IR 05000309/1999001
| ML20195F684 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 06/07/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20195F678 | List: |
| References | |
| 50-309-99-01, 50-309-99-1, NUDOCS 9906150063 | |
| Download: ML20195F684 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
INSPECTION REPORT Inspection N /99-01 Docket N License N DPR-36 Licensee: Maine Yankee Atomic Power Company l
Location: Bailey Point Road Wiscasset, ME 04578 q
Inspection Dates: February 14 through May 13,1999 Inspectors: Todd J. Jackson, CHP, Health Physicist :
Mark C. Roberts, CHP, Senior Health Physicist, ,
Jason C. Jang, Ph.D., Senior Radiation Specialist Steven W. Shaffer, Health Physicist
- Approved By: Ronald R. Bellamy, Ph.D., Chief Decommissioning and Laboratory Branch, DNMS
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Document Name: B:ONMS Documents \lnsp ReportWDPR-36.9941.wpd l
9906150063 990607
{DR ADOCK 05000309 PDR a L
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EXECUTIVE SUMMARY
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Maine Yankee Atomic Power Company NRC Inspection Report No. 50-309/99-01
. This integrated inspection included aspects of licensee operations, maintenance, and plant support. The report covers a three-month period of announced inspections by four regional inspectors. ' No violations were identifie '
Operations
Licensee personnel demonstrated the successful movement of fuel elements and other objects in the spent fuel pool (SFP). The fuelinspection process was being handled in a safe and conservative manner. The licensee was maintaining a safety-first focus at all times regarding handling of spent fuel. The licensee clearly demonstrated that they were willing to stop work at the first sign of a possible problem and resolve any issues before proceeding. (01.1)
Licensee preparations for spent fuel movement and inspection were thorough and complet l Personnel performing movements and inspections were trained and qualified in accordance with !
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licensee procedures, and adequate training records were maintained. (01.2)
The Maine Yankee (MY) staff safely performed an exchange of depleted, high-activity ion exchange resin from the submerged SFP domineralizer. Al. ARA and Foreign Material Exclusion l (FME) concems were evident in the planning for the event. (01.3)
Maintenance
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The decommissioning operations contractor (DOC) developed and was implementing a new work order system for authorizing and tracking decommissioning work. Pre-implementation testing identified minor procedural problems that were corrected. The new work order system .
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has been successfully used for work such as the source term reduction job. (M3.1)
Plant Support The licensee's control of work and process for planning work were aggressive in considering radiological conditions and in clearly defining limits en work. Appropriate rapid corrective action was taken when work was performed beyond the defined work scope. The source term reduction program was effectively reducing general area radiation levels in areas of the plant where many person-hours of decommissioning work are anticipated, which is therefore
- expected to minimize personnel exposures. The source term reduction program demonstrates a commitment to keeping personnel radiation exposures Al. ARA during decommissionin . (R1.1)
The licensee maintained effective radioactive liquid and gaseous effluent control programs. The Offsite Dose Calculation Manual contained su'ficient specification and instruction to acceptably implement and maintain the radioactive liquid and gaseous effluent control programs. (R1.2)
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j . The licensee established, implemented, and maintained an effective gaseous and particulate l- - effluent radiation monitoring system calibrstion program, including flow rate measurement systems. The licensee had resolved problems identified in the new primary vent stack (PVS)
I' sampling system, assuring representative sampling of the PVS. (R2.1)
- . The licensee established, implemented, and maintained an effective air cleaning surveillance program with respect to surveillance tests, HEPA mechanical efficiency tests, and air flow rate tests. All surveillance results were within the Technical Specifications (TS) acceptance criteri (R2.2) ,
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MY maintains sufficient Radiation Protection (RP) staff to support the areas where it retains responsibility. The transition of the RP organization from a focus on operational issues to a focus on decommissioning issues was accomplished in a planned, orderly manner. Immediate corrective actions were effective for correcting information in a database for RP instrumentation and performing required periodic performance tests. (R6.1)
The licensee established, implemented, and maintained an effective quality assurance program for the radioactive effluent control program with respect to audit scope and depth, audit team experience, and response to audit findings. The licensee also implemented an effective quality control program to validate measurement results for radioactive effluent samples. (R7)
Radioactive wastes generated from historical operations were appropriately characterized and prepared for disposal. Radiation Protection practices during characterization were strong, particularly those relating to maintaining personnel doses ALARA. (R8.1) j
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Radioactive waste was being packaged and shipped in accordance with approved procedure Appropriate and knowledgeable personnel were responsible for packaging and shipping
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. radioactive waste. Personnel were effectively implementing a program to keep waste package external exposure rates ALARA. (R8.2)
The licensee had effectively remediated two locations where measurable radiation was !
attributed to plant-related radioactive material.- Additional surveys were planned for further !
characterization of the parking lot area where the radioactive material was identified. (R8.3) {
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TABLE OF CONTENTS EXEC UTIVE S U M MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . li TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . lv R E PORT D ETAI LS ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 i
1. O perati ons _ . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1
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01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1. , - Soent Fuel Inspections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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O1.2: Preparations for Soent Fuel Movement and Inspection . . . . . . . . . . . . . . . . . . 2 l 01.3 Transfer of Hiah-Activity lon Exchanae Resin from Soent Fuel Pool . . . . . . . . 3 l i
11. M ai ntenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , 4
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- M3 Maintenance Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1 M3.1 Work Order System for Job Trackina and Authorization . . . . . . . . . . . . . . . . . . 4 l 111. Pla nt S u pport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . 5
- R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . . . . 5 R Source Term Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 R1.2 1mglpmentation of the Radioactive Llauld and Gaseous Effluent Control Proarams
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- R2 Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 R2.1 Calibration of Effluent Radiation Monitorina Systems (RMS) .. . . . . . . . . . . . . . 8 R2.2 Air Cleanina Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 R6 . RP&C Organization and Adtninistration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 R6.1 Radiation Protection Transition Oraanization . . . . . . . . . . . . . . . . . . . . . . . . . 10 R7' Quality Assurance (QA) in RP&C Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 R8 Miscellaneous RP&C issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 R8.1 - Characterization of Radioactive Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 R8.2 Radioactive Waste Manaaement and Transoortation . . . . . . . . . . . . . . . . . . . 13 R8.3 Control of Radioactive Material . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 R8.4 Control of Radioactive Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 R8.5 - Follow-Uo of Previous insoection Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 IV. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
' Community Advisory Panel (CAP) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 IV Inspection Report No. 50-309/99-01 BSNMS Documents \lnsp Report \RoPR-36.99-01.wpd
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., Exit M eetina . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Inspection Procedu res Used . . . . . . . . . . . . . . . . . . . . . . . . , , , , , , , , , , , , , , , , , , , , , , , , , $ 7
- Items Opened, Closed, and Discussed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
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- List of Acronyms Used . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
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REPORT DETAILS S.lgpmary of Plant Status Du-ing this inspection period Maine Yankee prepared to move fuel in the spent fuel pool and
' began moving fuel to perform video inspections of spent fuel bundles. Removal of installed equipment and components accelerated, and included removal of piping from containment to reduce area dose rates in locations where people are expected to spend a lot of time during future decommissioning work. The number of workers on-site increased as the amount of decommissioning work performed by the decommissioning operations contractor (DOC)
increased. The DOC began to perform more of the routine activities at the site, including those related to site access qualification and authorization, radiation protection, and radioactive waste managemen I. Operations 01 Conduct of Operations 01.1 Soent FuelInspections Insoection Scooe (60710. 80801)
The licensee's fuel handling activities and general spent fuel pool (SFP) activities were reviewed. Fuelinspections were ongoing during the inspectio Observations and Findinas -
The licensae's fuel inspection procedures were reviewed and inspection activities were observed. The licensee had initiated condition reports (CRs) for two incidents of fuel assemblies interacting with SFP racks during removal. CR 99-83 involved the snagging of a fuel spacer grid on the edge of a rack fuel cell and CR 99-84 involved the snagging of an upper end fitting on a rack fuel cell. Both interactions occurred in region two of the I fuel racks, which contained racks with different design dimensions than the rack cells in region one. The licensee immediately stopped work in each instance and initiated the CRs. Following the second interaction, the licensee determined that both interactions were caused by a feature unique to the racks in region two. Continued fuel movement and inspection were restricted by the licensee to only region one racks pending completion of the CR investigations. The major corrective actions were retraining, addition of a load cell to the fuel handling crane, addition of a slower speed for the crane, and fabrication of a " shoe horn" to help assemblies move past identihd snags without interacting. The inspector observed the restart of fuel movements in the region two racks following resolution of CR issues, as well as licensee technical discussions to resolve questions related to the performance of newly-installed SFP crane equipmen The licensee took a very deliberate, slow, and conservative approach to resolving this issue, keeping a " safety first" focus throughout the resolution proces Inspection Report No. 50-309/99-01 B:ONMS DocumentsVnsp ReporhRDPR-36.9901.wpd
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The licensee performed fuel inspections using an underwater remote videotaping system. Fuel handling procedure 13-2, " Fuel Handling in the Spent Fuel Pool," was used during all fuel handling and was updated appropriately. The licensee maintained records of the completed procedure 13-2 performances. The fuel handlers used two-way headset radios to ensure that instructions were transmitted clearly. Fuel handling was performed with at least one certified fuel handler (CFH) and one fuel handler on the refueling bridge during all fuel movements. All required walk-downs and bridge checks were completed before fuel handling and after completion of fuel handling. In addition, licensee procedure 1-203-1, " Fuel Handling Crane Frequent inspection," was completed at the required frequenc The general area radiation monitor and the continuous air monitor in the SFP building were operational. Both monitors were properly calibrated and the licensee electronically checked the general area radiation monitor daily and source checked it quarterly. The fuel floor was properly posted. The restricted area and foreign material exclusion (FME)
zone were properly delineated.-
The licensee had performed a quality assurance (QA) audit of the fuel inspection activities. Quality Assurance (QA) report 99-S11 was issued May 12,1999, and covered the fuel inspection activities from March 24,1999 through April 22,1999. The report identified that the fuel inspection contractor did not have a written process for communicating deviations and non-conformances to the licensee. The contractor revised their Project Management Plan to include a forma 1 notification process. The issue was documented by the licensee as CR 99-10 Conclusions Licensee personnel demonstrated the successful movement of fuel elements and other objects in the SFP. The fuel inspection process was being handled in a safe and conservative manner. The licensee was maintaining a safety-first focus at all times regarding handling of spent fuel. The licensee clearly demonstrated that they were willing to stop work at the first sign of a possible problem and resolve any issues before prec;; ding. No concems were identifie . 01.2 - Preparations for Soent Fuel Movement and insoection Inspection Scope (60705)
Licensee preparations were reviewed, including procedures, personnel qualifications and training, and equipmen b.' Observations and Findings Although Maine Yankee is no longer an operating facility, there is a need to maintain the capability to move spent fuel. Maine Yankee meets this need through the Certified Fuel Handler (CFH) program. The Defueled Technical Specifications (TS) 5.2.2 require that a l
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.CFH be part of each shift crew and TS 5.4.1 requires that an NRC-approved training program for CFHs be maintaine The inspector reviewed the CFH training program through review of procedures and ,
j interviews with operations personnel. Individuals that previously held the position of shift l operating supervisors were required to hold a senior reactor operators license and are exempt from most of the CFH training program elements. These individuals are required to annually demonstrate moving a fuel element from one pool location to another in order to be a CFH. Individuals who have not been senior reactor operators must complete the l entire training program package. Successful completion of each training program element is recorded by an evaluator on a qualification card for each individual. Records are maintained on the third floor of the Staff Buildin All CFHs and fuel handlers were properly trained in accordance with licensee procedures. The licensee conducted training for all fuel handlers to ensure that all involved personnel were fully aware of the procedural changes that were implemented as a result of CR 99-83 and CR 99-84 (described in $O1.1 above). The training included two different training courses, one of which included the video of the actual incidents, i
' which allowed the instructors to provide a detailed description of the events and how to prevent future occurrence The inspector reviewed the relocation of fuel bundles and trash baskets in the SFP to prepare for the inspection campaign. Eleven fuel bund!es and five baskets were moved j in preparation for the inspections because they were in locations where the inspection J equipment could not be used. It was necessary to remove installed crane end-stops to relocate these items, and additional staff were present to monitor crane travel once the stops were removed. The CFH directing the fuel movements held briefings with staff involved in the relocation of the baskets and fuel elements. As required by the TS, the CFH remained on the fuel crane bridge to directly supervise the movement activities. No problems were observed during the relocation of the bundles and trash basket Conclusions Licensee preparations for spent fuel movement and inspection were thorough and complete. Personnel performing movements and inspections were trained and qualifed j in accordance with licensee procedures, and adequate training records were maintaine !
i O1.3 Transfer of Hiah-Activity lon Exchance Resin from Soent Fuel Pool l i Inspection Scooe (83750)
The inspector reviewed the plans for the exchange of spent ion exchange resin in the submersible domineralizer system in the SF :
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. Observations and Findinos The inspector attended a briefing on the ion exchange resin exchange to be conducted for the submersible demineralizer system in the SFP. Approximately 20 ft* of spent resin from the submerged domineralizer in the SFP was to be slurried with a mix of air and water, then sluiced through hoses into a shielded High-integrity Container (HIC) in the RCA building. The demineralizer, located at the bottom of the SFP, produced a surface exposure rate of about nine R/ hour and had reached depletion of the anion resin. The briefing included the representatives from each organization involved in the resin transfer. Each step of the procedure was discussed in detail. FME concems were identified in the procedure and discussed. ALARA concems were addressed through consideration of the number and location of the staff directly involved with the spent resin transfe The inspector discussed the results of the resin sluice operation with MY staff following the transfer. No problems were identified during the resin transfer operation Conclusions The MY staff safely performed an exchange of depleted, high-activity lon exchange resin from the submerged SFP domineralizer. ALARA and FME concems were evident in the planning for the even . Maintenance M3 Maintenance Procedures and Documentation M3.1 Work Order System for Job Trackina and Authorization Insoection Scoos (83750) -
The inspectors reviewed the implementation of a new work order system for authorizing and tracking decommissioning work, and the integration of the Radiation Work Permit (RWP) system with the work order Observations and findings The DOC implemented a new work order system to assign, authorize, and track the decommissioning work. This system replaced the Maine Yankee work order syste Each work order is intended to provide a " road map" for successful completion of task Work orders identified prerequisites, defined the scope of the activity and the sequence of the work, and prescribed required radiological and industrial safety practices and equipment necessary to perform work safely. Work Orders were developed using a team approach that enabled all involved p'arties to have input into job planning. The DOC tested the system by developing mock work orders that included system walk-downs, work order authorization signatures, and simulated work. The test identifed 4 Inspection Report No. 50 309/99-01 B:ONMS DocumentsVnsp ReportVtDPR.36.99 01.wpd
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some procedural weaknesses and inefficiencies that were corrected. The existing RWP system remained in place for support to the work order syste Conclusions ,
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The DOC developed and was implementing a new work order system for authorizing and tracking decommissioning work. Pre-implementation testing identified minor procedural problems that were corrected. The new work order system has been successfully used for work such as the source term reduction job. No concems were identifie !
111. PlantSupport R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Source Term Reduction Inspection Scope (83750)
The inspector observed activities related to the removal of piping containing significant i radiation source ,
I Observations and Findinas The inspector observed work activities related to the removal of radiation sources located within plant equipment and components in the containment and primary auxiliary i building (PAB). The radiation sources had been previously located using the gamma
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camera and surveys, and were being removed to reduce the general area dose rates before bulk removal work proceeded. Pipe of four-inch diameter or less was being cut with a band saw to minimize generation of airborne contamination, and larger pipe was being cut with a plasma torch cutter. Appropriate engineering controls were observed for plasma torch work, including high efficiency particulate (HEPA) filters with suction ports located close to the cutting work. The worker performing the plasma torch cutting also wore a respirator. Airborne radioactivity monitoring in the vicinity of the work included a low-volume general area sampler running for the length of the job, high-volume grab samples collected during cutting work, and a low-volume sampler on the HEPA filter exhaust to monitor HEPA filter effectiveness for the entire job. Breathing zone samplers were used for nonradiological hazards monitorin The work p!anning process and pre-job briefings for work orders considered both the scope of work and limitations on expansion of scope by workers. Radiation Protection (RP) personnel covering the work were interviewed and were aware of limits on their authority in the field to modify work scope. Work orders were written for a specific component or pipe, and the RP technician was permitted to allow additional pipe from the same component or system to be removed in the vicinity of that desc11 bed in the work order. Work orders do not permit removal of different components because the radiological conditions within the different component or system may not be the same. A 5 Inspection Report No. 50-309/99-01 B:ONMS Documents \lnsp Report \RDPR-36.99-01.wpd i
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different work order and work planning evolution are required before work is performed on different components or system The licensee was also cognizant of the importance of adequately controlling the scope of work performed on individual work orders. CR 99-102 had been identified by the licensee because personnel had inappropriately expanded the scope of work beyond the planned limits of a decommissioning work order. It is a programmatic strength that the licensee and the DOC had initiated immediate corrective action to prevent recurrenc The source term reduction program had used a gamma camera to identify higher sources of gamma radiation exposure in areas of the plant, especially the containment and PABs. The sources were superimposed on video images of the components and equipment, facilitating removal of the componerts and the radiation sources. Significant reductions in area exposure rates (commonly by a factor of 10 or more) had been achieved, Conclusion The licensee's control of work and process for planning work were aggressive in considering radiologica! conditions and in clearly defining limits on work. Appropriate rapid corrective action was taken when work was performed beyond the defined work
'acope. The source term reduction program was effectively reducing general area radiation levels in areas of the plant where many person-hours of decommissioning work are anticipated, which is therefore expected to minimize personriel exposures. The source term reduction program demonstrates a commitment to keeping personnel radiation exposures ALARA during decommissionin R1.2 Imolementation of the Radioactive Liould and Gaseous Effluent Control Proorams Insoection Scope (84750-01)
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The inspector reviewed: (1) radioactive liquid and gaseous / particulate effluent release permits; (2) effluent control procedures; (3) the 1997 annual effluen't report; and (4) the j Offsite Dose Calculation Manual (ODCM). Observations and Findinas Radioactive liquid and gaseous effluent release permits were complete, including a projected dose to the public. The licensee's most recent release of radioactive liquid I waste occurred on October 16,1998. Effluent control procedures were well-written and easy to follo The 1995,1996,1997, and 1998 Annual Radioactive Effluent Reports provided data indicating total released radioactivity for liquid and gaseous effluents. The assessment of the projected maximum individual doses resulting from routine radioactive airbome 6 Inspection Report No. 50-309/99-01 B:ONMS DocumentsMnsp ReportVtDPR-36.9941.wpd
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and liquid effluents were included, as requited. Projected doses to the public were well I below the TS/ODCM limits, as shown in Table 1. There were no anomalous measurements, omissions or adverse trends in these report I Table Annual Calculated Maximum Whole-Body Doses to the Public due to Radioactive Liquid and Radioactive Gaseous (Particulate / lodine /H-3)
Releases Dose due to Dose due to Gamma air Direct external exposure )
liquid particulate and dose due to plus dose commitment Year release, lodines, noble' gas, from liquid and gaseous mrem /yr (1) mrom/yr (2) mrad /yr (3) releases, mrem /yr (4)
1995 0.021 0.020 ; 0.0006 .002 0.004 0.0003 .006 0.009 0.0006 '1998 0.012 0.005 None Detected (1) TS Limit : 3 mrem / year (2) TS Limit : 15 mrem / year l (3) TS Limit : 10 mradlyear j (4) EPA Limit (40CFR190): 25 mrem / year (mud flats in Bailey's Cove) j The ODCM provided descriptions of the sampling and analysis programs, which were established for quantifying radioactive liquid and gaseous effluent concentrations, and for calculating projected doses to the .public. All necessary parameters, such a7 effluent
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radiation monitor set point calculation methodologies and site-specific dilution factors, ;
were listed. Radioactive gaseous effluent release permits and monthly dose projections l
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The licensee maintained effective radioactive liquid and gaseous effluent control programs. The ODCM contained sufficient specification and instruction to acceptably irrplement and maintain the radioactive liquid and gaseous effluent control program Inspection Report No. 50-309/99-01 B:ONMS Documentsunsp ReportRDPR-36,99-01.wpd
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- R2 ~ Status L7 RP&C Facilities and Equipment
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R2.1 - Cslibidion of Effluent Radiation Monitorina Systems (RMS)
. Insoection Scone (84750-01)
The most r3 cent electronic and radiological calibration results for the following effluent RMS_ and the operability of flow rate monitors were reviewed e Spent Fuel Pool Building Radiation Monitor e Liquid Radwaste Discharge Radiation Monitor
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e- Spent Fuel Pool Building Flow Rate Monitor )
e Main Stack Flow Rate Monitor Observations and Findinas Primary and secondary calibration results of the spent fuel pool building (SFPB) effluent '
radiation monitor were within the licensee's acceptance criteria. Two conversion factors from the primary calibration were available ("Xe and "Kr) and the licensee used a "Kr conversion factor to monitor any noble gas release (only "Kr has a half-life long enough to still be present at Maine Yankee).
Primary and secondary calibrations of the liquid radweste discharge radiation monitor (RM-1664) were in progress during this inspection period. The licensee's procedures require the calibration of RM-1664 prior to use of the liquid radwaste system. The same radiation mon l tor had been installed previously as permanent plant equipment, designated as RM1601, the service water radiation monitor. A complete recalibration of
. RM1664 was necessary because the licensee's records of the RM1601 calibration, performed following installation in 1998, were incomplete and therefore could not be used. The licenser, was investigating and evaluating the incomplete service water radiation monitor calibration records as Condition Report 99-9 ' During a plant tour, the inspector verified the operability of the SFPB and main stack flow rate monitors. The licensee tracked these flow rates to calculate the total quantity of particulates and tritium release . The inspector reviewed licensee Technical Evaluation (TE) 009-99, dated March 24, 1999, titled * Primary Vent Stack (PVS) Sampling Skid Correction Factor Evaluation."
TE 009-99 assessed the representativeness of the PVS normal and attemate sampling l systems by evaluating the potential for particulates to be removed in the sample line before reaching the collection filter (known as "line-loss"). TE 009-99 also evaluated the uncertainty in PVS system air-flow measuring instrumentation, and defined appropriate correction factors to be applied to compensate for equipment variability. The licensee's implementation of the recommendations in TE 009-99 will be reviewed in a future inspection (IFl 50-309/99-0101).
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The inspector observed changing of the particulate sampling filter in February 1999 and noted that the distribution of particles was not uniform on the surface of the filter. The licensee had obtained the vendor's evaluation of the effect of this non-uniform distribution of particles, and had also performed an independent evaluation. The licensee I had identified an asymmetric fitting in the sample line as the cause of uneven deposition of sampled particulates on the filter and had replaced the fitting. The inspector observed PVS sample filters for samples collected after the fitting was replaced, and noted that )
distribution of particulates on the filter was uniform. The uniform particulate distribution indicated that the modification was effective in resolving the proble Conclusions j The licensee established, implemented, and maintained an effective radiation monitoring system calibration program, including flow rate measurement systems. The licensee had resolved problems identified in the new PVS sampling system, assuring representative sampling of the PV R2.2 Air Cleanina Systems Inspection Scope (84750)
The most recent surveillance test results (in-place HEPA (high efficiency particulate)
filters, air capacity tests, and pressure drop tests) were reviewed for: (1) the reactor building; (2) containment purges; and (3) primary auxiliary buildin Observations and Findinas Records of licensee testing were reviewed. The licensee maintained a negative pressure in the SFPB to prevent any unmonitored release. On March 24,1999, the negative pressure was measured at 0.05 inches of water gaug The individual responsible for air cleaning systems was interviewed by the inspecto This individual had very good knowledge of air cleaning system testing methodologies, acceptance criteria, and system operating parameters necessary to maintain a negative pressure for the SFP Conclusions The licensee established, implemented, and maintained an effective air cleaning surveillance program with respect to surveillance tests, HEPA filter mechanical efficiency tests, and air flow rate tests. All surveillance results were within the TS acceptance criteri Inspection Report No. 50-309/99-01 j BENMS Documents \lnsp ReportRDPR-36.99-01.wpd '
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R6 RP&C Organization and Administration i
R Radiation Protection Transition Oraanization a. - Insoection Scope (83722. 83750) l The inspectors reviewed the tumover of radiation protection duties related to the :
decommissioning of the facility from the MY staff to the DOC contractor staf I
b.- Observations and Findinos l
Because most of the plant has been tumed over to the DOC to conduct decommissioning operations, the Maine Yankee RP Organization has been reduced in ;
size, but with a corresponding staffing increase of the DOC's RP contractor, j Radiological Services, Inc. (RSI). Current staffing of the Maine Yankee RP organization I consists of a manager, two contracted radiological engineers, and five RP technician Radiation protection activities relating to spent fuel activities and other areas where MY has retained responsibility (e.g., legacy waste) are monitored by MY RP personne Radiation Protection activities in support of decommissioning will be directly monitored 3 by the staff from the DOC's radiological contractor. Many of the former MY RP and MY ;
- contractor staff are now employees of the DOC or its contractors. A former MY foreman is the site Radiation Protection Manager (RPM) for RS The RSI organization includes the RPM, who provides overall project m'anagement, ar d
. three radiological engineers, each heading one of three technical sections; Radiation Protection Operations (routine radiation protection activities for decommissioning work), j Radiological Support (dosimetry, instrumentation and chemistry), and Radiological Engineering (final site surveys and Al. ARA). In many cases, RSI has teamed up individuals with cutside work experience in a particular discipline with a former MY staff i member so that historical information is maintaine To prepare for the transition, the DOC and RSI revised MY procedures or wrote new procedures as needed. Many of the specific procedures (e.g., those describing operation of vario'us instruments or equipment) were simply reformatted. A significant category of procedures that were written related to final radiological survey Procedures were reviewed by the MY RP staff and revised as necessary. The Procedure Review Subcommittee of the MY Independent Review and Audit Committee
.(IRAC) then reviewed and approved the new procedures. Training was conducted for appropriate staff on the new or revised procedures. The DOC and RSI made formal presentations to the IRAC to describe the new RP organization and the operational readiness of the new organization to assume authority for the tasks of decommissionin From the date of authority transfer, a 30-day moratorium on complex work was observed to ensure that the new organization was functioning smoothly before it was challenge No major coordination problems were identified during the transition period. The initial complex work coverage performed by the new RP organization involved the source term removal project for general area dose rate reductio '10 Inspection Report No. 50-309/99-01 B:ONMS Documents \lnsp Report \RDPR-36.99-01.wpd i
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As part of the tumover of the RP program, the inspectors also reviewed the status of the MY computer program and database for control of health physics equipment. This ,
program (ECUP, for Equipment Control & Utilization Program) is used by both the MY !
and RSI RP staffs to assign instruments, track calibration information, and other similar tasks. Four recent CRs (99-9, 99-39,99-40, and 99-42) were written to document problems with out-of-calibration instrumentation or failure to perform daily or weekly performance testing on instrumentation. One identified cause for these problems was that the information in the ECUP database was not completely up-to-date or had not been used. Due to concem for the accuracy of the information in the database, the licensee immediately recalled from the. field all instruments and equipment to verify the
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status and calibrations of the equipment and to remove from service equipment that was no longer current. The result wss an accurate database with reliable calibration information for the equipment. To address any generic issues, CR 99-42 was also written to examine together the individual occurrences documented in the four CRs
(along with three other RP-related CRs). Two radiation measuring instruments that were i not performance-tested when required were functioning properly when subsequently
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tested. The failure to perform the periodic performance testing on two radiological measuring instruments as required by procedure is a violation of minor significance that is not subject to formal enforcement action Conclusions MY maintains sufficient RP staff to support the areas where it retains responsibility. The transition of the RP organization from a focus on operational issues to a focus on decommissioning issues was accomplished in a planned, orderly manner. Immediate corrective actions were effective for correcting information in a database for RP instrumentation and performing required periodic performance test R7 Quality Assurance (QA)in RP&C Activities Inspection Scope (84750)
The inspection consisted of: (1) review of the 1998 QA audit; and (2) implementation of the measurement laboratory quality control program for radioactive liquid and gaseous effluent sample l Observations and Findinas The licensee's QA audit findings from 1998 did not identify any significant regulatory or safety issues. The scope and technical depth of the audit were sufficient to assess the quality of the radioactive liquid and gaseous effluent control programs. Individuals with ;
experience in radioactive effluent control and chemistry participated as audit team member The QA Support Program consisted of the quarterly distribution of test or quality control samples and issuance of a performance evaluation report. Laboratory quality control
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charts for the gamma spectrometer and a tritium counter were frequently reviewed by licensee staff and used as a mechanism to assess and monitor laboratory performance Conclusions The licensee established, implemented, and maintained an effective QA program for the radioactive effluent control program with respect to audit scope and depth, audit team experience, and response to audit findings. ' The licensee also implemented an effective l laboratory quality control program to validate measurement resuits for radioactive i effluent sample R8 Miscellaneous RP&C lasues R8.1 Characterization of Radioactive Waste Insoection Scope (86750 The inspectors reviewed the characterization and shipping plans for radioactive waste from past operational activities (legacy waste) stored in the LSA buildin Observations and Findinas l
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located in a locked cage within the LSA building. Maine Yankee has referred to this material as " legacy waste" because it had been generated from 1985 through about 1995. Maine Yankee retained the responsibility for characterization and eventual disposal of this waste and did not assign this task to the DOC. The waste consisted of approximately sixteen drums and a few miscellaneous package Because the expected exposure rates on the drums were in excess of one R/ hour and the condition of the contents were unknown, pre-planning was essential to ensure contingencies were addressed and doses to personnel were maintained ALARA. The inspector reviewed the Al. ARA engineering analysis for the legacy waste characterization and shipping. The analysis appeared to address likely and potential .
pathways for radiation exposure to personnel, and recommended practices that would aid in maintaining doses to personnel ALARA. The analysis for the job was thorough and appropriat Initial planning included obtaining all historical information available on these waste Radiation protection practices for dose reduction included setting up a shielded inspection area so that exposure rates and contamination smears on objects couId be easily obtained; using a ykleo camera for remote viewing; establishing a shielded, low
' dose rate working area for the radwaste engineer; and using a fork-truck with long extension forks for drum lifting to take advantage of distance (from the drums) to reduce the dose to the fork-truck operator. A water mist was sprayed on the drum lids while opening drums to reduce potential airborne radiation levels and a continuous air monitor 12 Inspection Report No. 50-309/99-01 B:\DNMS Documents \insp Report \RDPR-36.9941.wpd
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was utilized to monitor airborne activity. Additional work practices to maintain doses ALARA included scheduling no concurrent work in the building, clearing the area of obstructions to allow the fork-truck free access, and ensuring an escape route was available. Drums were weighed with an attached load cell to the fork-truck. Following inspection, the drums were marked for identification and repositioned in an x-y-z coordinate system for ease in recovery to package and shi Maine Yankee's contractor used the historical information, the measurements on the drums, and the results of calculations from a commercial radwaste software program to determine shipping requirements for the wastes. Drums will be overpacked prior to shipment and placed into a shipping cask that can hold as many as six drum Conclusions
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Radioactive wastes generated from historical operations were appropriately characterized and prepared for disposal. Radiation Protection practices during characterization were strong, particularly those relating to maintaining personnel doses ALAR R8.2 ' Radioactive Waste Manaaement and Transoortation Insoection Scope (86750)
The inspector reviewed handling of radioactive waste generated during the source term removal project, and also a shipment of legacy waste from the LSA buildin Observations and Findinas Boxes for packaging waste generated during the source term removal work were observed by the inspector in containment, in the hot maintenance shop, and stored in the outside area of the RCA (Radiological Controlled Area). To minimize potential for exterior contamination, the boxes were wrapped in plastic before moving them into contaminated areas. Waste management technicians loaded the waste into the boxes in containment, grouping materials according to three categories of dose rates defined by the waste processor receiving the shipment. Personnel made efforts to minimize extemal dose rates from containers through use of shielding and centering more radioactive components within the box, as well as controls on the loading into any one I box When filled, the box was moved to the hot machine shop where it was cleaned as i
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necessary and prepared for shipment. When ready for shipment the box was moved to the outside yard for storage until loading onto a truck for transport to the waste processor. The inspector interviewed waste management personnel and noted that they were knowledgeable of ALARA methods to minimize package extemal dose rates and to I minimize the overall number of shipments by efficiently using available waste package ]
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The licensee had contracted for the characterization and packaging of legacy waste which had, until March 1999, been stored behind shielding in the LSA waste buildin The inspector reviewed the shipping manifest for the legacy waste shipment being loaded on May.13,1999. Two packages were being loaded into a shipping cask: one class C and the other class B. Shipment documents reviewed were correctly complete l The licensee demonstrated the computer software used for classifying and documenting radwaste packages and' shipments. The inspector also reviewed procedures PMP 9.1.3,
" Preparation and Shipment of Radioactive Waste Radioactive Material," and PMP 6.9,
" Selection, Training and Qualification of Radiation Protection Personnel" (which includes radwaste personnel). Responsibilities and qualifications for personnel performing radweste packaging and shipping activities were clearly defined in the procedures, as were the steps necessaiy for making waste shipment Conclusion Radioactive waste was being packaged and shipped in accordance with approved procedures. Appropriate and knowledgeable personnel were responsible for packaging and shipping radioactive waste. Personnel were effectively implementing a program to keep waste package extemal exposure rates Al. ARA. No discrepancies were identifie R8.3 Control of Radioactive Material Inspection Scoce 71801 Actions related to site characterization and remediation were reviewe ! Observations and Findinas The licensee had previously identified locations during the radiological characterization of the site where exposure levels were measurably above typical background. The !
licensee's contractor had removed small quantities of soil from two locations at the edge ;
of the contractor parking lot in order to remove radioactive material. Subsequent !
measurements at these locations indicated that exposure rates remained measurably ,
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above background, and in early May 1999 the licensee had removed particles of "Co from the two locations. A 3 pCi particle was removed from 6-inches depth at one i location, and a 13 pCi"Co particle was removed from 12-inches depth at the other location. Exposure rate measurements made by the licensee following removal of these particles were at background levels. Although the licensee could not attribute the raidioactive material to any specific event or operational activity in the parking lot area, additional surveys were planned for further characterization of the parking lot are Conclusion The licensee had effectively remediated two locations where measurable radiation was attributed to plant-related radioactive material. Additional surveys were planned for 14 Inspection Report No. 50-309/99-01 B:ONMS DocumentsVnsp ReportVtDPR-36.99-01.wpd
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further characterization of the parking lot area where the radioactive material was ;
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R8.4 Control of Radioactive Sources InspectioLSgggg_LQaZiQ)
. Follow-up actions were reviewed related to CR 98-361 which addressed discrepancies identified during an inventory of radioactive source i Observations and Findings As discussed in inspection Report 50-309/98-05, the licensee had identified discrepancies in the sources identified versus the records of sources installed in the i plant.: The' discrepancies were documented as a CR for further investigation. The )
inspector reviewed the licensee's evaluation for this CR, completed on February 18, 1 1999. The 1icensee concluded that all discrepancies identified in the inventory could be explained by past personnel errors in reading the identification data inscribed on the j surface of the sources involved. The licensee found that the identification characters l
' inscribed by hand on the small (0.25" by 0.25" right cylinders) sources were difficult to see and read. Additionally, past inventories were conducted based on the devices in j which sources were installed, and direct observation of the sources was not required. It was common practice to use sources interchangeably among the installed devices as
- necessary. Therefore, errors were carried through from one inventory to the next until i the source was directly observed and the errors correcte ; Conclusions
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The licensee conciuded that no sources had been lost, and the inventory discrepancy was due to past administrative errors carried through previous inventories.' The .!
licensee's investigation was found to be reasonable and thorough in identifying the probable causes for the identified radioactive source inventory discrepancie j
R8.5 - Follow-Uo of Previous inspection lasues !
i Insoection Scone (71801. 40500)
The status of selected previous inspection items was reviewe , Observations and Findinas (Closed) VIO 50-309/98-01-02: Failure to log items into Foreign' Material Exclusion 1 (FME) area.' The licensee's corrective actions were described in letter MN-98-46 dated June 17,1998.' Corrective actions were appropriate. The inspector confirmed on i
- numerous occasions that individuals were completing the FME log as require !
Conspicuous postings for FME requirements were apparent in the fuel buildin Inspection Report No. 50-309/99-01 ,
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- Brie 9ngs conducted for work in the fuel building also identified FME concems as prerequisites. This item is close (Closed) URI 50-309/96-12-04: Emergency Response Facilities Ventilation System. The licensee had tracked responses to the inspector's questions regarding the TSC/ EOF l ventilation system. The system is no longer required under the Defueled Er..ergency Plan, effective June 1,1998. This item is close (Closed) VIO 50-309/97 09-03: Radiological Control Area Maintenance Activities Deficiencies. Licensee actions to address this item are described in the response to the violauon by letter MN-98-35 dated April 26,1998. Licensee actions were adequate to address the poor practices and personnel errors determined to have caused the violation. The inspector obaerved personnel to be complying with procedure requirements. This item is close IV. Management Meetings Community Advisorv Panel (CAP)
NRC staff attended meetings of the Maine Yankee CAP on March 11 and April 29,199 The March 11 meeting was attended by three guests from the Connecticut Decommissioning Advisory Committee (CDAC), an organization similar to the CAP, established for oversight of the Connecticut Yankee plant. At the April 29 meeting, NRC staff provided a quarterly update of NRC inspection and licensing activities and discussed issues ofinteres Exit Meeting The inspectors presented the inspection results to representatives of the licensee at the end of each on-site inspection, and summarized the inspection period findings at an exit meeting on May 13,1999. The licensee acknowledged the findings presente Inspection Report No. 50-309/99-01 e ae4S DocumentsVnsp RepoMRDPR-36.99-Otwpd
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m j inspection Procedures Used l
. lP 49500 identifying, Resolving, and Preventing Problems !
IP 60705 Preparation for Refueling ;
" ~ IP 60710 Refueling Activities
' IP 60801 - Spent Fuel Pool Safety at Permanently Shutdown Reactors IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown '
Reactors !
IP 83722 Radweste: Orp2nization and Management Controls (Minimum / Basic)
IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmentai Monitoring IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials .
Items Opened. Closed. and Discussed Opened IFl 99-01-01 Implementation of recommendations in the licensee's Technical Evaluation Number 009-09 (" Primary Vent Stack Sampling Skid Correction Factor Evaluation") !
Closed L VIO 98-01-02' Failure to log items into Foreign Material Exclusion (FME) are URI 96-12-04 Emergency Response Facilities Ventilation Syste VIO . 97-09-03 Radiological Control Area Maintenance Activities Deficiencie Discussed None 4
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List of Acronyms Used CAP, Community Advisory Panel-CDAC Connecticut Decommissioning Advisory Committee CFH ' Certified Fuel Handler CRs _ Condition Reports DOC Decommissioning Operations Contractor ECUP Equipment Control & Utilization Program
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.FME Foreign Material Exclusion :
HEPA High Efficiency Particulate j
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HIC ' High integrity Containe IRAC independent Review and Audit Committee ODCM Offsite Dose Calculation Manual PAB Primary Auxiliary Buiding PVS- Primary Vent Stack QA Quality Assurance QA Quality Assurance
.RCA Radiological Controlled Area RMS ~ R! )diation Monitoring System-RP Fadiation Protection -
RP&C Radiological Protection and Ctemistry ;
RPM . Radiation Protection Manager !
RSI .. RaGological Services, In !
-SFP Spent Fuel Pool i SFPB Spent Fuel Pool Building - )
.TS- Technical Specification 1
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PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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M. ' Meisner, President M. . Ferri, Vice President-Decommissioning W.. Odell, Director of Operations W. Henries, Director, Engineering -
S. Dahlgren, Manager, Decommissioning
- T. Williamson, Quality Assurance Manager:
W. Ball, Manager, Operations J.; Mallon, Radiation Protect Manager
' J. Niles, Assistant Manager, Operations M. Evringham, Manager, Maintenance G. Zinke, Director-Regulatory Affairs
? J.- McCann, Licensing S. Gray, Site / Construction Manager, Stone & Webster W. Lach, Chemistry D. Hann, Chemistry E. Brand, Licensing M. Whitney, Licensing .
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R. Cole, Director, Waste Management / Radiation Protedion M. Readinger, Manager, Radwaste C. Young, Radweste Shipping Coordinator Dennis Hickey, RPM, RSI Glen Collins, ALARA engineer, MY contractor
Robert Gann, RP Supervisor, RSI Other P. Dostie, Maine, Nuclear Safety inspector D. Randall, Maine Nuclear Safety inspector l
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