IR 05000309/1998004
| ML20196G281 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 11/27/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20196G279 | List: |
| References | |
| 50-309-98-04, 50-309-98-4, NUDOCS 9812070299 | |
| Download: ML20196G281 (25) | |
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U. S. NUCLEAR REGULATORY COMMISSION j
REGION I
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Docket No:
50-309
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License No:
DPR-36 i
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Report No:
50-309/98-04 l
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Licensee:
Maine Yankee Atomic Power Company (MYAPC)
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Facility:
Maine Yankee Atomic Power Station
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Location:
Bailey Point i
Wiscosset, Maine Dates:
August 3,1998 through October 31,1998
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inspectors:
Todd J. Jackson, CHP, Health Physicist Decommissioning and Laboratory Branch
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William J..Raymond, Senior Resident inspector i
Division of Nuclear Materials Safety Nancy T. McNamara, Emergency Preparedness Specialist Division of Reactor Safety i
Approved by:
Ronald R. Bellamy, Ph.D.
l Chief. Decommissioning and Laboratory Branch
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Division of Nuclear Materials Safety l
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9812070299 981127 Y
i PDR ADOCK 05000309
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EXECUTIVE SUMMARY Maine Yankee Atomic Power Company NRC Inspection Report 50-309/98-04
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This integrated inspection included aspects of licensee operations, engineering, maintenance,
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and plant support. The report covers a three-month period of announced inspections by a
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resident inspector from the Haddam Neck site and two regional inspectors.
i Operations l
The inspectors conducted reviews of ongoing plant decommissioning operations. Inspectors
attended the licensee's moming plant-wide work coordination meetings and observed the
planning and conduct of decommissioning activities. Inspectors toured site buildings and j
observed work activities in progress. Site work during this period focused on transfer of control room operations to a new control room, modification of the spent fuel pool cooling system fans,
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abandoning of systems in-place, preparations to tum over to the Decommissioning Oversight Contractor (DOC) those parts of the plant not required to support the spent fuel pool island (SFPI), cold weather preparations, and continuing asbestos insulation removal. Work
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coordination issues were observed and discussed. No violations were identified.
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Maintenance l
Corrective actions for previously identified open items were reviewed, and two items closed.
Soent Fuel Safety.
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Limsee performance was good during completion of the nuclear island modifications, and to reduce ambient noise from operation of the fan coolers. Engineering calculations and technical evaluations supported the modifications.
j Discrepancies were identified in maintaining control room staffing and controlling safeguards informatiors. Licensee corrective actions for both issues were appropriate and thorough. The NRC exercised enforcement discretion for these matters.
j Plant Suooort The radiation protection program and liquid effluents monitoring program were reviewed during this inspection. Radioactive contamination surveys of asbestos insulation were examined, as were elements of the respiratory protection program and monitoring of site storm drain runoff. A discrepancy in radiation survey map data was examined.
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inspectors observed an exercise of the site emergency plan. Overalllicensee performance during this exercise was adequate as the licensee demonstrated it could implement the i
Defueled Emergency Plan (DEP). However, command and control in the control room was marginal due to minimal staffing, inadequate procedures, and hesitancy in declaring the Unusual Event. Discrepancies were found in the licensee's Emergency Plan implementing
Procedures (EPIPs).
i The licensee's critique process was considered an exercise strength. Post-exercise facility
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debnefs included both player and controller comments. Overall, the critique was balanced with positive and negative findings and was appropriately self-critical.
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Manaaement Y.xSncs At the request of the Community Advisory Panel on Maine Yankee Decommissioning, Region I i
staff made a presentation at the October 22,1998, Community Advisory Panel meeting to summarize Nuclear Regulatory Commission (NRC) activities relating to Maine Yankee conducted this year. Future presentations to the Community Advisory Panel will be approximately quarterly.
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TABLE OF CONTENTS TABLE OF CON TENTS......................................................... iv l.-
Operations............................................................ 1 O1 Conduct of Operations.............................................. 1 01.1 Qgneral Comments (71801)................................... 1 O3-Operations Procedures and Documentation............................ 1 03.1 System Abandonment Procedures.............................. 1 O3.2, Cold Weatrer Preparations................................... 1
Oporations Organization and Administration........................... 2
Miscellaneous Operations issues..................................... 2 08.1 Woric cosid;nst;cn and plannina................................ 2 11.
Maintenance........................................................... 3 M8 Miscellaneous Maintenance issues................................... 3 M8.1 Closure of Maintenance Open items............................ 3
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E agie :eering...........................
.............................. 4 E1 Engineering Support of Decommissioning Activities..................... 4 Ei.1 Facilitv Modifications...................................... 4 E1.2 Followuo of Condition Reports................................ 6 l
E1.3 Followuo of Previous Enoineerina inspection Issues................ 7 i
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Plant Su pport........................................................
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R1 Radiological Protection and Chemistry (RP&C) Controls.................. 8 R1.1 Effluent Monitorina.......................................... 8 R1.2 Respiratory Protection....................................... 9 R3 RP&C Procedures and Documentation................................ 9 R3.1 Asbestos Survey and Disoosal Surveys.......................... 9
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R3.2 Radiation Survey Maos..............................
..... 10 R8 Miscellaneous RP&C issues....................................... 11 R8.1 - Monitorina of Outside Yard Drains............................. 11 j
R8.2 In-Plant Surveys for Transuranics............................. 12 i
i P4 Staff Knowledge and Performance in Emergency Preparedness.........
.12 PS Miscellaneous EP Issues.......................................... 14 P8.1 Review of Emeroency Plan imolementina Procedures (EPiPs)....... 14 F5 Fire Protection Staff Training and Qualification......................... 15 V. Management Meetings................................................... 15 X1 Exit Meeting Summary.......................................... 15 X3 Community Advisory Panel Meeting............................ 15 i
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PARTIAL LIST OF PERSONS CONTACTED.................................... 17 t
l INSPECTION PROCEDURES USED.......................................... 17 i
I ITEMS OPENED, CLOSED, AND DISCUSSED.......
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I LIST OF ACRONYM S USED................................................. 19
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Report Details 1. Operations
Conduct of Operations O1.1 General Comments (71801)
Using inspection procedure 71801, the inspectors conducted reviews of ongoing plant decommissioning operations. Inspectors attended the licensee's morning plant-wide work coordination meetings and observed the planning and conduct of decommissioning activities. Inspectors toured site buildings and observed work activities in progress. Site work during this period focused on transfer of control room operations to a new control room, modification of the spent fuel pool (SFP) cooling system fans, preparations to turn over to the DOC those parts of the plant not required to support the SFPI, and continuing asbestos insulation removal. No safety concerns or violations were identified.
O3 Operations Procedures and Documentation O3.1 System Abandonment Procedures l
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Inspection Scope (71801)
The licensee's method for abandoning systems in-place was reviewed.
b.
Observations and Findinas Control of plant configuration and coordination of system abandonment activities was being accomplished through use of procedures 1-27-1 (" System Evaluation and Categorization") and 1-27-2 (" System Transition Process"). The inspector discussed control room awareness of changes in plant configuration with the Shift Manager and the Manager of Operations. Changes were being tracked in the control room and controlled by the referenced procedures at the time the changes were being made. Updated piping and instrumentation diagrams were being maintained in the control roorn.
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Conclusions
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No problems or safety concerns were identified. Changes appeared to be adequately controlled.
03.2 Cold Weather Preparations a.
Inspection Scope Licensee work to prepare plant systems and equipment to withstand freezing temperature conditions was reviewed.
b.
Observations and Findinas The licensee had identified in-core instrumentation (ICl) tubing as components requiring protection from freezing. Rupture of any of these tubes could cause the water inventory
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being maintained in the reactor vessel to drain. The licensee's review of piping connected to the reactor vessel showed that these were the only tubes that provided a drainage path from the vessel in case of rupture. The tubes had been filled with an epoxy sealer to displace the water, thus providing protection from freezing. The inspector observed the plugged tubes at the point where the epoxy had been injected.
One tube required additional protection because the internal configuration prevented injection of sufficient epoxy, and the licensee planned to use a freeze seal to isolate the tube, cut it, and cap the open ends in a location where there was no danger of freezing.
Other preparations were continuing through the end of this inspection period.
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Conclusions Preparations for cold weather were proceeding well, and were expected to be complete before freezing temperatures became a concern.
Operations Organization and Administration a.
Inspection Scope Preparations for transition to a site organization that incorporates the DOC, were reviewed. The licensee had completed arrangements to bring in the DOC to perform decommissioning work at the site, for all plant structures and components excluding those required in support of the SFP.
b.
Observations and Findinos A doc was selected and began to mobilize personnel at the Maine Yankee site.
Perfoca,ance of decommissioning work at the site will be the responsibility of the DOC, with the licensee retaining ultimate responsibility for compliance with the NRC license for the site. The details of the organizational interfaces were being developed, and were not yet clearly and completely defined by the end of this inspection period. The schedule for decommissioning was also being developed by the DOC, and will identify the expected dates for major decommissioning activities to be performed. The licensee subsequently provided the final schedule.
c.
Conclusions The licensee organization and administration is changing to support active decommissioning work.
Miscellaneous Operations issues 08.1 Work coordination and clannina a.
Inspection Scope The licensee had identified problems encountered in the coordination of work during the draining of plant systems and in isolating SFP related systems from the balance of the plant. Common factors relating to the identified issues were examined.
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Observations and Findinos The licensee had incorporated into the site Corrective Action Program (CAP) tracking system problems which had been encountered in coordinating work activities related to i
draining of systems and other activities related to completing the separation of SFP support systems from the rest of the plant. Examples of such issues include inadvertently bypassing a particulate filter during draining of the upender pit, incomplete j
communications during a lowering of reactor vessel water level, and incomplete planning i
for engineering design planning reviews (DPR) involving fire suppression reconfiguration, and installation of the new primary vent stack radiation monitoring i
system. Station organizations involved in the issues included Operations, Engineering, and the DOC.
Operations had developed corrective actions within the Department, including creation of
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Procedure 1-300-24, ' Draining Systems and Major Components". These actions by the Operations Department had effectively prevented problems with planned drain-down evolutions from recurring during the remaining drain-&mns. Additional work coordination problems, however, had subsequently occurred involving the other site organizations referenced above. The inspector noted that the CAP had effectively incorporated each of these individual issues as condition reports (CRs), and that the licensee was tracking the issues to assure complete corrective actions. The licensee had not addressed the potential for common factors contributing to work coordination problems across several site organizations. The licensee agreed that the common problems affecting work coordination, and development and implementation of corrective actions for the issues being tracked in the CAP, should also consider the impact of lessons-learned across the different site organizations.
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Conclusions The licensee's CAP has an appropriate threshold for identifying issues to be included in the CAP tracking system. Recent issues have common factors involving several different site organizations, and corrective actions implemented for each organization should consider the pertinent lessons-learned from other plant organizations. No violations were identified.
II. Maintenance M8 Miscellaneous Maintenance lasues MS.1 Closure of Maintenance Open items a.
Inspection Scope (92902)
Previous maintenance-related violations were reviewed. Specifically; VIO 96-04-01 (Failure to follow work process procedures), and VIO 96-04-02 (Maintenance procedure was not adequate). The inspector reviewed the events and the Maine Yankee corrective actions.
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Observations and Findinas
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Each of the listed violabons was formally addressed by Maine Yankee and documented 1,
in the Maine Yankee corrective action process The inspector reviewed the corrective
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actions and cons 6dered them adequate to address the specific events. As part of the correchve achon, the Maintenance Department condu 2d a stand-down of all maintenance work during the period April 8-12,1996. Procedure 0-16-3, " Work Order Process", Rev.15 was reviewed, and inceiiwates the licensee's committed corrective
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action routinely requiring a pre-job briefing in 95.6.1 of the procedure.
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Conclusions Based on reviews of the completed corrective actions and noted performance of the Maintenance Department, the two NRC violations listed above are considered closed.
(Closed VIOs 96-04 01 and 96 04-02)
111. Engineering E1-Engineering Support of Decommissioning Activities E1.1 Facility Modifications a.
Inspection Scope (37801. 60854)
The inspectors reviewed modification activities that supported spent fuel safety. Plant design change activities to establish the nuclear island were reviewed to verify that the modifications were implemented in accordance with licensee controls.
b.
Observabons and Findinog The completion of modifications associated with design change package (DCP) 97-42 were reviewed along with supporting engineering calculations. The list of references and materials reviewed is provided in Attachment 1. NRC review focused on the new security system modifications; the installation of the new control room, including the testing of the programmable logic controller (PLC); and the changes to the decay heat removal (DHR) system. The modifications included:
Control Room. Security Station. PLC Modifications for the new control room were completed and the new control room was established and manned starting in September,1998. Architectural modifications to provide for new control room and security alarm stations were reviewed. The inspector confirmed the changes were as described in the work package and drawing 98-00059-00.~ The installation was consistent with the exemption issued by the NRC in a letter to the licensee dated June 29,1998 relative to the requirements for the security station.
The control room has the PLC, which includes computer displays that provide mimics of plant systems, components and parameter displays, along with alarm functions and trending programs for monitoring the nuclear island. The displays are organized to
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provide screens for the primary cooling system, the secondary cooling system, the electrical distribution system, the radiological effluents and meteorological systems, and alarm functions. The core displays were functional when the new control room was manned. During this inspection period, the licensee was modifying the PLC to provide additional displays for the new ventilation stack sample points, and the fire protection system (showing the flow path from the Montsweag pumping station to the fire pond and the fire distribution header).
The licensee installed redundant sensors and associated instrument channels,
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LT/TT-SFP-20 and LT/TT-SFP-21, that provided control room indication of SFP level and temperature. Each dual sensor uses a float type level sensor, along with a platinum resistance temperature detector (RTD). The sensors were located in the SFP southeast and northwest comers of the SFP, and provided inputs into the PLC for readout in the control room. The channels were calibrated and functionally tested satisfactorily, which included the comparison with a local level and temperature measurements.
The licensee installed TIT-SFP-08 to provide temperature indication on the SFP
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heat exchanger E-25 secondary cooling outlet. The new channel provided local indication and remote readout via the SFP programmable logic controller in the new control room. The new platinum RTD was mounted in the heat exchanger thermowell where TI-3602 was located. The channel was calibrated and functionally tested (temperature loop response test) satisfactorily.
DHR System During much of this inspection period the licensee was installing new cooling fan equipment intended to reduce the noise level generated by the fans. The DHR cooling system used a series of six parallel water to air coolers. The fan coolers were located outdoors in a diked area with a gabled roof. The secondary cooling loop was designed to use water during the summer of 1998, and was changed to a 40% glycol solution during the period of September 30 - Octsoer 1, prior to the onset of cold weather.
The work was done in a slow and deliberate manner in order to provide adequate time after each bank replacement to measure any effect on system cooling capability. The six cooler units each had three fans (total of 18) operating at 1740 rpm. A high noise condition was identified during startup testing. The licensee reduced fan noise by insta!!ing different fan blades that operated at a lower speed (850 rpm) and had a different pitch. The licensee also removed the roof of the diked area to reduce the lateral deflection of the fan sound. When all six banks had been replaced, noise level measurements showed that noise levels had been reduced sufficiently to be in compliance with state requirements. The fan changes reduced the noise from 100 decibels (dBs) to 85 (dBs) at the fans and 45 dBs at the site boundary. The inspectors observed a noticeable improvement in the noise level near the fans after all had been
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replaced.
The licensee evaluated the impact of both changes (glycol, new fans) on the DHR system thermal performance, and the potential impacts of the glycol on the nuclear island (spills, leaks, criticality). Removing the roof had a 4 degree F improvement on
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DHR performance; adding the glycol had the effect of a 4 degree F penalty on DHR thermal performance.. The evaluations showed acceptable results, and the licensee concluded that the new cooling capacity of the replacement fans was adequate to assure SFP cooling. The licensee planned to evaluate DHR system performance during the winter of 1998-1999, and decide whether it was necessary to remove the glycol from the coolant prior to the Summer of 1999.
DG-SFP-1 The licensee completed testing of the emergency diesel generator for the nuclear island, DG-SFP-1, and provided an integrated review of it's operation. The maximum operating load limit was established at 225kW, which was greater than the expected total required load of 172 kW. Licensee actions continued during this inspection period to winterize the diesel. The changes were evaluated in TE-31-98, and included heating the engine compartment; heat tracing and insulating the fuel line; using winter grade fuel; and, assuring the operability of the block heater.
The inspection verified the design control program was appropriately implamented, and the observable portions of the installations were in accordance with the associated work packages. Inspector observations of as-built installations and a sampling review of work packages showed the modifications were completed per the DCP packages. Functional testing of the new systems was completed per DCP 97-42 and functional test instructions were controlled using the work order process. The supporting calculations and technical evaluations reviewed for DCP 97-42 are listed in Attachment 1. The calculations appeared to use acceptable methodologies and conclusions were supported by the results. The analyses and testing demonstrated satisfactory pool thermal performance for the DHR coolers.
c.
Conclusions in general, licensee performance was very good to implement the nuclear island modifications per its commitments and administrative controls. Engineering calculations and technical evaluations supported the modifications. The licensee resolved the problem of excessive noise generated by the SFP cooling fans, and also determined that the cooling capacity of the new, quieter fans was adequate for cooling requirements.
E1.2 Followuo o~ Condition Reports (CRs)
a.
Inspection Scope (40500)
The inspector toured the facility, interviewed personnel and reviewed the response to certain CRs issued during the period.
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Findinas and Observations CRs 98-244/272. Control / Loss of Safeauards information These items concemed the discovery on August 31 that a container of safeguards information (SGI) was left unlocked and unattended for 110 minutes (98-244); and, the discovery of a missing page from a security procedure (98-272). Immediate actions were taken to secure or search for the material, investigate both events, assess the consequences, and complete reportability evaluations. The events occurred because of personnel error and inattention to detail by the property custodians. Corrective actions were appropriate to counsel the specific individual (98-244) and to review the need to control safeguards materials with security personnel. Procedure 15-200.2 requires SGI to be locked when not attended. Taken together, the events described in the CRs appear as examples of the failure to follow procedures.
CR 98-246. Control Room Staffina This item concerned the failure to maintain staffing in the control room per license requirements on one occasion. Technical Specification (TS) 5.2.2.b requires that at least one person qualified to stand watch in the control room shall be present in the control room when irradiated fuel is in the fuel storage pool. The control room was left unattended for an estimated 12 minutes on August 28,1998, when the Shift Manager was in the plant, and the qualified watch-stander forgot he was the only person present in the control room and went to conduct duties in the turbine building. The SFP conditions were stable and the fuel remained adequately cooled during the period in question. The licensee completed a barrier screen evaluation per procedure O-16-1.
The licensee response to this item was appropriate and included actions to address the untimely initial followup upon discovery of the violation.
c.
Conclusions
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Licensee corrective actions for both the adverse conditions described above were appropriate and thorough. These non-repetitive, licensee identified and corrected violations are being treated as a Non-Cited Violation, consistent with Section Vll.B of the enforcement policy. (NCV 98-04-01)
E1.3 Followuo of Previous Enaineerina insoection issues a.
Inspection Scope (71801. 40500)
The purpose of this inspection was to review the status of previous inspection items.
b.
Observations and Findinas Previously opened issues related to systems or components no longer required to be maintained in the current plant condition were reviewed. The issues below were determined to no longer have any safety or regulatory significance with the plant in the decommissioning mode. The following list of unresolved items (URis), and Liegnsing Event Reports were reviewed and are closed.
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50-309/96-08-02 URI H;gh Energy Line Break
50-309/96-08-04 URI Turbine Building Doors and Flood Protection
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50-309/96-13-01 URI Loss of Designated Offsite Power Supply
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50-309/96-14-03 URI Electrical Separation issue i
50-309/96-16-18 URI 115 KV Offsite Power Supply l
50-309/96-16-21 URI Protected Switchgear Room Ventilation
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50-309/96-16-23 URI Atmospheric Steam Dump Rating
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50-309/96-04-00 LER Turbine Building High Energy Line Break
50-309/96-07-00 LER Emergency Feedwater Pump Room Ventilation 50-309/96-08-00 LER Turbine Hall Flood Protection
50-309/96-08-01 LER Turbine Hall Flood Protection i
50-309/96-22-00 LER Containment PCC Piping Design
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50-309/96-27-00 LER. Containment Spray Fans 44 A & B Inoperable
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50-309/96-38-00 LER Cable Separation 50-309/97-01-00 LER Cable Separation ll i
50-309/97-09-00 LER Design Basis for TB High Energy Line Break IV. Plant SuDDort R1 Radiological Protection and Chemistry (RP&C) Controls
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R1.1 Effluent Monitorina a.
Inspection Scoce (84750)
Effluent data were reviewed regarding radioactive material in liquid discharges during
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the period May - August,1998. A new replacement primary vent stack radiation
monitoring system was also reviewed
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b.
Observations and Findinas Liquid effluent monitoring data were reviewed for the period during which the licensee completed water inventory reduction throughout the plant in preparation for tuming systems and structures over to the DOC for decommissioning. The inspector reviewed the monthly totals of test tank batch sample analyses for May through July,1998.
During review of liquid discharge monitoring data, the inspector noted that there were blank portions of the record forms, sometimes having zero recorded as the appropriate value and sometimes left blank, lines indicating the name of the person completing the
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form were not filled-in, and strikeout corrections had been made without the person who made the correction initialing the change. The inspector stated that these records should be complete and clear. All required data was available, and the inspector was
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able to verify compliance with limits. The licensee agreed to eliminate the ambiguous data entry methods.
During this inspection period, in mid-October, the licensee completed processing liquid radioactive waste contained in plant systems and drained the liquid radwaste systems.
Liquid radwaste systems were abandoned in-place, to be tumed over to the DOC to dismantle, reinstate, or replace as necessary during decommissioning.
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Conclusions
. Liquid discharges of radioactive material for the period were within regulatory limits. The data will be included in the licensee's affluent release report covering the period reviewed The licensee agreed to modify practices for effluent data entry and recording to eliminate ambiguous entnes. No safety concoms or violations were identified.
R1.2 Respiratory Protechon a.
Inspechon Scope (83750)
The policy on use of respirators was reviewed
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Observations and Findinos A detailed analysis of work activities is performed by the licensee to determine if respirators are required. Recent work has not typically required respirators for protection from radioactive materials, but more commonly for asbestos abatement activities. The licensee maintains respirator qualification records in a computerized database, which is used to assure that respirators are issued only to qualified personnel. Quantitative fit tests are required for respirator qualification. Respirators used at Maine Yankee which provide the greatest protection factor are of the powered, positive powered air-purifying respirator (PAPR) type.
c.
Conclusions Recent respirator use at Maine Yankee has primarily been for protection from non-radiological hazards. No safety concems were identified.
R3 RP&C Procedures and Documentation R3.1 Asbestos Survey and Disposal Survevs a.
Inspechen Scope (83726)
The licensee's program for radiological survey of asbestos materials prior to release for disposalwas reviewed b.
Observations and Findinos The licensee was using existing procedures for survey and release of equipment and materials from the radiological control area (RCA), to scan and release asbestos containing materials from all areas of the plant. Asbestos-containing insulation was being removed from within the RCA, and also from areas not normally contaminated (the cold side), but with some potential for being contaminated. No special program or procedure had been developed in advance for the survey and release of asbestos removed from equipment on the cold side of the plant. The site characterization program had included the systems and piping on which the asbestos is located, so there is some data on the location and degree of contamination (or lack of contamination) on
the asbestos. The licensee was doing a sampling survey of the asbestos insulation prior to removal, ani of the under-side of some insulation as it was removed. Some sampling surveys of normally uncontaminated piping were also done after the asbestos insulation had been removed. The same criteria used to survey and release materials with potential for surface contamination from the RCA were also used for the insulation surveys (5000 dpm/100 cm' total,1000 dpm/100 cm removable). The exterior of full asbestos waste containers 'was also surveyed with microR meters to determine if external radiation fields were measurably above background.
The licensee had generated a guideline dated August 4,1998, describing the method used for surveying the cold-side asbestos insulation for free-release from the site.
Removal of asbestos from the cold side of the plant began during the early spring of 1998.
The inspector discussed with the licensee the value of docurnenting the method to be used for clearing types of materials for release from the site, prior to beginning the surveys. These surveys are different from the routine release of materials from the radiological control area, and are more typical of the site characterization survey.
Surveys of insulation prior to release are appropriate, because of known secondary side contamination in the past. The licensee acknowledged the value of developing written guidance / procedures for personnel in advance of implementing future surveys for release from the site of potentially contaminated materials for unrestricted use.
c.
Conclusions Based on review of the licensee's methods used to perform asbestos screening surveys, the inspector concluded that the licensee's surveys were reasonable and adequate. The licensee agreed that better practice for future surveys of materials for release, requiring survey methods different than the routine procedures in-use at Maine Yankee, would include written methods and planning in advance. There will be significant amounts of materials to be checked and released during the plant dismantling and decommissioning, with the need to document survey plans and procedures ;n advance.
J R3.2 Radiation Survey Maos a.
Inspection Scope (83750)
Radiation survey maps containing recent survey information were reviewed, on white-boards posted at the RCA access point and on paper at the containment access manway. The different survey maps were compared.
b.
Observations and Findinas On October 27,1998, the inspector reviewed the posted white-board survey map at the RCA access point in preparation for entering containment. A radiation source of 5 rem /h was noted in the vicinity of the ICI tubes on the -2 ft. elevation, based on the posted information. When entering containment, the radiation protection technician at the containment entrance reviewed with the inspector the latest survey information, using a written survey map of the area to iiiustrate. The written map, dated October 5,1998, did
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not show the filter as present, but did show two other radiation sources in the vicinity.
The sources, one 12 rem /h and the other 8.5 rem /h, had not been recorded on the RCA
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access white-board. The technician accompanied the inspector to the area, located behind a locked high radiation door, with a survey instrument and confirmed the accuracy of the paper survey map used for briefing purposes.
Radiation protection staff later informed the inspector that the filter had been moved from i
the area for disposal, and that there appeared to be no mechanism which would automatically prompt updating of the RCA access point white-board when conditions changed due to such actions. The licensee also explained that the RCA access white-boards were not intended to provide as much detail as the written survey maps, and
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therefore were not expected to show all the sources contained on the paper maps.
c.
Conclusions h
The inspector noted the possibility that posted survey map data could be inconsistent with another paper map of the same area, presenting confusing information to personnel i
prior to entering radiation areas. The licensee agreed the information shou'd be clear, and that it would be good practice to assure different survey maps of the same area contained consistent information. The licensee also noted that the entry to high radiation areas had also required use of a survey instrument to confirm mapped survey results. The technician had provided the inspector with correct and current information prior to entry. No violations were identified.
R8 Miscellaneous RP&C issues R8.1 Monitorina of Outside Yard Drains j
a.
Inspection Scope (84750)
The inspector reviewed the procedures and data for periodic monitoring of the effluent from yard drains within the outdoor radiological controlled areas of the plant.
b.
Observations and Findinos The inspector reviewed procedure 3-7-1-1, " Liquid Radioactive Waste Discharges",
which includes methods for periodic monitoring of effluents not normally containing radioactive materials. Section 6.4.2 of the procedure provides the guidance for sampling and analysis of effluents from the site stormwater drain system. The procedure specified use of the lower limits of detection (LLDs) described in Attachment A to the procedure, which are the effluent LLDs. The site storm drains are not part of the analyzed and approved Maine Yankee liquid discharge pathways, however, and therefore the LLDs
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described in the Offsite Dose Calculation Manual (ODCM) should be used. The licensee agreed that the environmental LLD described in the ODCM were appropriate for this monitoring and revised procedure 3-7-1-1 accordingly. The inspector confirmed the revision prior to the end of the inspection period. Additionally, the licensee performed an analysis of the impact ifliquids had been released via the storm drains, containing radioactive materials in concentrations less than the effluent LLDs, and therefore not detected. These concentrations could have been detected if environmental LLDs had
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been used in the analyses. The licensee's evaluation demonstrated that even if material j
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had been released at these concentrations, the impact calculated in accordance with the
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methodology of the ODCM would have been no more than 1.3 mrem /y. Review of past
j data for storm drain monitoring using the effluent LLDs had shown no radioactive
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materials detectable in storm drain water.
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Conclusions i
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The licensee was not using appropriate LLDs for periodic monitoring of the storm drain j
l discharges from the site. The licensee agreed with this observation and modified l
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procedures to require use of the appropriate environmental LLDs. In addition, the
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licensee evaluated the consequences of using effluent LLDs instead of environmental
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LLDs for this release pathway and concluded that there would have been minor impact if
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l radioactive materials had been present near the lower LLD concentrations. The
inspector found the licensee's corrective actions to be complete.
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j R8.2 In-Plant Surveys for Transuranics
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l a.
Insoection Scope
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Recent licensee survey data to characterize transuranics were reviewed i
b.
Observations and Findinas
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The licensee had analyzed samples from the upender pit for transuranics. Samples
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from this location were considered to be most representative of any transuranic contamination that might be present in the plant because the area would have been
more likely than other areas to be affected by contamination originating from past l
damaged fuel. Based on the analytical results, the licensee was using a scaling factor
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for plant surveys of 5000 p-y dpm/a dpm. Ten percent of all smears taken in plant i
surveys are analyzed for a activity, per procedure 9-303-102.
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Conclusions
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The licensee was using recent characterization data to consider the dose contribution
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from transuranics when measuring personnel doses from beta-gamma emitting
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radionuclides. No safety concems or violttions were identified.
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P4 Staff Knowledge and Performance in Emergency Preparedness I
a.
Exercise Evaluation Scope (82301)
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During this inspection, the inspectors observed and evaluated the licensee's biennial
emergency preparedness exercise in the control room and the Technical Support Center
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(TSC). The inspectors assessed licensee recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, command and control, communications, and the overall implementation of the Defueled Emergency l
Plan (DEP). In addition, the inspectors observed the post-exercise critique to evaluate the licensee's self-assessment of the exercise.
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b.
Observations and Findinos b.1 Control Room
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l Due to the decommissioning status of the plant, the control room staff consists of a shift I
manager, operator and a security supervisor. The room is an office-like environment with surveillance screens displaying the area around and in the SFPl. The initiating i
event clearly met the licensee's emergency action level (EAL) criteria for an Unusual
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Event (UE). However, the shift manager delayed making the declaration for 17 minutes because he wanted to verify plant damage and solicit the plant manager's opinion. The I
inspectors considered the 17-minute time period to be unusually long given that plant i
conditions specifically met the UE EAL criteria. Although the 17 minute time-delay did not negatively impact the outcome of the exercise, the inspector determined that the shift j
manager did not demonstrate his ability to make a quick independent decision and
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declare an emergency event for immediate response.
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i immediately following the simulated event that initiated the emergency (an earthquake),
the shift manager recognized that plant systems needed to be evaluated to ensure the earthquake had not caused any essential damage. Not knowing who was available for the exercise, the control room controller told him to send the control room operator. This resulted in the shift manager being left by himself to handle changing plant conditions, make agency notifications, receive and provide briefings to plant staff and follow emergency procedures. The shift manager hadn't realized he forgot to notify the NRC of
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the UE until 55 minutes after the declaration. The TSC made the UE notification at the same time of the Alert and just met the one-hour notification criteria. Also, the shift manager was so occupied that the security guard located in the control room provided the initial briefings pertaining to plant status to the TSC technical staff.
The staffing circumstances debilitated the shift manager from effectively demonstrating command and control. The licensee also recognized this area of concem during their formal critique and presented various ideas for resolution to the inspectors, which included improved procedures and a re-evaluation of the multiple duties of the shift
manager. The inspectors emphasized that under the guidelines of the DEP, the licensee is to ensure that control room staffing is sufficient and personnel are adequately trained to successfully protect the public health and safety under emergency conditions.
However, it should be noted that even though the control room atmosphere was exceptionally busy, the shift manager was able to successfully debrief the Emergency
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Director (ED) and turn over the responsibilities to the TSC staff without any major consequences.
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b.2 Technical Support Center The TSC was staffed in accordance with the DEP and activated within 30 minutes after the UE declaration. Command and control of the TSC staff was very good in that the ED's briefings were focused and orderly. Plant status information and response priorities were discussed and rearranged appropriately. Procedural guidance was utilized by response personnel to aid them and direct appropriate response actions.
Also, the scenario contained a spill of radiological material (resin) that was appropriately assessed by the radiological assessment team. The field teams took the necessary radiological precautions for minimizing any potential radiological exposure. Notifications to the State of Maine were made within the required time constraints.
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b.3 Licensee Exercise Critiaue immediately following the exercise, the licensee began its critique process with players, as well as controllers, providing debriefs. At the formal licensee critique on October 29, 1998, the licensee identified issues in addition to the ones identified by the inspectors.
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Positive and negative items were noted, and discussions regarding solutions to several significant issues took place. Overall, the critique was thorough and appropriately self-critical, and was assessed as an exercise strength.
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c.
Conclusions Overall licensee performance during this exercise was adequate to demonstrate the
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DEP could be implemented. Facilities were activated, procedures followed, and classifications and notifications were accurate and timely. However, the command and control in the control room was marginal due to minimal staffing, inadequate procedures, and the shift manager's hesitancy in declaring the UE. Discrepancies were found in the licensee's EPIPs.
The licensee's critique process was considered an exercise strength. Post-exercise facility debriefs included both player and controller comments. At the formal critique, the licensee identified numerous issues, and most importantly, was able to disseminate the significant issues that needed immediate resolution. Also, it included very good discussions with licensee management for proposed solutions for those significant issues. Overall, the critique was balanced with positive and negative findings and was appropriately self-critical. The training and staffing concern will be reviewed during the next EP program inspection. (IFl 98-04-02)
l P8 Miscellaneous EP issues P8.1 Review of Emeroency Plan Imolementina Procedures (EPIPs)
a.
Inspection Scope (82301)
EPIP implementation was reviewed during the exercise.
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b.
Observations and Findinos
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The inspectors reviewed several EPlPs and found errors that were determined to contribute to some of the discrepancies found during the exercise. Particularly, Procedures 2-50-0 and 2-50-2 contained some conflicting and/or inaccurate information l
regarding: (1) who makes declaration announcements and where these dxlarations are
made; (2) the lack of a clear definitiwi of the shift manager's role and responsibilities in
terms of working with a minimized staff, TSC tumover protocol and the shift manager's j
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duties post-tumover; and (3) who notifies the NRC via the emergency notification -
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system. The inspector discussed this matter with the EP Manager and the licensee e
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. committed to review the procedures for better accuracy.
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c.
Conclusions
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j-This issue will be reviewed in the next EP program inspection. (IFl 98-04 02)
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F5 Fire Protection Staff Training and Qualification
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a.
Inspection Scoos Qualification status of current fire brigade members was reviewed i
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E b.
Observations and Findinos Q
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The inspector reviewed revision 7 of the Maine Yankee Fire Protection Plan, dated
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. August 11,1998. The Plan requires three qualified fire brigade members available at all
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times for fire brigada duties. The fire brigade certification list dated October 19,1998,
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l was revewed. The list is valid through December 31,1998, and included 13 operators
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and 17 security staff.
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c.
Conclusions Qualifications were current for all personnel on the Fire Brigade Certification list. No safety concems or violations were identifed.
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l V. Mananoment Meetings X1 Exit Meeting Summary
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The inspectors presented the inspection resu'ts to members of the licensee on
August 27, October 15, and October 29,1998. The licensee acknowledged the findings presented.
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. X3 Community Advisory Panel Meeting
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On October 22,1998, Region i staff made a presentation to the Community Advisory Panel on Maine Yankee Decommissioning. The presentation included an overview of
the results of NRC inspections conducted at Maine Yankee since the beginning of the
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year, a schedule of upcoming NRC inspections, and a summary of NRC licensing
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activities. The staff made this presentation at the request of the Community Advisery Panel Chairperson so that the Community Advisory Panel would have a better understanding of NRC activities relating to Maine Yankee. Future NRC updates to the Community Advisory Panel will be conducted approximately quarterly.
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PARTIAL LIST OF PERSONS CONTACTED Licensee M. Meisner, President M. Ferri, Vice President-Decommissioning
W. Odell, Director of Operations R. Fraser, Director, Engineering S. Evans, Manager, Environmental Health & Safety / Emergency Preparedness
J. Sauger, Maintenance Manager i
T. Williamson, Quality Assurance ' Manager
- W. Ball, Manager, Operations J. Mallon, Radiation Protect Manager J. Niles, Assistant Manager, Operations M. Evringham, Manager, Maintenance G. Zinke, Director-Regulatory Affairs J. McCann, Licensing
W. Lach, Chemistry E. Brand, Licensing M. Whitney, Licensing J. Temple, Emergency Preparedness Coordinator Other P. Dostie, Maine Nuclear Safety inspector D. Randall, Maine Nuclear Safety inspector S. Gray, Site / Construction Manager, Stone & Webster j
P. Rosenthal, Licensing, Decommissioning Oversight Contractor (DOC)
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INSPECTION PROCEDURES USED IP 37801 Safety Reviews, Design Changes, and Modifications at PSRs IP 40500:
Effectiveness of Licensee Controls in identifying, Resolving, and Preventing
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Problems IP 60854:
Preoperational Testing of an ISFSI IP 71801:
Decommissioning Performance and Status Review
IP 82301:
Evaluation of Exercises for Power Reactors i
IP 83726 Control of Radioactive Materials and Contamination, Surveys and Monitoring
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IP 83750:
Occupational Radiation Exposure IP 84750:
Radwaste Treatment / Effluent and Environmental Monitoring IP 92902:
Followup-Maintenance
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l ITEMS OPENED, CLOSED, AND DISCUSSED
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Items Opened:
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50-309/98-04-02 IFl Emergency Preparedness Procedural Guidance, Training and Staffing
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items Closed:
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50-309/96-04-01 VIO Three Examples of Failure to Follow Work Process Procedures
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50-309/96-04-02 VIO Maintenance Procedure We Not Adequate l
50-309/96-08-02 URI High Energy Line Break 50-309/96-06-04 URI Turbine Building Doors and F.ood Protection
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50-309/96-13-01 URI Loss of Designated Offsite Power Supply 50-309/96-14-03 URI Electrical Separation issue
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50-309/96-16-18 URI 115 KV Cffsite Power Supply
50-309/96-16-21 URI Protected Switchgear Room Ventilation
50-309/96-16-23 URI Atmospheric Steam Dump Rating
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50-309/96-04-00 LER Turbine Building High Energy Line Break
i 50-309/96-07-00 LER Emergency Feedwater Pump Room Ventilation
50-309/96-08-00 LER Turbine Hall Flood Protection
50-309/96-08-01 LER Turbine Hall Flood Protection
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50-309/96-22-00 LER Containment PCC Piping Design
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50-309/96-27-00 LER Containment Spray Fans 44 A & B Inoperable
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50-309/96-38-00 LER Cable Separation l
50-309/97-01-00 LER Cable Separation ll l
50-300/97-09-00 LER Design Basis for TB High Energy Line Break
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LIST OF ACRONYMS USED
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' CAP Correchve Action Program CRs-Condition Reports dBs-Decibels DCP-Design Change Package DEP Defueled Emergency Plan DHR Decay Heat Removal-DOC Decommisioning Oversight Contractor DPR Design Planning Reviews EAL'
Emergency Achon Level
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.ED
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Emergency Director EPIPs ~
Emergency Plan implementing Procedures ICI in-Core Instrumentabon IP Inspection Procedure LERs Licensee Event Reports LLDs Lower Limits of Detection NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PAPR Powered Air-Purifying Respirator PLC Programmable Logic Controller t
RCA Radiological Control Area RP&C Radiological Protection and Chemistry RTD-Resistance Temperature Detector SFP Spent FuelIsland
- SGI
- Safeguards Information SPFI Spent Fuel PoolIsland TS-Technical Specification -
TSC Technical Support Center URI Unresolved items UE Unusual Event
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I Attachment I
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Spent FuelIsland Modifications The inspection of the design, modification and functional testing of the nuclear island included observation and/or review of design change packages (DCP), functional test instructions (FTis)
and associated safety evaluations, and work orders (WO) on a sampling basis, including the following references:
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MODIFICATION PACKAGES DCP 97-42, Spent Fuel Pool isolation WORK ORDER and TEST PACKAGES j
WO 98-00059-00, installation of SFPI ControllCAS Room Modifications I
WO 97-3435-18, FTl of Spent Fuel Islad PLC
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WO 98-97-3435-11, installation and Furdional Test of LT/TT SFP-20 and 21 WO 97-03435-14, installation and Functional Test of TIT-SFP-08 WO 98-545-00, FTl of the Backup Diesel Generator WO 98-582, DG-SFP1 Functional Test fo' DCP 97-042 WO 98-0617, Functional Test of SFP1 Csesel (Voltage Regulator Repair)
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CAG 98-010, independent Review of rG-SFP-1 Functional Testing CALCULATIONS and EVALUATICNS
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DHR Radioactivity-CDR 98-225
TE 14-98, DG-SFP1 Maximum Operating Limit Change
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TE 31-98, Diesel Generator Winterization FMD-97-523, Use of Ethylene Glycol at Maine Yankee EDCR 97-42. Enclosure G, Removing Glycol from SFP RPMY 97-037, impact of Ethylene Glycol to SFP Criticality THM-002-98, DHR Thermal Performance Following Fan Change and Glycol Addition THM-004-98, Winterizing Diesel Generator DG-SFP-1 i
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