ML102020027
ML102020027 | |
Person / Time | |
---|---|
Site: | Indian Point |
Issue date: | 07/21/2010 |
From: | Decommissioning Branch I |
To: | |
References | |
FOIA/PA-2016-0148 IR-10-009 | |
Download: ML102020027 (13) | |
See also: IR 05000003/2010009
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
INSPECTION REPORT
Docket No. 05000003
License No. DPR-5
Inspection No. 05000003/2010009
Licensee: Entergy Nuclear Operations, Inc.
Facility: Indian Point Energy Center (lPEC) Unit 1
Location: 450 Broadway
Buchannan, New York 10511-0249
Inspection Dates: June 22 - 24, 2010
Inspector: Laurie A. Kauffman
Health Physicist
Decommissioning Branch
Division of Nuclear Materials Safety
Approved By: Judith A. Joustra, Chief
Decommissioning Branch
Division of Nuclear Materials Safety
EXECUTIVE SUMMARY
Indian Point Energy Center Unit 1
NRC Inspection Report No. 05000003/2010009
A routine announced safety inspection was conducted on June 22 - 24, 2010, at Indian Point
Energy Center Unit 1 by a Region I inspector. The scope of the inspection included an
evaluation of the organization and management oversight; implementation of safety reviews,
design changes and modifications programs; implementation of the auditing, self-assessment,
and corrective action programs; implementation of long-term safe storage (SAFSTOR) program;
implementation of the maintenance and surveillance programs; implementation of the
occupational radiation exposure program; and implementation of the Effluent, Environmental
Monitoring and Radioactive Waste and Transportation programs associated with Unit 1 while in
SAFSTOR status. Within the scope of this inspection, no safety concerns or violations were
identified. A brief summary of each area inspected is described below.
Organization and Management Oversight
The licensee's organization and management oversight was adequate to support Unit 1
activities. The roles and responsibilities for the Unit 1 activities were consistent with the IPEC
Site Management Manual, Control of Indian Point 1 and the Technical Specifications (TS). The
IPEC Site Management Manual reflected the TS changes delineated in Amendment No. 54 to
. Facility Operating License No. DPR-5 for the Indian Point Energy Center, Unit 1, issued May 29,
2009.
Safety Reviews, Design Changes, and Modifications
The licensee conducted the safety review and engineering design change screening in accordance with
10 CFR 50.59 requirements.
Auditing, Self-Assessment, and Corrective Action Programs
The licensee maintained an adequate audit and self-assessment program and effectively utilized
the established corrective action program to self-identify, evaluate, and correct issues and
problems. Condition reports were properly prioritized and corrective actions were tracked in
accordance with approved procedures.
SAFSTOR
No dismantlement or decommissioning activities were performed since the previous inspection.
Maintenance and Surveillance
The licensee effectively implemented the preventive maintenance and surveillance program and
associated procedures in accordance with TS and Offsite Dose Calculation Manual (ODCM)
requirements.
11
Occupational Radiation Exposure
The licensee provided adequate controls to limit exposures of workers to external sources of
radiation. Posting and labeling of radioactive materials and radiation areas complied with
regulatory requirements. Radiological controls and dose estimates associated with Unit 1
activities were effective to achieve dose goals. Implementation and oversight of the SAFSTOR
program was effective for the storage of radioactive material.
Effluent, Environmental Monitoring and Radioactive Waste and Transportation
The licensee effectively implemented and maintained the radioactive effluent controls program,
the groundwater monitoring program related to Unit 1, the radiological monitoring program, and
the radioactive waste management and transportation programs.
111
REPORT DETAILS
1.0 Background
Indian Point Energy Center (lPEC) Unit 1 (Unit 1) is a pressurized water reactor that has
been shut down since October 31, 1974. Pursuant to the June 19, 1980, Commission
Order Revoking Authority to Operate Facility and the Decommissioning Plan for Indian
Point Unit No.1, approved by the U.S. Nuclear Regulatory Commission (NRC) in an
Order dated January 31, 1996, Unit 1 is permanently shut down and is being maintained
in long-tem storage (SAFSTOR) condition. Unit 1 has remained in SAFSTOR as defined
in NUREG 0586, Generic Environmental Impact Statement on Decommissioning of
Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors, dated
November 2002. SAFSTOR is defined as placing a facility in long-term storage until it is
decommissioned and decontaminated to levels that permit release of the property to
unrestricted use.
Units 1 and 2 are physically contiguous and share systems and facilities as well as a
common operating organization. The Unit 1 TS recognize this commonality as well as
the intended use of the Unit 1 facilities to support Unit 2 until retirement of that unit, and
contain specific references to the Unit 2 TS. The systems associated with Unit 1 are
divided into three classifications: a) systems required per the Unit 1 TS and that are
required to support the SAFSTOR condition of the unit; b) systems required to support
the operating units (e.g. Liquid Waste Processing) and c) systems that are not required
to support the TS, SAFSTOR condition, or the operating units.
2.0 Organization and Management Oversight at Permanently Shutdown Reactors
(PSRs)
a. Inspection Scope (Inspection Procedure {/Pl 36801 1
The inspector reviewed Amendment No. 54 to Facility Operating License No. DPR-5 for
the IPEC, Unit 1, issued May 29, 2009. Amendment No. 54 consisted of changes to
Facility Operating License No. DPR-5 and to the TS regarding the removal of spent fuel
from Unit 1 and drain down of the spent fuel pool. The inspector compared the TS with
procedure IP-SMM-DC-905, IPEC Site Management Manual, Control of Indian Point 1,
Rev. 6, dated February 4, 2010, and associated implementing procedures to ascertain
consistency with TS changes.
The inspector also reviewed procedure IP-SMM-DC-905 regarding the roles and
responsibilities for the operation, maintenance and control of Unit 1. The inspector
discussed organization. management and/or staffing changes as outlined in TS, Sections 3.1 and 3.2, and in IPEC Site Management Manual, Section 5.0.
b. Observations and Findings
Procedure IP-SMM-DC-905 defines roles and assigns responsibility for the operation,
maintenance and control of Unit 1. The licensee made no organizational structure
changes since the previous inspection. The inspector verified that procedure IP-SMM-
1
Enclosure
DC-905 and associated implementing procedures were consistent with the changes
delineated in License Amendment No. 54 and the TS regarding the removal of spent fuel
from Unit 1 and drain down of the spent fuel pool. Implementation of the TS and the
IPEC Site Management Manual were adequate.
c. Conclusions
The licensee's organization and management oversight was adequate to support Unit 1
activities. The roles and responsibilities for the Unit 1 activities were consistent with the
IPEC Site Management Manual, Control of Indian Point 1 and the TS. The IPEC Site
Management Manual reflected the TS changes delineated in Amendment No. 54 to
Facility Operating License No. DPR-5 for the IPEC, Unit 1, issued May 29, 2009. No
findings of safety significance were identified.
3.0 Safety Reviews, DeSign Changes, and Modifications at PSRs
a. Inspection Scope (IP 37801)
The IPEG Site Management Manual, Control of Indian Point 1 provides guidance for
modifying or working on Unit 1 structures, systems and components (SSCs) that have
been "retired in place" and that remain in place to support the operation of Unit 2. The
inspector reviewed Engineering Change (EC) reports to ensure that the licensee
conducted the safety review and engineering design change screening in accordance with 10
CFR 50.59 requirements.
b. Observations and Findings
As part of the licensee's Independent Safety Evaluation Program (ISE), which is a site
program to enhance the structural integrity and appearance of buildings, the licensee
identified areas for improvement regarding the Screenwell House (SWH). The purpose
of the SWH EC (EC#14789/EC#15360) was to enhance the physical appearance of the
SWH. EG#15360 was initiated to repair the roof and EC#14789 was initiated to remove
retired wall mounted SSCs, replace the degraded plywood louver covers with new acrylic
panels, and reconfigure the existing temporary power stand located east of the SWH. A
safety review and engineering design change screening was a requisite for EC#14789. The
inspector noted that the licensee conducted the safety review and engineering design
change screening in accordance with 10 CFR 50.59 requirements.
c. Conclusions
The licensee conducted the safety review and engineering design change screening in
accordance with 10 CFR 50.59 requirements. No findings of safety significance were
identified.
2
Enclosure
4.0 Auditing, Self-Assessment, and Corrective Action at PSRs
a. Inspection Scope liP 40801)
The inspector reviewed selected quality assurance (QA) audit reports related to Unit 1
SAFSTOR activities, selected condition reports (CRs), and associated corrective actions
to evaluate the licensee's ability to assess, identify, resolve, and prevent issues that
could impact safety or the quality of SAFSTOR activities. Specifically, the inspector
reviewed Quality Assurance Audit Report, QA-14/15-2009-IP-1, Combined Chemistry,
Effluent and Environmental Monitoring, dated October 2009, and Quality Assurance
Audit Report, QA-02-06-2009-IP-1, IPEC Radiation Protection and Radwaste, dated
November 2009.
b. Observations and Findings
The audit reports focused on site-wide plant support activities, such as the chemistry,
radiation protection and radioactive waste programs. The audits were adequate and
identified strengths and weaknesses related to the Unit 1 activities. As an outcome from
discussions regarding the above audit results, the QA Manager determined that audits
would be enhanced to focus on SAFSTOR activities, Unit 1 TS, and the IPEC Site
Management Manual, Control of Indian Point 1 procedure. The priority for addressing
condition reports and implementation of corrective actions was adequate and based
upon safety significance. Corrective actions were implemented to address identified
issues, and were being tracked to closure using the licensee's corrective action program.
The licensee did not identify any adverse trends or safety concerns.
c. Conclusions
The licensee maintained an adequate audit and self-assessment program and effectively
utilized the established corrective action program to self-identify, evaluate, and correct
issues and problems. Condition reports were properly prioritized and corrective actions
were tracked in accordance with approved procedures. No findings of safety significance
were identified.
5.0 SAFSTOR
a. Inspection Scope (IP 71801)
The inspector reviewed the licensee's current decommissioning status with respect to the
Decommissioning Plan for Indian Point Unit 1, approved by the NRC in an Order dated
January 31, 1996.
b. Observations and Findings
Unit 1 is currently in the SAFSTOR condition. The licensee informed the inspector that
they plan to actively decommission Unit 1 in parallel with the decommissioning of Unit 2
after that unit has been permanently shutdown.
3
Enclosure
c. Conclusions
No dismantlement or decommissioning activities were performed since the previous
inspection, conducted in April 2009. No findings of safety significance were identified.
6.0 Maintenance and Surveillance at PSRs
a. Inspection Scope (IP 62801)
The inspector evaluated the maintenance program, required by TS, Section 5.0 and
described in IPEC Site Management Manual, Control of Indian Point 1, Section 6.0. The
inspector reviewed the surveillance requirements for the Unit 1 radioactive effluent
monitoring instrumentation, required by TS, Section 5.2 and the ODCM. The inspector
examined the maintenance and calibration records for the liquid discharge monitor (R-
54) and stack vent noble gas monitor (R-60) for the period April 2009 through June 2010.
The inspector reviewed the operability of the radioactive effluent monitoring
instrumentation, required by TS Section 4.4 and the ODCM. The inspector toured the
nuclear service building (NSB), the chemical systems building (CSB), the fuel handling
building (FHB), the containment building, and containment sphere [i.e. vapor
containment (VC)]. The inspector reviewed the biennial SAFSTOR engineering and
structural assessment report and the Unit 1 Retired System Isolation Boundary (RSIB)
project report. The RSIB project was developed as a result of the initial self assessment!
SAFSTOR engineering and structural assessment and included identifying and marking
boundary interfaces between the Unit 1 and Unit 2 shared electrical and mechanical
systems.
b. Observations and Findings
The inspector verified that the maintenance and surveillance program for selected
systems and components had been conducted in accordance with TS, implementing
procedures, and the ODCM. The inspector also determined from a review of
maintenance and calibration records that the preventative maintenance, routine
surveillance, and calibration results were complete and the results were within the
acceptable tolerance limits.
The inspector determined from the plant tour, discussions with individuals cognizant of
the performance of the above systems and components, and a review of shift logs that
the radioactive effluent monitoring instrumentation were operable. The inspector verified
that the VC, which was maintained in a condition to allow safe storage and subsequent
decommissioning, contained the components utilized during operation, including the
steam generators and reactor coolant pumps.
The inspector verified that the licensee conducted the biennial structural inspection for
the NSB, CSB, Utility Tunnel and the exterior super heater building structural steel. The
licensee's most recent inspection was conducted in 2009. The purpose of the structural
inspection was to identify and monitor the facility for signs of age-related structural
degradation (i.e., masonry cracking, concrete spalling, and equipment corrosion) that
could potentially endanger the operating units or create an industrial safety hazard.
4
Enclosure
The RSIB project report contained details on hundreds of systems, included drawings
and photographs regarding each electrical and mechanical boundary interface, and
included documentation of the location of each label or tag. The inspector selected
electrical and mechanical systems for inspection and verified, during a tour, that each
selected system was appropriately marked as a boundary interface.
c. Conclusions
The licensee effectively implemented the preventive maintenance and surveillance
program and associated procedures in accordance with TS and ODCM requirements.
No findings of safety significance were identified.
7.0 Occupational Radiation Exposure
a. Inspection Scope liP 83750)
The inspector evaluated implementation of the occupational exposure program to
determine the licensee's capability to monitor and control radiation exposure to
employees, and to determine adequacy of the radiation protection program. The
inspector reviewed procedure EN-RO-101, Nuclear Management Manual, Access
Control for Radiologically Controlled Areas, Rev 5, dated January 20, 2010 and RP-STD-
17, Satellite RP Key Issuance and HRA, LHRA, and VHRA Boundary Verification, Rev.
10, dated May 17, 2010. The inspector interviewed responsible individuals, reviewed
radiological survey plans, survey maps of the radiologically controlled area, and
conducted field observations of radiological postings. The inspector evaluated the
radiation work permits (RWP) related to core bore sampling in the Unit 1 East and West
Spent Fuel Pools, the associated post-job dose evaluations, and the dose totals for 2009
and January through June 2010.
b. Observations and Findings
The radiologically controlled areas were appropriately posted and labeled for radioactive
material. Radiological postings were readily visible, well-maintained, and reflected
radiological conditions. The radiological survey maps and related information maintained
at the Unit 1 access point were current. High radiation areas and technical specification
locked high radiation areas were properly posted and locked as required. The RWPs
were commensurate with the radiological significance of the tasks and included the
appropriate exposure control measures for the safe implementation of the activities. The
RWP dose totals were below the dose goal totals for 2009 and January 2010 through
June 2010.
c. Conclusions
The licensee provided adequate controls to limit exposures of workers to external
sources of radiation. Posting and labeling of radioactive materials and radiation areas
complied with regulatory requirements. Radiological controls and dose estimates
associated with Unit 1 activities were effective to achieve dose goals. Implementation
5
Enclosure
and oversight of the SAFSTOR program was effective for the storage of radioactive
material. No findings of safety significance were identified.
8.0 Solid Radioactive Waste Treatment, and Effluent and Environmental Monitoring
a. Inspection Scope liP 84750)
The inspector evaluated the radioactive effluent control and the site radiological
environmental monitoring programs. The evaluation included a review of the annual
radioactive effluent release report for 2009, the annual radiological environmental
operating report for 2009, and the associated analytical results for each program. The
inspection also included a review of the Unit 1 TS and the ODCM. The ODCM contains
the current methodology and parameters used in the calculation of offsite doses due to
radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent
monitoring alarm/trip set-points, and in the conduct of the environmental radiological
monitoring program. The inspector evaluated the licensee's controls and processes
regarding the liquid and gaseous radioactive effluents related to Unit 1 activities, required
by TS, Section 4.2 and the ODCM. The inspector reviewed the associated radioactive
liquid release permits, the analytical sample results, and the projected doses to the public
associated with the groundwater in-leakage into the NCD and SFD sumps. The
inspector also reviewed the gaseous effluent results and the projected doses to the
public associated with the stack vent. The inspector also evaluated the radiological
environmental monitoring program, including the analytical results associated with
samples of shoreline sediment, fish, and water from January 2010 through June 2010.
b. Observations and Findings
The annual effluent and environmental monitoring reports demonstrated that the
calculated doses were well below regulatory dose criteria of 10 CFR 50, Appendix I. The
radioactive liquid effluent release permits were completed according to the ODCM. From
a review of the analytical data, the inspector verified that the projected doses to the
public from the liquid and gaseous effluent from Unit 1 were well below TS limits and
were performed in accordance with the ODCM and the Code of Federal Regulations (10
CFR 50.36a) for maintaining doses to the public from radioactive effluents as low as is
reasonably achievable. The inspector verified that the licensee collected and analyzed
the stack vent samples, NCD and SFD sump samples, and the liquid discharge monitor
samples within the required frequencies and that the sample collection was conducted in
accordance with applicable procedures. The chemistry technician responsible for the
oversight of the RMS demonstrated knowledge of the RMS relative to operability
requirements and performance history.
Analytical water sample results related to the groundwater monitoring program,
specifically, the NCD and SFD analytical sample results from January 2010 through June
2010 were compared to the results from 2009. The licensee informed the inspector that
the levels of radioactivity appear to be trending downward. The inspector's review Of this
data confirmed the licensee's conclusion.
6
Enclosure
The analytical results for shoreline sediment, fish, and water from January 2010 through
June 2010 for the radiological environmental monitoring program indicated that no
significant radioactivity was identified in fish and the environment.
c. Conclusions
The licensee effectively implemented and maintained the radioactive effluent controls
program, the groundwater monitoring program, and the radiological monitoring program.
No findings of safety significance were identified.
9.0 Solid Radioactive Waste Management and Transportation of Radioactive Materials
a. Inspection Scope liP 86750)
The inspector evaluated the radioactive waste management and transportation programs
to determine whether the licensee properly processed, packaged, stored, and shipped
radioactive materials. The inspector reviewed the most recent exclusive use shipment of
low specific activity radioactive waste that occurred in June 2009.
b. Observations and Findings
The licensee had significantly reduced the Unit 1 radioactive waste inventory. After the
completion of the drain down and clean up of the spent fuel pool, the licensee packaged
and shipped the resins and sludge in a 14-215 cask to a waste processing facility in
Tennessee. Radioactive waste shipment records were complete and included copies of
characterization reports and waste manifest shipping papers. The licensee met the
applicable radioactive waste and transportation requirements for the shipments reviewed.
Additionally, the inspector determined from the Unit 1 FHB tour and discussions with
individuals cognizant of the radioactive waste management and radioactive materials
transportation programs that the Class B waste from the cleanup of the spent fuel pool is
still being maintained in the Unit 1 FHB until an appropriate disposal option is available.
c. Conclusions
The licensee effectively implemented the radioactive waste management and
transportation programs. No findings of safety significance were identified.
7
Enclosure
Exit Meeting Summary
On June 24, 2010, the inspector presented the inspection results to Donald Mayer,
Director of Unit 1, and other members of the licensee's staff. Mr. Mayer acknowledged
the inspection findings. The inspectors confirmed that proprietary information was not
provided or examined during the inspection.
8
Enclosure
A-1
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
P. Donahue, Unit 1 Chemistry
C. English, Superintendant Unit 1
D. Fucito, Unit 1 ISE Projects
D. Gray, Chemistry Manager
W. Henries, Senior Engineer Consultant, Unit 1
F. Inzirillo, Quality Assurance Manager
D. Mayer, Director Unit 1
J. Michetti, System Engineering Support - RMS
S. Sand ike, Senior Chemistry Engineer
W. Scholtens, Radioactive Waste Engineer
D. Smith, Health Physicist, Radiation Protection
A. Stewart, Licensing Engineer
R. Tagliamante, Acting Radiation Protection Manager
INSPECTION PROCEDURES USED
36801 Organization, Management, and Cost Controls at Permanently Shutdown
Reactors (PSRs)
37801 Safety Reviews, Design Changes, and Modifications at PSRs
40801 Self Assessment, Auditing, and Corrective Action at PSRs
62801 Maintenance and Surveillance at PSRs
71801 Decommissioning Performance and Status Reviews at PSRs
83750 Occupational Radiation Exposure
84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
86750 Solid Radioactive Waste Management and Transportation of Radioactive
Materials
Attachment
A-2
ITEMS OPEN, CLOSED, AND DISCUSSED
Opened, Closed and Discussed - None
LIST OF ACRONYMS USED
ADAMS Agencywide Document Access Management System
CFR Code of Federal Regulations
CR condition reports
CSB chemical systems building
EC Engineering Change
FHB fuel handling building
IP Inspection Procedure
IPEC Indian Point Energy Center
ISE Independent Safety Evaluation Program
NCD North Curtain Drain
NSB nuclear service building
NRC Nuclear Regulatory Commission
ODCM Offsite Dose Calculation Manual
PSRs Permanently Shutdown Reactors
QA quality assurance
RMS radiation monitoring system
RSIB U 1 Retired System Isolation Boundary
RWP radiation work permits
SFD Sphere Foundation Drain
SSCs structures, systems and components
TS technical specification
Unit 1 Indian Point Unit 1
Unit 2 Indian Point Unit 2
VC vapor containment (containment sphere)
Attachment