ML20211F059

Forwards Assessment of Nene Response to Allegations of Retaliation & Potential Chilling Effect within Millstone MOV Dept

ML20211F059
Person / Time
Site:	Millstone
Issue date:	09/22/1997
From:	Jeffery Griffin AFFILIATION NOT ASSIGNED
To:	Travers W NRC (Affiliation Not Assigned)
References
ITPOP-97-0034, ITPOP-97-34, NUDOCS 9709300336
Download: ML20211F059 (11)

Text

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4 Little Harbor Consultants,Inc.

Millstone ITPOP Project Omee P.O. Box 0630 Niantic, Concecticut 06357 0630 Telephone 860 447.t791, est $966 Faz 860-444 5758 September 22,1997 Docket Nos 50 245 50 336 50-423 ITPOP 97 0034 Dr. William D. Travers, Director Special Projects Office Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 001 hiillstone Nuclear Power Station, Unit Nos.1,2, and 3 Little Harbor Consultants, Inc. (LHC) Assessment of'Githeast Nuclear Energy Company's (NNECo) Response to Allegations of Retaliation and R,ential" Chilling Effect Within the hiillstone hiotor Operated Valv$ Separtment 1

Dear Dr. Travers:

Transmitted herewith is the LHC assessment of Northeast Nuclear Energy Company's (NNECo) response to allegations of retaliation and potential " chilling effect" within the hiillstone hiOV department.

On September 17,1997, LHC met with NNECo management and representatives of the NRC to share the results of this assessment. In accordance with the protocol of our Oversight Plan, = f documentation of this discussion is provided within three working days of the meeting.

/ /

b Please note that Attachment I has been marked to indicate its confidential nature. The nature of is such that it revels personnel information, the public disclosure of which would constitute a clearly unwarranted invasion of personal privacy. Accordingly, pursuant to 10 C 2.790(a)(6), LHC requests that Attachment 1 be witi. held from public disclosure in its entirety.

An affidavit supporting LHC's request that Attachment 1 be withheld from public disclosure is enclosed. (Enclosure 1.) LHC, however, has no objection to the placement of this cover letter or in the NRC Public Document Room.

9709300336 930922 h

PDR ADOCK 05000245 P

PDR,

U.S. Nuclear Regulatoiy Commission ITPOP 97 0034/ Page 2 P! case de oot hesitete to contact me at 860-444 5626 should you have any quesilons or need additionalirformat'on.

Very truly yours, t]h,q N A

John M. Grimn Deputy Team Leader,ITPOP (Affidavit) cc: Bruce D. Kenyon Distribution List (w/o Attachment 1)-

__.__._._______________m

U.S. Nuclear Regulatory Commission ITPOP 97 0034/ Page 3 Distribution:

D.M. Goebel, NNECo Charles Brinkaan, Manager Washington Nuclear Operations p y,' m ABB Combustion Engineering Nuclear Power K. M. McBrien, NNECo 12300 Twinbrook Pkwy, Suite 330 He, 20852 W. J. Tengle, h%Co -

5. Baranski, NNECo Mr. John Buckingham C

Hc WHy Cond M. Quinn, ECOP Electric Unit U.S. Nuclear Regulatory Conunission 10 Liberty Square

- Atta: Docunent Control Desk New Britain, CT 06051 Washington, DC 20555 Citizens Regulatory Commission U.S. Nuclear Regulatory Commission ATTN: Ms. Susan Perry Luxton Atta: P.F. McKee 180 Great Neck Road Mail Stop: 014D4 Waterford, CT 06385 Washington, DC 20$$$ 0001 Citizens AwarenessNetwork U.S. Nuclear Regulatory Commission

$4 Old Turnpike Road Atta: H.N. Pastis Haddam, CT 0643g Mail Stop:014D4 Washingtoa, DC 20555 0001 The Honorable Terry C-=aa=

Nuclear Energy Addsory Council Mr. Wayne D. Lanning Legislative Omce Balding Deputy Director oflaspections Hartford, CT 06106 SpecialProjects Omce 475 AllendaleRoad Mr. Evan W. Woollacott Co Chair King of Prussia, PA 194061415 Nuclear Energy Advisory Council

- Kevin T. A. McCanhy, Director.

128 Ter7y's Plain Road Monitoring and Radiation Division Simstxuy, CT 06070 Department of Environmental Protection 79 Elm Street Ernest C. Hadley, Esquire 1040 B Main Street Hartford, CT 06106-5127 P.O. Box $49 Allan Johanson, Assistant Director West Wareham, MA 02576 Omce of Policy and Management-Mr. PaulChoiniere Policy Development and Planning Division 450 Capital Avenue-MS 52ERN "The Day" P.O. Sox 341441 47 Euges.c O'NeillDrive Hartford, CT 061341441 New London, CT06320

. First Feltetmen Bob DeFayette Town of Waterford 100 Kings Street Hall of Records-Gettysburg, PA 17325 200 Boston Post Road DonR~L==n

.Waterford, CT 06385 1071 State, Route 136 Belle Vernon, PA 15012

ENCLOSURE 1 AFFIDAVIT IN SUPPORT OF REQUEST TiiAT INFORhiATION BE WITHHELD FROM PUBLIC DISCLOSURE 1, John M. Griffin, being duly sworn, depose and state:

l.

I am Deputy Team Leader of the Independent Third Party Oversight Program at the niillstone Site of Northeast Nuclear Energy Company. I make this affidasit in support of LHC's request that Attachment I to LHC's letter of September 22,1997, be withheld from public disclosure pursuant to the provisions of 10 CFR 2.790(a)(6).

2.

Attachment I contains information related to the circumstances of actions taken against individuals by NNECo that may be used in making personnel decisions, the public disclosure of which would constitute a clearly umvarranted invasion of personnel privacy.

3.

The circumstances of personnel actions taken against individuals is customarily treated in strict confidence by NNECc.

4.

For the reasons stated in paragraphs 2 and 3 above, it is appropriate to withhold Attachment I to LHC's September 22,1997, letter from public disclosure pursuant to the provisions of 10 CFR 2.790(a)(6).

72.N h John M. Griffin Sworn to and subscribed before me this #2-day of 3rdre/a 1997 f&N &

Notary Pu6 Tic My Commission expires #& s'3,200 /

.....ai.GOODSON NOTARY PUBLIC Commission fapires November 30,2001

G l

a e

4 ASSESSMENT OF NORTilEAST NUCLEAR ENERGY COMPANY'S RESPONSE TO ALLEGATIONS OF RETALIATIOh AND POTENTIAL " CHILLING EFFECT" WITHIN Tile MILLSTONE MOV DEPA1TMENT lt is the consensus of Little Harbor Consultants (LHC) that Northeast Nuclear Energy Company (NNECo) took appropriate and timely action in response to allegations of retaliation'and potential

" chilling effect'in the Motor Operated Valve (MOV) Department. However, as detailed.below, NNECo senior management did not identify the management problems in the MOV department in sufficient time to prevent the demotions and terminations. Additionally, NNECo senior management was slow in recognizing and responding to indications of retaliation and " chilling effect' from the employees and the Employee Concerns Program (ECP).

EXECUTIVE

SUMMARY

LHC has concluded that NNECo's response to the allegations of retaliation within the MOV department by the NNECo ECP was timely and effective. First, the ECP recognized the significance of the allegations of retaliatory demotions received on July 25,1997, and within two business days responded to those allegations and initiated an investigation. That investigation was expanded to include the tenninations of the two contractors on August 8 and 11,1997, respectively. Second, the ECP recognized the potential for a " chilling effcc/' within the MOV department, initiated an evaluation of the impact of the demotions and terminations on the MOV department, and advocated retaining the terminated engir.cers during the pendency of the ECP investigation in order to mitigate the " chilling effect' in the MOV department. Third, when NNECo senior management failed to recognize the significance of the impact that the terminations were causing in the MOV department and the desirability of the remedial action of retaining the terminated engineers, the ECP Director successfully took the necessary actions to initiate reconsideration of that NNECo management decision.

While the actions of the EL' in this matter deserve recognition, the initial response of NNECo senior managers was inappropri.ite. As detailed below, NNECo senior management failed to ide itify the seriousness of the ir.anagement problems within the MOV department in time to prevent their escalation to demotions and terminations; missed several opportunities to prevent the terminatior., trom being carried out; did not recognize the significance of the allegations of

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retaliation once identified by ECP; and initially failet to take the recommended and appropriate remedird actions to address the findings of a " chilling effect' within the organization.

However, once NNECo senior management recognized the potential for retaliation in connection with the terminations and the effect the terminations had on the MOV department, NNECo management demonstrated the ability to promptly respond and took appropriate actions to counter the " chilling effect' in the MOV department. Likewise, once the ECP investigation confirmed that retaliation had been a factor in the decisions to terniinate the contract engineers, NNECo acted swiftly to remove the offending managers from supervisory positions. NNECo Page 1 of 6

management offered re-employment to the terminated contract engineers and have taken other positive actions to address the issues in the MOV depanment.

LHC has also concluded a review of the current status of employee attitudes in the MOV depanment and found no evidence of a lingering " chilling effect' within the department. To the contrary, employees report satisfaction with the new manager, an open attitude toward listening to employee concerns, the encouragement to raise questions, active lines of communications, and a "new energy" within the department. Finally, the contract engineer who has been brought back repons being treated with respect and inclusion within the MOV department.

FACTUAL BACKGROUND The background facts leading to the terminations within the MOV department are set forth in two previous reports, the August 25,1997, MOV " Chilling Effect' Report, ITPOP 97 0028 and the September 12,1997 MOV Retaliation Investigation Report,ITPOP 97 0030/0031.

ASSESSMENT OF NNECo'S ACTIONS

1. Senior Management failed to identify management problems in the management of the MOV department in sufficient time to prevent the retaliatory actions from occurring.

There were several indicators of management problems within the MOV department throughout the spring and early summer of 1997. Those indicators included two other terminations that created an appearance of retaliation for the MOV department employees, a confrontation between the Department Manager and another NNECo engineer over the approach being advocated, and a series ofinternal complaints raised to line management about the intimidating management style and questionable technical competence of the Department Manager and Supervisor.

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2. Senior Management initially failed to recognize that retaliation w as potentially involved in the terminations of the two MOV contract engineers.

Following the July 23,1997 decision by Department Manager and Department Supervisor to terminate the two contractors, Department Manager met with Jack McElwain, his immediate supervisor, to brief him on Department Manager's intent to terminate the two contractors for cause. McElwain had been made aware of potential problems within the MOV by Employee "C" on at least one occasion prior to this meeting. During this meeting McElwain did not ask any questions about involvement in protected activities by the two contractors, consider the potential

" chilling effeef' within the MOV group or ask for any substantiation of the performance issues alleged to be the reason for the terminations.

On July 29, Ed Morgan, net with Mike Brothers and Jack McElwain to discuss the ECP investigation into the demotions of Contractor "A" and Employee "C" that had occurred on July Page 2 of 6 s

_-_m.

21. Morgan indicated during this meeting that there was a possibility that retaliation was a factor in the demotions. McElwain did not inform Morgan that actions had been initiated to terminate the two contractors, one of whom had been demoted on July 21,

3. Management failed to intervene and mitigate the effect of the terminations when they were made aware that retallation was poten'lally involved in the terminations.

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l On August 13, Ed Morgan advised management that based on ECP's preliminary eviluation there was a possibility that retaliation was a factor in the terminations and recommended that in order to prevent further harm to the individuals and to mitigate the " chilling effect" within the MOV group, the contractors be kept on the payroll until the ECP investigation was completed. This recommendation was accepted by Carns, Brothers and McElwain. During a brief and informal meeting between Kenyon, Carns and Brothers, Kenyon reversed this decision. The basis for the reversal was Kenyon's belief, founded on i formation given him by Carns, Brothers and McElwain, that the terminations were appropriate discipline for the alleged offenses, and that should subsequent facts prove the opposite, that the contractors could be made whole at that time. Little, if any, consideration was given to the " chill /ng effect' caused by the terminations.

Neither Carns nor Brothers raised any objectiori to this reversal, even though all three knew that retaliation was a possible factor in the determinations.

4. Senior Management reversed its decision and took appropriate action to mitigate the

" chilling effect" in the MOV group.

As a result of the initial decision of Kenyon to reject the recommendation of Ed Morgan, as agreed upon by Carns, Brothers and McElwain, Morgan sought reconsideration of the decision.

On August 18, management reversed its decision and placed the terminated contractors on retainer until such time that the ECP investigation was completed. This reversal was significant.

Brothers briefed the MOV group on this decision and on the actims being taken to investigate and resolve the retaliation issue. The meeting had a positive criect on the MOV group. NNECo also issued a factual briefing sheet on August 18 to the workforce about the decision. This briefing sheet was an excellent decision and communicated openly about ongoing events within the MOV department.

An additional briefing sheet was distributed on August 25 that was also used to communicate the on-going activities to the entire Millstone workforce. These briefing sheets were factual and complete and are considered to be a very effective mechanism to conununicate important information to the workforce.

5. When presented with the ECP report which concluded that retaliation was involved in the termination of the two contractors, management took timely and appropriate action.

Upon receipt of the ECP conclusions that retaliation had been a factor in the termination Page 3 of 6

decisions, the two contractors were contacted and offered the opportunity to return to the Millstone MOV group in their previous positions.

The Department Manager and Department Super isor resigned and departed Millstone.

Management communicated these results to the MOV group and to the Millstone workforce in an accurate and straight forward manner.

6. The Contracts organization and the Legal department failed ta recognize potential retallation during the termination review process.

Contracts had been provided some knowledge about problems within the MOV group and failed to raise any questions on the legitimacy of the terminations to either management or the ECP.

Corrective action in the contracts organization from previous events invohing retaliation did not prevent this event from occurring. Neither the Legal department nor the Contracts organization asked for any substantiation of the alleged performance issues that were the basis for the terminations.

7. The performance of the ECP organization during the entire event was very good.

ECP recognized the potential of retaliation as a factor in the July 21 demotions. In addition, the department recognized the potential for a " chilling effect' within the department. In response to this concern, ECP contacted the senior management responsible for the MOV department to address these concerns. ECP was in the process of their investigation of retaliation and management issues when the terminations occurred. After the tenninations, ECP promptly began investigation into whether retaliation had been a factor in the terminations.

When ECP determined that retaliation was a possible factor in the terminations, the department immediately recommended that actions be taken to prevent further harm and to mitigate the

" chilling effcc/' in the MOV group. The investigation by ECP Investigator, Robert Pflueger, deserves recognition in these events. It was accomplished in a difficult environment, without well established protocols for ECP investigations of this sensitive nature, completed in an extreinely short time frame, as was called for by the seriousness of the allegations, and was well supported by the esidence, in addition, it is noteworthy that the ECP Director, Ed Morgan, advised Bruce Kenyon on August 14, that he believed Kenyon had made the wrong decision regaryng retaining the contractors on the payroll and on August 15 issued an E-mail to NNECo manage.nent advocating reconsideration of this decision. IIis actions, in advising the Nuch e Committee Advisory Team

("NcAl*) were appropriate and demonstrate the willingness ollhe ECP to insist that appropriate actions be taken, even ifinitially not supported by senior management.

Page 4 of 6

a LESSONS LEARNED There are several Lessons Learned from this event that must be understood by management and used as the basis for changing the work emironment at Millstone.

1.

During the investigation of this event it became obvious that Managers and Supenisors (including contractors serving in management and supeniso'y positions) have not been provided sufficient training to adequately deal with situations involving professional dissent. Managers and supervisors inteniewed during the investigation did not understand the basic concepts of protected activities or what constituted retaliation. They were not familiar with the regulations or the law regarding whistle blower protection.

2.

There were several missed warnings or " Red Flags" that were available to management, indicating that a problem existed in the MOV organization that required senior management intervention.

a. July 21 demotions of Contractor "A" and Employee "C" and resulting ECP complaint;

b. Contractor"C" termination;

c. Employee "X" June 13,1997 memo;

d. Contractor"1" tennination;

e. Employee "C"'s warnings to Unit 3 Engineering management that Department Manager's management style was retaliatory and that technicalissues had been raised that questioned the adequacy of the MOV program approach.

3.

There were several opportunities to prevent the terminations before they occurred, thus preventing any harm to the individuals and the creation of the " chilling effect" in the MOV group; the most notable was the July 29 briefing of McElwain and Brothers by Morgan about the allegaticas of retaliation against Contractor "A" and Employee "C" on July 21.

4.

There was a complete lack of recognition or appreciation of the impact that the termination decisions could have had on the future careers and livelihood of the terminated contract engineers.

RECOMMENDATIONS 1.

NNECo should immediately develop and conduct focused training for all supervisors, managers and the executive management team on how to recognize potential retaliation and " chilling effect," how to respond to these situations, and how to mitigate the harm from events which confirm retaliation or " chilling effect."

2.

NNECo should use the MOV retaliation investigation and findings as a " case study" to Page 5 of 6

l deliver " lessons learned" to the entire organization.

3.

NNECo should establish expectations and accountabilities for the Legal Department and the NNECo Contract Administration Depattment to provide additional barriers to possible future acts of retaliation.

4.

NNECo should continue to take actions to ensure that the employees in the $0V Group are willing to raise concerns and approach their positions with a " questioning attitude."

5.

NNECo should critically review the ability of the proposed disciplinary review panel's capability to provide the protection anticipated, formally institute the review panel, and insure that persons on the panel have the skills and qualifications necessary to make critical evaluations and judgments about proposed disciplinary actions to insure that future events such as the MOV tenninations do not occur, 6.

NNECo should insure that the retaliatory actions taken against the contract engineers are obliterated, including insuring that the termination letters are rescinded, that the security access records are restored and do not reflect terminations "for cause."

Page 6 of 6

4 Please contact me if you have any questions regarding this request.

Sincerely,

/A Tara Neider Director, Engineering Projects

Attachment:

TN-32 Storage Cask Generic Technical Specifications

E-15846 9/97 TN 32 Storage Cask Generic Technical Specifications

'.0 Content of Operating Controls and Limits during Loading, Unloading and 1

Transfer Operations The following operating controls and limits are imposed on the TN 32 cask and addressed in this section:

Cask Dose Rates Surface Contamination Levels Cask Leakage Limits Cask Intemal Helium Pressure Cask Vacuum Pressure Pool Boron Concentration Handling Height Limitations 1.1 Cask Dose Rates Limiting Condition of Operation:

The surface dose rate (neutron + gamma) on the exterior surface of the cask shall not exceed 200 mrem / hour (2.0 mSv/hr).

Applicability:

All TN 32 casks Actions Conditions Required Actions Completion Time Cask emerges from pool with total

1. If the limit is exceeded, Prior to surface dose rate >200 mR/hr (2.0 correct fuelloading shall be movement to MSv/hr) verified.

ISFSI.

2. Retum cask to pool and unload fuel.

Sunteillance Requirements Surveillance Frequency During cask loading operations, verify Once, prior to movement of cask to that the cask surface dose rates do not ISFSI.

exceed the specified limits.

1

.e E-15846 9/97 1.2 Surface Contamination Levels Limitir g Condition of Operation: Removable cask exterior surface contamination levels shall not exceed 1000 dpm/100cm* (0.2 Bq/cm ) from beta and gamma sources, and 2

20 dpm/100cm (0.003 Bq/cm*) from alpha sources.

Applicability:

All TN 32 casks Actions Conditions Required Action Completion Time Cask surface contamination levels Decontaminate cask Prior to 2

exceed 1000 dpm/100cm surfaces to below required movement to beta / gamma and/or 20 levels.

ISFSI.

dpm/100cm* alpha i

Surveillance Requirements Surveillance Frequency During cask loading operations, verify Once, prior to movement of cask to that the cask surface dose rates de not ISFSi.

exceed the specified limits.

1.3 Cask Leakage Limits Limiting Condition of Operation:

The total cask seal leakage (both inner and outer seals) shall be less than 10 '5 stc-cc/sec (1.0 x 10'5mbar-l/sec).

Applicability:

All TN-32 casks Actions Conditions Required Action Completion Time Cask sealleakage found to be A) If vent or drain sealis Prior to greater than 10' std-cc/sec, suspected - replace and movement to retest.

ISFSI B) If lid sealis suspected -

return cask to pool, remove lid, replace seal, remove cask from pool and retest.

2

E-15846 9/97 Surveillance Requirements Surveillance Frequency Mcnitor cask sealleakage using the Continuous overpressure system.

1.4 Cask Intemal Helium Pressure Limiting Condition of Operation:

Each TN 32 cask shall be backfilled with helium to a pressure of 2,230 +/- 100 mbar.

Applicability:

All TN 32 casks Actions Conditions Required Action Completion Time Cask is backfilled to a pressure

1. If the helium backfill Prior to cask outside the specified range, pressure remains below the movement to limit, check and repair the ISFSt.

cask seals, as necessary,

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4 and verify that the limit is met.

2. If the helium backfill pressure exceeds the limit, release a sufficient quantity of helium to lower the pressure.

3. If the limit cannot be met, return the cask to the spent fuel pool, remove the fuel assemblies from the cask, and retum them to the spent fuel pool.

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E-15846 9/97 Surveillance Requirements Surveillance Frequency Prior to moving a loaded cask to the Once, prior to movement of cask to storage pad, the helium pressure shall be ISFSI.

measured to ensure it is within the pressure range.

1.5 Vacuum Pressure Limiting Condition of Operation:

The cask cavity shall be evacuated to a vacuum pressure of 10 mbar or less to verify dryness. The vacuum pressure shall be held for 10 minutes.

Applicability:

All TN 32 casks Actions Conditions Required Action Completion Time Cask cannot hold vacuum for

1. Check and repair the Prior to required time period.

vacuum drying system, as movement to necessary.

ISFSI.

2. Check or verify that water is drained from cask.

3. Check and repair the cask seals, as necessary.

4. Verify that the limit is met.

5. If the limit cannot be met, retum the cask to the spent fuel pool, remove the fuel assemblies from the cask, and retum them to the spent fuel storage pool.

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E-15846 9/97 Surveillance Requirements Surveillance Frequency Prior to moving a loaded cask to the Once, prior to movement of cask to storage pad, the helium pressure shall be ISFSI.

measured to ensure it is within the pressure range.

1.6 Handling Height Limitations Limiting Condition of Operation:

The maximum lifting height of a cask outside of the containment building using a non-redundant lifting device shall be 18 inches or less.

Applicability:

All TN 32 casks Actions:

Conditions Required Action Completion Time Maximum cask lifting height of 18

1. Stop transfer activities 1.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, inches is exceeded, and lower to below 18 inches.

2. Prior to next

2. Evaluate why cask lift height was exceeded.

hask transfer to Surveillance Requirements Surveillance Frequency Transport equipment shall be designed to Adequacy of lift height limit shall be ensure that the maximum lift height is not verified by functional testing prior to first exceeded.

use of transporter.

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E-15846 9/97 1.7 Spent Fuel Pool Boron Concentration Limiting Condition of Operation:

The dissolved boron concentration of the water in the spent fuel pool and of the water added to the cavity of a loaded cask shall be no less than 2000 ppm. This limiting condition ensures that k.n < 0.95 during fuel loading and unloading.

Applicability:

All TN 32 casks.

Actions Conditions Required Action Completion Time During loading / unloading activities

1. If the limit is not met 1.N/A boron concentration falls below before the beginning of 2000 ppm.

cask loading operations, do not load the fuelinto the cask.

2. If the limit is not met

2. N/A before beginning cask unloading operations, do not add water to the cask cavity and do not place the cask into the spent fuel pool.

3. If the limit is not met during fuel loading,

3. Immediately suspend loading operations upon discovery of and restore the dissolved low boron boron concentration to meet concentration, the specified limit.

4. If the limit is not met

4. N/A.

during spent fuel unloading, continue unloading operations and restore the dissolved boron concentration to meet the specified limit.

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e c

E-15846 9/97 Surveillance Requirements o

Surveillance Frequency

1. Verify boron concentration levels prior

1. Once within four hours before to star 1 of cask loading activities, inserting the first fuel assembly into the ask

2. Verify that the dissolved boron concentration of the water in the spent

2. Once within four hours before flooding fuel pool and the water to be added to the cask cavity for fuel unloading, the cask cavity meets the specified limit.

3. Once every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> during fuel

3. Reverify that the dissolved boron loading and unloading.

concentration meets the specified limit during fuelloading and unloading operations.

2.0 Operating Controls during Fuel Storage The following operating controls are imposed during fuel storage at the ISFSI.

2.1 Pressure Monitoring The interspace between the inner and outer seals shall be monitored.

Applicability:

All TN 32 casks once installed at the ISFSI.

Action Conditions Required Actions Completion Time The reference pressure between

1. Investigate reason for 1.1 week.

the closure seals indicates a pressure reduction.

pressure below the set point.

Periorm a snoop test to determine if leak is in overpressure system. If leak is in overpressure system, repair or replace system.

2. If reference pressure 2.1 week.

indicates a loss of pressure and sealleakage, retum the cask to the decontamination building and repan or replace the seals, as necessary, to retum the cask to proper operation.

7 k

l

E-15846 9/97

. Surveillance Requirenients Surveillance Frequency Verify that the alarm panel status Daily indicators for each cask indicate satisfactory closure seal operation.

2.2 Pressure Monitoring System The pressure monitoring system shall be operable and shall monitor each cask loaded with fuel at the ISFSI.

Applicability:

All TN 32 casks once installed at the ISFSI.

Action:

Conditions Required Actions Completion Time

1. Cask pressure monitoring

1. Check and repair the

1. One week, system is inoperable, system.

Surveillance Requirements Surveillance Frequency Test that the cask pressure monitoring Yearly system is operable and is monitoring each cask loaded with spent fuel at the ISFSI 2.3 Cask Surface Examination The accessible surfaces of each cask shall be free of damage, deterioration and debris.

Applicability:

All TN-32 casks once installed at the ISFSI.

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E 15846 9/97 Action:

Conditions Required Actions Completion Time Siginificant damage, deterioration Remove debris, repaint

1. One month.

or debris accumulation to the cask surfaces or repair damage exterior surface such that the cask to retum the cask to proper function is impaired.

operation.

Surveillance Requirements Surveillance Frequency Visual examination of all casks at the Quarterly.

ISFSI to determine that no significant damage or deterioration of the exterior of the casks has occurred and that no significant accumulation of debris on the cask surfaces has occurred.

9 l