IR 05000309/1998005
| ML20196K916 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/26/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20196K913 | List: |
| References | |
| 50-309-98-05, 50-309-98-5, NUDOCS 9904080146 | |
| Download: ML20196K916 (24) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No:
50-309
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License No:
DPR-36 Report No:
50-309/98-05 Licensee:
Maine Yankee Atomic Power Company (MYAPC)
Facility:
Maine Yankee Atomic Power Station Location:
Bailey Point Wiscasset, Maine Dates:
November 1,1998 through February 13,1999 Inspectors:
Todd J. Jackson, CHP, Health Physicist Decommissioning and Laboratory Branch Division of Nuclear Materials Safety (DNMS)
William J. Raymond, Senior Reactor Engineer Engineering Programs Branch Division of Reactor Safety Mark C. Roberts, CHP, Senior Health Physicist Decommissioning and Laboratory Branch, DNMS Approved by:
Ronald R. Bellamy, Ph.D.
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Chief, Decommissioning and Laboratory Branch, DNMS 9904000146 990326 PDR ADOCK 05000309 g
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EXECUTIVE SUMMARY Maine Yankee Atomic Power Company NRC Inspection Report 50-309/98-05 This integrated inspection ir.cluded aspects of licensee operations, engineering, and plant f
support. The report covers a three-month period of announced inspections by three
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regional inspectors.
Operations I
The inspectors conducted reviews of ongoing plant decommissioning operations.
Inspectors attended the licensee's morning alant-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 abandoning of systems in-place, and preparations to turn over to the Decommissioning Operations Contractor (DOC) those parts of the plant not required to support the spent fuel pool island (SFPI). Work coordination activities were observed and discussed.
Enaineerina Sunoort of Decommissionina Activities The licensee completed actions as described in their November 9,1998, submittal to improve the licensing and design basis, improve the process to perform safety evaluations and to revise the corrective action process. The licenses took actions as appropriate to
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address deficiencies as related to the permanently shutdown condition of the plant.
Nuclear licensing provided good support to the plant staff to assure past issues were properly addressed for the decommissioning mode.
Soent Fuel Safety Licensee performance was very good to prepare the plant for cold weather, assure adequate freeze protection of the spent fuel pool and support systems, and to assure other i
plant systems were protected against freezing.
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Plant Support Responsibility for routine operation of the radiation protection program was transferred to
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the DOC in January,1999.
I Management Meetinos Representatives from NRC, the licerssee and its contractors, and the State of Maine-attended meetings on November 9,1998: November 19,1998; and January 21,1999; j
that were open for public participation. A teleconference exit meeting was held i
February 11,1999.
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TABLE OF CONTENTS EX EC UTIV E SU M M ARY.............................................. ii
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TABLE O F CO NTENTS.............................................. iii Report Details.................................................... 1 1. Operations
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Conduct of Operations......................................... 1 01.1 fagr e ral Com m e n t s....................................... 1
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Operational Support of Decommissioning Activities..................... 1 01.1 Cold Weather Preoarations................................. 1
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Operations Procedures and Documentation........................... 3 03.1 Preoarations for Soent Fuel Insoections
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Operations Organization and Administration..........................3
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l II. Enaineerina.................................................... 4 E1 Engineering Support of Decommissioning Activities
.................... 4 E1.1 Follow up of Escalated Enforcement issues..................... 4 E1.2 Follow un of Previous insoection Issues........................ 6 E1.3 Response to Advggg_f:enditions............................. 7 11!. Pla n t S uonort................................................. 10 R1 Radiological Protection and Chemistry (RP&C) Controls................. 10 R1.1 Effluent Monitorina
..........................................10 R1.2 Control of Radioactive Sources............................. 11 R1.3 Use of Gamma Radiation Field Imaaina........................ 12 R6 RP&C Organization and Administration............................. 12 R6.1 Control of Plant Access
..................................12 P8 Miscellaneous EP issues and Follow-Up of Previous inspection issues....... 14 IV. Manaaement Meetince.......................................... 14 X1 Exit Meeting Summary........................................ 14 X2 Community Advisory panel M eetings............................... 15 iii i
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At t a c hm e nt i................................................... A 1 - 1 lssues Related to the Escalated Enforcement Action
.......................A1-1 issues Related to Plant Operations.................................... A1 -2 PARTIAL LIST OF PERSONS CONTACTED.............................. A1-3 INSPECTION PROCEDURES USED................................... A 1 -4 ITEMS OPENED, CLOSED, AND DISCUSSED............................. A1-4 LIST OF ACRONYMS USED
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Rept t 7etails
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1. Operations l
Conduct of Operations j
01.1 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, ancl observed the planning and conduct of decommissioning activities. Inspectors toured site buildings and observed work activities in progress, as well as preparations fcer upcoming work activities. Site work during this period continued to focus on turnover of those areas of the plant not required to support the spent fuel pool island (SFPI) to the Decommissioning Operations Contractor (DOC), and on the turnover of administration of support programs.
Operational Support of Decommissioning Activities 01.1 Cold Weather Preoarations a.
Inspection Scooe (71714 )
Licensee activities to prepare the nuclear island and plant systems for cold weather were reviewed.
b.
Observations and Findinas The licensee had a process that prepared the plant for cold weather and recognized the circumstances specific to the decommissioning mode. The licensee developed a tracking list for cold weather operations issues, which identified all items needed to be completed by October 30,1998, along with the schedule and status for each item. The status of cold weather preparations was reviewed during the daily management meetings. Licensee preparations addressed the following areas:
Nuclear island - the spent fuel pool building (SFPB) was protected from
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freezing conditions through ventilation and heating systems that remained in service for the nuclear island. This included the addition of six 25 kW space heaters and a distribution fan that was added to the building under DCR 97-42. The portions of the decay heat removal (DHR) system exposed to
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outdoor ambient conditions were protected against freezing by the addition of a 40% glycol solution (reference Inspection 98-04). The fuel transfer tube j
was protected through the addition of a heated enclosure on the containment end. The inspector toured the spent fuel building during cold weather conditions on November 18 and noted that area temperatures were indicated l'
on local temperature gages and were adequate to preclude freeze concern [^
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Industry experience -licensee engineering staff reviewed NRC generic
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correspondences (e.g.,Bulletins 94-01, 79-24 and several Information Notices ) to identify industry concerns that might be applicable to Maine Yankee. The results of the review were discussed with the Engineering Manager, along with the file of items included in the licensee's review. The licensee concluded that freeze protection measures in place at Maine Yankee would preclude the types of concerns identified in the industry.
Spent Fuel Pool (SFP) support systems - plant systems and components that
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supported the nuclear island were protected against freezing using space heating, insulation, and heat-trace circuits. The inspector toured the facility to review the completion of activities to protect portions of the fire l
protection system, the plant ventilation stack system instruments, the emergency diesel generator DG-SFP-1, the primsry water storage tank, and l
the status of heat-trace panels and insulation. No discrepancies were i
identified. Inspection 98-04 described additional NRC inspection activities of the DG-SFP-1 winterization.
Balance of plant (BOP) systems - the licensee identified the systems to be
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abandoned to support plant decommissioning. The process was defined in l
procedure 1-27-2 and controlled using the System Evaluation and Re-classification Team (SERT) reviews. The list of systems abandone.1 was
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described in memorandum SERT 93-119 dated October 22,1998. All
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abandoned systems potentially subject to freeze conditions were drained by l
October 30,1998. The licensee drilled small holes in piping low points to
assure systems were completely drained. The drilled locations were tracked l
and marked on the piping systems for future reference. The reactor vessel j
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was left partially filled with water, and the incore instrument tubes were filled with epoxy to preclude freezing.
Procedures and logs -licensee controls for cold weather preparations and
freeze protection were provided in several documents, including procedures:
O-06-12, " Cold Weather Protection" (CRS-1); 3-1-1, " Operator Logs"; AOP 2-37.PLC, " Response to Prop"mmable Logic Controller Alarms"; and,1-107-3, " Heating and Ventilat- -" The inspector reviewed the completed log
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for November 18 and noted the freeze protection (and other) items were completed satisfactorily.
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Conclusions Licensee performance was very good to prepare the plant for cold weather, assure adequate freeze protection for the SFP and support systems, and to assure other plant systems were protected against freezing.
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Operations Procedures and Documentation O3.1 Preoarations for Seent Fuel Inspections a.
Insoection Scope - (60705)
The inspector reviewed the licensee preparations for movement of fuel to enable inspection of fuel in the SFP.
b.
Observations and Findinos The licensee was preparing to inspect the fuel stored in the SFP. The objective of the inspection campaign include verification and complete documentation of pool contents (to complement existing records) and to determine what work may be necessary to enable transition to dry cask storage of the fuel in the future. Dry cask -
storage is being examined as a.. alternative to continued use of the spent fuel fc long-term spent fuel storage at the site. In addition to spent fuel, there are some additional items such as filters stored in the pool, and these materials will be characterized as part of the inspection program.
The DOC is responsible for the inspection program, with Maine Yankee Certified Fuel Handlers moving the fuel during the campaign. A Maine Yankee supervisor will direct fuel movement. The licensee has procedures covering fuel movements, and the inspector reMswed procedure number 13-2, " Fuel Handling in the Spent Fuel Pool". The inspector observed preparatory work underway on the refueling bridgei Preparations for inspection were continuing at the end of this inspection period, c.
Conclusions
Preparations for movement and inspection of fuelin the SFP were in progress. This area will be reviewed again as preparations ara completed and fuellaspections begin.
Operations Organization and Administration a.
Inspection Scope Transfer of responsibilities from Maine Yankee to the DOC was reviewed.
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Observations and Findinos Program responsibilities continued te be transferred to reflect the decommissioning l
relationship between Maine Yankee and the DOC. During this inspection period the l
DOC assumed responsibility for radiation protection, training, security, and radwaste. The transitions included appropriate procedures, which were approved in i
advance by both the DOC and Maine Yankee, as well as thorough planning. In the
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case of Radiation Protection, a one-month period of minimal challenges to the new organization was planned, and a follow-up self-assessment critique planned.
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Conclusions Preparations for transition of program administration were thorough and complete before the transition occurred. Transitions were well-planned and deliberate.
II. Enaineerina E1 Engineering Support of Decommissioning Activities E1.1 Follow up of Escalated Enforcement issues a.
Insoection Scooe (92702)
The purpose of this inspection was to review the status of licensee actions to address previous inspection issues that were the subject of escalated enforcement.
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Qhgervations and Findinas The NRC issued a Notice of Violation by letter dated October 8,1998 as a result of several inspections conducted between July 15,1996, and March 15,1997,and three investigations conducted by the NRC Office of Investigations. The inspections included an Independent Safety Assey.nent (ISA) and several inspections. The inspection findings and violations involved concerns regarding conformance with the design and licensing bases, operational safety performance, and the self-assessment and corrective action processes. The investigations concerned the adequacy of the small break loss-of-coolant accident (SBLOCA) emergency core cooling system (ECCS) analyses, the submittal of inaccurate information to the NRC, and the failure to perform station tests as required by the technical specifications (TSs). The apparent violations associated with the investigation were described in a NRC letter dated December 19,1997.
The inspection and violation issues were the subject of enforcement conferences on March 11,1997 (Inspection 97-01), and on April 23.1998. The licensee responded to these matters by letters MN-97-39 dated February 28,1997, MN 98-23 dated April 3,1998, and MN 98-71 dated November 9,1998, which addressed both the specific violations and the broad issues that involve the underlying causes associated with the specific issues. Further, by letter MN-97-89 dated August 7, 1997, the licensee provided certifications pursuant to 10 CFR 50.82 (a)(1)(i) and 10 CFR 50.82 (a)(1)(ii) that it had permanently ceased power operations and the fuel had been permanently removed from the reactor vessel. The NRC acknowledged the certifications by letter dated September 3,1997. As a result of the certifications, the licensee was no longer subject to certain regulatory requirements, such as 10 CFR 50.49 for the environmental qualification of electrical equipment, and 10 CFR 50.46 for the performance of ECCSs.
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Further, the NRC issued Confirmatory Action Letter (CAL) 1-96-015 on December 18,1996, and a Supplement on January 30,1997 to confirm that the licensee would not restart the facility until corrective actions were completed related to existing offsite power capability to support plant operations, and design and configuration control problems. The NRC subsequently determined that the issues that were the subject of the CAL and Supplement were related to operation of the facility and do not apply to the permanent shutdown condition. By letter dated September 18,1998, the NRC released the licensee from any further responses regarding the subject of the CAL.
Since August,1997, the licensee has completed activities to establish a nuclear island to support the safe storage of spent nuclear fuel, and to abandon plant systems in preparation for plant decommissioning. The licensee completed the process to abandon plant systems by October 30,1998, and provided listings of all systems categorized as ABANDONED (e.g., procedure No.1-27-1 and SERT file 98-119). The licensee addressed weaknesses in maintaining the licensing and design basis by revising the program for conducting safety evaluations per 10 CFR 50.59 (as reflected in Revision 9 of procedure O-06-4 for the decommissioning mode), providing better definition of the licansing basis; providing
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additional training for personnel who prepare, review and approve safety evaluations; and, revising the process to update the Final Safety Analysis Report (FSAR), as reflected in Revision 3 of procedure 26-314. The conduct of safety evaluations under the new procedure was previously reviewed by the NRC and found acceptable. One of the underlying causes of the inspection and violation issues was that past corrective actions were sometimes inadequata or untimely.
Licensee actions to improve the corrective action process for the decommissioning mode is discussed further in Section E1.3 below.
Previous inspection and violation issues related to systems no longer required to be mair.tained in the current plant condition were reviewed in light of the certifications under 10 CFR 50.82. The issues listed in Attachment I were determined to no longer have any safety or regulatory significance with the plant in the decommissioning mode.
i in the licensee's November 9,1998, letter, the licensee generally agreed with the NRC's characterization of the issues, but took exception to one violation related to the core operating limits report (Violation 02014), and requested that the NRC reconsider the violations related to 10 CFR 50.46 as a lessor severity level. In a letter dated December 23,1998, NRC upheld the violation concerning the core operating limits report and sustained the severity level of the 10 CFR 50.46 violation.
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Conclusions
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The licensee completed actions as described in the November 9,1998 response to the escalated enforcement action to improve the licensing and design basis, improve the process to perform safety evaluations and to revise the corrective action
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process (CAP). The licensee took actions to address deficiencies as related to the l
permanently shutdown condition of the plant. Nuclear licensing provided good support to the plan staff to assure past issues were properly addressed for the decommissioning rr. ode.
E1.2 Follow up of Previous inspection issues a.
Insoection Scone (71801,40500)
The purpose of this inspection was to review the status of previous inspection items, b.
Observations ard F;ndings (Closed) LER 97-07-00: No Radiation Protection Technician Onsite. The licensee corrective actions were described in the follow-up activities described in Learning Bankissue 97-01450, which included the completion of a formal root cause evaluation. The event was caused by a personnel error. The corrective actions described in the LER were appropriate. The' failure to have a radiation protection technician, qualified in emergency plan duties, was a TS violation. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This item is closed. (NCV 98-05-01)
(Closed) VIO 97-08-01, Control of Security Systems. The licensee actions for this item were described in the response to the violation by letter MN-98-07 dated January 28,1998. Corrective actions were appropriate. This item is closed.
(Closed) VIO 97-08-02, Fire Watch Logs. The licensee actions for this item were
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described in the response to the violation by letter MN-98-07 dated January 28, i
1998. Corrective actions were appropriate, and included the incorporation of I
training and lesson plan information into procedure 19-5, Revision 11. Following the certification to permanently cease operations, the licensee no longer had to meet the requirements of 10 CFR 50 Appendix R. This item is closed.
(Closed) VIO 97-05-01, Inadequate Crane Checks During Refueling. The licensee responded to this item by letter MN 97-94 dated August 11,1997. The specific j
discrepancies cited in the violation were addressed during the refueling activities in May,1997, as described in inspection 97-05. The licensee also took additional actions to address crane functions. Evaluation reports 97-2295 and Root Cause Analysis PED-RC-97-OO6 describe further evaluations, identified discrepancies and corrective actions. This effort addressed the broader issue of proper crane function i
and established the design basis for crane interlocks. This item is closed.
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(Closed) URI 96-16-22, Heat Exchanger Temperature Rating. The licensee completed calculations to increase the rating of spent fuel heat exchanger E-25 from 200 to 225* F. This issue did not involve a violation of NRC requirements. The analyses were described in Calculation 97-001 dated 1/31/97, which was reviewed
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and approved in accordance with the quality assurance process. This item is
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J (Closed) VIO 96-12-01, installation of Primary Ventilation Stack Filters. The licensee response to this item was provided in MN 97-06 dated January 7,1997.
The filters were not installed following maintenance due to personnel error. The
licensee changed procedure 1-12-98 to ensure technicians install the filters. 'The
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procedure was later changed (Revision 13 dated October 19,1998) to reflect the new sampling system for the decommissioning mode. This item is closed.
E1.3 Resoonse to Adverse Conditions a.
Insoection Scooe (40500)
The licensee CAP to address adverse conditions was reviewed. The inspector toured the facility, interviewed personnel and reviewed the response to certain condHon reports (CRs) issued during the period.
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Findinas and Observations j
in the November 9,1998 response to the escalated enforcement action, the licensee acknowledged that weaknesses in the CAP at Maine Yankee was one of the broad underlying causes associated with the specific violations. The licensee's response was to revamp the CAP to reflect the decommissioning mode. The program as described in procedure O-16-1, " Condition Reports", Revision 13, was reviewed with the CAP Coordinator. The CR process was simplified, compared to the predecessor Learning Bank process, and was converted to a hard copy system for tracking adverse conditions from identification through the completion of corrective actions. The Learning Bank data base was reviewed and rolled into the new system as necessary to assure continuity of corrective actions and trending.
The CR process has provisions for assigning significance and evaluation levels to adverse conditions, performing operability and reportability reviews, providing management oversight, assuring root causes of significant issues are addressed, assigning corrective actions and tracking actions to closure, trending performance in the various areas of decommissioning activities, and tracking the overall performance of the CAP through quarterly trend reports. Computer databases are used to trend issues and track the completion of corrective action assignments.
The inspector reviewed implementation of the revised CAP through discussions with the CAP Coordinator and by review of periodic trend reports. Three hundred thirty CRs had been issued through November 19,1998, with corrective actions completed to address adverse conditions for about 87% of the issues. As of this inspection, forty-four CRs remained open pending the completion of corrective action assignments. The licensee assigned the following significance levels te the CRs: 5 were classified significant conditions adverse to quality,133 were classified as conditions adverse to quality, and 192 were classified as "other" conditions. The
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significant conditions adverse to quality included 98-73, radiation monitor issues;98-103, cutting of cable / conduit,98-133, weak implementation of the foreign material exclusion program;98-160, communication system issues affecting emergency preparedness; and,98-292, ineffective implementation of corrective actions for radiation protection issues. The inspector reviewed licensee action in response to the CRs discussed below.
I 98-87. Adverse Trend identified for Craft Labor Performance This report concerned the licensee's determination that an adverse trend was l
developing for craft labor industrial safety performance. The licensee noted an increased frequency of safety precursor events that was caused by deficiencies in l
skills, knowledge and rule-based errors. The corrective actions included meetings
- with craft supervisors and personnel to resolve the individual problems, and the completion of a common cause analysis for CR98-8 dated April 21,1998. The analysis identified organizational, program and management deficiencies, and identified additional corrective actions to resolve the issues. The corrective actions included the development of a " Master Corrective Action Plan for Contractor Oversight and Physical Work Performance," that would remain in place until improvements were made. The licensee used the Quality Programs Department to develop a set of quality indicators to measure performance improvements.
Licensee perfo nance was good in the use of the new CAP to trend performance, and follow up
. ions were thorough to evaluate the causes for the trend and to take appropris actions.
23-252/277. L A PLC Stopoed Uodatina/ Lock-uo This item concerned the discrepancies in the operation of the control room programmable logic controller (PLC): the discovery on September 9,1998, that the j
PLC had stopped updating (98-252), and that the PLC had locked up on
September 30,1998 (98-277). Both problems were identified in a timely manner by l
licensee personnel and proper functioning of the PLC was immediately restored.
Corrective actions were appropriate to identify and correct the cause of the problems, which involved a space limitations on the hard drive used on the server workstation (reference engineering memorandum JST98-002 dated j
October 7,1998).
i 98-276 & 283. Loss of SFP Water This item concerned the loss of water from the SFP due to valve lineup erro's. The first event was discovered on September 30,1998, when workers noted water flowing into the fuel building pipe tunnel (98-276). The licensee found fuel pool sample valve FPU-18 open, and estimated the valve had been open for about 75 minutes. Corrective actions were appropriate to shut the valve, verify other valves in the vicinity were shut and investigate the event. FPU-18 is a ball valve with a level handle that turns through 90 degrees to operate the valve. The licensee
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concluded the handle on FPU-18 was inadvertently bumped open by workers in the area. To preclude recurrence, the licensee removed the handle on FPU-18 and an adjacent valve which was deemed susceptible to inadvertent operation. Additional corrective actions were under evaluation and not yet complete as of October 9,1998.
On October 9,1998, workers noted that water was flowing into the fuel buildhg sump (98-283). The licensee found fuel pool sample valve FPU-9 open, and estimated the valve had been open for about 30 minutes. Corrective actions were appropriate to shut the valve, remove the handles from FPU-9 and FPU-25, stop work in the area that might impact the spent fuel systems, and brief workers on precautions to take when working around valves. Additional corrective actions included adding pipe caps (or verifying caps were installed) on similar drain valves (as well as vent and interface valves). This action was effective to add an additional barrier to leakage.
The inspector walked down the plant system and components involved in these events to verify the adequacy and completion of the corrective actions. The pipe caps and valve handles were configured per the licensee's administrative controls established in procedure 1-17-1. Level recordings of the SFP showed that the decrease in water levelin each event was minor (fractions of an inch). The SFP and attached piping were designed such that any drain down event was self limiting due
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to the presence of siphon breaks (reference drawings SFPI-OD and SFPI-FM-97A),
providing assurance that spent fuel would remain covered by greater than ten feet of water, and thus would remain adequately cooled and shielded. Finally, the inspector independently verified that pipe caps wore added to all valves susceptible to the type of event described in CRs98-276 and 283. All similar valves in the SFP cooling system were controlled except for FPU-11 and FPU-13, which are vent and drain valves for filter FL-2. The licensee concluded that since these valves were located in an inaccessible area under concrete shield blocks, W,9 caps were not necessary to assure adequate control of the valve lineup configuration.
The inspector concluded that the licensee corrective actions for the first event were incomplete at the time of the second event. The corrective actions following the second event were comprehensive and thorough, and sufficient to preclude recurrence of this non-repetitive, licensee identified and corrected failure to maintain configuration of valves in accordance with procedures. This f ailure to maintain configuration of these valves is a violation of TS 5.5.1.a. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CR 98-276 and CR 98-283 (NCV 98-05-02).
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Conclusions The inspector concluded the revised process had the essential elements to assure compliance with 10 CFR 50 Appendix 8. The new CAP process was well implemented as was evident in the organization of the process, the kno.vledge of
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the CAP personnel, the use of trending and quarterly reports to track performance, and the thorough investigation of adverse conditions. Further improvements can be achieved in preventing repetitive events and assuring timely corrective actions.
Licensee corrective actions for the specific adverse conditions described above were appropriate and generally thorough.
111. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Effluent Monitorina a.
Insoection Scone (84750)
The newly installed primary vent stack (PVS) air sampler system for monitoring airborne releases was reviewed. Plans for handling liquid wastes generated during decommissioning were also reviewed.
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Observations and Findinas Airborne Effluents Beginning in December 1998, the licensee had observed potential problems with particulate samples collected from the new PVS air sampler. Each sample is collected for a week, arid when the filters were collected it was noted that the pattern of particulates on the surface of the filter was atypical for such samples.
There was not a sharp delineation at the edge of the collected particulates, indicating the possibility of bypass air flow around the sample filter. The pattern also looked as if some liquid had been on the filter surface, in a system designed to be dry. The licensee had been dealing with these problems as they arose, and was in contact with the equipment vendor to resolve them. When the vendor acknowledged the filter could have bypass flow of indeterminate magnitude, the licensee declared the system inoperable, and commenced alternate sampling in
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accordance with the TSs. Alternate sampling was in place for about one week until
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the vendor's recommendation was implemented to add gasket material to the filter assembly. The licensee's investigation and evaluation of system performance was being tracked as CR 99-02.
Liauid Effluents The licensee has abandoned the liquid waste processing system as part of the decommissioning of the facility. The DOC has the responsibility for handling the disposal of liquid radioactive waste. Liquid wastes are collected in liquid waste tank TK-109. Previously, the liquids received by this tank were processed through the Duratek system, an ion exchange resin cleanup system that removed radioactive contaminants from the water. TK-109 has a volume of 5800 gallons. The tank still receives waste, primarily the content of sumps pumped from the fuel handling building and waste water from respirator cleaning. The DOC, through its subcontractors, has analyzed methods for handling the liquid waste from TK-109.
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Solutions under evaluation include pumping the water into tank trucks for offsite processing and eventual disposal or re-powering the Duratek system and re-issuing the procedure as a DOC procedure. This latter method involves altering the
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flowpath of the liquid effluents because the service water volume is no longer available for dilution. The Offsite Dose Calculation Manual (ODCM) is to be revised to incorporate the change in the liquid release methodology and will be submitted as part of the routine ODCM report.
As a short-term solution, the DOC is using tank trucks and off-site processing / disposal to handle the liquid radwaste release. An inspector observed the loading of one tank truck of waste water and found no problems. lne DOC wa<
planning to implement a liquid waste processing system during 1999 to handle future liquid wastes generated during decommissioning activities. Engineering work was in process on this system, and the inspector noted that the licensee planned a system readiness review after installation was complete, and prior to placing the system into service. Radiation monitor 1601 had been moved from its previous location in the plant and installed as part of the new processing system, to provide capability for continuous monitoring of liquid discharges. The startup testing of this system will be controlled by a work orcer installation and startup of the system will continue to be reviewed as work progresses.
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Conclusions
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The licensee is actively working with appropriate emphasis on these issues related to gaseous discharge particulate monitoring and re-establishing on-site capability for processing and discharging liquid waste.
R1.2 Control of Radioactive Sourqng a.
Insoection Scooe Follow-up actions were reviewed related to CR 98-361 which addressed discrepancies identified during an inventory of radioactive sources.
b.
Observations and Findinas Durir.g the inventory at the end of 1998, the licensee identified discrepancies in the sources identified versus the records of sources installed in the plant. The discrepancies were documented as a CR for further investigation. The licensee reviewed previous inventories, as well as procurement and disposal records since Maine Yankee began operation, and determined that the preliminary probable cause of the discrepancies was misreading of the difficult-to-interpret identifications on the sources themselves. For example, at times over the years a "3" was recorded as an
"8" or a "6", and then again later as a "3". The total activity for which disposition is not determined at the close of this inspection is less than the threshold requiring a report to the NRC. The licensee plans a comprehensive review of all discrepancies as part of the investigation associated with this CR, and expects to review
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disposition of sources shown on previous inventories to assure that there is accounting for all sources.
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Conclusions Licensee investigation work was in process and was addressing all aspects of the issue. Results of the investigation will be reviewed when they are completed.
R1.3 Use of Gamma Radiation Field Imaoina a.
Insoection Scope l
Use of a gamma camera to document location and intensity of radiation sources was reviewed.
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Observations and Findinas
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The licensee was using a gamma camera / detector instrument to superimpose gamma radiation field measurements on a video image of installed equipment in the plant. The resulting images showed the greatest radiation source in a room as color superimposed on a black and white photo. The images were being collected to enable removal of radiation sources in the vicinity of plant equipment so that general area and localized radiation fields can be efficiently reduced before workers enter the areas to work on dismantlement. The licensee's approach to reduce radiation sources was effectively identifying the highest exposure sources to be removed and offers significant potential for worker dose savings.
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Conclusions Use of the gamma camera is expected to be an effective element in the licensee's ALARA program, potentially reducing radiation exposures in areas of the plant with the highest radiation fields.
R6 RP&C Organization and Administration I
R6.1 Control of Plant Access
a.
Inspection Scooe Procedures and other controls to limit plant access and issuance of dosimetry to qualified individuals wero reviewed. The circumstances related to granting access to the protected area (PA) and permitting entry to the radiological control area (RCA)
on a radiation work permit (RWP) contrary to the requirements of plant procedures were reviewed.
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Observations and Findinas On January 14,1999, the inspector was denied dosimetry by the automated dosimetry system upon attempting to log-in to observe the routine changing of the particulate filter in the primary vent stack sampler. The inspector had entered the plant, been issued dosimetry by the automated system, and successfully signed-on to radiation work permits (RWPs) on January 13,1999. The inspector discussed the circumstances with Security and with Training Department personnel. The licensee's procedures require that access training (General Employee Training, or GET) be current, and training qualifications expire at the end of the 12* month following the previous training administration date. In this case, the inspector's training had been conducted in December 1997, and therefore the qualifications had expired at the end of December,1998. The Training Department typically sends a notice to individuals 30 days in advance of qualification expiration, although in this case, it was not clear to what address the notification had been sent. Typically, the i
individual is required to complete requalification prior to being granted access to the
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plant. This requirement should have prevented the granting of access and issuance
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of dosimetry on January 13,1999.
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The licensee's mechanism for controlling and limiting access to only individuals with current qualifications is described in Maine Yankee Training Department Training Course Description " General Employee Training (GET) Recertification Course". The course description specifies that " Failure to recertify for plant access will result in written notification to the Security Director requesting that plant access be denied.
This notification will be sent on the cognizant instructor's first working day after failure to recertify." The MY Training Department had generated a list of individuals whose qualifications expired at the end of December,1998. However, two names were omitted from the report transmitted from the Training Department to the Security Department. Security did not, therefore, suspend access authorization for these individuals.
When dosimetry was issued to the inspector on January 13,1999, the computer system raised an administrative flag indicating that GET was expired. This flag was erroneously waived at the time for the inspector, and dosimetry issued.
The inspector noted that the Training Department's failure to notify Security of the expired qualifications did not follow the licensee's procedure contained in the GET Recertification Course document, which is a violation of NRC requirements. The licensee also noted that the waiver of GET qualification by dosimetry violated licensee Health Physics procedure 0.2, " Restricted Area Access and Dosimetry Program". Prior to the inspector's departure from the site on January 14,1999, the licensee confirmed that no other individuals with expired qualifications had been mrmitted to access the site, and that all personnel then working on the site had been issued dosimetry appropriately.
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Conclusions To address these procedural violations, the licensee initiated CR 99-7 in the Maine Yankee corrective action tracking system. Licensee corrective actions were being implemented at the end of the inspection period, with an initial barrier screening and immediate corrective actions complete. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is ir ? 3 licensee's corrective action program as CR 99-07 (NCV 98-05-03).
P8 Miscellaneous EP issues and Follow-Up of Previous inspection issues a.
Insoection Scope A training drill in the control room was observed, and licensee work on open items was reviewed.
b.
Qb_pervations and Findinns A training drill was observed in the control room. The objective of the drill was to address the observations and findings identified during the last exercise conducted during October,1998. The inspector noted that the drill specifically covered areas identified during the October exercise as requiring performance improvement.
Licensee corrective actions to address violation 95-16-01 were reviewed. This violation was a failure to maintain currently calibrated self-reading dosimeters and radiation survey equipment within some emergency kits in accordance with procedures. Since the violation occurred, the licensee had revised procedures controlling how calibrated EP equipment was maintained. The inspector reviewed Procedure No.26-406, Revision 0, " Emergency Equipment Inventory". This procedure specifies that during quarterly inventories of EP equipment, any equipment with calibration dua dates before 2he next inventory due date shall be replaced. This action will assure that the causes for the violation will not recur.
The inspector reviewed the EP equipment stored in the Technical Support Center and noted that the equipment calibrations are current.
c.
Conclusions Based on the effective corrective actions taken, violation 50-309/95-16-01is closed.
IV. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspe' ton results to representatives of the licensee at the end of each o site inspection, md summarized the inspection period findings
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during a teleconference on February 11,1999. The licensee acknowledged the findings presented.
X2 Community Advisory Panel Meetings Region I staff attended meetings of the Community Advisory Panel for Decommissioning Maine Yankee on November 19,1998 and January 21,1999, to provide updates on NRC activities.
Region I staff and representatives from NRR attended two meetings on November 9, 1998. At a meeting open for public observation, the licensee introduced representatives from the DOC and presented an overview of the schedule for decommissioning the facility. The licensee also entertained questions at the conclusion of the meeting. On the evening of November 9,1998, representatives of the State of Maine, the licensee, and NRR made presentations concerning the defueled emergency plan to representatives of the community. This meeting was conducted by the state's Nucl ear Safety Advisory Panel.
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Attachment I
The issues listed 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), LERs and follow up of previous violation (VIO) issues are closed.
Issues Related to the Escalated Enforcement Action 01013 VIO Flood Elevations in Containment (EA96-299)
01013 VIO Testing of Safety Actuation System (EA96-320)
01013 VIO Corrective Actions for Check Valves (EA97-34)
01013 VIO Corrective Actions for Ventilation issues (EA97-147)
01023 VIO Testing of Safety Systems (EA96-299)
-01033 VIO Testing of Emergency Power Systems (EA96-299)
01043
. VIO Testing of Emergency Feedwater System (EA96-320)
01053 VIO Testing of Safety System Check Valves (EA96-320)
02013 VIO CCW Pump Motor Environmental Qualification (EA96-299)
02013 VIO Testing of Safety Instruments (EA96-320)
02013 VIO Control Room Ventilation Pressure (EA97-34)
02023 VIO SCCW Pump Motor Environmental Qualification (EA96-299)
03013 VIO Technical Specification 4.5 Testing (EA96-320)
03013 VIO Corrective Actions for HVAC Test (EA97-34)
03013 VIO Failure to Make Changes per 50.59 (EA97-34)
03023 VIO Failure to Make Changes per 50.59 (EA97-34)
03033 VIO Failure to Make Changes per 50.59 (EA97-34)
03043 VIO Failure to Make Changes per 50.59 (EA97-34)
03053 VIO Failure to Make Changes per 50.59 (EA97-34)
03063 VIO Failure to Make Changes per 50.59 (EA97-34)
08013-VIO Failure to Make Changes per 50.59 (EA97-34)
j 04013 VIO Technical Specification 4.6 Testing (EA96-320)
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04013 VIO Failure to Make Changes per 50.59 (EA97-34)
04013 VIO Corrective Actions for Breathing Air System (EA97-34)
04023 VIO Corrective Actions for instrument A!r System (EA97-34)
04033 VIO Corrective Actions for CSB Ventilation (EA97-34)
09013 VIO Corrective Actions for CSB Ventilation (EA97-34)
04043-VIO Corrective Actions for Auxiliary Feedwater System (EA97-34)
10013 VIO Corrective Actions for Auxiliary Feedwater System (EA97-34)
04053 VIO Corrective Actions for Turbine Hall Flooding (EA97-34)
11013 VIO Corrective Actions for Turbine Hall Flooding (EA97-34)
04063 VIO Corrective Actions for Service Water System (EA97-34)
05013 VIO Failure to Make Ch6nges per 50.59 (EA97-34)
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05014 VIO Procedures for Staffing (EA97-34)
12014 VIO Procedures for Staffing (EA97-34)
13014 VIO Inadequate Control of Testing and Logs (EA97-34)
'06014 VIO Inadequate Operability Determinations (EA97-34)
14014 VIO Inadequate Operability Determinations (EA97-34)
07014 VIO Testing of Emergency Feedwater Pump (EA97-34)
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15014 VIO.
Testing of Emergency Feedwater Pump (EA97-34)
08014 VIO Procedures for Fastener Lock Wires (EA97-34)
16014 VIO Procedures for Fastener Lock Wires (EA97-34)
09014-VIO Work Control Practices (EA97-34)
17014 VIO Work Control Practices (EA37-34)
18013 VIO - Inadequate Testing of Safety Components (EA97-34)
19013 VIO Inadequate LPSI Design (EA97-34)
20013 VIO Corrective Actions for CSB Fans (EA97-34)
01012 VIO Inadequate 50.46 Accident Analyses 01022 VIO Inadequate 50.46 Accident Analyses 02034 VIO Inadequate 50.46 Accident Analyses 02044 VIO Inadequate 50.46 Accident Analyses issues Related to Plant Operations 97-03-01 VIO Operator Error During LPSI Testing 97-06-01 VIO Operator Error Performing Valve Lineups 97-05-02 VIO Inadequate Corrective Action for Crane Interaction 96-16-26 URI Design Basis information Varied-96-16-27-URl Conflicting Calculations for Post-LOCA Conditions
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96-16-29 URi Atmospheric Steam Dump Valve 96-16 30 URI Specialty Training Program for Technicians 96-16-28 URI Corrective Actions 97-06-00 LER Propane Tank Stored Near Pump House 97-07-01 URI Temporary Fans in Switchgear Room 98-14-01 VIO Operation of the Spent Fuel Crane 96-04 02 VIO Maintenance Procedures for Safety Systems 96-11-01 URI Testing of SIAS Circuit i
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PARTIAL LIST OF PERSONS CONTACTED Licensee l
M. Meisner, President M. Ferri, Vice President-Decommissioning l
W. Odell, Director of Operations R. Fraser, Director, Engineering S. Evans, Manager, Environmental Health & Safety / Emergency Preparedness J. Sauger, Maintenance Manager T. Williamson, Quality Assurance Manager W. Ball, Manager, Operations J. Mallon, Radiation Protect Manager J. Niles, Assistant Manager, Operations M. Evringham, Manager, Maintenarice G. Zinke, Director-Regulatory Affairs J. McCann, Licensing W. Lach, Cherr;stry E. Brand, Licensing M. Whitney, Licensing
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J. Temple, Emergency Preparedness Coordinator j
Other P. Dostie, Maine, Nuclear Safety inspector
D. Randall, Maine Nuclear Safety inspector
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S. Gray, Site / Construction Manager, Stone & Webster
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INSPECTION PROCEDURES USED IP 40500:
Effectiveness of Licensee Coritrols in Identifying, Resolving, and Preventing Problems IP 60705:
Preparation for Refueling IP 71714:
Cold Weather Preparations IP 71801:
Decommissioning Performance and Status Review IP 84750:
Radwaste Treatment / Effluent and Environmental Monitoring ITEMS OPENED, CLOSED, AND DISCUSSED ltems Opened:
None items Closed:
LER 97-07-00, No Radiation Protection Technician Onsite.
VIO 97-08-01, Control of Security Systems.
VIO 97-08-02, Fire Watch Logs.
VIO 97-05-01, Inadequate Cranc Checks During Refueling.
tJRI 96-16-22, Heat Exchanger Temperature Rating.
VIO 96-12-01, installation of Primary Ventilation Stack Filters.
NCV 98-05-01, No Radiation Protection Technician Onsite.
NCV 98-05-02, Licensee identified and corrected failure to maintain configuration of valves in accordance with procedures.
NCV 98-05-03, Licensee failure to follow GET procedure.
Items Discussed:
None.
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LIST OF ACRONYMS USED BOP Balance of Plant CAL Confirmatory Action Letter CAP Corrective Action Process CRs Condition Reports DHR Decay Heat Removal DOC Decommisioning Operations Contractor ECCS Emergency Core Cooling System FSAR Final Safety Analysis Report ISA Independent Safety Assessment LDB Licensing and Design Basis ODCM Offsite Dose Calculation Manual
.PLC Programmable Logic Controller PVS Primary Vent Stack RP&C Radiological Protection and Chemistry SBLOCA Small Break Loss-Of-Coolant Accident SERT System Evaluation and Reclassification Team SFP Spent Fuel Pool SFPB Spent Fuel Pool Building SFPI Spent Fuel Pool Island TS Technical Specificptions
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