IR 05000029/1997002

Insp Rept 50-029/97-02 on 970401-0814.No Violations Noted. Major Areas Inspected:Licensee Activities Re Decommissioning

ML20217C461
Person / Time
Site:	Yankee Rowe
Issue date:	09/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20217C445	List: IR 05000029/1997002 ML20217C440
References
50-029-97-02, 50-29-97-2, CLI-95-14, CLI-96-09, CLI-96-9, NUDOCS 9710010406
Download: ML20217C461 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket N License N DPR-03 Report N /97-02 Licensee: Yankee Atomic Electric Company ,

580 Main Street '

Colton, Massachusetts 01740 1398 Facility Name: Yankee Nuclear Power Station Location: Rowe, Massachusetts Dates: April 1 - August 14,1997 Inspectors: J. Nick, Region i Radiation Specialist, Region 1 M. Fairtile, Project Manager, NRR W. Raymond, Senior Resident inspector, Region 1 Approved By: J. White, Chief Radiation Safety Branch Division of Reactor Safety 9710010406 970923 PDR ADOCK 05000029 G PDR

O Reoort Details 01 Summary Of Facility Operations On October 12,1995, the Commission served Memorandum and Order CLI-9514 to Yankee Atomic Electric Company (YAEC) concerning activities at the Yankee Nuclear Power Station (NPS) in Rowe, Massachusetts. The Order states, in part, that "the NRC's approval of the Yankee NPS Decommissioning Plan cannot be accorded further legal effect, pending an [ adjudicatory] hearing opportunity," and, that in accordance with the pre-1993 interpretation of the decommissioning regulations, "the Commission expects YAEC not to conduct any further ' major' dismantling er decommissioning activities until final approval of its [ decommissioning) plan after completion of the hearing process." Subsequently, the Commission issued an Order (CLl 96-9), dated October 18,1996, which granted YAEC's Motion for Summary Disposition in a hearing convened to determine whether the decommissioning plan should be approved. Since YAEC had originally submitted the decommissioning plan before the Commission amended its decommissioning regulations, and the decommissioning plan was approved by the NRC in February 1995, YAEC had been given approval to conduct decommissioning activities at the Yankee site per a letter from the NRC (reference correspondence, dated October 28,1996, from Mr. Morton Fairtile to Mr. James Kay).

Based upon issuance of the Order and correspondence, the inspectors observed YAEC's activities during routine inspections on various dates from April 1 through August 14,1997. The inspectors verified by observation, documentation review, and/or discussions with responsible or involved plant staff, the activities on the current work schedule and the actual activities being conducted at the site. No major safety concerns were identified by the inspectors and appropriate radiological and industrial safety practices were observed for those jobs in-progres O2 Operations 02.1 Facility Tours The inspectors toured radiological controlled areas (RCAs) within the vapor contaMment. The inspectors noted operating air samciing equipment in various area Personnel dosimetry was worn by all workers in the area. Workers had removed most of the mechanical and electrical components (duct-work, conduit, cables, and fan units)

outside the bioshield, in the vapor containment. Workers had also removed most of the remaining structural, mechanical and electrical components from the steam generator and pressurizer cubicles. The stainless steelliner had been removed from the shield tank cavity walls and floor, and workers were removing the remaining metal rings and supports from the reactor vessel opening. The in::pectors observed that high radiation area (HRA) controls were satisf actory. All areas were posted and barricaded as required by NRC regulations and Technical Specifications. The posting and Ici,dling of radioactive material were satisfactory. Very good radiological controls were provioed by health physics technician coverage for jobs / activities in RCA _ _ . __ __ _ _ . ._ . _ - . _ _ . _ ____m . _

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2 The inspectors toured most of the RCAs outside the vapor containment including the  !

primary auxiliary building (PAB), the service building, the radioactive waste processing (compactor) building, the potentially contaminated area (PCA) storage building (a  ;

storage / staging area for potentially contaminated equipment and materials), and the 1

PCA warehouse attached to the radwaste processing building Most electrical and

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mechanical systems were removed from the Primary Auxiliary Building (PAB). Workers had stopped decontamination efforts on the ion exchange pit floor and walls because the low levels of radioactivity were difficult to measure with the high source term in the spent fuel pool next to the ion exchange pit. All radiation areas (ras) and HRAs were posted and barricaded as required. Locked HRAs were maintained locked with

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appropriate warning signs. Housekeeping in contaminated areas was very good, and

many areas that presented a challenge due to work conditions showed improvement since the last period of inspection. Contamination control was evident by the use of

" step-off pads", personnel monitoring equipment (friskers), and contaminated area postings at the boundaries. Posting and labelling of radioactive materials was inconsistent and a few items required immediate correction by the licensee's staff l

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during the first part of the inspection period. However, significant improvement was noted toward the end of the inspection period due to an increased effort by the

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licensee's radiation protection staff in labelling radioactive materials to warn workers i regarding the potential radiological hazards. No significant safety or NRC regulatory

concerns were noted by the inspector .2 Current Activities Most mechanical and structural components were removed from the steam generator

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cubicles in the vapor containment. Electrical work was completed to direct temporary power and isolate buildings for further dismantlement. Asbestos abatement work was

completed on the secondary side in the turbine building and contractors had begun to-dismantle the secondary side equipment. Work was continuing to disassemble the

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, system components of the old radwaste evaporator system. The removal of remaining main coolant piping, the feed and bleed heat exchanger from the vapor containment,

and structural steel outside the auxiliary building were all completed. Asbestos

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abatement was continuing in the former administrative office spaces.

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The licensee was experiencing delays in their decommissioning schedule due to the identification of PCBs in the paint on many metal surfaces. The metal was being temporarily stored in cargo vans at the site while the licensee worked with the Environmental Protection Agency (EPA) regarding removal and disposal methods for the ,

contaminated paint.

I Other work planned for the end of 1997 included completion of the items mentioned above, dives in the spent fuel pool to remove the fuel upender, an upgrade to the yard l area crane, and other modifications to the spent fuel pool building. The final site survey project was slated to begin near the end of 1997 or early 199 .

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R1 Plant Support - Radiological Protection and Chemistry (RP&C) Controls R1.1 External Exoosure Control Insoection Scope (83100)

The inspectors reviewed the controls for external radiation exposure through

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observation of work activities, tours of the facility, interviews with personnel, and a review of licensee documents.

' Observations and Findinas The inspectors observed the various work activities throughout the facility during the period of this inspection. Personnel in the RCA were observed wearing their. assigned thermoluminescent dosimeter (TLD) and pocket ion chamber (PIC) dosimeter. The dose

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totals for each individual were tallied on each workday and reports were available for review by personnel. Plant management periodically reviewed the status of workers in the respective department As stated in Section O2.1 of this Report, controls for radiation areas and high radiation areas were appropriate throughout the facility. The inspectors noted that the number of high radiation areas was decreasing, and only seven high radiation areas were currently identified with two being controlled through locked doors / gates (excluding the underwater dose rates from the spent fuel). Radiation work permits (RWPs) and a computerized access control system were also used to control workers' radiation exposure. The inspector reviewed selected RWPs written for various work activities and concluded that they contained appropriate requirements including administrative dose limits, protective clothing, and special monitoring or dosimetry, Conclusions Controls for external radiation were verY good including controls used during the various work activities. The number of high radiation areas had decreased due to the removal of components with higher radiation dose rates. No violations of NRC regulations or safety concerns were identifie =R1.2 Internal Exoosure Control Inspection Scoce (83100)

The inspectors reviewed the controls for internal radiation exposure through observation of work activities, tours of the facility, interviews with personnel and a review of licensee document .. . _ - . , . - _ . - -- - . . - . - - . - . . - - . . ..

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4 Observations and Findinas The inspectors observed air sampling equipment in the various areas of the facility during work activities. - The equipment was positioned to provide representative sampling of the breathing air in areas occupied by workers in addition, air handling and filtration equipment was used in areas with potential airborne radioactivit The inspectors reviewed the results from internal dose assignments and determined that the dose assigned through air sampling and bioassay were very small when compared to the total dose assignment, t Conclusions The licensee had provided good controls for internal radiation exposure including air sampling and bioassay for dose assessment. No violations of NRC regulations and no safety concerns were noted.

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R1.3 Control of Radioactive Materials and Contamination, Survevs and Monitorina

! inspection Scoce (83100)

The inspectors reviewed the controls for radioactive materials and contamination, surveys and monitoring through observation of work activities, tours of the facility,

interviews with personnel and a review of licensee documents.

i Qbservations and Findinas The inspectors verified that there was an adequate supply of radiation survey and monitoring equipment. All equipment checked by the inspector was operable and within the current calibration period. Portal monitors and frisking instruments were located throughout the facility for use by workers as they left radioactive materials

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areas or contaminated areas. Current radiological surveys of various work locations were reviewed by the inspector. The surveys contained detailed information regarding current dose rates and hazards in the work areas. Surveys were posted at the main

. control point for the RCA and at the vapor containment. Appropriate licensee management personnel had reviewed the radiological survey Radiological housekeeping was good throughout the plant with appropriate controls

established to minimize the spread of contamination. However, as noted in section

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O2.1 of this Report, some areas presented more of a challenge to the licensee's staff i due to changing conditions and ongoing work. These areas (mainly in the lower PAB)

showed signif' cant improvement in maintenance of the areas in accordance with the licensee management's expectations and to effectively control radioactive contamination. Posting of radioactive material areas and labelling of radioactive

[ materials was appropriate, but some containers were not labelled consistently during

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the early portion of this inspection period. Some container labelling was brought to the attention of licensee representatives by the inspectors. These problems were immediately corrected by the licensee's staff. Significant improvements were noted in the later part of the inspection period and were a result of major efforts by the licensee's radiation protection staff.

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' Conclusions lhe licensee provided very good controls fs radioactive materials and contamination, surveys and monitoring during decommissioning work activities. No violations or significant safety concerns were identifie R1.4 Maintaininu occuoational Radiation Exoosures ALARA insoection Scone (83100)

- Through interviews with personnel ano review of several documents, the inspectors examined the program to maintain petronnel exposures ALAR Observations and Finding 3 The total radiation exposure for all workers at the Rowe site was approximately 58 person ram during the period from January 1,1997 through August 8,1997, as measured by thermoluminescent dosimeters (TLDs) and pocket ion chambers (PICS).

The highest total dose assignment to an individual at the site was 1.495 rem during the same period. The majority of the radiation dose (96%) was attributed to direct decommissioning v>ork activities or activities to support decommissioning. The remaining radiation dose was attributed to routine work and site scoping activitie , Conclusions The licensee continued to maintain an very good program for maintaining occupational radiation exposures ALARA. Effective ALARA initiatives were implemented for the various decommissioning work ac'ivitie R2 Status of RP&C F.cilities and Equipment R2.0 Radioactive Material Shloments Inspection Scoce (8675 The inspectors observed the shipment of the reactor vessel from the site to the railroad via heavy hauler truck. The inspectors also reviewed licensee records and interviewed personnel to determine the scope of radioactive material shipments from the Yankee Rowe sit R

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b. Observations and Findinas The licensee shipped the reactor vessel from the Rowe site to the railroad located near the Hoosac Tunnel on April 27,1997. A heavy haul truck carried the reactor vessel,

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enclosed in a specially designed cask, to the railroad site approximately six miles from the plant. The licensee had made detailed plans to ensure that all conditions were appropriate for the oversize, heavy load, including replacement of under road culverts ,

and raising electrical power lines where necessary. Tht truck arrived at the railroad site with no difficulties, and the transfer to a rail car was immediately starte The steel caak that enclosed the reactor vessel was 13 feet in diameter,28 feet in length, and weighed 90 tons. The vessel was filled with low density concrete and a similar concrete was used to fill the space between the outside of the reactor versel and the inside of the cask. The total weight of the package (reactor vessel, low density concrete, and cask) was approximately 365 ton The dose rates were recorded by the licensee before the shipment left tho Rowe sit The highest radiation dose rate on contact with the package was approximately 100 millirem per hour. The highest radiation dose rate measured at 2 meters from the package was 4 millirems per hour. The regulatory radiation dose rate limit at 2 meters from a package is 10 millirems per hour. The inspectors verified that the radiation dose rates did not exceed the regulatory limits. The inspectors also independently verified the radiation dose rates through measurements with a properly calibrated dose rate meter. The inspectors reviewed the shipment paperwork including the radiolugical surveys, bill of lading, in't emergency response information. The inspectors noted that the cask and contents were designaud as a Greater Than Type A, Low Specific Activity (LSA) 11 package as per the D6partment of Transportation (DOT) regulation Total radioactivity of the package was opproximately 3030 curies. The inspectors verified that the shipment met the specifications of DOT regulation The inspectors observea the transfer of the cask to the rail car and preparations for the rail shipment. The shipment was properly prepared and dose rates did not exceed the regulatory limits as mentioned above. The shipment was sent from the Hoosac Tunnel to the low level radioactive waste disposal site near Barnwell, South Carolina via a dedicated train. As a precaution, the licensee sent radiation protection staff with the train shipment. The inspectors also observed the briefing for the railroad engineers and other railroad personnel on the rail shipment. The briefing was very good and describea the potential radiological implications of the shipmen The licensee was continuing to use vendors for volume reduction and decontamination of radioactive materials. Various other radioactive material shipments were made from the f acility including contaminated protective clothing for laundering and radioactive samples for laboratory analysi _. . -_ - _ - . - . _

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7 Conclusions The lices. ee appropriately planned and implemented the reactor vessel shipment for disposal. The licensee had shipped a significant quantity of radioactive materials to i vendors and disposal facilities. Licensee records were well maintained and no safety l concerns or violations of regulations were noted, l

R6 RP&C Organization and Administration a. Insoection Scone (831001 i

The inspector reviewed the organization and administration of the radiation protection l

program and discussed with the licensee changes made since the last inspection, '

conducted in March 199 b. Observations and Findinas The licensee had maintained a relatively stable staff comprised of approximately 35 technicians supporting the radiation protecticn and radweste activities. Other personnel were used for decontamination activities and chemistry / count room wor These technicians supported all decommissioning and routine activities for approximately 300 full time and part time workers at the sit The inspector reviewed the qualifications and training for selected radiation protection technicians. The training records included initial qualification for various tasks, attendance at refresher training sessions, and documentation of specialized trainin The inspector found that the records were well maintained and easily retrievable. All initial qualifications were complete for the selected technicians with one exceptio One radiation protection technician's qualification record was signed by the instructor, but was not signed by the technician. The inspector questioned the radiation protection supervisor regarding this record, and was told that the original record was lost. Since the instructor remembered signing the original record, the record was recreated. However, the record was not recreated before the technician left the sit Therefore, the record did not contain the technician's signature, but the licensee representatives were adamant that the technician was appropriately qualified. The radiation protection supervisor added a note to the record to indicate what had transpired. Since this was an isolated example, the inspector found the documentation appropriat The inspector also observed a continuing training session for radiation protection

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technicians. The inspector noted that the content of the training was very good, I understanding of the subject matter and participation by the technicians was also good, and attendance at the training session was well documented, l

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8 Conclusions

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The inspector determined that the licensee was adequately staffed to perform radiation protection activities for the decommissioning work. Radiation technician qualification and training was very good, with only one minor discrepancy in training records.

M8 Miscellaneous lesues R Review of Updated Final Safety Analysis Report (UFSAR) Commit.nents

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A recent discovery of a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a

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special focused review that compares plant practices, procedures and/or parameters to

the UFSAR description.

While performing the inspections discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector

verified that the UFSAR wording was consistent with the observed plant practices, procedures, and/or parameter X1 Exit Meeting Summary

. The inspectors met with the licensee representatives denoted b3 low at the conclusion of the on site inspection on April 30,1997. The inspectors summarized the purpose, scope, and findings of the inspection. Another briefing was held with licensee representatives at the

, conclusion of the on site inspection on August 14,1997. The licensee representatives i t

acknowledged the inspection findings.

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l PARTIAL LIST OF PERSONS CONTACTED Licensee

' G. Babineau, Radiation Protection and Chemistry Manager

1. ' W. Blackadar, Radiation Protection Engineer H. Breite, YNSD, Lead Engineer

• W. Cox, YNSD, Radiation Protection Engineer

• R. Durfey, Senior Engineer / Maintenance and Construction

• N. Fetherston, Maintenance and Construction Manager

1. S. Garvie, Security Supervisor

1. J. Grant, Decommissioning Manager

1. ' R. Greenfeld, Radiation Protection Engineer /ALARA Program

1. R. Grippardi, YAEC, Quality Assurance Supervisor

• K. Helder, Site Manager

• S. Litchfield, Health and Safety Supervisor

1. C. Melin, Construction Manager

• R. Mellor, YNSD Decommissioning Manager (via telephone).

S. Mullet, Radiation Protection Techniclaa

1. ' A. Trudeau, Quality Services Group Senior Engineer

• M. Vandale, Radiation Protection Senior Engineer

• B. Wood, Assistant Site Manger

1. F. Williams, Plant Superintendent

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Denotes those individuals participating in the exit briefing held on April 30,199 # Denotes those individuals participating in the exit briefing held on August 14,199 INSPECTION PROCEDURES USED IP 83100: Occupational Radiation Exposure During Decommissioning IP 86750: Solid Radwaste Management and Transportation IP 84750: Effluent and Environmental Monitoring IP 81700: Physical Security Program for Power Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened NONE Closed NONE Discussed NONE