ML20217H255
| ML20217H255 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20217H239 | List: |
| References | |
| 50-309-97-09, 50-309-97-9, NUDOCS 9804030232 | |
| Download: ML20217H255 (24) | |
See also: IR 05000309/1997009
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!' U. S. NUCLEAR REGULATORY COMMISSION
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REGION I
Docket No: 50-309
License No: DPR-36
Report No: 50-309S 7-09
Licensee: Maine Yankee Atomic Power Company (MYAPC)
Facility: Maine Yankee Atomic Power Station
Location: Bailey Point
Wiscasset, Maine
Dates: December 8,1997 to March 7,1998
Inspectors: Richard Rasmussen, Senior Resident inspector, DNMS
INillia.a Raymond, Senior Resident inspector, DNMS
Ronald Burrows, Project Manager, NRR
Mark Roberts, Senior Health Physics, DNMS
Todd Jackson, Health Physics, DNMS
Randy Ragland, Radiation Specialist, DRS
Approved by: Ronald Bellamy, Chief
Decommissioning and Laboratory Branch
Division of Nuclear Materials Safety
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9804030232 980326
PDR ADOCK 05000309
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EXECUTIVE SUMMARY
Maine Yankee Atomic Power Company i
NRC inspection Report 50-?OW97 09
This integrated inspection included aspects of licensee operations, engineering, maintenance,
and plant support. The report covers a three-month period of resident inspection; in addition, it
includes the results of announced inspections by regional health physics specialists.
Operations
Operators remained focused on safe operation of the spent fuel pool cooling systems. !
Additionally, manipulations of plant systems for the primary system decontamination effort were
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well performed.
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A loss of offsite power was handled appropriately by station personnel. Operations and security -
promptly responded to tne loss of systems. The corrective action system was effectively ut;lized
to identify problems and implement corrective actions.
The Spent Fuel Safety Management Program was a useful tool for operators to assure basic
equipment requirements were met. The program was being appropriately implemented and
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operators were knowledgeable of the program requirements
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Maintenance
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Poor worker practices which resulted in a rag being left in a pump recirculation line, and the
tripping of an electrical circuit breaker due to a short circuit, are violations of Maine Yankee work
control procedures. However, these violations are not being cited in accordance with section
Vll.B.1 of the NRC enforcement policy. Although these are further examples of poor worker
performance, corrective actions were still being develope, and implemented by Maine Yankee
due to similar issues earlier in the period. These licensee-identified violations were promptly
addressed by Maine Yankee and were not considered willful. NCV 50 4 09/97 09 01
Evolutions ossociated with the removal of the reactor vessel head demonstrated several ;
instances of poor worker performance and inadequate supervision at the job site. Although the
corrective actions addressed the short term performance issues, they lacked substantial actions '
to assure long term performance standards are met. VIO 80409f97-09-02
Three examples of contractors failing to follow appropriate radiological control procedures
indicate a lack of focus in this area. Additionally, the fact that two of these issues were NRC :
identified indicates a lack of Maine Yankee oversight of contractors. These three examples of
failing to follow radiological control procedures are a violation of NRC requirements.
VIO 80-309f97 0943 1
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Engineering
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I The design change packerje for the spent fuel pool island project thoroughly documented the !
j design basis considerations for the new spent fuel pool island. NRC evaluation of the Maine j
l Yankee system classification p;ccedure was ongoing. i
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i Plant Sucoort
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L Planning and implementation of radiological controls for system chemical decontamination were
very good as evidenced by thorough and detailed ALARA reviews, close health physics
oversight, and subetantive and sound radiological controls.
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The site charactenzation process was being conducted in accordance with the Maine Yankee
plan. Sampling and laboratory techniques were appropriate and sample results correlated with
results from the NRC laboratory.
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Radiological boundaries including radiation areas, high radiation areas, and contaminated areas
were well defined and maintained, and overall conditions of housekeeping were good with some
exceptions in containment and the radiological control area (RCA) building. ,
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The Maine Yankee Low Level Waste and Equipment Temporary Storage Building was
inspected and found in good condition. One issue regarding unnecessary fire-retardant treated
I wood stored in the truck bay was promptly corrected.
Based on interviews and a review of procedural guidance, the inspector concluded that the
threshold for entering radiological control issues into the corrective action program was not )
clearly defined.
Based on observations and interviews, the inspector concluded the methods and procedures for
collecting and analyzing soil samples were adequate to enable generation of high-quality data
for site characterization. !
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!* TABLE OF CONTENTS
TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
1. Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01. Conduct of 0perations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
01.1 General Comments (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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01.2 Maine Yankee Manaaement Chanaes . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
l O2 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . 1
l O2.1 Loss of Offsete Power .......................................1
l' 03 Operations Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
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03.1 Soent Fuel Safety Manaaement Proaram . . . . . . . . . . . . . . . . . . . . . . . . 2
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11. Mai ntenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 j
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M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 i
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M1.1 Worker Performance lasues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
M4 Maintenance Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . 4
M4.1 Reactor Preparations for System DecontaminMon . . . . . . . . . . . . . . . . . 4
M4.2 Insseicoriate Radioloaical Practices Durina Maintenance . . . . . . . . . . . . 5
l 111. Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . 7
E2.1 Soent Fuel Pool Island Develooment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
IV. Plant Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . . . . 8 I
R1.1 Radioloaical Plannina and Preoaration for Chemical Decontamination . . 8 l
R2 Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
l R2.1 Site Character'zation Update . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
R2.2 Evaluation of RM!olmim! Control Practices . . . . . . . . . . . . . . . . . . . . . 13
R2.3 Insoection of the Low Level Waste and Eauioment Temoorary Storaae
l Build i na . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
! R7 Quality Assurance in RP&C Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
R8 Miscellaneous RP&C issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 l
R8.1 Closed URl 96-16-31 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
R8.2 Site Characterization Samole Collection and Analysis . . . . . . . . . . . . . . 16 l
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V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 l
X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
X3 Management Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 :
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PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
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LIST OF ACRONYMS USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
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Report Details
Summary of Plant Statug
During this inspection period, the major site activities included; site characterization, primary
system decontamination, and construction of the spent fuel pool island. Detailed descriptions of
these activities are contained within this report.
L Operations
01 Conduct of Operations
01.1 General Comments (71707)
Using inspection procedure 71707, the inspectors conducted reviews of ongoing plant
operations. Operators remained focused on safe operation of the spent fuel pool cooling
systems. Additionally, manipulations of plant systems for the primary system
decontamination effort were well performed. The system decontamination effort, which
was primarily performed by contractors, required significant tagouts and valve lineups by
operations to establish the required plant configurations.
01.2 Maine Yankee Manaoement Chanaas
Maine Yankee announced that as of March 1,1998, Mike Meisner, the current Vice
President for Nuclear Safety and Regulatory Affairs, will assurne the duties of President
of Maine Yankee following the resignation of Michael Sellman. Mr. Sellman accepted
the position of Senior Vice President and Chief Nuclear Officer at Wisconsin Electric
Power Company. Mr. Meisner continues Michael Sellman's duties as President under
the provisions of a contract for management services between Maine Yankee and
Energy Nuclear Inc.
O2 Operational Status of Facilities and Equipment
O2.1 Loss of Offsite Power
a. Inspection Scooe (71707)
The !nspector reviewed Maine Yankee's response to a loss of offsite power. Condition
report 98-43, which documented the event, was also reviewed
b. Observations and Findinas
On February 18,1998, at 7:00 pm, the site lost all offsite power due to an external fault
on the 115 kV grid. Although no longer required, Maine Yankee had the emergency
diesel generators (EDGs) in standby. The EDGs started and loaded as expected.
Offsite power was available after two minutes. Approximately six hours later, on
February 19,1998, at 12:59 am, another loss of power occurred. This time the offsite
power was unavailable for six minutes.
During both of these loss of power events, operators appropriately responded. Cooling
to the spent fuel poo! was promptly restored in each case. Maine Yankee was
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evaluating the cause of the power loss, which was believed to be related to protective l
relays on the distribution system extemal to the plant.
During these events, several equipment problems were identified. The most significant
l of these was the failure of a security system backup power supply. Compensatory :
l measures were established by the security force during the periods the security systems ;
l were unavailable. The equipment problems were documented in a condition report and l
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entered into the work control system with the appropriate priorities.
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l The security system backup power supply failure was found to be a faulty battery in a
bank of eight batteries used in the backup power supply. Based on this failure, Maine
Yankee was replacing all of the batteries and increasing the surveillance test frequency
- from annualto quarterly.
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c. Conclusions
l The loss of offsite power was handled appropriately by station personnel. Operations l
and security promptly responded to the loss of systems. The corrective action system 4
vcss effectively utilized to identify problems and implement corrective actions.
! 03 Operations Procedures and Documentation
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03.1 Soent Fuel Safety Manaoement Proaram
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a. Inspection Scooe (71707)
l Maine Yankee instituted the Spent Fuel Safety Management Program to identify and
manage systems that are desired to be maintained to assure safety analysis report and
technical specification requirements are met. The inspector reviewed the program
l requirements and implementation.
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b. Observations and Findings
l The Spent Fuel Safety Management Program replaced the Outage Risk Management I
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Program that was previously being used. The program defined safety functions, listed
safety systein requirements, and provided guidance on equipment outage times and ,
! requirements for deviating from the requirements. The program was formatted similar to i
technical specifications with requirements and exceptions clearly stated. Deviations
from the requirements and exceptions require detailed contingency plans to be
developed. The three system requirements addressed by the program were spent fuel ,
l pool cooling, spent fuel pool make up, and power availability. !
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i Through interviews, it was concluded diat operators were knowledgeable of the new
l program. Two contingency plans developed during the inspection period were reviewed.
One plan addressed maintenance problems on one of the primary component cooling
water pumps and the other plan was developed as a contingency for a heavy cask lift
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that had the potential to affect power to both of the spent fuel pool cooling pumps. The
contingency plans addressed the requirements of the program and contained
reasonable actions. ,
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c. Conclusions
I The Spent Fuel Safety Management Program was a useful tool for operators to assure
basic equipment requirements were met. The program was being appropriately
implemented and operators were knc;is;+able of the program requirements.
IL Maintenance
!- M1 Conduct of Maintenance
M1.1 Worker Performance issues l
a. Inspection Scope (40801)
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The inspector reviewed condition reports for two issues involving inadequate worker
performance.
b. Observatioris and Findinos
On February 25,1998, Maine Yankee experienced the failure of a non-safety primary
i water pump. The pump failed due to high bearing temperatures. In evaluating this .
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failure, Maine Yankee determined that the increased bearing temperatures were partially ,
caused by a rag that was plugging the pump recirculation line. The rag was left after i
! work activities that opened the line for site characterization surveys.
On February 26,1998, an electrical contractor shorted a live wire in a non-safety lighting
panel while performing an inspection of the panel. The worker was using a non- ,
l insulated tool to pry wires for inspection. The short circuit caused the panel circuit !
breaker to trip. I
Both of these examples were formally addressed by the Maine Yankee corrective action
program. In the case of the electrical safety issue, electrical work by the contract group
' involved was suspended pending the evaluation and corrective acbons. In the case of
the rag in the recirculation line, Maine Yankee evaluated other work that was performed ;
that could have resulted in rags in pipes; Of particular concern was work on the fire
protection systems. As a result, Maine Yankee tested 12 flow paths that did not have
quality control oversight during closure. No further problems were identified.
c. Conclusions
Poor worker prachces which resulted in a rag being left in a pump recirculation line, and i
the tripping of an electrical circuit breaker due to a short circuit, are violations of Maine l
l Yankee work control procedures. However, these licensee-identified ar.d corrected l
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violations are being treated as a Non-Cited Violation consistent with soebon Vll.B.1 of ,
the NRC Enforcement Policy. Although these are further examples of poor worker l
performance, corrective actions were still being developed and implemented by Maine
i- Yankee due to similar issues earlier in the period. These licensee-identificci violations '
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were promptly addressed by Maine Yankee and were not considered willful.
NCV 50-309/97 09-01
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M4 Maintenance Staff Knowledge and Performance
M4.1 Reactor Preoarations for System Deconteminetion
a. Inspection Scoce (62707)
Maine Yankee was removing the reactor head, upper intomals, and core support barrel
in preparation for the primary system decontamination project. The inspector reviewed
the procedures and observed portions of the work activities.
b. Observations and Rndings
On January 5,1998, the maintenance staff began the evolutions to prepare the reactor
for the system decontamination project. This sequence of activites was classified as an
infrequently performed evolution. The first step of the sequence was a retest of the
reactor cavity seal to assure the cavity seal would function when the cavity was flooded.
During the performance of the cavity seal test, a number of deficiencies were noted. All
but one of the deficiencies was identified by the NRC Inspector.
A Maine Yankee quality control (QC) inspector identified that a procedure
prerequisite which required the test rig gauges to be calibrated within
three months of the test was impropedy signed off. The mechanic who
signed for the calibration based his signature on a one-year requirement
and did not note the thme-month requirement stated in the procedure.
A health physics technician was performing activities leaning over the
edge of the cavity without fall protection.
A mechanic assigned to remove the gauges and relief valve from the test
rig was not knowledgeable of the rig and was not adequately supervised.
During this period the lead mechanic who had supervisory oversight
responsibility for the evolution was operating the containment polar crane.
During the test, the test procedure was not reahtep-by-step by the
mechanic and the procedure was not performed properiy. Key steps
related to isolating the pressure source prior to performing the air drop
test were not performed. After questioning by the inspector the test was
redone satisfactorily following the procedure. However, it was noted that
the mechanic and QC inspector did not stop to inform their management
of the error prior to continuing.
QC oversight of the test did not identify that the leak test procedure was
not being performed properly. Additionally, QC did not correct the
mechanic for not using the procedure during the test.
As a result of these deficiencies, Maine Yankee stopped the evolution and performed a
barrier screening evaluation. The barrier screening identified several problems, and
corrective actions were applied. In the cases of poor worker performance, corrective
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actions included counseling involved workers and briefing of other personnel. The lack
of adequate oversight of the evolution was addressed by assigning an additional crane
operator to free the lead mechanic of this responsibility and by assigning the mechanical
l maintenance supervisor to act as a coach for the lead mechanic.
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The Maine Yankee assessment of the QC oversight concluded that the QC inspector did
not meet the expectations for oversight of the evolution. The QC inspector performed
the minimum inspection stated in the procedure by only observing the pressure drop at
the end of the test and not observing other key attributes of the test. This poor
performance was contrasted by the discovery of the gauge calibration issue identified
earlier in the day which was not a specific QC hold point. The management
expectations for QC oversight in the field were reiterated to the inspector and the
remainder of the QC personnel. Additionally, QC performed a review of remaining
l activities associated with the reactor disassembly to assure the QC hold points were
adequate to focus the inspectors on the areas of concem.
Following the implementation of the corrective actions the remainder of the reactor
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disassembly evolutions were performed without any problems. The pre-evolution
i briefings and supervisory oversight were improved during the remainder of the
6Volutions.
c. Conclusions
This evolution demonstrated several instances of poor worker performance and
inadequate supervision at the job site. Although the corrective actions addressed the
short term performance issues, they lacked substantial actions to assure long term
performance standards are met.
The failure to follow procedures is a violation of NRC requirements. Specifically, Maine
Yankee Procedure 5-58-1, Cavity Seal Ring Installation, steps 5.3.1.f and g required the
air regulator outlet valve and the test device relief valve isolation valve to be closed.
Contrary to the above, On January 5,1N, the air regulator outlet valve and the test
device relief valve isolation valve were t.ot closed as specified by the procedure. The
omission of these procedure steps left the air source aligned to the test rig during the air
drop test. Leakage of air from the air source could have affected the results of the test.
VIO 50-309/97-0942
M4.2 Inaooropriate Radioloalcal Practices Durina Maintenance
a. Inspecson Scope (62801)
The inspector observed maintenance activities within the radiologically controlled area.
These maintenance activities involved deficiencies in contamination control practices. ;
The inspector reviewed the subsequent condition reporto. l
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b. Observations and Findinas
On January 26,1998, workers were installing radiologically clean equipment on an i
instrument rack that was built on the boundary of an area that was posted as
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contaminated. The reason for the radiological posting was the contamination present in
a trench in the floor along the wall. The entire area from the start of the trench up to and
including the wall was posted as contaminated. The postirvj was accomplished by a
strip of tape on the floor and a sign in the middle of the area. Workers were reaching
l across the contamination boundary without appropriate anti-contamination clothing or
controls.
Condition report (CR) 99-22, was issued to document this issue. The CR was' assigned
an evaluation level B, which required a barrier screen evaluation and corrective actions.
In response to this issue, the area was resurveyed and the boundary was reduced to
only the trench. Health physics personnel determined that no spread of contamination
i occurred. Corrective actions consisted of briefing workers and health physics
, technicians.
- On January 27,1998, a similar example was identified by Maine Yankee. A worker
exiting containment reached across the contaminated area boundary to retneve some
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papers without the required protective clothing. Condition report 98-25, was wntten to l
document this issue.
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On February 5,1998, workers removed the top of spent fuel pool cooling system check
valve, FP-12, to allow access for site characterization surveys Due to minor boundary
valve leakage, a catch bag was set up to catch water that was leaking out of the system.
However, the workers left the area unattended and water was filling up the catch bag.
Tho catch bag, which was installed with tape, had collected several gallons of water and
was starting to pull free when workers were called to the area to drain the bag.
Additionally, while trying to dra!n the valve cavity of residual water, a' worker was
observed not following radiological procedures by removing his hands from the intemals
of FP-12, a contaminated area, without removing his gloves. Condition report 98-37,
was issued to document these ist,ues.
It was noted that each of these examples involved contractor personnel. Technical .
specification 5.11.1, requires in part that procedures for personnel radiation protection l
shall be prepared. Procedure 9-5-100, Contamination Control / Decontamination !
Program, provides specific requirements. Section 7.3.1, requires that personnel shall l
not reach into contaminated areas except as specifically authonzed. Section 4.15.1.1,
requires personnel to comply with specific radiation protection instructions regarding
contamination controls. Radiation Protection Guideline (RPG)-002, Working Across
Contaminated Area Boundaries, provides instructions that require gloves to be changed
whenever removing hands from the contaminated area. Contrary to the above, the
previous three examples of failures to comply with procedure 9-5-100 were observed.
These are a violation of NRC requirements VIO 50-309/97 09-03
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c. Conclusions j
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Three examples of contractors failing to follow appropriate radiological control .
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procedures indicate a lack of focus in this area. Additionally, the fact that two of these
issues were NRC identified indicates a lack of Maine Yankee oversight of contractors.
These three examples of failing to follow radiological control procedures are a violation
of NRC requirements.
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E2 Engineering Support of Facilities and Equipment
E2.1 Soent Fuel PoolIsland Develooment
a. Inspection Scope (37801)
The inspector reviewed design modifications in support of the sont fuel pool island
project.
b. Observations and Findinas
The spent fuel pool island (SFPI) was being developed to provide long term wet storage
and cooling of the spent fuel. The island concept uses the existing spent fuel pool and
some of the existing systems within the pool. New systems include the ultimate heat
sink, which will be air coolers; the electrical supply and distribution systems; the control
room and instrumentation; security systems; and the backup power supply.
Design change package 97-42, Spent Fuel Pool isolation, documented the design basis
and design considerations for the new systems. One issue related to this project is the
classification of the systems under 10 CFR 50, Appendix B, Quality Assurance for
Nuclear Power Plants. Maine Yankee developed procedure 0-02-1, Classifications of
Systems, Structures, and Components, to describe the critelia used to determine the
classification of remaining systems NRC review of the Maine Yankee system
classification process was ongoing.
Construction of the new facilities started during this inspection period. Construction of
the new control room, installation of new spent fuel pool instrumentation, installation of
electrical supply and distribution components, and construction of a shelter for the new
air coolers were the major projects. Construction and testing of the SFPI is expected to ;
be completed early this summer, j
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c. Conclusions
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The design change package for the spent fuel pool island project thoroughly
documented the design basis considerations for the new spent fuel pool island. NRC
evaluation of the Maine Yankee system classification procedure was ongoing.
l LE Plant Support
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R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 Radiolonical Plannina and Preparation for Chemical Decontamination
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s. Inspection Scope
A review was performed of planning, preparation, and implementation of radiological
controls for system chemical decontamination for decommissioning. Specific areas
reviewed included procedural controls and evaluations to maintain radiation exposures
as-low-as-is-reasonably-achievable (ALARA), and radiological controls for various
evolutions including filter changeouts, resin sluicing, and waste transfers.
b. Observations and Findings
Chemical Decontamination Overview
in order to minimize radiation exposures during decommissioning, Maine Yankee
contracted with PN Services to plan and petform an aggressive chemical
decontamination of various reactor water systems. The planning, preparat on, and
implementation of the chemical decontamination of the reactor coolant system and
related systems were reviewed. The licensee made a presentation to the NRC on
January 28,1998, to describe the process and the Maine Yankee project approach. The
active process chemicals were designed to dissolve corrosion deposits and move
contamination from the piping surfaces onto ion exchange resins for cAsposal.
The process was planned for completion in two sequential phases, the first phase
beginning on February 14,1998 and the second phase beginning immediately after
completion of the first phase. The first phase included charging, pressurizer spray,
letdown, high pressure safety injection, low pressure safety injection, seal water retum,
and loop drain and fill systems. The second phase included the reactor coolant system,
loop drain and fil!, and residual heat removal systems. The reactor vessel and steam
generator tubing were not included in the scope of the decontamination. The reactor
vessel was bypassed by installing a large, star-shaped, pipe-plugging assembly that
bridged flow from each nozzle penetration across the reactor vessel between coolant
loops. The objective of the process was to achieve an average decontamination factor l
of approximately 100, to be determined by the average contact exposure rate
measurements made at defined points in the systems. The decontamination factor was
defined as the exposure rate measured prior to system decontamination divided by the
post-decontamination exposure rate at the same point. j
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A skid-mounted chemical injection, circulation, and heating system was set up near the
equipment hatch, and chemicals were injected into the reactor cooling system (RCS)
through temporary adapter plates installed on the steam generator manways. The
chemical decontamination process involved fluoroboric acid injection to dissolve iron and
nickel oxides, on-line ion exchange, the addition of potassium permanganate to dissolve
chrome oxides and precipitate manganese dioxide, followed by the addition of oxalic
acid to dissolve manganese dioxide and on-line ion exchange to remove cations. This
process was repeated multiple times to maximize effectiveness.
Preoarations and Manaaement Controls
The inspector reviewed the status of the preparations during the week of
February 9 - 13,1998 to verify management controls were in place to conduct the
decontamination. The inspector met with the decontamination project manager to
review the status of planning and readiness. The licensee controlled the
decontamination per procedure 0-06-9, infrequently Performed Tests and Evolutions.
Responsibilities were defined, communications were established, and measures needed
to assure compliance with the safety analyses were established and maintained. A
punch list was established with the appropriate items being tracked. The licensee used
mockup training as needed in the preparations for the conduct of the evolution (e.g.,
installation of steam generator manway covers with jumpers).
The inspector conducted a review to verify the procedures were adequate to compete
the process. The review included a field walkdown of vendor procedure OP-2470-1,
Maine Yankee Decontamination Off-Normal Procedure and Maine Yankee operations
procedure 4-1-71, Primary System Decontamination. The procedure controls included:
draining borated water from the system, filling and venting the systems for
decontamination, establishing and controlling the system isolation boundaries (via
procedure and tagout controls), conducting the baseline system radiological surveys,
injection of decontamination chemicals, and monitoring the progress of the
decontamination. Procedures were adequate to conduct the evolution.
The licensee established methods to prevent spill of chemicals, as part of the lessons
leamed from the industry experiences. The licensee credited the use of all stainless
steel piping within the treated boundary. The inspector verified this was accomplished
by a sampling review of the decontamination boundary using drawir.gs i 1550-FM-90A,
91 A,92A, and the Piping Specification MYS 442 Rev B. The licensee reviewed the RCP
seals and noted that there were no compatibility problems with the decontamination
solution. The pump seals were adjusted to minimize intemal clearances within the seal.
The seal leakoff piping was modified so that leakage would be directed to drums and
piped back into the system Although this contingency was in place, a maximum
allowable leakage rate had not been determined as it had for other types of leaks. The
inspector completed a field walkdown of the skid and associated plant system hookups
to assure connections appeared strong and tight. The inspector attended a pre-job brief
of the operations crew on February 10 which described the process and the coordination
between Maine Yankee and vendor personnel.
The inspector reviewed the licensee calculation in support of the safety evaluation to
evaluate the impact on containment pressure of a postulated resin fire inside the
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containment during a resin transfer to a high-integrity container (HIC). The assumptions
and methodologies used in OA calculation RPJ-98-005 were reasonable and supported
the conclusion that a resin fire would result in a 0.2% increase in containment pressure,
and thereby have minimal impact on the approach to seal the equipment hatch. During
a meeting with the Operations Director on February 12, the inspector stated that the
calculation satisfied the commitment to the NRC made during the January 28,1998
meeting at Region 1.
In summary, the licensee was prepared to conduct the RCS decontamination, and the
combination of procedures, equipment readiness, and management controls were good. ,
Communications and coordination were good. Vendor representatives were '
experienced and very knowledgeable of the decontamination equipment and process.
6_LARA Reviews
ALARA review AR-98-02, ' System Chemical Decontamination," provided overall
guidance for the implementation of radiological controls for the project. The review
included identification of extemal dose sources; lessons learned from previous chemical
decontaminations including industry experience; methods for minimizing radiation
exposure (time, distance, and shielding); engineering controls; work scheduling and
administrative controls; requirements for pre-job briefings; contamination control and
radwaste considerations; and contingency plans for spills and equipment problems. The
review was thorough, well detailed, and included substantive and sound radiological
controls.
The insraector met with the ALARA planning engineer to discuss the rationale behind i
survey points and how these points will be used for planning purposes and
decontamination effectiveness. The inspection verified that ALARA goals were
established for major evolutions of the process. The licensee used various systems to
keep radiation exposure to personnel to a minimum. These included video cameras to
view gauges end fittings and remote dosimetry (teledosimetry). In addition, the
containment was controlled as a locked high-radiation area during the process, and
work not directly related was postponed. ;
During the decontamination evolution, the inspector observed several control room shift
tumover meetings providing technical briefings to oncoming shift personnel. Briefings
were thorough and alerted shift personnel to current status, current concems, issues
warranting special attention, and the names of contractor and licensee personnel on the
shift responsible for specific aspects of the project. Personnel were alerted to watch for
leaks, with vendor personnel performing hourly quick walkdowns to look at sumps in
containment. About two times per 12-hour shift, personnel also walked down accessible
piping and observed drainage trenches leading into the sumps, in order to determine if
there was observable leakage flow. During the evolution, two minor leaks at mechanical
fittings were identified. The leaks were inside the containment building and were
handled within the secpe of the contingency plans. No spread of contamination
occurred.
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Filter Chanae-out
Filters on the decontamination process skid had the potential for loading with signifmant
radioactivity, and presented a radiological challenge for filter change-out. The filter
change out process involved setting up contamination controls, transferring cylindrical
filters by hand from the filter housing to a HIC, removal of the HlO from the work area,
and installation of new filters. The inspectors reviewed the licensee's ALARA analysis of
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the filter change task, which provided the basis for the licensee's conclusion that manual
replacement was better than using remote handling tools. Radiation dose estimates and
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ALARA controls were based on exponence gained during the previous Maine Yankee
RCS decontamination performed in 1995. Radiological controls included requirements
for radiological surveys, use of plastic coverings, prejob briefinga using a video from the
1995 filter change-out, and contingencies for spills'and equipment problems. Under the
worst-case radiological conditions, a maximum personnel dose of 550 mrom to the
extremities (bands and fingers) and 127 mrem whole body could be produced. At the
end of the first phase the filters had an estimated contact exposure rate of 7 R/h, which
had decreased from a peak of 19 R/h. The filter change-out process was well-planned,
and included good contamination controls and health physics planning. The first two
filter change-out events yielded whole body doses of 17 and 70 mrom, respectively.
Resin Sluicina to a Hiah Intearity Container
The ion-exchange system was designed to remove dissolved radionuclides, rnetal .
corrosion products, and solvent chemicals by passing decontamination solutions through
lon-exchange columns. The system included six cation, two anion, and one mixed-bed
resin columns. Licensee staff predicted that exposure rates as high as 300 R/h could
accumulate on the cation resin bed. Consequently, the transfer or sluicing of resin from
ion-exchange resin columns to a HIC presented a significant radiological challenge.
Procedural controls for resin sluicing were contained in procedure SP-2470-2, " Resin
Sluice-out Procedure," and radiological controls were outlined in ALARA review
AR-98-02, " System Chemical Decontamination." Controls ' included step sign-offs, multi-
discipline group involvement, pre-job briefings with key individuals, and a requirement to
check resin transfer hoses for tightness and to tie-wrap camlock levers. Procedural and
ALARA controls were designed to ensure close oversight, prevent accidental spillage,
and minimize personnel exposure.
HIC Transfer to the Low Level Waste Storaae Buildina
The inspector interviewed the radweste supervisor and discussed planned methods for
transferring packaged resin HICs to the low-level waste and equipment temporary
storage building (LLWETSB). Licensee staff planned to use routine methods to transfer
resin HlCs to the LLWETSB, which included transporting the HIC to the LLWETSB in a
j shielded transport cask, staging health physics personnel for access control, and
transfer of the HIC to a concrete overpack. Radiological controls appeared sufficient to
prevent a resin spill, minimize radiation exposures, and to restrict personnel access
during HIC transport. The HIC transport evolutions were conducted without incident.
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Health Physics Controls
Due to the potent;al for changing exposure rates during chemical decontamination, the
entire containment was controlled es a Technical Specification 5.12, locked
high-radiation area. Personnel entsring containment were required to have a legitimate
. reason for entering, sign onto a radiation work permit, wear a personal alarming
dosimeter, receive a health physics briefing, and have the personnel hatch gate opened
by a health physics technician. Radiological boundaries were well delineated and
clearly posted. Health physics personnel controlling access to containment were
thoroughly familiar with radiological conditions and radiological controls associated with
chemical decontamination activibes.
Cent.;rimer,t Air Flow
During entries into the containment building, inspectors observed a hanging ribbon
located at the containment personnel hatch. The movement of the ribbon indicated that
the flow of air at the containment personnel hatch was from the containment building
(contaminated area) to the spray building (clean area). Although air in the spray building
is monitored prior to release, it is considered a poor practice to allow eir to flow from a
contaminated area to a clean area.- Prior to commencement of the second phase of the
project, the air flow indication showed that the flow of air was into the containment
building.
c. Conclusign *
Planning and implementation of radiological controls for chemical system
decontamination were very good as evidenced by thorough and detailed Al. ARA
revews, close health physics oversight, M rubstantive and sound radiological controls.
R2 Status of RP&C Facilities and Eolprear.t
R2.1 Site Characterizabon Uodatg
a. Inspection Scope (71801)
The inspector reviewed the status of the Maine Yankee site characterization process
and performed observations of select field activities.
b. Observations and Findinas
The site characterization was being performed as a prerequisite for site
decommissioning. Because the characterization will be used by contractors bidding for l
the decommissioning project, Maine Yankee requested interested contractors to
participate in the characterization process by observing the project and making
suggestions as to the scope of the project.
The characterization included surveys and samples from the environment, structures,
and systems. The charactenzation included both radiological and hazardous materials
sampling. J
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The NRC review of the site characterization has primarily focused on the radiological
surveys of the environment. Preliminary results have identified five areas with elevated
readings of plant-related activity. These areas are described below-
A small area on Bailey Point, just outside of the plant fence, had a !
reading of 30 micro-roentgens / hour at a distance of one meter. Maine
Yankee remediated the area by removing approximately one cubic meter
of soil.
A scan of a parking lot near the warehouse identified a small particle ,
reading 40 micro-roentgens / hour at a distance of one meter. The area !
was remediated by removing the particle and the sampling scope was
expanded in the area. No further activity was identified.
Three soil samples had elevated readings of plant-related isotopes. One
soil sample taken south of the security fence near the forebay had 0.4
picocuries/ gram Co-60 and 27 picoeuries/ gram Cs-137. One soil sample
taken near the road to Foxbird Island had 0.2 picoeuries/ gram Co-60.
One sediment sample taken in the discharge water forebay had 11
picocuries/ gram Co-60 in the upper three inches of sediment, and 5
picocuries/ gram Co-60 in the lower three inches of a six-inch sample.
None of the sample results indicate an immediate radiological concem and are being
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included in the site decommissioning effort.
In addition to observing site characterization activities, reviewing procedures and
observing sample preparation and counting, the NRC took independent soil samples at
severallocations on the owner-controlled property. The results of ten soil samples
indicated a positive correletion between the on-site laboratory and the NRC laboratory
located at the NRC Region I office in Pennsylvania. Because none of the samples had
elevated levels of Co-60, the levels of Cs-137 and K-40, which are present in all soil
samples, were used to compare the results. Two other samples were somewhat
divergent and efforts were ongoing to evaluate the discrepancy. Because the samples
were independent samples and not controlled split samples, some divergence was
expected. The review of soil sampling was ongoing.
c. Conclusions
The site characterization process was being conducted in accordance with the Maine
Yankee Plan. Sampling and laboratory techniques were appropriate and the majority of
the sample results correlated with results from the NRC laboratory. The review of soil
sampling is ongoing.
R2.2 Evaluation of Radiolooical Control Practices
a. Inspection Scope (83750)
The inspector performed an evaluation of radiological control boundaries and
housekeeping. Information was gathered through tours of the primary auxiliary building,
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ths vapor containment, the hot machine shop, the radiological control area (RCA) and l
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low specific' activity (LSA) buildings, and the low level waste storage building.
- b. Observabons and Findinas
Radiological boundaries were well delineated with radiological postings, rope, tape, and
! physical barriers. Contaminated area boundaries were well controlled and extension
cords and service lines crossing contaminated area boundaries were well secured. High
radiation areas were clearly posted, and locked high radiation areas were securely
locked and controlled. No discrepancies in radiological boundaries or high radiation
area access controls were identified. In addition, the inspector reviewed radiological
i_ survey data posted near the entrance to the radiologically controlled area and noted that !
l survey data maps were useful for radiological briefings. j
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Overall, housekeeping in restricted areas was good. Walkways and isles were clear and j
no readily identifiable industrial safety concems related to housekeeping were identified. 1
An accumulation of stored materials was identified in some areas of containment and the
RCA building.
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c. Conclusions
Radiological boundaries including radiation areas, high radiation areas, and
contaminated areas were well defined and maintained, and overall conditions of
housekeeping were good with some exceptions in containment and the RCA building.
l R2.3 Insoection of the Low Level Waste and Eauipment Temoorary Storace Buildina
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a. Insoection Scoos /71750)
L The inspector toured the Maine Yankee LLWETSB and reviewed procedures 9 313-16,
l Transfer to and Storage of Radweste and Material in the Low Level Waste and
Equipment Temporary Storage Building, and 9-313-17, Surveillance of the LLWETSB, .
High-Rad Bunker, and LSA Building.
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b. Observations and Findinos l
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l On December 11,1997, the inspector toured the facility. Locks, alarms, and fire
detsction systems associated with the facility were in place and functioning. The facility,
which is normally unmanned, was found in a neat and orderly condition. Containers
used for storage of material in the facility appeared to meet the procedural requirements.
One exception to this was a stack of fire-retardant treated wood that was unnecessarily
stored in the truck bay. The wood was subsequently removed by Maine Yankee. There
were no obvious signs, such as wet spots or stains, to indicate problems with water
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intrusion into the building. l
In response to questions related to possible ignition sources in the LLWETSB, Maine
Yankee revised procedure 9-313-16 to specifically limit vehicles that could be operated j
or stored in the building. The previous revision allowed the operation and storage of !
propane powered lift vehicles in the building. The new revision prohibits the operation of
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other than electric lift vehicles in the LLWETSB. As was previously allowed, trucks will
be allowed in the truck bay for loading and unloading, but may not be stored in the
building.
Procedure 3-313-17 required a monthly surveillance of the LLWETSB. The surveillance ;
consisted of a radiological survey, visualinspections of the building and containers
within the building, and a review of documentation to assure the limit of 7000 curies
within the building was not exceeded. The inspector reviewed the file of completed
surveillances and verified the activities were being conducted.
c. Conclusions
The Maine Yankee Low Level Waste and Equipment Temporary Storage Building was
toured and found in good condition. One issue regarding unnecessaiy fire- retardant
treated wood stored in the truck bay was promptly corrected.
R7 Quality Assurance in RP&C Activities
a. Insoection Scoos (83750)
A review was performed to determine the threshold for entering radiological control
issues into the station corrective action program. Information was gathered by a review
of procedure O-16-1, Rev.12," Corrective Action Program," a selected review of -
condition reports and issues identified in an informal health physics self-assessment
program, and interviews with health physics personnel.
b. Observations and Findinas
The inspector used radiological work permit (RWP) 98-00002 to enter the RCA. The
computerized electronic dosimeter assigned an alarm dose setting of 17 mrem for the
work activity number used; however, note *B" on the written RWP stated, "Each task
under this RWP shall be kept to less than 10 mrom por entry". The inspector pointed out
to the licensee that the written instruction and limitation were not consistent with the
computerized system limitation for the same activity. Ttm licensee investigated,
determined that the discrepancy was an error, and that the two values should be the
same. Other RWPs were reviewed and no additional discrepancies were identified. The
licensee immediately corrected the error, making the computerized limit consistent with ,
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the written note of 10 mrom.
The inspector discussed with the licensee the mechanism to be used to determine what I
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caused the error to occur and how to prevent recurrence. Procadure O-16-1, Corrective
Action Program," provided guidance for initiating a condition report, and provided
examples of issues considered to be significant conditions adverse to quality, conditions
adverse to quality, and other conditions. The inspector noted that criteria for entering an
issue into the condition reporting system were subject to judgement. In addition, during
interviews, health physics personnel reported that there was some confusion as to the
threshold for initiating condition reports and examples included improper protective
clothing removal techniques, inconsistent informat*onal postings, and housekeeping i
deficiencies. The operations health physics supervisor acknowledged that the criteria
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and threshold for initiating a condition report needed to be'more thoroughly
- communicated within the health physics staff.
c.- Conclusions
, Based on interviews and a review of procedural guidance, the inspector concluded that 1
the threshold for entering radiological control issues into the corrective action program
was not clearly defined.
R8 Miscellaneous RP&C lesues
R8.1 - Closed URI 96-16-31. " Greater Than 50% of Personnei Contamination Occurred in
Clean Areas.". This item was opened because in 1996, more than 50 percent (67/127) of
the 127 personnel contaminations were attributed to work in non-contamination control
areas within the radiologically controlled area. The licensee attributed the high
percentage to use of tools with semi-fixed contamination, contamination falling from
overhead areas, and a reluctance of the health physics staff to vigorously challenge
plant personnel to determine root cause when potential human performance issues were
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involved. Subsequent to this observation, the licensee conducted a campaign to
decontaminate stored tools and specific overhead areas. Miscellaneous tools stored in
the radiological machine shop were deconttminated, and many overhead areas were
decontaminated in conjunction with cable spread inspections. In addition, supervisory -
personnel made a greater effort to investigate contaminations assigned to the category
of " work-in-clean-areas" to determine root cause. In 1997, the number of contaminations
attributed to work in clean areas dropped to approximately 25% (55/216). Since mid-
1997, performance has shown that the number of RWP-hours without a personal
> contamination exceeded the established goal of fifteen hundred hours / personal
contamination, and no personal contaminations were assigned to the category of work-
in-clean-areas during the first two months of 1998. This item is closed.
R8.2 Site Charac.teiizedon Samole Collection and Analysis
a. Insoection Scope
The inspectors observed collection of selected soil samples, recording of sample
information related to date, time and location collected, name of collector, sample
number and type. Operation of the contractor lab established to analyze
characterization samples was reviewed
b. Qbservation and Findinos
The inspector reviewed the laboratory operation and sample processing for analysis of
site characterization samples. The licensee's contractor had written procedures for all
activities important to the quality of data produced. All contractor procedures had been
reviewed and approved by the licensee's Plant Operations Review Committee (PORC).
' Samples were stored in a locked facility until removed for processing. Processing
included oven-drying and crushing prior to placing in containers for gamma
spectrometry. Chain-of-custody procedures were in place and used to control the flow of
samples from the point of collection throughout processing and analysis. Analyzed
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samples were being retained in the gamma spectrometry trailer until a location is
identided for long-term archiving. It was planned that all analyzed samples would have a
j chain-of-custody seal on the container prior.to transferring to long-term archive storage.
Quality control procedures for the sampling and analysis of soil samples were typical of
a high-quali ty nuclear power plant laboratory. Two samples were collected at some
locations and processed as dup!! cates. The work plan specified that ten percent cf the
< sample load was subjected to duplicate counts. Some samples were split with the State
j- of Maine. Daily laboratory quality control checks for each gamma detector included
l photopeak, full-width at ha!f-maximum, and efficiency for each of 9 nuclides;
[ energy / channel (calibration slope); and detector background. Daily quality control data
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was charted and tracked. Personnel responsible for analyzing the samples had
significant expedence in gamma spectroscopy and sample handling.
c. Conclusions j
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l Based on observations and interviews, the inspector concluded the methods and )
procedures for collecting and analyzing soil samples were adequate to enable
generation of high quality data for site characterization.
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E ManagementMeedLnna )
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X1 ExM Meeting Summary
The inspectors presented the inspection results to members of the licensee on
' March 17,1998. The licensee acknowledged the findings presented.
X3 Management Meeting Summary
On January 21,1998, Maine Yankee met with the NRC at the NRC headquarters in l
Rockville, Maryland to discuss changes to the security plan.
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On January 28,1998, Maine Yankee met with the NRC at the Region i Office in King of
Prussia, Pennsylvania to discuss the primary system decontamination effort, the spent
fuel pool island, and system reclassification. This meeting was open for public
observs.Jon.
On March 12,1997, the NRC Project Manager and the Chief, Decommissioning and
Laboratory Branch, Region I, presented a decommissioning briefing in Augusta, ME, to
members of the Maine Legislative Joint Standing Committee on Utilities and Energy.
The information presented enabled the Committee to evaluate budget requests from
State agencies involved in the oversight of the Maine Yankee Decommissioning.
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, PARTIAL LIST OF PERSONS CONTACTED
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l Licensee
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M. Meisner, President
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W. Odell, Director of Operations
l- R. Fraser, Director of Engineering
G. Zinke, Director of Regulatory Affairs
M. Ferri, Director of Decommissioning
- W. Ball, Manager of Operations Department
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H. Torberg, Manager of Security
S. Dahlgren, Manager of Site Characterization
l J. Sauger, Manager of Decommissioning
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A. Capristo, Manager of Quality Programs !
J. Mallon, Manager of H.P/ Technical Services !
,
J. McCann, Licensing Section Head
l M. Readcinger, Radwaste Shipping Coordinator
l P. Plante, Principal Engineer
R. Gann, RC Supervisor
P. Dostie, Maine, Nuclear Safety inspector
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INSPECTION PROCEDURES USED
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IP 37551: Onsite Engineering
IP 40500: EffectNeness of Licensee Controls in Identifying, Resolving, and Preventing
Problems -
IP 60705: Preparatton for Refueling
l IP 60710: Refueling ;
l lP 61726: Surveillance Observation
l lP 62707: Maintenance Observation
p. IP 71707: Plant Operations
L IP 71750: Plant Support
L IP 83726: Control of Radioactive Material & Contamination Surveys and Monitoring
i IP 83750: Occupational Radiation Exposure
! IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor
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IP 92901: Followup-Operations
IP 92902: Followup- Maintenance
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IP 92903: Followup- Engineering
IP 92904: Followup- Plant Support
IP 93702: Prompt Onsite Response to Events at Operating Power Reactors
l ITEMS OPENED, CLOSED, AND DISCUSSED
l Opened.
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l 50-309/97-09-01 NOV Poor worker practices not cited in accordance with Section Vll.B.1
l of NRC Enforcement Policy.
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50-309/97-09-02. VIO Contrary to Maine Yankee Procedure 5-58-1, Cavity Seal Ring
Pressurization Test was not properiy performed.
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l 50-309/97-09-03 VIO Contrary to Procedure 9-5-100, three failures of compliance were
l observed.
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Closed.
50-309/96-16-31 URI Contaminations in clean areas (Section R8.1)
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LIST OF ACRONYMS USED
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ALARA As Low As is Reasonably Achievable
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CR Condition Report
EDGs Emergency Diesel Generators
HIC High-integrity Container
LLWETSB Low Level Waste and Equipment Temporary Storage Building
LSA Low Specific Activity
PDR Public Document Room
PORC Plant Operations Review Committee
QC Quality Control
RCA Radiological Control Area
RCS Reactor Cooling System
RP&C Radiological Protection and Chemistry
RWP RadiologicalWork Permit
SFPI Spent Fuel PoolIsland
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