IR 05000309/1997006
| ML20210N969 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 08/14/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20210N956 | List: |
| References | |
| 50-309-97-06, 50-309-97-6, NUDOCS 9708260214 | |
| Download: ML20210N969 (22) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No:
50 309-License No:
DPR-36 Report No:
50-309/97-06 Licensee:
Maine Yankee Atomic Power Company (MYAPC)
Facility:
Maine Yankee Atomic Power Station Location:
Bailey Point Wiscasset, Maine Dates:
June 9,1997 to July 27,1997 Inspectors:
Jimi T. Yeroken, Senior Resident inspector Division of Reactor Projects
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Richard A. Rasmussen, Resident inspector Division of Reactor Projects Handolph C. Ragland, Radiation Specialist
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Division of Reactor Safety
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Approved by:
. Curtis J. Cowgill, Ill, Chief Projects Branch No. 5 Division of Reactor Projects-
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9708260214 970814 PDR ADOCK 05000309 G
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EXECUTIVE SUMMARY Maine Yankee Atomic Powar Company NRC Inspection Report 50-309/97 06 This integrated inspection included aspects of licensee operatians, engineering, maintenance, and plant support. The report covers a 7. week period of resident inspection; in addition, it includes the results of an announced inspection by a regional radiation specialist inspector.
Operations Operators demonstrated lack of focus and caused two instances of valve lineup errors i which resulted in a violation of NRC requirements (VIO 50 309/97 06 01), in addition, the timeliness of reporting errors was weak since the earlier problem of June 26, was not reported and entered in the learning bank until the inadvertent transfer of 10,000 gallons of water transfer to the RWST was being discussed on June 30. Once the significance of the errors was understood, plant management properly intervened and quickly instituted a stand down in operations to conduct a detail review of the issues prior to proceeding with further plant activities. However, it appeared that the corrective actions implemented to resolve the operator performance issues were not adequately received at the working level as evidenced by the following: During a subsequent evolution to lower the reactor vessel level, there was a lack of good pre planning and willingness of the operations crew to attempt to compensate for this short coming without sacrificing the schedule, in other areas, operators performed well and maintained the systems required to curnort spent fuel pool cooling appropriately. Core offload was completed satisfactorily and fuel movement in the spent fuel pool to support ongoing reracking activities were conducted well, Maintenance Maintenance activities were well controlled and maintenance procedures were properly implemented. Personnel displayed good knowledge of the equipment designated as the protected train for spent fuel pool cooling. Personnel were knowledgeable of the procedures and performed testing and maintenance activities well. There was good management and technical oversight.
Plant Suonort in the area of plant support, there was adequate health physics (HP) support and radiclo0 cal control preparations provided for planned work; radiological boundaries were i
well defined and maintained; and the HP staff was effectively tracking and trending personnel contaminations. However, the practice of storirig long handled tools that had not been verified as acceptable for use, immediately adjacent to the fuel pool was considered a poor practice, il I
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TABLE OF CONTENTS l. O per a tion s..................................................... 1
Conduct of Operations.................................... 1 01.1 General Comments (71707)........................... 1
Operator Knowledge and Performance......................... 1 04.1 Valve Lineup Errors................................. 1 04.2 Fuel Movement in Spent Fuel Pool
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04.3 Reactor Vessel Draining.............................. 5 11. M aint ena n c e................................................... 6 M1 Conduct of Maintenance
.................................. 6 M4 Maintenance Staff Knowledge and Performance.................. 6 M4.1 Loop Isolation Valve Maintenance....................... 6 M4.2 Safety injection Tank Testing.......................... 7 Ill. Engineering.................................................... 8 E1 Conduct of Engineering
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E1.1 General Comments
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I V. pla nt S upport.................................................. 8 R8.2 (Closed) URI 50 309/96 06-04, Review of Post Accident S ampling Syst em.................................. 16 V. Management Meetings........................................... 16 X1 Exit Me e ting Sum m a ry................................... 16 X3 Management Meeting Summary............................ 16 PARTI AL LIST OF PERSONS CONTACTED............................... 17 INSPECTION PROCEDURES U3ED..................................... 18 ITEMS OPENED, CLOSED, AND DISCUSSED...................... [...... 18 LIST O F AC RO NYM S U S E D......................................... 19 iil i
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a Beoort Details Summarv of Plant Status This inspection period began with Maine Yankes in a plant preservation mode pending decisions by the owners regarding a future sale or decommissioning of the plant. The focus of the ongoing work was to complete items required to optimize shutdown safety.
The offload of the fuel from the reactor vessel to the spent fuel pool was completed on June 19,1997. During the remainder of the period Maine Yankee focused their limited resources on completing maintenance activities in containment, l. Operations
Conduct of Operations'
01.1 General Comments (71707)
Using inspection procedure 71707, the inspectors conducted reviews of ongoing plant operations. Operators maintained the systems required to support spent fuel pool cooling appropriately. Core offload was completed satisfactorily and fuel movement in ti e spent fuel pool to support ongoing teracking activities were conducted well. However, instances of " Lack of Attention to Detail" that resulted in equipment / system malfunction were noted.
Operator Knowledge and Performance 04.1 Valve Lineuo Errors a.
inspection Scope (71707)
Shift operators made two valve lineup errors in systems required for current plant conditions, in one case, the error resulted in an unplanned diversion of about 10,000 gallons of water from the upender pit to the Refueling Water Storage Tank
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(RWST). In the other case, the error resulted in a trip of the purification pump when it was started without suction flow, b.
Observations and Findinos
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On June 28,1997, operators inadvertently diverted approximately 10,000 gallons of water from the upender pit (adjacent to the reactor cavity) to the RWST. This occurred due to incorrect valvo lineup. Operators wero attempting to place the RWST in the recirculation mode in accordance with Operations Procedure, OP 1-11-8, RWST Makeup, Recirculation and Purification using purification pump, P 8. This
' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report cuttine. Individual reports aro not expected to address all outline topics.
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was deemed necessary following several planned evolutions that had diverted water from the reactor cavity to the RWST. During the system alignment for placing the RWST in recirculation, the operator incorrectly opened the pump's suction valve (CPU 9) from the upender pit instead of it's suction valve (CPU 24) from the RWST as required in step 6.3.4 of the procedure. This error was not detected until the pump had been operating for about half an hour and a control room operator noticed the RWST levelincreasing. The evolution was then stopped and the valves proparly aligned. However, operators found that the levelin the upender had decreased about four feet (from about one foot below the cavity floor to about five feet below the floor). The RWST's volume had increased from approximately 323,00 gallons to 332,00 gallons. The level was near it's capacity of 345,000 gallons.
During another event, earlier on June 26,1997, operators had also misaligned a valve during a planned drain down of the cavity, in that event, an operator had f ailed to properly open a suction valve (CPU 2) to the purification pump, P 8, as
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required by procedure 1-17 4, Cavity Draining, Step 6.3.25, prior to starting the pump. When started, the pump tripped due to lack of suction flow. The valve was subsequently opened and the evolution completed.
The event that caused the diversion of approximately 10,000 gallons of watsr into the RWST was discussed at the next management meeting on June 30,1997, as a learning bank issue (No. 97-02909). It was during this discussion that operetione management raised the issue involving the earlier valve lineup error that had caused the pump trip. That issue was later entered in the learning bank also (No. 97-02919). Additionally, there were severalless significant events such as documentation errors on valve lineups during the same period. Because these events appeared to be due to !sek of focus on the part of operators, management instituted a stand down in plant operations pending results obtained by an ovent review team assembled to investigate the events in the Operations department.
Meanwhile, only work associated with systems, structures and components of the spent fuel pool cooling and necessary support systems were allowed. A:so allowed were surveillance and related activities to maintain compliance with the technical specifications and activities required to maintain the plant in a safe condition as deemed necessary by the Plant Shift Superintendent.
On July 1,1997, Maine Yankee's senior management including the vice-president of Operations, the vice president of Engineering and the managers of Operations, Quality Programs, System Engineering, and the acting Plant Manager, held a telephone conference call with the NRC to discuss the issue. The discussion focused on the immediate actions taken and those actions that would have to be accomplished prior to lifting the im,70 sed stand down in plant activities.
The inspector inspected the accessible areas of the RWSt and the valves involved to ascertain that there were no unresolved hazards and that the systems were properly restored to their proper status. The inspector reviewed the control room and radiation protection logs to asses Maine Yankee's documentation and follow up of the problem. The control room log reflected the sequence of events and documented the problems. The radiation protection shift log reflected the actions
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taken to ascertain acceptable dose rates around the cavity and RWST following earlier planned transfer of water from the cavity to the RWST. Also, radiation control techalcians conducted dose assessments of the charging floor area and found no change in dose rates following the unplanned water transfer. However, it was not until questioned by the inspector that a survey of the area around the l
RWST was conducted. That survey also revealed no elevated dose rates. Radiation j
protection management rationale for not previously conducting a survey around the tank area following the unplanned transfer wa a that previous survey results following planned transfer of large quantity of water into the tank had shown no substantial dose rate. And therefore, they had not expected the addition of approximately 10,000 gallons water to cause any radiological concern.
Maine Yankee completed a root cause evaluation report on July 19,1997. Af ter the report had been approved by the Plant Operations Review Committee (PORC),
Maine Yankee held a telephone conference call with the NRC on July 22,1997.
The discussion focused on Maine Yankee's accomplishment of the immediate corrective actions, the planned long term corrective actions, the result of the root cause evaluation, and management's plan to lift the imposed operations stand down. Based on the inspectors' initial review of the root cause, discussion with licensee management, and observations of plant activities, no concerns were expressed regarding the lifting of the stand down.
The issues involving the misalignment of valves were identified as significant weaknesses in operator performance. Technical Specification 5.8.2 requires, in part, that written procedures shall be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, (Rev.
2), February 1978. Regulatory Guide 1.33, (Revision 2), dated February 1978, recommends in Appendix "A", Section 3, procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems, that instructions for energizing, filling, venting, draining, startup, shutdown, and changing modes of operation should be prepared for safety related systems. Maine Yankee Procedure No OP 1-11-8, Refueling Water Storage Tank (RWST) Makeup, Recirculation and Purification, step 6.3.4, requires valve CPU 9 from the Refuel Cavity to be shut, and valve CPU 24 from the RWST to be opened, prior to starting pump P-8, to place the RWST in the
" Recirculation Purification Mode." Also, Maine Yankee Procedure 1 17-4, Cavity Draining, Step 6.3.25, requires valve CPU-2 to be opened prior to starting the purification pump to transfer water from the cavity to the RWST via Spent Fuel Pool purification. These two events were violations of plant procedures and together constitute a violation of Technical Specification 5.8.2.
(VIO 50 309/97 06 01)
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Conclusion Operators c'emonstrated lack of focus and caused two instances of valve lineup errors that isulted in a violation. In addition, the earlier error of June 26, was not reported ai
.1tered in the learning bank in a timely manner, and it was not until the inadvertent transfer of 10,000 gallons of water transfer to the RWST was being discussed on June 30, that it was brought up and then entered into the learning bank.
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Once the significance of the errors was understood, plant management demonstrated good safety perspective in quickly instituting an operations stand down to conduct a detail review of the issues prior to proceeding with further plant activities.
04.2 Fuel Movement in Soent Fuel Pool a.
Insoection Scope (71707,607101 Following the lifting of the operations stand down, one of the first activities resumed by operations was movement of fuelin the spent fuel pool in support of the rerack project. The inspector observed operations performance during this evolution, b.
Observations and findinas On July 23,1997, operations resumed movement of fuel bundles in the spent fuel pool. To assure the evolution was conducted properly, a senior person from operations was appointr.d as the fuel move coordinator. This coordinator was assigned to oversee the evolution and assure allissues were properly addressed and resolved. As part of the corrective actions for the stand down, this evolution was only performed on day shift.
A longstanding practice at Maine Yankee has been for operators to use what is termed rough copies of procedures in the field and transcribe the recorded data to the smooth or record copy at the end of the shift. However, during the evaluation of recent operator errors it was determined that this practice lead to transcription errors and in most cases was unnecessary. As one of the cortective actions for the operations stand down, procedure 1200 9, Operations Department Procedure implementation, Compliance and Review, was revised to provide guidance on minimizing the transcription of data.
However, during observation of fuel movement in the spent fuel pool on July 24, 1997, the inspector observed that operators performing and documenting the fuel movement were using a rough copy that was subsequently transcribed to a smooth copy in the control room. The operator stated that the procedure allowed transcription and he had elected to use the rough copy because the data sheets sometimes become contaminated during fuel moves. The inspector noted that in this case the rough data sheets were not contaminated and therefore could have been retained.
Additionally, because the data sheets were considered rough, the sheets were not filled in as formally as the smooth copy. Lines were used to indicate the continuation of the date vica writing the date in the required blocks. The operations procedure on transcription required that an operator second check the transcription for accuracy. In this case, fuel movement required two operators to initial the page.
The operator performing the transcription assumed the second coerator was performing a review of the transcription when the smooth data sheett were initiated
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at the end of the shift. However, the second operator was not aware that *.e was performing a validation of the entire transcription.
Supervisors overseeing the fuel moves were not aware of the use of the rough
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copies or the transcription of the data. After questioning by the inspector, the plant shift superintendent (PSS) reviewed a transcribed data sheet and found a minor discrepancy involving an erroneous date. The transcription of data had also been performed for fuel moves conducted the previous day. The inspector discussed these observations with operations management. Operations management directed that a learning bank entry be made and the previous guidance and expectations would be re-evaluated, c.
Conclusions Fuel movement in the spent fuel pool was one of the first and the most significant evolutions performed by operations following the termination of the stand down. In general, the evolution was well controlled and performed safely. However, the inspector considered the inconsistent implementation of the revised guidance on procedure use an indication that recent corrective actions implemented to resolve the operator performance issues were not fully offective.
04.3 Reactor Vessel Drainina a.
Insoection Scone (71707)
On July 25,1997, Maine Yankee performed a procedure to lower reactor vessel level to support planned maintenance activities. The inspector observed the preparations and brisfing for this evolution.
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Observations and findinas Operations was required to drain approximately 50,000 gallons of water from the reactor vessel and reactor coolant piping to support valve maintenance and the radiographic inspection of a residual heat removal system piping nozzle. Operations procedure 4-1-70, Draining the Reactor Vessel to Below the Loops with no Fuel in the Core, required a modification to assure loop two would be drained with the core to allow the planned maintenance.
Although operations knew of the requirement for the procedure change several days prior to the evolution, the change was not completed and issued until just prior to the use of the change. The inspector reviewed the change and found that it was technically adequate and processed in accordance with plant procedures. However, the handwritten procedure change continued several steps written in the mergins with arrows indicating the placement on the page which made the change appear confusing.
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The inspector had several concerns which were discussed with the operations manager. The procedure change was prepared by the on shift crew, issued, briefed
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and performed with very little time for review. The quality of the change was poor and could have presented a challenge to operators. The sequence of events seemed rushed and contrary to the managernent expectations outlined during the recent operations stand down. Following this discussion the operations manager stopped the evolution, had the procedure change typed, and reissued the revision prior to continuing.
The subsequent pre-evolution brief was done well with the appropriate safety focus and management oversight. The draining evolution was completed as planned with no problem, c.
Conclusions This evolution demonstrated a lack of pre-planning and the willingness of the operations crew to attempt to compensate for this short coming without sacrificing the schedule. The poor quality of the procedure change and lack of pre planning were noteworthy because the operations stand down to improve operator
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performance had been lifted only four days prior to this event.
11. Maintenance M1 Conduct of Maintenance M1.1 General Comm9nts During the period maintenance activities were well controlled and maintenance procedures were properly implemented. Maintenance personnel interviewed displayed good knowledge of the equipment designated as the protected train for spent fuel pool cooling. Portions of the following maintenance and surveillance items were observed. No discrepancies were identified.
WO 97 02740-00 Modify CR 9 Cable Reel WO 97-02919 00 Install Control Room Fire Barrier Seals 35105 Testing of 480 volt Circuit Breakers M4 Maintenance Staff Knowledge and Performance M4.1 Loon isolation Valve Maintenance
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inspection Scope (62707)
Inspections and repacking of valve RC-M 21, a loop two isolation valve, were being performed as part of the maintenance activities with the core off loaded. The inspector observed portions of this maintenance.
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Observations and findinas The maintenance on valve RC-M-21 was planned to correct stem leakage and to inspect the valve for damage which could have resulted from the previous failure of the torque switch on January 7,1997. The details of the torque switch failure are documented in NRC Inspection Report 50 309/96 14.
Mechanics working on the valve were knowledgeable of the valve construction, the details associated with the packing installation and the work packages.
Additionally, good radworker practices were observed during the performance of the job. A remote camera was utilized by health physics to monitor activities at the job site without entering the radiation area.
Detailed measurements of the valve stem were taken and Maine Yankee concluded that no valve damage occurred as a result of the overtorque event. The results of the measurements were appropriately documented in the work packago.
After the completion of the repacking, the valve was tested using the Motor Power
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Monitor (MPM) unit. The MPM is a computer based system that measures motor current and voltage to determine the electrical power being used by the valve operator. The engineer was able to compare this data with the previous data from the valve and with similar valves. The testing was appropriately controlled and performed in accordance with the procedure.
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Conclusions Maintenance demonstrated excellent knowledge of the job, work package, and appropriate ALARA awareness during work on the loop two stop valve. The subsequent testing was appropriately controlled and performed in accordance with the procedure.
M4.2 Safety Inlection Tank TvE D2 a,
jngncction Scoce (61726)
On June 23,1997, the inspector observed the pre shift brief and portions of the tests conducted to meet the inservice test requirements for the safety injection tank
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discharge and header check valves, b.
Observations and findinas Procedure 3.17.8.9, Safety injection Tank Discharge Check Valves / Safety injection Header Check Valves Full Stroke Exercise, was utilized to perform the test. The test involved lowering cavity water level, establishing the initial pressure and level in the safety injection tanks, and un-isolating the safety injection tanks. The test was performed after the completion of the core offload to eliminate the potential for any interruption of core coolin _ - _ _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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Because the test was infrequently performed, Maine Yankee invoked their procedure for special controls during infrequent tests and evolutions. This procedure required a special management brief and additional management oversight. Additionally, a member of the engineering staff was on station as the technical test advisor. The brief included managements expectations, an overview of the evolution, details of communications, contingency actions and past problems.
Testing was conducted well with good oversight, formal and concise communications and procedural adherence. Because the procedure used strip chart recorders to record data, a dry run was performed to assure personnel activating the recorders understood the countdown and started the recorders on cue. No anomalies were identified during the test, c.
Conclusignll Personnel performing the test were knowledgeable of the procedure. Testing was conducted in a formal manner with notable management and technical oversight.
111. Enaineerina E1 Conduct of Engineering E1.1 General Comments On occasions, the inspectors met with members of the engineering organization to discuss the status of engineering issues, and the plans and staffing of the department. Some of the topics discussed were the planned improvements in the Safety Evaluation (50.59) process, notable planned designs (HELB, Cable Separation), engineering programs (IST, MOV), engineering systems approach, and engineering improvement plans, Other specific issues were discussed, such as the efforts to address the problems with the 480 volts circuit breakers, in general, the inspectors noted that the department personnel demonstrated good safety perspective and provided good support to the plant.
[V. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Occuoational Radiation Exoosure Review a.
Inspection Scona (83750)
Reviews were performed of occupational radiation exposure. Specific areas reviewed included pre job planning; contamination controls; status of facilities and
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equipment; organization and administration; and facility conditions versus the requirements in the UFSA.. _ _ _ _ _. _ _ _ _ _ _ _ _ _ _
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Observa1}2np and Findinas Major refueling outage activities had been placed on hold due to a management imposed work suspension. This included steam generator work, refueling, and major plant modifications. Examples of work that remained on the work schedule included maintenance on miscellaneous valves, including severalloop stop valves, partial reactor cavity drain down, and various housekeeping activities, ypive Work
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The inspector attended pre job planning meetings for work scheduled on several loop stop valves. Thorough planning was performed to identify specific details of work scope, methods to efficiently conduct work, and the necessary radinjogical controls. Notable discussion topics included use of shielding; use of a high pressure low volume water spray tool to loosen valve packing; use of mockups; use of HEPA filters and water spray to control airbo6ne activity; schedule sequence; stay times; and dose estimates. The inspector noted that the health physics technical support supervisor was the driving force for the meeting and there was good participation by the attendees.
Cavity Drain Down The inspector discussed radiological control plans for partial cavity drain down with members of the HP staff. Topics were generally limited to controls for the potential generation of airborne radioactivity and did not include valve line up or flow paths.
Plant history showed thet signifi&t airborne activity would not be generated as long as the cavity floor remained covered with water. Based on this information, the HP staff planned to monitor airborne activity with continuous air monitoring equipment and to periodically monitor radiation levels around the reactor cavity, in the event that airborne activity increased, sprayers would be used to suppress particulate act{vity, in the event radiation levels increased at the top of the cavity wall, preparations were made to use long handled tools to move a suspected source to the upender pit.
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Conclusl2D Based on this review, the inspector concluded that radiological control pre-job planning was good and adequate preparations were being made for radiologically complex work.
R1.2 Contamination Control a.
Inspection Scooe (83750)
A review was performed of contamination controls. Information was gathered by reviews of radiological survey data, personnel contamint. tion reports, specific learning bank issues related to contamination controls, tours through the facility, and discussions with cognizant personnel.
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Observations and Findinag A review was performed of radiological survey data for the vapor conta!nment. The inspector noted that general area contamination levels were generally low. For example, contamination levels in the outer annulus of the vapor containment were being maintained less than 10,000 dpm/100 cm'.
The inspector reviewed graphs generated to track and trend personnel contamination events. Graphs demonstrated that the HP staff closely tracked and evaluated personnel contamination events to identify trends and monitor performance. Examples included graphs of contamination events per month and year, by department, by activity, by location of contamination on skin or clothing, by suspected cause, and the number of hours personnel worked on radiation work permits per contamination event. For 1997, the data suggested that the majority of personnel contamination events were due to relatively low level cont:mination (i.e.,
less than 1000 corrected counts per minute as measured with a Eberline HP 210 probe); the majority of contamination events resulted from discrete particles rather than distributed contamination; the majority of personnel contamination events involved members of the maintenance and engineering support (steam generator work) staffs; and the number of radiation work permit (RWP) hours worked per personnel contamination event had increased (improved) when compared to previous years history.
During a review of personnel contamination reports, a health physics supervisor identified several jobs, such as shielding and scaffolding installation where minor personnel contaminations events had been anticipated and occurred. These jobs involved strenuous work in high radiation areas (0.5 2.5 R/h), with elevated temperatures (approximately 85 degrees Fahrenheit), and elevated conth.nination levels (approximately 50,000 80,000 dpm/100 cm'). In order to address heat stress concerns, single rather than double layers of protective clothing (PCs) were utilized. The HP supervisor stated that use of single Pcs allowed the individuals to work faster and resulted in lower overall radiation doses to the workers. Several personnel contaminations did subsequently occur when contamination leached through protective clothing that was wet with perspiration. Personnel contamination levels were generally low (e.g., less than 10,000 dpm/100 cm'), and the individuals were successfully decontaminated upon exit from the rostricted area.
Based on this set of circumstances, the inspector concluded that the decision to use a single layer of protective clothing was a reasonable application of the ALARA concept.
Learnina Bank issue 97-02097 The inspector reviewed Learning Bank issue 97 02097, in which elevated-radioactivity was detected in sand located in the back yard of the restricted area.
The HP radwaste coordinator stated that the area in question was previously evaluated in accordance with 10 CFR 50.75 (g),'and it was concluded that the residual soil contamination, located within the restricted area, could be lef t in place until decommissioning of the plant, at which time permanent disposal of the
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contaminated soil must be addressed by Maine Yankee. The inspector noted that documentation of this review was included in the 10 CFR 50.76(g) file in preparation for future dscommissioning. Corrective actions to address the loose contaminated sand included re sealing the area in question with asphalt and performing a 10 CFR 50.7C (g) file review. The inspector examined the area and observed that a scalant had been recently applied to the surface. The inspector also observed radiation surveys obtained in an adjacent area and noted that one location had a dose rate of 6 mR/h on contact with the asphalt. The HP tadwaste supervisor stated that radiological surveys of this location showed that the contamination was fixed in the asphalt, and not loose. The radiation protection manager stated that plans had been made to acquire a specialized instrument to perform a detailed survey of the entire back yard cf the restricted area, but that action had been placed on hold due to c management imposed suspension of work. Based on this information, the inspector concluded that appropriate actions had been initiated in response to the learning bank issue.
Elimination of Use of Friskers at the Back Yard of tite Restricted Area The HP technical support supervisor informed the inspector that the requirement to use portable contamination monitors (friskers) at the restricted area back yard doors had been eliminated. This was based on the following:
the back yard of the restricted area was not a routine restricted area release point, and any materials released from the restricted area still had to be thoroughly surveyed for radioactive contamination;
multiple years of personnel contamination monitoring data at the back yard door had demonstrated that contamination was not being tracked to back yard areas via personnel foot traffic; the potential release of radioactive material to off site areas via this pathway
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the putential release of radioactive material would continue to be monitored by routine surveys of sticky pads placed at entrances to backyard areas.
The plant manager added that the HP staff was seeking ways to become more efficient and eliminate unnecessary requirements, and after careful study, the requirement to use personnel contamination monitoring equipment to enter the back yard of the restricted areas was determined to be unnecessary.
Based on the information provided, the inspector agreed that it was unlikely that elimination of the personal contamination monitoring requirement for the back yard of the rastricted area would result in a significant unmonitored release of radioactive material to off site areas, or in a significant undetected exposure of personnel to contamination. The inspector noted that while there was no regulatory concern relative to the licensee's cecision, the action essent5tly eliminated a barrier to
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potential spread as contamination, and an opportunity to monitor the effectiveness of personnel work practices and radiological control implementation.
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Conclusions Based on this review, the inspector made the following conclusions:
The HP staff was effectively tracking and trending personnel contaminations, and decontamination efforts had resulted in reduced contamination levels in the vapor containment.
Although the decision for eliminating the personnel contamination monitoring
requirement for the back yard of the restricted area did not result in a regulatory concern, it did diminish opportunities for early detection of problems in work practices and radiological controls.
R1.3 Storane of Fuel Pool Tools a.
Insoection Scone (837501 t
The inspector reviewed practices for storing long handled tools at the fuel pool.
Information was gathered through tours at the fuel pool, discussions with members of the health physics and reactor engineering staffs, and reviews of procedural guidance and other documents, b.
Observations and Findinos The inspector toured the fuel pool area and observed various long handled tools stored in racks adjacent to the fuel pool. The tools were wrapped in plastic and many were labeled with hand written tags indicating HP Hold." A reactor engineer stated that the "HP Hold" labels were placed on long handled tools that had not yet been inspected to verify that the tools were properly vented or shielded to avoid potential radiation streaming. The inspector inquired as to what controls were in place to ensure that unvented/ unshielded long handled tools were not used in the fuel pool. The reactor engineer stated, and the inspector verified, that procedure O-16 3, " Work Order Process" included a requirement for the work order planner to ensure that long handled tools used in the fuel pool were properly vented or shielded; that the plant manager had sent out a supervisory communication bulletin to specifically address the issue; and that health physica staff members were knowledgeable of and sensitive to this issue, due in part to a radiological incident report (RIR 95-036) written in 1995. The inspector then reviewed RIR 95-036 that was initiated by health physics in 1995, after questions were raised regarding the use of properly vented / shielded long handled tools in the fuel pool. The inspector noted that various actions had been taken to address this concern including performance of an inspection to verify that alllong handled tools that were in use were properly vented / shielded; handwritten "HP Hold" labels were attached to all long handled tools that had not been inspected to verify proper venting / shielding; and plant communications were issued to increase awareness of the issue.
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However, the inspector noted that one of the actions had not been completei This action was to identify, inspect and permanently label / tag alllong handled tools that could potentially be used in the fuel pool. The reactor engineer stated that sithough the action item had not been completed, all applicable long handled tools. vere either verified acceptable for use or labeled with an "HP Hold" label. The reactor engineer also stated that both health physics a.ed reactor engineering were involved in the inspection process, but that a formalinspection and certification process had not been established. The reactor engineer also stated that the action item to identify, inspect, and label or tag all applicable tools at Maine Yankee would be accomplished, but that a target date for completion had not been established.
c.
Conclusion Based on this review, the inspector concluded the following.
Procedural guidance and health physics precautions were adequate to ensure
that no unvented/ unshielded tools that could resu't in radiation streaming were used in the fuel pool.
The storage of long handled tools immediately adjacent to the fuel pool, that
were not certified as being properly vented / shielded for use in the fuel pool was considered a poor practice, and the lack of a formalinspection process for verifying that a long handled tool was properly vented / shielded for use in the fuel pool was considered a weakness.
R2 Status of RP&C Facilities and Equipment a.
insoection Scoce (83750)
The inspector performed an evaluation of radiological control boundaries and housekeeping. Information was gathered through tours of the primary auxiliary building (PAB), the vapor containment (VC), and the hot machine shop, reviews of radiological survey data, and interviews with plant workers, b.
Qhservations and Findinan Radiological boundaries were well delineated with radiological postings, rope, tape, and physical barriers. Contaminated crea boundaries were well controlled and extension cords and service lines crossing contaminated area boundaries were well secured. High radiation areas were clearly posted, and locked high radiation areas were securely locked and controlled. No discrepancies in radiological boundaries or high radiation area access controls were identified, in addition, the inspector reviewed radiological survey data posted at the entrance to the vapor containment and noted that survey data maps were complete, clear and legible, and useful for ALARA planning purposes, a
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Overall, housekeeping in restricted areas was good. The hot shop showed significant improvement over previous inspections in that miscellaneous tools and equipment had been removed, and floor surfaces had been painted. The inspector observed personnel cleaning various areas inside the restricted area including removing excess debris from the restricted area yard, removing scaffolding from containment, and mopping various areas within the plant. Some miscellaneous scaffolding and equipment were observed in various areas of the plant due to a management imposed work suspension; however, walkways and aisles were clear, c.
Conclusions Dased on this review, the inspector made the following conclusions:
Radiological boundaries including radiation areas, high radiation areas, and contaminated areas were well defined and maintained, and conditions of housekeeping were good.
R6 RP&C Organization and Administration a.
Insnection Scone (8375Q1 The inspector performed a review to deterrnine if adequate HP staffing was available to support planned work and emergency responus functions. The inspector also reviewed the qualifications of a newly appointed HP technical support supervisor. Information was gathered through discussions with cognizant personnel, by reviews of HP work schedules, and by a review of a resume for the newly appointed HP technical support supervisor, b.
Observations and Findinas Staffina The majority of major refueling outage work including steam generator work, refueling, and major modification work had been temporarily suspended; as a result, HP technician contractor staffing had been eliminated. The radiological controls organization was operating with a staff of 1819 HP technicians to cover 3 shifts, on a 24-hour basis. All major work was scheduled on day shift, and only one HP technician was scheduled for weekends, evenings and back shift. To ensure that adequate radiological control oversight and support was provided for radiologically complex work, HP supervision developed a " guideline for support of unscheduled work." This guideline essentially required all work involving system breaches, high radiation area work, or work involving expenditure of significant HP resources to be on the plant work schedule, if the wcrk was not on the schedule, the schedule had to be modified by the shift outage coordinator, and/or HP support had to be approved by HP supervision.
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l The inspector also reviewed Maine Yankee's Emergency Plan Table 5.1, which listed the Emergency Plan Organization Transition Matrix and NUREG 0054,
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" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans
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and Preparedness in Support of Nuclear Power Plants." Dased on this review, the l
inspcctor determined that it was acceptable for Maine Yankee to have only one HP shift technician on back shift as long as additional support could be obtained within a timely manner.
The inspector also noted that Maine Yankee had hired an individual to act as an HP technical support supervisor. The inspector reviewed the qualifications dc::umented in the individual's resume and determined that the individual was qualified for the position in accordance with ANSI /ANS 3.1 1987, " Selection, Qualification and Training for Personnel for Nuclear Power Plants," and brought good experience to the organization.
c.
C_onclusions Based on this review the inspectors concluded the following:
Health physics technician staffing was adequate to support ongoing work e
and emergency response functions, The newly appointed HP technical support supervisor was qualified for the e
position in accordance with ANSI /ANS 3.1 1987, " Selection, Qualification and Training for Personnel for Nuclear Power Plants," and brought good experience to the organization.
R8 Miscellaneous RP&C lssues R8.1 Violation 50-309/9614-05 (Closed)
VIO 50 309/9614-05, " Failure to Follow Contamination Control Procedures" (Individual did not remove gloves after reaching across a contaminated area boundary). The inspector verified that corrective actions described in the licensee's Reply to Notice of Violation letter, dated April 25,1997, to be reasonable and complete:
Procedure 9 5100 Radiological Contaminant Control, Rev. 6, had been revised to allow reaching across a contamination control boundary under defined circumstances that were not likely to result in the spread of contamination and were controlled by HP; and RP Guideline RPG-002, Rev.1 was revised to provide guidance for
circumstances in which workers could reach across a contaminated area boundary.
The inspector also reviewed an attendance roster that documented that HP technicians had been briefed on the subject. No similar problems were identified.
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This item is closed.
R8.2 (Closed) URI 50 309/96 06 04, Review of Post Accident Samolina Svstem a.
Insoection Scope (92904,71750)
This unresolved it6m was opened because, at the time of the Inspection Maine Yankee had not performed a trial run of a procedure to assure the capability of the post accident sample system (PASS) to sample via the charging system and to return flow to the primary system via the charging system. The inspector reviewed the completed procedure which documented this capability.
b.
Observations and fitHf!Qat Unresolved item 96 06 04 was opened because Maine Yankee had not documented a functional test of the ability to sample from the charging pump discharge path and to return the flow to the charging system.
Procedure 711, Post Accident Sampling Panel Operation (During Accident Conditions), revision 10, dated 2/21/95, provided the directions for obtaining the ssmple. Maine Yankee performed the procedure on November 13,1996, to validate the procedure. The inspector reviewed the completed procedure and concluded that the procedure established the required lineups and functioned as required, c.
Conclusions Based on the successful completion of sampling and the validation that the procedures previously instituted were adequate, this URI is closed.
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V. Mananoment Meetinaa X1 Exit Meeting Summary An exit meeting for the occupational radiation exposure inspection was performed on June 26,1997. The resident inspectors presented their inspection results to members of the licensee on July 30,1997. The licensee acknowledged the find %gs presented.
X3 Management Meeting Summary On July 22,1997, the NRC held a management meeting with Maine Yankee Atomic Power Company to discuss the Licensee's approach to resolving the cable separation issues at Maine Yankee. The meeting was held at the NRC Region i office and it was open for
public observation. The.esults of the meeting are documented in NRC Inspection Report 50-309/97 02, t
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PARTIAL LIST OF PERSONS CONTACTED Licensee
'B. Blackmore, Plant Manager D. Karr, Engineer - QA, YAEC D. Rivard. Supervisor Reactor Engineering
'J. Weast, Licensing Engineer
'J. Mallon, Manager, Radiological Protection -
'J. Frothingham, Manager Nuclear Safety Oversight
'M. Readinger, Radweste Shipping Coordinator S. LeClerc, Section Head + QP
- 'W. Odell, Manager - Technical Support
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A. Capristo, Supervisor Employee Concerns Coordinator
'8 Plummer, Operations Manager D. Hickey, Supervisor Health Physics E. Soule, Systems Engineering Manager
'G. Zinke, Quality Programs Manager
'G Leitch, Vice President Operation H. Farr, Supervisor HP Technical Support J. McCann, Licensing Section Head J. Hebert, Regulatory Aff airs Manager J. Sauger, Maintenance Manager M. Meisner, VP, Nuclear Safety and Regulatory Affairs
'R. Fraser, VP, Engineering T. Shippee, Supervisor, Health Physics W. Ball, Assistant Manager, Operations Support Other
'P. Dostle, Maine, Nuclear Safety inspector NEC R. Ragland, Hadiation Specialist
- Denotes those present at the exit meeting on July 30,1997
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IN3PECTION PROCEDURES USED IP 37551:
Onsite Engineering IP 40500:
Effectiveness of Lk msee Controls in Identifying, Resolving, and Proventing Problems IP 60710:
Refueling IP 61726:
Surveillance Observation IP 62707:
Maintenance Observation
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IP 71707:
Plant Operations IP 71750:
Plant Support IP 83750:
Occupational Radiation Exposure IP 92700:
Onsite Followup of Written Reports of Non routine Events at Power Reactor Facilities IP 92901:
Followup Operations IP 92902:
Followup Maintenance IP 92903:
Followup Engineering IP 92904:
Followup Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED ltems Ooened:
50 309/97 06-01 VIO Failure to follow procedures resulting in unplanned transfer of 10,000 gallons of water from the upender pit to the RWST. (Section 04.1)
{tems Closed:
50 309/96 14-05 VIO Failure to follow contamination control procedures (Sectbn R8.1)
50-309/96-06-04 URI Review of Post-Accident Sampling System (Section RB.2)
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LIST OF ACRONYMS USED ALARA As low As is Reasonably Achievable ANSI American National Standards Institute CFR Code of Federal Regulations CRO Control Room Operator CVCS Chemical and Volume Control System DRP Discrete Radioactive Particle FSAR Final Safety Analysis Report gpm gallons per minute IP inspection Procedure LP Learning Process MYAPS Maine Yankee Atomic Pewer Station MYLP.
Maine _ Yankee Learning Process NOV Notice of Violation NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PRCE Plant Root Cause Evaluation PSS Plant Shift Supervisor QA Quality Assurance RCS Reactor Coolant system RMS Radiation Monitoring System RP Radiation Protection RP8C Radiological Protection and Chemistry RPM radiation protection manager RWP radiation work permit RWST Refueling Water Storage Tank TB Turbine Building TS Technical Specification USFAR Updated Final Safety Analysis Report WO Work Order
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