ML20198N282
| ML20198N282 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/29/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198N260 | List: |
| References | |
| 50-213-97-08, 50-213-97-8, NUDOCS 9711030257 | |
| Download: ML20198N282 (73) | |
See also: IR 05000213/1997008
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No:
50-213
License No:
DPR 61
Report No:
50 213/97-08
Licensee:
Connecticut Yankee Atomic Power Company
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P.O. Box 270
Hartford, CT 06141-0270
Facility:
Haddam Neck Station
Location:
Haddam, Connecticut
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Dates:
July 3,1997 and August 11 - September 19,1997
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Inspectors:
Ronald L. Nimitz, CHP, Senior Radiation Specialist
William J. Raymond, Sr. Resident inspector
Haddam Neck Station
Todd J. Jackson, CHP, Health Physicist
Randolph C. Ragland Jr., CHP, Radiation Specialist
Approved by:
John R. White, Chief, Radiation Safety Branch
Division of Reactor Safety
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9711030257 971029
ADOCK 05000213
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EXECUTIVE SUMMARY
Haddam Neck Station
NRC Inspection Report No. 50-213/97-08
This inspection was an inspection of the radiological controls program at the Connecticut
Yankee Atomic Pvwer Station, Haddam, Connecticut. Areas reviewed during the
inspection ine'.uded the applied radiological controls program, including external and internal
exposure controls, the contamination control program, training of personnel relative to
49 CFR 172, Subpart H, the licensee's plans and activities associated with radiological
characterization of the site for decommissioning planning purposes, and licensee action on
commitments to the NRC relative to NRC Confirmatory AcW metter (CAL) No. 1 97-082,
dated March 4,1997. The inspection included review of liwee provided documents at
the NRC Region I office.
The licensee provided a letter dated September 10,1997, that indicated that it has
completed Phase 1 of its Radiation Protection improvement Plan. Phase 1 of _the plan is to
address deficiencies which have a potential risk of affecting public or worker health and
safety or compliance with regulations.
There was limited on-going radiological work activities to chat!enge the radiological controls
program. Applied radiological controls for reactor coolant letdown filter change out
appeared adequate. However, weaknesses were identified in communications and work
control in that three security personnel improperly signed-in on the radiation work permit
for the task and had not received the specified RWP briefing. Although the personnel were
not directly involved in the. task, they had received an briefing commensurate with their
assigned task, the observation reflected continuing weaknesses in communications of work
tasks and control of RWP work.
Two violations were identified. The first violation invo!ved'three examples of failure to
follow radiation protection procedures and was idertified by the NRC. The second
violation involved failure to perform adequate radiological surveys of material deposited in
the landfill and was identified the licensee.
There was insufficient information in a worker dose assessment, involving a potential
internal exposure on February 22,1985, to allow the inspector to understand the
licensee's bases for determining the magnitude of exposure to the individual.
The licensee performcd a comprehensive review of its contamination controls for egress of
material from the radiological controlled area and took a number of actions to enhance the
program. Contamination control practices appear weak relative to control of inadvertent
tracking of contamination to outdoor areas from process building within the radiological
controlled area. Additional licensee attention is needed in the area of control of stored
materials outdoors.
A number of unresolved items were identified relative to license monitoring and control of
radioactive material.
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TABLE OF CONTENTS
PAGE
EX EC UTIVE S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . il
R1
Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . . . 1
R1.1 External and internal Exposure Controls . . . . . . . . . . . . . . . . . . . . . . . . 1
R1.2 Contamination Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
R5
Staff Training and Qualification in RP&C . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
R5.1 Radioactive Material Handling / Shipping
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R8
Miscellaneous Matters . . . . . . . . . . . .
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R8.1 Confirmatory Action Letter . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
R8.2 Haddam Neck Site Characterization (General Description of Licensee
Activities and Discussion) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
R8.3 Previous Contamination Events (NRC Specific Observations and
Reviews).............................................
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R8.4 NRC Review of Licensee Radiological Surveys and NRC Survey
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Results..............................................
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R8.5 NRC Information Notices 9 7-3 6, 9 7-6 6, 9 7-68 . . . . . . . . . . . . . . . . . . 31
- R8.6 40 CFR 190 Dose Limits (IFl 50-213/97-01 -10) . . . . . . . . . . . . . . . . . 32
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Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
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INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . 34
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ITEMS OPEN, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
LIST OF ACRONYMS USED
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Report Details
PLANT SUPPORT
R1
Radiological Protection and Chemistry (RP&C) Controls
. R 1.1
External and Internal Exoosure Controls
a.
insoection Scoce (83726,83750)
The inspector toured the radiological controllsd areas and reviewed radiological
co itrols including posting, barricading, and access control, as appropriate, to
ra fiation and high radiation areas. The inspector also reviewed selected radiological
work activities.
The inspector selectively reviewed whole-body-count records and licensee follow-up
radiological evaluations, as appropriate.
b.
Qbservations and Findinag
b.1
General
The inspector's tours indicated little in-plant radiological work activities were on-
going due primarily to restrictions placed on work by NRC Confirmatory Action
Letter (CAL) No. 1 97-082, dated March 4,1997. The licensee was continuing to
perform scoping surveys for site characterization purposes. The surveys were
primarily conducted outdoors, including outside the protected areas of the station,
b.2
Letdown Filter Chanaeout
The inspector reviewed documentation associatad with change-out of the reactor
coolant letdown filters on August 12,1997. The licensee periodically changes the
filters to maintain reactor cavity water quality. The inspector noted that due to
plant design, it is necessary that this activity be conducted in an open area on top
of the ion exchange facility. A shield plug was removed from top of the facility to
permit the change-out. The licensee installed a high efficiency particulate air
filtration ventilation system to produce a negative pressure area in the pipe trench
beneath the facility. This caused air at the filter changeout location to be drawn
into the pipe trench. The filter change area was enclosed to approximately waist
level with contamination control sheeting. The licensee withdrew the filter into a
shielded transfer bell using long handled tools. - Air monitoring was provided and no
airborne radioactivity was identified. No significant perst,nnel exposure was
sustained during the task.
The inspector noted that due to weaknesses in communication, three security
personnel logged in on the RWP for the filter change out activity. The security
personnel were to have logged in on their normal RWP for security duties. Although
the personnel had received radiological controls instructions commensurate with
their assigned duties, the personnel did not follow the RWP in that they were to
receive a comprehensive briefing and sign a special briefing record sheet in
accordance with the work permit. This matter was identified by the licensee, and
was being reviewed. This matter is unresolved pending review of the licensee
corrective actions. (UNR 50-213/97-08-10)
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b.3
Hioh Radiation Areas
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The inspector reviewed locked High Radiation Area access controls and noted that
the licensee took action to preclude unauthorized access to gated areas by installing
lock guards,
b.4
Whole Body Countino
During review of whole-body-count data and records, the inspector noted that
Radiation work permit (RWP) records showed that a vendor omployee was signed in
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on RWP 1950603, " Primary Steam Generator Nozzle Cover Installation and
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Removal," on February 22,1995, from 4:34 p.m. to 6:56 p.m. Apparently, during
the course of work this individual received a facial contamination. Whole-body-
count records contained a copy of a personnel contamination form (PCF) for the
individual that documented a facial contamination of 200 corrected counts per
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minute (ccpm) (i.e., about 2,000 dpm assuming a 10% detector efficiency) which
occurred on February 22,1995. The PCF was signed on March 27,1995, and a
note written next to the " Reviewed By" signature space indicated that the PCF had
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been " recreated" due to loss of the c,riginal form.
The inspector noted that the personnel contamination form (PCF) created on
March 27,1995 to document the February 22,1995 facial contamination event
was checked "No" for "Whole Body Counted." The inspector noted that procedural
guidance contained in RPM 2.7-3 " Contaminated Personnel Survey and
Decontamination," Revision 9, required a person with facial contamination to be
whole-bady-counted. Whole-body-count records showed that the individual was
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not whole-body-counted on February 22,1995, in accordance with procedural
guidance, but was whole-body-counted on February 23,1995, and multiple times
thereafter. Through interviews, the inspector learned that the request for the
whole-body-count was initiated by the individual rather than by the HP technician
that performed the initial personnel contamination survey. This indicated that
procedural guidance contained in RPM 2.7-3 " Contaminated Personnel Survey and
Decontamination," Revision 9, was not properly followed or enforced on
February 22,1995. This is a violation of Technical Specification 6.11 which
requires that radiation protection procedures be adhered to for all operations
involving personnel radiation exposure. (VIO 50-213/97-08 01)
The inspector reviewed the February 28,1995, dose estimate for this individual.
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The dose estimate and whole body count data indicated the individual sustained an
intake of radioactive material. The dose estimate indicated no significant dose
attributable to the intake was sustained. The individual sustained an external dose
of 200 millirem. The inspector reviewed the internal dose assessment and had the
following questions:
The licensee concluded that the intake was sustained as a result of an
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ingestion. However, there was insufficient information available to verify the
adequacy of the exposure determination.
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The licensee concluded that the doce attributable to alpha radioactivity was
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negligible and should not be considered in the final dose calculation it was
unclear to the inspector as to the technical basis for this conclusion.
The dose assessment for this individual is considered an unresolved item pending
additional NRC review of its technical bases. (UNR 50-213/97 08-02)
c.
Conclusion
There was limited on-going radiolog! cal work activities to challenge the radiological
cont ols program. Radiological controls for reactor coolant letdown filter change
were adequate, but weaknesses in communication resulted in personnel logging in
on an incorrect RWP.
A violation of radiation protection procedures was noted in that procedural guidance
contained in RPM 2.7-3 " Contaminated Personnel Survey and Decontamination,"
Rev. 9, step 3.3.7.a, (whole body count following facial contamination was not
implemented) on February 22,1995.
There was insufficient information in a worker dose assessment to allow the
inspector to understand its technical bases.
R1.2 Contamination Controls
a.
inspection Scope (83750)
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The inspector toured the radiological controlled area and reviewed contamination
controls. The inspector followed-up on unresolved item 50-213/97-01-11 in which
problems in contamination control were identified for review.
b.
Findinas and Observations
b.1
Contamination Controls-General
As discussed in NRC inspection Report Nos. 50-213/97-01 and 50-213/97-06, the
licensee had taken actions to restrict and improve the monitoring for release of
material from the radiological controlled and protected areas at the Haddam neck
station. The inspector determined that the licensee 1) performed a review of the
radiation protection instrumentation program with a focus on instrumentation used
for monitoring of material to be released to the unrestricted area,2) evaluated the
calibration and source checking of survey and monitoring equipment used to
perform in-plant surveys, and 3) performed an evaluation of the station's material
release program.
The inspector further noted that the routine survey program was being revised to
address concerns raised in recent self assessments and to strengthen the program's
capability to readily detect anomalies.
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The inspe: tor reviewed selected revised survey maps for the program and noe d the
following changes.
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routine contamination survey base point locations were established to allow
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for computerized tracking and trending of contamination levels and the
spread of contamination;
base point locations were selected to allow for rapid evaluation of the spread
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of contamination (e.g., base points locations included major walkways and
areas immediately adjacent to contaminated area boundaries);
contamination smears were required to be evaluated for both beta gamma
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and alpha activity; and
a requirement was added to perform large area smears (LAS) near
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radiologically controlled area (RCA) building entry and exit doors.
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The inspector concluded that changes made to the routine survey program allowed
for better tracking and trending of plant contamination levels, were responsive to
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recent self assessments, and reflected an increased sensitivity of station
management to contamination controls.
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The foilowing area for improvement was identified:
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The inspector requested the licensee to provide a current estimate (e.g.,
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square footage, percentage, etc.) of the accessible areas of the station that
the licensee considered to be contaminated and which would therefore
require some degree of personnel contamination control (e.g., booties, lab
coat, coveralls, etc.). The inspector noted that the licensee was apparently
not tracking such an estimate and could not provide an informed response.
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The inspector noted that the tracking of such estimates provides an
indication of the degree of monitoring and control of contamination sources.
During the review of contamination controls, the inspector interviewed various
health physics personnel and performed selected reviews of issues placed into the
plant information reporting system (PIR), the rac"ological deficiency reporting
system, and the radiological incident reporting (NR) during the 1986 time frame.
No issues or trends were identified relating to improper shipment of contaminated
communications equipment.
b.2
On-ooino Material Survev Prooram
The licensee continued to survey materials and equipment located at the site both
inside and outside of the protected area in an effort to idantify material that may
have been released with residual contamination. The surveys were being performed
in accordance with the licensee's radiological survey action plan. As of
September 19,1997, the licensee had surveyed approximately 178,666 items.
This effort included monitoring approximately 174,736 items located outside of the
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RCA but within the protected area gate, and approximately 3950 outside of the
protected area gate in the warehouse. The licensee relied on tool type monitors to
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identify any detectable activity.
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Preliminary results were as follows:
Table 1
Material Survey Status
items
items
Percent
Location
Surveyed
Contaminated
Contaminated
Protected Area:
174736
405
0.232 %
Warehouse:
3950
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0.709 %
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Approximately 433 items were identified as having detectable levels of licensed
radioactive material. Essentially, allitems exhibited fixed (nonremoveable
contamination). Of the 433 items, approximately 72 percent had contamination
levels below 100 corrected counts per minute (ccpm) as measured with an HP 210
Geiger Mueller probe. The contamination on the items was identified with state of-
the-art high sensitivity material monitoring equipment. Seven items in the protected
area were found to have contamination levels greater than or equal to 1000
corrected counts per minute (ccpm) (i.e.,10,000 disintegrations per minute
assuming a 10% detector efficiency), with the highest activity being a pipe cutter
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with 4500 cepm. One item in the warehouse exhibited fixed activity of 800 ccpm.
Three small pieces of piping were found to have loose (smearable) contamination on
internal surfaces. The items consisted of a small pipe reducer, a 1/2 inch elbow, and
a 1/4 inch piece of piping, and were found in a turbine building storage cage used by
the operations department. The item with the highest smearable (i.e., removable)
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contamination was a small pipe reducer with an activity of 2,600 disintegrations per
minute (dpm) per 100 cm' beta-gamma activity, and 180 dpm/100 cm alpha
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activity. These items were in the protected area. All contaminated items were
returneo to the radiological controlled area.
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The majority of items found to have detectable levels of licensed material were
small tools and equipment, and were suspected of being released from the
radiologically controlled area over an extended period of time. The radiation
protection manager stated that the review of this issue was ongoing, and that
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based on the types of equipment and contamination levels found, it was unlikely
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of these items outside of the radiohgically controlled area,
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The inspector concluded that the initiative to monitor tools and equipment in areas
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outside of the radiologically controlled area was prudent; approximately 433 items
with detectable levels of licensed material were identified in areas outside of the
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radiologically controlled area; and although evaluations were not complete,
preliminary results indicated that no significant personnel exposures were incurred in
these cases.
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The inspector noted that consistent with the licensee's March 20,1997,
Supplemental Response to NRC Confirmatory Action Letter No. 1-97 007, dated
March 4,1997, the licensee is to 1) complete performance of its radioactive
material survey action plan elements by September 30,1997, and 2) is to provide a
report of this effort to the NRC upon its completion. This report will provide the
results of the licensee's efforts to identify equipment (e.g., tools) that may have
been released from the RCA with detectable contamination.
b.3
Earess from Process Buildinos to Outdoor Areas
The following negative observation was made:
During a previous inspections (Reference NRC Inspection Nos. 50 213/97-01
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and 50-213/97 06) the inspector observed that the licensee had designated
outdoor yard areas as portions of the radiological controlled area (RCA) and
that personnel routinely egressed main plant process buildings (a.g., auxiliary
building) to outdoor yard areas. However, the licensee did not require
personnel to frisk for contamination prior to exiting the plant buildings.
Although the likelihood that personnel would track contamination into the
environmert appeared low based on current conditions, the inspector
considered the practice to be questionable. In addition, the inspector noted
that doors to radiological controlled areas were left open potentially allowing
low level contamination to be wind blown out of an area.
The inspector noted that decommissioning activities could significantly
challenge the licensee's contamination control program and an effective
monitoring program for personnel was an integral part of contamination
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monitoring program to prevent inadvertent tracking of contamination into the
environment (i.e., outdoor yard areas).
b.4
Storaae of Material Outdoors
During a previous inspection (Reference Inspection 50-213/97 06) the inspector
observed that rusted drums, labeled radioactive material were observed in backyard
areas of the station near the 115 kV switchgear yard trench. The inspector noted
that if left to degrade, the drums could potentially be a source of low level
contamination to the environment. The inspector observed that the drums were
removed and the area cleaned up, During tours during this inspection, the inspector
observed large metal containers that appeared to be tool storage containers
outdoors near the butler building at the southeast corner of the protected area. The
containers were also marked radioactive, the containers were rusting and contained
materiallabeled radioactive. The containers were subject to wind and rain and were
not water tight. The licensee initiated action to review these instances.
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c.
Conclusions
The licensee performed a comprehensive review of its contamination controls for
removal of material from the radiological controlled area and took a number of
actions to enhance the program, Contamination control practices appear weak
relative to control of inadvertent tracking of contamination to outdoor areas from
process building within the radiological controlled area. Additional licensee
attention is needed in the area of control of stored materials outdoors.
The unresolved item associated with the effectiveness of contamination controls
program remains open pending additional NRC review of licensee control of
contamination in outdoor areas. (UNR 50 213/97 0111)
R5
Staff Training and Qualification in RP&C
R5.1 Radioactive Material Handlina/Shinoino
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a.
Scone (86750)
During a previous inspection (Reference NRC Inspection Report No. 50 213/97-06),
the inspector noted that training documentation could not be located for one
radiological controls technician who performed surveys of new fuel elements
received in August 1996 to indicate that the individual had been properly trained
and qualified as required by 49 CFR 172, Subpart H. Further, no apparent clearly
defined program could be identified, as required by 49 CFR 172 Sut part H, for
personnel (non-radiological controls) who supported new fuel receipt in 1996. The
licensee had identified and documented a concern in this area in its adverse
condition reporting program. The above observations were previously considered an
unresolved item (UNR 50-213/97 06-02).
b.
Observations and Findinas
b.1
Fuel Handlina
The inspector reviewed the training and qualification program and training provided
for individuals who performed among other ectivities fuel receipt, unloading,
inspection, radiological controls and other activities for receipt of the new fuel. The
inspector noted that no clearly defined program was established which referenced
49 CFR 172, Subpart H, and outlined minimum training required by 49 CFR 172,
Subpart H. However, the inspector's review ii.dicated personnel ir volved in the
above referenced activities had received appropriate training commensurate with
their duties and responsibilities through radiation protection training, general
employee training and other site access training provided (e.g., crane training). The
inspector noted that the specific sign-off step for the radiation protection technician
for fuel receipt training had been deleted due to comparable training provided in
other training sign-off steps,
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The inspector's review also noted that the licensee had contacted representatives of
the Department of Transportation (DOT) and had received confirmation that the
training provided met the intent of Subpart H. As noted in WRC inspection report
50-213/97 06, the licensee provided applicable training to personnel involved in
new fuel shipment activities,
b.2
Transoort of Material
The inspector also reviewed the training provided an individual involved with
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transport of a Limited Quantity shipment to the Millstone Station (Reference NRC
Inspection No. 50-213/97 06). The inspector noted that the licensee identified and
documented, in an Adverse Condition Report (ACR No. 97-00 42, dated
January 21,1997), that a 5 gallon _ pail of contaminated fuelinspection lights, was
shipped to another nuclear power station by a bui! ding services attendant an left
unattended on January 17,1997,
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The inspector's previous review determined that sufficient control of the material
was maintained to meet the control of radioactive material requirements of 10 CFR 20.1802. The inspector noted that the licensee completed a causal factor and
corrective action plan relative to this matter and concluded that the individual did
not understand that the package was to be physically received and not left
unattended. The individual contacted appropriate personnel and left the package
under the cognizance of security personnel. The licensee suspended use of building
services personnel to transport radioactive material and elected to us commercial
-carriers to transport such material. The licensee initiated a revision to the applicable-
procedure (RPM 3.6-3) to include guidance in this area. The inspector reviewed the
individual's training records relative to the training requirements v.' 49 CFR 172,
Subpart H and concluded that the individual had received applicable training and
that the training was within the retraining frequency outlined therein. The general
training included hazard communication, package / container information, safety
aspects and driver responsibilities, incident actions, and loading / unloading
information training. The individual who authorized the shipment was trained and
qualified. The inspector also reviewed appliccble regulatory requirements for
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shipment of Limited Quantity radioactive materials outlined in 49 CFR 173.421
- 49 CFR 172.422, and 49 CFR 172.600. No concerns were noted.
Based on the above, the inspector concluded that personnel had received applicable
training and that the above referenced unresolved item was closed.
Tt.0 inspector also noted that radioactive material handling personnel receive
specific training for their assigned responsibilities relative to shipment of radioactive
material.
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b.3
.TJainino Relative to Projected Staffino Needs
During NRC Inspection 50 213/97 06, the inspector noted that there did not appear
to be a well defined program to ensure all personnel expected to handle radioactive
material were properly trained and qualified as required by 49 CFR 172 Subpart H.
As a result, the NRC requested the licensee, in a letter dated August 12,1997, to
describe its program and actions taken or planned to ensure that personnel who
were expected to handle radioactive materials were adequately trained and qualified
in accordance with 49 CFR 172, Subpart H.
As outlined in its September 16,1997 letter, the licensee committed to review
applicable safety training requirements of other regulatory agencies (e.g., DOT) and
augment training qualification matrices in order to ensure applicable health and
safety and DOT training requirements were met. The licensee's letter indicated this
effort is scheduled for completion by the end of 1997.
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In addition, the inspector noted that the licensee had reviewed its staffing
requirements and concluded that, based on the limited activities to be performed, its
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radioactive material staffing was adequate to complete activities in 1997, but that
additional staffing needs would be evaluated to support the organization during
decommissioning. As outlined in its letter, the license ladicated that in order to
ensure that an appropriate level of training exists in the radioactive material handling
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area, the licensee would augment individual training matrices as required. Based on
discussions with the Radioactivo Material Handling Supervisor, the Radioactive
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Meterial Handling Group had reassumed decontamination activities following
radiological controls weaknesses identified during NRC Inspection No. 50-213/96-
12. According to the supervisor, no specific training program was established for
decontamination personnel. As discussed above, the I:censee plans +o evaluate
training needs to ensure personnel receive appropriate training for assigned tasks.
c.
Conclusions
Personnel had received appropriate training for fuel receipt, urloading, and
inspection activities. The licensee committed to augment its training and
qualification matrices fo environmental health and safety and DOT training
requirements to ensure personnel involved in such activities received applicable
training.
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R8
Miscellaneous Matters
R8.1 Confirmatorv Action Letter
a.
Scope
The NRC issued Confirmatory Action Letter (CAL) No. 197-007, dated March 4,
1997, to confirm the licensee's actions and commitments to identify and effectively
resolve weaknesses and deficiencies in the i nplementation of its radiological
controls program. The implementation of the CAL was previously reviewed during
NRC Inspection No. 50-213/97-06, dated August 12,1997. During the previous
inspection, the inspector determined that the licensee was implementing
commitrnents to the NRC, as required.
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b.
Observations and Findinas
During this inspection, the inspector made the following observations relative to
licensee implementation of the CAL:
The inspector attempted to perform an inter-comparison of the licensee's
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corrective actions / program improvements in response to
concerns / recommendations outlined in the licensee's independent
assessment of the radiological controls program. The licensee's commitment
to perform such as assessment was outtined in the CAL. However, the
inspector was unable to readily identify and compare corrective actions
developed ir response to concerns and recommendations made in the
independent assessor's report. The licensee subsequently developed a
matrix to depict the status of actions and program improvements relative to
the findings of the independent a:;sessment.
The licensee provided training to personnel on eleven new and/or revised
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procedures developed during Phase I of the radiological controls improvement
program. The licensee provided the training in a group review / discussion
tormat and a training instructor had asked questions of personnel to
ascertain if the individuals were knowledgeable of the new procedures and/or
revised procedures.
-
The inspector noted that the licensee's Technical Specificationr quire that
the licensee implement a training and qualification program nn3.aent with
ANSI N18.1,1972. The inspector noted that Section 5.5 of the ANSI
standard specifies that a means of verification of the effectiveness of training
be provided. The inspector questioned the adequacy of the verification of
the effectiveness of the training of personnel on the eleven procedures.
Specifically, based on discussions witF the cognizant instructor, limited
questions were asked of personnel and all personnel were not asked
questions. Consequently, it was not apparent that the means employed to
determine the effectiveness of personnel training was adequate and that
personnel were fully cognizant of requirements in the new and/or revised
procedures.
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11
The inspector reviewed the licensee's training program procedure that
provided guidance for establishing training for personnel on matters such as
new and or/ revised procedures. The inspector observed that the procedure
provided little guidance relative to the means to be utilized to verify the
effectiveness of training provided personnel based on '.he safety significance
of the material to be covered. This was considered a training program
weakness.
The inspector considered this an important matter in that 1) the procedure
revisions undertaken in Phase I were for the purpose of ensuring minimum
conformance with applicable regulatory rcquirements, 2) the licensee would
be undertaking activities that could impact worker health and safety, and
3) previous NRC reviews concluded that personnel sometimes neither knew
applicable procedure requirements or followed requirements during
performance of their tasks.
The licensee initiated a review of this matter and indicated that an enhanced
means of verifying the offe:tiveness of the training would be implemented
(e.g., testing). The licensee indicated the individuals would be tested
appropriately.
The licensee provided special training to personnel on alpha contamination
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and hazards, and on free releasing material. The inspector identified
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individuals who had not received the training, it was unclear as to the
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reasons all personnel were not trained on such matters, including individuals
(
involved with site characterization who may be working in areas with
elevated alpha contamination.
The inspector questioned several program aspects that were not addressed
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within the scope of Phase I program improvements, in particular, tha
inspector questioned the adequacy of guidance for performing internal dose
assessments in that program procedures allowed for limited evaluation of
apparent minor intakes of radioactive material. The inspector questioned the
adequacy of this guidance in light of the potential for intakes of trensuranics
during decommissioning activities. The inspector also noted that the
licensee's dose assessment program provided for evaluation of diver tritium
exposure in derived air concentrations hours (DAC-hrs) even though airborne
activity would not be the likely exposure hazard. The licensee ihitiated a
review of these matters,
in addition, the inspector previously identified (Reference NRC Inspection Report No.
50 213/97-06) the following matters which were not reviewed in the Phase I
program.
There was a need to evaluate the adequacy and effectiveness of radiological
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contamination control practices within the radiological controlled area. Such
an evaluation should examine matters such as the appropriateness of egress
of personnel from procese building to outdoor areas without frisking.
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(Note: As discussed above, the evaluation should also review the practice of
leaving process building doors open and the storage of material outdoors in
rusted, non-weather tight containers.)
The inspector noted a review of the adequacy and effectiveness of
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radiography practicos should be performed.
The inspector noted that, in response to the CAL, the licensee had developed a list
of areas with potential alpha emitters. The inspector noted that the list did not
contain the residual heat removal sump. The licensee initiated a review of this
matter.
c.
Conclusion
'
The inspector's preliminary revicw indicated the licensee was implementing Paase I
'
cf its radiological controls improvement program. However, the inspector
questiorsed several matters as discussed above.
R8.2 Haddam Neck Site Characterization (General Descriotion of Licensee Activities and
4
Discussion)
a.
Scope
10 CFR 50.82, Termination of License, provides requirements for the licensee
relative to termination of its power reactor license. One requirement is that licensee
is to provide the NRC a license termination plan. The plan is to include, among
other matters, a site characterization. The inspector reviewed the licensee's plans
and activities in the area of radiological characterization of the Haddam Nock site.
b.
Observations and Findina
b.1
Survevs - General
At the time of this inspection, the licensee was performing a scoping survey of the
site for residur! contamination. The purpose of the survey was to develop a general
status of the site, relative to planning for site characterization, and decommissioning
activities. The licensee was reviewing previous spill and remediation records, event
records, and recollections of long time employees, as to the likelihood of residual
contamination at various site locations. As part of this effort, the licensee was
performing extensive reviews of station documents in an effort to identify locations
of spills and events with the likelihood of residual contamination. The licensee
identified as of September 19,1997, eleven activities and/or events that may have
rv.ulted in potential residual contamination. Based on the information obtained, the
licensee constructed a site map which depicted areas of potential or suspected
residual contamination. The licensee was also reviewing all plant systems relative
to contamination potential. Attachment 1 to this report identifies the events and
areas where potential residual contamination may be encountered as a result of the
spille e events.
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b.2
NRC Review of Characterization Documents
The inspector reviewed the licensee documentation files developed, to date, for site
characterization. The inspector noted that as of September 19,1997, the licensee
had documented or identified approximately 125 individual " events" (e.g., an
activity, event, or spill) that may have resulted in residual contamination of the site
over its operating history. Of the 125 events, about 12 involved non radiological
type events (e.g., oil spill). The events, dating back through 1969 were
documented in records such as abnormal occurrence reports, plant incident reports,
licensee event reports, adverse condition reports, and event notifications. The
inspector noted that, in general, each event included an event description, a
statement of what corrective actiun was known to have been taken at that time,
and including remediation efforts.
The inspector selectively reviewed the files and evaluated the potential for
significant site residual contamination or offsite environmental impacts, including
offsite doses. The inspector also attempted to determine if selected notable events
were reported based on documents contained in the event files.
The notable events reviewed by the inspector are discussed in Section R8.3 of this
inspection report. The licensee was continuing to review historical files at the end
of this inspection.
The inspector noted that it was not apparent in some instances that corrective
actions to prevent recurrence were always completed or documented. The
inspector did noted that the licensee was continuing to search archives for spill
history records and corrective actions,
b.3
Locations of Potential Residual Contamination and Dose Calculations
in general, the inspector's discussicn with licensee personnel and subsequent
review of the documentation indicated that areas of potential residual contamination
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were principally located around, and potentially under, the various radiological
controlled process buildings. These buildings are centrally located on the site and
within the protected area. The licensee had performed core bores at three locations
around this area and noted that, based on these limited preliminary samples, no
significant st. ;urf ace (e.g., greater than 6 inches) residual activity was present.
Areas where residual contamination may be present included areas previously used
for outdoor handling of radioactive waste (e.g., outdoor resin handling station). In
addition, the areas identified also included an area known as "the ballfield" (an area
within the protected area) and an outfa? area at the south end of the facility,
(outside the protected area but within the owner controlled ares), known as the
"Leachfield".
The "ballfield" may have received potentially low level contaminated fill soil from
building excavation projects when it was paved over. The inspector noted that the
apparent excavation was performed to support the construction of the radwaste
reduction facility as described in plant design change request No.85-733, dated
October 15,1985.
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in the course of the excavation, the licensee detected soil contamination, excavated
the contaminated soil to a pre-determined specific activity based on an evaluation,
disposed of contaminated soil by transier to a licensed disposal site, and performed
a dose calculation based on residual radioactivity remaining in the excavation. The
inspector noted asphalt was surveyed by direct frisk for contamination. The
inspector's review of radiological survey records for 1985, indicated radiological
surveys were conducted of soil areas through the latter pertion of 1985. The
licensee performed direct frisking of soil and analyzed the soil using gamma
spectroscopy. Preliminary data reviewed by the inspector indicated identified
contaminated soil was drummed and disposed of as radioactive waste.
At the time of the inspection, the inspector was not able to ascertain if all soil
excavations were loentified and reviewed for disposition of contaminated soil. The
inspector's review noted that soll sampling was also performed in 1987 using direct
frisking techniques and gamma spectroscopy. The licensee's procedures for that
time identified survey and monitoring criteria and specified the use of gamma
spectroscopy. In addition, soil excavations occurred in October 1988 (Reference
NRC Inspection Report No. 50 213/88 19). Soils were direct frisked and analyzed
by gamma spectroscopy systems.
The outfall received some contamination following at least one spill event in 1989,
and could regularly receive run off from RCA yard areas. The licensee remediated
soil contamination at the outfall location but residual low level soil activity remains.
The licensee calculated potential doses to individuals, attributable to the
contamination, relative to decommissioning guidelines for the outfall and concluded
the estimated doses would be under the current NRC decommissioning criteria (i.e.,
25 millirem / year).
The inspector noted that due to changing boundaries over the years, the actual
protected area and radiological controlled area surface areas have increased
resulting in paving over of areas (e.g, "balifield") that may exhibit low level
,
radioactive contaminetion).
The inspector noted that the licensee developed a site " potential residual
contamination map" depicting areas onsite that may exhibit residual contamination.
A number of the potential contaminated areas (e.g., " ball- field") have been
incorporated into the protected area and are inaccessible to the public.
b.4
Stack Releases
The inspector noted that during 1979, the licensee experienced a number of
apparent unplanned releases from the stack due problems involving the degassifier
and the steam generator blowdown. In addition to the expected noble gesses and
tritium, on some occasions, the releases appeared to have deposited particulate like
ma;ter within the owner controlled area and contributed liquid releases to the storm
drain system. The material was detected during a routine site survey effort in
March 1980. Subsequently, additional surveys and cleanup efforts were conducted
to identify and remove the material. The licensee notified the NRC and the State of
Connecticut upon identification of the material.
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15
b.5
Releases to Storm Drains
The inspector also noted that, over its approximately 30 year operating history, the
licensee had experienced a number of onsite spills and storm drain overflows due to
leaks, clogging of drains, and/or cracked pipes. The inspector's reviews also
l
indicated that the affected areas appeared to have been remediated when the
contamination was detected,
Of particular note was a discharge in early 1989 of contaminated liquid from a
spent fuel storage building drain to a trench in the protected area known as the
115 kV switch yard trench. The release was detected during routine outdoor
surveys and the area underwent remediation, including the outfall area into which
the trench discharged it was not apparent that contaminated discharges to the
trench was limited to 1989. It is possible, that previous discharges may have been
made through this pathway and that early spills may have occurred. The NRC was
informed of the 1989 occurrence and reviewed licensee actions in this matter. NRC
Inspection Report 50-213/89-02 pertains.
The inspector also noted low level tritium releases from the External Containment
sump. This matter is discussed in Section R8.3 b.1. The releases appeared to be a
small fraction of typically releases.
b.6
Landfill
The inspector noted that in July 1997, the licensee became aware that an area
know as the " landfill," located about 0.25 miles northeast of the station in the
owner controlled area, had received fill / rubble from an onsite work activity. The
licensee performed radiological measurements at the location and detected residual
low level contamination, The area was subsequent!y fenced in and controlled as a
radiological controlled area. The licensee performed a dose assessment for potential
exposure to the material and concluded that exposure to the material would not
result in an personnel exposure in excess of current NRC decommissioning
standards. The licensee was continuing to review this matter.
b.7
Other Activities
The licensee was, at the end of the inspection, reviewing all onsite
construction / excavation projects in an effort to locate potential excavation / fill
materialin order to determine where the material had been placed and to verify that
no residual contamination may have inadvertently been released form the station.
The licensee was coordinating this effort with the State of Connecticut's
Department of Environmental Protection (DEP) and was monitoring offsite locations
and performing sampling and analysis of soil, water, and other media. The licensee
was analyzing the samples at or below the lower limits of detection (LLDs) specified
in the radiological environmental monitoring program (REMP). NRC and DEP
personnel obtained samples for independent evaluation.
16
As of the end of the inspection (September 19,1997), no offute surveys or
samples (i.e., outside the owner controlled area) were identified that indicated the
presence of radioactive material from the Haddam Neck Station. The licensee
identified about 12 offsite areas that were believed, with reasonable assurance, to
have received some fill / rubble from the site. The licensee was continuing to
evaluate the excavation projects at the end of the inspection.
The NRC, licensee, and DEP personnel were performing cooperative surveys and/or
monitoring and/or sharing survey data and split samples at the locations. The
results of surveys at one location, noted to have obtained fill / rubble, are cortained
in NRC Inspection Report No. 50-213/97-07. The surveys did not indicate
contamination attributable to the Haddam Neck station.
During the inspection, the licensee provided the NRC a briefing as to the current
status of site scoping and characterization. The attachment to this inspection
report provides the licensee's briefing material which includes, among other
matters, preliminary licensee dose calculations, core bore 4ssults, and a map
depicting onsite areas that may exhibit potential residual contamination based on
operating history of the station.
,
The following matter was acted:
10 CFR 50.75 (g) requires, among other matter that the licensee keep
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records of information important to the safe and effective decommissioning
of the facility in an identified location until the license is terminated. The
records are to include records of spills where significant residual
contamination may remain and also as-built drawings showing locations
where radioactive materialis used and where corstamination may have
spread to inaccessible locations.
The inspector noted that 10 CFR 50.7E (g) became effective in July 1990, a
file was apparently initiated at that time consistent with 10 CFR 50.75 (g)
but the file was not maintained current with updated information. The
licensee identified this matter and issued an adverse condition report. The
inspector indicated the adequacy of the licensee's maintenance of
documents relative to 10 CFR 50.76 (g) is an unresolved item pending
review of the extent of information maintained. (UNR 50-213/97 08-03)
c.
Conclusion
The licensee was performing site radiological scoping surveys in support of efforts
to characterize and develop decommissioning and remediation plans for the site.
The inspector noted that the licensee appeared to be performing a good effort, in
this very early stage of site evaluation, to identify areas of potential residual
contamination that may require remediation. The inspector considered the surveys
to be preliminary and noted that the site would be subjected to extensive suiveys
and monitoring for purposes of site characterization, remediation and final
termination survey. The licensee was also performing follow-up of reports of
,
fill / debris removed offsite and surveving the material. The licensee did not appear
to mairitain a 10 CFR 50.75 (g) file.
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17
The inspector did not identify any areas with apparent extensive significant residual
contamination remaining in place that constituted an immediate health and safety
concern to workers or the public. The licensee appeared to have taken steps to
remediate notable spills and/or events, as discussed above. The licensee
calculations, as provided in the attachment to this report, indicated that preliminary
dose assessments show the identified onsite residual contamination would produce
radiation doses below current NRC decommissioning dose guidelines.
R8.3 Previous Contamination Events (NRC Specific Observations and Reviews)
a.
Insoection Scoce (83726,84750)
As discussed above, the licensee had identified approximately 125 events dating
back through 1969 and identified eleven principle activities or events that appeared
to be a source of patential residual contamination which could lead to suspected
contamination of the site. At the time of the inspection, the licensee was
continuing to gather data on the events and the remediation efforts that hed or may
have occurred. The inspector selectively reviewed the data relative to the potential
for significant residual contamination, impact on the environment, or offsite dose. In
addition, the inspector selectively reviewed the licensee's reporting of these events.
b.
Observations and Findinas
b.1
Releases to Soils, Storm Drains, and Contamination of Storm Trench and Outfall
Area
The inspector noted that the licensee experienced a number of spills and releases
over the operating history of the Haddam Neck, including spills to soil areas, storm
drains, storm trenches, and outfall areas. The inspector's review indicated spills as
little as 2 gallons were documented in the licensee's plant incident reporting system
and identified as remediated. The inspector's selective review indicated that the
licensee appeared to have notified the former Atomic Energy Commission or the
NRC of notable spill events particularly those that were unplanned gaseous or liquid
releases. Some onsite spills did not result in NRC notification.
A notable spill occurred in early 1989 when contaminated water was released from
the spent fuel building floor drsin to the 115 kV switch yard trench due to
ineffective control of floor drains. The inspector reviewed the radiation work permit
for the activity and noted that during work activities associated with clean-up of the
reactor cavity, a drum of radioactive liquid was decanted to a floor drain in the
spent fuel storage building. The floor drain was believed to connect to the
licensee's radioactive waste processing system. However, the floor drain actually
led to a trench on the northwest side of the station. The circumstances surrounding
the event, including the licensee remediation efforts were discussed in NRC
Inspection Reports 50-213/89-02, dated May 17,1989, and 50-213/90-11, dated
June 29,1990. The contamination within the trench was detectea four weeks
after the event during outdoor surveys performed by the licensee's radiation
protection personnel. After discovery of the event, the licensee declared an
Unusual Event (i.e., lowest level of emergency warning) and notified the NRC and
the State of Connecticut.
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The inspector reviewed the initial and post decontamination survey activities for tim
trench. The lice nee surveyed the outfall and detected contamination at that
location, built coffer type dams to collect the residual contamination and flushed the
trench to collect residual activity. The licensee performed excavations of the
affected soil. The contaminated soil was shipped for disposal at a licensed disposal
facility.
Since 1980, the licensee routinely sampled the outfall to det t the presence of any
residual activity. The inspector's review did not identify any anificant increase in
outfall soil sample activity however apparent increases in activity were noted after
the spill to the trench. Most recent sample data, reviewed by the inspector
indicated soil contamination ranging from 0.5 to 3.2 picoeuries/ gram (pCi/g) for
Cobalt-60 and 0.5 to 2.4 pCi/g for Cesium-137. Licensee alpha spectroscopy did
i
not identify any apparent plant related alpha emitters. The licensee provided the
inspector a calculation, which assumed that a large area of the outfall was
contaminated at the highest contamination levels noted. The licensee's calculations
indicated dose rates to potential intruders were well within NRC Decommissioning
guidelines. Licensee survey data for February 25,1989, did not identify any
significant residual contamination.
The inspector's review of the releases identified the following questions:
The inspector did note that some spills occurred around tanks a.9., the
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refueling water storage tank, primary water storage tanks) and under
buildings. In particular, the inspector noted that the licensee discovered in
June 1976 (Reference LER No. 76-13/990) that the waste discharge pipe
was leaking under the drumming room floor at the juncture of the service
water pipe. Although the licensee indicated that radioactise material
released was reported through the normal release report mechanism the
inspector noted that there was a potential for residual contamination at the
location. A similar leak was identified in December 1976 (Reference LER
No. 77-01/3L). The licensee indicated sand in the immediate vicinity was
drummed. The inspector concluded that subsurface areas around these tanks
and under buildings has yet to be characterized.
The inspector's review of radiological data for external monitoring of storm
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drains and outfalls at the station indicated that the licensee continues to
experience low concentration tritium releases from a sump around the
containment structure. The inspector's preliminary review did not indicate
the presence of fission or corrosion products in the water. The sump is
known as the External Containment Sump (ECS) and its effluent discharges
into the 115 kV switchyard trench which ultimately leads, via storm drains,
to the discharge canal or the outfall.
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+
The inspector noted that the licent.e9 had recently (December 1996) took action to -
quantify, on a weekly basis via a stesse permit, the tritium released from the sump
and include that quantity in its NRC required effluent release report it was unclear
as to why such " permitting" was not performed previously although sampling had
been conducted. The licensee was using conservative release quantities of water.
The inspector's review indicated that prior t. secember 1996, no such " permitting"
was apparently performed. Further, the inspector was unable to ascertain if any
systematic effort had been undertaken to determine the source of the tritium and
terminate its source.
The inspector also noted that the licensee had recently recognized that apparent
small quantities of water from the ECS was backflowing to the outfall area. The
licenses sampled the standing water in the outfall and noted that the tritium
conceritration in the outfall was comparable to that contained within ECS discharge
water. The licensee sand bagged the trench to prever.t the backflow. It was not
apparent that these release paths were included in the licensee's offsite dose
calculation manual. At the time of the inspection, the licensee was not able to
provide bases for not considering this pathway.
The inspector reviewed effluent release reports for the period 1979 through 1996
and noted that the reports contained no apparent reference to unplanned liquid
releases or an indication that the storm drain or trench releases were included as
release paths.
The inspector performed preliminary calculations and noted that the additional
tritium that may have been released was a small fraction of the tritium that was
normally released from the station. Consequently, potential offsite doses
attributable to the additional tritium appear to be minor and within "aplicable limits,
in addition, it was not apparent, due to the small fraction of total trkium released
via the ECS sump, that such releases were significant and needed to be reported.
The inspector indicated that reporting of releases of tritium from ground water
sources to the NRC was an unresolved item pending NRC review of the licensee's
bases for not " permitting" the releases until December 1996. (UNR 50 213/97-08-
04)
The inspector also reviewed the offsite dose calculation associated with the
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1989 spill of radioactive liquid from the spent fuel building to the 115 kV
switchyard. - The inspector noted that the dose assessment included a
aasumption of a release of 50 gallons of liquid to the environment. The
inspector noted however that the dose assessment only included dcse due to
gamma emitting radionuclides. The inspector's review of survey data of the
115 kV trench after the spillindicated the presence of alpha emitters. Alpha
emitters were not included in the dose assessment. The inspector's review
of the survey data and discussions with radiation protection technicians did
not indicate the presence of hot particles. A recent survey of the trench did
not identify any removable contamination or contact radiation levels above
background. The drain was plugged and a cap was placed over the drain in
the trench.
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The inspector noted that the licensee had developed guidelines for
-
remediation of soil contamination as a result of spills (e.g., radwaste
reduction facility excavation).. However, the inspector noted that the
guidelines appeared to be inconsistently apolied to alternate situations. For
example, the licensee implemented a soil remediation guideline for the
outfall. However, the inspector could not identify any documented basis for
the guideline (1E-4 uCi/g) for this specific area. The inspector did note that a
recent calculation indicated doses were under the decommissioning
'
guidelines however, it was not apparent that such a calculation was done
when the soil guideline was impleme'nted.
,
Ac part of the review, the inspector teviewed licensee action on a previously
-
issued Inspection and Enforcement Bulletin (IEB) 80-10. The IEB provided
guidance to license's relative to inadvertent release of material from the
,
station as a result of cross contamination or system interfaces. It appears
that the licensee did not effectively implement the guidance in the bulletin in
that floor drains were ineffectively controlled that allowed release of
'
contaminated material to the environment. The inspector ncted that, as a
result of subsequent licensee review of systems, the licensee recently
,
discovered low level contamination in turbine sumps and the closed loop
cooling water.
.
The inspector observed that the refueling water storage tank apparently has
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.
exhibited a small leak for an extended duration. The tank contains tritiated
'
water and may be a source of low level tritium contamination. The licensee
has initiated action to review the leak and correct the matter.
,
l
As a result of the above issues, the licerisce developed (August 30,1997), a
ground water tritium and IE Bulletin 80-10 task force, and scheduled actions to be
<
completed. The licensee initiated action to attempt, via use of ground water wells
-
and support from hydrology personnel, to identify the source of the tritium. The
.
licensee has initiated action to review all plant systems which have the potential to
fall under IE Bulletin 80-10, conduct safety evaluations in accordance with the
bulletin, and develop a comprehensive IE Bulletin 80-10 program for
decommissioning.
Notwithstanding the above, based on the rev~.ew, the inspector concluded that it
I
was appropriate for the licensee to re-review, the liquid spill events and releases
from sumps (e.g., ECS and cable vault) that may have introduced radioactive
material (e.g., trit!um and other radionuclides) into the storm drains and soil to
ascertain if 1) the quantities of radioactive material released were properly
incorporateJ into effluent release summaries provide to the AEC/NRC, and 2)
radiation' doses were properly calculated using allidentifiable radionuclides.
The inspector considered the documentation and reporting of other releases to the
NRC as well as the adequacy of the. dose assessments as an unresolved item
'
pending NRC review of licensee bases for not including the information in effluent
i
release reports. (UNR 50-213/97-08-05)
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b.2
. Stack Releases to Owner Controlled Area
f
The inspector noted that on March 9,1980, the licensee detected a number of
j
locations of contamination onsite. The licensee notified the NRC and the State of
Connecticut of the findings. Throughout the month, the licensee performed a scan
f
survey of the entire site and extensive portions of the owner controlled area to
i
1
identify any additional contamination. The licensee identified isolated spots of
radioactive material at various locations on site including within the protected area
l.
and in publicly accessible areas of the owner controlled area. When detected, the
!
spots of contamination were remo"ed. The licensee completed and documented an
j
,
'
evaluation of the findingw including potential causes. The llcensee concluded that
the most likely mode of dispersion was material ejected from the primary vent stack
due to apparent unplanned releases from the stack via introduction of activity in the
sta, < am other systems (e.g., degassifier, steam generator blowdown). The
.
e
'
liceme daveloped and implemented an action plan to address the causes of the
i
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contamination.
The inspector's preliminary review of this event indicated that the licensee
performod extensive surveys of the site and remediated allidentified spots. The
licenses also performed external and internal dose calculations. The releases
included short lived fission products. The dose calculations did not indicate any
apparent significant doses.
.
Subsequent to the inspection, the licen.,ee provided to the inspector results of an
October 1981 Department of Energy Aerial Radiological Fufvey of the Haddam Neck
l
Plant. The report, pavided to the licensue as an enclosure to a August 25,1982,
letter from the NRC, covered exposure rates in a 108 square kilometer area
.
.
centered on the Haddam Neck Plant. The survey provided radiatlan exposure dose
!
rates at one meter above the ground surface. The report also provided an inter-
comparison of groundbased lonization chamber measuren enta, soll measurements,
.
and aerial measurements. The renort concluded that, based on a comparison of
results with the August 1969 aerial radiological survey, no changes in radiological
,
characteristics were detectable outside the plant bounderles in the 12 years of plant
operation since the August 1969 survey. Tue report did note an increase in
radiation directly over the plant as would be expected.
The mspector had the following questions on the stack releases:
i
The inspector was not able to complete a review of the accuracy of the
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licensee's stack effluent releases reported for 1979 or the adequacy of its
,
effluent monitoring capabilities at that time, in consideration of the above
discussed releases.
These matters are considered an me
ad item in that it was not clear that
the licensee had included the parucu4
releases in its 1979 effluent release
report. (UNR 5(,213/97 08 06).
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22
Although inspector review of licensee data indicated no significant personnel
.
dose was sustained following the 1979 releases, the inspector questioned
the adequacy of the potential dose assessments.
It was not apparent that the licensee's on she radiation survey program at
-
the time of the events was effective in that the survey program did not
provide for timely detection of contamination (e.g., contamination
attributable to the 1979 events detected in March 1980). In addition, the
licensee had also detected instances of isolated contamination prior to 1979
and subsequent to 1980. Although the spots were remediated and
l
additional areas surveys, it was not apparent, in allinstances as to the cause
of the contaminat;on or the effectiveness of corrective actions to prevent
recurrence. This is an unresolved item pending NRC review of the licensee's
contamination monitoring program for that period. (UNR 50 213/97 08 07)
Although no specific deficiencies were noted, the inspector questioned the
-
adequacy of the licensee's current onsite survey and monitoring practices to
detect small particulate type activity and its non-RCA survey program. The
licensee initiated a review of thlo matter.
Regarding reporting of issues the inspector noted there was no apparent program
procedure to ensure all appropriate 10 CFR 20 incident / event reports were made as
appropriate. The licensee initiated a review of this matter.
b.3
Deposition of Soil / Fill at the Landfill
The licensee performed radiological measurements at the landfill and detected
residual low level contamination. Soil samples were conducted in the area and
radiation dose rate measurements were made. Co 60 activity in isolated spots
ranged from about 0.31 pCilg to 4.3 pCi/g. Cs 137 ranged from 0.17 pCl/g to
34.8 pCi/g. The licensee collected material from the area (e.g., fabric, soll, brick)
that indicated 400 600 corrected counts per minute (ccpm). The licensee
performed preliminary estimates of potential doses to personnel who may have
inadvertently entered the area and concluded that dose received would be below
decommissioning guidelines (i.e.,25 millirem / year).
The insoector noted that 10 CFR 20.1501 requires that the licensee make or cause
to be (lade surveys that may be necessary to comply with the regulations in this
part and are reasonable under the circumstances to evaluate concentrations or
quantitles of radioactive material.
The inspector noted that surveys of the fill / rubble released from the station were
necessary to comply with the requirements of 10 CFR 20.1801,20.1802,
20.1902, and 10 CFR 20.1302. The f ailure to survey the materialis a violation.
(VIO 50 213/97-08 08)
.
I
23
The inspector noted that 10 CFR 20.2203 requires the licensee to report, within 30
days, among other requirements, levels of radiation or concentrations of radioactive
material exceeding the constraints or limits specified therein. The inspector's
preliminary review of the above matter Indicated a report did not need to be
provided in that the contamination was detected in the licensee's owner controlled
area. However,10 CFR 50.72 requires a four hour report be made for among other
matters an inadvertent release of contaminated naterial for which a news release is
plannec or notification to other government agencies has been or will be made. The
reporting of the contaminctiort relative tn 10 CFR 50.72, is an unresolved item
pending NRC review of licensee notifications made. (UNR 50 213/97 08 09).
The inspector noted that although the licensee had fenced the area of identified soil
contamination to prevent unauthorized access, personnel could enter the area and
walk around without frisking of their feet upon egress. The mspector noted that
although the likelihood of tracking residual contamination was low, it appeared
reasonable to provide frisking for personnel egressing the area pending complete
characterization and evaluation of radioactive contamination the location. Also, the
inspector noted that material used in the area should be removed. The inspector
walked on the surface during reviews at the location and surveyed his person for
contamination. None was detected.
The licensee indicated that personnel did not frisk out at the area due to limited
work activities and subsurfcce contamination. The licensee subsequently resurveyed
the landfill area and did not detect any change in radiological conditions from that
previously noted. The licensee indicated that effective September 12,1997, the
'
area would be controlled as an RCA, an RWP would be used to access the area, a
'
radiation protection technician would provide coverage for access to the area, and
frisking will be required to egress the area. The licensee also indicated pre job
briefs would be provided to review conditions and controis, controls would be
commensurate with planned activity and keys to the gate for the area would be
controlled by the radiation protection supervisor.
The licensee also indicated material used for sampling (e.g., plastic gloves) was
retrieved and that the sampling area was covered with plastic to prevent runoff of
potential contamination,
c.
Conclusion
The licensee identified at least 125 events dating back through 1969 and eleven
principle activities (e.g., resin handling) or events that appeared to be a source of
potential residual cor :mination which could lead to suspected contamination of the
site. At the time of the inspection, the licensee was continuing to gather data on
the events and the remediation efforts that had or may have occurred. Weaknesses
in control and evaluation of radioactive contamination were noted including
identificat!on of a violation of NRC requirements. Unresolved items were identified
relative to evaluation of contamination and reporting of spills,
i
m
24
R8.4 NRC Heview of Licensee Radioloalcal Survevs and NRC Survev Results
a.
Insnection Scone
The inspector reviewed the status of site contamination caused by known events
that resulted in the inadvertent spread of radioactivity inside the radiological,
protected, and owner controlled areas of the station. The review involved a
walkdown of site areas both inside and outside the protected area, and performance
of direct radiation measurements to ascertain the presence of significant residual
contamination. The inspector performed ground level scanning measurements in
selected areas to identify areas of potential residual contemination in known and
suspected areas. Soil and water samples were also collected as appropriate in
areas likely to contain radioactivity. The inspector also interviewed licensee
personnel regarding actions h response to past contamination events.
The inspector also accompanied licensee personnel and State of Connecticut
representatives as surveys were made of offsite locations.
b.
Observations and Findinas
b.1
Survevs Made on Juiv 3,1997
Accompanied by a qualified CY health physics technician on July 3,1997, the
inspector walked down station areas of interest. The technician used an ASP 1
GM tube dose rate survey instrument (SN 2007) with a full scale reading of 1
mrem /hr) and made radiation measurements at 1 meter off ground (waist height)
and on contact with ground / asphalt / vegetation in areas of interest. Surveys were
taken inside the RCA, outside the RCA but within the protected area (PA), and
outside the PA but within the owner controlled area (OCA). The inspector closely
monitored the radiation meter as the technician made measurements with the
calibrated and source checked survey meter.
Outside the PA
The surveys outside the PA focused on the fields (i.e., outfall) that received
contamination from past events (e.g., an event in 1989 in which radicactive liquids
were discharged into a floor drain inside the spent fuel building). All areas surveyed
outside the PA were at a background level of less than 0.02 mrem /hr on the ASP 1
(i.e., less than 20 microR/hr), including at a location of known low lovel
contamination from plant operations. The licenseo had remediated the 1989 spill
and was monitor!ng residual contamination in the field.
A licensee survey of the area using a high sensitivity Nal detector indicated elevated
count cate readings. The licensee reported that drainage pipes from this field to the
discharge canal have not shown measurable activity. The inspector collected a soil
and water sample from the outfall area and noted difficulty in scanning the area due
to apparent radiation shine from sources within the radiological controlled areas.
.
. . _
~
,_
_ _ - ,
r
j
25
1
The licensee performed a dose calculation for the residual contamination contained
in the soil and concluded that potential radiation exposures attributable to the
residual comamination were within decommissioning limits.
'
The inspector noted that one area monitored by the licensee, but not surveyed on
July 3,1997, was the discharge from the site storm drains into the north end of the
discharge canal. The licensee's previous environmental surveys at this location
have found plant activity at levels of 17 picoCi/g at 2 feet depths in the sediment at
the outfall from the pipe. Contamination levels were slightly higher in the upper
layers of sediment. This activity was limited to the soll below the discharge pipes
and is not considered by the licensee to be a significant source term to the effluents
in the discharge canal. This conclusion is based on part on routine licensee
measurements of radioactivity as part of the environmental monitoring program at a
point just downstream of the outfall discharge.
Inside the Protected Area But Outside the RCA
All ASP 1 measurements inside the PA, but outside the RCA, showed ambient
ba:kground levels at less than 0.02 mrem /hr (i.e, less than 20 microR/hr).
Inside the Protected Area and Inside the RCA
Dose rates at areas of interest inside the RCA were generally less than
0.02 mrem /hr, with a few exceptions. These surveys were hampered by ambient
low level radiation from normally contaminated tanks and components within the
RCA. One manhole cover in the RCA yard, located 10 ft east of the nitrogen
storage area and in a location of past overflows events, indicated a contact dose
rate of 0.2 to 0.4 mrem /hr, and less than 0.02 mrem /hr at 1 meter.
The inspector discussed these findings with licensee personnel and was informed
that the manhole was sealed ar.d was a collection point for radioactive liquids
coming from the chemistry laboratory and the hot machine shop. The manhole was
essentially a collection point with a pathway to the aerated drain tank. The
inspector noted that this particular collection manhole had overf! owed on occasions
during previous years resulting in unplanned releases to storm drains. The
collection point was previously cleaned out. When identified, the storm drains were
pumped out for disposal. The manhole was eventually sealed. The radiation dose
rates indicate potential residual radioactivity within the collection area of the drain.
The asphalt around Bus 10, which was the former location of the spent resin cask
wash down area, exhibited isolated readings on contact at its base in the range of
0.1 to 0.3 mrem /hr, with some spots in the seam between the concrete and the
asphalt reading 2 mrem /hr.
,
.
I
).,
~
J
26
(Note: The inspector resurveyed the base of Bus 10 on September 11,1997. The
inspector identified dose rates up to about 5 millirem /hr at the location. The
inspector noted loose soil at the base of the concrete stab, upon which Bus 10 sits,
near the asphalt. An open widow reading indicatsd the presence of loose surf ace
contamination. A subsequent licensee survey identified loose beta / gamma
contamination of up to about 4,000 dpm/100 cm'. No alpha contamination was
identliiod. The area was cleaned and sealed with a tar like substance.)
The inspector noted that licensee radiation protection procedure NUC RPM 5.1.2,
Revision 1, Posting of Radiological Controlled Areas specifies (Attachment 2) that
contaminated areas be posted with signs bearing the radiation caution symbol ano
the words " Caution Radioactive Material". The inspector noted that the ares was
not posted. This is a violation of Technical Specification 6.11 which requires that
radiation protection procedures be implemented. (VIO 50 213/97 08-01)
e
The inspector noted that the licensee collected 3 core bores inside the RCA in May
1997. The core bores were about 3 feet deep. No significant activity was found in
the soil, and only in the top six inches of soil under the asphalt. The highest levels
,,
recorded in the asphalt was 12 picoCl/g at location #2 (spent fuel cask wash down
area). The licensee was reviewing those areas as part of the decommissioning
process,
b.2
jiurveys Made on Auaust 12 and 13,1997
On August 12 and 13,1997, the inspector also walked down accessible areas of
the site outside the protected area and made radiation measurements. The
inspector performed scanning measurements with a high sensitivity sodium iodide
detector on the station's south peninsula, including scans of discharge canal dredge
materialin a holding area. No radioactivity above background levels was detected.
Landfill (Shootina ranagl
On August 13,1997, the inspector toured the licensee's landfill (shooting range)
and obtained split samples from areas of elevated readings at the land fill. The
inspector obtained split samples from the following locations:
Firing Range, about 1 foot east of licensee sample point 15A, depth about 6-
-
12 inches.
Firing Range, about 1.5 feet east of licensee sample point 9A, depth about
-
612 inches.
Firing Range, about 1.5 feet east of sample point 9A, depth about 0 6
-
inches.
l
_ . _ _ . _ . .
- - - - - - - -
27
These samples were collected by licensee personnel and were observed by the
inspector and the State of Connecticut DEP representative.
Exposure rate measurements were made at the locations of these samples at the
time of collection, in the existing hole near sample point 15A the exposure rate
-
was approximately 50 microR/h. At the surface of the sarnple location near sample
point 9A the exposure rate was about 30 microR/h. Typical background rneasured
in the vicinity and away from the Haddam Neck plant ranged from 7 9 microR/h.
'
The inspector collected a gamma spectrum at licensee sample point 9A on
August 12,1997, the day before the inspector's soll samples were collected. The
licensee informed the inspector that Yankee Lab had made in situ gamma spectrum
measurements at the firing range and identified Cs 137 and Co 60 as the
radionuclides causing the exposure rates to be greater than background. The
inspector identifled only Cs 137 and Co 60 as the contributing radionuclides other
than naturally occurring materials.
.
115 Kv switch vard trench
The inspector reviewed radiological surveys made by the licensee of the trench.
The surveys indicated no measurable contamination or radiation was identified,
in addition, the inspector requested a sample of water from the trench. The
,
licensee collected a water sample from the trench in the 115 kV switchyard. This
sample collection was not observed by the inspector.
Areas Outside the Protected Area and inside the Protected Area Fence
On August 14,1997, the inspector made radiation and scanning measurements at
the station and collected samples. The following samples were obtained:
A soil sample was obtained from inside site security fence at south corner of
-
site at lowest point on the edge of the asphalt (about 10 feet from fence line
at river end of gate GS-2). A split / equivalent sample at the same location
was collected for the licensee.
A soil sample was obtained from inside the SE site fence line, about 10 feet
-
in the " plant east" or NE direction from the edge of the concrete wall over
the discharge canal. The top 1 inch layer of soil was sampled. A split
sample for the licensee was also collected.
A soil sample was obtained from outside of security fence, plant south side,
-
on the discharge canal side of the paved driveway exiting through gate GS-7.
The sample was about 40 feet from driveway,10 feet south of security
fence corner post, at edge of grass / gravel at a low point, where visible
erosion would deposit soil / runoff. A licensee split sample was also collected.
-
. . - - _ .. . - -
. _ . - - . . - - - . . - - - - - . - _ - - - .
. - - . - -
28
A soil sample was obtained from outside the security fence, plant south side,
I
-
at estimated low point in the outfat (i.e, "Leachfield") (about 75 feet from
outside security fence,3 feet south of rusted metal post). The top
3 6 inches of soil was collected and noted to be, dark, loamy soil. A
!
licensee split sample was also collected.
A water sample was obtained from a point where the runoff pipe emerges at
-
.
the south outfall (i.e., "Leachfield"), outside of security fence. The sample
was about 5 feet from edge of gravelin an open depression containing
standing water. The pipe was described by the licensee as directing water
from the 115 kv switchyard and running under the basketball court area
blacktop and security fence. Licensee split also collected. NRC sample was
1 liter for gamma spectroscopy and 20 mi vial for tritium analyses.
The inspector was unable to identify a runoff point for water exiting the
r
outfall area. The only available water in the area was at the " top" of the
leachfield where the licensee said the pipe ends. The end of the pipe was
not directly visible.
The above samples were integrity sealed and provided to the licensee for shipment
to the NRC.
b.3
Survevs Made on Seotember 19,1997
The inspector toured the back yard areas of the radiological controlled area and
made surveys of ptvement areas and concrete joints near the base of buildings. No
unusual radiation readings were noted including areas around the spent resin and
ion exchange facilities.
The inspector attempted to enter an area known as the Culvert Area behind the
!
zone 6 control point. The area was locked and was used to store cement shields
for radioactive material storage therein (e.g., resin liners). The inspector requested
a survey of the area. Loose removable contamination up to about 4,000 dpm/100
cm' was identified on the pavement area. The licensee initiated action to
decontaminate the area.
The inspector noted that licensee radiation protection procedure NUC RPM 5.1.2,
Revision 1, Posting of Radiological Controlled Areas specifies (Attachment 2) that
contaminated areas be posted with signs bearing the radiation caution symbol and
the words " Caution Radioactive Material." The inspector noted that the areas was
not posted. This is a violation of Technical Specification 0.11 which requires that
radiation protection procedures be implemented. (VIO 50 213/97 08 01)
The inspector did not identify any apparent similar areas inside the RCA with
potential loose surface contamination other than the Bus 10 area discussed in
Section R8.b.1.
,
,
m.
-
, --
m----,.,n-,
. . . . ,
c-%
-.. - - . . .
.-.m.,,.mm<,
-,- -
, - . . - - - , - . ,
,.r--
-m-
y
.---
m---.,
.
-
- _ _ - - _ _ _ - - _ -
29
b.4
NRC Laboratorv Results
The laboratory results are reported in the following tables. Table 2 provides the soil
sample analysis results and Table 3 provides the water sample analysis results,
included in the soil sample results is a Cs 137 background of about 1 pCi/g which
can be attributed to past nuclear weapons testing fallout. No Am 241 was detected
in any samples. Am 241 would be indicative of other transuranic nuclides. Tritium
in the two water samples was less than the EPA drinking water standard of 20,000
pCi/l.
i
_
-.
-
__
_ -
_ _ - . _ -
--
-..
..
.--__
.-
---
1
30
Table 2
HADDAM NECK STATION Soll SAMPLES
COLLECTED AUGUST 13 14,1997
SAMPL5
NUCLIDE
RESULT
3
(pCl/g)
- 1, Firing Range,1 ft, east of point 15A,
Co 60
0.52 * 0.02
612 inches depth
Cs 137
5.79iO.05
,
- 2, Firing Range,1.5 ft. east of point
Co 60
0.22 0.02
9A,612 inches depth
- 3, Firing Range,1.5 ft. east of point
Co 60
1.1410.03
9A,0 6 inches depth
Cs 137
15.231 0.08
- 4, SE corner of plant site,inside security
Co 60
0.0881 0.015
.
fence,10 ft, from fence at river end of
}
Gate GS 2
Cs 137
0.063 i O.014
- 5, SE fence line, inside fence, 10 f t.
0.47 t O.03
i~
NE from edge of concrete wall over
discharge canal
Cs 137
0.70 t 0.03
^
Cs 134
0.074 1 0.015
.
- 6, SE fence line, outside fence, near
<0.03
fence corner 40 ft. SW of gate GS 7
Cs 137
0.101 i O.011
- 7, Leachfield outfall (Iow point in gully),
6.66io.11
outside fence, NE of gate GS 7
Cs 137
5.61 0.09
Note: Am 241 was not detected in any samples, with a minimum detectable activity
(MDA) of approximately 0.2 pCi/g.
31
Table 3
,
HADDAM NECK STATION WATER SAMPLES
'
COLLECTED AUGUST 13 14,1997
i
SAMPLE
NUCLlDE
RESULT
( Cl/ml)
Standing water, at emergence of runoff
H3
1.79E Sio.02E 5
pipe, upper end of outfall
(17,900i200 pCill)
(i.e, " Leach field")
Co 60
<4E 8
Cs 137
<4E 8
Licensee sample, water and sediment
H3
1.68E 5 0.02E 5
from trench around 115 kv switchyard,
(16,800i 200 pCill)
,
"*
6E 8i2E 0
Cs 137
1.0E 710.2E-7
c.
Conclusions
Within the scope of the limited qualitative reviews and radiation surveys conducted
on July 3, August 1213, and September 11,1997, no areas were identified
outside the protected area with significant residual contamination. Selected surveys
within the protected and radiological controlled areas identified apparent localized
contamination. Direct measurements of radiation dose rates showed no significant
impact on public or plant worker safety.
Nonetheless, licensee activities were in progress to complete scoping surveys in
support of site contamination survey in accordance with 10 CFR 50.82(a)(9). The
NRC will continue to review licensee actions in response to the past events, the
present levels of contamination at the site, and the licensee's activities to complete
site characterization.
R8.5 NRC Information Notices 97-36,97 66.97-68
a.
Scope
The NRC issued several Information Notices that were potentially applicable to
licensee decommissioning activities. These were:
NRC Information Notice 97-36, Unp!anned Intakes by Workers of Transuranic
-
Airborne Radioactive Materials and External Exposure Due to inadequate
Control of Work, dated June 20,1997.
-
- . . - .
_.
.
.
,-
__
-
_ _ _.. _ -- . _ _ _ _ _ ._. _ -
__-
. ..___ ___ _ -___ _ _ - _ _ _ _ _
32
i
NRC Information Notice 97 66, Failure to Provide Special Lenses for
-
Operators Using Respirators or Self Contained Breathing Apparatus During
Emergency Operations, dated August 20,1997.
NRC Information Notice 97 68, Loss of Control of Diver 11 a Spent Fuel
-
Storage Pool, dated September 3,1997.
The inspector discussed the above notices with licensee representatives to ascertain
if the notices had been received and reviewed,
b.
Findinas and Observations
Although no specific actions were required, the licensee was aware of the
Information Notices and was reviewing them and the NRC concerns / problems
discussed within the Notices,
c.
Conclusion
The licensee had received and was reviewing recent NRC Information Notices for
applicability to station activities,
i
R8.6 40 CFR 190 Dose Limits (IFl 50 213/97 01-10)
a.
Scope
During the referenced inspection, and NRC 'nspection No. 50 213/97-06, the
inspector discussed conformance with the Eavironmental Protection Agency (EPA)
regulation 40 CFR 190 with the licensee. The review was prompted, in part by
elevated direct radiation dose rates in the back yard areas of the station and posted
"ALARA walk ways." The inspector's previous reviews indicated documentation
and basis, relative to conformance with 40 CFR 190 was weak or not available for
review. Subsequently, the licensee initiated a review of this matter,
b.
Findinas and Observations
The inspector met with cognizant licensee personnel who provided data obtained via
routine processing of environmental TLDs located within the owner controlled area.
The TLD data provided for 1995 and 1996, including analysis of potential annual
doses to members of the public who may enter the owner controlled area, indicated
that the licensee was in conformance with 40 CFR 190 as referenced in 10 CFR 20.1301 using the occupancy factors provided. The inspector noted that the
licensee maintained extra environmental TLDs along the protected area fence for
purposes of ensuring conformance with 10 CFR 20. The inspector had the
following additional questions.
_____ _ _
_ _ - _ _ _ _ _
33
One area near the intake structure indicated periodic increases (spikes) in
-
radiation it was not clear as to the reasons for the increase. The licensee
indicated the increases were attributable to rediography in the area. The
annual average dose rates continued to be low.
c.
Conclusion
Based on ths data provided, the licensee protected area boundary exhibited dose
limits within 10 CFR 20 limits. This follow-up item is closed. (IFl 50 213/97-01 10)
X1
Exit Meeting Summary
The inspector presented the inspection results to members of licensee management at the
conclusion of the onsite portion of the inspection on August 15, September 12 and 19,
1997. The licensee acknowledged the findings presented.
On September 19,1997, the licensee provided a briefing as to the status of site scoping
and characterization activities and radiation protection program activities including actions
.
associated with the Confirmatory Action Letter. The licensee provided briefing package is
attached to this report.
-__
34
l
PARTIAL LIST OF PERSONS CONTACTED
Licensee
T. Folgenbaum, Executive Vice President and Chief Nuclear Officer
R. Mellor, Director Site Operations and Decommissioning
G. Bouchard, Work Services Director
R. Gault, Radiation Protection Supervisor
J. Goergen, Assistant Health Physics Manager
!
S. Herd. Chemistry Manager
l
G. van Noordennen, Licensing Manager
l
R. Sexton, Radiation Protection Manager
l
R. Shippee, Site Characterization
!
L. Rayburn Silvia, Health Physicist
M. Sweeney, Radiation Protection Services Supervisor
'
J. Warnock, Quality Assurance Manager
N. Winters, Senior Radiation Protection Specialist
HilG
W. Axelson, Deputy Regional Administrator, NRC Region 1
J. White, Chief, Rediation Safety Branch, NRC Region l
State of Connecticut
K. McCarty, Director, Department of Environmental Protection
M. Firsick, Health Physicist
INSPECTION PROCEDURES USED
IP 71707:
Plant Operations -
IP 83726:
Contamination Control
IP 84750:
Effluent Monitoring
IP 92904:
Followup - Plant Support
l
_ _ _ . . .
. . _ . .
_ _ _ - . . _ . . _ _ _
_ . . _ - ._ _ _ _ _ . _ . . _
- ._ ._ . _ . _ _ __ _ . _
,
t
35
ITEMS OPEN, CLOSED, AND DISCUSSED
,
QARIl
97 08 01
Failure to Follow RP Procedures
'
97 08 02
UNR Dose Assessment for Worker
97 08 03
UNR Establishment of 10 CFR 50.75(g) Program
.
97 08 04
UNR Reporting of Groundwater releases of Tritium
97 08 05
UNR Review unplanned Releases
97 08 06
UNR Review 1979 Stack Releases
97 08 07
UNR Adequacy of onsite surveys
T 08 08
Failure to Survey per 10 CFR 20.1501
'
u-08 09
_UNR Reporting of Releases of material to the Landfill
"
97 08 10
UNR Workers did not follow RWP
!
Qlacussed
.
97-01 11
UNR Review Release of Contaminated Material
Closed
i
97 01 10
IFl
Compliance with 40 CFR 190 not verified
97-06 02
UNR Training of Workers per DOT Requirements
!
,
i
a
i
i
-
i
-, -
.e-.
-
- - ,
,-.
n
,r-,-
-,.
.,
- - _ ~ , . , - - - - -.
,.,----------w-m-w~e.---
,
,
- - + --
.o
e-
36
LIST OF ACRONYMS USED
ACR
Adverse Condition Report
Confirmatory Action Letter
l
CCPM
corrected counts per minute
CFR
Code of Federal Regulations
CYAPCo
Connecticut Yankee Atomic Power Company
l
Final Safety Analysis Report
!
GL
Generic Letter
!
Health Physics
IFl
inspection Followup ltem
IR
inspection Report
large area smear
Nuclear Materials Safety and Safeguards
Notice of Violation
-NRC
Nuclear Regulatory Commission
Nuclear Reactor Regulation
PAB
Primary Auxiliary Building
PCF
personnel contamination form
OA
Quality Assurance
Quality Assurance Surveillance
OC
Ouality Control
Radiologically Controlled Area
Updated Final Safety Analysis Report
Unresolved item
Violation
WCM
Work Control Manual
-.
-
-
. . . . .
.
.-
-.
.
--
-
-
.
.
ATIAODENT
Connecticut Yankee
Site Characterization
.
_
4
CY Site Characterization
.
Purpose
Process
Scope / Methodology
Status / Schedule
Release Criteria
CV
<
--
.
-.
.
-
.
-
-
.
. _
--
-
-
. -
_ - .
L
!
I
Purpose of Site Characterization
i
Identify the Type, Location and Level of
l
-
Contamination Present On the CY Site
!
I
Estimate the Volume and Type of Waste Material
-
i
Identify Significant Radiological and Chemical
l
-
Hazards Requiring Consideration During
Decommissioning Work Planning
l
(Y
.
-
-
.-
-.
-_- .
- _ _
_ - - -
- . .
. _ -
-
.
!
_
_
,
,
,
,
!
!
!
r
'
Characterization Approach
!
-
,
!
!
I
!
!
l
!
!
Systems
Structures
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Site Characterization - Process
1
.
Phase 1- Scoping (1997)
l
-
-Evaluate the Radiological Status of the Land
'
'
Areas, Systems, and Structures Which Could
Have a Significant Decommissioning Cost
!
!
Phase 2 - Characterization (1998-2003)
-
.
-Iterative Process Which Builds On Existing Data
.
-Provides Data for Detailed Decomm. Planning
-Validates Effectiveness of Decomm. Activities
l
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-Supports Final Survey Process
4
!
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4
.
Site Characterization - Process
,
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Phase 3 - Final Status Survey (2003-2004)
-
!
.
-Confirm That No Licensed Material Remains
On the Site in Excess of NRC Final Survey
Limits
,
,
t
-Survey and Sampling Data Statistically Based
and Analyzed to Demonstrate Compliance
,
With Release Limits (NUREG 5849 and
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Historical Site Assessment
,
Purpose
-
-
- Assemble the Radiological History of CY With
the Intent of Defining Areas Where Additional
,
Evaluation is Required
,
Process
-
-Review Historical Records
.
-
,
-Interview Past/Present Employees
Status / Schedule
-
-Near Completion - Complete by End 1997
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EVENTS _ ASSOCIATED __WITH AREAS OF SUSPECTED RESIDUAL RADIOACTIVITY
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khXd by radiological events
_
1) Resin transfer and related activities resuttng in yard area surface contam'natro.1
Yard drains affected by
2) Yard area surface contamination outside of Fuel building
b
documented radiolog. cal events
3) Radwaste storage and handhng/RCA run-off
4) Tank leaks, Tank heater leaks and Prima'y vent stack events
~
Area of potential migrat.on of
5) Contam:nated dra:n system overflow release caused oy system backup
b
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residual rad;oactivity
6) Rad;oactrvity : dent:fied in Yard Storm Drain system e"hents
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F
Potential residual radcactnnty in the
8) fAgration flow path of rad!oactivity from the RCA or aMected areas
b
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expanded protecteo area (orig grade)
9) Accumutabon of radioact:vity from storm drain and mondored release emuents
10) Area af'ected by storage and handhng of n.atenat and equ'pment
-
Area of potential restdual radioactivity
11) Leakage from poing of monstored emuent release path under PAB
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SCOPING SURVEY STATUS
(1 OF 2)
! CORE BORES >
~5uxiliary Exit
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PAREING LOT
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All Spaces Surveyed' Asphalt 10mR/yr.
r SPHALT & SOIL
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- ---
Road
Soil No Activity !
STOPM DRAIN
No Detectable
No Detectable
b.
SAMPLES
RUNOFF
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No Activity
Avg 11mR/yr
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AREA
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- .Samp s Be,ng
coNNECDcUT RNER
No Detectable
Activity
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Act,vity-
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-
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b: _us. INDICAVS AREAS OF THE SITE THAT HAVE BEEN SURVEYED / SAMPLED FOR RADIOACTIVE MATERIALS
k.
NOTES:
1) Dose Rates Calculated using NRC Approved Code - Highest Occupancy Case Assumption (ie. Resident Farmer)
2) Current Applicable NRC Limits for Dose to a Member of the Public Onsite is: 100mR/yr (10 CRF 20)
3) Current Offsite Limit (40 CFR 190) + Final Site Release Criteria (10 CFR 20. Subpart E) is: 25mR/yr
Revision #0 09/18/97
_ ___________-____
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SCOPING SURVEY STATUS
(2 OF 2)
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INDICATES AREAS OF THE SITE THAT HAVE BEEN SURVEYED / SAMPLED FOR RADIOACTIVE MATERIALS
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Revision #0 09/18/97
.
Land Areas Scoping Survey
Scoce/ Methodology
Scan Surveys, in-Situ Gamma Spec, Soil Sampling
-
Approx.14 Protected /Non-Protected Areas identified
-
- Areas Selected Based on Historical Assessment
Soil Sampling to include Core Boring
-
Groundwater Sampling
-
Hazardous Material Analysis
-
CV
--.
- -.
- - - _ .
- _ - _ _ . _ .
-
. _ -
-
.
!
Land Areas Scoping Survey
!
Status
!
-
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-Survey Plan Drafted
i
-4 RCA . Soil Samples
-4 On-Site Areas 100% Scanned, in-Situ
Gamma Spec and Soil Sampling of Areas With
Elevated Readings
'
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!
!
Schedule
l
-
<
-Most Surveys to Be Performed Mid Sept to
j
.
l
Late October
!
!
-Lower Risk Surveys in November
,
.
-
_
_
.
_ _ _ _ _ _
.
- - -
_
_._ _ _ .
-
_
-
.
Land Areas Scoping Survey
l
Groundwater Surveys
-
-Scope / Methodology-
Selected RCA Locations Due to Tritium
,
Detection
Landfill Locations Due to Detected Activity
l
Peninsula / Switchyard Locations Due to
Hazardous Materials Concerns
!
-Status / Schedule
i
!
n Work Scheduled to Begin in Late September
i
!
!
.
_ _ -
-
_ _ _
.
.-___
__ _ _ ______ - __ - _ _ - _ _ _ - - _ _ _
O
O
o
.
!
SCOPING SURVEYS (Grounds)
(Priorities set based on radiologicalimportance)
l
Area Description
Area.# Classification Priority
Surveys to be Performed
Comments
Shooting Range Landfill
9535
1
Gridding and surface scans, so.1 samples, split
!
spoon core bores, deep penetrating core bores,
i
}
h
groundwater
I
I
Northwest Protected
9302
2
Groundwater
NRC prionty
,
i
'
Area Grounds
!
N
Southwest Protected
9304
3
Groundwater
NRC poonty
l
1
Area Grounds
g
i
4
Groundwater
NRC prionty, suspected beause RCA
j
South Central Protected
9306
Suspected .'l
stormoram exists berow grade.
!
!
Area Grounds
S
.
1
!
Southeast Protected
9308 } ~ Suspected
5
Deep penetrating core bores
suspected because of contam.nat<on that
[
existed in ong nal grade. Fdi was
!
Area Grounds
q l -.
screened , rnay have contamination
<
i
(basketball cou.rt)
[
-
l
YD 115 KV Switchyard
9102
6
surface scans,2 ft split spoon core bores,
Shiefded in-situ Gamma
l
Area
A
l
YD PAB / Service
9307
7
Asphalt and soil core bores
Building / Containment
p
f
'
'
Alley.vay Area
PAB Sub-Surface
9130
8
Concrete core bores to permit 2 to 3 ft sptit
l
spoon core bares, shielded in-situ Gamma
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.
.
.
,
_ _ _ _ _ _ _
O-
o
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Area Description
Area # Classification Priority
Surveys to be Performed
Comments
YD South Tank Farm
9110
9
surface scans, Asphalt and soil core bores
Area
4
YD lon Exchange Area
9114
T~seface scans, asphalt and so.1 core bores
j
4
i,
i
YD Resin Slurry Area
9116
11
surface scans, asphalt and soit core bores
!
4-
l
!
Upper End of Discharge W
T
below water sediment samples
Canal
i
A
i
i
Southwest Site Storage
952
Suspected ;
13
surface scans, sois samples,2 ft spl.t spoon
'
core bores, in-situ Gamma
Area
14
surface scans, soit samples,2 ft spiet spoon
North End of Peninsula
9529 l Suspected --
core bores, in-Situ Gamma
l
'
Central Peninsula Area
9530 - Suspected: .
15
suvace scans, soit samples,2 ft split spoon
core bores, deep penetrating core bores in
j
dredge dumping area, in-situ Gamma
Southeast Site Grounds
9522
16
surface scans. soit samptes,2 ft split spoon
c re bores, deep penetrating core bores in
(Non-Protected Area)
n4-
cverfWed re s, Shielded in-situ Gamma
"stormdrain outfal!
YD North Tank Farm
9108
17
Asphalt and soil core bores
f
Area
jy
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.
.
. . . _
.
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-
_
. _ - _ - _ _ .
__.
.
.
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Area De.s.criptjon
Area # Classification .Prionty
Surveys to be Performed
Comments
'
Lower End of Discharge
9107
18
operational canal water level sediment and
,
below water sediment samples
[
ggggj
A
' ~ ~ ' ' " -
.
YD PWST Area
9122 ! Suspected l
19
surface scans, aspnart and sois core bores
'-~'~;
l-
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i
$
f
]
!
YD Backup PWST Area
9124 i; Susoected
20
surface scans, asphatt and sois core bores
i
$
~
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1
i
YD Large Yard Crane
9126
-
21
surface scans, aspnatt and sosi core bores
Area
j
YD Boron Storage Tank
9112
-
22
sutace scans, asphatt and so : ccre bores
j
Area
4
_
1
Northeast Site Grounds
9502 . Suspected
23
surface scans, in-situ Gamma, soit samples
Area poss biy affected from years of
'
accumulation of stack effluent and event
(Non-Protected Area)
3
1
releases
l
9
24
surface scans asphatt and soit core bores
' ~ ~ '310 '
-
1
East Protected Area
Grounds
4
Northeast Protected
9312
25
surface scans, asphalt ar'd soil core bores
Area Grounds
j)
South End of Peninsula
9531
-
26
surface scans, soit samples
it
..
-
s-sydd
4. ,,y of i Jc 1 OckU *
S c-
u
u s. fTr d w
--
-
-.
.
. . _ _ - _ _ _
_ _ _ - -
. . _ _ . _ _ _ _ _ - - - - - -
_ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ - _ _ _ _ _ _ _ _ _ -
- - - - ,
1
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O
O
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Area.De.s.cription
Area #
ation Priority
Surveys to be Performed
Comments
South Site Grounds
9524
27
sudace scans soit samples. in-sisu gamma
I
(Non-Protected Area)
9
-
i
l
Northeast Mountain Side
9526
28
sudace scans
!
,
I
4
i
f
Central Mountain Side
9527
-
29
sudace scans
'
k
,i
t
,
!
.
Southeast Mountain
9528
30
sudace scans
!
l
Side
_
g
,
1
Southwest Site Grounds
9518
31
sudace scans
j
i
(Non-Protected Area)
i
R
!
Bypass Road /
9504
T
Secondary Parking Lot
!
,
'
M
'
Pond
9508
-
33
water sevel and below water sediments
-
!
lt
-
\\
.
Primary Parking Lot
9514
34
I
.!
4
West Central Site
9516
35
sudace scans
!
Grounds (Non-Protected
4
j
Area)
__
u s e. I Odtd
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M
k,te5< or tb ad. h < & L
i
.
. .
.
.
- .
_ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ -
-
_ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ . . . _ _ _ _ _
. _ _ _ _ . . '
_
O
O
O
i
,
!
i
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4
Area Description
Area #_
I
onlPrio.rity
Surveys to be Performed
Comments
i
i
Northwest Site Grounds
9512
36
surface scans
!-
l
i
(Non-Protected Area)
N
f
Nortn Site Grounds
9506
37
surface scans
!
!
(Non-Protected Area)
i
i
R
i
i
Access Raod
_
38
surface scans
9510
l
>
-
surface scans, soet sampfes
l
.
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YD Fuel Oil Tank Area
9118
39
!
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R
9104
40
surface scans
Nea
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2
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cf idee l' #i t < I I 'D'
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!
4
.
.
.-
--
-
.
.-.
--
-
_
.
.
Systems Scoping Survey
'
To identify Internal Contamination
-
.
-Scope / Methodology
- No Surveys of Known Contaminated Systems
- 20 Systems identified As Suspect (Yellow)
- Smears / Scans of Internals at Selected
Locations
.
-
- . _ - - - - . . - -
- - - - - . _ - - - , - - -
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Systems Scoping Survey { cont'd}
i
To identify Internal Contamination (cont'd)
-
-Status / Schedule
!
- System Scoping Plan Drafted
!
- Completed One System, Working 4 Others
!
- 16 Of Approximately 100 Survey Locations
Performed.
- Schedule for Completion in November
'
1997
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Structures Scoping Survey
1
Compiling Existing Contamination / Dose Rate
-
Data
Concrete Core Bores and Roof Samples to
-
Determine Depth of Contamination
-Locations Based On Avg. And Worse Case
Conditions
Schedule / Status
-
-Sampling in Late September Thru October
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OFF SITE ASSESSMENTS and STATUS
Survey Area
Status of Evaluation
9605
A scan survey of the area perfonned by CY on 7/16. No elevated indications found.
Surface soil samples and a water sample were collected and split with CT DEP and
NRC. No plant related radioactivity detected in the samples.
9601
Fixed point dose rate surveys and scan survey of the area performed by CY and
State DEP on 9/16. No elevated indications found. Surface soil samples collected
and split with CT DEP and NRC. No plant related radioactivity detected in the
samples. Subsurface sampling scheduled.
9604
Fixed point dose rate surveys and scan survey of the area performed by CY and CT
DEP on 9/17. No elevated indications found. Surface soil samples collected and
split with State DEP and NRC. Awaiting sample results.
9608
Fixed point dose rate surveys and scan survey of the area performed by CY and
State DEP on 9/18. No elevated indications found. Surface soil samples collected
and split with CT DEP and NRC.
9602
Survey scheduled for 9/19 in the aflernoon. Survey will be performed in
J
9603
Contact with owner made. Walk down of property with owner complete. Tentative
i
survey scheduled for week of 9/22.
l
9606
Inquiry / investigation in progress. Contact has been made with owner.
i
9607
Inquiry / investigation in progress. Contact has been made with owmer.
!
9609
Component purchased by plant employee and removed from site. Identified 9/17.
Inquiry / investigation in progress.
9610
New property identified 9/18. Inquiry / investigation in progress.
'
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Release Limits
Limits for Material Released From Site Under the
-
Operational Program - No Detectable
Final Survey Release Limits Higher As They Are
-
Dose Based - 25Mr/Yr to an Individual
- Soils
- 30 To 100 Times Higher (Based On
i
RESRAD Code)
-Systems / Structures
'
- More Than 10 Times Higher (NUREG-1500)
'
,
--
-
.
6
Radiation Proteetion
Program
,
Ct
.
---
.
.
_ _ - -
_ _ _ _ _ . - _ _ _ _ _
-
- - _ . - - -
.
.
-
,
Radiation Protection Improvement
Project {RPIP)
Phases & Schedule
.
Phase I - Completed on Schedule 09/02/97
-
!
!
Phase II - Scheduled Completion 12/15/97
-
Phase ill - Scheduled Completion Second
-
Quarter 1998
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Phase I Accomplishments
i
192 Corrective Actions Completed
-
,
Cultural Changes Initiated
-
.
Standards and Expectations Established
f
-
.
Work Planning, RWPs, and Pre-Job Briefings
-
Strengthened
i
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.
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-
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-
.
-
_ _ _ - .
.
-_----_
Phase I Accomplishments (Cont.}
.
HP instrument Prog;am improved
-
Alpha Monitoring Enhanced
-
1
HP Staff Training Conducted
-
.
t
Enhanced Radiation Worker Training Has Begun
-
!
!
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. _ - .
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Procedure Compliance
!
!
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Management Reaffirmation of Strict Procedure
-
!
Adherence as a Policy
j
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Staff Focus on Correcting Procedure issues Rather
-
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than Procedure Work-arounds
!
!
Procedures Edited to Achieve Compliance During
-
!
PhaseI
'
Procedure Overhaul During Phase ll
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_
_ _ _ _
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HP C'rganization & Expectations
j
.,
Positive Culture Change "We can fix it"
-
'
Threshold for Identification of Problems and
-
Issues are Dropping (ACRs increasing)
Improved Sense of Near-Term and Long Term
-
Direction for the Program
i
!
Expectations for a High Quality Product
-
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Alpha Monitoring
Increased Sensitivity to the Presence of Alpha
-
,
Contamination
!
-
1
'
Initial Air Sampling and Assessment issues
-=
Resolved
.
Improved Detection Capabilities Planned for
-
PhaseIl
!
!
!
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C.orrective Action Letter (CAL) Sta1:us
,
.
Meeting with NRC Scheduled for End of Month
-
!
NRC Onsite Evaluating Progress of RPIP
-
Transition Plan Drafted
-
.
7
-Most Work Control Measures to Remain in Place
-Plan to Gradually increase Radiological Challenge of
Authorized Work
- Monitor Effectiveness of Improvements
i
'
,
'
.
.
_.-._ _ _ __ _ - --_
- _ _ - _ .
.-
_
.
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!
NRC lssues
NOV on Failure to Follow Procedures'
-
i
-
- Underwater Work
-!
-Posting & Control of Airborne Radioactivity
Areas
'
!
HAZMAT Training Weakness identified
l
-
Response to NOV & HAZMAT Training
-
Weakness- 09/11/97
!
!
Site Characterization Was the Focus of the Last
-
l
Inspection - No Concerns identified
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-
- _ _ -
-
. _ _
- _
- _
-
- - - - -
- _
.
-
,
Confirmatory Survey Status
!
Confirmatory Survey Near Completion
-
169,150 items Surveyed tc Date
1
-
373 Items or 0.23% Had Detectable Activity
l
-
!
-73% Had < 100 Cepm
(287 Items)
t
Conclusions - No Significant Health or Safety
-
Concern
!
!
!