IR 05000309/1997003

Insp Rept 50-309/97-03 on 970316-0426.Violations Noted. Major Areas Inspected:Aspects of Licensee Operations, Engineering,Maintenance & Plant Support

ML20140C699
Person / Time
Site:	Maine Yankee
Issue date:	06/05/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140C683	List: ML20140C679 ML20140C691 ML20140C699
References
50-309-97-03, 50-309-97-3, NUDOCS 9706100030
Download: ML20140C699 (26)

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l U. S. NUCLEAR REGULATORY COMMISSION

REGION I

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Docket No: 50-309 License No: DPR-36  ;

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Report No: 50-309/97-03

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Licensee

Maine Yankee Atomic Power Company (MYAPC)

i Facility: Maine Yankee Atomic Power Station l

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Location: Bailey Point Wiscasset, Maine

Dates: March 16, through April 26,1997 l Inspectors: Jimi Yerokun, Senior Resident !nspector  ;

i Division of Reactor Projects Richard Rasmussen, Resident inspector Division of Reactor Projects Randolph Ragland, Radiation Specialist  ;

Division of Reactor Safety i Approved by: Curtis J. Cowgill, Ill, Chief, Projects Branch No. 5 Division of Reactor Projects

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9706100030 970605 PDR ADOCK 05000309 te O PDR

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EXECUTIVE SUMMARY Maine Yankee Atomic Power Company NRC Inspection Report 50-309/97-03 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a six week period of resident inspection; in addition, it includes the results of an announced inspection by a regional inspector in the area of radiation protection,

Ooerstions l

Plant personnel responded appropriately when it was determined that some safety-related valves had not been tested as required by in-Service Test Program. Operability determinations were timely and well documented and provided an adequate basis for returning the residual heat removal (RHR) system to an operable condition. When an RHR ,

suction valve failed to open during this testing, operators were cautiously monitoring core I temperatures, and were prepared to open the valve manually, if necessary. (Section 01.2)

During the RHR suction valve testing, an inadequate cross-disciplinary review and lack of understanding of the impact of other ongoing surveillance activities, was considered an example of inadequate control of activities resulting in a configuration control problem. A prior example was documented in NRC inspection report 50-309/97-01, which involved a l 1300 gallon spill of RWST water due to operations not understanding the effects of l ongoing pump work on the pressure boundary. (Section 01.2)

Operators generally maintained good safety focus and properly operated the systems needed to maintain the plant in a safe, shutdown condition. The " protected train" program clearly identified components of concern and restricted access into these areas, providing an additional level of control for this equipment. (Section 02.1)

Instances of weak operator performance continued to occur as demonstrated during the baseline testing of a containment spray (CS) pump and during residual heat removal (RHR)

suction valve testing. As a result of inattention to detail, an operator started a low pressure safety injection pump in lieu of a CS pump. Contributing to this event was weakness in the control room command cnd control function and poor on-shift communications. The Shift Operating Supervisor did not take the appropriate immediate action to deal with the operator error, which would have been termination of the test, and the Plant Shift Superintendent was not notified of the error in a timely manner. (Section 04.1)

Progress was made in implementing the Learning Process; however, continued focus to fully implement the process was noted as necessary. Approximately three months after initiation, a back log had developed and the majority of learning bank issues with the highest risk levels (one and two), had not been formally accepted by issue manager (Section 07)

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Maintenance As the focus shifted to a refueling outage, the volume of maintenance work increase l Work was appropriately controlled in the field and performed in accordance with approved I procedures. (Section M1)

Enaineerina Good efforts were ongoing to address the problems with fire barrier penetration seal j Initiallicensee engineering inspection results indicated that about 90% of the '

approximately 2,600 penetrations inspected required replacement or repair. Some of the discrepancies included: inadequate seal thickness; improper damming; defective seals (bad structure, gaps or voids); inadequate material (cerafiber only); and presence of foreign materials. (Section E8.3)

Plant Sucoort in the area of plant support, we found that Maine Yankee continued to maintain adequate programs in the areas of occupational radiation exposure. ALARA planning and health physics oversight of steam generator work activities were excellent, and contamination control initiatives were very good. Notwithstanding, the restricted area tool control program was not fully developed; some contamination monitoring practices were found to be inconsistent. The newly implemented learning process had distinct advantages over the formerly used radiological incident reporting system, although some difficulties with administrative use of the learning bank were encountered and a backlog appeared to be -

developing relative to high priority issues that remained to be assigned to an issue manager. Finally, although learning bank corrective action tasks were generally sufficient to prevent recurrence, an example was identified where the corrective action addressed the symptom and not the listed apparent cause. (Section R1)

In the security area, activities continued to be conducted well as evidenced by the good performance of two security officers on April 15,1997, when they diligently performed their task and identified contraband during a vehicle search and thus prevented the item from being brought into the protected area. (Section S4.1)

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TABLE OF CONTENTS -

TABLE O F CO NT ENT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv l . O pe r a tio n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 O1 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 02 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . 2 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . .-. 3 07' Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ll. Maintenance................................................... 7 M1 Conduct of Maintenance .................................. 7 M8 Miscellaneous Maintenance issues (92902) . . . . . . . . . . . . . . . . . . . . . 7 111. Engineering ................................................... 8 E8 Miscellaneous Engineering issues . . . . . . . . . ...................8 I V. Pl a nt Su p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . 9 R2 Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 14 R5 Staff Training and Qualification in RP&C . . . . . . . , . . . . . . . . . . . . . . 15 R6- RP&C Organization and Administration ....................... 15 R7 Quality Assurance in RP&C Activities ........................ 16 R8- Miscellaneous RP&C lssues ............................... 18 S4 Security and Safeguards Staff Knowledge and Performance ........ 19 V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 X1 Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 X April 3,1997, Public Meeting . . . . . . . . . . . . . . ............... 20 INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21-LIST OF ACRONYMS USED ......................................... 22

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Report Details

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Summarv of Plant Status Maine Yankee remained in the cold shutdown condition and officiaily entered a refueling outage during this period. The spent fuel pool re-rack project was the critical path for the i outage. Maine Yankee plans a full core off-load in conjunction with the replacement of the I leaking fuel assemblies and similar, susceptible assemblie J

l. Operations

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01 Conduct of Operations

l 0 General Comments (71707)

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Using Inspection procedure 71707, the inspectors conducted reviews of ongoing plant l operations. Operations maintained good fccus on and control of the systems required for chutdown cooling. They provided good support for ongoing outage activities, such as the j spent fuel pool re-racking and the eddy current testing of the steam generators.

i 01.2 Residual Heat Removal System Declared inoperable i

• Insoection Scope i

On April 11,1997, engineering personnel notified operations personnel of deficiencies in the in-service test program (IST) that resulted in the technical specification required boration flowpath and both trains of residual heat removal

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(RHR) being declared inoperable. The inspector reviewed the testing and verifications performed prior to declaring the boration flowpath and RHR operable.

. Observations and Findinas

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Prior to the review of the IST issues on April 11,1997, RHR was in service and both trains were considered operable. The IST program review was being

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performed as outlined in Appendix G of the Maine Yankee Restart Readiness Pla identified deficiencies ranged from tests that were performed, but were not adequately documented, to tests that were never performed, in total, thirty deficiencies were identified that affected boration, RHR or RHR support system Operations utilized the learning bank process and operability determinations to address the various concerns. The operability determinations documented the i resolutions to each of the specific problems. For some manually operated valves, the IST test requirement was that the valve had operated properly within a specified

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period of time. Several valves were declared operable based on records of having been operated due to normal plant procedures. However, some corrective actions

included developing and implementing new test procedures to test the valve Other deficiencies such as relief valves that required testing were able to be compensated for in the shutdown condition by administratively tagging open vent paths to provide alternate over pressure protectio .

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Maine Yankee worked this issue as urgent on a 24-hour-per-day basis until operability of the boration flowpath and one RHR train was restored. The second train of RHR was not restored because it was scheduled to be taken out of service for outage work and only one train was required for the current plant conditio Maine Yankee experienced one problem while performing a test of the RHR suction ;

valves. Procedure 3.1.20.4, IST Valve Testing at Cold Shutdown, was revised to l incorporate the cycling of the RHR motor-operated suction valves, RH-M-1 and RH- i M-2. The procedure required all RHR to be secured and the suction valves cycle I During the cycling of the first valve, RH-M-2, the valve shut and failed to reope l The operators quickly determined that the failure was due to an open slide link configured to support other ongoing instrumentation and control (l&C) work. The !

valve was reopened within approximately 35 minutes. During the time RHR was I secured, operators were appropriately monitoring core temperatures and an operator was stationed ready to manually open the suction valve if require ;

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The issue of RH-M-2 failing to open was entered into the learning process as a risk level 2 issue, indicating that a root cause evaluation was required. The apparent causes, initially identified by operations, inc!uded: an inadequate cross-disciplinary review of the procedure change; and, inadequate understanding by operators of the effects of other ongoing l&C surveillance activitie po glusions Maine Yankee responded appropriately to the determination that key valves had not been tested as required by IST. Operability determinations were well documented and provided an adequate basis for returning the system to operable. The response to the failure of the RHR suction valve to open was appropriate. Operators were prepared to open the valve manually and were cautiously monitoring core temperature However, this is another example of challenges to the operators caused by a Icck of knowledge of configuration control during the outage. The inadequate cross-disciplinary review and lack of understanding of the effects of ongoing surveillance activities indicate a lack of focus in the area of procedure development and work coordination. A prior example was documented in NRC inspection report 50-309/97-01, which involved a 1300 gallon spill of RWST water due to operations not understanding the effects of ongoing pump work on the pressure boundar O2 Operational Status of Facilities and Equipment 0 Service Water and Primary Comoonent Coolina Water Systems Insoection Scope (71707)

The inspectors conducted walkdowns of portions of the service water (SW) and primary component cooling (PCC) water systems to ascertain that the systems were maintained operable for the plant conditio _ _ _ _ _ . __ _ _ . . . _ _ . -. . _ _ _ . _ . . ~. _ . . . _ . _

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i 3 Observations and Findinas

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] With the plant in cold shutdown and preparing for refueling, the inspectors focused

,- on core and spent fuel pool cooling systems. The core was stillloaded, with RHR, j train A, maintaining core cooling. The heat sink for RHR, train A is the primary

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component cooling water system via the RHR heat exchangers. The spent fuel pool is cooled by PCC via the spent fuel pool heat exchangers. The PCC is cooled by

SW, the ultimate heat-sink via the PCC heat exchangers.

l The inspector observed the material conditions in areas of the PCC pumps and heat exchangers in the turbine building, the RHR pump and heat exchanger in the containment spray (CS) building, and the service water pump house. There were no significant discrepancies observed. The pumps, heat exchangers, valves and other components were maintained well and showed no deficient conditions. The - )

systems were operating well and within the expected flow and temperature i conditions. Control room switches and indications were as expecte As a method for ensuring outage work did not impact the equipment required for maintaining the plant in a safe condition, operations developed and implemented the

" protected train" concept. -This required compononts of the protected train to be -

roped off and labeled with a warning sign. Access to the affected areas was restricted and controlled by the plant shift supervisor (PSS). Personnel were permitted into the area (s) only after discussing their tasks with, and being briefed by the PSS. Exceptions included personnel such as operators, security and fire watches, who make frequent tours and observations in these area Conclusion Operators generally maintained good safety focus and properly operated systems required to maintain the plant in a safe, shutdown condition. The " protected train" program clearly identified components of concern, and as implemented, restricted access to the areas containing these components providing an additional level of l control for the equipmen !

04 Operator Knowledge and Performance 04.1 Containment Sorav (CS) Pumos Baseline Test Inspection Scool The inspector observed and reviewed portions of tests of the containment spray pumps conducted in accordance with surveillance test procedure 3-1-15-3, emergency core cooling system (ECCS) Operational Pump Flow and Check Valve  !

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4 Observations and Findinas On April 9,1997, the inspector observed testing of CS pump, P-61 A. The test was conducted to gather pump operating data as baseline information prior to the proposed modification of the CS pumps. Pumps P-61B and P-61S were also scheduled to be tested. The test involved operating the pump at various flow rates and obtaining operating parameters (vibration, flow, and pressure). A temporary procedure change (TPC 97-154) was incorporated into the test procedure to accommodate the testing condition The inspector reviewed the test instructions, observed testing activities and discussed the test with the licensee. The test procedure and TPC were current and had been properly approved. There was background information provided with the TPC discussing the reason for the test. The pre-test brief in the control room was detailed and well conducted. Test conduct, controls and expectations were clearly discussed. Duties were clearly delineated. At the test locations, test instruments were located well and properly calibrated. Test personnel were stationed at each instrument locatio At the start of the test, the inspector observed that low pressure safety injection-(LPSI) Pump, P-12A, started and stopped almost immediately. Subsequently, the CS pump started and testing continued. After the test, when the inspector asked the Plant Shift Superintendent (PSS) about the LPSI pump start, he was unaware -

that it had happened. Subsequently, he was informed by the reactor operator who had made the error. He indicated that he had erroneously started the LPSI pump '

instead of the CS pump and upon realizing his error had immediately stopped the ;

LPSI pump and then started the CS pump. The controls for both pumps are located on the ECCS portion of the control board in close proximit The inspector expressed concern regarding several aspects of the evolution. First, the operator had continued with the conduct of the test after starting the wrong ECCS pump. Also, the Shift Operating Supervisor (SOS) who had direct supervision of the operator had not directed that the test be terminated. The PSS was not made aware of the error in a timely fashio l This issue was entered into the learning bank, Maine Yankee's corrective action ;

process. The SOS and operator involved were counseled and removed from shift l pending completion of the investigation of the event. Operations management I initiated additional immediate corrective actions that included re-emphasizing the responsibilities and authorities of the SOS as delineated in procedure 1-26-4, Responsibilities and Authorities of Operating Personnel, to operators. The LPSI pump was inspected to verify that the inadvertent start and stop had no detrimental effect. The licensee also verified that there was no effect on any other related component The inspectors assessed the safety consequence of this error and determined that it was minimal. The pump operation was for a short period of time and caused no detrimental effect on the pump. There was no effect on core cooling since the train

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maintaining core cooling was unaffected. Nevertheless, the event was indicative of l

a lack of attention to detail on the part of the operators, in, addition, operators failed to properly execute their responsibilities as expected. Specifically, plant '

procedure 1-26-4, Responsibilities and Authorities of Operating Personnel, revision 9, Section 3.2.3, required the SOS to ensure that his personnel stop evolutions

when unexpected conditions arise. Section 3.3.3 of the same procedure required the Control Room Operator to stop an evolution when unexpected conditions arise.

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the inspectors considered that operators failing to properly execute the responsibilities of their position as required by procedure 1-26-4 a violation of Technical Specification (TS) 5.8.2. TS 5.8.2 required that written procedures shall be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, (Rev. 2), February 1978, which include

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administrative procedures for authorities and responsibilities for safe operation and shutdown. (VIO 50-309/97-03-01)

l Conclusion The inspector concluded that this incident was indicative of weakness in operator I '

performance due to inattention to detail. There was also weakness in control room 4 command and control, and shift communications. The SOS did not take the appropriate immediate action to deal with the issue, which would have been test termination, and the PSS was not notified of the error in a timely manne I

, 07 Quality Assurance in Operations

, Inspection Scope (40500)

The inspectors performed a review to evaluate the effectiveness of the station problem identification / resolution program (learning process) for correcting deficiencies. Information was gathered by a review of lists of learning bank issues, a various learning bank reports, and through discussions with cognizant personne l

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i Observations and Findinas  !

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The inspectors reviewed a report generated from the learning bank entitled, I

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" Learning Bank Acceptance Report." This report listed the learning bank issue (s), j

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discovery date, data entry date, general status, issue manager by name, and j whether the issue had been formally accepted by the issue manager. Learning bank

issues were assigned risk levels from one to four. Risk level one issues were j

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considered urgent with an extremely high risk. These required a formal root cause and normally involved a multi-disciplined team to evaluate the issue. Risk level four issues were considered to have a low risk to the company. The inspectors noted l

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that as of April 2,1997,42 risk level one issues had been entered into the learning bank; however, only 20 had been accepted by an issue manager. Similarly,74 risk l level two issues had been entered into the learning bank and only 21 had been

, accepted by an issue manager. The inspectors raised a concern to a learning

. process team member that the report indicated that the majority of urgent and very urgent issues had not yet been accepted by issue managers. The learning bank

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team member stated that many of the issues that had not been formally  ;

(administratively) accepted were associated with cable separation issues, and were '

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actually being handled by management teams that were in place to address cable separation issues. The learning process team member also stated that although )

issues were being entered into the syster, at a higher rate than originally anticipated, immediato actions were taken for such issues. Further, it was indicated

that management was aware of this concern and was considering additional

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action !

l Conclusions 1 The inspectors concluded that management attention and focus on the Learning Bank continues to be warranted. Approximately three months after initiation of the learning bank (problem identification / resolution system), a backlog had developed and the majority of learning bank issues with the highest risk levels (one and two), l had not been formally accepted for evaluation and resolution by issue manager Miscellaneous Operations lasues I.n.soection Scope (92901)-

The inspectors reviewed previously identified issues including Licensee Event )

Reports (LER), Inspector followup items, and unresolved items to determine if they j could be closed.- The review included a review of documentation, and activities to '

ascertain that the issues had been properly addressed and that the appropriate ,

regulatory action is taken as required. The following previously identified issues were reviewed:

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I 08.1 Qosed. Licensee Event Reoort 96-001. Emeroency Core Coolina Pumos Declared lnocerable Due to a Reduction of Ventilation Flow On January 10,1996 Maine Yankee declared both trains of the LPSI and CS systems inoperable due to less than design room ventilation flow rates. The inadequate ventilation flow was caused by a partial blockage of the suction flow path for the CS building HVAC unit, HV- This issue was addressed in various NRC inspection reports and included in NRC i Inspection Report 50-306/96-16 as an apparent violation of NRC requirements. The inspectors reviewed the LER and verified that the information provided was accurate. This item is close .2 Closed. IFl 50-309/96-02-01. Containment Sorav Buildina Heatina Unit HV-7 in NRC Inspection Report 50-309/96-02, the inspectors expressed a concern regarding conduct of maintenance on a non-safety related component causing both trains of LPSI and CS to be declared inoperable. The problem was that a blockage of the inlet plenum of CS building heating unit, HV-7, caused fans FN-44A and 44B to be inoperable. The insufficient ventilation to the CS building resulting from the l

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inoperability of these fans caused both trains of LPSI and CS pumps to be inoperable. HV-7 is a non-safety related component while fans, FN-44A and 44B, and the LPSI and CS pumps are safety related. This issue was identified as an  !

inspector follow-up item pending completion of further review to determine the ;

regulatory significance. In NRC Inspection Report 50-309/96-16, this issue was

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dispositioned as an apparent violation of regulatory requirements. This item is ;

close ;

11. Maintenance

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M1 Conduct of Maintenance M 1.1 General Comments

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During the period, the volume of maintenance work greatly increased as Maine {

Yankee shifted focus to the refueling outage. The outage management presence was increased with the adoption of daily outage meetings. The inspectors monitored the daily shutdown safety ascessment and found no work activities

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compromising this assessment. Work observed in the field was appropriately .

I controlled and performed in accordance with approved procedures. The following maintenance and surveillance items were specifically observed. No discrepancies were observed.

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- WO 97-00629 Periodic maintenance of check valve SCC-7 1 - WO 96-00064 Repair of valve CS-72  ;

, - WO 97-00787 Replacement of the spent fuel pool purification pump motor [

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- WO 96-3140 Periodic maintenance of 6.9 kv breakers

- 3-1 -2 ECCS Routine Testing of Service Water Pumps  ;

M8 Miscellaneous Maintenance issues (92902)

M8.1 Closed, URI 50-309/96-06-01, and URI 50-309/96-13-02, Auxiliarv Feedwater (AFW) Pumo i in NRC Inspection Report 50-309/96-06, the inspectors identified a concern with

, maintenance activity on the AFW pump oil cooler. Specificaily, there appeared to be a weakness in the repair effort of the oil cooler on June 12,1996. Following that repair, the oil cooler failed again on June 16. In general, the inspectors were concerned with the licensee's efforts to maintain the reliability of the AFW pump since a review of the pump's availability records revealed that numerous corrective

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maintenance activities had occurred. The issue was left unresolved pending a review of licensee actions to ensure pump operabilit Also, in NRC Inspection Report 50-309/96-13, the inspectors identified an apparent inadequacy during maintenance on the AFW pump. The maintenance was to

enhance the pump's operation because of the pump's relatively poor past operating history causing it's reliability to be declining over the past several year .

Subsequent post-maintenance testing revealed some inadequacy with the pump

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packing rings testing. In addition, the inspector noted apparent inadequate test control and inattentiveness by a technician who adjusted the steam admission valve controller contrary to test requirements. This item was left unresolved pending completion of licensee action and further NRC staff revie In NRC Inspection Report 50-309/96 16, inadequate maintenance for the AFW pump was identified as an apparent violation of regulatory requirements. The licensee's corrective actions and activities to ensure the improved reliability of this pump will be reviewed and addressed as part of the NRC's review and followup of the response to the violatio Ill. Enaineerina E8 Miscellaneous Engineering issues

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E Closed. URI 50-309/96-11-02, HPSI Cut Wire, Event Review Board - Root Cause Analvsis in late August,1996, Maine Yankee convened an Event Review Board to investigate the circumstances surrounding the severed wire found in the control circuitry of high pressure safety injection (HPSI) pump, P-14A on August 17,199 In NRC Inspection Report 50-309/9611, this item was left unresolved pending the NRC's review of the results of the board's investigatio In NRC Inspection Report 50-309/96-16, the HPSI severed wire issue was identified as an apparent violation of regulatory requirements. The licensee's corrective actions, including the root cause determination will be reviewed as part of that violatio E8.2 Closed, URI 50-309/96-16-04. HPSI Flow Testina and Throttle Valve Settinas In NRC Inspection Report 50-309/96-16, the inspectors identified a concern with the testing of the HPSI pumps at high flow conditions and the setting of the HPSI system throttle valves. During previous pump test at full flow, it appeared that the pumps could have been operating at close to runout conditions. In addition, the setting of the position of the throttle valves needed a more precise tolerance to ensure that required flow is met and pump runout conditions are not exceede This issue was left unresolved pending review of further licensee testing of the HPSI pumps and resetting of the throttle valve In response to this concern, Maine Yankee performed testing of the HPSI system to verify adequate net positive suction head for all required modes of pump operatio The test was witnessed and reviewed by the inspectors as documented in NRC Inspection Report 50-309/96-14 (section E1.1). The issue was identified as an unresolved item (50-309/96-14-02) pending completion of detailed review of the test results by the NRC. This issue will be tracked via item 50-309/96-14-02, and this item, URI 50-309/96-16-04, is close q l

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E8.3 Open,URi 50-309/96-08-05, Fire Protection Barrier Seals The inspectors reviewed the licensee's activities involving the fire barrier I penetration seal repair projec Following the identification of several degraded 8-inch fire barrier penetration seals ;

in 1996, Maine Yankee embarked on a project to inspect all fire barrier penetrations at the plant and restore each one to the qualified state. The NRC inspected this issue and left it unresolved pending completion of NRC's reviews of the licensee's actions to eddress the proble The inspectors reviewed on-going licensee actions to address this issue. In March 1997, the inspectors discussed and assessed the status of the project with the licensee. The purpose of the project was to conduct detailed walkdowns of the seals to identify problems and implement any required repairs / upgrades, in addition, the intent was to properly label and map the barriers and improve the detail in existing documentatio With the initial inspection of all seals completed, the licensee has identified that about 90% of the approximately 2,600 penetrations inspected, required replacement or repair. Some discrepancies identified include: inadequate seal thickness; improper damming; defective seals (bad structure, gaps or voids);

inadequate material; and presence of foreign material The licensee had just initiated repairs to address the identified discrepancies. Along .

with fire barrier consideration, the seal design requirements include: high energy line break; flooding; current induced heat load; and cardox/halon retention. The inspectors will continue to monitor licensee efforts in this area. This item remains open pending completion of the repairs, the root cause analysis, and NRC review of the licensee effor LV. Plant Suocort R1 Radiological Protection and Chemistry (RP&C) Controls Reviews were performed of occupational radiation exposure. Specific areas reviewed included radiological cor:trols for steam generator inspections; locked high radiation area key control; contamination controls; status of f acilities and equipment; staff training; organization and administration; and a review of the effectiveness of the newly imp!emented problem identification / resolution system (learning process). A review of facility conditions versus the requirements in the Updated Final Safety Analysis Report (UFSAR) was also performe _. . .

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R1.1 Steam Generator Work Inspection Scoce (83750)

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The inspector reviewed radiological control preparation and planning for steam generator work. Information was gathered through reviews of ALARA pre-job and work-in-progress reviews; graphs of average historical dose rates for steam generator bowls; pre- and post- steam generator bowl decontamination efforts; i inspections of health physics controls at the steam generator platforms and in the steam generator monitoring trailer; and discussions with cognizant personne Observations and Findinas

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The inspector reviewed various ALARA reviews for steam generator primary side testing and repair, including setup and decontamination activities. Total radiation i dose for steam generator primary side testing and repair was estimated to be 62 person-rem. This included 2.5 person-rem for manway cover, diaphragm, and ALARA shield door removal / installation; 4.5 person-rem for decontamination of the steam generator bowls; 50 person-rem for primary side testing and repair; and 5 .

person-rem for radiological protection (RP) technician dose. Person-rem estimates

were based on anticipated work scope and historical data, and appeared reasonabl In addition, ALARA reviews showed evidence of extensive planning; required -

coordination between multiple work groups (e.g., health physics, decontamination crews, maintenance); and were comprehensive and very detailed. Information was included on work schedules, job prerequisites, dose reduction initiatives, engineering controls, training, contamination controls, and radwaste consideration One of the major ALARA measures implemented in preparation for steam generator inspections was a high pressure wash (decontamination) of the steam generator channel heads (bowls). The process involved installing a specialized decontamination manway with a remotely operated 3-D water jet lance. The system (Hennigan decontamination system) delivered a high pressure water spray to exposed surfaces within the bowls. The effluent was removed through suction lines from the bottom of the bowls and filtered, and the entire process took approximately two days to complet A graph of average steam generator tube channel head dose rates versus time indicated that average channel head dose rates in 1978,1980, and 1985 were greater than 30 R/h. The chemical decontamination performed in 1995 reduced channel head dose rates to an average of about 6 R/h, and the post chemical decontamination bowl wash' reduced channel head dose rates to about 2 R/ Nineteen ninety-seven survey results indicated that channel head dose rates had increased to about 2.5 R/h, and contamination levels were estimated to be on the order of 500,000 - 3,000,000 dpm/100 cm'. Upon completion of the high pressure bowl wash, survey results showed that loose contamination levels in the c.hannel head were reduced by about a factor of five, down to about 100,000- 600,000 dpm/100 cm'. In addition, although overall gamma levels were only slightly reduced, the dose rates at a single point at the plane of the manway were reduced

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by 40 percent. The inspector noted that this decontamination had the potential to result in significant dose savings due to decreased needs for use of respirators, hot particle controls, platform decontaminations, and trash changeout The inspector noted that the health physics staff maintained very close oversight of j work on the steam generator platforms from a remote health physics control point !

located outside of the restricted area. Pan, tilt, zoom cameras, and audio head sets l allowed health physics technicians to communicate directly with personnel on the

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steam generator platform, and observe essentially all activities. Remote reading area radiation monitors allowed for dose rate monitoring, and remote readout dosimetry (telemetry) allowed for continuous monitoring of personnel exposures and exposure rates. Further, steam generator airborne radioactivity levels were also remotely monitored by technicians in the remote control point. The inspector questioned various health physics technicians concerning health physics monitoring ,

of steam generator work and found the technicians to be extremely knowledgeable j of radiological controls and ongoing work. The inspector concluded that health physics oversight, monitoring, and control of steam generator work was excellen Conclusion Based on this review, the inspector concluded the following:

• ALARA planning for steam generator work was thorough, comprehensive, e and detaile * Health physics oversight, monitoring, and control of steam generator work was excellen R1.2 Hiah Radiation Area Kev Control Inspection Scoce (83750)

i A review was performed on the use of keys to control access to high radiation !

areas. Information was gathered by inspections of locked high radiation area doors, inspections of the locked high radiation area key storage cabinet, review of the l health physics shift log, review of procedural guidance, and by interviewing a shift )

health physics technicia i Observations and Findinas During tours through the plant, the inspector checked the integrity of high radiation area door locks. All doors to areas controlled as a locked high radiation area were ;

either locked or properly controlled to prevent inadvertent access. All doors and locking devices inspected appeared to be in good physical conditio The inspector examined the key storage locker located in the health physics office, and noted that the keys were contained in a locked box, had encumbering devices, !

and were well controlled by the shift technician. The health physics shift log book i

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also showed evidence that keys were being properly inventoried on a shift-by-shift basi The inspector reviewed procedural guidance contained in procedure 9-2-101,

" Control of Keys and Doors to High and Very High Radiation Areas," Rev. Procedural guidance was good in that it was clear, specifically listed responsibilities and methods for controlling access to locked high radiation areas, and keys were only issued to health physics and operations personnel. The inspector did, however, identify a program weakness in that high radiation area keys were generic and each one could be used to unlock any Tech Spec 5.12 High Rad door in the plant. The shift Health Physics technician explained that health physics supervision had previously recognized this, and had initiated steps to eliminate the use of generic keys, and use only specific keys for high radiation area door Conclusion Based on this review, the inspector concluded the following:

• The high radiation area key control program was generally good, and steps were being taken to improve the progra R1.3 Contamination Control Inspection Scoce (83750)

A review was performed on ongoing efforts to improve contamination controls at Maine Yankee. Information was gathered by a review of procedural guidance and other documentation, discussions with cognizant personner, and tours through the plan Observations and Findinas The assistant Radiation Protection Manager (RPM) stated that efforts to improve contamination and radioactive material controls included increased tracking and trending of the type, activity, and cause of personal contaminations; procedure revisions to require radioactive material stickers to be applied to equipment being released from a contaminated area until a determination could be made that the material met the condition for release into clean areas; decontamination staffing augmentations; initiation of an extensive hot machine shop clean-up; increased area wipe-downs; increased use of sticky pads at area exits; investigations into the use of a temporary radioactive material processing facility; and the development of a tool control progra The inspector noted that the licensee was effectively tracking and trending contamination events, and was addressing the root causes of personnel contaminations. Efforts to increase staffing of decontamination personnel, increase plant decontaminations, improve material handling practices, and development of a tool control program were very good initiatives. However, the inspector noted that

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the tool control program was not fully developed, in that the maintenance department had not yet taken the lead for this activity. The assistant RPM stated that due to plant priorities, the maintenance department had not been able to allocate the time necessary to meet preliminary goals for the development of the tool control progra The inspector also reviewed ALARA Review 96-01, " Spent Fuel Pool Reracking

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Project Contamination Control Program," and discussed contamination controls implemented during the fuel pool rerack project with a lead health physics technician. The inspector noted that the rerack project required contaminated fuel racks to be transported to outside areas (back yard of the restricted area) for loading into transport containers. Contamination control measures included requirements to rinse items down as they were removed from the fuel pool, wrap items prior to transport to outside areas, and establishing contingencies in the case of high winds or precipitation. The lead health physics technicians was able to describe, in detail, contamination control measures implemented for each sequence of work. The inspector concluded that although the fuel rerack project presented significant contamination control challenges, the measures implemented were reasonable and effectiv During tours of the facility, inspectors identified an inconsistency in the contamination control program. An RP technician was observed transporting a cart through the new fuel receiving area backyard door. The RP technician performed-personnel contamination monitoring prior to exiting the door, but did not perform ,

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contamination monitoring of the cart or wheels of the cart prior to transporting the cart into the back yard. The inspectors questioned this practice, and the RP technician and the shift RP technician explained that this was an accepted practic l The rationale expressed was that if an individual was contaminated, the hands and feet would be the most likely indicators; therefore, additional surveys of equipment and materials were not necessary; and the potential for offsite release was low since the back yard was not used as a routine restricted area exit point. The ;

inspectors acknowledged that it was unlikely that this practice would result in a i measurable offsite release (if contaminated equipment was inadvertently transported l to the back yard of the restricted area). However, trends for personnel contaminations produced by the radiological controls department showed that, of the personnel contaminations documented from January 1,1997 to March 31, 1997, only 35 of 94 of the contaminations occurred on hands or shoes. This issue was raised to the RPM who stated that contamination monitoring practices would be revised to require all cart wheels to be surveyed prior to transportation to backyard areas, and that contamination monitoring practices at the new fuel '

receiving area back yard door would undergo further revie Conclusions Based on this review, the inspector made the following conclusions:

e The licensee was effectively tracking and trending contamination events, and was addressing the root causes of personnel contamination )

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• ' Contamination control program improvement initiatives such as increased l r plant decontaminations, procedure upgrades, and development of a tool :

control program were very goo {

e' .The restricted area tool control program was not fully developed, and preliminary milestones for program development were not being me j e Contamination monitoring practices were inconsistent in that contamination ;

monitoring was required for personnel, but not materials and equipment, prior to movement through the new fuel receipt area door, to the back yard l

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of the restricted are 'R2 Status of RP&C Facilities and Equipment

a. Insoection Scope (86750)

The inspector performed an evaluation of radiological control boundaries, !

radiological postings, housekeeping, and personnel use of an automated access control / electronic dosimetry system. Information was gathered through tours of the primary auxiliary building (PAB), the vapor containment (VC), and the hot machine l shop, reviews of radiological survey data, and interviews with plant worker !

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b. Observations and Findinas  !

Radiological boundaries in the PAB, VC, and hot machine shop were clearly i delineated and well maintained, and radiological postings met procedural and -

regulatory requirements, and were informativ Overall housekeeping was good and showed improvement. Walkways and aisles in the containment building and lower spray building were notably clear and free of debris, and the boundary around the reactor cavity was wellidentifie The inspector also observed personnel use of a newly installed automated access control / electronic dosimetry system. The system was generally easy to use to assign personnel to work-activity-numbers on radiation work permits, and to track personnel radiation exposure. Training had been conducted prior to system implementation, and personnel " greeters" were stationed at the restricted area access point to assist personnel with use of the system. Based on this limited ,

review, the inspector concluded that the administrative implementation of the newly installed automated access control system was goo c. Conclusions Based on this review, the inspector made the following conclusions:

• - Radiological boundaries including radiation areas, high radiation areas, and contaminated areas were well defined and well maintained, and conditions of housekeeping were good and showed improvemen .

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1 e The administrative implementation of a newly installed automated access j control / electronic dosimetry system was goo i i

R5 Staff Training and Qualification in RP&C l a. Insoection Scooe (83750)

The inspector performed a review of selected portions of the health physics technician training program, information was gathered through discussions with ,

cognizant personnel, and a review of a syllabus for a three-week health physics i systems course, b. Observations and Findinas The training manager stated that in order to address a need for more systems training for health physics personnel, a three-week course was developed that included specific radiological / health physics concerns. All Maine Yankee health physics technicians were scheduled to attend the class, and at the time of the inspection, seven health physics technicians were attending the third week of the course. The training manager added that feedback from participants in the course was very good. The inspector noted that the course syllabus included classrocm training, plant walkdowns, and appeared broad in scop c. Conclusion Based on this review, the inspector made the following conclusions:

e Health physics systems training represented a commitment to improving health physics technicians' knowledge of plant system R6 RP&C Organization and Administration a. Inspection Scooe (83522)

The inspector performed a review of the organization and administration of the radiological controls organization. Information was gathered by a review of a resume for the newly appointed RPM, reviews of current and proposed organizational charts, and through discussions with cognizant personne b. Observations and Findinas The inspector interviewed the newly appointed RPM, and reviewed a copy of the

! individual's resurne. The individual was determined to be capable and qualified for the position of RPM in accordance with NRC Regulatory Guide 1.8, " Personnel Selection and Training."

The RPM stated that the current focus of the radiological controls organization was to support outage work. The assistant RPM duties had been limited to focus on

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oversight of health physics-operations, in order to support outage work. The inspector interviewed the assistant RPM, various health physics technicians, and a health physics planning supervisor. These individuals indicated that current staffing levels were adequate to support ongoing work, but additional staffing would be necessary to support future planned work. The RPM indicated that seven health physics technicians would be available upon completion of systems training, and additional staffing of contract health physics technicians was in progres I c. Conclusions l Based on this review the inspectors concluded the following:

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• The newly appointed RPM was capable and qualified for the position of RPM !

in accordance with NRC Regulatory Guide 1.8, " Personnel Selection and ,

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• Current health physics technician staffing levels were adequate to support ongoing wor ;

R7 Quality Assurance in RP&C Activities a. Insoection Scope (83750)

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The inspector performed a review to evaluate the effectiveness of the station problem identification / resolution program (learning process) for correcting radiological deficiencies. Information was gathered by reviews of lists of learning bank issues related to radiological controls, reviews of selected learning bank issues, and discussions with cognizant personne b. Observations and Findinas The inspector reviewed a list of radiological control issues entered into the learning process during the first three months of 1997, and compared the list to the issues entered into the former radiological incident reporting system in the first three months of 1996. The inspector noted that during the first three months of 1997, approximately 25 issues were entered into the learning process, which was greater than five times the rate at which issues were entered into the former radiological incident reporting system. The inspectors also noted that several of the issues entered into the learning process would likely not have been entered into the radiological incident reporting system (e.g., shortage of protective clothing hoods, personnel contamination events, improper use of tool bags, and communications breakdowns in health physics). As a result, the inspectors concluded that radiological control issues were being entered into the learning process at a lower threshold and at a higher volume than issues entered into the former radiological incident reporting system. This was considered a positive observatio The inspectors interviewed several members of the radiological controls staff regarding their use of the learning process. The individuals had attended training

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and had access to the learning bank computer system. Although individuals could easily enter the learning bank computer program and look at specific issues, some difficulties were observed when individuals were requested to perform queries or l print out reports: system queries took an extended time during periods of high system use; some printouts could only be obtained on a page-by-page basis; and a computer screen locked-up during a print request. Although these individuals were able to obtain the requested information with persistence or assistance, this raised the concern that if individuals were not fully familiar with the system, or if data retrieval was difficult, personnel may not fully utilize the system to evaluate and resolve radiological control issues. A learning process team member indicated that a computer memory upgrade was in progress to speed processing time; that training was being conducted; that individual skills would improve with increased system use; and that system enhancements were being performed to make the program more user friendl i The inspector also reviewed procedure No. 0-16-1, " Learning Process Implementation Procedure," Rev.10, and a Learning Bank " General Task Report" to evaluate use of the learning process. The inspector noted that the learning process did have strong advantages over previous problem identification / resolution system For example, anyone could enter an issue into the learning process; multiple personnel review, evaluate, and assess the significance of issues during the initial review process (e.g., initial screening, team review, and management review process); and accountability was designed into the system with the assignment of issue and task " owners." The inspector noted that this was a significant improvement over the former radiological incident reporting syste !

The inspectors reviewed lists of tasks (corrective actions) associated with various radiological control learning bank issues, and noted that tasks addressed apparent causes and were generally sufficient to prevent recurrence. However, an example was identified where corrective action " tasks" did not address the apparent caus Learning bank issue No. 96-00055 was generated to address the discovery of a discrete radioactive particle (DRP) found in the back yard of the restricted area during the performance of a prejob survey in preparation for digging trenches. The listed " apparent cause" was " contaminated particles have come loose from contaminated tools and equipment." The corrective action was to " perform more frequent surveys to keep the discovery of DRPs to a minimum." The inspectors noted that the corrective action appeared to address the symptom, but did not identify " apparent cause." Conclusions Based on this review, the inspector made the following conclusions:

• Radiological control issues were being entered into the learning process at a higher volume and lower threshold than issues entered into the former radiological incident reporting syste _

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e Difficulties were encountered with administrative use of the learning bank including extended computer processing times, system user friendliness concerns, personnel unfamilimity with the system, and sorne system programming weaknesse * The learning process had distinct advantages over previously used radiological control problem identification / resolution systems in that anyone could enter an issue into the system, issues were reviewed by multiple personnel, and accountability for resolving issues was designed into the syste e Learning bank corrective action tasks were generally sufficient to prevent recurrenc R8 Miscellaneous RP&C lssues R8.1 UFSAR Review A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, and procedures and/or parameters to the UFSAR description. While performing the inspections discussed in this report, the inspectors reviewed the -

applicable portions of the UFSAR that related to the areas inspecte I

The inspector reviewed selected sections of Chapters 11, " Radiation Protection" of the UFSAR pertaining to radiological controls to evaluate the accuracy of the UFSAR l regarding existing plant conditions and practices. No UFSAR discrepancies were identified during this revie R8.2 Learnina BankJssue 97-01450 The inspector reviewed a licensee-identified learning bank issue, No. LB 97-01450-001. Technical Specification 5.2.2(d) states that, "an individual qualified in radiation protection procedures shall be on-site when fuelis in the reactor" (this includes training in emergency planning procedures). This Technical Specification was violated on March 12,1997, from approximately 0230 to 0530 hours0.00613 days <br />0.147 hours <br />8.763227e-4 weeks <br />2.01665e-4 months <br />, when an RP supervisor allowed the Radiological Controls (RC) shiit technician to leave the site due to illness, without finding a replacement who was fully trained in emergency plan procedures. Identified causes included the f ailure to notify the Plant PSS that the on-shift qualified RC shift technician was leaving the site; the on-shift RC Supervisor was pre-occupied with ongoing work; the posted schedule did not specifically identify who was assigned to act as the "on-shift qualified RC shift technician;" and the replacement technician did not understand his role with regard to qualifications and training associated with being the qualified RC shift technicia This issue was entered into the learning bank for evaluation and corrective actio The inspector reviewed the recommended corrective actions and noted that they would be sufficient to prevent recurrence. This licensee-identified and corrected

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violation is being treated as a Non-Cited Violation, consistent with Section Vll. l of the NRC Enforcement Polie l l

S4 Security and Safeguards Staff Knowledge and Performance l

S4.1 Contraband Found in Vehicle Durina Search inspection Scoce (717501 The inspector reviewed the circumstances involving the identification of marijuana in a contractor's vehicle during a search of the vehicle in preparation for the contractor's access into the protected are Observations and Findinas On April 15,1997, two Maine Yankee Security Officers identified a small bag of marijuana in a contractor's truck. This occurred when the officers were conducting a search of the vehicle in preparation for the vehicle to be taken into the protected area for delivery of some non-safety related material. Upon discovery, the security force notified the Control Room and local law enforcement. Local law enforcement personnel respondet, to the site and dealt with the issue.

l Maine Yankee reviewed the individual's previous access into the protected area. It appeared that the individual had been on site on two occasions in the past. On both occasions, the individual was escorted by, and under the supervision of a badged employee. This person also had not been involved in any safety-related activities. Based on this, the licensee was satisfied that the individual's prior on-site activities had been monitored and considered acceptabl The inspector noted that Maine Yankee handled the issue properly. The notifications to the Control Room and the locallaw enforcement agency were timely. The reviews to determine the potential impact of the individual's previous site visits were thorough and revealed no adverse effec Conclusions Security activities continued to be conducted well as evidenced by the good performance during the April 15,1997 even V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee on May 2, 1997. The licensee acknowledged the findings presente . . . _ . . . . . . - _ . _ . . . . _ . _ _ _ _ _ _ . ~ . _ _ _ . . _ _ _ . _ . . . _ _ _ . _ . _ _ . . _ _ - . _ _ _ _ _ _ _ _ _ _ .

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X2 April 3,1997, Public Meeting  :

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On April 3,1997, the NRC held a' meeting with representatives of Maine Yankee at the l Maine Yankee Media Center. The meeting was to discuss the Maine Yankee Restart Readiness Plan as documented in the March 7,1997 letter to the NRC. The meeting was limited to public observation only. Later on, the NRC held a meeting with members of the public at the Wiscasset Middle School, Wiscasset, Maine. The meeting was to receive public comment regarding the Maine Yankee Restart Readiness Pla l l

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INSPECTION PROCEDURES USED

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IP 40500

Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing 4 Problems

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IP 62707: Maintenance Observation

IP 71707

Plant Operations i

, IP 92700: Onsite Followup of Written Reports of Non-routine Events at Power Reactor

Facilities

, IP 92901: Followup - Operations a

IP 92902: Followup - Maintenance j IP 92903: Followup - Engineering

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IP 37551: Onsite Engineering i

IP 61726: Surveillance Observation

IP 71750: Plant Support IP 83750: Occupational Radiation Exposure i

IP 86750: Solid Radiation Waste Management and Transportation of Radioactive Materials

IP 83522: Radiation Protection, Plant Chemistry, Organization and Management Controls ITEMS OPENED, CLOSED, AND DISCUSSED ltems Opened:

VIO 50-309/97-03-01, Operators Failing to Perform Duties Required by TS 5.8.2 and plant procedure,1-26-4, Responsibilities and Authorities of Operating Personnel. (04.1)

ltems Closed:

LER 96-001, Emergency Core Cooling Pumps Declared Inoperable Due to a Reduction of j Ventilation Flow. (08.1) i IFl 50-309/96-02-01, Containment Spray Building Heating Unit, HV-7. (08.2)

URI 50-309/96-06-01, Auxiliary Feedwater Pump. (M8.1)

URI 50-309/96-13-02, Auxiliary Feedwater Pump. (M8.1)

URI 50-309/96-11-02, HPSI cut wire, Event Review Board. (E8.1)

URI 50-309/96-16-04, HPSI Flow Testing and Throttle Valve Settings. (E8.2)

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ltems Discursed:

URI 50-309/96-08-05, Fire Protection Berrier Seals. (F2.1)

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LIST OF ACRONYMS USED l

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AFW Auxiliary Feedwater CFR Code of Federal Regulations

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CS Containment Spray {

CSB Containment Spray Building  ;

DRP Discrete Radioactive Particle l ECCS Emergency Core Cooling System HP Health Physics HPSI High Pressure Safety injection l&C Instrumentation and Control IST In-Service Test Program LER Licensee Event Report LPSI Low Pressure Safety injection MYAPC Maine Yankee Atomic Power Company NRC Nuclear Regulatory Commission ,

PAB Primary Auxiliary Building '

PCC Primary Component Cooling PSS Plant Shift Supervisor RC Radiological Controls RHR Residual Heat Removal RP Radiological Protection RP&C Radiological Protection and Chemistry RPM Radiation Protection Manager RWST Refueling Water Storage Tank SALP Systematic Assessment of Licensee Performance SOS Shift Operating Supervisor SW Service Water TPC Temporary Procedure Change UFSAR Updated Final Safety Analysis Report

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VC Vapor Containment I

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