, containing LSA material. Additionally, shipping preparations for two americium-beryllium (AmBe) neutron sources were observed relative to the licensees source recovery program.
b. Observations and Findings Selected shipping papers related to LSA radioactive waste shipments included completed copies of a Characterization Report, Straight Bill of Lading, Waste Manifest Shipping Papers (Forms 540 and 541), Emergency Response Information, Survey Record Forms, US DOT Classification Summary and other documentation, such as shipment inspection plans and truck inspection plans. The licensee met the transportation requirements for the selected shipments reviewed.
The licensee implemented the Off-Site Source Recovery Program to transfer two AmBe neutron sources to a licensed facility for disposal. The licensee researched and planned the shipment to safely transport the sources as an exclusive use shipment and used a US DOT 6M Type B drum for the shipment according to regulatory requirements. The inspector observed portions of the transfer of the drum from a shielded culvert to the vehicle and reviewed the shipping papers and support documentation. The inspector verified that the licensee applied the correct markings and labels on the drum, performed an adequate survey of the package and truck, and applied the correct placards on the truck.
The inspector evaluated two deficiencies concerning NRC regulations that were identified by the Duratek burial facility, located in Tennessee. Specifically, exclusive use shipment (CY-2005-0179) containing LSA material (spent resin) was evaluated. On February 1, 2005, the licensee shipped a US DOT Specification 7A,Type A radioactive material transportation cask (shipping cask) to Duratek for burial. On February 3, 2005, Duratek received the shipment and the Radiation Safety Officer subsequently identified two deficiencies in the configuration of the packaging of the shipping cask. The identified deficiencies were: (1) two of the eight ratchet binders on the primary lid were not secured in accordance with the cask-handling procedure and (2) the eight secondary lid hold-down nuts were not installed as required by the cask-handling procedure. On February 9, 2005, Duratek notified the licensee and asserted that the conditions were contrary to NRC requirements in 10 CFR 71.87, Routine Determinations.
The licensee generated a CR (CR-05-0162), incorporated the issue into the Corrective Action Enclosure
Program (CAP) (Section R7.1 of this inspection report), and notified the NRC inspector.
Because this issue was reportable, Duratek also notified the State of Tennessee.
The inspector reviewed the vendor cask-handling procedure. The inspector noted that Sections 7.7 through 7.10 of the procedure provided guidance to properly install primary and secondary lids for the shipping cask, with specific steps for loading the cask cavity, installing the secondary lid onto primary cask lid, inspecting gaskets, tightening lid stud nuts, and preparing the cask and vehicle for shipment. The licensees spent resin transfer project, including shipment of the cask, consisted of several parts and several organizational groups (D&D, Waste Management), each with a specific Work Plan and Inspection Record (WPIR).
The inspector reviewed the WPIRs and noted that the D&D WPIR allowed workers to place the secondary lid onto the primary lid, but did not allow for tightening of the nuts or gasket inspection, which were steps considered to be the responsibility of Waste Management. The steps associated with proper lid installation or gasket inspection had not been incorporated into a Waste Management WPIR.
The licensee performed the radiological surveys to make decisions to meet transportation requirements. The results indicated that the measured radiation and contamination levels were below US DOT limits prior to leaving the site. However, the inspector noted that the licensee initially performed a partial survey while the loaded cask was in storage, and on the shipment date, completed the survey and entered additional data to the original survey record form, without initializing or dating for revised data entries. This practice does not meet industry expectations. The inspector also noted that the waste manifest had been signed and determined, based on interviews and the above observations, that a thorough verification of the package had not been performed prior to shipment. Although contamination levels were below regulatory limits and no significant transportation event had occurred, the licensee did not properly install and secure the primary and secondary lids and ensure gaskets were free of defects on a US DOT Specification 7A, Type A shipping cask, contrary to NRC Regulation 10 CFR 71.87 (c), which states, in part, that the licensee shall determine that each closure device of the packaging, including any required gasket, is properly installed and secured and free of defects.
Based on the above findings, the inspector determined that the licensees failure to properly install and secure the primary and secondary lids and ensure gaskets were free of defects of a US DOT 7A, Type A shipping cask was a violation of the requirements of 10 CFR 71.87 (c).
Because of the low safety significance of this violation, it has been classified at Severity Level IV. The NRC decided to cite this violation, because it was not self-identified. (VIO 50-213/05-01-03)
c. Conclusion The licensees implementation of the solid radioactive waste management and radioactive waste transportation programs was generally adequate. Based on the reviewed shipments and field observations, radioactive waste was adequately characterized, classified, stored, packaged, and shipped with one exception. The licensee failed to properly install and secure the primary and secondary lids, and ensure gaskets were free of defects on a US DOT 7A, Enclosure
Type A shipping cask in accordance with NRC regulations. Because this event was of low safety significance, but was not self-identified, it is being cited as a Severity Level IV violation consistent with Section VI.A.8 of the NRC Enforcement Policy.
R1.3 Radioactive Waste Treatment and Effluent Monitoring a. Inspection Scope (IP 84750)
The inspector evaluated the effectiveness of the licensees radioactive liquid and gaseous effluent control programs through a walk-down of facilities and equipment, the most recent calibration results for radiation monitor -22), selected effluent release permits, projected dose calculations, and associated procedures.
b. Observations and Findings The calibration results for the radiation monitor was within acceptance criteria. The projected dose contribution was performed using the Radiological Environmental Monitoring Offsite Dose Calculation Manual (REMODCM). Counting equipment such as the gamma spectrometry system and the radiation monitor were appropriately calibrated. No findings of safety significance were identified.
c. Conclusions The Radioactive Effluent Release Program was adequate and was implemented within the scope of the REMODCM and TS.
R7 Quality Assurance in RP&C Activities R7.1 Quality Assurance and Surveillance Reports a. Scope (IP 40801)
Quality Assurance (QA) Audit and Surveillance reports were reviewed to determine the licensees capability to self-identify and resolve conditions adverse to quality, and to prevent problems. The inspector reviewed the following surveillances and audits:
QSR-05-013, Packaging of Neutron Sources - Los Alamos - Off Site Recovery QSR-05-020, Augmented Radwaste Inspections QSR-04-156-CY, Review of Postings and Labels QSR-04-162-CY, Radwaste Shipment Documentation Review QSR-05-001, Septic Sand Filter Survey Plans Condition Report (CR-05-0162), relative to CY Shipment Number 2005-0179, containing LSA material was reviewed.
Enclosure
b. Observations and Findings The inspector noted that Nuclear Oversight used Oversight Quality Procedure OQP-4.10, Rev. 11 as guidance for conducting surveillances. The audits and surveillances were well planned and identified areas for improvement. Identified issues were entered into the CAP and appropriately dispositioned.
The inspector also reviewed Condition Report (CR-05-0162), relative to the two deficiencies identified by the Duratek burial facility in Tennessee regarding an exclusive use shipment, CY Shipment Number 2005-0179, containing LSA material. (See Section R1.2 of this inspection report for details.) The inspector noted that the licensee conducted an evaluation to identify any missed or failed barriers that could have prevented the event from occurring. The licensee incorporated a shipment inspection plan to the cask-handling procedure to promote and enhance independent verification of each item to be inspected. The licensee increased quality assurance oversight surveillances regarding radioactive waste shipments. The inspector determined that the corrective actions were timely and adequate to prevent a similar occurrence.
c. Conclusion The licensee maintained an adequate program to identify safety concerns, programmatic weaknesses, and areas of declining performance.
S1 Conduct of Security and Safeguards Activities S1.1 Physical Security Program a. Scope (IP 81700)
The inspector verified and assessed the licensees implementation of the NRC-approved security plans, regulatory requirements, and commitments in response to Orders dated May 23, 2002, October 16, 2002, and August 18, 2004. The inspector reviewed Access Authorization of personnel the Protected Area (PA), security manning of alarm stations, and controls for the Owner-Controlled Area (OCA) and the PA. Following the completion of onsite inspection activities, the inspector also reviewed the licensees revised response to the August 18, 2004, Order that was submitted to NRC by letter dated April 26, 2005.
b. Observations and Findings The inspector performed performance observations of the security force conducting PA controls and staffing of alarm stations. The inspector reviewed Safeguards Logs for conducting OCA controls and program documentation of access authorization and re-authorization. The inspector also reviewed with the Security Manager the additional details that would be required to address how personnel were authorized to access the PA in response to the August 18, 2004. The inspector confirmed that the list of personnel that were authorized access had been Enclosure
grand-fathered under the provisions of the Order dated August 18, 2004. No safety concerns were identified.
c. Conclusions The licensee effectively implemented the security program and was in compliance with the NRC-approved security plans, regulatory requirements, and commitments in response to Orders dated May 23, 2002, October 16, 2002, and August 18, 2004.
III. Management Meetings X1 Exit Meeting The inspectors presented the inspection results to representatives of the licensees staff at the end of each inspection visit during the inspection period. On May 19, 2005, a summary of the inspection findings for the entire inspection period was presented to Mr. R. Benner and others of your staff. A subsequent discussion was held on July 20, 2005 with Mr. to discuss the disposition of the apparent violation regarding a high radiation area procedure violation. Although proprietary items were reviewed during the inspection, no proprietary information is presented in this report. Licensee representatives acknowledged the inspection findings.
Enclosure
A-1 PARTIAL LIST OF PERSONS CONTACTED Licensee and Contractor Staff
- J. Arnold, Staff Assistant
- R. Benner, Director of Decommissioning G. Bouchard, Management Oversight Manager, Nuclear Safety and Regulatory Affairs J. Bourassa, Director, Nuclear Safety and Regulatory Affairs
- P. Clark, Regulatory Affairs Engineer, Regulatory Affairs
- J. Fan, Fuel Transfer Manager
- H. Farr, Radiation Protection Manager, Nuclear Safety and Regulatory Affairs
- R. Joshi, Regulatory Affairs Engineer
- J. Marchi, Quality Assurance Manager M. Marston, Director of Project Support and Engineering Manager
- J. McCarthy, Engineer, Site Closure, Decommissioning R. Mitchell, ISFSI Manager W. Norton, President, CYAPCO T. Peacock, Manager of Site Closure, Decommissioning D. Roberson, Health Physics Supervisor, Radiation Protection A. Barry, Nuclear Safety Engineer, Quality Assurance J. Tarzia, Technical Assistant to Director, Nuclear Safety and Regulatory Affairs
- G. van Noordennen, Regulatory Affairs Manager
- R. Yetter, FSS Project Lead, Site Closure, Decommissioning R. Haight, Waste Management Coordinator, Waste Management, Decommissioning R. Porter, Waste Management Supervisor, Waste Management, Decommissioning C. Young, Waste Management Engineer, Waste Management, Decommissioning State of Connecticut M. Firsick, Connecticut DEP
- These individuals participated in the exit briefing held on May 19, 2005 Attachment
A-2 INSPECTION PROCEDURES AND TEMPORARY INSTRUCTIONS USED IP 36801 Organization, Management, and Cost Controls IP 40801 Self Assessment, Auditing, and Corrective Actions IP 60855 Operation of Independent Spent Fuel Storage Installation IP 71801 Decommissioning Performance and Status Review IP 81700 Physical Security Program IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPEN, CLOSED, AND DISCUSSED Opened None Opened and Closed 05000213/2005001-01 NCV Failure to follow SNM 1.4-5 procedure in accordance with 10 CFR 50, Appendix B, Criterion V 05000213/2005001-02 VIO Failure to adhere to Radiation Control Program procedures in accordance with Technical Specifications 6.6.1 05000213/2005001-03 VIO Failure to properly install and secure the primary and secondary lids of a US DOT Specification 7A, Type A shipping cask in accordance with 10 CFR 71.87 (c)
Discussed None Attachment
A-3 LIST OF ACRONYMS USED ALARA As Low As Is Reasonably Achievable AmBe Americium-beryllium CAP Corrective Action Program CR Condition Report CY Connecticut Yankee CYAPCO Connecticut Yankee Atomic Power Company DAW Dry Active Waste DB Decommissioning Branch DNMS Division of Nuclear Materials and Safety DOT Department of Transportation FSAR Final Safety Analysis Report FAS Can Fuel Assembly Sized Canisters FSS Final Status Surveys GTCC Greater Than Class C HP Health Physics HRA High Radiation Area IP Inspection Procedure ISFSI Independent Spent Fuel Storage Installation LSA Low Specific Activity NAC-MPC NAC International Multi-Purpose Canister NCV Non-Cited Violation Notice Notice of Violation PDR Public Document Room PM Plant Manager QA Quality Assurance RCA Radiologically Controlled Area REMODCM Radiological Environmental Monitoring Offsite Dose Calculation Manual RP Radiation Protection RP&C Radiation Protection & Chemistry RPM Radiation Protection Manager RSRs Radiation Safety Reviews RWPs Radiation Work Permits SFB Spent Fuel Building SFP Spent Fuel Pool TS Technical Specifications TSC Transportable Storage Canisters US DOT United States Department of Transportation WPIR Work Plan and Inspection Record Attachment