ML20140C699
| ML20140C699 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 06/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20140C683 | List: |
| References | |
| 50-309-97-03, 50-309-97-3, NUDOCS 9706100030 | |
| Download: ML20140C699 (26) | |
See also: IR 05000309/1997003
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Docket No:
50-309
License No:
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Report No:
50-309/97-03
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Licensee:
Maine Yankee Atomic Power Company (MYAPC)
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Facility:
Maine Yankee Atomic Power Station
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Location:
Bailey Point
Wiscasset, Maine
Dates:
March 16, through April 26,1997
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Inspectors:
Jimi Yerokun, Senior Resident !nspector
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Division of Reactor Projects
Richard Rasmussen, Resident inspector
Division of Reactor Projects
Randolph Ragland, Radiation Specialist
Division of Reactor Safety
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Approved by:
Curtis J. Cowgill, Ill, Chief, Projects Branch No. 5
Division of Reactor Projects
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9706100030 970605
ADOCK 05000309
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EXECUTIVE SUMMARY
Maine Yankee Atomic Power Company
NRC Inspection Report 50-309/97-03
This integrated inspection included aspects of licensee operations, engineering,
maintenance, and plant support. The report covers a six week period of resident
inspection; in addition, it includes the results of an announced inspection by a regional
inspector in the area of radiation protection,
Ooerstions
Plant personnel responded appropriately when it was determined that some safety-related
valves had not been tested as required by in-Service Test Program. Operability
determinations were timely and well documented and provided an adequate basis for
returning the residual heat removal (RHR) system to an operable condition. When an RHR
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suction valve failed to open during this testing, operators were cautiously monitoring core
temperatures, and were prepared to open the valve manually, if necessary. (Section 01.2)
During the RHR suction valve testing, an inadequate cross-disciplinary review and lack of
understanding of the impact of other ongoing surveillance activities, was considered an
example of inadequate control of activities resulting in a configuration control problem. A
prior example was documented in NRC inspection report 50-309/97-01, which involved a
1300 gallon spill of RWST water due to operations not understanding the effects of
ongoing pump work on the pressure boundary. (Section 01.2)
Operators generally maintained good safety focus and properly operated the systems
needed to maintain the plant in a safe, shutdown condition. The " protected train" program
clearly identified components of concern and restricted access into these areas, providing
an additional level of control for this equipment. (Section 02.1)
Instances of weak operator performance continued to occur as demonstrated during the
baseline testing of a containment spray (CS) pump and during residual heat removal (RHR)
suction valve testing. As a result of inattention to detail, an operator started a low
pressure safety injection pump in lieu of a CS pump. Contributing to this event was
weakness in the control room command cnd control function and poor on-shift
communications. The Shift Operating Supervisor did not take the appropriate immediate
action to deal with the operator error, which would have been termination of the test, and
the Plant Shift Superintendent was not notified of the error in a timely manner. (Section
04.1)
Progress was made in implementing the Learning Process; however, continued focus to
fully implement the process was noted as necessary. Approximately three months after
initiation, a back log had developed and the majority of learning bank issues with the
highest risk levels (one and two), had not been formally accepted by issue managers.
(Section 07)
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Maintenance
As the focus shifted to a refueling outage, the volume of maintenance work increased.
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Work was appropriately controlled in the field and performed in accordance with approved
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procedures. (Section M1)
Enaineerina
Good efforts were ongoing to address the problems with fire barrier penetration seals.
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Initiallicensee engineering inspection results indicated that about 90% of the
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approximately 2,600 penetrations inspected required replacement or repair. Some of the
discrepancies included: inadequate seal thickness; improper damming; defective seals (bad
structure, gaps or voids); inadequate material (cerafiber only); and presence of foreign
materials. (Section E8.3)
Plant Sucoort
in the area of plant support, we found that Maine Yankee continued to maintain adequate
programs in the areas of occupational radiation exposure. ALARA planning and health
physics oversight of steam generator work activities were excellent, and contamination
control initiatives were very good. Notwithstanding, the restricted area tool control
program was not fully developed; some contamination monitoring practices were found to
be inconsistent. The newly implemented learning process had distinct advantages over the
formerly used radiological incident reporting system, although some difficulties with
administrative use of the learning bank were encountered and a backlog appeared to be -
developing relative to high priority issues that remained to be assigned to an issue
manager. Finally, although learning bank corrective action tasks were generally sufficient
to prevent recurrence, an example was identified where the corrective action addressed the
symptom and not the listed apparent cause. (Section R1)
In the security area, activities continued to be conducted well as evidenced by the good
performance of two security officers on April 15,1997, when they diligently performed
their task and identified contraband during a vehicle search and thus prevented the item
from being brought into the protected area. (Section S4.1)
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TABLE OF CONTENTS -
TABLE O F CO NT ENT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
l . O pe r a tio n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
O1
Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
02
Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . 2
04
Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . .-. 3
07'
Quality Assurance in Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
08
Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
ll. Maintenance...................................................
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M1
Conduct of Maintenance
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Miscellaneous Maintenance issues (92902) . . . . . . . . . . . . . . . . . . . . . 7
111. Engineering
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E8
Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
I V. Pl a nt Su p p o rt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
R1
Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . 9
R2
Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 14
R5
Staff Training and Qualification in RP&C . . . . . . . , . . . . . . . . . . . . . . 15
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RP&C Organization and Administration
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Quality Assurance in RP&C Activities
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Miscellaneous RP&C lssues
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Security and Safeguards Staff Knowledge and Performance
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V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19.
X1
Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
X2.
April 3,1997, Public Meeting . . . . . . . . . . . . . .
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INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21-
LIST OF ACRONYMS USED
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Report Details
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Summarv of Plant Status
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Maine Yankee remained in the cold shutdown condition and officiaily entered a refueling
outage during this period. The spent fuel pool re-rack project was the critical path for the
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outage. Maine Yankee plans a full core off-load in conjunction with the replacement of the
leaking fuel assemblies and similar, susceptible assemblies.
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l. Operations
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Conduct of Operations
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01.1
General Comments (71707)
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Using Inspection procedure 71707, the inspectors conducted reviews of ongoing plant
operations. Operations maintained good fccus on and control of the systems required for
chutdown cooling. They provided good support for ongoing outage activities, such as the
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spent fuel pool re-racking and the eddy current testing of the steam generators.
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01.2 Residual Heat Removal System Declared inoperable
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a.
Insoection Scope
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On April 11,1997, engineering personnel notified operations personnel of
deficiencies in the in-service test program (IST) that resulted in the technical
specification required boration flowpath and both trains of residual heat removal
(RHR) being declared inoperable. The inspector reviewed the testing and
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verifications performed prior to declaring the boration flowpath and RHR operable.
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b.
Observations and Findinas
Prior to the review of the IST issues on April 11,1997, RHR was in service and
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both trains were considered operable. The IST program review was being
performed as outlined in Appendix G of the Maine Yankee Restart Readiness Plan.
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identified deficiencies ranged from tests that were performed, but were not
adequately documented, to tests that were never performed, in total, thirty
deficiencies were identified that affected boration, RHR or RHR support systems.
Operations utilized the learning bank process and operability determinations to
address the various concerns. The operability determinations documented the
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resolutions to each of the specific problems. For some manually operated valves,
the IST test requirement was that the valve had operated properly within a specified
period of time. Several valves were declared operable based on records of having
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been operated due to normal plant procedures. However, some corrective actions
included developing and implementing new test procedures to test the valves.
Other deficiencies such as relief valves that required testing were able to be
compensated for in the shutdown condition by administratively tagging open vent
paths to provide alternate over pressure protection.
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Maine Yankee worked this issue as urgent on a 24-hour-per-day basis until
operability of the boration flowpath and one RHR train was restored. The second
train of RHR was not restored because it was scheduled to be taken out of service
for outage work and only one train was required for the current plant condition.
Maine Yankee experienced one problem while performing a test of the RHR suction
valves. Procedure 3.1.20.4, IST Valve Testing at Cold Shutdown, was revised to
incorporate the cycling of the RHR motor-operated suction valves, RH-M-1 and RH-
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M-2. The procedure required all RHR to be secured and the suction valves cycled.
During the cycling of the first valve, RH-M-2, the valve shut and failed to reopen.
The operators quickly determined that the failure was due to an open slide link
configured to support other ongoing instrumentation and control (l&C) work. The
valve was reopened within approximately 35 minutes. During the time RHR was
secured, operators were appropriately monitoring core temperatures and an operator
was stationed ready to manually open the suction valve if required.
The issue of RH-M-2 failing to open was entered into the learning process as a risk
level 2 issue, indicating that a root cause evaluation was required. The apparent
causes, initially identified by operations, inc!uded: an inadequate cross-disciplinary
review of the procedure change; and, inadequate understanding by operators of the
effects of other ongoing l&C surveillance activities.
c.
po glusions
Maine Yankee responded appropriately to the determination that key valves had not
been tested as required by IST. Operability determinations were well documented
and provided an adequate basis for returning the system to operable. The response
to the failure of the RHR suction valve to open was appropriate. Operators were
prepared to open the valve manually and were cautiously monitoring core
temperatures.
However, this is another example of challenges to the operators caused by a Icck of
knowledge of configuration control during the outage. The inadequate cross-
disciplinary review and lack of understanding of the effects of ongoing surveillance
activities indicate a lack of focus in the area of procedure development and work
coordination. A prior example was documented in NRC inspection report 50-
309/97-01, which involved a 1300 gallon spill of RWST water due to operations not
understanding the effects of ongoing pump work on the pressure boundary.
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Operational Status of Facilities and Equipment
02.1
Service Water and Primary Comoonent Coolina Water Systems
a.
Insoection Scope (71707)
The inspectors conducted walkdowns of portions of the service water (SW) and
primary component cooling (PCC) water systems to ascertain that the systems were
maintained operable for the plant condition.
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b.
Observations and Findinas
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With the plant in cold shutdown and preparing for refueling, the inspectors focused
on core and spent fuel pool cooling systems. The core was stillloaded, with RHR,
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train A, maintaining core cooling. The heat sink for RHR, train A is the primary
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component cooling water system via the RHR heat exchangers. The spent fuel pool
is cooled by PCC via the spent fuel pool heat exchangers. The PCC is cooled by
SW, the ultimate heat-sink via the PCC heat exchangers.
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The inspector observed the material conditions in areas of the PCC pumps and heat
exchangers in the turbine building, the RHR pump and heat exchanger in the
containment spray (CS) building, and the service water pump house. There were no
significant discrepancies observed. The pumps, heat exchangers, valves and other
components were maintained well and showed no deficient conditions. The -
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systems were operating well and within the expected flow and temperature
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conditions. Control room switches and indications were as expected.
As a method for ensuring outage work did not impact the equipment required for
maintaining the plant in a safe condition, operations developed and implemented the
" protected train" concept. -This required compononts of the protected train to be -
roped off and labeled with a warning sign. Access to the affected areas was
restricted and controlled by the plant shift supervisor (PSS). Personnel were
permitted into the area (s) only after discussing their tasks with, and being briefed by
the PSS. Exceptions included personnel such as operators, security and fire
watches, who make frequent tours and observations in these areas.
c.
Conclusion
Operators generally maintained good safety focus and properly operated systems
required to maintain the plant in a safe, shutdown condition. The " protected train"
program clearly identified components of concern, and as implemented, restricted
access to the areas containing these components providing an additional level of
control for the equipment.
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Operator Knowledge and Performance
04.1 Containment Sorav (CS) Pumos Baseline Test
a.
Inspection Scool
The inspector observed and reviewed portions of tests of the containment spray
pumps conducted in accordance with surveillance test procedure 3-1-15-3,
emergency core cooling system (ECCS) Operational Pump Flow and Check Valve
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Testing.
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b.
Observations and Findinas
On April 9,1997, the inspector observed testing of CS pump, P-61 A. The test was
conducted to gather pump operating data as baseline information prior to the
proposed modification of the CS pumps. Pumps P-61B and P-61S were also
scheduled to be tested. The test involved operating the pump at various flow rates
and obtaining operating parameters (vibration, flow, and pressure). A temporary
procedure change (TPC 97-154) was incorporated into the test procedure to
accommodate the testing conditions.
The inspector reviewed the test instructions, observed testing activities and
discussed the test with the licensee. The test procedure and TPC were current and
had been properly approved. There was background information provided with the
TPC discussing the reason for the test. The pre-test brief in the control room was
detailed and well conducted. Test conduct, controls and expectations were clearly
discussed. Duties were clearly delineated. At the test locations, test instruments
were located well and properly calibrated. Test personnel were stationed at each
instrument location.
At the start of the test, the inspector observed that low pressure safety injection-
(LPSI) Pump, P-12A, started and stopped almost immediately. Subsequently, the
CS pump started and testing continued. After the test, when the inspector asked
the Plant Shift Superintendent (PSS) about the LPSI pump start, he was unaware -
that it had happened. Subsequently, he was informed by the reactor operator who
had made the error. He indicated that he had erroneously started the LPSI pump
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instead of the CS pump and upon realizing his error had immediately stopped the
LPSI pump and then started the CS pump. The controls for both pumps are located
on the ECCS portion of the control board in close proximity.
The inspector expressed concern regarding several aspects of the evolution. First,
the operator had continued with the conduct of the test after starting the wrong
ECCS pump. Also, the Shift Operating Supervisor (SOS) who had direct supervision
of the operator had not directed that the test be terminated. The PSS was not
made aware of the error in a timely fashion.
This issue was entered into the learning bank, Maine Yankee's corrective action
process. The SOS and operator involved were counseled and removed from shift
pending completion of the investigation of the event. Operations management
initiated additional immediate corrective actions that included re-emphasizing the
responsibilities and authorities of the SOS as delineated in procedure 1-26-4,
Responsibilities and Authorities of Operating Personnel, to operators. The LPSI
pump was inspected to verify that the inadvertent start and stop had no detrimental
effect. The licensee also verified that there was no effect on any other related
components.
The inspectors assessed the safety consequence of this error and determined that it
was minimal. The pump operation was for a short period of time and caused no
detrimental effect on the pump. There was no effect on core cooling since the train
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maintaining core cooling was unaffected. Nevertheless, the event was indicative of
a lack of attention to detail on the part of the operators, in, addition, operators
failed to properly execute their responsibilities as expected. Specifically, plant
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procedure 1-26-4, Responsibilities and Authorities of Operating Personnel, revision
9, Section 3.2.3, required the SOS to ensure that his personnel stop evolutions
when unexpected conditions arise. Section 3.3.3 of the same procedure required
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the Control Room Operator to stop an evolution when unexpected conditions arise.
the inspectors considered that operators failing to properly execute the
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responsibilities of their position as required by procedure 1-26-4 a violation of
Technical Specification (TS) 5.8.2. TS 5.8.2 required that written procedures shall
be established, implemented and maintained covering the activities referenced in
Appendix "A" of Regulatory Guide 1.33, (Rev. 2), February 1978, which include
administrative procedures for authorities and responsibilities for safe operation and
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shutdown. (VIO 50-309/97-03-01)
c.
Conclusion
The inspector concluded that this incident was indicative of weakness in operator
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performance due to inattention to detail. There was also weakness in control room
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command and control, and shift communications. The SOS did not take the
appropriate immediate action to deal with the issue, which would have been test
termination, and the PSS was not notified of the error in a timely manner.
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Quality Assurance in Operations
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a.
Inspection Scope (40500)
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The inspectors performed a review to evaluate the effectiveness of the station
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problem identification / resolution program (learning process) for correcting
deficiencies. Information was gathered by a review of lists of learning bank issues,
various learning bank reports, and through discussions with cognizant personnel.
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b.
Observations and Findinas
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The inspectors reviewed a report generated from the learning bank entitled,
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" Learning Bank Acceptance Report." This report listed the learning bank issue (s),
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discovery date, data entry date, general status, issue manager by name, and
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whether the issue had been formally accepted by the issue manager. Learning bank
issues were assigned risk levels from one to four. Risk level one issues were
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considered urgent with an extremely high risk. These required a formal root cause
and normally involved a multi-disciplined team to evaluate the issue. Risk level four
issues were considered to have a low risk to the company. The inspectors noted
that as of April 2,1997,42 risk level one issues had been entered into the learning
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bank; however, only 20 had been accepted by an issue manager. Similarly,74 risk
level two issues had been entered into the learning bank and only 21 had been
accepted by an issue manager. The inspectors raised a concern to a learning
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process team member that the report indicated that the majority of urgent and very
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urgent issues had not yet been accepted by issue managers. The learning bank
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team member stated that many of the issues that had not been formally
(administratively) accepted were associated with cable separation issues, and were
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actually being handled by management teams that were in place to address cable
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separation issues. The learning process team member also stated that although
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issues were being entered into the syster, at a higher rate than originally
anticipated, immediato actions were taken for such issues. Further, it was indicated
that management was aware of this concern and was considering additional
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actions.
c.
Conclusions
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The inspectors concluded that management attention and focus on the Learning
Bank continues to be warranted. Approximately three months after initiation of the
learning bank (problem identification / resolution system), a backlog had developed
and the majority of learning bank issues with the highest risk levels (one and two),
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had not been formally accepted for evaluation and resolution by issue managers.
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Miscellaneous Operations lasues
I.n.soection Scope (92901)-
The inspectors reviewed previously identified issues including Licensee Event
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Reports (LER), Inspector followup items, and unresolved items to determine if they
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could be closed.- The review included a review of documentation, and activities to
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ascertain that the issues had been properly addressed and that the appropriate
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regulatory action is taken as required. The following previously identified issues
were reviewed:
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08.1 Qosed. Licensee Event Reoort 96-001. Emeroency Core Coolina Pumos Declared
lnocerable Due to a Reduction of Ventilation Flow
On January 10,1996 Maine Yankee declared both trains of the LPSI and CS
systems inoperable due to less than design room ventilation flow rates. The
inadequate ventilation flow was caused by a partial blockage of the suction flow
path for the CS building HVAC unit, HV-7.
This issue was addressed in various NRC inspection reports and included in NRC
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Inspection Report 50-306/96-16 as an apparent violation of NRC requirements. The
inspectors reviewed the LER and verified that the information provided was
accurate. This item is closed.
08.2 Closed. IFl 50-309/96-02-01. Containment Sorav Buildina Heatina Unit HV-7
in NRC Inspection Report 50-309/96-02, the inspectors expressed a concern
regarding conduct of maintenance on a non-safety related component causing both
trains of LPSI and CS to be declared inoperable. The problem was that a blockage
of the inlet plenum of CS building heating unit, HV-7, caused fans FN-44A and 44B
to be inoperable. The insufficient ventilation to the CS building resulting from the
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inoperability of these fans caused both trains of LPSI and CS pumps to be
inoperable. HV-7 is a non-safety related component while fans, FN-44A and 44B,
and the LPSI and CS pumps are safety related. This issue was identified as an
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inspector follow-up item pending completion of further review to determine the
regulatory significance. In NRC Inspection Report 50-309/96-16, this issue was
dispositioned as an apparent violation of regulatory requirements. This item is
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closed.
11. Maintenance
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Conduct of Maintenance
M 1.1 General Comments
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During the period, the volume of maintenance work greatly increased as Maine
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Yankee shifted focus to the refueling outage. The outage management presence
was increased with the adoption of daily outage meetings. The inspectors
monitored the daily shutdown safety ascessment and found no work activities
compromising this assessment. Work observed in the field was appropriately
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controlled and performed in accordance with approved procedures. The following
maintenance and surveillance items were specifically observed. No discrepancies
were observed.
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Periodic maintenance of check valve SCC-7
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Repair of valve CS-72
Replacement of the spent fuel pool purification pump motor
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Periodic maintenance of 6.9 kv breakers
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ECCS Routine Testing of Service Water Pumps
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M8
Miscellaneous Maintenance issues (92902)
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M8.1 Closed, URI 50-309/96-06-01, and URI 50-309/96-13-02, Auxiliarv Feedwater
(AFW) Pumo
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in NRC Inspection Report 50-309/96-06, the inspectors identified a concern with
maintenance activity on the AFW pump oil cooler. Specificaily, there appeared to
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be a weakness in the repair effort of the oil cooler on June 12,1996. Following
that repair, the oil cooler failed again on June 16. In general, the inspectors were
concerned with the licensee's efforts to maintain the reliability of the AFW pump
since a review of the pump's availability records revealed that numerous corrective
maintenance activities had occurred. The issue was left unresolved pending a
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review of licensee actions to ensure pump operability.
Also, in NRC Inspection Report 50-309/96-13, the inspectors identified an apparent
inadequacy during maintenance on the AFW pump. The maintenance was to
enhance the pump's operation because of the pump's relatively poor past operating
history causing it's reliability to be declining over the past several years.
Subsequent post-maintenance testing revealed some inadequacy with the pump
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packing rings testing. In addition, the inspector noted apparent inadequate test
control and inattentiveness by a technician who adjusted the steam admission valve
controller contrary to test requirements. This item was left unresolved pending
completion of licensee action and further NRC staff review.
In NRC Inspection Report 50-309/96 16, inadequate maintenance for the AFW
pump was identified as an apparent violation of regulatory requirements. The
licensee's corrective actions and activities to ensure the improved reliability of this
pump will be reviewed and addressed as part of the NRC's review and followup of
the response to the violation.
Ill. Enaineerina
E8
Miscellaneous Engineering issues
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E8.1
Closed. URI 50-309/96-11-02, HPSI Cut Wire, Event Review Board - Root Cause
Analvsis
in late August,1996, Maine Yankee convened an Event Review Board to
investigate the circumstances surrounding the severed wire found in the control
circuitry of high pressure safety injection (HPSI) pump, P-14A on August 17,1996.
In NRC Inspection Report 50-309/9611, this item was left unresolved pending the
NRC's review of the results of the board's investigation.
In NRC Inspection Report 50-309/96-16, the HPSI severed wire issue was identified
as an apparent violation of regulatory requirements. The licensee's corrective
actions, including the root cause determination will be reviewed as part of that
violation.
E8.2 Closed, URI 50-309/96-16-04. HPSI Flow Testina and Throttle Valve Settinas
In NRC Inspection Report 50-309/96-16, the inspectors identified a concern with
the testing of the HPSI pumps at high flow conditions and the setting of the HPSI
system throttle valves. During previous pump test at full flow, it appeared that the
pumps could have been operating at close to runout conditions. In addition, the
setting of the position of the throttle valves needed a more precise tolerance to
ensure that required flow is met and pump runout conditions are not exceeded.
This issue was left unresolved pending review of further licensee testing of the HPSI
pumps and resetting of the throttle valves.
In response to this concern, Maine Yankee performed testing of the HPSI system to
verify adequate net positive suction head for all required modes of pump operation.
The test was witnessed and reviewed by the inspectors as documented in NRC
Inspection Report 50-309/96-14 (section E1.1). The issue was identified as an
unresolved item (50-309/96-14-02) pending completion of detailed review of the
test results by the NRC. This issue will be tracked via item 50-309/96-14-02, and
this item, URI 50-309/96-16-04, is closed.
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E8.3 Open,URi 50-309/96-08-05, Fire Protection Barrier Seals
a.
The inspectors reviewed the licensee's activities involving the fire barrier
penetration seal repair project.
Following the identification of several degraded 8-inch fire barrier penetration seals
in 1996, Maine Yankee embarked on a project to inspect all fire barrier penetrations
at the plant and restore each one to the qualified state. The NRC inspected this
issue and left it unresolved pending completion of NRC's reviews of the licensee's
actions to eddress the problem.
The inspectors reviewed on-going licensee actions to address this issue. In March
1997, the inspectors discussed and assessed the status of the project with the
licensee. The purpose of the project was to conduct detailed walkdowns of the
seals to identify problems and implement any required repairs / upgrades, in addition,
the intent was to properly label and map the barriers and improve the detail in
existing documentation.
With the initial inspection of all seals completed, the licensee has identified that
about 90% of the approximately 2,600 penetrations inspected, required
replacement or repair. Some discrepancies identified include: inadequate seal
thickness; improper damming; defective seals (bad structure, gaps or voids);
inadequate material; and presence of foreign materials.
The licensee had just initiated repairs to address the identified discrepancies. Along .
with fire barrier consideration, the seal design requirements include: high energy
line break; flooding; current induced heat load; and cardox/halon retention. The
inspectors will continue to monitor licensee efforts in this area. This item remains
open pending completion of the repairs, the root cause analysis, and NRC review of
the licensee effort.
LV. Plant Suocort
R1
Radiological Protection and Chemistry (RP&C) Controls
Reviews were performed of occupational radiation exposure. Specific areas
reviewed included radiological cor:trols for steam generator inspections; locked high
radiation area key control; contamination controls; status of f acilities and
equipment; staff training; organization and administration; and a review of the
effectiveness of the newly imp!emented problem identification / resolution system
(learning process). A review of facility conditions versus the requirements in the
Updated Final Safety Analysis Report (UFSAR) was also performed.
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R1.1 Steam Generator Work
a.
Inspection Scoce (83750)
!
The inspector reviewed radiological control preparation and planning for steam
generator work. Information was gathered through reviews of ALARA pre-job and
work-in-progress reviews; graphs of average historical dose rates for steam
generator bowls; pre- and post- steam generator bowl decontamination efforts;
i
inspections of health physics controls at the steam generator platforms and in the
steam generator monitoring trailer; and discussions with cognizant personnel.
b.
Observations and Findinas
.
The inspector reviewed various ALARA reviews for steam generator primary side
'
testing and repair, including setup and decontamination activities. Total radiation
i
dose for steam generator primary side testing and repair was estimated to be 62
person-rem. This included 2.5 person-rem for manway cover, diaphragm, and
ALARA shield door removal / installation; 4.5 person-rem for decontamination of the
steam generator bowls; 50 person-rem for primary side testing and repair; and 5 .
person-rem for radiological protection (RP) technician dose. Person-rem estimates
were based on anticipated work scope and historical data, and appeared reasonable.
In addition, ALARA reviews showed evidence of extensive planning; required
-
coordination between multiple work groups (e.g., health physics, decontamination
crews, maintenance); and were comprehensive and very detailed. Information was
included on work schedules, job prerequisites, dose reduction initiatives,
engineering controls, training, contamination controls, and radwaste considerations.
One of the major ALARA measures implemented in preparation for steam generator
inspections was a high pressure wash (decontamination) of the steam generator
channel heads (bowls). The process involved installing a specialized
decontamination manway with a remotely operated 3-D water jet lance. The
system (Hennigan decontamination system) delivered a high pressure water spray to
exposed surfaces within the bowls. The effluent was removed through suction
lines from the bottom of the bowls and filtered, and the entire process took
approximately two days to complete.
A graph of average steam generator tube channel head dose rates versus time
indicated that average channel head dose rates in 1978,1980, and 1985 were
greater than 30 R/h. The chemical decontamination performed in 1995 reduced
channel head dose rates to an average of about 6 R/h, and the post chemical
decontamination bowl wash' reduced channel head dose rates to about 2 R/h.
Nineteen ninety-seven survey results indicated that channel head dose rates had
increased to about 2.5 R/h, and contamination levels were estimated to be on the
order of 500,000 - 3,000,000 dpm/100 cm'. Upon completion of the high pressure
bowl wash, survey results showed that loose contamination levels in the c.hannel
head were reduced by about a factor of five, down to about 100,000- 600,000
dpm/100 cm'. In addition, although overall gamma levels were only slightly
reduced, the dose rates at a single point at the plane of the manway were reduced
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,
by 40 percent. The inspector noted that this decontamination had the potential to
result in significant dose savings due to decreased needs for use of respirators, hot
particle controls, platform decontaminations, and trash changeouts.
The inspector noted that the health physics staff maintained very close oversight of
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work on the steam generator platforms from a remote health physics control point
located outside of the restricted area. Pan, tilt, zoom cameras, and audio head sets
allowed health physics technicians to communicate directly with personnel on the
~
steam generator platform, and observe essentially all activities. Remote reading
area radiation monitors allowed for dose rate monitoring, and remote readout
dosimetry (telemetry) allowed for continuous monitoring of personnel exposures and
exposure rates. Further, steam generator airborne radioactivity levels were also
remotely monitored by technicians in the remote control point. The inspector
questioned various health physics technicians concerning health physics monitoring
,
of steam generator work and found the technicians to be extremely knowledgeable
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of radiological controls and ongoing work. The inspector concluded that health
physics oversight, monitoring, and control of steam generator work was excellent.
c.
Conclusion
Based on this review, the inspector concluded the following:
ALARA planning for steam generator work was thorough, comprehensive, e
and detailed.
Health physics oversight, monitoring, and control of steam generator work
was excellent.
R1.2 Hiah Radiation Area Kev Control
a.
Inspection Scoce (83750)
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A review was performed on the use of keys to control access to high radiation
areas. Information was gathered by inspections of locked high radiation area doors,
inspections of the locked high radiation area key storage cabinet, review of the
health physics shift log, review of procedural guidance, and by interviewing a shift
)
health physics technician.
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b.
Observations and Findinas
During tours through the plant, the inspector checked the integrity of high radiation
area door locks. All doors to areas controlled as a locked high radiation area were
either locked or properly controlled to prevent inadvertent access. All doors and
locking devices inspected appeared to be in good physical condition.
The inspector examined the key storage locker located in the health physics office,
and noted that the keys were contained in a locked box, had encumbering devices,
and were well controlled by the shift technician. The health physics shift log book
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also showed evidence that keys were being properly inventoried on a shift-by-shift
basis.
The inspector reviewed procedural guidance contained in procedure 9-2-101,
" Control of Keys and Doors to High and Very High Radiation Areas," Rev. O.
Procedural guidance was good in that it was clear, specifically listed responsibilities
and methods for controlling access to locked high radiation areas, and keys were
only issued to health physics and operations personnel. The inspector did,
however, identify a program weakness in that high radiation area keys were generic
and each one could be used to unlock any Tech Spec 5.12 High Rad door in the
plant. The shift Health Physics technician explained that health physics supervision
had previously recognized this, and had initiated steps to eliminate the use of
generic keys, and use only specific keys for high radiation area doors.
c.
Conclusion
Based on this review, the inspector concluded the following:
The high radiation area key control program was generally good, and steps
were being taken to improve the program.
R1.3 Contamination Control
a.
Inspection Scoce (83750)
A review was performed on ongoing efforts to improve contamination controls at
Maine Yankee. Information was gathered by a review of procedural guidance and
other documentation, discussions with cognizant personner, and tours through the
plant.
b.
Observations and Findinas
The assistant Radiation Protection Manager (RPM) stated that efforts to improve
contamination and radioactive material controls included increased tracking and
trending of the type, activity, and cause of personal contaminations; procedure
revisions to require radioactive material stickers to be applied to equipment being
released from a contaminated area until a determination could be made that the
material met the condition for release into clean areas; decontamination staffing
augmentations; initiation of an extensive hot machine shop clean-up; increased area
wipe-downs; increased use of sticky pads at area exits; investigations into the use
of a temporary radioactive material processing facility; and the development of a
tool control program.
The inspector noted that the licensee was effectively tracking and trending
contamination events, and was addressing the root causes of personnel
contaminations. Efforts to increase staffing of decontamination personnel, increase
plant decontaminations, improve material handling practices, and development of a
tool control program were very good initiatives. However, the inspector noted that
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the tool control program was not fully developed, in that the maintenance
department had not yet taken the lead for this activity. The assistant RPM stated
that due to plant priorities, the maintenance department had not been able to
allocate the time necessary to meet preliminary goals for the development of the
tool control program.
The inspector also reviewed ALARA Review 96-01, " Spent Fuel Pool Reracking
Project Contamination Control Program," and discussed contamination controls
'
implemented during the fuel pool rerack project with a lead health physics
technician. The inspector noted that the rerack project required contaminated fuel
racks to be transported to outside areas (back yard of the restricted area) for
loading into transport containers. Contamination control measures included
requirements to rinse items down as they were removed from the fuel pool, wrap
items prior to transport to outside areas, and establishing contingencies in the case
of high winds or precipitation. The lead health physics technicians was able to
describe, in detail, contamination control measures implemented for each sequence
of work. The inspector concluded that although the fuel rerack project presented
significant contamination control challenges, the measures implemented were
reasonable and effective.
During tours of the facility, inspectors identified an inconsistency in the
contamination control program. An RP technician was observed transporting a cart
through the new fuel receiving area backyard door. The RP technician performed-
personnel contamination monitoring prior to exiting the door, but did not perform
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contamination monitoring of the cart or wheels of the cart prior to transporting the
cart into the back yard. The inspectors questioned this practice, and the RP
technician and the shift RP technician explained that this was an accepted practice.
The rationale expressed was that if an individual was contaminated, the hands and
feet would be the most likely indicators; therefore, additional surveys of equipment
and materials were not necessary; and the potential for offsite release was low
since the back yard was not used as a routine restricted area exit point. The
inspectors acknowledged that it was unlikely that this practice would result in a
measurable offsite release (if contaminated equipment was inadvertently transported
to the back yard of the restricted area). However, trends for personnel
contaminations produced by the radiological controls department showed that, of
the personnel contaminations documented from January 1,1997 to March 31,
1997, only 35 of 94 of the contaminations occurred on hands or shoes. This issue
was raised to the RPM who stated that contamination monitoring practices would
be revised to require all cart wheels to be surveyed prior to transportation to
backyard areas, and that contamination monitoring practices at the new fuel
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receiving area back yard door would undergo further review.
c.
Conclusions
Based on this review, the inspector made the following conclusions:
e
The licensee was effectively tracking and trending contamination events, and
was addressing the root causes of personnel contaminations.
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Contamination control program improvement initiatives such as increased
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plant decontaminations, procedure upgrades, and development of a tool
control program were very good.
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.The restricted area tool control program was not fully developed, and
preliminary milestones for program development were not being met.
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e
Contamination monitoring practices were inconsistent in that contamination
monitoring was required for personnel, but not materials and equipment,
prior to movement through the new fuel receipt area door, to the back yard
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of the restricted area.
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'R2
Status of RP&C Facilities and Equipment
a.
Insoection Scope (86750)
The inspector performed an evaluation of radiological control boundaries,
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radiological postings, housekeeping, and personnel use of an automated access
control / electronic dosimetry system. Information was gathered through tours of the
primary auxiliary building (PAB), the vapor containment (VC), and the hot machine
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shop, reviews of radiological survey data, and interviews with plant workers.
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b.
Observations and Findinas
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Radiological boundaries in the PAB, VC, and hot machine shop were clearly
delineated and well maintained, and radiological postings met procedural and -
regulatory requirements, and were informative.
Overall housekeeping was good and showed improvement. Walkways and aisles in
the containment building and lower spray building were notably clear and free of
debris, and the boundary around the reactor cavity was wellidentified.
The inspector also observed personnel use of a newly installed automated access
control / electronic dosimetry system. The system was generally easy to use to
assign personnel to work-activity-numbers on radiation work permits, and to track
personnel radiation exposure. Training had been conducted prior to system
implementation, and personnel " greeters" were stationed at the restricted area
access point to assist personnel with use of the system. Based on this limited
,
review, the inspector concluded that the administrative implementation of the newly
installed automated access control system was good.
c.
Conclusions
Based on this review, the inspector made the following conclusions:
- -
Radiological boundaries including radiation areas, high radiation areas, and
contaminated areas were well defined and well maintained, and conditions of
housekeeping were good and showed improvement.
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The administrative implementation of a newly installed automated access
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control / electronic dosimetry system was good.
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R5
Staff Training and Qualification in RP&C
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a.
Insoection Scooe (83750)
The inspector performed a review of selected portions of the health physics
technician training program, information was gathered through discussions with
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cognizant personnel, and a review of a syllabus for a three-week health physics
systems course,
b.
Observations and Findinas
The training manager stated that in order to address a need for more systems
training for health physics personnel, a three-week course was developed that
included specific radiological / health physics concerns. All Maine Yankee health
physics technicians were scheduled to attend the class, and at the time of the
inspection, seven health physics technicians were attending the third week of the
course. The training manager added that feedback from participants in the course
was very good. The inspector noted that the course syllabus included classrocm
training, plant walkdowns, and appeared broad in scope.
c.
Conclusion
Based on this review, the inspector made the following conclusions:
e
Health physics systems training represented a commitment to improving
health physics technicians' knowledge of plant systems.
R6
RP&C Organization and Administration
a.
Inspection Scooe (83522)
The inspector performed a review of the organization and administration of the
radiological controls organization. Information was gathered by a review of a
resume for the newly appointed RPM, reviews of current and proposed
organizational charts, and through discussions with cognizant personnel.
b.
Observations and Findinas
The inspector interviewed the newly appointed RPM, and reviewed a copy of the
!
individual's resurne. The individual was determined to be capable and qualified for
the position of RPM in accordance with NRC Regulatory Guide 1.8, " Personnel
Selection and Training."
The RPM stated that the current focus of the radiological controls organization was
to support outage work. The assistant RPM duties had been limited to focus on
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oversight of health physics-operations, in order to support outage work. The
inspector interviewed the assistant RPM, various health physics technicians, and a
health physics planning supervisor. These individuals indicated that current staffing
levels were adequate to support ongoing work, but additional staffing would be
necessary to support future planned work. The RPM indicated that seven health
physics technicians would be available upon completion of systems training, and
additional staffing of contract health physics technicians was in progress.
c.
Conclusions
Based on this review the inspectors concluded the following:
The newly appointed RPM was capable and qualified for the position of RPM
in accordance with NRC Regulatory Guide 1.8, " Personnel Selection and
,
Training."
.
Current health physics technician staffing levels were adequate to support
ongoing work.
R7
Quality Assurance in RP&C Activities
a.
Insoection Scope (83750)
{
The inspector performed a review to evaluate the effectiveness of the station
problem identification / resolution program (learning process) for correcting
radiological deficiencies. Information was gathered by reviews of lists of learning
bank issues related to radiological controls, reviews of selected learning bank
issues, and discussions with cognizant personnel.
b.
Observations and Findinas
The inspector reviewed a list of radiological control issues entered into the learning
process during the first three months of 1997, and compared the list to the issues
entered into the former radiological incident reporting system in the first three
months of 1996. The inspector noted that during the first three months of 1997,
approximately 25 issues were entered into the learning process, which was greater
than five times the rate at which issues were entered into the former radiological
incident reporting system. The inspectors also noted that several of the issues
entered into the learning process would likely not have been entered into the
radiological incident reporting system (e.g., shortage of protective clothing hoods,
personnel contamination events, improper use of tool bags, and communications
breakdowns in health physics). As a result, the inspectors concluded that
radiological control issues were being entered into the learning process at a lower
threshold and at a higher volume than issues entered into the former radiological
incident reporting system. This was considered a positive observation.
The inspectors interviewed several members of the radiological controls staff
regarding their use of the learning process. The individuals had attended training
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and had access to the learning bank computer system. Although individuals could
easily enter the learning bank computer program and look at specific issues, some
difficulties were observed when individuals were requested to perform queries or
print out reports: system queries took an extended time during periods of high
system use; some printouts could only be obtained on a page-by-page basis; and a
computer screen locked-up during a print request. Although these individuals were
able to obtain the requested information with persistence or assistance, this raised
the concern that if individuals were not fully familiar with the system, or if data
retrieval was difficult, personnel may not fully utilize the system to evaluate and
resolve radiological control issues. A learning process team member indicated that
a computer memory upgrade was in progress to speed processing time; that training
was being conducted; that individual skills would improve with increased system
use; and that system enhancements were being performed to make the program
more user friendly.
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The inspector also reviewed procedure No. 0-16-1, " Learning Process
Implementation Procedure," Rev.10, and a Learning Bank " General Task Report" to
evaluate use of the learning process. The inspector noted that the learning process
did have strong advantages over previous problem identification / resolution systems.
For example, anyone could enter an issue into the learning process; multiple
personnel review, evaluate, and assess the significance of issues during the initial
review process (e.g., initial screening, team review, and management review
process); and accountability was designed into the system with the assignment of
issue and task " owners." The inspector noted that this was a significant
improvement over the former radiological incident reporting system.
The inspectors reviewed lists of tasks (corrective actions) associated with various
radiological control learning bank issues, and noted that tasks addressed apparent
causes and were generally sufficient to prevent recurrence. However, an example
was identified where corrective action " tasks" did not address the apparent cause.
Learning bank issue No. 96-00055 was generated to address the discovery of a
discrete radioactive particle (DRP) found in the back yard of the restricted area
during the performance of a prejob survey in preparation for digging trenches. The
listed " apparent cause" was " contaminated particles have come loose from
contaminated tools and equipment." The corrective action was to " perform more
frequent surveys to keep the discovery of DRPs to a minimum." The inspectors
noted that the corrective action appeared to address the symptom, but did not
identify " apparent cause."
c.
Conclusions
Based on this review, the inspector made the following conclusions:
Radiological control issues were being entered into the learning process at a
higher volume and lower threshold than issues entered into the former
radiological incident reporting system.
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Difficulties were encountered with administrative use of the learning bank
e
including extended computer processing times, system user friendliness
concerns, personnel unfamilimity with the system, and sorne system
programming weaknesses.
The learning process had distinct advantages over previously used
radiological control problem identification / resolution systems in that anyone
could enter an issue into the system, issues were reviewed by multiple
personnel, and accountability for resolving issues was designed into the
system.
e
Learning bank corrective action tasks were generally sufficient to prevent
recurrence.
R8
Miscellaneous RP&C lssues
R8.1 UFSAR Review
A recent discovery of a licensee operating their facility in a manner contrary to the
UFSAR description highlighted the need for a special focused review that compares
plant practices, and procedures and/or parameters to the UFSAR description. While
performing the inspections discussed in this report, the inspectors reviewed the
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applicable portions of the UFSAR that related to the areas inspected.
1
The inspector reviewed selected sections of Chapters 11, " Radiation Protection" of
the UFSAR pertaining to radiological controls to evaluate the accuracy of the UFSAR
regarding existing plant conditions and practices. No UFSAR discrepancies were
identified during this review.
R8.2 Learnina BankJssue 97-01450
The inspector reviewed a licensee-identified learning bank issue, No. LB 97-01450-
001. Technical Specification 5.2.2(d) states that, "an individual qualified in
radiation protection procedures shall be on-site when fuelis in the reactor" (this
includes training in emergency planning procedures). This Technical Specification
was violated on March 12,1997, from approximately 0230 to 0530 hours0.00613 days <br />0.147 hours <br />8.763227e-4 weeks <br />2.01665e-4 months <br />, when
an RP supervisor allowed the Radiological Controls (RC) shiit technician to leave the
site due to illness, without finding a replacement who was fully trained in
emergency plan procedures. Identified causes included the f ailure to notify the
Plant PSS that the on-shift qualified RC shift technician was leaving the site; the on-
shift RC Supervisor was pre-occupied with ongoing work; the posted schedule did
not specifically identify who was assigned to act as the "on-shift qualified RC shift
technician;" and the replacement technician did not understand his role with regard
to qualifications and training associated with being the qualified RC shift technician.
This issue was entered into the learning bank for evaluation and corrective action.
The inspector reviewed the recommended corrective actions and noted that they
would be sufficient to prevent recurrence. This licensee-identified and corrected
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violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1
of the NRC Enforcement Poliev.
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S4
Security and Safeguards Staff Knowledge and Performance
S4.1 Contraband Found in Vehicle Durina Search
a.
inspection Scoce (717501
The inspector reviewed the circumstances involving the identification of marijuana
in a contractor's vehicle during a search of the vehicle in preparation for the
contractor's access into the protected area.
b.
Observations and Findinas
On April 15,1997, two Maine Yankee Security Officers identified a small bag of
marijuana in a contractor's truck. This occurred when the officers were conducting
a search of the vehicle in preparation for the vehicle to be taken into the protected
area for delivery of some non-safety related material. Upon discovery, the security
force notified the Control Room and local law enforcement. Local law enforcement
personnel respondet, to the site and dealt with the issue.
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Maine Yankee reviewed the individual's previous access into the protected area. It
appeared that the individual had been on site on two occasions in the past. On
both occasions, the individual was escorted by, and under the supervision of a
badged employee. This person also had not been involved in any safety-related
activities. Based on this, the licensee was satisfied that the individual's prior on-site
activities had been monitored and considered acceptable.
The inspector noted that Maine Yankee handled the issue properly. The
notifications to the Control Room and the locallaw enforcement agency were
timely. The reviews to determine the potential impact of the individual's previous
site visits were thorough and revealed no adverse effect.
c.
Conclusions
Security activities continued to be conducted well as evidenced by the good
performance during the April 15,1997 event.
V. Manaaement Meetinas
X1
Exit Meeting Summary
The inspectors presented the inspection results to members of the licensee on May 2,
1997. The licensee acknowledged the findings presented.
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X2
April 3,1997, Public Meeting
!
On April 3,1997, the NRC held a' meeting with representatives of Maine Yankee at the
Maine Yankee Media Center. The meeting was to discuss the Maine Yankee Restart
Readiness Plan as documented in the March 7,1997 letter to the NRC. The meeting was
limited to public observation only. Later on, the NRC held a meeting with members of the
public at the Wiscasset Middle School, Wiscasset, Maine. The meeting was to receive
public comment regarding the Maine Yankee Restart Readiness Plan.
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,
INSPECTION PROCEDURES USED
.
IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing
4
Problems
IP 62707:
Maintenance Observation
>
IP 71707:
Plant Operations
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IP 92700:
Onsite Followup of Written Reports of Non-routine Events at Power Reactor
,
Facilities
4
IP 92901:
Followup - Operations
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IP 92902:
Followup - Maintenance
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IP 92903:
Followup - Engineering
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IP 37551:
Onsite Engineering
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IP 61726:
Surveillance Observation
IP 71750:
Plant Support
IP 83750:
Occupational Radiation Exposure
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IP 86750:
Solid Radiation Waste Management and Transportation of Radioactive
Materials
IP 83522:
Radiation Protection, Plant Chemistry, Organization and Management
Controls
ITEMS OPENED, CLOSED, AND DISCUSSED
ltems Opened:
VIO 50-309/97-03-01, Operators Failing to Perform Duties Required by TS 5.8.2 and plant
procedure,1-26-4, Responsibilities and Authorities of Operating Personnel. (04.1)
ltems Closed:
LER 96-001, Emergency Core Cooling Pumps Declared Inoperable Due to a Reduction of
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Ventilation Flow. (08.1)
IFl 50-309/96-02-01, Containment Spray Building Heating Unit, HV-7. (08.2)
URI 50-309/96-06-01, Auxiliary Feedwater Pump. (M8.1)
URI 50-309/96-13-02, Auxiliary Feedwater Pump. (M8.1)
URI 50-309/96-11-02, HPSI cut wire, Event Review Board. (E8.1)
URI 50-309/96-16-04, HPSI Flow Testing and Throttle Valve Settings. (E8.2)
ltems Discursed:
URI 50-309/96-08-05, Fire Protection Berrier Seals. (F2.1)
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LIST OF ACRONYMS USED
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CFR
Code of Federal Regulations
1
{
CSB
Containment Spray Building
Discrete Radioactive Particle
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Health Physics
High Pressure Safety injection
l&C
Instrumentation and Control
In-Service Test Program
LER
Licensee Event Report
Low Pressure Safety injection
Maine Yankee Atomic Power Company
NRC
Nuclear Regulatory Commission
,
PAB
Primary Auxiliary Building
'
PCC
Primary Component Cooling
PSS
Plant Shift Supervisor
RC
Radiological Controls
Radiological Protection
RP&C
Radiological Protection and Chemistry
Radiation Protection Manager
Refueling Water Storage Tank
Systematic Assessment of Licensee Performance
SOS
Shift Operating Supervisor
TPC
Temporary Procedure Change
Updated Final Safety Analysis Report
{
Vapor Containment
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