SUBJECT: NRC INTEGRATED INSPECTION REPORT NO /98-05 and OFFICE OF INVESTIGATION REPORT NOS AND

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1 NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA December 21, 1998 EA EA Mr. R. A. Mellor, Vice President Operations and Decommissioning Connecticut Yankee Atomic Power Company 362 Injun Hollow Road East Hampton, CT SUBJECT: NRC INTEGRATED INSPECTION REPORT NO /98-05 and OFFICE OF INVESTIGATION REPORT NOS AND Dear Mr. Mellor: On November 2, 1998, the NRC completed an inspection at Connecticut Yankee Atomic Power Company. The enclosed report presents the results of that inspection. During the three month period covered by this inspection period, your conduct of activities at the Haddam Neck Station facility was characterized by the continuation of radiological work associated with restoration from the primary system decontamination, and completion of several tasks to transition to a decommissioning status. The plant staff performed well to safely complete the installation, testing and initial operations of phase 1 of the nuclear island components. Engineering support was good to support the design modifications and assure the timely and smooth completion of tie-in activities, and to monitor initial system performance against design criteria. Failure to perform adequate review of existing survey data for the RHR room resulted in the uptake of radioactive material by two individuals. Although not yet complete, your dose assessment for the unplanned exposure was appropriate. NRC is continuing to review this matter. This inspection completes our review of your actions described in the letter dated June 12, 1997, in response to the Notice of Violation (NOV) proposed imposition of Civil Penalties dated May 11, This also completes our review of your actions in response to the NRC Request for Information per 10 CFR 50.54(f) dated October 9, Based on our reviews during several inspections of your licensed activities, the NRC confirmed that you have taken the corrective actions to address concerns in the areas of engineering programs, operating procedures and practices, the corrective action process, and maintaining the licensing and design basis. Notwithstanding this conclusion, our reviews of the preparation for, and the conduct of, the reactor coolant system decontamination noted that weaknesses remain which warrant your continued attention. These concerns include the control of the plant configuration, procedure quality, integration of engineering support, and effective corrective actions. These matters were described in Inspection Report Nos and The NRC will continue to inspect your performance during your decommissioning efforts. No further response is required regarding the NOV or 10-CFR 50.54(f) at this time. The NRC Office of Investigations (OI) recently completed two investigations. The first investigation was conducted to determine whether a health physics technician deliberately violated Technical Specification a when he failed to follow radiation protection procedures at your facility. Based on a review of the evidence developed during NCR's investigation, OI found that the individual deliberately did not follow radiation protection procedures by using only one functioning survey meter during a pre-dive survey on December 9, 1996, and by falsifying radiation survey data regarding this survey, a verification survey conducted on December 10, 1996, and a dive survey conducted on December 10, From your letter dated April 12, 1998, we understand that you also concluded that the individual knowingly violated your procedures by continuing the pre-dive survey after one of the two required survey meters failed. The second investigation was conducted by OI to determine whether a former senior health physics technician attempted to conceal the release of contaminated video equipment from the Haddam Neck Plant to a non-licensed vendor facility and falsify survey results. Based on a review of the evidence developed during NCR's investigation, OI found that the individual deliberately attempted to conceal the release of contaminated video equipment by contacting the non-licensed vendor and suggesting that the vendor attribute the February 26, 1997, contamination survey results on a bad frisker cord or probe. Further, the individual planned to have the vendor put the contaminated cables aside for later retrieval into his personal car. Follow-up surveys conducted by your staff and an NRC inspection confirmed radioactive contamination up to 10,000 disintegrations per minute (dpm) on the video equipment.

2 We have requested pre-decisional enforcement conferences with both individuals to further review these matters. With respect to this second matter, based on the results of this inspection, an apparent violation of regulatory requirements was identified, which involved the failure to survey contaminated equipment before it was shipped to an offsite vendor. The NRC is still evaluating both the dive survey and the contaminated cable events with respect to your licensed activities, and will inform you of our decision by separate correspondence. In accordance with 10 CFR of the NCR's Rules of Practice, a copy of this letter and its enclosure will be placed in the NRC Public Document Room (PDR). Sincerely, ORIGINAL SIGNED BY: GEORGE PANGBURN Ronald Bellamy, Chief Decommissioning and Laboratory Branch Division of Nuclear Materials Safety Docket No License No. DPR-61 Enclosure: NRC Inspection Report No /98-05 cc w/encl: D. K. Davis, Chairman, President and Chief Executive Officer T. W. Bennet, Vice President and Chief Financial Officer K. Heider, Decommissioning Director G. Bouchard, Unit Director J. Haseltine, Strategic Planning Director G. P. van Noordennen, Manager, Nuclear Licensing J. Ritsher, CYAPCO Counsel R. Bassilakis, Citizens Awareness Network J. Block, Attorney for CAN J. Brooks, CT Attorney General Office K. Ainsworth, Town of Haddam L. Elisa II, FEMA, Region I State of Connecticut SLO U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket No.: License No.: DPR-61 Report No.: /98-05 Licensee: Connecticut Yankee Atomic Power Company 362 Injun Hollow Road East Hampton, CT Facility: Haddam Neck Station Location: Haddam, Connecticut Dates: July 20 - November 2, 1998 Inspectors: Dr. Jason C. Jang, Senior Radiation Specialist Marie Miller, Senior Health Physicist Daniel Barss, EP Program Reviewer, NRR

3 Thomas Fredrichs, Project Manager, NRR John Wray, Decommissioning Health Physicist Joseph Nick, Decommissioning Health Physicist Ronald L. Nimitz, Senior Radiation Specialist William J. Raymond, Senior Resident Inspector Approved by: Ronald Bellamy, Chief, Decommissioning and Laboratory Branch Division of Nuclear Materials Safety EXECUTIVE SUMMARY NRC Inspection Report No /98-05 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a three-month period of resident inspection. It also includes the results of announced inspections by regional specialists to review the unplanned exposure of workers to radiation, and the implementation of the gaseous effluent control program during the time period in which the Reactor Coolant System (RCS) decontamination was in progress and the stack monitoring function was degraded. Further, it includes the results of the inspection of the contaminated cables that were released to the vendor on February 19, Decommissioning Operations and Maintenance: Operators performance was good to monitor the status of operating plant equipment and to monitor the spent fuel pool (SFP). Operators showed good regard for plant procedures and responded well to off-normal conditions. Maintenance personnel performed well to test and maintain equipment, and showed a good regard for spent fuel safety by providing reliable and redundant heat removal capability. Licensee actions were slow to address degraded electrical equipment and restore full functionality of a backup diesel generator. Spent Fuel Safety: Licensee performance was very good to implement the nuclear island modifications per commitments and administrative controls. Engineering support was very good, as evidenced in the quality of the calculations and technical evaluations that supported the modifications. Engineering and technical support activities this period were good to support decommissioning planning and spent fuel safety. NRC review confirmed the licensee had taken the committed actions in the response to the May 12, 1997 enforcement action and the 10 CFR 50.54(f) letter. The licensee completed actions to improve performance in the areas of engineering, operational practices, emergency preparedness, the licensing and design basis, and the corrective action program. The corrective actions were generally effective, but some weaknesses remain that warrant continued licensee attention to assure station practices and programs remain effective for decommissioning. NRC reviews continued to confirm the effectiveness of actions to address performance weaknesses. Plant Support and Radiological Controls: The NRC reviewed the implementation of the gaseous effluent control program for the time periods when the RCS decontamination was in progress, and when the stack monitoring function was uncertain. The licensee maintained good air balance for the primary auxiliary building (PAB) and the containment buildings; therefore, all air from these building was released to the environment through the air cleaning system (HEPA). Good laboratory measurement techniques for in-plant and main stack samples were implemented. The projected doses to the public from a potential unplanned release during the RCS decontamination period were calculated and the results were insignificant. An apparent violation of 10 CFR 20 was identified regarding the failure to survey which resulted in a release of contaminated equipment to an offsite vendor on February 19, The licensee's failure to perform adequate review of existing survey data for the Residual Heat Removal (RHR) room resulted in the intake of radioactive material by two individuals. Although the estimated occupational exposures did not exceed 10 CFR limits, the NRC staff will continue to evaluate this item in future inspections. The licensee conducted adequate follow-up actions including taking of sufficient bioassay samples to assess the dose to the whole body and body organs. An unresolved item will track the final dose assessments following additional sample analyses.

4 The licensee conducted security activities in a manner that protected public health and safety. The response to offnormal conditions was good to assure security functions remained effective. Compensatory measures were taken per procedures and instructions. One discrepancy was noted in the failure to assure emergency power for security equipment remained functional. An unresolved item will track the review to determine whether the availability of emergency power met the requirements of the security plan. This inspection evaluated the licensee's performance during its first graded defueled emergency preparedness exercise. The inspectors observed facility staffing at the two emergency facilities, control room (CR) and technical support center (TSC), command and control, and turnover from the CR to the TSC. The inspectors observed demonstration of procedure implementation including: event classification, notifications, on-site protective actions, and search and rescue. Communications, rumor control an drillmanship were also evaluated. The licensee conducted an adequate exercise in accordance with the defueled emergency plan and defueled emergency plan implementing procedures. All NRC and licensee exercise objectives were met. The CR and TSC were staffed and activated in a prompt manner. The Emergency Director and the response staff demonstrated the following: adequate assessment, classification, notification, command and control, and onsite protective actions. The search and rescue effort was delayed because of cumbersome procedures. The licensee's selfcritique was a noted strength. The licensee identified numerous issues and categorized those issues according to significance. The NRC inspectors agreed with the licensee's findings and reemphasized a few of the licensee's selfidentified improvements items. TABLE OF CONTENTS EXECUTIVE SUMMARY ii TABLE OF CONTENTS iv REPORT DETAILS 1 Summary of Plant Status 1 I. Decommissioning Operations and Maintenance 1 O1 Conduct of Operations Operating Activities and Status of Operating Systems 1 O1.2 Maintenance and Surveillance Activities 2 O1.3 Conclusions for Decommissioning Operations and Maintenance 4 II. Spent Fuel Safety 4 E1 Engineering Support for Decommissioning 4 E1.1 Spent Fuel Cooling System Modifications 4 E8 Miscellaneous Engineering Issues 6 E8.1 Review of Licensing Event Reports LERs) ( and Telephonic Notifications 6 E8.2 Enforcement Follow-up - Management, Design and Corrective Actions 8 E8.3 Status of Previous Inspection Items 12 III. Plant Support and Radiological Controls 14 R1 Radiological Surveys and Contamination Control 14 R8 Miscellaneous Radiological Protection Issues 25 R8.1 Status of Previous Inspection Items 25 S1 Security and Safeguards 26 S1.1 Review of Security Activities 26 P3.1 Review of Exercise Objectives and Scenario (82302) 27 Exercise 28 IV. Management Meetings 32

5 X1 Exit Meeting Summary 32 REPORT DETAILS Summary of Plant Status The Haddam Neck plant conditions remained stable with the spent fuel safely stored in the SFP. The licensee completed the RCS decontamination and finished installation and testing of design modifications for phase 1 of the nuclear island. On July 27, 1998, NRC Commissioner Nils Diaz and Nuclear Reactor Regulation (NRR) Project Manager Thomas Fredrichs toured the site and met with licensee management to discuss the status of decommissioning activities. On July 28, 1998, Mr. W. Raymond and Ms. M. Miller attended a public meeting hosted by Mayor Bette Giesing of Groton to discuss public questions regarding the activities to complete radiation surveys and remove licensed materials from offsite properties. The inspectors discussed the NRC independent reviews and radiological measurements at the offsite locations, along with the basis for the NRC conclusions that there was no threat to public health and safety based on the findings to date. The inspectors attended meetings of the Community Decommissioning Advisory Committee on July 29, September 15, September 29, October 13, and October 27, On September 4, 1998, the licensee announced the selection of Mr. K. Heider to the position of Decommissioning Director, reporting to the Vice President of Operations and Decommissioning. The creation of the new position was part of a reorganization of Haddam Neck staff that would better integrate operations, maintenance and engineering organizations with the decommissioning staff. The "B" loop intermediate and spray cooling systems were tied in to the SFP heat exchangers on September 27, The inspectors performed a special inspection of an internal exposure that occurred when two health physics technicians entered the RHR pit on September 30, I. Decommissioning Operations and Maintenance O1 Conduct of Operations 01.1 Operating Activities and Status of Operating Systems a. Inspection Scope (71707, 62801) Using Inspection Procedure and 62801, the inspector reviewed plant status and licensee activities to maintain the plant in the defueled condition. b. Observations and Findings The operators maintained stable plant conditions, and adequate level and cooling for the SFP. The licensee operated plant equipment necessary to support the SFP, and assured the operability of support systems. The inspector verified compliance with Technical Specifications (TS) TS , SFP water level; TS , fuel storage air cleanup systems; and, TS , pool temperature below 150&Mac176;F. The spent fuel pool cooling system (SFPCS) remained operating per Normal Operating Procedure (NOP) , with the "B" SFP heat exchanger in service. The operating procedure was revised to reflect the status of the new cooling systems for the SFP. On September 24, 1998, following the revision of procedures and the completion of training, the licensee implemented License Amendment 193, which formally made the Defueled TSs effective (NL/CY ). The secondary side of the SFPCS was initially cooled using the service water (SW) system. The licensee completed installation and initial test activities on September 27, 1998, to place the "B" loop of intermediate and spray cooling systems into service. The systems remained in a test and evaluation mode of operation under Surveillance Test (ST) B until October 8, when the "B" loop was declared operable. The licensee conducted routine surveillance of the SFP and building. Operator actions observed during periodic plant tours were consistent with the procedures. Operators activities to monitor the spent fuel from July to November were good to operate plant systems as necessary to maintain spent fuel storage, and to assist maintenance, testing and decommissioning activities. Operators performed well to follow procedure NOP during the transition to the new cooling system. Plant personnel responded well to off-normal conditions, as described below.

6 Storm Preparations The plant staff prepared the site and tracked the progress of Hurricane Bonnie during the period of August 25-29, The operators followed the guidance of abnormal operating procedure (AOP) 3.2-5, Natural Disasters on August 25 as the storm came within 800 miles of the site. The licensee inspected the site and secured loose material which could impact personnel, structures or power supplies. Site inventories were replenished and emergency diesels were confirmed to be in a standby/ready condition. The inspector toured the site periodically during August 25-28, and verified licensee preparations. Hurricane Bonnie and subsequent storms tracked south of New England and had no impact on the site. Licensee preparations for adverse weather were generally thorough. Leakage From Dike Plant staff discovered on September 3, 1998, the loss of water from the dike around the aerated drain holdup tank and the recycle test tanks (Adverse Condition Report (ACR) ). The licensee normally processed rain water collected in dike areas as radwaste. That practice was stopped on August 26, 1998 when radwaste tank inventory margins became low. Licensee follow-up actions were good to develop a temporary modification to allow the alternate processing of rain water from the dike areas to the aerated drain tank and to the waste test tank for processing and release. O1.2 Maintenance and Surveillance Activities a. Inspection Scope (62801, and 62707) Using Inspection Procedure 62801, and 62707, the inspector conducted periodic reviews of plant status and ongoing maintenance and surveillance. b. Observations and Findings The inspector reviewed licensee activities to test and repair plant equipment. The licensee maintained plant equipment necessary to support the SFP. The licensee implemented compensatory measures and the action statements in the TS and the technical requirements manual during periods of degraded equipment performance (e.g., for work on Radiation Monitor (RM) 14B, the seismic monitor and the stack flow instrument). Additionally, the inspector reviewed on a sampling basis the planning, work controls and radiological controls for the following activities: pressurizer surge line cutting and capping tie-in of the "B" loop cooling to the SFP heat exchanger "A" spent fuel heat exchanger cleaning and repairï uninterruptible power supply UPS-2 troubleshooting and repair preparations to install the core barrel into the reactor vessel "A" Spent Fuel Heat Exchanger (AWO ) After initiating spent fuel cooling using the "B" loop intermediate cooling (IC) system, the licensee removed the "A" heat exchanger from service for cleaning prior to tie-in of the "A" IC loop. The "A" heat exchanger tubes were also cleaned and leak tested, and the bonnet (end bell) was inspected. The licensee identified corrosion induced wear on the bonnet divider plate, which had the potential to create a bypass flow path. The "A" heat exchanger performance to cool the pool was acceptable during the installation of the "B" IC system. The "A" heat exchanger bonnet was dispositioned under Non-Conformance Report (NCR) , Replacement Item Evaluation (RIE) and Automated Work Order (AWO) A new bonnet was available onsite and was installed. The new bonnet had superior mechanical and corrosion resistance characteristics compared with the original item. The licensee coated the internal carbon steel surfaces of the new bonnet to further minimize corrosion. The licensee showed a conservative approach to spent fuel safety through a good regard for maintaining redundancy in SFP heat removal capability and by expeditiously restoring the "A" heat exchanger to service in the best possible condition. UPS-2 Failure (AWO ) The licensee performed troubleshooting and repairs per AWO after UPS-2 failed to carry supplied loads. The Uninterruptible Power Supply (UPS) failed when a voltage conditioning transformer on the input supply from a motor control center (MCC) failed in-service on October 25, Temporary power was restored by bypassing the failed transformer. The in-service MCC was the alternate supply for the UPS-2 loads, which had been on-line since June 22,

7 1998 (AWO ) when a failure of the UPS-2 batteries caused the loss of the rectifier/battery charger feed from the preferred MCC and a backup diesel generator. With the preferred MCC feed inoperable, the backup diesel generator was unavailable to supply loads downstream of UPS-2. Despite actions to replace the batteries and fuse FU-2 (AWO ), the rectifier/charger/inverter portion of UPS-2 remained inoperable due to the tripping of the battery supply breaker. The cause for the tripping remained unknown and the repair of UPS-2 was hampered by the lack of complete information at the site regarding the UPS-2 design. Licensee actions continued at the end of the inspection period to obtain vendor assistance to investigate and repair UPS-2. While maintenance support was good in response to the loss of power on October 25, the licensee did not fully appreciate the vulnerability in the UPS-2 that had existed since June 22, Also, the vulnerability was not fully known by all affected plant groups. Licensee actions were not timely to resolve degraded equipment conditions prior to the failure on October 25, 1998, and to restore the functionality of a backup diesel generator. O1.3 Conclusions for Decommissioning Operations and Maintenance Operators performance was good to monitor the status of operating plant equipment, and to monitor the SFP. Operators showed good regard for plant procedures and responded well to off-normal conditions. Maintenance personnel performed well to test and maintain equipment, and showed a good regard for spent fuel safety by providing reliable and redundant heat removal capability. Licensee actions were slow to address degraded conditions and restore full functionality of a backup diesel power supply. II. Spent Fuel Safety E1 Engineering Support for Decommissioning E1.1 Spent Fuel Cooling System Modifications a. Inspection Scope (37801, 60851, 60854, 37700) The inspector reviewed modification activities that supported spent fuel safety. Plant design change activities to establish the nuclear island were reviewed to verify that the modifications were implemented in accordance with licensee controls. b. Observations and Findings The modifications associated with design change record (DCR) CY-97010, 015, 016, 017, 018 and 032 were reviewed, along with supporting engineering calculations and analyses. The list of references and materials reviewed is provided in Attachment I. The DCRs detailed the installation of new equipment for the spent pool fuel island (SFPI) that eliminated reliance on the existing plant cooling water systems. Inspection Report Nos and provide documentation of further NRC review in this area. The licensee classified the SFP and cooling systems under DCR-CY97015, and applied graded quality assurance (QA) to the installation per Administrative Control Procedure (ACP) (the Spent Fuel Pool Quality Assurance Program). The modification and testing included: The use of the existing SFP heat exchangers (E-10-1A and E-10-1B25) and fuel pool cooling pumps (P-21-1A and 21-1B) with the new IC and spray cooling (SC) systems. The SC system used fan spray coolers to disperse heat to the outside air. The new IC system piping had inlet and outlet connections to allow for the emergency supply of cooling water from the fire system in the event of the loss of the normal cooling system. Normal makeup of coolant is provided by the existing 100,000 gallon primary water storage tank (PWST) and the primary water transfer pumps. The primary water distribution header was modified to supply automatic make-up capability to the SC and IC surge tanks located in the truck bay of the spent fuel building. During this inspection, the licensee completed the modifications to install the IC and SC systems; performed component level testing; tied the "B" loop IC and SC systems into the SFPCS (functional on September 27, 1998); and, completed thermal performance testing. The tie-in of the "A" loop systems continued at the end of the inspection period. The new cooling system operated smoothly, and performed well during the periods of high ambient temperature and humidity to cool the pool and maintain temperatures well below 100&Mac174;F. The licensee noted that the spent fuel temperature would track ambient temperature and humidity conditions, as monitored by the temperature difference (delta-t) between the heat exchanger outlet (return of cooled water to the SFP) and the ambient wet bulb temperature. When the delta-t was greater than 26&Mac176;, the pool would cool down; when the delta-t was less than 26&Mac176;, the pool would heat up (reference ST B, Attachment 12.5). The maximum temperature for the design conditions, 104&Mac176;F at a wet bulb temperature of 76&Mac176;F, was not reached.

8 New instrumentation was provided in the CR and locally in the spent fuel building, including: SFP temperature and level indicators mounted in control panel F1; IC and SC surge tank low and high level alarms located on CR panels FF and EE; locally mounted control and indicators for makeup control valves, relative humidity and dry bulb temperatures, and wet bulb temperature; and newly installed radiation monitors RMS-19A and 19 B, used to monitor the IC loop for radioactivity. The existing CR alarms for SFP high and low level and high temperature remained operable Panel E. on The IC/SC systems used two 100% capacity, water-to-air fan coolers. The IC/SC cooling loops were designed based on the decay heat load requirements for July 1, 1998, an assumed ambient wet bulb temperature of 76&Mac176;, and the ability to cool the pool to below 110&Mac176;F for at least 95% of operating hours per the American National Standards Institute (ANSI) The fan coolers were located outdoors on top of the truck bay roof of the spent fuel building. The SFPI electrical power was provided by a 480-volt power feed from the existing onsite power supplies, with a new feed provided from Bus 11 via a splice connection in the cable vault. The backup power supply remained the station emergency diesel generators, EG-2 A and EG-2B. In the future, the licensee planned to use a mobile air-cooled diesel for the nuclear island instead of the station diesels. The design control program was appropriately implemented and onsite fabrication and testing activities were conducted in accordance with the associated work packages. The DCRs were developed and implemented per the administrative controls in the Design Change Manual. Inspector observations of as-built installations and activities in progress, based on a sampling review of work packages, showed the modifications were well controlled and completed per the DCR packages. Plant operational procedures were changed to reflect the new systems, components and valve lineups. Component and performance testing of the new systems was completed per DCR and ST , A, and B. Test activities were controlled using the work order process. The testing included flushing of the IC and SC systems, and performance testing on spent fuel cooling after the final tie-in; functional testing of IC and SC surge tank high and low level alarms and interlocks; and, functional testing of new operator interface alarms and indicators that provide for monitoring of the SFP conditions in the CR. The supporting calculations and technical evaluations reviewed for DCR-CY are listed in Attachment 1. The safety evaluations completed per 10 CFR and supporting the DCR appeared to be completed per the administrative controls and were consistent with the Updated Final Safety Analysis Report (UFSAR) and design work to declassify plant systems. The inspector completed a sampling review of structural and thermal calculations that supported the development of the nuclear island. The calculations used acceptable methodologies, and conclusions were supported by the results. The analyses (Calculations 97-SFPI-1610 and 1611) and testing (SFP Heat up Rate Test per Procedure ST B) determined the pool thermal performance and provided the basis for the sizing and operational thermal requirements of the fan coolers. NRC review focused on the mechanical and electrical portions of the SFPI cooling systems. Licensee planning for additional modifications continued at the end of the inspection, including the changes to the SFP purification system, installation of alternate normal and emergency power supplies; relocation of make-up equipment inside the spent fuel building; and installation of a new heating system. c. Conclusions Licensee performance was very good to implement the nuclear island modifications per commitments and administrative controls. Engineering support was very good, as evidenced in the quality of the calculations and technical evaluations that supported the modifications. Engineering and technical support activities this period were good to support decommissioning planning, and spent fuel safety. E8 Miscellaneous Engineering Issues E8.1 Review of Licensing Event Reports LERs) ( and Telephonic Notifications a. Inspection Scope (92700, 90712) The purpose of this inspection was to review prompt reports and LERs to verify the requirements of 10 CFR and were met. b. Observations and Findings LER , Stack Radiation Monitor RMS-14B Samples Not Analyzed Properly. This LER described the discovery on September 1, 1998 that some of the particulate and iodine samples taken from July 21 through August 28, 1998 were not analyzed as required by the TSs and the Offsite Dose Calculation Manual. The causes included operation of the

9 sample skid with a mispositioned vent valve, and the discovery that the sample system design allowed the formation of condensation in the sample lines under certain environmental conditions, with the consequent deposition particulates of and iodines at a higher fraction than previously evaluated. The event was reported per 10 CFR 50.73(a)(2)(I) as a condition prohibited by the TSs. Licensee actions to correct the deficiency and NRC findings are described in Section R1.2 and R8.1. This LER is closed. LER , Excessive Check Valve Seat Leakage. This LER described the discovery on September 15, 1998 that SW check valve SW-CV-963 had excessive seat leakage. The valve was declared inoperable, since it could not perform the design function to eliminate the potential for water hammer event following a loss of normal power and the subsequent restart of the SW pumps. The inoperable condition was discovered during a surveillance test that was being conducted at an increased frequency (monthly versus quarterly) after testing in August identified a similar problem (LER 98-07). Licensee actions were appropriate to exercise and test the valve on September 16, which freed the disc from the stuck open position, and to increase the surveillance test frequency to weekly to assure the valve remained functional. The long term corrective actions were to complete modifications to install the new intermediate and spray cooling systems, and thereby eliminate reliance on the service water system to cool the SFP. The licensee made the "B" loop of the new cooling systems operable on October 8, This LER is closed. LER , Contaminated Material Found Offsite. The licensee provided a supplemental report to describe the discovery at an offsite location of a welding machine that showed radiological contamination containing transuranic radionuclides. The contamination was removed, and the welder was returned to the site. Licensee action to follow-up this finding were good to conduct additional surveys at the offsite property (no additional transuranic isotopes were found), complete detailed assessments of the internals of the welder (no additional transuranic isotopes were found), and to initiate plans to locate and conduct follow-up surveys of other welders from Haddam Neck and Millstone. The licensee reported that, as of October 8, 1998, a total of 15 welders had been identified for further investigation. Inspection item will track NRC follow up of licensee actions to identify and remediate radioactive materials at offsite locations. Inspection item will track the potential exposure to members of the public from offsite radioactive materials. This LER is closed. LER 96-29, PAB Internal Flood Protection. The licensee issued Revision 1 to this LER on July 7, 1997 to reflect the decommissioned status of the plant. A licensee engineering evaluation concluded the plant could be maintained in safe shutdown following a postulated internal flooding event. Further corrective actions were no longer required. This LER is closed. In addition to the above, the inspector also reviewed the licensee actions regarding event notification made to the NRC per 10 CFR on 10/1/98 (EN 34861), and 9/15/98 (EN 34783). No inadequacies were identified in meeting reporting requirements. The licensee reported to the NRC per 50.72(b)(2)(vi) on October 1, 1998, that about 6000 gallons of rain water collected in the dike around the recycle test tanks and the aerated drain tank may have seeped into the ground since August 26. The rain water became partially contaminated due to contact with contaminated surfaces, and contained trace levels of radioactivity, including 6.09E-9 µci/ml of Cs-137, and 4.19E-5 µci/ml of tritium. The concentrations were less that the TS 3.11 limits of 1E-6 µci/ml for Cs-137 and 1E-3 µci/ml for tritium, respectively. Potential dose to any offsite area will be reported in the annual effluent report to the NRC. Licensee follow-up actions were appropriate to reactivate the sump pump in the dike area, evaluate the status of the dike in borated the waste storage tank area, and to include the ground water leakage in the process to evaluate the site remediation. for E8.2 Enforcement Follow-up - Management, Design and Corrective Actions a. Inspection Scope (92702) The purpose of this inspection was to complete the review of the licensee corrective actions for the enforcement action issued by the NRC letter dated May 12, This review also covered the licensee actions committed to in response to the NRC Request for Information under 10 CFR 50.54(f) dated October 9, 1996, which addressed issues similar to those in the enforcement action, including the licensing basis and design basis (LB/DB) for the safe storage of spent fuel, the identification of commitments, configuration management of major processes, and updating the Final Safety Analysis Report (FSAR). Past NRC reviews in this area were provided in Inspection Report Nos , 97-05, and b. Observations and Findings The licensee took actions to address deficiencies in broad categories that included engineering and operating practices and the corrective action process. The licensee addressed deficiencies in engineering which included failures to meet commitments, and the failure to establish and adequately maintain the LB/DB. The licensee provided a final response to the NRC Request for Information per 10 CFR 50.54(f) by letter dated September 30, 1998 (CY ).

10 Engineering Programs and Practices In the licenseeís response dated June 11, 1997, the licensee described the actions to address weaknesses in the processes for safety evaluations, UFSAR updates, safety classification, instrument set points and procurement engineering. The corrective actions addressed the common causes for the process deficiencies by upgrading the LB/DB information, the design control process, the configuration management process, resource management, training, and by setting new management standards and expectations. The following areas were reviewed: Regulatory Commitments A commitments database was used to verify plant design, procedures, programs and processes were as reflected in the license. The licensee identified over 13,950 licensing commitments, with 2080 commitments applicable to decommissioning, which were reviewed to determine which remained active commitments, or commitments that required further action. The review of outstanding commitments was tracked as a key performance indicator until the backlog was reduced. As of September 1998, 130 items that required action to implement the commitment, such as procedure steps were being tracked by the licensee. The licensee demonstrated completion of this action through a review of the database, and the list of assignments in the action tracking system. NRC commitments due in 30 days are also tracked in the weekly performance indicators for the site. Procedure LDI 2.01, "Regulatory Commitments", will be used to identify, manage and track future regulatory commitments. Inspection Item concerned the failure to meet TS commitments for the calibration of stack flow instruments. One of the corrective actions in response to this item was to verify that License Amendment No. 125 was correctly translated into the surveillance procedures. The Quality Oversight organization completed a review to assure TS surveillance items were correctly covered in plant procedures. Discrepancies were identified and addressed through ACRs. Finally, Inspection Item concerned the adequacy of review under LDI 2.02 to identify commitments, and specifically whether items received an independent review. The licensee completed a self-assessment in this area as described in NL/CY The assessment found numerous discrepancies in the database in which the verification appeared lacking; however, the source documents showed the verification reviews were completed but the data entries for the reviewer names were not entered into the database. The assessment addressed the NRC concern in this area. The assessment was thorough and identified recommendations to improve the commitment tracking database. The licenseeís action to address issues identified in the NOV response is complete. Licensing Basis for Safe Storage of Spent Fuel The UFSAR was revised to correct deficiencies applicable to Structures, Systems and Components SSCs) ( and programs required to support the defueled condition. The revised UFSAR, Change No. 30, was submitted to the NRC by letter dated January 26, 1998 (NL/CY ). The inspector reviewed the UFSAR during routine inspections to verify the upgraded document accurately reflected plant conditions and the licensing commitment. The inspector reviewed, on a sampling basis, the following sections of the UFSAR for general accuracy, as well as for the adequacy of those systems that were important to the decommissioning status of the plant: Section 1.0, Plant Systems and Categorizations; Section 2.4, Hydrology and Ultimate Heat Sink; Section 2.5, Seismology; Section 3.2 Classification of SSCs; Section 3.1, Conformance with General Design Criteria (GDC); Section 3.4, Flood Protection; Section 3.10, Seismic Qualification Section 6.2, Containment Systems; Section 6.3, Emergency Core Cooling Systems; Section 6.4, Habitability Systems; Section 7.0, Instrumentation and Controls; Section 8.3, On-site Power; Section 9.1, Fuel Storage and Handling; Section 9.2.1, Service Water System; Section 9.2, Water Systems Section 11.0, Radioactive Waste Management; Section 13.0, Conduct of Operations; and, Section 15.0, Accident Analyses. Within the scope of this sampling review, the updated UFSAR was accurate in regard to significant plant design criteria, specifications and physical features. The defueled condition LB/DB for spent fuel storage was issued in a new Design Basis Document, which was maintained as indicated in Revision 3 issued on October 8, The licensee completed an independent review of the LB/DB, as described in the report, AIndependent Third Party Review of the Defueled Licensing and Design Basis at Connecticut Yankee Atomic Power Company.@ The independent review was completed by two outside contractors (XWest Group, Inc., and Duke Engineering and Services) to assure that the LB/DB document was supported by the reference documents and acceptable for use. The open issues from both independent reviews were resolved, and verified complete by the auditing organizations (reference: DE&S memorandum CYR dated April 9, 1998; and XWest memoranda through issued in December, 1997). The inspector noted the licenseeís method to track and resolve the open issues was thorough, and verified by a sampling review that the discrepancies were addressed. The licenseeís action to address issues identified in the Notice of Violation (NOV) and 10 CFR 50.54(f)

11 responses is complete. The licensee continued to review and categorize plant systems using the methodology described in Section 1.1 of the UFSAR. Plant systems were abandoned when no longer needed to support the safe storage of spent fuel, or were no longer needed to support the RCS decontamination. The licensee achieved a significant milestone during this inspection period through the installation of new cooling systems for the SFP, which eliminated the reliance on the SW system and the Connecticut River as the ultimate heat sink for decay heat removal. Further, the licensing requirements for several plant systems were eliminated by issuance of the Defueled TSs in License Amendment 193 on June 30, Several NRC issues involving plant program or equipment problems were evaluated as no longer significant to the decommissioning status of the plant. A summary of resolved issues is provided in Attachment 2 of this report. While some discrepancies indicate some weaknesses in the actions to improve station practices and programs (e.g., the DCR for the seismic monitor, and the initial DCR to declassify systems for the nuclear island), these items appeared as exceptions to the generally good effort to revise and maintain the LB/DB. The licenseeís action to address issues identified in the NOV and 10 CFR 50.54(f) responses is complete. Operations Procedures and Practices The corrective actions to address the causes for violations involving inadequate procedures were previously inspected. Licensee actions to address procedure deficiencies for the core off-load and the nitrogen intrusion event were reviewed in NRC Inspection Report No The licensee took long term corrective actions to revise and improve operating procedures. The last major Aoperational@ event prior to transitioning into the decommissioning and plant dismantlement mode was the conduct of the RCS decontamination during the Summer of NRC concerns regarding the adequacy of procedures for the RCS decontamination were addressed in Inspection Report No The licensee completed the actions necessary to meet the commitments in response to the May 12, 1997 enforcement item. Additional NRC reviews of this areas are described in Attachment 2. Corrective Action Program The actions to improve the corrective actions program (CAP) were described in Inspection Report Nos and The licensee also completed an independent assessment of the CAP, and benchmarked the program against other nuclear power plants with a good CAP. The licensee implemented changes and completed actions to address the recommendations from the self-assessments, as described in memorandum CYCA dated January 19, The inspector reviewed the tracking and status of the follow-up actions in a meeting with the Corrective Actions Program Manager. The priority 1 and priority 2 items were completed in the third quarter of Based on the above, the licensee completed the actions necessary to meet the commitments in response to the May 12, 1997 enforcement item. Past NRC inspections verified the licensee actions to improve the CAP, and the generally good performance to implement the revised process. Good performance was noted in the following areas: definition, administration and implementation of the ACR process; low threshold for problem identification; generally thorough and appropriate reviews to establish apparent and root causes for identified discrepancies; use of appropriate indicators to track performance; generally thorough and appropriate corrective actions that address the causes for discrepancies; and, a strong performance by the management review team to assess individual issues and to identify general station performance trends to assure a viable CAP. Notwithstanding the above findings indicating general improvement had been achieved, there were examples where licensee findings and plant events suggested the need for continued attention to assure effective corrective actions. Examples include the NRC findings describe in Inspection Report No Licensee actions continued at the end of this inspection period to review the CAP as implemented in the ACR process. The licensee completed the actions necessary to meet the commitments in response to the May 12, 1997 enforcement item. c. Conclusions In summary, the NRC review confirmed that the licensee had taken the actions committed to in the response to the May 12, 1997 enforcement action and the 10 CFR 50.54(f) letter. The licensee completed actions to improve performance in the areas of engineering, operational practices, emergency preparedness, the LB/DB, and the CAP. NRC review determined that the corrective actions were generally effective, but some weaknesses remained that warrant continued licensee attention to assure station practices and programs are effective throughout the decommissioning process. NRC reviews continued to confirm the effectiveness of actions to address performance weaknesses. E8.3 Status of Previous Inspection Items (Closed) Unresolved Item : Corrective Actions for LERs and This item was open pending the

12 review of licensee actions for issues related to AOPs (96-09) and evaluation of flooding through an open floor block in the PAB (LER 96-08). The licensee reviewed the station AOPs and identified no other similar deficiencies. This result was reported in LER 96-09, Revision 1, dated June 10, In regard to PAB flooding, a licensee engineering evaluation concluded the plant could be maintained in safe shutdown following a postulated internal flooding event. Further corrective actions to develop a barrier control program were no longer required following the decision to permanently shutdown the plant and the removal of all fuel from the reactor, as described in LER 98-08, Revision 1 dated January 28, This item is closed. (Closed) Unresolved Item : Special Nuclear Material (SNM) Inventory Requirements. This item concerned the requirements for the conduct of inventories of SNMs per 10 CFR The NRC determined that recording fuel assembly serial numbers is not specifically required in order to meet the inventory requirements of Section 70.51(a)(8). Recording serial numbers remains a good practice as defined by industry standards such as ANSI Standard N , Nuclear Material Control Systems for Nuclear Power Plants, Section The licensee is not committed to the requirements of ANSI N15.8; however, past inventories of SNM in the SFP per SNM have included verifying serial numbers depending on whether fuel shuffle activities have been conducted. Further, the inventory conducted in 1997 under AWO included the verification of serial numbers after cleaning the top nozzles of the fuel assemblies. This item is closed. (Closed) Violation : Seismic Monitoring Instrumentation. This item concerned the failure to revise TSs the prior to modifying the seismic monitoring instrumentation. The licensee responded by letter CY dated June 12, Modifications were completed under DCR to place the new seismic instrumentation channel in service. The licensee proposed to revise the TSs to reflect the new system by letter to the NRC dated June 2, 1998 (CY ), and to relocate the requirements for the system from the TSs to the technical requirements manual. The system remained functional (except during periods of test or repair) but inoperable per TS pending the issuance of a license amendment by the NRC. Licensee actions to address the causes of the violation included: revisions to the design change process: the conduct of a lessons-learned review by the oversight committees (Plant Operations Review Committee and Nuclear Safety Assessment Board): and, revising the procedure to conduct safety evaluations to better control changes to the TSs. This item is closed. (Closed) Unresolved Item : Battery Oscillations and DC Ground. Further licensee reviews and follow-up actions were described in memorandum CT-TS dated February 12, The current oscillations on the "A" battery charger decreased and were no longer observable after reducing loads on the battery following the plant shutdown. No subsequent oscillations were observed during inspector reviews of plant status. The batteries were no longer required to be operable as a safety system, and the TSs 3/4.8 operability and surveillance requirements were deleted in Licensed Amendment 193. This item is closed. (Closed) Unresolved Item : Quality Attributes for the Nuclear Island. The licensee completed the engineering evaluations to disposition the quality issues addressed in NCR for the new spent fuel cooling systems. DCR CY classified the new systems as requiring augmented QA. NCR addressed the potential discrepancies for the initial actions to procure and install the systems as non-qa. The resolution included additional inspections to document the quality attributes of the mechanical, instrumentation and electrical modifications, the pressure testing and functional testing, and the development of drawings, manuals and project documentation. The licensee identified and corrected weld quality issues in the piping for the new pump skids. Items identified as adverse to quality were addressed using separate NCRs. The inspector conducted independent walkdowns of the new system components, piping and instrumentation. This review identified no discrepancies not already addressed by the licensee. This item is closed. (Closed) Violation : Failure to Follow Procedure for Vendor Contacts. The licensee used the VETIP process to obtain vendor information on component reliability problems. The licensee addressed this violation reinstituting by the vendor program per procedure PEG 6.05, AVendor Interface for Key Safety Related Components.@ Implementation of this program was demonstrated in memoranda NMDM , , , and CY-TS for 1997; and, PEG-MP , 399, 456, 457, and 504 for These actions satisfied the response to the violation. Program changes included the implementation of the process at Haddam Neck, and revision of the Key Safety Related Equipment List to reflect the permanently shutdown status of the plant (CY-TS and ). The licensee also planned to administer the vendor program in a revised Industry Experience Program for Haddam Neck, as described in procedure ACP , ARegulatory Affairs Quality Procedure Industry Practices@, Revision 1, which was in draft review on October 30, This item is closed. (Closed) Violation : Failure to Disposition Non-conformances. The licensee revised ACP , Section on 10/23/97 to address the scheduling and tracking issues identified by the NRC. The revised procedure guidance addressed the use of nonconforming items in plant systems. This item is closed.