ML20138J675
| ML20138J675 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 02/04/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20138J669 | List: |
| References | |
| 50-213-96-13, NUDOCS 9702070418 | |
| Download: ML20138J675 (28) | |
See also: IR 05000213/1996013
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U.S. NUCLEAR REGULATORY COMMISSION
REGION 1
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Docket No.:
50-213
License No.:
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Report No.:
50-213/96-13
Licensee:
Connecticut Yankee Atomic Power Company
P. O. Box 270
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Hartford, CT 06141-0270
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Facility:
Haddam Neck Station
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Location:
Haddam, Connecticut
Dates:
November 16,1996 - January 5,1997
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inspectors:
William J. Raymond, Senior Resident inspector
Peter J. Habighorst, Resident inspector
Joseph T. Furia, Senior Radiation Specialist
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Approved by:
John F. Rogge, Chief, Projects Branch 8
Division of Reactor Projects
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9702070410 970204
ADOCK 05000213
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EXECUTIVE SUMMARY
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Haddam Neck Station
NRC Inspection Report No. 50-213/96-13
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This integrated inspection included aspects of licensee operations, engineering,
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maintenance, and plant support. The report covers a 7 week period of resident inspection;
in addition, it includes the results of announced inspections by a regional specialists in the
area of radiological controls.
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Plant Operations
The licensee successfully completed activities to end refueling outage work and maintain
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the spent fuel adequately cooled. Actions were taken to place plant systems in standby or
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layup as needed to assure short term protection and long term preservation as plans to
decommission the facility were completed. The licensee uses a technical clarification
process to assure uniform implementation of license requirements. The licensee will
remove references to discussions with the NRC as part of the documented bases for the
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clarifications.
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Maintenance
Poor procedure adherence was demonstrated when emergency diesel generator 2B was
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operated for a routine surveillance test with the Jacking tool attached 1to the engine.
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Although there was no apparent damage to the diesel, the error appears as a continuation
of past performance problems. The failure to follow procedures was a violation of NRC
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requirements. Poor work planning, communications and an inadequate procedure
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contributed to the failure to install bolting as intended on a blank flange for the fuel transfer
tube. Although health physics support was good to conduct surveys for the job and to
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monitor the diver's exposure, the failure to adequately plan the job resulted in the need for
an additional dive and worker exposure to complete the task. Plant personnel exhibited
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good procedure adherence to account for special nuclear material.
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Enaineerina
The licensee completed an operability assessment of the loading sequence for the "A"
emergency diesel generator. An engineering evaluation determined that the diesel was
capable c' performing its intended function. The past reportability evaluation for this
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historicai condition was conservative. Licensee evaluations for a 10 CFR Part 21 issue
regarding the seismic qualification of plant relays were appropriate. However, the delays in
processing the vendor notification highlight a continuing weakness in the corrective action
process.
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Plant Sucoort
Although the licensee maintains a generally effective program in radiation protection, a
general decline in performance in this area was noted. While the licensee continues to be
very effective in reducing the amount of contaminated areas in the plant and effectively
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implements As Low As is Reasonably Achievable (ALARA) controls for planned work
evolutions, the general quality of surveys, Radiation Work Permits and control point log
books has declined. The Northeast Utilities Services Company (NUSCO)
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thermoluminescent dosimeter (TLD) laboratory continues to maintain National Voluntary
Laboratory Accreditation Program (NVLAP) accreditation of its programs. Recent NVLAP
identified deficiencies are currently being addressed by the NUSCO TLD Laboratory. The
licensee has selected a fully qualified individual to serve as interim Radiation Protection
Manager. Other staffing changes in the interim and decommissioning organization have
generally minimalimpact on the type and number of personnel serving in the radiation
protection organization.
The licensee does not document on trouble reports all deficiencies identified in the
perimeter intrusion detection system. An open inspection item will track the licensee
actions to complete timely corrective actions for nuisance alarms.
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TABLE OF CONTENTS
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EX EC UTIVE S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
TA B LE O F CO NTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
R E PO R T D ET A I LS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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Summ ary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1. O p e r a t i o n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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O1
Condu ct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01.1 Cessation of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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Operations Procedures and Documentation
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03.1 Technical Specification Clarification Process
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Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
08.1 (Closed) IFl 94-22-01, Risk Significant Operator Actions . . . . . . . . . . . . 5
11. M a i n t e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
M1
Conduct of Maintenance
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M1.1 Maintenance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
M1.2 Surveillance Observations
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M4
Maintenance Staff Knowledge and Performance . . . . . . . . . . . . . . . .
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M4.1 Emergency Diesel Generator Testing (VIO 96-13-01)
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M8
Pre viou s O pe n it e m s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
M8.1 (Closed) URI 96-08-07, Appendix J Test of Penetration P50 . . . . . . . . . 9
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M8.2 (Closed) IFl 93-01-01, EDG Instrument Calibration . . . . . . . . . . . . . . . 10
M8.3 (Closed) URI 94-14-01, Corre ctive . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
111. Engineering
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E2
Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 11
E2.1
Diesel Generator Loading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
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E2.2
10 CFR 21 Report on Seismic Certification of Safety-Grade . . . . . . . . . 12
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Previous Open item s (9 2902) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
E8.1
(Closed) URI 93-15-02, Modify Pressure Locking MOVs
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E8.2 (Closed) URI 95-04-01, Operation with Steam Generator Plugs
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E8.3 (Closed) URI 96-01-02, Design Basis Verification
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E8.4 (Closed) URI 96-01-03, RVLIS Operating Practices . . . . . . . . . . . . . . . 13
E8.5 (Closed) URI 96-02-01, Containment Controls for Main Steam Valves
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E8.6 (Closed) URI 96-06-02, Emergency Operating Procedure Changes . . . . 13
E8.7 (Closed) URI 96-08-14, Core Deluge Valve Calculations
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E8.8 (Closed) URI 96-201-23, Service Water Two Phase Flow
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E8.9 (Closed) URI 96-201-25, R H R Pu m p N PS H . . . . . . . . . . . . . . . . . . . . . 14
E8.10 (Closed) URI 94-25-01, Actions to improve Instrument Air Quality . . . . 14
E8.11 (Closed) URI 94-17-03, Design of Reactor Coolant Pump Oil Piping
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E8.12 (Closed) IFl 94-09-01, Corrective Actions for Boron Dilution . . . . . . . . 15
I V Pl a n t S u p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
R4
Staff Knowledge and Performance in RP&C . . . . . . . . . . . . . . . . . . . . . . . . . 16
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R4.1
Effectiveness of the Radiation Protection Program implementation . . . . 16
R4.2 Dosimetry Laboratory Review by NVLAP . . . . . . . . . . . . . . . . . . . . . . 17
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Miscellaneous Radiological Protection and Chemistry Controls issues . . . . . . . 18
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R8.1
(Closed) URI 95-06-01, Bypass of Locked HRA Gate . . . . . . . . . . . . . . 19
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R8.2 (Closed) URi 95-10-01, Evaluation of the MRCA Function . . . . . . . . . . 19
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Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . . . . . 19
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Fitness for Duty Events . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
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Status of Security Facilities and Equipment
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S2.1
Maintenance of Security Equipment (IFl 9 6- 13-0 2 ) . . . . . . . . . . . . . . . 19
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V. M a n a g em e nt M e eting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
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Exit Mee ting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
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REPORT DETAll.S
Summary of Plant Status
Haddam Neck remained shutdown with the reactor in a defueled condition during the
inspection period. On December 4,1996, the board of directors for the joint owner of
Haddam Neck voted to permanently close the plant and immediately cease operations prior
to expiration of the operating license. The decision to retire the facility followed an
economic analysis that showed continued operation was not favorable. The closing
occurred after 29 years of service for an operating license that expires in 2007. On
December 5, the licensee informed the NRC pursuant to 10 CFR 50.82(a)(1)(i) and
50.82(a)(1)(ii) that the fuel had been permanently removed from the reactor and that the
reactor would no longer be operated.
l. Operations
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Conduct of Operations'
01.1 Cessation of Operations
a.
Inspection Scoce (93702)
The purpose of this inspection was to review the licensee activities following the
decision to permanently cease plant operations.
b.
Observations and Findinas
00 December 5,1996, the licensee submitted a letter to the NRC pursuant to 10
CFR 50.82(a)(1)(i) and 50.82(a)(1)(ii) certifying the permanent cessation of
operations, and that the fuel had been permanently removed from the reactor.
Following the December 5 certification letter, the licensee was no longer authorized
under operating license DPR-61 to operate the reactor, or to place or retain fuel in
the reactor vessel. The licensee has 2 years from the date of the certification letter
to file a plan to decommission the plant, and began actions necessary to prepare the
Post Shutdown Decommissioning Activities Report (PSDAR). The licensee intends
to use the 1997 period to analyze and plant the decommissioning options. The
PSDAR will describe the planned decommissioning activities, describe a schedule for
accomplishing the activities, provide an estimate of tne cost of the
decommissioning, and discuss the environmental impacts. The PSDAR will be
supplemented by the license termination plan, which willidentify the activities and
schedule releasing the site for unrestricted use. The licensee cannot begin any
major activities to dismantle the plant until 90 days after the submittal of the
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Topical headings such as 01, M8, etc., are used in accordance with
the NRC standardized reactor inspection report outline.
Individual reports
are not expected to address all outline topics.
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Defueled Ooeratino Status and Activities
The licensee ended refueling outage #19 with the completion of defueling, and
ceased all plant operating and maintenance activities except as necessary to
maintain the spent fuel pool conditions, and place plant systems in standby or layup
conditions for long term preservation. During this period, the licensee shut down
reactor systems that were no longer needed, and maintained operating or operable
those systems required to support the spent fuel cooling. For example, with all fuel
removed from the reactor vessel as of November 15,1996, there no longer was a
need to keep the residual heat removal (RHR) or the nuclear instrumentation
systems (Nis) operable. The operating RHR pump was shut down and the A RHR
heat exchanger inlet valve RHR-V-791 A was closed on November 15. The Nis were
de-energized on November 16.
Other plant systems were left in the condition needed to support the defueling,
maintenance or modification work. The emergency core cooling systems remained
shutdown, and in a functional status, except that surveillance testing on these
systems (residual heat removal, low pressure safety injection, and high pressure
safety injection, emergency safety features actuation and reactor protection) vvas no
longer required. The reactor coolant pumps and other reactor support systems
remained shutdown, with the loop isolation valves closed and the bypass valves
open. The reactor remained in the condition that existed to support defueling, with
the reactor head removed and the internal package stored in the flooded cavity.
The spent fuel pool sluice gate and the fuel transfer tube valve had been closed at
the completion of defueling an November 15 to separate the spent fuel pool from
the reactor cavity. The licensee completed actions this period to further secure the
fuel transfer tube by installing a blind flange on the cavity end of the tube. The
primary contair: ment and isolation system remained functional, but reactor integrity
or closure was no longer required. The licensee opened the containment equipment
hatch on December 12 to facilitate personnel access and the removal of refueling
outage equipment. Systems that were disturbed for the outage for maintenance
and modifications (e.g., the service water lines to the containment air recirculation
fan coolers) were left out of service and drained as needed to assure freeze
protection.
The spent fuel ventilation and cooling systems were maintained functioning per
Normal Operating Procedures (NOP) 2.10-1 and 2.15-3 to keep the spent fuel
cooled. The "B" spent fuel pool (plate) heat exchanger and the "A" spent fuel
coolir g pump remained in service to keep fuel pool temperature below 150 degrees
fahrenheit (F). The e tual temperature remained in the range of 80 to 85 degrees F.
The licensee kept the "D" service water pump operating and part of the South SW
header in service to support spent fuel pool cooling. The "A" component cooling
water pump also remained in service to support operation of the radwaste systems.
The spent fuel building enclosure and ventilation system remained operable. The
inspector reviewed licensee activities to assure compliance with the following
Technical Specifications (TS):
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TS 3.9.3, Spent Fuel Decay Time for Offload
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TS 3.9.12, Spent Fuel Building Air Cleanup System
TS 3.9.13, Movement of Fuel in SFP (Boron Concentration)
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-TS 3.9.14, SFP Reactivity Condition
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Technical Specifications 3.9.1, 3.9.2, 3.9.4, 3.9.5, 3.9.6, 3.9.8, 3.9.9, and 3.9.10
apply to plant conditions with fuel in the reactor vessel or movement of fuel inside
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the containment, and were no longer applicable to the defueled condition. The
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inspector reviewed licensee activities to complete the surveillance requirements for
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the spent fuel pool and building, which included the tours by the nuclear side
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operators once each shift per SUR 5.1-OA. No inadequacies were identified.
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Surveillance Testina
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Surveillance testing was performed per the existing Technical Specifications (3.0.1
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and 4.0.1), and as defined for equipment required to be operable for the applicable
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operating mode. Most surveillance requirements were no longer applicable with the
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reactor in the defueled condition, and are no longer planned. The testing would be
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reinstated as needed when the plant entered a mode in which the associated
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equipment was required to be operable, or was changed by a license amendment.
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The suspension of testing was permitted under the current license conditions. The
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licensee elected to keep performing surveillance testing on some equipment not -
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required to be operable. For example, Technical Specifications 3.8.1.1, 3.8.1.2,
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4.8.1.1. and 4.8.1.2 require the emergency diesel generators be operable during
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operational modes 1 through 6, and do not specifically require any diesels be
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operable for the defueled condition. The licensee maintained both emergency
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diesels operable and under surveillance, as well as the shutdown risk (air-cooled)
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diesel. The licensee continued to perform the operational readiness, hourly test
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runs on the diesels on a biweekly schedule. Other plant systems that were required
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to remain operable for all modes (such as radiation monitoring and fire protection)
remained operable and tested. No inadequacies were identified.
Facility Staffina
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Technical Specification 6.2.2 establishes the facility staffing requirements and
establishes the minimum shift crew composition for operational modes 1 through 6.
The minimum staffing for a defueled condition was not specified in the current
license conditions. The licensee elected to maintain minimum shift staffing in
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accordance with the requirements for Mode 6 - refueling, with the following crew
composition: 1 shift manager (senior reactor operator); 1 control operator (licensed
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reactor operator); and, 2 auxiliary operators (non-licensed).
Aside from the minimum shift staffing, the licensee announced plans to reorganize
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the plaat staff and reduce plant staffing to levels needed to complete ths
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decommissioning project. The licensee's intention was to decrease the plant
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staffing levels (excluding contractors) from the present level of 322 in two phases.
By April,1997, the licensee plans an organization comprised of a permanent and an
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interim decommissioning staff. The permanent staff (about 105 workers,
supervisors and managers) would be the long term staff needed to complete the
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decommissioning project. The interim staff (about 66 members) would be the extra
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personnel needed to complete a smooth transition from the operation phase to the
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decommissioning phase. The interim staff would remain in place until the end of
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1997. The licensee initiated programs to assure the orderly placement of
permanent plant staff into other jobs. In addition to the permanent staff, the
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licensee maintained contractor personnel on site as necessary to assure continuity
of programs in progress, such as the configuration management plan (CMP). Even
though the scope of plant systems requiring definition of the design and licensing
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basis would shrink considerably for the decommissioning status of the plant, the
CMP still had to be completed for systems needed to support the safe storage,
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handling and cooling of spent fuel.
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At the end of the inspection period, the licensee had initiatives in prorress to define
the decommissioning plan and project, evaluate which plant systems and interfaces
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would have to be maintained for the safe storage of fuel, define the set of
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surveillance and technical specification equipment requirements needed to support a
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defueled status, and to prepare proposed changes to the license as needed.
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c.
Conclusions
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The licensee successfully completed activities to end the refueling outage work and
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maintain the spent fuel adequately cooled. Actions were taken to place plant
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systems in standby or layup as needed to assure short term protection and long
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term preservation as plans to decommission the facility were completed.
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Operations Procedures and Documentation
O3.1 Technical Specification Clarification Process
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a.
Inspection Scooe
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The inspection was to evaluate the licensee's technical specification (TS)
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clarification program and prior NRC approval or involvement. The NRC's position is
that it is an unacceptable practice for licensee's to use informal NRC approved or
accepted clarifications of TSs. Clarification mutt be sought through a formal
licensing process, implementation of the 10 CFR 50.59 process, or official NRC
correspondence.
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b.
Observations and Findinas
The licensee has approximately fifty (50) TS clarifications that are documented in
the technical requirements manual. The TS clarification program began in April,
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1991. Inspector review of the TS clarification program concluded that the program
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does not include informal NRC endorsement or approval. However, three TS
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clarifications had documented discussions with the NRC staff as part of the
supporting information. The clarifications involved definition of Mode 6, opening of
one of two containment hatches in Modes 1,2,3 or 4, and technical specification
surveillance requirements for the main steam safety relief valves.
The inspector notified licensee personnel of the NRC position on TS clarifications.
The licensee acknowledged the NRC position, and committed to evaluate the three
referenced TS clarifications for omittance at the end of the inspection period. On
December 5,1996 the licensee informed the NRC pursuant to 10 CFR 50.82(a)(1)(i)
to permanently cease operations at the Haddam Neck facility. The TS clarification
program is expected to undergo extensive revision to support this decision.
c.
Conclusions
The licensee's TS clarification program does not include informal NRC endorsement
or approval. Three examples were identified in supporting documents documenting
NRC staff discussions of the TS issues outside the formallicensing or 10 CFR
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50.59 process. The licensee agreed to evaluate the removal of the documented
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references.
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Miscellaneous Operations issues
08.1 (Closed) IFl 94-22-01. Risk Sianificant Operator Actions
This item was to verify that the licensee emphasized in operator requalification
training the high risk significant operator actions as documented in the individual
plant examination (IPE) report. The particular risk significant operator actions were
during the transfer to containment sump recirculation during a postulated large or
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medium break loss-of-coolant accident (LOCA). The inspector confirmed that
operator requalification program instruction guide C-O-LOFT-95-2-L95203 provided
annual training on the significance of transfer to containment sump recirculation.
Additionally, during simulator scenarios, operators perform the transfer to sump
recirculation.
On December 5,1996, the licensee informed the NRC pursuant to 10 CFR
50.82(a)(1)(i) to permanently cease operations at the Haddam Neck facility. The
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risk significant operator action is postulated during a LOCA at power, for which this
action is no longer applicable. This item is closed.
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11. Maintenance
M1
Conduct of Maintenance
M1.1 Maintenance Observations
a.
Insoection Scope (62703)
The inspectors observed all or portions of the following work activities:
SUR 5.1-1578, Emergency Diesel EG-28 Fast Start Test
PMP 9.1-31, Diesel In-Leakage and Fuel Oil Transfer Pump Availability
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AWO 96-09572, Diving Evolution to Install Transfer Canal Flange
Except as described below, the inspector had no further comments in this area.
b.
Observations and Findinas
On December 10,1996, the inspector observed licensee personnel perform a diving
evolution within the fuel transfer canal to install a flange. The inspector noted a
good pre-evolution briefing for this maintenance activity. The briefing was
performed by the maintenance supervisor and health physics personnel. .he
briefing went over the procedure steps, controls for foreign material exclusion areas,
required health physics surveys, diver stay times for both radiological and personnel
safety, and contingency plans for a loss of diver air supply and a loss of power.
The operations shift manager also provided addition controls on communications
and lessons-learned on the implementation of the wrong revision to the procedure.
The inspector observed good controls for foreign ma:erial, and good health physics
support to monitor the diver's exposure and surveys to detect potential " hot"
particles. After the installation of the blank flange upon the diver's exit from the
canal, maintenance supervision and workers questioned whether the flange was
installed per expectations. The procedure required that five evenly spaced studs or
bolt / nut combinations be installed. The diver installed the fasteners equally spaced
apart on the upper 180 degrees of the blank flange, but not on the lower half. The
diver could not install and torque the bolts as specified due to interferences
between the flange and the transfer cart tracks.
The apparent cause for this work performance issue was a mis-communication
between the diver and the mechanical maintenance supervisor. Contributing causes
were that the diver was provided insufficient studs and bolt / nuts to meet the
procedure's expectation, and the torque wrench used could not torque the lower
fasteners due to interferences. The inspector's interview with the diver noted that
he had performed this evolution in the past, however this was the first time with
only 25% of the bolts installed, and the first time using a torque wrench. No safety
consequence existed due to failing to install bolts equally spaced, since the spent
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fuel pool sluice gate was closed, the containment transfer gate closed, and water
level equalized between the reactor cavity and the spent fuel pool. Additionally, the
licensee did not lower the cavity level until corrective actions could be implemented.
At the end of the inspection period, the licensee decided to perform the dive, and
install all twenty fasteners.
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Coriclusions -
The licensee planning for this work activity failed to adequately address possible
interferences between the flange and the transfer cart tracks. Contributing causes
were the inadequate communications between the job supervisor and the diver. No
safety consequence existed from the inadequate procedure to install the blank
flange. Corrective actions included performance of the evolution after the
inspection period.
The inspector observed good controls for foreign material, and good health physics
support to monitor the diver's exposure and surveys to detect potential " hot"
particles. However, the failure to adequately complete this job resulted in the need
for an additional dive and worker exposure to complete the task.
M1.2 Surveillance Observations
a.
Insoection Scope
The inspectors observed all or portions of the following surveillance activities:
SNM 1.4-19, Fission Chamber Inventory and Accountability (Revision 12)
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b.
Observations and Findinas
On December 23,1996, the inspector observed licensee personnel perform a
periodic inventory of the special nuclear materiallocated on site. The special
nuclear material verified were the excore and incore fission chambers.
The inspector noted that the pre-job briefing performed by the reactor engineer
adequately described the intent of the procedure and the roles of the individuals
involved. The health physics briefing and involvement in this surveillance was
assessed by the inspector as good. The assigned health physics technician
provided a good briefing of the radiation work permit controls, and expected
radiation levels during the inventory. The technician also provided good radiation
monitoring during the temporary movement of shielding for an excore fission
chamber located on the mid-level of the spent fuel building.
The inspector observed involveme ' by a quality control (OC) inspector. The quality
control inspector observed the activity and noted poor lighting in the mid-level of
the spent fuel building, and observed questionable independent verification of serial
numbers for the detectors, since both individuals involved were discussing the
location of the serial number. Both of these observations were discussed between
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the quality control inspector and the licensee. Licensee personnel acknowledged
the QC inspector's comments and identified these issues in the problem
identification process.
The inspector noted that one procedural step states to inventory excore fission
chambers in the containment sump area. The reactor engineer performing the
surveillance told the inspector that no excore fission chambers were located in the
sump area, and that the procedure step was intended to be implemented if excore
fission chambers were temporarily stored in this location. The inspector verified
that no chambers were in the sump area, and noted that the reactor engineer was in
the process of clarifying the procedural step at the end of the inspection period.
The inspector observed that all fission chambers were accounted for and that the
procedure was adhered to by licensee personnel.
M4
Maintenance Staff Knowledge and Performance
M4.1 Emeraency Diesel Generator Testina (VIO 96-13-01)
a.
Insoection Scope (71707)
The inspector reviewed licensee action to test emergency diesel generator EG-2B on
November 27,1996.
b.
Observations and Findinas
The licensee conducted a routine test of EG-28 on November 27,1996. The test
activities included the pre-start jacking and in-leakage checks of diesels EG-2A and
EG-2B per procedure PMP 9.1-31, and the fast start and test of EG-28 per
procedure SUR 5.1-1578. EG-2B started and ran successfully for the one hour test
run. After shutting down EG-28, the nuclear side operator (NSO) conducting the
test noted that he had left the jacking gear mechanism installed for the duration of
the test. The NSO informed the shift manager and prepared adverse condition
report (ACR) 96-1322 to describe the event.
The licensee's immediate corrective action included recovery of the disassembled
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pieces of the jacking gear mechanism from inside the engine compartment; and,
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using a spare gear to jack the engine to inspect the condition of the engine starting
gear and the air start pinions - no degradation was found on the steel components
of the diesel engine. The damage was limited to the jacking mechanism since it has
)
gears made of aluminum. The licensee concluded EG-2B was unaffected by the
)
event and remained operable. The diesel was declared operable at 1:25 p.m. The
licensee verified the jacking mechanism was properly stored on EG-2A and installed
spare jacking tools in the EG-2B room. The inspector observed the conditions of the
damaged jacking tools, the EG-2B engine gear and the air start motor gears, and
verified the licensee conclusions regarding the status of EG-2B. The inspector
completed a post-event review of the standby status of EG-2A and EG-28, and
confirmed both engines were properly. aligned for standby operation.
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The NSO who conducted the November 27 test completed an excellent self-
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assessment of his activities, as documented in ACR 96-1322 and a memorandum
dated December 3,1996. EG-2B was Jacked per steps 6.2.10 through 6.2.12 of
PMP 9.1-31, which is classified as a continuous use procedure which must be in-
hand during the conduct of the test and signed off as each step is completed. After
installing the tool and jacking the engine, the NSO had signed step 6.2.12 as
complete, indicating that the crank tool had been removed and placed on its storage
bracket inside the engine room. In fact, only the electric motor portion of the tool
had been stored and the gear mechanism was left installed on the engine. The NSO
failed to notice the gear as he reinstalled the cover over the jacking area inside the
engine compartment. The NSO discovered the error after completion of the one
hour test run when he noticed that the jacking gear was not stored on the bracket.
The NSO concluded he failed to complete step 6.2.10 of PMP 9.1-31 because he
became distracted when he noticed a frayed cord on the electric motor which
needed to be replaced, and by a brief conversation he had with a quality control
inspector present in the room to observe the EG-2B fast start test.
The inspector identified no inadequacies regarding the diesel status or the licensee's
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conclusions regarding the cause of the event. Although the inspector was not
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aware of a similar event within the last 4 years, the operators noted that the
inadvertent running of a diesel with the Jacking tool installed has occurred in the
past.
]
The inspection record contained other examples of worker performance deficiencies
in the conduct of routine activities: the operator errors and failure to follow
procedures while transferring water to the refuelng water storage tank (Inspection
'
Item 96-11-02); the operator performance issues during the nitrogen intrusion event
in September 1996 (Inspection 96-80, Sections 03 and 04); and, operator errors
while aligning a fuel oil transfer pump and the air compressor during a emergency
diesel test in July,1996 (Inspection 96-08, Section M1.1). The error on November
27 appears as a continuation of past performance problems. The failure to follow
PMP 9.1-31 during the conduct of EG-28 testing on November 27 was a violation
of Technical Specification 6.8.1 (VIO 96-13-01).
c.
Conclusions
Poor procedural adherence was demonstrated during a test of EG-2B on November
27,1996. The occurrence of personnel performance errors in the conduct of
routine activities remains an NRC concern that warrants further licensee action.
M8
Previous Open items
M8.1 (Closed) URI 96-08-07. Apoendix J Test of Penetration P50
This item was open pending NRC review of licensee actions to_ assure containment
penetration P50 was tested in accordance the 10 CFR 50, Appendix J prior to the
resumption of power operation. Other NRC concerns associated with the deficiency
continues to be tracked per item 96-08-08. The technical and regulatory concerns
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associated with this item were no longer applicable to a defueled plant condition
and primary containment integrity that will no longer be required. The plant
systems required to support spent fuel pool cooling contain either manual or air
operated valves that are not susceptible to the type of problems highlighted by tnis
issue. This item is closed.
M8.2 (Closed) IFl 93-01-01. EDG Instrument Calibration
This item was open pending the completion of licensee actions to calibrate
tachometers on the emergency diesel generators as needed to support surveillance
testing. The calibrations were performed per procedure PMP 9.2-101/102 during
the 1995 refueling outage, as described in authorized work orders 93-7665 for FG-
2A and 93-8375 for EG-2B. This action completed the licensee corrective action
required in response to the initial deficiency with the dieselinstruments. Other NRC
concerns regarding the calibration of instruments needed to support equipment
required to be operable by the technical specifications are described in inspection
96-11 (reference item 96-11-09). This item is closed.
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M8.3 (Closed) URI 94-14-01. Corrective Actions for PASS Valve Leakaae
This item we, considered open pending review of licensee actions to identify be
cause of valve leak-by, and to verify adequate isolation between the reactor coolant
system and the low pressure piping of the alternate letdown system. On June 22,
1994, during alignment of the reactor coolant drain header to obtain a reactor
sample using the post-accident sample system (PASS), leakage was observed
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through a normally shut motor-operated valve (DH-MOV-310).
The licensee's apparent cause of the valve leak-by was inadequate closure of the
valve prior to deenergizing the power to the motor operator. A contributing cause
was control room operator inability to determine valve position and lack of
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procedural guidance to ensure that the valve was closed. Procedure revisions were
processed to full stroke valve (DH-MOV-310) after using it for throttling and before
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opening its breaker. The inspector reviewed the procedural revisions implemented
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by the licensee to confirm that the corrective action was completed. No violation
was identified for this item.
i
On December 5,1996, the licensee informed tts NRC pursuant to 10 CFR
50.82(a)(1)(i) to permanently cease operations at the Haddam Neck facility. The
use of the post-accident sampling alignment will not be required during future plant
conditions. This item is considered closed.
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111. Enaineerina
E2
Engineering Support of Facilities and Equipment
E2.1
Diesel Generator Loadina
a.
Insoection Scope
The inspector reviewed the licensee's engineering evaluations of the load sequence
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for the emergency diesel generators.
b.
Observations and Findinas
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The licensee completed dynamic calculations of the loading sequence for the
emergency diesel generators (EDG) as part of the engineering evaluation of recent
changes to the load sequencer profiles. The load profiles had previously been found
to be acceptable based on static load analyses. The new evaluations were
performed by a contractor using dynamic computer modeling of the load sequence
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for the diesel response to a safeguards actuation signal with a loss of offsite power.
One of the new loads evaluated in the analysis was for the "B" high pressure
!
injection pump (HPSI), whose load had been increased as a result of the discovery
in 1995 that the pump impellers installed during the 1994 overhaul were larger than
previously assumed. The preliminary results of the dynamic simulations reported by
the contractor on October 31,1996 showed that EG 2A could not sustain the
restarting of the B HPSI pump to support high head recirculation. This potential
rendered EG-2A and HPSIinoperable as a historic condition, in that the load profiles
with the plant shutdown were less limiting. The engineering evaluation were
summarized in a reportability and operability evaluation dated October 31,1996,-
and in adverse condition report ACR 96-1272. The license reported the issue to the
NRC Duty Office, per 10 CFR 50.72(b)(2)(iii)(D) as a condition that could have
prevented the fulfillment of a safety function.
The licensee's final assessment for this issue was provided in engineering evaluation
DCY-96-0607 dated November 12,1996. The issue was first reported as a
possibility that EG-2A may not have been capable of accelerating the B HPSI pump.
The preliminary conservative evaluation was based on the computer simulations
which an excessive length of time to accelerate the B HPSI pump as part of the load
sequencing. The licensee re-performed the computer calculations after adjusting
overly conservative load assumptions for pre-existing loads in the sequence (service
water pumps and containment recirculation fans). The revised calculation showed
successful system operation, and demonstrated that the diesel and HPSI system
was capable of performing the required safety function. On November 19, the
licensee rescinded the 50.72 report made on October 31.
c.
Conclusions
The inspector reviewed the engineering evaluations and the bases for the final
operability decisions. No inadequacies were identified.
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E2.2
10 CFR 21 Report on Seismic Certification of Safetv-Grade Relavs
a.
Insoection Scope
The inspection scope was to evaluate licensee response to a 10 CFR 21 report
concerning deviations in seismic qualifications for safety-grade relays.
b.
Observations and Findinas
On November 13,1996, the licensee was informed of this 10 CFR 21 report
through a Westinghouse Nuclear Service Advisory Letter (NSAL)96-005. The
deviation was that previous analysis techniques to evaluate the zero period
acceleration (ZPA) rating for a safety-grade relays were non-conservative. The
analysis technique changed from a straight-line standard response spectrum (SRS)
to the average of the lowest test response spectrum (TRS) curve. The revised
method identified in ANSl/IEEE C 37.98-1987 uses a biaxial input motion calculation
to bound the TRS curve within the SRS. The revised analysis technique results in
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lower ZPA rating for the relays.
On December 11,1996, the licensee's design engineering personnel completed a
review of the revised ZPA numbers versus the qualified ZPA rating for the unit's
design safe shutdown earthquake. The seismic design ZPA for all relays was less
than the revised ZPA numbers using ANSI /IEEE C 37.98-1987.
The inspector noted that the 10 CFR 21 report was delayed in the licensee's
problem identification process, in that on December 19,1996 an Adverse Condition
Report was prepared to document this issue. The design engineering review
completed on December 11,1996, was in response to an informal request from the
Design Enginee ing Manager. This informal assignment process is not recognized as
part of the pre m identification process. This particular example is considered to
have no safe), consequence, since the actions taken by design engineering
personnel were appropriate. This issue is closed.
c.
Conclusions
The licensee appropriately evaluated a 10 CFR 21 report concerning seismic
qualification analysis. Notwithstanding, negative performance was noted on the
delay to process this issue in the problem identification process.
E8
Previous Open items (92902)
E8.1
LQlosed) URI 93-15-02. Modifv Pressure Lockina MOVs
This item was closed pending further NRC review of the licensee position regarding
modifications needed to assure motor operated valves (MOVs) were not susceptible
to pressure locking due to either hydraulic lock in the spring pack, or operation
under design basis events following operation at high system temperatures and
pressures. The technical concerns associated with this item were no longer
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applicable to a defueled condition with a primary and secondary plant that will not
be operated at elevated temperatures and pressures. This item is closed.
E8.2 (Closed) URI 95-04-01, Ooeration with Steam Generator Pluas
This item was open pending further NRC review of licensee actions needed to
monitor and assure the structural integrity of steam generator tubes with tube
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plugs. The technical and regulatory concerns associated with this item were no
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longer applicable to a defueled plant condition and steam generators that will no
longer be operated. This item is closed.
E8.3 (Closed) URI 96-01-02. Desian Basis Verification
This item was opened to track the identification of problems in the licensing and
design basis (LDB), and to determine whether there were programmatic concerns in
meeting the LDB. Subsequent inspections identified there were widespread
weaknesses in meeting the LDB (reference Inspections 96-04,96-06,96-08,96-11
and 96-201). This matter is the subject of a pending NRC enforcement action in
response to the captioned inspections, and ongoing discussions with the licensee
regarding his actions to re-establish the LDB. This item is closed.
E8.4 (Closed) URI 96-01-03, RVLIS Operatina Practices
This item was open pending NRC review of licensee actions to evaluate the
methods of reme.wg inoperable sensors from service in a reactor vessel level
indication system (RVLIS) train, and to improve the technical specifications to better
define an operable train. The technical and regulatory concerns associated with this
item were no longer applicable to a defueled plant with a reactor that will no longer
be operated. This item is closed.
E8.5 (Closed) URI 96-02-01, Containment Controls for Main Steam Valves
This item was open pending NRC review of licensee action to assure administrative
controls for main steam vent and drain valves were established in plant procedures
to assure the integrity of primary containment. The technical and regulatory
concerns associated with this item were no longer applicable to a defueled plant,
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with steam generators that will no longer be operated. Primary containment
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integrity will no longer be required. This item is closed.
E8.6 (Closed) URI 96-06-02. Emeraency Ooeratina Procedure Chanaes
This item was open pending the completion of licensee actions to assure that
emergency operating procedures were revised for Core Operating Cycle 20 to
address concerns involving boron precipitation following a postulated loss of cooling
accident The technical and regulatory concerns associated with this item were no
longer applicable to a defueled plant with a reactor that will no longer be operated.
This item is closed.
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E8.7 (Closed) URI 96-08-14. Core Deluae Valve Calculations
This item was opened pending the completion of licensee actions to assure that the
core deluge valves were fully qualified to function under worst case design base
conditions following a postulated loss of coolant accident. The technical and
4
regulatory concerns associated with this item were no longer applicable to a
defueled plant with a reactor that will no longer be operated. NRC concerns and
3
licensee actions to assure the licensing basis is accurately established and
implemented will be tracked as part of the pending enforcement action in response
i
to inspections 96-08 and 96-201. This item is closed.
E8.8 (Closed) URI 96-201-23. Service Water Two Phase Flow
This item was open pending further NRC review of licensee action to address the
.
potential for and consequences of two phase flow in the service water system
under conditions involving a postulated design basis accident inside the reactor
containment. The licensee completed engineering evaluations and identified design
deficiencies in meeting the design basis for the service water system during past
periods of plant operation. The regulatory concerns regarding past plant operations
and the associated NRC followup of the design and licensing issues are tracked as
part of Inspection item 96-08-02. The technical concerns associated with this item
were no longer applicable to a defueled plant condition and for containment air
recirculation fans that cannot experience containment environmental conditions
postulated to occur for design basis events. This item is closed.
E8.9 (Closed) URI 96-201-25. RHR Pumo NPSH
This item concerned the NRC review of licensee actions to assure the residual heat
removal pump net positive suction head (NPSH) was acceptable under postulated
design basis accident conditions. The licensee completed engineering evaluations
and identified design deficiencies in meeting the design basis for the RHR system
during past periods of plant operation. The regulatory concerns regarding past plant
operations and deficiencies in the design basis are tracked under Inspection item
96-08 11. The technical concerns associated with this item were no longer
applicable to a defueled plant with a reactor and RHR system that will no longer be
operated under containment environmental conditions postulated to occur following
design basis events. This item is closed.
E8.10 (Closed) URI 94-25-01. Actions to Imorove Instrument Air Quality
This item involved NRC identification that the installed instrument air dryers could
not maintain dew point values that complied with industry standards nor as
described in the Updated Final Safety Analysis Report (UFSAR) section 9.3.1.2.
Specifically, the industry standard recommends a dew point of -38 degrees
fahrenheit (F); and the UFSAR states that the dryers could deliver -40 degrees F.
Additionally, the periodic maintenance procedure and the operator log reading
allowed for an acceptance criteria of O degrees F.
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The licensee completed a plant modification (PDCR 1520) to rebuild the instrument
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air dryers. NRC observations of air dryer performance have noted that the dew
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points have maintained less than -40 degrees F. Additionally, the operator log
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reading and the periodic maintenance procedure were verified by the inspector to
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have been revised with an acceptance criteria of -40 degrees F. This item is not
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considered a violation.
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On Decembu 5,1996, the licensee informed the NRC pursuant to 10 CFR
,
50.82(a)(1)(i) to permanently cease operations at the Haddam Neck facility. The
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use of instrument air to provide a vital support system function to safety equipment
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is not applicable. This item is closed.
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E8.11 (Closed) URI 94-17-03. Desian of Reactor Coolant Pumo Oil Pioina
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This open item was associated with a misapplication of design calculations for non-
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metallic couplings used for the reactor coolant pump lube oil system. The present
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design calculations and components used for a modified reactor coolant pump lube
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oil system were found acceptable in inspection report 50-213/94-18. The licensee
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did however reanalyze the seismic margins of the non-metallic couplings and found
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that it maintained seismic structural integrity. No violation was identified for this
item.
On December 5,1996, the licensee informed the NRC pursuant to 10 CFR
50.82(a)(1)(i) to permanently cease operations at the Haddam Neck facility. The
seismic qualification of the reactor coolant pump lube oil system does not serve a
safety function given the defueled conditions and the pending decommissioning of
the facility. This item is closed.
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E8.12 (Closed) IFl 94-09-01. Corrective Actions for Boron Dilution
This item involved a non-conservative assumption that was used in the analysis of a
postulated boron dilution event in the reactor coolant system. The analysis had an
error regarding the response of source range nuclear instrumentation following
reductions in soluble boron concentration. The licensee revised the assumptions,
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and during the startup from the last refueling outage in 1995, the licensee
!
confirmed agreement in predicted values of source range instrument response with
actual response during boron dilution.
On December 5,1996, the licensee informed the NRC pursuant to 10 CFR
50.82(a)(1)(i) to permanently cease operations at the Haddam Neck facility. The
possibility of a boron dilution event in the reactor coolant system is no longer a
concern for a defueled reactor with all nuclear fuel stored in the spent fuel pit. This
item is closed.
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IV. Plant Suncort
R4
Staff Knowledge and Performance in RP&C
R4.1 Effectiveness of the Radiation Protection Proaram lmolementation
a.
Inspection Scope (83729)
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During the week of November 18, the inspector reviewed the licensee's program for
radiation protection during an extended outage. The licensee entered a defueling
outage in late July,1996. This inspection examined the effectiveness of
implementation of the radiation protection program.
b.
Observations and Findinas
Since the last specialist inspection in the radiation grotection area, conducted in
May 1996, the licensee has shutdown the plant, defueled the reactor and is
awaiting final determination on whether the plant should be decommissioned.
During this inspection, the effects of these changes were evaluated as they impact
on performance of radiation workers and radiation protection technicians.
The inspector reviewed numerous radiation ymrk permits utilized by the licensee,
especially those for work in the containment, n /iewed survey maps, log books, and
interviewed a number of radiation protection technicians. In general, a noticeable
decline in quality of work documentation and information available to radiation
workers was observed. This is in comparison to earlier inspections conducted in
1996 (NRC Inspection Nos. 50-213/96-02; 96-04), where the licensee's program
for radiation protection was determined to be highly effective during significant
radiological work (diving evolutions in the spent fuel pool), and during the last
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refueling outage in 1995 (NRC Inspection No. 50-213/95-03).
'
Radiation work permits (RWPs) for the diving evolutions were determined to be well
written, including extensive instructions on work control and exposure minimization.
RWPs, log books and worker briefings observed during the last refueling outage
were of a similar high quality. The inspector noted during this inspection a general'
lack of effective communications on work area dose rates presented in the RWPs,
especially those utilized for containment area work. Dose rate information was very
limited, and the RWPs were not cross referenced to the appropriate survey maps.
Worker instructions crentained in the RWPs were limited and very generalized, and
log books kept at the containment control point were found to contain only the
most minimalinformation. Given the relatively high general and specific area dose
rates in the licensee's containment, extensive and detailed instructions to radiation
workers is necessary to assure sufficient communication of radiological conditions.
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The inspector noted that the amount of contaminated spaces in the plant continues
to be significantly low as a result of a concerted effort on the part of the plant staff
and management. Additionally, occupational exposures for radiation workers
continues to be maintained as low as is reasonably achievable (ALARA) for planned
work evolutions,
c.
Conclusions
Although the licensee maintains a generally effective program in radiation
protection, a general decline in performance in this area was noted. While the
licensee continues to be very effective in reducing the amount of contaminated
areas in the plant and effectively implements ALARA controls for planned work
evolutions, the general quality of surveys, RWPs and control point log books has
declined.
R4.2 Dosimetrv Laboratory Review by NVLAP
a.
inspection Scone (837291
The inspector reviewed the recently completed audit of the NUSCO Dosimetry
Laboratory conducted by the National Voluntary Laboratory Accreditation Program
(NVLAP), and licensee actions and their effectiveness in addressing these audit
deficiencies and recommendations,
b.
Observations and Findinas
The inspector reviewed the recently completed NVLAP audit of the NUSCO
Dosimetry Laboratory which provides thermoluminescent dosimeters (TLDs) to the
licensee. Previous audits conducted by NVLAP, especially that in July 1994,
indicated significant deficiencies in the program, including a general failure to take
timely and appropriate corrective actions for identified deficiencies. Since the last
NVLAP audit, management of the laboratory has been placed under Millstone
Station, and several management positions have been created to aid in the oversight
and support of the TLD lab.
The inspector reviewed the results of the September 1996, NVLAP audit as part of
this inspection. Four deficiencies and six recommendations are contained in the
NVLAP report. The deficiencies involved the need to improve control of the TLDs
while in the lab, and enhance Quality Control (OC) checks for the lab. All of the
deficiencies, with the exception of the weaknesses involving QC checks, were
issues previously identified as self-assessments by the laboratory staff, and for
which corrective actions had been initiated and were stillin progress at the time of
the audit. Discussions with the lab staff indicated that a follow-up NVLAP audit will
be conducted next year, rather than the regularly scheduled biennial review in 1998,
in order to evaluate the effectiveness of management oversight of the lab, given the
significant management changes undergone by Northeast Utilities in the past year.
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c.
Conclusions
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The NUSCO TLD laboratory continues to maintain NVLAP accreditation of its
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programs. Deficiencies highlighted by a recent NVLAP audit were being addressed
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by the NUSCO TLD Laboratory.
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R6
RP&C Organization and Administration
a.
Inspection Scope (83729)
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The inspector reviewed the qualifications of the recently designated acting Radiation
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Protection Manager (RPM) and reviewed the interim and decomnmioning
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organization structures recently announced by the licensee.
b.
Observations and Findinas
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Recently the licensee's RPM left to take another position within Northeast Utilities.
The plant Unit Director named as an interim RPM an individual who had recently
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been serving as the Radiological Engineering Supervisor. The position of RPM and
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its associated qualification requirements are discussed in Plant Technical
Specification 6.3.1.1. The inspector reviewed the qualification of the interim RPM
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against these standards and determined that the selected individual meets the
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qualification requirements.
With the anticipated permanent closure of the plant, on November 16,1996, the
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licensee developed two organizational charts. One represents an interim
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organizational structure which remains in effect until the end of 1997, while the-
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second is a decommissioning organization which goes into effect in 1998. In both
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charts, the number and type of staff in the health physics and radiological
engineering organizations remains essentially the same. The staff reductions in this
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area are four radioactive material handler positions. The effectiveness and
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adequacy of this staffing arrangement will be reviewed by the NRC after
implementation.
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c.
Conclusions
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The licensee has selected a fully qualified individual to serve as interim RPM. Other
staffing changes in the interim and decommissioning organization have generally
minimalimpact on the type and number of personnel serving in the radiation
protection organization.
R8
Miscellaneous Radiological Protection and Chemistry Controls issues
A recent discovery of a licensee operating their facility in a manner contrary to the
Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a
special focused review that compares plant practices, procedures and/or parameters
to the UFSAR descriptions.
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While performing the inspections discussed in this report, the inspector reviewed
the applicable portions of the UFSAR that related to the areas inspected. The
inspector verified that the UFSAR wording was consistent with the observed plant
practices, procedures and/or parameters.
R8.1
(Closed) URI 95 06-01. Bvoass of Locked HRA Gate
This item was open pending further NRC management review of this event in which
a worker violated the established controls for entry into a locked high radiation area.
The licensee's action taken at the time of the event and described in inspection 95-
06 were appropriate. No similar problems have occurred in the control of locked
high radiation areas. This licensee-identified and corrected violation is being treated
as a Non-cited violation, consistent with Section Vll.B.1 of the NRC Enforcement
Policy. This item is closed.
R8.2 (Closed) URI 95-10-01. Evaluation of the MRCA Function
This item concerned the NRC review of the licensee function to analyze the
radiological consequences of postulated accidents. The NRC reviewed this function
during the emergency preparedness exercise in August,1996, along with the
licensee actions to provide protective action recommendations to offsite authorities.
NRC actions for licensee deficiencies in this area are tracked as part of the pending
enforcement for inspection item 96-07-02. This item is closed.
S1
Conduct of Security and Safeguards Activities
S1.1
Fitness for Dutv Events
The inspector reviewed licensee actions in response to three fitness for duty events
that occurred during the period from November 17 - 21,1996. None of the events
involved supervisory personnel, in each case, the licensee actions were appropriate
to identify and investigate a potential problem, and to take corrective actions. The
licensee increased supervisory oversight of worker activities in light of the increased
stress experienced by the plant staff. No inadequacies were identified.
S2
Status of Security Facilities and Equipment
S2.1
Maintenance of Security Eauioment (IFl 96-13-02)
j
a.
Insoection Scoce
I
The inspection scope was to evaluate the licensee's problem identification process
and the adequacy of maintenance activities for the perimeter intrusion detection
system during the last three quarters of 1996.
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b.
Observations and Findinas
The inspector learned that forty-five corrective maintenance activities were
performed on the perimeter intrusion detection system for the last three quarters of
1996. A majority of the deficiencies were documented in the licensee's trouble
report system, however approximately 20% of the corrective maintenance was
performed when identified informally between security force members and the
instrument and controls personnel. This was discussed with licensee personnel,
who acknowledged the inspector's observations and were planning corrective :
actions to increase the sensitivity and consistency of personnel actions for problems
' identified in security equipment.
The inspector concluded approximately 70% of the maintenance activities
documented the type and results of the post maintenance test within the authorized
work order (AWO). Separate from the AWO, Security procedure SEC 1.3-10,
Surveillance Testing and Maintenance of Security Equipment, documentation
provided the detailed results of the testing on the deficient perimeter intrusion
detection systems. The inspector compared the expectations of various post-
maintenance tests in SEC 1.3-10 with the actual deficiency and work performed
and found no deficiencies.
The inspector reviewed the licensee's requirements in procedure SEC 1.3-10 with a
security supervisor as it relates to the conduct of functional testing following .
maintenance actions to address nuisance alarms. The licensee stated that the
requirements of SEC 1.3-10 would be revised as needed to enhance and clarify
expectations for conducting functional testing. This item is considered open (IFl 96-
13-02) pending further NRC review of licensee activities to identify and take timely
actions to correct deficiencies in security equipment.
c.
Conclusions
The licensee does not document on trouble reports all deficiencies identified in the
perimeter intrusion detection system. An inspection item was opened pending
further review of licensee activities to fix deficiencies and test security equipment
following nuisance alarms.
V. Manaaement Meetinas
X1
Exit Meeting Summary
i
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The inspectors presented the inspection results to members of licensee management at the
conclusion of the inspection on January 10,1997. The licensee acknowledged the
findings presented.
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
Jere LaPlatney, Unit Director
Gerry Waig, Maintenance Manager
Douglas McCracken, Acting Operations Manager
James Pandolfo, Security Manager
James Lenois, Security Supervisor
Ron Sachatello, Radiation Protection Manager
Tom Cleary, Nuclear Licensing Engineer
NRC
Stephen Dembek, Haddam Neck Project Manager
Morton Fairtile, Haddam Neck Project Manager - Decommissioning
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INSPECTION PROCEDURES USED
IP 40500:
Effectiveness of Licensee Controls in identifying, Resolving, and Preventing
Problems
IP 62707:
Maintenance Observation
IP 71707:
Plant Operations
IP 83729:
Occupational Exposure During Extended Outages
IP 83750:
Occupational Exposure
IP 92700:
Onsite Followup of Written Reports of Nonroutine Events
IP 92902:
Followup - Engineering
IP 92903:
Followup - Maintenance
IP 93702:
Prompt Onsite Response to Events at Operating Power Reactors
ITEMS OPEN, CLOSED, AND DISCUSSED
Open
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96-13-01
Failure to Follow Emergency Diesel Surveillance Procedure
96-13-02
IFl
Maintenance of Perimeter Intrusion Detection System
Closed
96-08-07
Appendix J Test of Penetration P50
93-01-01
IFl
EDG Instrument Calibration
93-15-02
Modify Pressure Locking MOV
95-04-01
Operation with Steam Generator Plugs
96-01-02
Design Basis Verification
96-01-03
RVLIS Operating Practices
96-02-01
Containment Con'. ;is for Main Steam Valves
96-06-02
Emergency Operating Procedure Changes
96-08-14
Core Deluge Valve Calculations
96-201-23
Service Water Two Phase Flow
96-201-25
95-06-01
Bypass of Locked HJRA Gate
95-10-01
Evaluation of the MRCA Function
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94-22-01
IFl
Training for Risk Significant Reactor Operator Actions
94-14-01
Followup Corrective Actions for PASS Valve Leakage
94-25-01
Actions to improve Instrument Air Quality
94-17-03
Piping Design for Reactor Coolant Pump Oil Supply System
94-09-01
IFl
Proposed Corrective Actions for Boron Dilution
Discussed
None
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LIST OF ACRONYMS USED
<
ACR
Adverse Condition Report
1
As Low As is Reasonably Achievable
'
Corrective Maintenance Procedure
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F
fahrenheit
High Pressure injection Pump
LDB
Licensing and Design Basis
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Motor Operated Valve
Normal Operating Procedure
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i
Net Positive Suction Head
,
NRC
Nuclear Regulatory Commission
,
NSO
Nuclear Side Operator
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NUSCO
Northeast Utilities Service Company
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National Voluntary Accreditation Program
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Public Document Room
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I
Preventive Maintenance Procedure
Post Shutdown Decommissioning Activities Report
OC
Quality Control
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Radiation Protection Manager
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Reactor Vessel Level Indication System
j
Radiation Work Permits
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Thermoluminescent Dosimeter
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Updated Final Safety Analysis Report
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