IR 05000213/2006002
| ML063560253 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/19/2006 |
| From: | Roberts M Decommissioning Branch I |
| To: | Norton W Connecticut Yankee Atomic Power Co |
| References | |
| IR-06-002 | |
| Download: ML063560253 (15) | |
Text
UNITED STATES ber 19, 2006
SUBJECT:
INSPECTION 05000213/2006002, CONNECTICUT YANKEE ATOMIC POWER COMPANY, EAST HAMPTON, CONNECTICUT SITE
Dear Mr. Norton:
The NRC has completed an announced inspection at your East Hampton, CT facility, which covered an inspection period that began on June 1, 2006, and concluded on December 19, 2006. The findings of the inspection were discussed with you and members of your staff upon the conclusion of our onsite inspections on June 29 and August 25, 2006, an in-office inspection on July 28, 2006, and during a telephone conversation on December 19, 2006. The enclosed report (enclosure 1) presents the results of that inspection.
Your decommissioning activities related to organization, corrective action, maintenance and surveillance, final status survey, occupational exposure controls, and solid radioactive waste treatment and transportation programs were inspected during this inspection period. The operation of your Independent Spent Fuel Storage Facility was also inspected. The inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations made by the inspector. In addition, the inspection included the analysis of soil samples by the NRC contractor, Oak Ridge Institute for Science and Education (ORISE). A copy of the analytical report is also enclosed (enclosure 2). With respect to these inspection areas, we noted that you maintained an effective program for decommissioning the site and for the safe storage of spent fuel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred during this inspection period. The violation involved the failure to survey equipment and materials being released from the Radiologically Controlled Area (RCA) for unrestricted use in accordance with the requirements of Radiation Protection Manual (RPM) procedure, Contamination Control Program (RPM 2.7-0), Section 4.9.2. This violation is being dispositioned as a Non-Cited Violation (NCV), consistent with the NRC Enforcement Policy. The NCV is described in Section 2.1 of the enclosed inspection report. No response to the above NCV is required.
In accordance with Section 2.390 of the NRCs Rules and Practices, Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room (PDR) and will be accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. No reply to this letter is required.
Sincerely,
/RA/
Mark Roberts, Branch Chief Decommissioning Branch Division of Nuclear Materials Safety
Enclosures:
1. NRC Region I Inspection Report No. 05000213/2006002 2. Analytical Results for Two Soil Samples Collected March 2, 2006 from Connecticut Yankee, Haddam Neck, Connecticut [ADAMS A
REGION I==
INSPECTION REPORT Inspection No. 05000213/2006002 Docket No. 05000213 License No. DPR-61 Licensee: Connecticut Yankee Location: 326 Injun Hollow Road East Hampton, CT 06424-3099 Inspection Dates: June 26 - 29, 2006 July 24 - 28, 2006 August 21 - 25, 2006 Inspector: Laurie A. Kauffman, Health Physicist Decommissioning Branch (DB)
Division of Nuclear Materials Safety (DNMS)
Approved By: Mark Roberts, Branch Chief DB, DNMS Enclosure
EXECUTIVE SUMMARY
Connecticut Yankee
NRC Inspection Report No. 05000213/2006002 This integrated inspection includes aspects of decommissioning activities regarding dismantlement and decommissioning of the facility, and storage of spent fuel. The report covers announced safety inspections conducted by one regional inspector and contractor assistance provided by the Oak Ridge Institute for Science and Education (ORISE)
Environmental Survey and Site Assessment Program (ESSAP). The report covers evaluations of your decommissioning activities related to organization and management, the corrective action program, the maintenance and surveillance program, the Independent Spent Fuel Storage Installation (ISFSI) program, the radiation protection program, the decommissioning performance and final status survey programs, and the solid radioactive waste treatment and transportation programs.
Facilities and Management Control The licensees organization adequately supported decommissioning activities and management provided effective oversight. The licensee maintained an adequate Corrective Action Program to identify and resolve issues. The licensee maintained an effective program regarding ISFSI operations. The licensee maintained an adequate maintenance and surveillance program for the safe operation of radiation monitoring and effluent control equipment and remaining equipment important to decommissioning activities.
Radiation Protection Program The licensee maintained a generally effective radiation control program. However, the licensee identified several examples where tools, items, and small articles crossed the Radiologically Controlled Area (RCA) boundary without a radiological survey. This is a violation of procedure Contamination Control Program (RPM 2.7-0), Section 4.9.2 and is being considered a Severity Level IV, Non-Cited Violation consistent with the NRC Enforcement Policy.
Decommissioning Performance and Final Status Surveys The licensee conducted decommissioning activities in accordance with the approved License Termination Plan (LTP) requirements. The licensee effectively implemented sampling procedures and protocols to support the final status survey program.
Radioactive Waste Management The licensee effectively implemented the solid radioactive waste management and transportation programs.
ii
REPORT DETAILS
1.0 Facilities and Management Control 1.1 Organization and Management
a. Inspection Scope
(Inspection Procedure (IP) 36801)
Recent decommissioning organization changes since February 2006 were evaluated to determine the effectiveness of the Connecticut Yankee (CY) management oversight on waste management and overall decommissioning activities. The inspector assessed the effectiveness of management oversight through observations in the field, attendance at Management Review Team meetings, and interviews with management and staff.
b. Observations and Findings
No findings of significance were identified.
Effective February 2006, the former Director of Site Closure and Project Support had been assigned to Yankee Rowe, and the responsibilities of that position had been assumed by the Manager of Regulatory Affairs. In May 2006, the position of Director of Decommissioning had been eliminated and the Waste Management organization had been moved under the Executive Director of Business Operations. The individuals in the new positions were knowledgeable of the NRC requirements for their respective responsibilities. The inspector noted that the decrease in management positions reflected the decrease in decommissioning activities.
c. Conclusion The licensees organization adequately supported decommissioning activities and management provided effective oversight.
1.2 Corrective Action Program
a. Inspection Scope
(IP 40801)
The Corrective Action Program (CAP) was evaluated to determine the licensees ability to identify, resolve, and prevent the recurrence of conditions and issues that degrade safety or the quality of decommissioning activities. Condition reports (CRs) from June -
September 2006 were selected randomly and by potential safety significance. The inspector evaluated the CRs based on the nature of the issues and the licensees ability to correctly characterize, disposition, and complete corrective actions.
b. Observations and Findings
No findings of significance were identified.
The inspector evaluated the CRs (CR-06-138, CR-06-140, and CR-06-152) related to contaminated tools and equipment found outside of the RCA boundary and noted that the licensee completed an extent of condition evaluation regarding RCA boundary controls. Details of this issue are documented in Section 2.1 of this inspection report.
The licensee appropriately closed this issue under their CAP. The inspector also reviewed the CRs (CR-06-0066 and CR-06-0069) related to the identification of radioactive material on certain areas of the peninsula. The inspector noted that the licensee completed an investigation. The investigation was thorough and the conclusions were reasonable. Details of this issue are documented in Section 3.2 of this inspection report. The licensee appropriately closed this issue under their CAP.
c. Conclusions
The licensee maintained an adequate CAP to identify and resolve issues.
1.4 Maintenance and Surveillance
a. Inspection Scope
(IP 62801)
The Preventive Maintenance (PM) and Surveillance Programs were evaluated to verify the operation of radiation monitoring equipment and remaining equipment important to decommissioning activities. The inspector reviewed the maintenance and surveillance procedures and inspection records from April through August 2006 for the effluent tank system, truck monitor, and yard crane, and inspected the equipment in the field.
b. Observations and Findings
No findings of significance were identified.
Preventive maintenance and routine surveillances were performed within frequencies specified in the procedures and results were within the acceptance criteria. The equipment was operable and was being maintained according to the PM program.
c. Conclusions
The licensee maintained an adequate maintenance and surveillance program for the safe operation of radiation monitoring and effluent control equipment and the remaining equipment important to decommissioning activities.
1.5 Operation of Independent Spent Fuel Storage Installation (ISFSI)
a. Inspection Scope
(IP 60855)
The inspector reviewed procedures and interviewed selected staff who support ISFSI operations. The inspector reviewed temperature logs, and maintenance and surveillance records, from April through August 2006. The temperature logs were reviewed to verify the integrity of the fuel storage canisters and determine whether radiation exposure rates and contamination levels were within the prescribed limits of the licensees procedures. The inspector also reviewed the most recent changes to the ISFSI Emergency Operating Procedures, Emergency Planning Administration (EO-1),and Non-Emergency Event Assessment (EO-6).
b. Observations and Findings
No findings of significance were identified.
The licensee implemented routine maintenance and surveillance activities in accordance with the associated procedures. The licensee monitored temperature of the fuel storage canisters and recorded the data in accordance with the required frequencies specified in the associated procedure. The temperature results were within the acceptance criteria.
Radiation exposure rates and contamination levels of the fuel storage canisters were within the prescribed limits of the procedures. The changes to the procedures, EO-1 and EO-6, were administrative and did not impact the intent of the procedures.
c. Conclusions
The licensee maintained an effective program regarding ISFSI operations.
2.0 Plant Support 2.1 Occupational Radiation Exposure
a. Inspection Scope
(IP 83750)
The scope of this inspection area included an assessment of the effectiveness of the radiation control program. The inspector reviewed selected calibration and source check results for survey instrumentation and portable air monitors. The inspector conducted field observations of Radiation Protection (RP) technicians performing radiological surveys in the Radiologically Controlled Area (RCA) and selected land areas on the peninsula. The inspector observed radiation worker practices and radiological postings and boundaries. The inspector reviewed the licensees evaluation following the self-identification of a small article being passed across the RCA boundary rope without first requesting a radiological survey, and the subsequent self-identification of three tools and 31 small items with fixed radioactive contamination found outside of the RCA.
b. Observations and Findings
Calibration and source check results for the survey instrumentation and portable air monitors were within the licensees acceptance criteria. RP technician performance for conducting radiological surveys in the RCA, including in the Spent Fuel Building (SFB),containment, east trench, and in selected land areas on the peninsula were adequate.
Radiation worker practices and adherence to the RCA boundary requirements were generally adequate. However, on May 18, 2006, a contract maintenance worker was seen passing a small article, destined for the maintenance truck, across the RCA boundary rope without first requesting a radiological survey. RP staff immediately stopped the work, surveyed the article, and determined that the item was not contaminated. As a result of this observation, RP staff surveyed every tool and article on the truck (approximately 1000 items) and identified three items with fixed contamination. According to the Radiation Protection Manual (RPM) procedure, Vehicle and Material Release from Radiologically Controlled Areas and CY Site (RPM 2.2-22), a positive response is anything detectable above background. CY defines an acceptable background count rate for in-field surveys to be no greater than 300 counts per minute (cpm) using a pancake-type GM detector. For this survey, the background count rate was determined to be 100 cpm using a Ludlum Model 12 ratemeter connected to a HP210 probe. Contaminated items identified were a crescent wrench (600 corrected counts per minute1 (ccpm)), a hammer (800 ccpm), and an allen wrench set (1400 ccpm). The licensee also determined that the truck was allowed to routinely leave the site (for example, at the end of the day or at lunch) without requiring any radiation surveys because the truck had not entered the RCA. Because the truck was taken to the home of a maintenance worker, the licensee conducted a survey of the maintenance workers garage and home and did not detect any contamination. Based on the survey results, the licensee notified the NRC of an inadvertent release of radioactively contaminated material per ISFSI Emergency Operating Procedure EO-6, Non-Emergency Event Assessment, Revision 5.
The licensee initiated an extent of condition evaluation of the radiation worker program, with a focus on the contamination control program. During the evaluation, the licensee reviewed the survey records for a trailer-mounted sub-surface soil sampling device (earth probe) and the associated toolbox items that were sent to Yankee Rowe (YR) on May 3, 2006. On June 5, 2006, a YR RP technician surveyed the probe and the items in the toolbox using a Ludlum RM-14 with HP210 probe. YR noted that a shackle and pin (clevis), used to connect the trailer to a vehicle to transport the earth probe onsite, had 600 ccpm fixed contamination localized in the threaded areas. Connecticut Yankee (CY) evaluated the YR results, and, on June 7, 2006, determined that the clevis may have originated from CY, and therefore, notified the NRC of a second inadvertent release of radioactively contaminated material, per the EO-6 procedure.
As part of the extent of condition evaluation, the licensee also conducted a review of several CRs from 2004 through 2006 related to contaminated tools and items that had been found outside of the RCA, and conducted a radiological survey of every tool and item stored outside of the RCA. Based on the CR review, the licensee noted that the corrective actions were either ineffectively implemented or inadequately addressed for several CRs. The inspector noted that the radiological survey was thorough. The licensee surveyed 6,287 items and, of those items, 31 were identified with low levels of The value corrected counts per minute is calculated by subtracting the background (cpm) from the total counts per minute observed on the survey meter, for example: 700 cpm total - 100 cpm background = 600 ccpm.
contamination. The licensee identified that the RP procedures, the RCA physical boundary, and radiation worker culture was in need of improvement. The inspector also noted that the licensee fortified the RCA boundary by replacing the rope with a chain-linked fence and establishing a single access control point. The licensee also initiated procedure changes and increased communication between RP and radiation workers.
The inspector reviewed the licensees radiation protection and contamination control programs and associated procedures, and noted that the procedure, Contamination Control Program (RPM 2.7-0), Section 4.9.2, requires, in part, that equipment and materials being released from the RCA for unrestricted use shall be surveyed for radioactive contamination. Contrary to the RPM 2.7-0 requirement, on May 18, 2006, a radiation worker passed an item across the RCA boundary without first requesting a radiological survey. Also, based on the conclusions of the licensees evaluation that 31 tools and items were subsequently identified with fixed contamination outside of the RCA boundary, the inspector determined that over a period of time, the licensee conducted inadequate surveys or evaluations of equipment and materials released from the RCA for unrestricted use. Failure to survey or conduct adequate surveys of equipment and materials prior to release from the RCA for unrestricted use, is a violation of procedure, Contamination Control Program (RPM 2.7-0), Section 4.9.2.
(NCV 0500213/2006002/01)
Because this issue was self-identified; resulted in a low potential for worker overexposure and there was no spread of radioactive material offsite; was not willful; and corrective actions were timely and effective, the violation is being considered a Severity Level IV, Non-Cited Violation, consistent with the NRC Enforcement Policy.
c. Conclusions
The licensee maintained a generally effective radiation control program. However, the licensee identified several examples where tools, items, and small articles crossed the RCA boundary without a radiological survey. This is a violation of the procedure Contamination Control Program (RPM 2.7-0), Section 4.9.2 and is being considered a Severity Level IV, Non-Cited Violation consistent with the NRC Enforcement Policy.
3.0 Decommissioning Performance and Final Status Surveys 3.1 Decommissioning Performance
a. Inspection Scope
(IP 71801)
The inspector conducted site tours and held discussions with the licensee to evaluate the status of decommissioning activities and to verify that the licensee was conducting decommissioning activities in accordance with the LTP. The inspector also reviewed the licensees evaluation regarding the self-identification of buried drums in Survey Unit (SU) 9520-0002. The inspector sent soil samples collected from this SU to the NRCs contractor, ORISE, to verify the licensees results and compare the results to the licensees Derived Concentration Guidelines Levels (DCGLs) in the approved LTP.
b. Observations and Findings
No findings of significance were identified.
The licensee completed demolition of the containment building and has been loading the debris into trucks for disposal. The licensee excavated the ground under the former SFB and collected concrete cores for the basement fill dose model calculations. In September 2006, the licensee submitted the core results and the calculations to the NRC for review. The results of the review will be discussed with the licensee in December 2006. The licensee also began the dismantlement and removal of equipment and components from the Radwaste Reduction Facility (RRF).
In February 2006, during a scheduled excavation of the septic system that was located in the leach field of SU 9520-0002, the licensee discovered buried drums that contained turbine blades with fixed radioactive contamination. The licensee conducted an investigation and concluded that the blades were from the Low Pressure (LP) turbine and had been buried in the 1970s. The inspector reviewed the licensees report and agreed with their assessment. The licensee collected two soil samples beneath the blades for radioactivity analysis. No radioactive contamination was identified. The inspector sent the same two soil samples to ORISE for analysis to verify the licensees results. The results were below the licensees DCGLs.
Specific details of the ORISE analysis are contained in the ORISE Report, Analytical Results for Two Soil Samples Collected March 2, 2006 from Connecticut Yankee, Haddam Neck, Connecticut [Inspection Report No. DPR-61/20060001][RFTA No.
06-001], which is enclosed. [ADAMS Accession Number ML061370464]
c. Conclusions
The licensee conducted decommissioning activities in accordance with the approved LTP requirements.
3.2 Inspection of Final Status Surveys (FSS)
a. Inspection Scope
(IP 83801)
The scope of this inspection area was to conduct confirmatory measurements in SUs where the licensee had completed FSS field activities. The inspector reviewed the licensees chain of custody and sample storage areas for adequacy of procedure implementation and sample preservation.
b. Observations and Findings
No findings of significance were identified.
On April 25 and 26, 2006, ORISE conducted surface gamma scans and collected soil samples in the four SUs of 9527. ORISE noted high background radiation exposure rates in a portion of SU 9527-0003 near the parking lot where the licensee maintained shipping containers with radioactive waste. ORISE also noted high background radiation exposure rates in a portion of SU 9527-0004 near the RRF, where the licensee maintained a Locked High Radiation Area (LHRA). The inspector discussed this with the licensee, reviewed the survey reports, and verified that the background radiation exposure rates were lower when the licensee conducted final surveys in these SUs. On August 22 and 23, 2006, ORISE conducted a second survey in SUs 9527-0003 and 9527-0004 after the licensee removed containers that were the source of the high background radiation exposure rate.
The licensee submitted Final Status Survey Report (FSSR) - Phase III, dated May 4, 2006, to NRC for review. The Phase III report included the following Survey Areas:
9521-Southwest Pond; 9527-East Mountain Side; 9528-Southwest Mountain Side; and 9531-South End of Peninsula. The inspector and NRC headquarters staff reviewed the report and compared survey and soil sample results with the ORISE results. The NRC noted that the licensees method for determining elevated areas and the description of operational DCGLs was not clear. On June 29, 2006, the NRC discussed these issues with the licensee. The licensee revised and resubmitted the Phase III FSSR, Revision 1, dated September 21, 2006. The NRC headquarters staff is currently reviewing the licensees revised Phase III FSSR. The results of the Phase III report review will be discussed with the licensee and will be documented in the next inspection report. The ORISE reports are also under review and will be publicly available and documented in the next inspection report.
During the prior inspection period, the inspector noted that previously analyzed soil and sediment samples were stored in plastic bags and that some of the bags were torn. The contents of these samples were spilling out onto the shelves. This matter was discussed with the licensee and the licensee corrected the issue.
c. Conclusions
The licensee effectively implemented sampling procedures and protocols to support the final status survey program.
4.0 Radioactive Waste Management 4.1 Radioactive Waste Management and Transportation
a. Inspection Scope
(IP 86750)
The scope of this inspection area was to evaluate the Solid Radioactive Waste Management and Transportation programs and to determine whether the licensee properly processed, packaged, stored, and shipped radioactive materials. The inspector reviewed selected Low Specific Activity radioactive waste shipments from June through August 2006, including dry active waste and low-level radioactive demolition debris. The inspector observed the licensee conduct surveys and prepare shipments for transport.
b. Observations and Findings
No findings of significance were identified.
The selected radioactive waste shipment records included completed copies of Characterization Reports, Waste Manifest Shipping papers, Emergency Response Information, Survey Record Forms, and related documentation, including shipment inspection plans and truck inspection records. The licensee met the applicable radiation protection and transportation requirements for the shipments reviewed.
c. Conclusions
The licensee effectively implemented the solid radioactive waste management and transportation programs.
5.0 Exit Meeting The inspectors presented the inspection results to representatives of the licensees staff at the conclusion of onsite inspections on June 29 and August 25, 2006, and an in-office inspection on July 28, 2006. On December 19, 2006, a summary of the inspection findings for the entire inspection period was presented to the licensee. Licensee representatives acknowledged the inspection findings. Although proprietary items were reviewed during the inspection, no proprietary information is presented in this report.
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
- J. Arnold, Executive Staff Assistant
- B. Couture, Project Support, Resource Conservation and Recovery Act Coordinator
- J. Fan, Project Support and Engineering Manager
- R. Haight, Waste Management Coordinator, Waste Management, Decommissioning
- R. Hoak, Decommissioning Manager
- M. Marston, Director, Project Support/Environmental Compliance Officer
- J. McCarthy, Engineer, FSS
- R. McGrath, Radiation Protection/FSS Manager
- R. Mitchell, ISFSI/Unit Manager
- W. Norton, President and Chief Executive Officer
- C. Newson, Technical Support Supervisor/FSS
- R. Porter, Waste Management Supervisor, Waste Management, Decommissioning
- E. Seargent, QA/QC Engineering Lead, Quality Assurance
- T. Smith, Executive Director of Business Operations
- C. Young, Waste Management Engineer, Waste Management, Decommissioning
- G. vanNoordennen, Manager, Nuclear Safety/Regulatory Affairs
State of Connecticut
- These individuals participated in the exit briefing held on December 19, 2006.
INSPECTION PROCEDURES USED
36801 Organization, Management, and Cost Controls
40801 Self-Assessment, Auditing, and Corrective Action
60855 Operation of Independent Spent Fuel Storage Installation
2801 Maintenance and Surveillance
71801 Decommissioning Performance and Status Reviews
83750 Occupational Radiation Exposure
83801 Inspection of Final Status Surveys
86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials
ITEMS OPEN, CLOSED, AND DISCUSSED
Items Opened:
05000213/2006002/01 NCV Failure to survey equipment and materials being
released from the RCA for unrestricted use in
accordance with the requirements of Radiation
Protection Manual (RPM) procedure,
Contamination Control Program (RPM 2.7-0),
Section 4.9.2.
Items Closed:
05000213/2006002/01 NCV Failure to survey equipment and materials being
released from the RCA for unrestricted use in
accordance with the requirements of Radiation
Protection Manual (RPM) procedure,
Contamination Control Program (RPM 2.7-0),
Section 4.9.2.
Items Discussed:
None
LIST OF ACRONYMS USED
CAP Corrective Action Program
ccpm corrected counts per minute
cpm counts per minute
CR Condition Reports
CY Connecticut Yankee
CYAPCO Connecticut Yankee Atomic Power Company
DCGL Derived Concentration Guideline Levels
ESSAP Environmental Survey and Site Assessment Program
FSS Final Status Survey
FSSR Final Status Survey Report
IP Inspection Procedure
ISFSI Independent Spent Fuel Storage Installation
LHRA Locked High Radiation Area
LTP License Termination Plan
LP Low Pressure
ORISE Oak Ridge Institute for Science and Education
PM Preventive Maintenance
QAP Quality Assurance Program
RCA Radiologically Controlled Area
RP Radiation Protection
RPM Radiation Protection Manager
RRF Radwaste Reduction Facility
RWP Radiation Work Permit
SFB Spent Fuel Building
SU Survey Unit
YR Yankee Rowe
Attachment