IR 05000213/1997005

Insp Rept 50-213/97-05 on 970708-1006.No Violations Noted. Major Areas Inspected:Plant Operations,Maint Engineering & Plant Support

ML20202F093
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	11/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202F089	List: IR 05000213/1997005 ML20202F085
References
50-213-97-05, 50-213-97-5, NUDOCS 9712090009
Download: ML20202F093 (46)

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U.S. NUCLEAR REGULATORY COMMISSION REGION i .

- l Docket No.:- 50 213 ..

License No.: - DPR-61.'

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Report No.: 50 213/97-05

Licensee: Connecticut Yankee ' Atomic Power Company

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P. O. Box 270 '

Hartford, CT 06141-0270 ,

Facility: - Haddam Neck Station' -

? Location: Haddam, Connecticut

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Dates: -July 8 - October 6,1997 .

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inspectors: William J. Raymond, Senior Resident inspector Dr. Jason Jang, Senior Radiation Specialist Eben L. Connor, Project Enginee Morton B. Fairtile, Project Manager *

l Approved by: Richard J. Conte, Chief, Projects Branch 8

. Division of Reactor Projects f

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9712090009 971126 PDR ADOCK 05000213 6 POR a o-r-. . -rr m-,- , , - , --,

s g EXECUTIVE SUMMARY Haddam Neck Station NRC Inspection Report No. 50 213/97-05 This integrated inspection included aspects of decommissioning operations and plannin The report covers a three mnnth period of resident inspection, and the reviews by regional and headquarters inspectors in the areas of operations, engineering and plant suppor Plant Op_etations:

Performance varied in the quality of plant operations. Operators performed duties well to maintain spent fuel cooling, to monitor the status of the spent fuel, and to respond to deficiencies that challenged spent fuel cooling. Events and human performance errors challenged operators and hampered the ability to monitor and control plant condition Exceptions to good performance were noted in some informal practices (poor communications and the unreviewed actions to de-energize circuits). Inadequate procedures hampered operator response to off normal conditions. Shortages were noted in operator staffing and the availability of qualified personne Maintenance:

Plant personnel performed well to address problems, including the troubleshooting and repair of the emergency diesel generator EG 2A shutdown circuit. Plant personnel completed routine tests of plant equipment well, recognized degraded conditions, and initiated actions to complete troubleshooting and repairs. Good work controls were noted, including good pre-job briefs, control of tags, and adherence to work packages. Actions to maintain the operable portions of the seismic monitoring system and to initiate design work to replace the system entirely were acceptabl Enoineerinm Engineering provided effective support to plant operations and decommissioning planning during the period. A good regard for spent fuel safety was noted in the actions to address beyond design basis events for the spent fuel pool. Mixed performance was noted in licenses actions to meet NRC commitments, and to make timely reports. The effectiveness of actions to address these process weaknesses remains to be demonstrated. The licensee was working to implement Bulletin 94-01 for the spent fuel pool. For those portions of the pregram completed, the licensee's controls were adequate. An open item will track NRC review of the bulletin actions, and the liner leakage monitoring progra Piant Support NRC review of offsite contamination surveys continued, along with an assessment of past practices for handling potentially contaminated materials and fill from the site. Licens3e practices to process environmental samples in the onsite counting laboratory were poor, as was the communication of preliminary results for sample 9608. The radiological controls for routine work was acceptable. The corrective actions to address weaknesses in the program to calibrate the radiation monitoring system were well conceived and execute NRC review of this matter was in progress, ii

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TABLE OF CONTENTS E X EC UTIV E SU M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

TA BL E O F C O NT ENT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii -

R EPO RT D ET A I L S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Summ ary of Plant St atu s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. O pe r a t io n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ,

01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 Operating Activities and Status of Operating Systems . . . . . . . . . . . . . . 1-01.2 Lig h t ning S tr ik e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 01.3 Loss of Closed Cooling Water (CLW) ..........................4 01.4 Inadvertent Control Room Halon Actuation (IFl 9 7-0 5 01 ) . . , . . . . . . . . . 6

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03 Operations Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . 12 03.1 Procedures for Shutdown Operations (URI 9 7-0 5-02) . . . . . . . . . . . . . . 12 03.2 Logs for Radwaste Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 04 Operator Knowledge and Performance . . , . . . . . . . . . . . . . . . . . . . . . . . . . . 14 04.1 Operator Errors During Routine Duties ........................14 06- Operations Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . 16 06.1 Operator Staffing and Work Hours ..........................16 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 08.1 Conclusions for Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 11. M a i nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 7 M1 Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 M1.1 - Maintenance and Surveillanco Activities . . . . . . . . . . . . . . . . . . . . . . . 17 M1.2 Deficient Material Conditions - SFP Cooling Supply . . . . . . . . . . . . . . . 19 M1.3 Conclusions for Maintenance ..............................19 f

Ill . E ng ine e ring . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 0 E1 - Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 E Engineering Support for Operations and Decommissioning (URI 97-05-03)

...... ............................................20 E1.2 Follow-up on Enforcement issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 E1.3' Conclusions for Engineering Support .........................23 iii

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E2 Engineering Support of Facilities and Equipment ......................23 E Controls for Spent Fuel Pools - NRC Bulletin 94 01 (IFl 97-05-04) . . . . . 23 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

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E8.1 - Review of LERs and Telephonic Notifications (URI 97 05-05) ........28

- I V. Pl a nt S u pp o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 0 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . . 30 R1.1 Offsite Contamination and Radiation Surveys . . . . . . . . . . . . . . . . . . . 30 R1.2 Review of Radiological Controls and Radiation Surveys ............32 R2 Status of RP&C Facilities and Equipment ............................33 R2.1 Effluent / Process Radiation Monitoring Systems (RMS) Calibration . . . . . 33 R8 Miscellaneous RP&C lssues (92904) ...............................37 I R (Open) Apparent Violation, eel 50 213/97-02-01. . . . . . . . . . . . . . . . . 37 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . . . . . . 37 S 1,1 Containment Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 V. M anagement Meeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 8 X1 Exit Meeting Sum m ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 8 PARTI AL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 ,

INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 LI ST O F AC RO NYM S U S ED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 ATTA C H M E N T l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2 iv v u ---- v-'- -- -r- _ -

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REPORT DETAILS Summarv of Plant Status

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l The Haddam Nech plant conditions remained stable with the spent fuel safely stored in the '

, spent fuel pool, The licensee maintained controls to keep the fuel adequately coole l There were no significant changes in the plant systema not required to support spant fuel I cooling. The licensee submitted the post shutdown decommissioning activky report, and l continued to plan decommissionir,g activitie NRC inspections during e period included the reviews by the resident inspector of post operating activities, and the preparations for decommissioning. A specialinspection was-conducted of an inadvertent ectuation of the halon system in the control room on August 7, which resulted in the temporary evacuation of the control room and the declaration af an Unusual Event emergency classification. A special review was conducted of the issues identifieriin NRC Bulletin 94-01 for the control of spent fuel pools, rJ'IC activities at the site included plant tours: on July 2125, by Messrs. Mort Fairtile and T. Fredericks of the NRR Office of Decommissioning Projects; on July 29 30, by M Richard Conte, Chief of Reactor Projects Branch #8; and, on September 18-19, by M William Axelson, Deputy Regional Administrator and Mr. John White, Chief of the Radiation Safety Branch. NRC personnel attended a meeting of the Community Decommissioning Advisory Committee on July 29,199 juOperations 01 Conduct of Operations'

Using Inspection Procedure 71707, the inspector conducted periodic reviews of plant status and ongoing operations. Operator actions were reviewed during periodic plant tours to determine whether operating activities were consistent vcith the procedures in effect, including the alarm respcnse procadure .1 Qparatina Activities and Status of Operatina Systems

' Insoection Scope (71707)

The purpose of this inspection was to review the licensee activities to maintain the plant in the defueled condition, and to prepare for decommissioning activities, Observations and Findingg Operating activities during this period included those operations needed to maintain stable plant conditions with the reactor defueled, to maintain adequate level in the spent fuel pool, and to assure adequate cooling of the spent fuel. Service water, l

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Topical' headings such as 01, Ma, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports l- are not expected to address all outline topics.

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component cooling water and closed cooling water pumps were operated as needed to support spent fuel pool cooling. The operating closed cooling water (CLW) pump was lost temporarily on September 18, as described in Section 01.3 below. The i normal and emergency eleMac distribution system remained in servic The number of control board annunciators that remained illuminated was reduced !

from about 100 to 50 as the licensee implemented NOP 2.0-9, Disposition of Control Room and Local Panel Annunciators. This action partially addresses the concerns identified in Inspection item 97-01-01, which will temain open pending further review of the implementation of NOP 2.0-9. Operator responses to off normal condith '.s were consistent with the applicable procedure The inspector observed operator actions for several activities during the period, and reviewed operator adherence to procedures. The operating activities observed included: the response to an inadvertent halon system actuation on August 9; the response to a lightning strike on August 17; cleaning the B SFP heat exchanger on August 19 per NOP 2.10-1; the loss of the CLW system and the station air system on September 18; transferring water from the refueling water storage tank to the borated waste storage tank on October 8 per NOP 2.14-18; and, monitoring plant w status in the dafueled condition throughout the perio Confiauration Control and Taaaina The inspector reviewed the licensee's control of the physical configuration of the plant. Licensee actions to issue and/or remove tags under the following clearances were reviewed: 96-1102,97 286,97-292,97 293 and 97 300. This review included the implementation of the tagging process during the conduct of work activities, and the control of systems removed from service due to plans to decommissien the plant. No performance problems were note Spent Fuel Coolina The inspector reviewed licensee activities to assure compliance with Technical Specifications (TS) TS 3.9.11, SFP Water Level; and, TS 3.9.15, SFP Coolin There were no activities during this period involving the movement of fuel or heavy loads over the spent fuel pool. The licensee conducted routine surveillance of the spent fuel pool and building, which included the tours by the nuclear side operators-once each shift per SUR 5.1-0 The spent fuel pool cooling system (SFPCS) remained operating per normal operating procedures (NOP) 2.10-1. The SFPCS operated with at least one heat exchanger and one pump aligned to the pool. The licensee maintained pool temperature below the limit of 150 F per TS 3.9.15. The service water (SW) side of the SFP cooling system was maintained using either the normal SW piping or through a temporary bypass per NOP 2.24-3 during times when the normal cooling lines were not availabl .

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As in the past, deficiencies in material conditions of service water comporants caused the licensee to take the service water supply to the SFP out of seMee, and to rely on temporary, alternate cooline supplies (fire hoses) to cool the spent fuel pool. The licensee followed TS 3.9.15 during thu period from July 21 to August 18,1997 as several deficiencies were addressed. The inspector also periodically reviewed license actions to meet the following requirements during the period: TS 3.3.3.3, TS 3.3.3.7, 3.3.3.8 and tech aiul requirements manual (TRM) II.1.E and ll,1.A. No inadequacies were identifie Conclusions Operators performance was good to monitor the status of operating plant equipment, and those systems in a lay un condition. Operators sh.wed good regard plant procedures, Operators performed we;! to monitor o o SFP and the SFPCS, and to use alternate cooling methods as actions were taken to address discrepant conditions. Several problems caused condit;ons that challenged the operators and the normal cooling supply for the spent fuel pool; operator response 'vas goo .2 Ljohtnino Strike Inspection Scope (71707,93702)

The purpose of this inspection was to review the licensee activities following a lightning storm that effected plant equipment. Toe inspector responded to the site to verify plant status and revisw licensee action Observations and Findinos With the piant shutdown and the reactor defueled, a lightning strike at the station at 2:07 a.m. on August 17,1997 caused the loss of spent fuel pool cooling and tripped several plant components. The plant equipment affected included the trip ci the operating A spent fuel pool cooling system (SFPCS) pump, the temporary loss of the plant process computer (PPC) and security lighting, the tripping of several ventilation system fans (control room, switchgear room, spent fuel building, turbine building, administration building), and the tripping of the opw dng A service air compressor and the sample pumps for stack high range monitor RM-14 Numerous alarms were received in the control room and the security diesel '

generator started and assumed loads. The plant emergency diesels did not start and were not required since there was rw loss of the 4KV or 480 voit emergencv buses, which remained powered from the 115KV syste Plant operators and security personnel responded to the event using abnormal and emergency respons; procedures tu identify eff normal equipment conditions and to restore normal equipment operation. Under atage (uv) lockout relay 27-X5 tripped (which monitors 480 volt 8uses 4, 5,6, and 11), s id caused the isolation of service water to the SFPCS. However, the 480 volt buses remained energized and no flags were noted on the individual bus uv relays. The PPC was restarted and

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functional by 2:21 a.m. Operators restarted the A SFP cooling pump, reset the 27-l

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i X5 relay, ard restored cooling to the SFP by 2:25 a.m. Spent fuel pool temperature remained stable at about 100 degrees F. The operators reviewed plant equipment conditions and restored equipment affected by the voltage transient. Plant electric'ans assisted in a systematic review of all electrical buses and panels. No equipment dumage was found. Equipment affected by the transient was restore The licensee long term review and follow-up of the event was provided by ACR 97-616 and oy the engineering programs group. An engineering evaluation of plant equipment performance was provided by memorandum CY-TS 97-0497 dated October 3,1997. Plant equipment operated as expected during the voltage transients, in:,luding the operation of the 27 X5 lockout relay, which operates by undervoltage telays on the 480 voit buses. The lockout relay cperated without the loss of the 480 buses on undervoltage because of differences in sensitivity a operating settings of the relays, Conclusions Operators responded well in responso to plant upset conditions cat, sed by the lightning, and to quickly restore norm::l equipment conditions. Licensee folicw-up actions were good to evaluate equipment performance and to plant systems operated properl .3 Loss of Closel Coolina 'Nater (CLW) Inspection Scoce (71707)

The purpose of thia inspection was to review the licensee activities following a loss of the operating closed cooling water system, Observations and Findinos On September 18,1997, the operators received a trouble alarm on the turbine building closed cooling water (CLW) system. The NSO found that the CLW pumps were cavitating due to an air leak into the system. The operators shutdown the CLW pumps to preclude damage, which left the station and control air systems (A station air compressor, and the A and C control air compressors) without any cooling. The applicable alarm response procedure, ANN 4.8-23B, was written for the full power operations condition, and directed the operator within 10 minutes to line up the well water system to supply cooling to the air comp'essors. The alternate CLW cooling mode would use a modified CLW valvo lineup that resulted in an open path the discharge canal. The Shift Manager noted that the CLW contained chemically treated water and had recently been discovered to contain radioactive contamination (ACR 97-694, at levels of 3 X 10-7 pCi/ml). Thus, following the alarm procedure would have resulted in an unanalyzed and unmonitored discharge to the river. Since the alarm procedure was written to prevent a loss of station air with the plant operating at full power, a much more severe transient than with the plbnt in cold shutdown and defueled, the SM directed the NSO to shutdown the

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oporating air compressors. The operators use the guidance of EOP 3.134 to respond to a loss of station air at 9:15 a.rn, on September 1 The loss the station air caused the primary auxiliary building and radwaste building fens to shutdown because the air operated pressure instruments caused the purge fans to trip. Actions were taken to monitor building pressure and airborne radioactivity. The loss of air caused the flow controller for the nitrogen supply to the waste gas system to f ail open, which resulted in an uncontrolled pressurization of the waste gas surge tank (WGST) tank. The WGST pressure remained below the lif t setpoint of the relief valves since the nitrogen supply bottles were almost empt This event was a precursor event because, had the nitrogen supply tanks been full, the event would have resulted in the pressurization of the WGST to tha lift setpoint, in an unplanned release of the WGST. The tank contained one year decayed fission gases and nitrogen. The diesel generator fire pump fuel tank level instrument depended on control air and failed. The lack of levelindication did not affect pump operability. There was no other impact on plant operations. The event did not affect the spent fuel pool cooling system, since the service water return valve SW-AOV 9, was designed to fail-as-la on loss of air. There was no change in SFP temperature during the transient.

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The operators restored the ventilation system to normal. Subsequent investigations

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of the service and controlled air systems found the CLW system became air bound

! because of a leak in the A SAC aftercooler. The operators isolated all CACs and SACS operatino at the start of the event, vented 6nd started the CLW system at 12:25 p.m., and started the unaffected B SAC. Control and service air supplies were restored to the station at 1:50 p.m. and plant ventilation systems were returned to normal. ACRs97-764 and 97-765 were written to address the loss of CLW and the inadequate procedures issues, respectivel The licensee subsequently completed a controlled release of the WGSTs and discontinued use of the waste gas system. This action eliminated the poter.tial waste gas system vulnerability to a loss of station air, c. Conclusions The operators responded well to the degraded plant conditions. The SM decision to avoid an unplanned release via the liquid pathway was good in consideration of the defueled condition of the plant and the expected minor plant response to a loss of air. However, the operators did not anticipate the impact of the loss of air on the waste gas system. Plant procedures contained inappropriate directions assuming a plant power operations condition, and hampered the operater +

anse to the even The inadequate procedures created a vulnerability to an inaos ment waste gas release. This is another example of procedures inadequacies for the shutdown condition. See Section 03.1 below for further NRC review of this matte . __ _ . _ - _ _ . _ _ _ _ _ -_

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01.4 Inadvertent Control Room Halon Actuation (IFl 97-05-01) Incoection Scope The purpose of this inspection was to review the inadvertent actuation, of the halon system on August 7,1997, which resulted in the evacuation of the main control room at 9:47. The control room was remanned at 10:34 a.m. The inspector was notified of the event by a call from the Shift Manager at 10:20 a.m. and responded to the plant at 11:30 a.m. to review plant status and licensee actions, Observations and Findinos Plant Status At the time of the event, the plant was shutdown with all nuc! ear fuel stored in the !

spent fuel pool. The spent fuel pool (SFP) cooling system was in operation with the A SFP cooling pump in service aligned to the B heat exchanger. Spent fuel pool temperature was at 94 degrees F, which did not change during the even At the time of the event, the following personnel and activities were la prograss in the control room: a Shift Manager (SRO) and two licensed operators, the normal shift complement, were performing routir.e duties; an electrician was stationed at i the fire detection system (FDS) panel, wort ing with a second electrician conducting tests of smoke detectors in the auxiliary feedwater pump room per TRM 16.9 51; two generation system test (GTS) personnel were working on the SCADA supervisory panel for the offsite electrical distribution system; and, a training department representative was taking pictures of fire system panels to develop training aid Halon System Discharoe

The time line for major events, provided in Attachment I, was developed by the licensee and validated by the inspector. The sequence was reconstructed from control room annunciator and access door card reader er. nt logs and personnel briefings after the even The training representative took pictures of the ANSUL Autopulse 2000 Halon control panel mounted on the wallin the southwest corner of the control room. The pictures were for an upgrade of the Fire Protection - Control Room Halon System training manual. He was using a digital Canon PS1001, Power Shot 600 camer The trainer had opened the door of the halon control panel to photograph the alarm reset / silence pushbuttons located on a printed circuit board (PCB) inside the pane On taking the first picture with automatic flash, a small annunciator mounted in the PCB began beeping and continued until he closed the panel door (probably two or three beeps). The trainer talked with the operator and both returned to the halon fire control panel to review what had caused the alarm. The operator and trainer checked with the electrician to determine that none of the FDS test activities

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7 caused the alarm. The electrician stated he recalled that pho'.agraphy in the past had caused alarms on the fire system. The operator noted the condition and intended to file an cdveise condition report to document the alarm condition for further investigation. The trainer proceeded to take additional picture On taking the second picture with automatic flash, the Halon system went into an immediate full alarm condition and a complete discharge of Halon through discharge nozzles located throughout the controi room envelope (9:47 a.m.). The alarm was generated on Halon system annunciator and strobe flash warning lights mounted on the control room walls, which went into a continuous wail. The alarm system did not provide the expecteo 60 second warning of immediate Halon discharge. The Halon discharged in about 15 seconds rapidly filled the room with Halon fog. The high velocity discharge blew papers around the room, and knocked several ceiling tiles loose. Three plexiglass light panels were knocked out of the ceiling fixtures, and assorted pieces of ceiling panel support steel was pushed up or knocked loos A f alling ceiling panel support steel broke the cover glass and bont the case f astener on relay 85-M2, which provided backup line protection to 345KV line 12R-32 Qoerator Resoonsg The operatmv and other personnel, startled by the unexpected discharge and rapidly decreasing visibility, immediately withdrew from the control room (9:47 a.m.) to the access foyer and communications room or the turbine hall immediately adjoining the control room. The precautionary evacuation was completed in less than one minute. Both the foyer and commuiiications room have large windows allowing full view of the control room prope The Shift Manager (SM) assessed the events leading to the halon discharge and plant conditions. Other than the halon discharge, there was no indication of a fir Based on their training, the operators knew that halon by itself was not immediately life threatening and short duration exposures could be endured. The SM and licensed operator immediately reentered the control room with the halon concentration at its maximum value to assure all personnel had evacuated and to complete a sweep of the room to verify there was no fire. The GTS personnel met the operators at the control room access door exiting the room. The SM again walked through the control room, including the front section, the back panel areas and the interior to the control panels, to verify there was no indication of fire, and that all personnel had evacuated. The operating staff then withdrew to the access foyer and communications roo The Shif t Manager considered what procedures applied to the situation and to formulate a plan of action. The following procedures were considered:

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• - AOP 3.2 50, Operations from Outside the Control Room, was in a "Do Not Use" status since it prescribed actions that assumed the reactor was operating at full power and directed actions from shutdown panels with controls and indicators for systems no longer in operation for a defueled plant and which provided no information for systems required for SFP ccolin * AOP 3.2-57, Station Fires, was also considered, but not entered because it was not fully applicable. Even though the halon e Mem actuation was one of the entry conditions for the procedure (Symptom 2.4), the Shif t Manager had ve:;fied that no indications of fire was present, and the halon actuation was related to the photography of the control pane * AOP 3.2-7, Loss of Fire Systems was deemed app!icable and was entered to compensate for the inoperable Halon fire system. The operators took actions to implement compensatory measures per the technical requirements manual (TRM) for the inoperable fire system, to reset the Halon system, and to place the control room ventilation in the riormal mode to clear the Halon from the roo The operators concluded that except for AOP 3.2-7, plant procedures did not address the conditions and responded to the event using their knowledge and experience. The response actions were to account for personnel, secure and disable the halon system, initiate the ventilation system and check ali quality to regain unrestricted access to the control room. The operators re-entered the control room briefly as necessary to obtain procedures and respond to alarm (only one came in on FDS 2 as a result of the testing in progress). Additional support was requested and received from management end support personnel, who assisted in the event classification and notifications. Further inspector review of the procedures is provided in Section 03.1 belo The Shift Manager and operators remained stationed in the adjoining rooms to monitor the status of the control boards. Through the use of the viewing windows, the operators had view of the FDS status panel, the 115 kv and 345 KV and inplant electrical distribution system, the status of the operating service and component cooling water pump, and the status of the area and process radiation monitors. The control room annunciators were visible, including those on panel E1 for SFP temperature and leve An auxiliary operator was sent to the spent fuel pool to verify pool level, and the operators completed a second set of rounds to verify there were no undetected changes in plant conditions. Following the completion of air quality checks, the operators re-manned the control room at 10:34 a.m. The licensee entered the

' action statement for TRM ll.1.E 3.1.b for the inoperable halon system and maintained a compensatory measure that assures a continuous fire watch was posted in the control roo O

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Event Classification and Ememency Declaration The Shif t Manager considered the available emergency actions levels (EALs) and noted no symptoms specific EAL exactly applied to the plant status and condition EAL GA-1 would have required an Alert classification had the control room been evacuated p_nd AOP 3.2 57 had been cntered dua to an actual fire. The operators had nnt entered AOP 3.2-57, and although the operators had left the control room, the panels were monitored and the room was accessible as needed to respond to alarms. The plant conditions did not meet the general event classification criteria for an Alert of " events in progress rapresenting an actual or potential degradation in plant safety," since the spent fuel was cooled and not affected by the even The Shift Manager classified and declared an Unusual Er it at 10:45 a.m. based on EAL JU-1, DSEO Judgement: any condition which indicates a potential degradation in the level of safety of the plant. The NRC Duty Officer was notified per 50.72(a)(1)(l) at 10:53 a.m. The Unusual Event was terminatcd at 12:35 o.m. after confirming stable plant conditions, completing habitability surveys and resumlag normal marining of the control room and SA The time frame for classifying the event did not meet licensee performance expectations. The event was classified in 51 minutes after cymptoms appear that warrant classification versus the expected 15 minutes. This matter was noted for further licensee follow up. The inspector reviewed EPIP 1.5-1,1.5-2, and 1.6-3 regarding event evaluation, classification and notificativns. No other deficiencies were identifie Security Response The central alarm station (CAS) was affected by the event. The CAS operator tried to contact the control room. No one was reached since the control room had been evacuated momentarily. Security personnel evacuated the CAS at 9:53 Security compensatory rueasures were implemented. A security supervisor entered the CAS with self-contained breathing apparatus (SCBA). The security force remained fccused on plant security. The security supervisor was qualified for fire brigade duty and to use the SCBA. Following the completion of air quality checks, the guards resumed ncrmal manning of the CAS at 10:33 Manaaement Resoonse The Unit Director convened a meeting of the management team to review the event, assess plant status, and make assignments to follow up the event. The Director concurred at 12:30 p.m. with the plans and actions to terminate from the Unusual Event based on an assessment that plant conditions were stable and follow-up habitability surveys were acceptable. An Event Review Team was chartered to review and determine the event cause and to develop recommendations for further actions. Other licensee evaluations and follow up action were described in ACR 97-

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570. (he licensee reported this event to the NRC in voluntary licensee event report LER 9713. The follow-up actions included:

• A walkdown of the control room was completed to r.ssess conditions and the impact on electrical equipment, and structural damage. Only minor damage was noted. Actions were taken to correct material deficiencies, and to support halon system operabilit * Based on the apparent cause, all fire system control panels in the plant were posted to warn personnel that " photography is prohibited inside the cabinets". The inspector independently verifiec' the caution tags were hung and signs were posted as intended. The licensee completed a review to determine what other systems used digital components that might be similarly affected by flash ohotograph * Tags blew off the panels during the discharge were rehung: the panels were reviewed to verify affected tagouts were correctly restore * The site nurse conducted a medical assessment of personnel exposed to halon and identified no acute affects: the material safety data sheets (MSDS)

and halon manufacturer were contacted to determine what the toxicity effects were and whether further medical assessment (blood work) was recommended. No adverse effects were expected based on a 5% to 7%

halon concentration derived to the control envelope (system design basis)

and for continucus exposures up to 15 minute * Actions were taken to inspect and clean the detectors, recharge the halon bottles and test the system. The licensee also consioned whether technical and regulatory requirements required the continued use of the halon system for fire suppression (since the raquirements of 10 CFR 50, Appendix R no longer applied to the plent due to the decichn to enter decommissioning).

• The licensee Event Review Team completed funher testing on August 7 fo"owing the event, in which conditions were recreated to take photographs of the Autopulse 2000 control panel. The test showed that the halon system actuated in response to the flash photography. When a picture was taken without the flash, the system showed no response. The test was conducted twice with the same results. No discharge occurred since the halon bottles were empt Root Cause Investiaation The licensee conducted additional testing and root cause investigations to determine why the halon actuation occurred, and in the sequence observed. Technical Programs personnel provided extensive engineering support for this effort. The inspector observed additional testing during the week of August 25 conducted insitu on the halon panel with the system functicnal but rendered incapable of injecting halo ~ ._ . .

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The Autopulse 2000 control panel has a processor control board containing a microprocessor based logic, database, memory, field terminals, auxiliary relays and switches. The inputs from the detectors are monitored by the microprocessor which contains the programmable logic to receive the sensor inputs, generate the time delays for the reaction warnings, and generate the signals actuate the Halon discharge and the alarms. The microprocessor is sensitive to electromagnetic (EMI)

and radio frequency (RFI)interfers nce in that the signals can actuate affect the processor outputs, including the generation of an actuation signal down stream of the time delay circuit. This has been noted by several similar events in the industry, including one at another power plant on February 4,1997. An almost identical event occurred when flash photography of a Chemetron Micro 1.EV control panelin the Relay Room caused the ventilation syttom to isolate and the CO, to charge to the localisolation valv The results of the Event Review Team investigations and evaluations were prov:ded in a report on Septc.nber 17,1997 (CT TS 97 0550). The licensee concluded that the enuso for the August 7 halon actuation was that the Autopulse 2000 EPROM reacted to the camera flash. Testing sl. owed thet neither EMI nor RFI was a contributor. As a corrective action to address this, tha licensee temporarily installed electrical tape over the EPROM window to assure it would be shielded from this type of light. This control was subsequently made permanent as a bpasa jumper

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(97-06). The licensee also evaluated the vulnerabiltty of other systems that have EPROM circuits (such as fire protection and auxiliary feedwater controle).

The ERT evaluations identified other items to improve performance that ' vere addressed in nine recommended corrective actions. T1e findings included issuts related to praceA es, communications, emergency plan notifications, human performance errors and the application of the " STAR" process, dissemination of industry information, procedure adequacy, and guidance on Q use of self-contained breathing apparatus. The licensee actions to addn these matters will be followed in subsequent NRC inspections (IFl 97 05 01).

The licensee's critique of the event identified the faifure by control room personnel to notify the CAS about the evacuation, and it.cluded this issue in the evaluation of the incident. The licensee also noted other inadequacies in communications amongst the operators and between the operators *nd the training eepresentativ The halon actuation might have been prevented hau these communications been more thorough and deliberat The licensee remained in the action statement for TRM ll.1.E as of the conclusion of this inspection, pending the completion of r :tions to return the halon system to operation, c. fanclusions Operators responded well to the inadvertent actuation to monitor plant system status, assure personnel safety, and to mitigate the event.1he guard force performancu was good to remain focused on plant security titation management

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provided good supp # n, the operators to assist in event classification and notifications, and to easign resources for long term follow up and event evaluatio Engineering evaluations were timely and thorough to investigate the cause of the

, event, identify recommendations to improve performance and identify corrective actions. Station procedures contained references to power operating conditions and i did not provide for shutdown condition, and hampered the operator response to the :

even Operations Procedures and Documentation

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03.1 Procedures for Shutdown Oo1 rations (URI 97-05 02) Insoection Scoos (IP 42700)

The purpose of this inspection was to review plant procedures governing operations in a shutdown and defueled condition. The review also focused on procedures for shutdown from outside the control room conducted in follow up to the August 7 halon actuation even >

" Observations and Findinas

AOP 3.2 59. Loss of Soent Fuel Coolina ,

The inspector reviewed this procedure to validate the licensee changes (TPC 97-281) follow!ng the accision to remove the refueling water storage tank from servic The licensee planned to drain the tank and to repair the tank bottom to stop a chronic leak of tritium from t .e tank. The procedure change was made to substitute the use of the demineralized water storage tank (DWST) as a backup source of makeup water to the spent fuel pool (reference safety evaluation SE EV-97103). AOP 3.2 59, Attachment 11 was written to describe the method for transferring DWST water to the pool. The inspector reviewed plant drawings, interviewed operators and walked down the procedure in the field to verify that the procedure methodology would work and that the procedure would work as writte No inadequacies were identifie AOP 3.2 50. Shutdown from Outside the Control Room

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The inspector reviewed procedure for plant shutdown from outside the control room, AOP 3.2 50, which included a walkdown in the plant with an operator. This review confirmed that the procedure could not be performed as written, in part,

because of references to actions for plant conditions that no longer existed in the 4 shutdown condition. Aithough the remote shutdown panel was still energized, the controls and indications provided there were for systems that either were not ,

operating or not useful for monitoring the spent fuel pool or the spent fuel cooling system. Procedure steps for combating an actual station fire were also provided in '

the procedure for station fires, AOP 3.2-57. The inspector concluded that there would have been no benefit for the operators to have manned the remote shutdown pane ;

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The inspector concluded that the procedures available at the time of the event did not help the operators mitigate the event. There was no guidance on how to respond to an inadvertent halon actuation (ANN 4.231, AOP 3.2 57). Procedures in the active status (AOP 3.2 57) referenced procedures in the "DO NOT USE" status (AOP 3.2 50). AOP 3.2 G7 contains some steps (tripping the reactor) that are no longer applicable to the defuel condition and should be revised to reflect the decommissioning status of the plant. When outside the control room, the operators did not ham ready access to procedures, and obtained copies of procedures by re-entering the control room. The operators need additional procedures for recovery from events like those on August 7, and for actions outside the control roo The procedure for classifying events, EPIP 1.51, did not have a specific EAL to help the operator classify the event for the shutdown and defueled condition of the plant. The inspector identified that the licensee administrative controls for procedure usage did not address the operator rules of use for AOPs. The licensee acknowledged this finding and issued ACP 1,2 6.22 to address this area. The inspector concluded deficiencies existed in the procedures for shutdown operations which hampered the operator response to the halon even Qglity of Procedures The adequacy of plant procedures has been a past NRC concerns (reference inspection 9010,97 01 and 97 03). The inspector met with Operations personnel to review the status of the efforts to revise procedures for shutdown operation The licensee status list shows a number of procedures in several categories that still require revision: convert 4 EOPs to AOPs; and change 7 AOPs to eliminate references to power operations or other wise make current for permanent shutdown operations). Numerous other system and normal operuting procedures require revision to reflect permanent shutdown status. While station Key Performance indicators show some reductions in the procedure revision backlog since March 1997, progress had been hampered by the lack of operations and engineering resources to revise and review procedures, respectivel As described in Section 01.4 above, other procedure deficiencies for the shut down operations hampered the operator in the response to events. The following ACRs were issued by the plant staff during the pcriod and show concerns renarding procedure adequacy in broad areas of plant activities: 97 605,606, FJ7,612,626, 607,691,688,689,697,701,710,724,741,749,764 and 76E, Licensee

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actions for r ych individual discrepancy were appropriate This item is unresolved

pending the wmpletion of actions to revise procedures for decommissioning operations, a d subsequent review by the NRC (URI 97 05 02).

c. Conclusions Although the licensee had initiated procedure reviews and revisions for shutdown conditions, procedures contained inappropriate references to power operations conditions and hampered operator responses to events in the defueled conditic The availability of adequate resources impacted the timeliness of revising . -_ - - . . - . - - - .- --.- ..- - - *

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i procedures for shutdown operations. While licensee actions to address individual procedure issues were appropriate, the findings indicate the need for continued licensee actions to address procedure quality for shutdown operation .2 Loos for Radwaste Operations I

The inspector reviewed the requirements for record retention and the licensee '

practices for maintaining logs of radwaste system operation A hard bound log book is enaintained at the auxiliary operator desk opposite the radwaste panel on the first floor of the primary auxiliary building. The inspector reviewed the log periodically during routine inspections of operating activities and i notcd that the log typically was used to povide a narrative description of radwaste ;

activities, including a record of waste transfers and release ;

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The inspector noted that the licensee practice was to discard the log book when tuli, and thus, past copies of the log book were no longer available for review. The ,

inspector reviewed this practice for compliance with the record retention i requirements in Technical Specification 6.10. The only applicable requirement was stated in TS 6.10.3.e, which requires that the licensee maintain for the duration of the f acility operating license..." records of gaseous and liquid radioactive materials released to the environment". The inspector requested the licensee to demonstrate how the requirements of TS 6.10.3.e were met without the radwaste lo The Operations Manager responded that the Shift Manager and control room logs, . l together with the radioactive discharge permits, were the official plant records used to comply with TS 6.10.3.e. Management expectations for log keeping were

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provided in procedures NOP 2.0 2 and ODI #1. The inspector reviewed both the radwaste and Shift Manager logs for typical operating activities covering the period from July 13 30,1997, and noted that both logs contained entries for the radwaste operations. The inspector also noted, based on past routine reviews of  ;

operating activities, that the control room logs contained entries regarding plant effluents made under the approval of discharge permits. The licensee otated that maintenance of the radwaste log was an initiative and was not required to meet record retention requirement Cone'usions Licensee practices regarding the maintenance of records for radioactive effluents -

. released to the environment met the requirements of TS 6.10 Operator Knowledge and Performance 04.1 Ooerator Errors Durina Routine Dutiet While operators performed routine duties generally well during this inspection period ,

(See Sections 01.1 and 01.2 above), exceptions to good performance were note ,

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The following human errors challenged stable plant conditions, and operator control of the plan Ons exception to good performance occurred on September 20 when an operator manipulated with wrong breaker on 480 voit Bus 4. The nuclear side operator (NSO) attempted to close the bleaker for the A service air compressor in response to directions from the control room operator. The NSO in!!! ally identified the correct breaker, but tripped the supply breaker for motor control center (MCC) 9. The error caused the loss of the radwaste ventilation system and other minor loads. The error was recognized and corrected immediately. There were no adverse radiological consequences or operational affects on spent fuel cooling due to the event. The licensee documented this event in adverse vundition report ACR 97-772; corrective actions were appropriat A second instance of poor performance was discovered on August 9 when operators attempted to pump down the containtnent sump, but were prevented due to the existence of a containment isolation signal that prevented the sump pump discharge valves from opening. The containment isolation signal was in effect because the high containment pressure (HCP) relays were tripped (ACR 97 583).

Further investigation determined that the HCP relays were inadvertently actuated on July 30,1997 when operators turned off circuits to equipment no longer in service, which included the vital 120 volt AC circuits powering the HAP circuits in the A1 and A2 reactor protection system cabinets. The licensee concluded the event occurred as a result of operator error in making the unreviewed and uncontrolled changes in the plant configurstion. The licensee reported the inadvertent containment actuation to the NRC per 50.72(b)(2)(ii) on August 8,1997, and as licensee event report LER 9714 on September 5,1997. The inspector reviewed the control room indications of the HCP actuation and determined that, once the isolation signal was generated, none of the subsequent checks routinely performed t'y the operator could have discovered the condition prior to the activities on August 9 to pump the sump. There were no adverse safety consequences of this event for the defueled plant conditions. Licensee corrective actions were appropriat The above human performance errors appear as additional examples of concerns previously identified by the NRC (reference lnspection item EA 97 366 issued October 7,1997). Licensee correctiv; actions to address personnel errors were in progress at the conclusion of this inspection. The licensee completed a common cause evaluation (CCE) of personnel errors (in response to ACR 97 444), which was completed on September 5,1997. The CCE identified 7 contributing causes for personnel errors, and made four recommendations to reduce errors. Licensee actions to address this matter were in progreas, and will be reviewed as part of the NRC follow-up to inspection item EA97-36 c. Conclusions Human performance errors and informal operational practices caused events that challenged operations. The effectiveness of licensee actions to reduce personnel errors remains to be demonstrate __

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06 Operationo Organization and Administration 06.1 Operatqr Staffino and Work Hours- inspection Scoqn The purpose of this inspection was to review the licensee actions to previdt operator resources for plant activitie Observations and Findinas The operations department staffing remained sufficient during this inspection period to staff 5 four person crews on a rotating shift schedule. Each shift had 1 senior reactor operator /shif t manager (SM),1 reactor operator / control opere. tor (CO), and 2 non licensed operators / nuclear side operators (NSO). The staffing plan met the requirements of Technical Specification 6.2.2 for the requirements for Mode 6 -

refueling. Additional anticipated transfers of operators expected by the end of 1997 would further reduce the number of qualified, experienced operators. The ,

reductions in qualified operators became a f actor in the licensee's planning for decommissioning activities, and contobuted to the consideration of alternative '

methods to conduct the full reactor coolant system decontamination (planned use of the reactor coolant pumps was abandoned in f avor of simpler operational methods to flush the loops).

The reductions in op; ator staffing and additional duties caused by the need for compensatory measures (fire watches) for degraded fire systems, resulted in the need for the routine use of overtime by the operators. The inspector reviewed the overtime worked by the operators during the period of July 16 October 1,1997, and noted that hours worked in excess of the administrative guidelines (reference TS 6.2.2.f) were approved in accordance with administrative procedure NGP 1.0 The operator staffing shortages and the chronic use of high work hours provided stress on the operators, as described in several ACRs, including 97 665,767,700, 742,739, and 767. The licensee had hired several contractor personnel for use as auxiliary operatore (log keepers), but actions were in progress at the conclusion of this inspection period to fully train and qualify these individuals, Conclusiom Reduced staffing in operations resulted in the chronic use of excessive overtim The lack of qualified operators was a factor in decommissioning planning. The effectiveness of licensee actions to address this area remain to be demonstrate __

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08 Miscellaneous Operations issues 08.1 Conclusions for Opera 11ent Performance varied in the quality of plant operations. Operators performed routine duties well to maintain spent fuel cooling and to monitor the status of the spent i fuel. Operators responded well to events or deficiencies that challenged spent fuel ,

cooling. Events and human performance errors challenged operators and hampered the ability to monitor and control plant conditions. Exceptions to good performance !

were noted in some informal practices (poor communications and the unreviewed actions to de-energize circuits). Inadequate procedures for decommissioning status of the plant hampered operator response to off normal conditions. Shortages were noted in operator staffing and the availability of qualified personne :

t 11. Maintenance  ;

M1 Conduct of Maintenance insoection Scone-Using Inspection Procedure 71707,61726 and 62707, the inspector conducted periodic reviews of plant status and ongoing maintenance and surveillance. The inspector reviewed licensee activities to test, troubleshoot and repair plant equipment, and to address enverging condition M 1.1 Mpintenance and Surveillance Activities During the inspection period, the inspector observed licensee activities to maintain and test plant equipment necessary to support the spent fuel pool and spent fuel pool cooling system, and to assure the operability of support systems, such as the service water, process and ef tiuent radiation monitoring, fuel oil, fire protection, ventilation, AC and DC electrical distribution, and the emergency diesel generator  ;

systems. During periods of degraded equipment performance, the inspector ,

observed licensee actions to correct the problems, to implement compensatory measures, and to implement the requirements of action statements prescribed by the technical specifications and the technical requirements manua The inspector reviewed portions of the following work activities:

e test and repair of the emergency diesel generators e replacement of letdown post filter FL 11 1 A e test and restoration of halon and fire detection systems e test of the seismic monitoring instrumentation e cleaning the B SFP heat exchanger o testing the spent fuel building ventilation system o testing of the diesel fire pumps e packaging and shipment of new fuel (see Inspection 97 06)  :

e installation of the new fuel oil storage tank

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• test and repair of several degraded SW valves in the SFP supply line (SW-V300, SW V1412, SW CV 963, SW V238)

The inspector verified the licensee followed the action statement of TS 3.9.15 at various times during the inspection period when the spent fuel pool cooling system was declared inoperable in response to discrepancies associated with of service water system valve material conditions (SW CV 963, SW V300, SW V 238), testing of SFP support systems (SW CV 963), and SFP system design (single f ailure considerations). The inspector also periodically verified licensee act!ons to meet the required action statement for the following requirements during periods of degraded equipment performance: TS 3.3.3.3 for the seismic monitor; TS 3.3. and 3.3.3.8 for the radiation monitoring systems (R18, R22, R148); and fire protection technical requirements manual (TRM)ll.1.E and ll.1.A for the fire detection systems and the control room halon actuation system. No inadequacies were noted in the licensee responses to the degraded equipment condition Maintenance persormi provide good support to operations in response to emerging conditions and followmg several events, such 1 the lightning strike at the facility, the restoration of the control room halon system, and the timely repair of degraded conditions in the SW supply to the spent fuel coolmg cystem. The industrial safety reviews and topple analysis (reference memorandun CY-TS-97 0401)to install the new fuel oil storage tank were thorough to assure tha work would not adversely impact plant or worker safet Seismic Monitor The RSA 50 seismic monitor system remained degraded due to a failure of the data play back system. Spare parts were not available due to the age of the syste Four of the five system components remained operable and capable of recording a seismic event at the station, including: the triaxial accelerometer, the digital cassette acceleiograph, the seismic warning panel, and the SMR 102 playback system. The operable instrumentation would provide indication to control room operators that a seismic event has occurred, and a trace of the vibration time history would be recorded on tape for subsequent analysis offsite. The data that is not immediately available would be the instantaneous response spectrum comparisons, which would be and indicator of the magnitude of the event. This information would be available to the licensee from offsite (such as from Millstone or the Weston Geophysical Laboratory).

The licensee notified the NRC in accordance with TS 3.3.3.a on August 14,1997 regarding the status of the seisneic monitoring system and the plans tu restore it to fully operational status. Engineering and design work was in progress at the conclusion of this inspection to completely replace the seismic monitoring system

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M1.2 Deficient Material Conditions - SFP Coolina Sunolv As in the past, deficient material conditions challenged the operators and affected  ;

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the reliability of the normal cooling supply to the spent fuel pool. The deficient conditions caused the licenses to use alternate cooling for the spent fuel pool (fPe 6 hoses). The fire hoses were in service as the licensee completed piping repairs, modifications and test activities to address material discrepancies in the SW lines to '

the SFP heat exchangers. The inspector reviewed licensee actions during this period to address degraded conditions in service water system. The deficiencies were identified during the conduct of routine testing per SUR 5.7 217, or during troubleshooting and repair activities following that test. The deficiencies included the failure of SW CV 963 to limit back leakage in the SW supply line to the SFP cooling system; the inability to meet test acceptance criteria for SW flow delivered .

to the SFPCS; the excessive leakage through SW isolation valve SW V300; and, the ,

mechanical f ailure (disk separated from stem) of SW isolation valve SW V23 ,

The licensee took appropriate action to address each deficiency, including the replacement of valves, the use of improved flow measurement instrumentation, and

revising the test methodology for the check valve test (discussed further below).

Engineering and maintenance personnel provided good support to operations to investigate and evaluate the conditions, and to expeditiously address deficiencies to return the SFP cooling supply to normal configurations as soon as possible. The licensee improved the methodology to backwash the B SFP heat exchanger per NOP 2.101, which was successfulin reducing the silt induced fouling and provide srme improvement in the heat transfer capacit During the routine quarterly test of SW CV 963 on July 24,1997, the check valve f ailed to meet the 2 gpm leakage criteria, causing the operators to declare the valve inoperable. The valve had been installed as a design change in April 1997 to eliminate the potential for waterhammer in the SW supply to the SFPCS during loss of normal power events. The licensee made an untimely 50.72 report of the issue *

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as a condition outside the design basis (see Section E8.1 below), and submitted

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licensee event report LER 97-12 to describe the follow up investigations and corrective actions. The apparent cause for the failed surveillance was a variation :n

the test methodology which presumable allowed debris to be back flushed into the seat area during system filling operations. The surveillance procedure was revised to assure debris could not be backflushed into the seat area. The check valve passed the test when this test deficiency was addressed; the next quarterly leak rate test was also successful. Although it was inconclusive whether the check valve was actually inoperable during the July 1997 test, the condition was conservatively roported per GO.73(a)(2)(li) as a condition outside the design basis. Licensee actions to address this matter were effective and appropriat M1.3 Conclusions for Maintenance Plant personnel performed well to address problems, including the troubleshooting ,

and repair of the emergency diesel generator EG 2A shutdown circuit. Plant personnel completed routine tests of plant equipment well, recognized degraded [

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conditions, and initiated actions to complete troubleshooting and repairs. Good work controls were notec', including good pre-job briefs, control of tagouts, and adherence to work packages. Licensee actions to maintain the operable portions of the seismic monitoring system and to initiate design work to replace the system entirely were acceptabl Ill. Enaineerina E1 Conduct of Engineering E1.1 Enaineerina Suomort for Operations and Decommissionina (URI 97-05-03)

Engineering provided effective support to plant operations during the period to address issues important to shutdown operations and decommissioning planning. In support of operations, engineering assisted in the successful resolution of: (l) the evaluation of surveillance tests and development of technical and safety evaluations (to improve the methodology for leak testing SW CV 963 SY EV 97 001, SY EV 97-002 and SY EV 97003);(ii) the development and implementation of detailed testing and root cause investigation of the control room halon actuation; (iii) the troubleshooting and repair of emergency diesel generator problems; (iv) the identification and prompt operability assessment of an anomalous operation of the spent fuel building ventitetion system (a CMP finding - see ACR 97 680 and 610 below); (v) the development of revised cleaning methods to reduce fouling in the B SFP heat exchanger; (vi) the investigation of plant performance following a lightning strike (memorandum CY-TS-97 0497);(vii) the evaluation of the electrical distribution for spent fuel power supplies (ACR 97 457);(viii) the evaluation of backup water supplies for the spent fuel pool (SY EV 97103); and (ix) the completion of common cause evaluations for personnel errors and procedure adherence (CY JDH 97-004).

In support of decommissioning, engineering: continued to implement the process in ENG 1.7156 to categorize plant systems; made progress in the completion of decommissioning planning (GRPIs), particularly in the areas, of calculations and analyscs to support long term storage of spent fuel (see below); developed plans and procedures to remove a reactor coolant system artifact to use in the evaluation of decontamination solutions; and, developed revised procedures and made preparations to optimize the geometry of fuel stored in the spent fuel poo Assessments and safety evaluations completed in support of operations and decommissioning activities were reviewed by the inspector while in progress ared were technically sound and adequately documente The licensee submitted the Post Shutdown Decommissioning Activities Report on August 22,1997, which initiated a 90 day period for the NRC staff to obtain public comments and to determine whether the report met the submittal requirements of 10 CFR 50.8 _ _ . . _ __

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SFB Ventilation In support of reviews to define the licensing and design basis for the Spent Fuel Building Ventilation System, site engineering (Configuration Management Group)

identified the need to test the system to obtain performance data. A test conducted during this period identified design deficiencies that constituted conditions outside the original design basis. These conditions were reported to the NRC per 50.72 on August 25,1997 (ACR 97 680) and October 3,1997 (ACR 97 810). The licensee found that the SFB exhaust f an could not deliver flow at the design condition of 13,000 cim. Engineering completed timely operability assessments and investigated the causes for the discrepant conditions. The SFB fan performance deficiencies occurred as a result of a 1974 modification that replaced the original primary auxiliary building exhaust fans with higher capacity fans. The SFB exhaust flow decreased when the PAB f ans operated since the SFB fan exhausted to the main stack via a ventilation path just downstream of the PAB fans. NRC review of this event was in progress at the conclusion of this inspection (URI 97 05 03).

SFP Calculations The licensee completed additional analyses of the safety of the fuel; stored in the spent fuel pool, and showed good regard for plant safety by analyzing events considered beyond the design basis of the plant. By letter dated September 26, 1997 (CY 97 066), the licensee submitted for NRC review the results of an assessment of a loss of all water in the spent fuel pool. This assessment included calculations by the licensee's vendor, Holtec Report HI 971705. The calculations determined the date by which the fuel decay heat level would be reduced to the point that cladding temperatures would remain below the ignition point assuming all water was lost from the spent fuel pool One assumption for this calculation was that the configuration of the stored fuel would be optimized to assure that the zircaloy clad fuel was interspersed amongst the stainless clad fuel and that the new racks would be used. Licensee actions were in progress at the conclusion of this inspection to optimize the pool configuration to meet the calculation assumption NRC:NRR review of the licensee's submittal was also in progress at the conclusion of the inspectio E1.2 Follow-up on Enforcement issues Status of Previous inspection items (Open) Violation 97+1108, Failure to Report inoperabia Residual Heat Removal Pump. The licensee responded to this matter by letter dated February 13,1997 (810121)to describe the corrective actions to preclude recurrence. The licensee stated that additional guidance would be provided on performing operability and ,

reportability evaluations. The guidance would include a requirement to consider a component inoperable whenever it is determined that the equiprnent was not maintained in such a manner to assure its design basis. The licensee committed to revise procedures by June 30,1997 to issue the new guidanc __

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The licensee identified a failure to meet its commitment in response to item 9611-08, as described in a letter to the NRC dated September 25,1997 (CY 97 093).

The action to address the violation was related to an action in response to LER 96-24, which was linked in the licensee's corrective action process. Subsequent to the February 1997 response, the licenace decided to split the reportability and operability processas, and to write separate procedures for each. The effort to was scheduled to be completed by September 30,1997. The action to address the violation was linked to the September 30 effort, and the June 1997 commitment was overlooked. The licensee issued two new procedures on September 26,1997:

ACP 1.2 2.82, Operability Determinations; and ACP 1.2 2.44, Reportability Determinations and Licensee Event Report Processing. This item remains open pending completion of the licensee action to implement the operability and reportability guidance, and subsequent review by the NR The licensee identified other weaknesses in its programs and processes to meet NRC commitments, as described in ACRs 97 753 and 97 779. In the June 11, 1997 response to the NRC's May 12,1997 Enforcement Action and Civil Penalty and as part of the changes to improve corrective actions, the licensee committed to make new procedures include standardized causal factors codings to provide the necessary data to f acilitate the recognition of programmatic or recurring causes and evaluate the effectiveness of corrective actions. This commitment was to be implemented by the second quarter of 1997, but was not done (ACR 97 753).

Similarly, a OA audit identified that there is no formal process to incorporate NRC inspection commitments into station procedures, which resulted in the f ailure to incorporate Nuclear Oversight surveillance of radwaste processing activities on a monthly basis (ACR 97 779). In addition to the corrective action for these specific discrepancies, the licensee changed the tracking processes to give increased visibility to the tracking of NRC commitments. Those commitments already entered into the new Action Tracking System (ATS) were published and discussed weekly as part of the morning management meeting. Licensee actions were in progress at the conclusion of the inspection to better track items stillin the Action item Trending and Tracking System, and to issue a new procedure to enhance the process (ACP 1.2 2.62 Regulatory Commitment). The effectiveness of licensee actions in this area remains to be demonstrate Status of Coriective Actions for Escalated Enforcement Licensee engineering and support staff completed several projects during period to support decommissioning projects and to address program and prout:. weaknesses that were the subject of previous NRC violations. Thu licensee issued the Design Control Manual, along with a revised process to control the plant configuratio The Configuration Management Group completed the review and definition of the design and licensing basis for systems needed to support spent fuel storage and decommissioning. As reported previously, the licensee revised the corrective action program and continued to implement the new process. Finally, the licensee revised the process to upgrade the UFSAR and issued two new sections internall The licensee plans to submit a completely revised UFSAR to the NRC in December in 199 _ __- _ . _ . _ _ _ . _ _ _ . _ . _ . _ ___ _ _ _ _ _ _ - _ _ _

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E1.3 C.onclusions for Enoineerina Suooort  :

Engineering provided effective support to plant operations and decommissioning

_ planning during the period. A good regard for spent fuel safety was noted in the actions to address beyond design basis events for the spent fuel pool. Mixed performance was noted in licensee actions to meet NRC commitments. The l effectiveness of licensee actions to address process weaknesses to meet commitments remains to be demonstrate E2 Engineering Support of Facilities and Equipment

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E Controls for Soent Fuel Pools NRC Bulletin 94-01 (IFl 97-05-04) laitoection Scope (730511 The purpose of this inspection was to review the licensee controls for the spent fuel pool relative to the issues identified in NRC Bulletin 94 01. NRC Temporary ,

instruction Tl 2561/002 was used for this revie ; Observations and Findinaji Backaround  ;

On April 14,1994, the NRC issued Bulletin 94 01 to nuclear plants permanently shut down by that date, in reaction to a potential spent fuel pool (SFP) drain down event caused by inadequatc; maintenance practice:. 3t Dresden Unit 1. At Dresderi, a piping system, not connected to the spent fuel storage pool, experienced a frozen pipe that ruptured, and resulted in the loss of 55,000 gallons oi water from the impacted system. There was a potential for a similar pipe rupture in systems communicating with the fuel pool. The bulletin required licensees of permanently shut down plants to verify that the SFP eith3r was not susceptible to the Dresden ev6nt or to modify the SFP, supporting structures and systems to ensure against the Dresden event. While the Haddam Neck Plant was not shut Jown at that time, the licensee, af ter permanent shut down, took a prudent course of action and initiated a response to the bulletin. However, that response will not be completed untillater in 199 The NRC issued Temporary Instruction 2561/002 (TI) that included an inspection program that addresses potential mechanisms that could lead to pool drainage and -

possible loss of integrity of stored spent fuel. The purpose of the Tlis to provide NRC inspectors with guidance to enable assessment of the adequacy of protection provided for the storage of spent fuel. This was accomplished through inspections of: (1) management oversight, (2) quality assurance, (3) fuel storage practices -

(foreign materials exclusion), (4) fire protection. (5) maintenance of fuel pool and its associated equipment, (6) fuel pool water chemistry, (7) siphon and freeze concerns and 18) training.- Those portions of the Tl covering the 1997 safety review program (10 CFR 50.59), emergency preparedness, and radiat!on protection were the subject of other inspections.

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(1) Manaaement Oversiaht The inspectors through interviews with upper level plant management, interviews with mid level and first line supervisors and review of detailed plant staff organization charts, determined that the plant organization as related to spent fuel 1

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integrity is adequate. The inspectors determined that both the Radiation Protection Manager and the Manager of Oversight (Quality Assurance) have a direct reporting link to the Director of Site Operations, which assures independence from plant operation The inspectors reviewed the numb;'a of plant staff and contractor personnel and ,

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the adequacy of management support to this staff. The inspectors conclude that staff size and management support is adequat ;

CY management has instituted a " Work Observation Program" which la designed to  ;

provide self assessment of the recent changes effected by the CY managemen Supervisory and management personnel have been trained in this program and CY plans to bring in outside expertise to participate in the progra ,

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( 2) Quality Assurancs

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The quality assurance function at CY has been renamed Oversight. The inspectors reviewed many audits of the former Quality Assurance organization dated from to July 1996 through 1997 and interviewed quality assurance personnel including the department manager. Based on the audit reviews and the personnelinterviews, the

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inspectors find the new Oversight organization to be adoquat .

(3) Forelan Material Exclusbn (FME)

The inspectors interviewed a member of the plant staff responsible for this program and also reviewed two of the program documents, Foreign Material Control and Spent Fuel Pool Housekeeping, in addition, the inspectors conducted a walkdown of the fuel pool. Licensee self assessments identified areas for improvement in FME controls (ACR 97 497). Based on these considerations the inspectors conclude that CY has an adequate FME program in plac (4) Fire ProtectioD The inspector;. verified that the licensee has a fire protection program and that it was applied to the structurcs and systems related to spent fuel storage. The '

inspector reviewed the Fire Hazards Analysis description for SPENT FUEL AREAS ,

(Fire Area F 1, Zones A, B, C, D) and confirmed that hazards in the zone were as analyzed, and that the credited fire detection (ionization / smoke) and suppression equipment were provided as described in the FHA. The inspector toured the spent fuel areas to verify that plant conditions for transient combustibles matched those

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Resident inspections of routine activities during testing and inspections have found the staff performed well to assure the TRM requirements have been met, such as during the times to troubleshoot the diesel fire pump, or to conduct required surveillances which require entry into the TRM action statements. The inspector verified that fire brigade was being maintained per the requirements of TRM ll. for staffing, shif t coverage, qualifications. The inspector reviewed records for the period of April 27 to July 19,1997 and verified the licensee met the requirements to maintain a five man fire brigade (FB). This review identified that two crews (D &

E) were light on qualified FB members, which has resulted in significant administrative effort and NSO rotations to keep th e brigade staffed. The licensee had cctions in progress to train and qualify the rec.intly hired contractors in operations to augment the qualified FB staf Based on the above, the inspector concluded that the licensee had adequately applied the fire protection program to the spent fuel area. The control of SFC fire :

hazards and fire protection program controls was goo ) Maintenance of Fuel Poo! and Associated Eculoment NRC Regulation 10 CFR 50.65(a)(1) requires the licensee of a permanently shut down plant to maintain the spent fuelin a safe condition and outlines the scope of an acceptable maintenance program for such a plant. The inspectors, as noted in Section (7) below, reviewed Procedure PMP 9.9146, related to freeze protection, interviewed the Maintenance Manager end conducted a walkdown of the Fuel Storage Building and its systems. This limited inspection did not show any -

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inadequacies in the maintenance progra (6) Fuel Pool Water Chemistry The licensee maintained a well defined chemistry program with PORC approved procedures in affect (CHM 7.4-1 and SUR 5.4 4). The procedures were technically acceptable ana implemented the requirements of TS 3/4.9.1 and 3/4.9.13. The program established limits for contaminants that will assure clarity and purity of poo! water. The limits were based on original Westinghouse specifications. The inspector reviewed data for samples collected to date in 1997. Analyses were made of the parameters listed in Section 6.4/ Attachment A, and r.t the frequency required by the procedur Licensee radioisotopic analyses results showed thsre were no indications of fuel '.

leaks in pool or clad defects. Chemistry parameters / impurities were maintained within the established limits, and deviations were highlighted for supervisory review and trending. One exception was for silicates (SiO2), which has consistently exceeded the limit of 1.0 ppm (in the range of 1.02 to 1.41 in 1997). The licensee had a justifiable basis for accepting tMs condition, and demonstrated there was no corrosive action on the fuel. The licensee planned to re-evaluate the 1.0 limit and intends to process a procedure change as part of the transition to the nuclear island (ACR 97-467 and QA Surveillance CY-P-97-063).

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As noted above, deviations in chemistry parameters were generally highlighted for supervisory review and trending. One exception to good performance was that the out of specification SiO2 parameter had not been highlighted or trended. This matter was disctissed with the Chemistry Manager during the briefing on July 25, 1997, who stated the matter would be addresse The SFP makeup water is nuclear grade primary water, with no relaxation in standards planned. The boron 10 concentration was maintained per license requirements, to assure the K effective limits were satisfied. The SFP skimmer and purification systems were normally in service to maintain pool clarity. Licentee data showed consistently good decontamination factors across the SFP lon exchanger Pool cleanliness conditions were very good, with good clarity and no large debris visible by observations from the dock. One minor exception was that the skimmer was not fully effective in removing debris (bugs) on NW corner of pool. The licencee subsequently addressed this condition. While no debris on top of the fuel won visiNe form the deck, fuel debris in past had impacted the ability to complete the audit of special nuclear material per the procedure requirements. This area was also the subject of recent licensee findings (ACR 97 655). Licensee, 'ngineering staff was reviewing the industry operating experience regarding debris in the SFP for lessons learned and applicability to Haddam Neck, in summary, the oversight and control of SFP chemistry and water purity was very goo (7) Leakaae, Siohon and Freeze Concerns The licensee has conducted a study of those piping systems that communicate with the SFP and could possibly produce a siphoning event. The inspectors reviewed the study, interviewed cognizant licensee personnel involved in the study, reviewed system drawings, and conducted an independent walkdown of the SFP and its systems to determine if any pipe or hose lines, not shown in the drawings or study, might provide a potential siphon path. This walkdown confirmed that there does not appear to be any such undocumented siphon path Siphoning or pool drainage could also be related to a freezing event. Such an event could only occur in pipe lines or components that communicated with the SFP and had an outdoor component in the system. The only such system is the Spent Fuel Pool Purification Loop. This is a pipe line that is insulated and electrically heat traced in the outdoors portion of the system. The heat trace circuit contains an ammeter which is monitored every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and would indicate a loss of electrical heat. There is a level monitor in the SFP that alarms in the Control Room and would immediately indicate a pipe break due to any cause. The licenseo plans to take this loop out of service after the winter of 1997/98 and replace it with a totally indoor loop, thus eliminating the freeze hazard. If failure of the current freeze protection is postulated, it would take more than the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> interval of curator rounds to cause the warm flowing water in the pipe to freeze, expand and ourst the pipe. The licensee has an established preventive maintenance pro', ram for the heat trace circuit that is contained in procedure, PMP 9.9-146, F.eeze Protection Equipment

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Preventive Maintenance. This procedure was reviewed by the inspectors and found adequat The licensee has noted ambiguous indications of minor leakage from the poolline Small amounts of water are collected periodically from a standpipe at the southeast corner of the SFP. The water has shown boron and radioisotopes, but not at concentrations that match those in the spent fuel poo!. This matter has been the subject of past NRC review (reference Inspection item 94-09-02), as well as recent focus by the licensee to improve the leakage monitoring program and further investigate the liner status (ACRs 97 608,658). Licensee actions to invertigate SFP liner leakage will be followed on a subsequent inspectio Based on the above considerations, the inspectors conclude that leakage monitoring, siphoning and freeze protection at the Haddam Neck Station as related to spent fuelintegrity meets the intent of Tl Sections 03.05 Siphon Concerns and 03.06 Freeze Concern (8) Trainina Connecticut Yankee has in place, a detailed training program for both new and experienced employees at the Haddam Neck Plant. The inspectors reviewed only those programs related to the maintenance of spent fuelintegrity under normal and exigent conditions. The inspection was conducted through interviews with Training Department personnel, review of Training Department Manuals, review of training aids, review of course content and other details of trainin0 related to spent fuel integrity. These programs covered both requalification training for licensed operators and non-licensed operator continuing training. The Senior Resident inspector attended a CY training session. NRC currently has under review the Certified Fuel Handler Training Manual. Certified fuel handlers will replace licensed operators only af ter the NRC issues a license amendment to that effec Based on the above considerations, the inspectors conclude that the training programs at the Haddam Neck Station as related to spent fuelintegrity meet the intent of Tl Section 03.11 Training, c. Conclusions The licensee was working to implement Bulletin 94-01 and should complete this work by the end of 1997. For the portions of the Bulletin areas that were inspected at this time, the inspectors found all of the programs reviewed in Sections (1)

through (8), above, to be adequate. This area will remain open until af ter the NRC reviews the licensee's response to the 'oulletin, and pending further NRC review of the results of the liner leakage monitoring program (IFl 97-05 04).

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E8 Miscellaneous Engineering issues E Review of LERs and Teleobonic Notifications (URI 97-05-05) insocction Scope (927QD. 90712)

The purpose of this inspection was to review prompt reports and licensee event reports (LERs) to verify the requirements of 10 CFR 50.72 and 50.73 were me Observations and Findinas The following event reports were found to be acceptable. The references in parentheses refer to the sections of this report that describe further NRC review of the event. The LERs listed belew are considered close * LER 9711, SFP Cooling System Outside the Design Basis'

• LER 9712, Excessive Check Valve Seat Leakage (Section M1.1)

• LER 9713, inadvertent Halon System Discharge (Section 01.5)

• LER 9714, Containment isolation Actuation (Section 04.1)

• LER 9715, RMS Test Not per Technical Specifications (Section R2.1)

• This event was reviewed in inspection 97 03, Section E The inspector reviewed licensee actions to make prompt notifications to the NRC per 10 CFR 50.72, including those made on: July 29 for Event 32693 (SW check valve leakage), August 4 for Event 32719 (SFP Cooling Flow Test), August 7 for Event 32736 (Halon Event), August 9 for Event 32745 (Containment Isolation), and October 10 for Event 33027 (Offsite Contamination). Notifications on August 25 (Event 32812) and October 3 (Event 33026)concerning the spent fuel building ventilation system were still under NRC review at the conclusion of this inspection, and will be reported in a subsequent NRC inspection. Except as noted below, the inspector had no further comments in this are On July 24,1997, the licensee completea c test of a check valve in the service water (SW) supply to the SFP heat exchangers, SW CV 963. The valve f ailed the acceptance criteria by allowing greater that 2 gpm backflow. The excessive back leakage rendered the valve incapable of performing its design functions to mitigate a water hammer during loss of normal power events. The check was declared inoperable, and ACR 97 484 was written to initiate corrective actions and a reportability evaluatio ACR 97-484 was reviewed by the Management Review Team (MRT) on July 25, and was assigned to system engineering to complete a reportability evaluation within 5 days. The engineering review on July 29 determined that the failure to mest the test acceptance criteria placed the spent fuel pool cooling system in a condition outside its design basis (see LER 97-12) and was reportable per 10 CFR 50.72(b)(1)(ii)(B). The telephone notification was made to the NRC duty Officer at 10:19 a.m. on July 29. However, the inspector reviewed the above sequence of l

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events, and questioned why the report had not been made on July 24 when the i valves was declared inoperable. The inspector's concerns were discussed with the i Unit Director on July 29. The licensee's review of the reportability sequence was provided in memorandum REB 97 800 dated August 1,1997, which concluded that j the 50.72 notification was not timely and should have been made at the time the check valve was declared inoperable on July 24. The licensee initiated ACR 97 530 in response to this concer As recently as March 1997, the licensee had completed a reportability evaluation )

which concluded that a water hammer event in the service water system could >

render the SFP cooling system inoperable, and that SW CV 963 was necessary to eliminate the potential for this event. Potential contributing factors for the untimely 50.72 report included: whether the Shif t Managers had been provided adequate information regarding the March 1997 evaluations; whether the individuals involved in the reportability reviews on July 24 had sufficient informat ion to recognize the significance of the f ailed check valve test; the licensee test procedures (SUR 5.7-217) did not provide clear guidance on the significance of the f ailure to meet the test acceptance criteria; and, the MRT reviews on July 25 were not sufficient to recognize the significance of the degraded valve conditions. The licensee's evaluation of the event identified similar finding The inspector reviewed the licensee's performance history to complete timely reports per 50.72. Although reporting practices generally meet the requirements, past NRC findings regarding adequate reporting were described in Inspection item 90 11 08. The inspector determined that the licensee action to address the violation described in item 961108 might have prevented the untimely reporting of the July 24 event; however, problems were noted in comp'eting commitments, as described in section 01.3 abov Licensee actions to address the inadequacy identified in ACR 97 530 and to assure the timely reporting of cond tions will be reviewed on a subsequent inspection. The adequacy of licensee actions to assure events are reported per 50.72 is unresolved (URI 97 05 05). Conclusions Mixed performance was noted to make timely reports por 10 CFR 50.72, and to complete correct!ve actions to improve the toportability proces _ _ . _ - - - - . . - - . _ - . - - - - _ - . _ - _ . _ - . - - - - . . . _ - - . - -

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IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls

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RI .1 Offsite Centamination and Radiation Surveys  ;

! Insoection Scoos (83729)

The purpose of this inspection was to review the licensee activities to monitor - '

preliminary scoping onsite surveys for site characterization, and to conduct reviews of offsite properties for potential contamination from licensed material, Observations and Findinas inspection 97 08 reported the NRC review of licensee efforts to complete onsite  ;

scoping surveys for site characterization, and to identify the extent and nature of licensed materials that became uncontrolled and released from the plant sit Licensed material was identified in a landfill located outside the protected area but on the owner controlled area (ACR 97 450). Inspection 97-08 addressed that matter, inspection 97 07 described past NRC reviews and licensee surveys of

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private property offsite that received fill material from Haddam Neck. During this inspection period, the NRC reviews of licensee efforts to conduct contamination surveys both onsite and offsite continue The NRC worked with the licensee and the Connecticut Department of i Environmental Protection (DEP) to conduct radiation surveys offsite, and in public accessible areas onsite. The offsite radiation surveys included gamma scans, fixed point surveys, in situ gamma spectroscopy and environmental samples that were split three ways for independent analyses. The inspector reviewed the conduct of the licensee surveys by independently monitoring radiation instrumentation readouts >

as surveys were taken, and by assuring instrumentation was properly calibrate NRC split samples were analyzed by the Region Ilaboratory in King of Prussia, Pennsylvani The survey of offsite areas was stillin progress at the end of this inspection. A summary of the NRC's analyses and findings will be provided in a subsequent ,

inspection when all surveys are completed. For all offsite areas surveyed as of October 6,1997, no plant related activity was identified except in one, that designated as Survey Location 9608.- ,

Sptvev 9608 During interviews with licensee personnel on October 1, the inspector identified that i the licensee analysis of a soil sample from Location 9608 was potentially positive for cobalt 60 (Co 60). The preliminary licensee finding was identified on September 29, but no action was taken to confirm or communicate the results. The licensee suspected that the sample may have been contaminated by handling within the onsite laboratory located inside the radiation controlled area. Actions were in

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progress in October 1 to ship the licensee samples to the environmentallaboratory in Massachusett The inspector immediately informed NRC management and the Connecticut DEP of the potential positive results so that NRC and DEP samples could receive expedited processing and analysis. The "ccnsee was requested to count its samples a cacond time onsite, which was analyzed as negative for Co 60 af ter wiping the ex, 'nai surface of the sample container. The samples were sent on an expedited bi i to the environmentallaboratory. By October 2, both licensee and DEP analyses were reported positive for CO 60. The NRC results were also positive, as listed below:

Ep.rDDig Co-60 Result foicoCi/nm)

9608CS001 0.076 + \ 0.004 9603CS002 0.075 + \ 0.004 ,

9608CS003 0.076 + \ 0.004 9608CS004 0.025 +\ 0.004 -

NRC, licensee and DEP results were in general agreement. The property owner was notified of the results. The licensee issued a press release summarizing the sample results, and provided an assessment of contamination level, and the associated exposure dose rates. The WRC's independent assessment indicated that the trace levels of Co 60 produced no measureable dose rate of above background using micro R meters. Further, NRC analyses of the potential dose resulting from the trace contaminates, indicated that the annual dose received would be significantly less than that received from natural background (i.e., approximately less than 1 % of that received for natural background.) Licensee, NRC and DEP actions were in progress at the conclusion of the ir spection to fully assess the causes, extent and required corrective actions for the contaminated soils at Location 960 On October 2,1997, a telephone conference was conducted between NRC Management and the Haddam Neck Directur of Site Operations and Decommissioning to review the performance weaknesses relative to the initial onsite handling of the 9608 samples and the communication of preliminary result Drotocols and expectations for the communication of samples results were established. The licensee abandoned the practice of bringing the soil samples into the RCA for a preliminary analysis prior to processing at the environmental laborator Reauests from Concerned Citizens The inspector also responded to requests from citizens during the period, who had not received fill from the site but were concerned regarding the potential for radioactivity on their property. The inspector responded to residences at Maple Avenue in East Haddam on October 4, and at Rock Landing Road in East Hampton on October 21. The inspector conducted radiation measurements using a calibrated Eberline E600 survey instrument with an HP 300 geiger-mueller probe. The detector was sensitive to radiation at environmentallevels. The inspector performed exposure rate measurements at both locations in areas of interest to the

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were identifie Conclusigna NRC reviews of licensee offsite contamination surveys continued at the end of the inspection, along with an assessment of the licensee past practices for handling  :

potentially contsminated materials and fill from the site. Licensee practices to process ensironmental samples in the onsite counting laboratory were poor, as was the preliminary handling of sample 9608 and the communication of preliminary ,

result RI.2 Review of Radioloalcal Controls and Radiation Surveys

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! insoection Scoce (83722) ,

I The purpose of this inspection was to review the licensee activities to provide radiological control of plant activities, Observations and Findinog t

During inspection tours, the inspector toured the radiological controls area Jfed reviewed radiological controls and contamination controls. Access to various ,

radiologically controlled areas and the use of personnel monitors and frisking methods upon exit from those areas was also obacrved. Posting and control of "

radiation areas, contaminatad areas and hot spots, and labeling and control of containers holding radioactive materials were verified to be ir, accordance with licensee procedure The inspector reviewed the licensee follow up to the discovery of a hot particle on -

the spent fuel bridge on August 15,1997, which was discovered during surveys in -

support of inspections to document the fuelinventory in the pool. The particle read 50 mrem /hr with an R^ 2 closed window reading, and 150 mrem /hr in the open window readin Work was stopped and the bridge was evacuated. Personnel were checked for contamination by frisking and the PCM 1. No personnel contamination was foun The particle was removed for further analysis and largo area swipes were completed to locate any other particles. None were found. The licensee believes the particle came from the spent fuel pool as tools were removed during the inventory wor The event was documented in ACR 97 624),

' Conclusions The radiological controls for routine work was acceptable. No inadequacies were identified in the licensee follow-up of the discovery of a hot particl ,

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R2 Status of RP&C Facilities and Equipment s R2.1 Effluent / Process Radigilon Monitorina Systems (RMS) Calibration Insoection Scoce (929041 During the previous inspection of the radioactive liquid and gaseous effluent control programs conducted on February 3 7 and February 24 26,1997, an apparent violation (eel 50 213/97 02-01)and an unresolved item (URI 50 213/97 02 02)

were identified relative to the RMS calibration methodology (See inspection Report >

No. 50 213/97-02 for detail). The licenses submitted to the NRC the " Revised Commitments and Corrective Actions" for the apparent violation on August 7, 1997. During these inspections (August 1."t 13 and October 6 9,1997), the inspector reviewed the licensee's correctivo actions to determine their ,

effectivenes ObservttignLand Findinos l b.1 Adeauacy of R9yi.udfMS Calibration Procedures and Techniaues

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The inspector reviewed the following revised calibration procedures and calibration results of effluent / process RMS to determine the adequacy of the corrective actions:

• Main Stack Noble Gas Radiation Monitor (R 14A);

e Main Stack Wide Range Noble Gas Radiation Monitor (R 148);

e Radioactive Liquid Effluent Radiation Monitor (R 18);

• Spent Fuel Pool Radiation Monitor (R 19); and

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• Test Tank Effluent Radiation Monitor (R 22).

Revised electronic and radiological calibration procedures associated with the above RMS were well developed and incorporated applicable industry specifications and guidance (e.g. Regulatory Guide, ANSI, and EPRI) Calibration results were within the licensee's acceptance criteria, including linearity tests and conversion factor determination. The inspector noted that the licensee's data reduction techniques were sufficient to demonstrate the validity of the calibration results. The inspector noted that the licensee purchased new calibration sources and used correct geometry for the liquid RMS calibration. The inspector also noted that the above RMS were operable during this inspectio The licensee stated that the electronic and radiological calibration procedures will be combined as one procedure in the near future to avoid multiple work orders. The inspector stated that one procedure for the electronic and radiological calibration was a common practice and was acceptable to the NRC. The licensee's decision to delete !* steam generator blowdown radiation monitors (R 16 A&B) from the TS!'M ' requirements was acceptable since this monitor is no longer used, since cessfm ,1 plant operation :

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b.2 Flowmeters. Isokinetic Norrie, and ScanRad Comouter System The licensee ordered identical flowmeters for R 18 and R 14A. These flowmeters were scheduled to be installed and calibrated for use by September 30,1997. The inspector reviewed calibration results and me results were acceptabl The licensee identified that the sampling station for the main stack noble gas radiation monitor (R 14A) was not provided with the isokinetic nozzle, however, the main stack wide range noble gas radiation monitor (R 'i48) was connected to an isokinetic sampling device. A redundant sampling pathway was installed, using the R140 isokinetic nozzio, to permit isokinetic sampling with the R 14A monitor. The inspector verified that the corrective action for this issue w ts complete and acceptably performe The licensee used the ScanRad computer system for RMS data acquisition, however, the system had malfunctioned about one month after installatio Subsequently, a new ScanRad computer system was installed with upgraded sof tware. The inspector confirmed that the system has operated miiably sir e June 20,199 b.3 UFSAR and Technical Soecification (TS) Adeamtay The licensee reviewed the UFSAR and TS requirements for the effluent / process RMS as part of the review of unresolved item, URI 50 213/97 02-0 On August 13,1997, during review of the UFSAR/TS requirements, the licensee identified a discrepancy involving the channel functional test relative to the table I notation (Tables 4.3 7, Radioactive Liquid Effluent RMS: and 4.3 8, Radioactive Gaseous Effluent RMS) of the TS and the TS definition. Tables 4.3 7 and 4.3 8 of the TS requires the performance of a quarterly channel functional test for the subject effluent RMS channels. This quarterly requirement refers to th6 channel functional test as an Analog Channel Operational Test (ACOT)in the TabM Notations. The notation described that the ACOT shall demonstrate that centrol room alarm annunciation occurs if any of the following conditions exist: Instrument indicates measured level above the alarm / trip setpoint; j Instrument indicates a downscale f ailure or circuit f ailure; and Instrument controls not set in operate mod However, Section 1.2 of the TS defines that "An ACOT shall be the injection of a simulated signalinto the channel as close to the sensor as practicable to verify OPERABILITY of alarm, interlock and/or trip functions. The ACOT shallinclude adjustments, as necessary, of the alarm, interlock and/or Trip Setpoints such that the Setpoints are within the required range and accuracy." The quarterly test method in SUR 5.1-11 did not use a simulated signal to perform the ACOT as described in Section 1.2 of the TS. The setpoints were lowered to the point below

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The licensee initiated an Adverse Condition Report 97 612 to establish corrective actions, to evaluate the issue for reportability and operability, and to track deposition of the item. The RMS were considered operable since action had been completed in July 1997 to re calibrate the RMS using new procedures that met the TS definition for ACOT. The licensee planned to use the new calibration procedures to check the RMS channels as the next quarterly test came due, pending the development of new procedures that incorporated the TS requirements. The licensee developed and issued procedures SUR 5.2134 (RM 14A),5.2135 (RM 18)

and 5.2136 (RM 22) on October 10,1997. The new procedures incorporated a test method that injected a test signal as close to the detector as practicable. The licensee reported this event to the NRC per 10 CFR 50.73(a)(2)(1)(B) as licensee event report LER 97-1 The inspector was informed that the review of the UFSAR/TS was ongoing. As a result of this review, the licensee committed to update the UFSAR/TS as appropr! ate. Accordingly, the licensee submitted the *Defuelir ? TS" change to NRR. The inspector reviewed the Defueling TS with resput to the RMS. The fl.1al updated UFSAR, with associated documentation, was reviewed during the inspection conducted on October 6-9,1997. The inspector did not identify any discrepancies with the Defueling TS or UFSA The licensee was requested by the NRC to evaluate the impact of any potential inaccuracy on past operation by comparing past surveillance results with the results obtained using new calibration sources and improved procedures. An independent historical operability assessment wac performed by a contractor. The contractor identified several weaknesses which resulted in reduced sensitivities and increased the uncertainties for effluent RMS over the years. Although these weaknesses existed, the calibration data suggested that all effluent monitors reviewed were adequate to monitor and detect increases in normally expected effluent releases with the exception of R 22, the waste test tank monitor. This monitor had several significant weaknesses which affected the operability and accuracy of the monitor for many years. Notwithstanding, the inspector noted that the final discharge water was monitored by the radioactive liquid effluent radiation monitor (R 18),

downstream of R 2 b.4 Root Cause Evaluation The licensee submitted the root cause evaluation results of the previously identified RMS deficiencies to the NRC (Revised Commitments and Corrective Actions dated August 7,1997). The inspector reviewed the root cause evaluation results. The licensee identified that the RMS inaccuracies were introduced during a major revision to calibration procedures which inadvertently changed the t'alibration methodology and the responsibility (from the Chemistry Group to the I&C Group).

The following causes were identified by the licensee:

• inadequate management oversight of the work transition process;

• weak engineering input during procedure revisions;

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• lack of followup on previously identified problems with the ScanRad computor; and e inadequate Plant Operations Review Committee (PORC) review of the procedure revision The licensee evaluated the effectiveness of the PORC review process and made improvements through: (1) changes in membership; (2) process changes in the administrative controls; (3) clarification of expectations; and (4) training PORC members in ti.. associated responsibilities and performance expectation The C < -' r "w:ertment participated in several elements of the RMS improvew . o eluding: (1) review of calibration procedures; (2) review of documen..m m .ir calibration source traceability; (3) observation of the work activity; (41 ruview of system modification documentation and implementation; (5) program enhancements; and (6) oversight of engineering input during procedure revision The licensee's corrective actions pertaining to the ScanRad Computer were described in Section b.2 of this inspection repor c. C9ackslons The licensee's corrective actions described in the " Revised Commitments and Corrective Actions" were considered to be well conceived and executed. The inspectors made the following conclusions based oa the above reviews and findings:

o Revised calibration procedures contained necessary steps, as recommended by Regulatory Guides, ANSI, and EPRI guidance to perform meaningful calibration of +.he effluent / process RMS; e Calibration results were within the licensee's acceptance criteria and were well defined in the revised calibration procedures; e Calibration data reduction technique was sufficient to demnnstrate the validity and reliability of the RMS;

• Subject effluent / process RMS were operable at the time of this inspection;

• The licensee commitments for installation of flowmeters and the isokinetic nozzle described in Section b.2 were complete;

• The review process for the UFSAR/TS adequacy was appropriate and effective; o The evaluation of the historical calibration results (evaluation for the impact of any potentialinaccuracy on past operation by comparing past surveillance results with the results obtained using new calibration sources and improved

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procedures) suggested that all effluent monitors (except R 22) were adequate to monitor and detect normally expected increases in effluent release e The licensee performed good root cause evaluations, including irnprovement of the PORC review process; and

• Functions and responsibilities of the Oversight Department appeared appropriate to detect an early sign of the program breakdown or safety focus neglec R8 Miscellaneous RP&C lesues (92904)

R8.1 (Ocen) Accarent Violation, eel 50 213/97 02 01: Effluent / process radiation monitoring systems (RMS) had been improperly calibrated because procedural guidance was inadequate: (1) no documentation or poor documentation of the electronic calibration data; (2) no performance of in situ primary calibration; (3) no plateau curve to determine optimum operating high voltage; (4) incorrect performance of the secondary calibration; and (5) no determinatiens of conversion ,

f actors and linearity for the intended monitoring ranges. This area remains open pending NRC staff review of safety significance and final enforcement actio R8.2 ' (Closed) URI 50 213/97 02-02): The 10 CFR 50.59 implications regarding RMS calibration discrepancies. The licensee's actions were acceptable, as described in Section R2 of this inspection repor S1 Conduct of Security and Safeguards Activities S I .1 Containment Air Quality Inspection Scooo_(83729)

The purpose of this inspection was to review the security activities at the site, and the licensee response to an industrial safety issue, Observations and Findinna lhe implementation of the physical security program was reviewed during inspection tours of the plant. The security controls for the acce.as to the protected and vital areas were maintaine On September 13,1997, the licensee notified the inspector that a security guard had been relieved of duty early on the mid shift due to nausea caused by an odor that emanated from the containment. The relocated the guards to an area away from the affected area, and to prohibit unrestricted entry into the containment until-the cause for the odor could be investigated and analyzed. The source of the odor was not known, but it occurred in conjunction with the start of the containment air recirculation (CAR) fans on September 11 following an extended period in l

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shutdown. An Industrial Hygienist was consulted to assist in the investigation and to obtain samples necessary to evaluate containment air quality. The odor abated considerably by September 15. After taking the camples on September 16, the containment purge was reestablished on September 18. An analysis of the containment air samples showed trace quantitles of 8 chemicals: toluene, benzene, ethyl benzene, perchloroethylene, xylene, butyl acetate, trichloroethane, and hext ne, with the most prevalent being hexane and benzene. None of the chemicals war.s known to be used at the site. The trace amounts measured based on the concentrations present on September 16 were below toxic levels for the chemical At the conclusion of the inspection. licensee actions were still in progress to investigate the cause of the event and identify the source of the chemicals, and to evaluate the quality of conditions inside the containment. A representative of the Occupational Safety and Health Administration was involved with a review of the event and the licensee's response, EQngWsions

NRC review noted that security requirements were satisfied. Routine NRC aviews of site activities will follow the licensee resolution of this industrial safety issu V. Manaaement Meetinas X1 Exit Meeting Summary

- The inspector presented the inspection results regarding the radiation moEtoring system to the licensee on August 13, and October 9,1997. The licensee acknowledged the finding The inspector presented a summary of inspection results to the Unit Director at the conclusion of the inspection on October 17,1997. The licensee acknowled ,ed t the findings presented, i

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PARTIAL LIST OF PERSONS CONTACTED LittD1 +* G. Bouchard, Unit Director

+ J. Bourassa, QA Supervisor

• i,. Carnesi, System Engineer e J. DeLawrence, Supervisor, Engineering Programs

J. Dawson, Operator Training Specialist N. Fetherston, Decommissioning Project Manager

+ J. Hasettine, Engineering D; rector D. Heffernan, Maintenance Manager

+* S. Herd, Chemistry Manager

+* R. Mellor, Director, Site Operations and Decommissioning J. Pandolfo, Socurity Manager J. Pointkowski, Shift Manager R. Sexton, Radiation Protection Manager

+ J. Tarzia, HP/ Chemistry Technical Support

+ B. van Nieuwenhuise, Chemistry Supervisor A G. von Noordernen, Licensing Manager G. Waig, Operations Manager J. Warnock, Quality Assurance Manager A. Nerriccio, Public information NBC

+* W. Raymond, Sr. Resident inspector

M. Fairtile, Project Manager, NRR R. Nimitz, Senior H6alth Physicist

• Denotes those preser.t at the exit meeting on August 13,199 + Denotes those present at the exit meeting on October 13,1C9 The inspectors slso interviewed other licensee personne DEP, State of Connecticul j l

Michael Firsick, Radiation Control Physicist I Kevin McCarthy, Director, Radiation Control Division  !

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INSPECTION PROCEDURES USED IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems IP 62707:- Maintenance Observation IP 61726: Surveillance Observation IP 64704:- Fire Protection Program IP 71707: Plant Operations

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IP 83729: Occupational Exposure During Extended Outtges IP 92700: Follow-up of Written Reports of Nonroutine Events at Power Reactors IP 92902: Follow-up - Engineering IP 92903: Follow up - Maintenance IP 93702: Prompt Onsite Response to Events at Operating Power Reactors ITEMS OPEN, CLOSED, AND DISCUSSED 9PJtD 97-05-01 IFl Correct lve Actions for Halon Actuation 97-05-02 URI Procedures for Decommissioning Operations 97-05 03 URI Actions to Address SF Building Ventilation 97 05 04 IFl Actions to AddressBulletin 94-01 issues 97 05-05- URI Adequacy of Reports per 50.72 Closed 97-02-02 URI The ?O CFR 50,59 implications regarding RMS calibration discrepancie LER SFP Coolinq System Outside the Design Basis 97-12-00 LER Excessive Check Valve Seat Leakage 97 13-00 LER Inadvertent Halon System Discharge 97 14-00 LER Containment isniation Actuation 97-15-00 LER RMS Test Not per Technical Specifications Discussed 97-01 01 URI Status of Defueled Systemt 97 11-08 VIO Reporting Degraded Equipment Conditions 97-02-01 eel Effluent / process radiation monitoring systems (RMS) had been improperly calibrated because procedural guidance was inadequate

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LIST OF ACRONYMS USED ACP Administrative Control Procedure-ACR- Adverse Condition Report AEOD Office for Analysis and Evaluation of Operational Data ALARA As Low As is Reasonably Achievable ANN Annunciator Response Procedure AOP _ Abnormal Operating Procedure CAR Containment Air Recirculation CFR Code of Federal Regulations CW r. i - Connecticut Yankee Atomic Power Company DE? Department of Environmental Protection EA' Escalated Action EDG Emergency Diesel Generator ENG Engineering Procedure EOP Emergency Operating Procedure EPIP .- Emergency Plan Implementing Proceduro ESF- Engineered Safety Feature

-- F - Fahrenheit gpm gallons per minute IR Irispection Report LD'4 Licensing and Design Basis LER Licensee Event Report NOP Normal Operating Procedure NOV Non-Cited Violation NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulation NSO Nuclear Side Operstor NUSCO Northeast Utilities Service Company ODCM Offsite Dose Calculation Manual PDR Public Document Room PORC Plant Operations Review Committee PSDAR Post Shutdown Decommissioning Activities Report QA Quality Assurance OC Ouality Control RFO Refueling Outage RMS Radiation Monitoring System RPM Radiation Protection Manager RWPs - Radiation Work Permits

, _ RWST Refueling Water Storage Tank UR Surveillance Procedure

'SW Service Water TRM - Technical Requirement Manual TS Technical Specification UFSAR Updated Final Safety Analysis Report WCM Work Control Manual

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ATTACHMENT I AUGUST 7,1997 HALON ACTUATION SEQUENCE OF EVENTS 0944 Picture Taken of the Halon Control Panel -Internal Alarm 0946 Second Picture Flash - Halon Discharge Occurred 0947 Evacuation of Control Room 0953 Evacuation of central alarm system (CAS)

1008 CR Fire Detection System Defeated - alarm silenced; entered TRM 1009 CR Ventilation System Placed in Smoke Evacuation Mode 1009 Central Alarm Station /SSS entered with SCBA 1020 Air sample CAS - normal 1033 CAS Resumed Normal Manning

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1034 Air Sample in Control Room - normal 1034' Control Room Resumed Normal Manning 1045 Declared Unusual Event 1116 Control Board Walkdown Completed - No abnormal conditions noted 1149 Primary Side Operator Completed Second Set of Rounds 1235 Secured from Unusual Event e

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