IR 05000245/1998080

Insp Repts 50-245/98-80,50-336/98-80 & 50-423/98-80 on 980223-26.No Violation Noted.Major Areas Inspected:Status of EP Facilities,Equipment & Resources,Ep Procedures & Documentation & Staff Knowledge & Performance

ML20217J833
Person / Time
Site:	Millstone
Issue date:	04/01/1998
From:	Modes M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20217J811	List: IR 05000245/1998080 ML20217J807
References
50-245-98-80, 50-336-98-80, 50-423-98-80, NUDOCS 9804070029
Download: ML20217J833 (20)

Text

{{#Wiki_filter:, U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos.

50-245,336,423/98-80 . License Nos.

DPR-21, DPR-65, NPF-49 Licensee: Northeast Nuclear Energy Company Facility: Millstone Nuclear Power Station Dates: February 23 - 26,1998 Inspectors: David Silk, Senior Emergency Preparedness Specialist, RI William A. Maier, Emergency Preparedness Specialist, RI Nancy McNamara, Emergency Preparedness Specialist, RI Richard Struckmeyer, Senior Radiation Specialist. RI Robert Bores, State Liaisor Officer, RI Approved by: Michael C. Modes, Chief Emergency Preparedness and Safeguards Branch Division of Reactor Safety 9904070029 900401

PDR ADOCK 05000245 G PM i

.; . .1 - EXECUTIVE SUMMARY -

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> MILLSTONE NUCLEAR POWER STATION Emergency Preparedness Program inspection February 23 - 26,1998 Inspection Report 50-245;336;423/98-80 During this inspection, three violations identified in IR 97-81 were closed: Licensee corrective actions in response to VIO 97-81-02 (failing to maintain

emergency response facilities in accordance with the emergency plan) were effective. The inspectors determined that the facilities and equipment were in a - good state of. operational readiness.

Strong licensee performances during table-top dose assessment scenarios along

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with revisions to dose assessment procedures adequately addressed VIO 97-81-04 (improper implementation of dose assessment standards).

._The licensee completed adequate actions to correct the 10 CFR 50.54(t) audit

process, including a thorough Nuclear Oversight audit of the emergency . preparedness program. This corrective action adequately addresses VIO 97-81-05 (inadequate audit of the emergency preparedness program).

However, during this inspection, additional negative findings pertaining to the emergency preparedness program were identified:

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Numerous longstanding problems were found to exist in the post accident sampling system. Due to the nature of the problems, these findings are being made an unresolved item and will be documented in a subsequent inspection report. (URI 98-80-01) The Nuclear Oversight audit of the emergency preparedness program indicated that

more corrective actions are required by the Emergency Preparedness Services Department. When the Nuclear Oversight Board is satisfied with the status of the emergency preparedness program, the NRC will review the effectiveness of the corrective actions.

- Due to a lapse in tracking respirator qualifications many site emergency response

organipation (SERO) members became disqualified but were not removed from the SERO roster.

Despite good corrective actions addressing the issues identified in IR 97-81, several - ! significant issues exist, namely the problems associated with the PASS and the findings of ~ the Nuclear Oversight audit. Until these issues are resolved and a satisfactory NRC assessment of Revision 24 of the Plan is completed, the condition of the Millstone emergency preparedness program currently does not support restart.

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. , , Report Details -' P2 . Status of EP Facilities, Equipment, and Resources - P2.1 - ' Emeroency Response Facility (ERF) Maintenance a.

Insoection Scone (82701) The inspectors reviewed procedures, documentation, the licensee's corrective action plan and toured the ERFs to determine if corrective actions were adequate to address NRC Violation 97 81-02 (failure to maintain emergency facilities).

b.

Observations and Findinas The inspectors determined that all the previously identified issues were corrected.

For example: (1) revised EPAP 1.15, Management Program for Maintaining Emergency Preparedness, included a detailed inventory list for all EP-related items stored in the facilities; (2) emergency plan (the Plan) and procedures located in the ERFs are being maintained by a dedicated individual to ensure that they are kept current; and (3) other departments that conduct inventories for the EP Services Department (EPSD), are required to send documentation indicating discrepancies, findings and corrective actions.

One area of concern was noted during the facility tours. The inspectors noted that all the emergency field kits contained an 8 microcurie, Cesium-137 radiological instrument check source and the source was located in close proximity to the thermolumines. cent dosimeters (TLDs) used for personal monitoring. The inspectors requested the dosimeters be analyzed in order to determine the ' background dose of the kits. The licensee's results indicated an average of 65 millirem was accumulated on the TLDs. Because the licensee does not use a " control" badge for monitoring background, they would not be able to differentiate between background dose and actual dose accumulated in the field during an emergency. The inspectors brought this matter to the attention of the licensee who immediately proceeded to remove the sources from the kits and replace all the TLDs.

c.

Conclusions The inspectors concluded that licensee corrective actions to address VIO 97-81-02

were appropriate and the violation is closed. The inspectors toured the ERFs and

. determined the facilities were in a good state of operational readiness.

, P2.2 - Post Accident Samolmg System (PASS) ,a .During this inspection, the inspectors reviewed procedures, surveillance records, V ' i condition reports, and conducted interviews to determine the adequacy of the ." - _ PASS prior to restart. Problems revealed by this review included procedures that lacked sufficient detail, deletion of a yearly sump sample, a number of condition ~ reports which did not seem to get the system repaired adequately, missing valve ' identification, and instrument tubing and fitting leaks.' The findings regarding the x PASS will be documented in a subsequent report covering the unresolved issues , ' raised by this review._ (URI 98-80-01) ' .- , . _ ___1 __

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' ' P2.3 - Site Emeroency Response Oraanization (SERO) Notification System ' The inspectors evaluated the status of the SERO notification system du' ring this inspection. Inspection Report (IR) 97-202 documented observations of the current notification system'during a test of the system on June 18,1997; prior to official implementation. The current notification system was implemented and tested in June and again in July 1997 to assure a two month overlap with the previous system. The previous _ system was eliminated in August 1997. Prior to December 1997, the tests were conducted during normal work hours. When the pagers . actuate, the SERO members respond via telephone to the system by dialing an 800 number. Because of limited capacity for outgoing calls from the site to the 800 - number, the timeliness of more than 200 SERO members to respond to the page was impacted. To address the timeliness inue and to more realistically test the system,1 the licensee began conducting the monthly tests in the evening hours.

The inspectors considered this to be a reasonable effort because if an event

occurred during ' normal working hours, the SERO members would already be onsite and would be activated via public address announcement internally to the site obviating the need for 800 number confirmation.

l The licensee has been trending the success rate of the system to reach SERO members by pager and those results indicated an increasing success rate. When the decision is made to activate the SERO by pager signal, the system sends out two signals over a short period of time in an effort to reach as many individuals as < possible. All SERO members (including those who are not designated on duty for that week) are to respond via telephone and inform the system that they are going to respond. SERO members who do not respond to a peger sieval within a I specified time period, are automatically called by the systerr., We system is programmed to continue searching for individuals until all SERO positions' have been notified and are expected to be staffed. The inspectors reviewed test records of the current system from June 1997 to February 1998, the procedures used to initiate and activate the SERO notification process, and the procedures governing SERO expected actions. No discrepancies were identified and the inspectors had no further questions in this area. Based upon the information reviewed during this inspection, the inspectors determined that the notification process was acceptable.

~ P2.4 ERF Activation During this inspection, the inspectors determined the licensee implemented criteria for activation of the emergency response facilities. According to licensee personnel, there were no activation criteria prior to June 1997. The individuals . leading the facility can now declare the f acility activated when a minimum staffing level has been achieved instead of waiting for supplementary staff, such as clerical support. The activation criteria were based on minimum staffing criteria stated in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG.0654 FEMA-REP-1, Revision 1, Table B-1. The inspectors reviewed the , licensee's 10 CFR 50.54(q) review for establishing the activation criteria _ The " licensee's review concluded there was no decrease in effectiveness. The ' .

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. I inspectors determined the licensee has not conducted minimum staffing drills since implementing this criteria. This is not a requirement. However, based upon compliance with NUREG-0654, the licensee's 10 CFR 50.54(q) review, and the successful results of monthly notification tests to activate the SERO, the inspectors j concluded that the establishment of activation criteria was acceptable and had no further questions in this area.

l P3 EP Procedures and Documentation ! IR 97-81 documented a violation due to licensee changes made to the cmergency plan (the Plan), without prior NRC approval, which decreased its effectiveness and , l l in some cases, the Plan as changed, no longer met the standards of 10 CFR l 50.47(b) and the requirements of Appendix E (VIO 50-245,336,423/97-81-03).

! As a result of the violation, the NRC will review Revision 24 of the Plan for , compliance to NRC requirements and for other instances of decrease of effectiveness. These results will be documented in a subsequent inspection report, i P4 Staff Knowledge and Performance i a.

Inspection Scope (82701) ! The inspectors evaluated licensee dose assessment performance during table-top scenarios and to assess licensee corrective actions for VIO 50-245,336,423/97-l 81-04, improper (implementation of dose assessment standards).

b.

Observations and Findinas Twenty licensee developed table-top scenarios were selected by the inspectors to evaluate ten shift manager (SM)/ chemistry technician (chem tech) teams l performing on-shift dose projections using the IDA (Initial Dose Assessment) code.

) Each team was evaluated in two scenarios. The SMs were well aware of the IDA process and assisted the chem technicians as necessary in obtaining the dose assessments. The SMs demonstrated excellent knowledge of use of the dose projection results and the protective action recommendation (PAR) generation , l process. The NRC inspectors noted excellent, consistent use of repeat-back ) communications, and thorough and accurate completion of IDA input forms. The SM/ chem tech teams consistently generated the textbook answers for the given scenarios in a timely manner. The inspectors also evaluated two EOF dose assessment teams using two different scenarios selected by the inspectors. The inspectors assessed the teams' performances as very good.

During the SM/ chem tech scenarios, the inspectors observed two discrepancies with the IDA model. The IDA model used unrealistically high iodine to noble gas ratios in some scenarios, resulting in much higher than expected thyroid committed dose equivalent (CDE) projected doses. Also, for fuel handling accidents, the IDA model did not realistically treat decay of fission product fuel activity since the time of shutdown, resulting in calculated doses being much higher than could be predicted from actual situations. The licensee had identified these two

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discrepancies prior to this 'nspection and initiated a condition report (CR). The.

i licensee planned to address these issues by June 30,1998. Because IDA can project very large thyroid CDEs such that the thyroid CDE, rather than the deep.- dose equivalent (DDE) dose, is the limiting dose, SMs need to consider the resulting total effective dose equivalent (TEDE) when recommending protective . actions for field team personnel since the team dosimetry requires only monitors DDE.

As a scenario / training issue, some scunarios resulted in dose projections orcers of , magnitude higher than could be expected from a realistic event. While the:,e scenarios e.ffectively allowed the demonstration of the dose assessment process, g the unrealistic results could result in some negative training regarding ext,ectations , for these postulated accident conditions.

Procedure modifications were made to address previously identified concerns. For example, to address the lack of TEDE and ground shine calculations by the ' Accident Dose Assessment Model (ADAM), the licensee incorporated the use of the NRC RASCAL 2.1 modelinto response procedures. This model calculates TEDE and includes the ground shine component which was not available through ADAM. Since the previous inspection, the IDA computer assessment was . developed to replace the manual calculations, which often resulted in inconsistent and untimely results. The IDA model, as successfully demonstrated consistently provided timely results which were identical to the textbook answers generated for each of the scenarios. This was a very significant improvement and when the above described discrepancies are remedied, this will be a very useful assessment tool. Overall, procedures were successfully demonstrated during the table-top exercises.

The inspectors identified two discrepancies with the procedures that were used.

Procedure 4428G, Protective Action Recommendations, Attachment 8 has a decision chart involving three decision paths used to determine the need for upgrading a PAR. The first decision path assesses barrier failures. Some SMs were confused as to number of barriers lost or applicability of this decision path for a fuel handling accident. The indication of loss of the fuel barrier is important because the chem technicians require identification of fuel damage state in order to ~ ' perform an IDA' projection. The second discrepancy involved the emergency action level (EAL) chart for each unit and it resulted in some confusion for SMs during scenarios in which loss of reactor coolant occurred outside of containment. The EAL chart indicates the occurrence of fuel damage if containment radiation monitors read greater than 5 R/hr "with no RCS release." The EAL should state that fuel damage may be indicated with 5 R/hr containment radiation monitor readings "with no RCS release into containment." The EAL basis was appropnate 'but the wording of the EAL is unclear.

c.

Conclusions i Based on the excellent performances during the scenarios, the training received, and procedure revisions, the dose assessment issues documented in IR 97-81 have been corrected and VIO 50-245,336,423/97-81-04 is closed.

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• P5 EP Training and Qualification a.

Insoection Swoe (82701) The inspectors reviewed training records and procedures and interviewed EP training staff to determine the status of EP training issues identified in the 97-81 inspection.

b.

Observations and Findinos , Systematic Acoroach to Trainino Issues EP training staff informed the inspectors that the EP training program had been revised to incorporate the five element systematic approach to training. All but four courses in the EP training curriculum have been revised and recertified, and the staff stated that the remaining four are planned for recertification prior to the beginning of the 1998 EP training cycle in March.

Nuclear Training Manual procedure 6.01, " Training Evaluation and Feedback," has been approved, incorporating a training evaluation and feedback form that training recipients can use to provide comments for training product improvement. This element of the systematic approach to training was the only one not yet incorporated into the training restart plan at the time of the 97-81 inspection.

The training staff participates in weekly Change Review Committee meetings in which any changes to the EP program or procedures are discussed. This participation ensures that the training staff is kept informed so they may incorporate changes into the applicable lesson plans. Lesson plan changes are then presented to the EP Curriculum Advisory Committee (CAC) for approval.

The discussion of revised EP tasks for the Shift Technical Advisor, Station Duty Officer, Shift Technician and the Emergency Operations Facility Health Physics Technician (EOF-HP Tech) have been added to the Emergency Preparedness Services Department (EPSD) corrective action plan. They were identified as an issue in the licensee's annual review of the EP program, The licensee plans to discuss revised tasks for these positions in an up::oming EP CAC meeting. The EP Manager stated his intention to revise the Plan to require radiation worker qualification for the EOF-HP Technicians.

SERO Issues The EPSD committed, at the time of the 97-81 inspection, to update the tracking of the on-shift responders in the SERO. As this was being accomplished, the EPSD staff, in communication with the Health Physics Support organization, noted there r was a generallack of tracking of the supporting respirator qualifications of many L responders and that many responders' respirator qualifications had expired without their subsequent removal from the qualified emergency response roster. These supporting qualifications were medical screens and respirator fit tests, which were required to be completed annually. Satisfactory completion of these activities, along with respirator training, are required prior to respirator use.

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, ~ Tha licensee's investigation culminated in the issue of CR M3-97-4791. The peak number of emergency responders whose supp%ng qualifications had lapsed was ' 240 out of approxirnately 450 responders rege an respiratory qualification.

Table 51 of the.. n requires several emergency aspmse' positions to maintain sc:oiratory qualifications.: At the time of the inspection, the licensee had identified ,j one position in the SERO that had only one qualified responder. This position was 'I augmented with an additional qualified responder prior to the end of the inspection.

There were no positions without any qualified responders at the time of the inspection.

' Since the initial discovery of the problem, the licensee has pursued' corrective I action to remedy the situation. EPSD sent an E-mail memoramium to the emergency responders, listing the personnel whose qualifications had lapsed. The licensee conveyed expectations to the personnel and to their supervision that requalificatian was to be given a high priority and that only qualified personnel should respond to an emergency. Staffing of support activities for respirater A quchficetions was increased to expedite responder requalification. The licensee had succeeded in reducing the number of unqualified responders from 240 to approximately 100 by the time of the inspection.

The EPSD management is pursuing a qualification goal of 100% of responders , requiring respiratory protection. The EPSD management committed to maintaining l . no fewer than two qualified responders in each position. Finally, they are pursuing the incorporation of respirator qualifications into a data base tracking system that will alert responders, their supervisors, health physich personnel, training staff, and

EPSD staff of upcoming qualification expirations. This last action is designed to

prevent future occurrences of this problem.

c.

Conclusions Br. sed on the progress made by the training staff in restarting the courses in the EP treining curriculum, the attention planned and committed to for the issues identified it' the 97eS1 inspection and the corrective actions planned for the respirator qualification issue, the inepectors concluded that the EP training program is adequate to prepara responders to perform their emergency duties.

) Secause NRC regulations require licensees to follow and maintain in effect emergency plans that meet certa!n standards, and because the licensee did not follow the Plan by ensuring that only respirator-qualified individuals were assigned to those positions requiring such qualification, the inspectors concluded that a violation of NRC regulations occurred. This violation was due to the licensee's failure to adequately track respirator qualifications and ensure that only qualified ~ personnel were assigned to the SERO. However, this issue was self-identified by the licensee, not a recurrence of a previously identified issue, not a willful violation i

on the part of the licensee, and corrective actions have been initiated and committed to. Therefore, the violation satisfies the criteria of Section Vil of the NRC's Enforcement Policy and is non-cited (NCV 98-80-01).

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- _ _ , . .. '7 . 'P7 Ctality Assurance in EP Activities-The inspectors reviewed the licensee's response to VIO 97-81' 05, in0dequate - - 10 CFR 50.54(t) audit, by assessing the correctba s.:tions for the vioin' ion and by reviewing the licensee's most recent audit of the C' orogram (MP-91-A12-02); completed in December 1997. The corrective actions i.,c!uded a root cause evaluation, revision of the audit procedure to provide clarification and require management involvement, pursuit of using industry EP specialists on the EP program audits, increase the number of auditors, and ic conduct audit MP-97-A12-02. : he inspectors determined that the corrective actions were adequate and that ' the rrcent audit met all of the requirements of 10 CFR 50.54(' The inspectors noted that this audit was detailed and very self-critical and concluded that the corrective actions taken by the Nuclear Oversight organization were adequate and that this violation is closed.

Br. sed upon the assessment made by audit MP-97-A12-02, the inspectorr, ' concluded that additional corrective actions were required on the part oi the EPSD in order to certify the EP function as ready for plant restart. The inspectors noted that the EPSD had outlined a correctivo act in pan in response to the audit and that some corrective actions had already been completed. The NRC will evaluate the licensee's completion of these actions and the need for enforcement, during a future inspection (IFl 50-245,336,423/98-80-02).

'P8 Miscellaneous EP lasues P8.1 (OPEN) - IFl 97-81-01 - Potential over classification because of EALs CNB4 and CNB5 Duriag the August 1997 exercise, it was observed that EALs CNB4 and CNB5, as worded, could result in overclassification of an event in which the RCS barrier was lost, with a moderate amount of core damage, even with the containment barrier intact.

The inspectors discussed the proposed changes to these EALs to prevent simh, mis-interpretation of them. The inspectors concluded that these changes were adequate to prevent over classification of certain events as had occurred during the August 1997 exercise. Pending Plant Operating Review Committee approval of these changes, this item will remain open.

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_ C e PARTIAL LIST OF PERSONS CO3YACTED

Millstone Station Personnel D. J Alol Emergency Planning Coordinator M. Bauchmann Manager, Operator Training K. Beagle Nst Accident Sampling System Engineer, Millstone Unit 3 T. Blount l/,raner, Emergency Planning Services T. Dembek Senior Emess. &e Planning Coordinator D. Emborsky Lead Nuclear Emerge-y Nnning Coordinator i J. Fuller Emergency Planning instructor D. Gorence Manager, Maintenance Assessment E. Groover Manager, Plant Support Assessment 1. Haas Senior Engineer, Health Physics Support P. Hinnenkamp Unit Director, Millstone Unit 1 S. Hook Director, Emergency Planning Services ) M. Indino Senior Auditor, Audits and Evaluations ] FI. Lueneburg Acting Supervisor, Operator Training, Millstone Unit 3 ' ' E. MacLean Emergency Planning instructor S. Matthess Chemistry Manager, Millstone Unit 3 C. Palmer Manager, Health Physics Support J. Rigatti Manager, Radiation Protection Training J. Watson Lead Emergency Planning Coordinator, Facilities and Equipment I < ,

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o . ' INSPECTION PROCEDURES USED IP 82701: Operational Status of the Emergency Preparedness ~'rogram ITEMS OPENED, CLOSED AND DISCUSSED Ooened 50-245,336,423/98-80-01 NCV Failure to maintain qualified personnel on SERO 50-245,336,423/98-80-02 IFl Completion of corrective actions for issues identified in licensee Audit. Report MP-97-A12-02 Closed 50 245,336,423/97-81-02 VIO Fai!ure to maintain emerges.cy response facilities 50-245,336,423/97-81 04 VIO Improper implementation of dose assessment standards 50-245,336,423/97-81-05 VIO Adequacy of oversight review of 10 CFR 50.54(t) and oversight requiremnts Discussed 50-245,336,423/97-81-01 IFl Potential over classification because of EALs CNB4 and CNB5 50-245,336,423/97 81-04 VIO Decrease in effectiveness of the Plan without prior NRC approval

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• l UST OF ACRONYMS USED

' ADAM ~ Accident Dose Assessment Model C/.C Curriculum Advisory Committee CDE'~ Committed Dose Equivalent CEDE Committed Effective Dose Ec;uivalent ' Chem Tech Chemistry Technician ~CFR Code of Federal Regulations CR Condition Report DDE Deep Dose Equivalent EAL Emergency Action Level EP Emergency Preparedness EPSD' Emergency Planning Services Department EOF Emergency Operations Facility EOF HP. Tech Emergency Operations Facility - Health Physics Technician EPIP . Emergency Plan Implementing Procedure 'ERF . Emergency Response Facility ERO Emergency Response 0,ganization 'GE General Emergency IR inspection Report. LOCA Loss of Coolant Accident NRC Nuclear Regulatory Cort mission NUREG 0654 - Criteria for Preparation and Evaluation of Radiological Emergency

Response Plans and Preparedness in Support of Nuclear Power

' Plants, NUREG 0654 FEMA REP-1, Revision 1 OSC Operational Support Center PAR Protective Action Recommendation PASS Post Accident Sample System Plan Emergency Plan RCS Reactor Coolant System SERO Site Emergency Response Organization ' SM Shift Manager TEDE Total Effective Dose Equivalent ) TLD Thermoluminescent dosimeter TSC-Technical Support Center < . . m i ['. - < -

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REACTS luBPECTitEl FISIIIGS IFS DATA ENTRY FmM e ~ REACTM/flEL FACILITY IIINECTitBIS ] ' fAGE l,0F 4 , SITE: MlltSTONE REVIEWED BY: l QN_lJ.

REPORT IRAIBER DOCKET NUMBER

50 245 A

• 50-336

98 -

50-423 C

- REPORT TRANSMITTAL (SIGNATURE) DATE: / / RESPONSIBLE ORG. CODE: 1f8f6f0! LEAD INSPECTOR (RITS INITIALS): DfS!I1 ITEMS OPENED BY THIS REPORT (Y/N): i! IF "Y" COMPLETE SECTION A ITEMS UPDATED / CLOSED BY THIS REPORT (Y/N): Yl IF "Y" COMPLETE SECTION 8 ~ (USE CONT!uTION SHEET IF MJLTIPLE ITEMS) SEQUENCE NBR.: h, ' f f ITEM TYPE CODE: NfC!Vf SgRgtEVEL: S$PEgTCODE: f, l ! htN) ' $ hNt UNIT.

STATUS A g, 2 / 26/ 98

L 2/ 26 98 C 9.,, 2/ 26 98

• TITLE: FAILURE TO MAINTAIN QUALIFIED PERSONNEL ON STATION EMERGENCY RESPONSE ORGANIZATION

SEQUENCE NsR.: bI2l ITEM TYPE C(DE: Il Fill sevEaITY level: I suPPLEDENT MDE: 1, j .- (vso entv) (vio oMtv) Y bY N Nrf UW1i 57ATUS CL A D / /

0 / / C D / / awesw. A <4 GP.pwnw b'vL k * rue.v M k i M .c o - TITtE: s --. s Mlh!MI CONTACT EMPs I l ! / lE !61U ! mESP/ CLOSEOUT EMP afsp/ CLOSEOUT oRG: (oPTsoMAL) PROCEDURE W: [d M i b!/lT!.3!V! f, ! ! ! ! ! ! INTEREST C(DE: 1N.ffl CAUSE CODE: ! , FUNCTL AREA: NOV !$$UE DATE: / / N Lt mae, Yc e b(b N' Nemt.

• E 5 U,CY4 6 fA * r t 4 J.'s t i Or r'C s.i t Av Io 1 (Vio oNLT)

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h ! f-! 1! SEWRin LEVEL: '! SUPPLEMENT C@E: ' !, } SEQUECCE NBR.: [)!/! ITEM TYPE CODE: (vio oNLv) (vio oNLY) PROMCTED (OPT ONAL. PROVIDE oMLT UWlf STATUS CL0st0UT gr auLtst c DATE) _O / /e A D / /

_ C

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• T l.T L.E :

Q,k Y) M '1 f bY !) e . <m > ( i f!k!d!O! RESP /CLOSE00T EMP: l' l ! CONTACT EMPs ! ! ! RESP /CloSE0VT ORG: (OPTIONAL) h878/ PROCEDURE W: k! b! 7 ! b ! Y! P!, ! ! ! ! ! ! INTEREST CN E: s CAUSE CTE: 23, _] FUNCIL AREA: NOV ISSUE DATE: / /

/ 81 h1 UlNe / NA1L4f%. lAM A4' lf% llN14brM4 N15: ~~w mn-mamnLtuw ' ' ' ' ' 'l t SEQUECCE NBR.: ? ! ITEM TYPE CODE: ! ! ! $EVERITY LEVEL: ! SUPPLEMENT CODE: !,,, ] (vio oNLT) (VIO oNLT) PROJECTED (OPTIONAL. PROVIDE oNLY UN I T. _ STATUS CLOSE001 tr atAtistic cAtt) / / A _ / /

_ / / C _ 'T 11L.E : e . aws , RESP /CLOSE0U1 ORG: ! ! ! ! RESP / CLOSEOUT EMP: ? ! ! CONTACT EMP: ! ! ! (optional) PROCEDURE #: FUNCIL AREA: ! ! ! ! ! J, ! ! ! ! ! ! lNTEREST'C00E: INfil CAUSE CODE:,,_ ], ,,,,,,,,.} NOV ISSUE DATE: / / (trio oNLT) 'COctENTS: m i.en.

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CONTINUATION SMEE1 TO REGION I FORM 325 (OCT 1995)

O - CONTINUATION SHEET - PAGE _._ Or , EACTOR INSPECTIM F!staes IFE BATA WTRY F4WI - MiACTM/FWL FACILITY INSPECTIONS SECTION 8 coornmatnm er ITees woAform-> ' sus er ruse== SEGENCE NLMBER: ! ! ITEM TYPE CODE: f I f ORIGINATING IR NLMBER: __ and "NOV ID: - 'EA NLMBER : OR (IF FOLLOW-UP TO ENFORCEMENT $CTION LETTER VIOLATION): ACTUAL UPDATE /CLOSE0UT m u swi.uT __ Closto -,,NLMBER IR-(JWIT - STATUS <> , _ _ _, / / - A _ / /

- g _ I I - C _ 'CO M NTS: .n----,-=., ORIGINATING 1R NUMBER: - $EQUENCE NUMBER: ! ! ITEM TYPE CODE:

1 ! OR (nr FOLL0u-UP TO [NFORCEMENT 8CT10N Li'TTTR VIOLATION): "EA NUMBER : and *NOV ID: ACTUAL UPDATE / CLOSEOUT -.R,,NtMB.ER e C.L.O,SE.00T I UNIT STATUS n ww-i un <> f - / / A _ / /

- f _ / / C - _ co w NTS: _.u m --a ..s . =sv e m,m.. $EQUENCE NUMBER: f f ITEM TYPE CODE: I I I ORIGINATING 1R WUMBER: and *NOV ID:

OR (IF FOLLOW UP TO [WFORCEMENT 6CTION (ITTfR VIOLATION): "[A NUMBER : ACTUAL UPDATE /CLOSE001 CLOSfouT UNIT STATUS TR WUMBER cme as sura- > m p surn43 A - / / _ B - / / _ C - / / _ 'CDetE.NTS: ....n.,i . -.. p e a:girs\\:r s, cost.r m CONilWUA110h SHEET to REGION I FORM 325 (Oct 1995) J - - - - ,

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CONTINUATION SEET - PAGE g, OF g

' . REACTOR INSPECTION FI s lNGS IFS MTA ENTRY F M - EEACTOR/FE L FACILITY InsPECTI m s

SECTION B ccQNTimmTION oF ITm8 uPoars/cir-n> 5tt utvtusa rm ritis arts on.

ORIGINATING IR NUMBER: 97-81 SFOUENCE NUMBER: 0f5I ITEM TYPE CODE: VfI!0l m (IF FOLLOW-UP TD fptFORCEMENT ACTION [[IJE VIOLATION): *EA NLDIBER : and *NOV ID: UPDATE /CLOSEQUT ACTUAL N SE NhW5 m??IJ A L 98 80 2 / 26/ 98

L 98 - 80 2/ 26/ 98 C L 98 - 80 2/ 26/ 98

• COMMENT $t LICENSEE COMPLETED CORRECTIVE ACTIONS AS OUTLlWED IN THEIR 2/5/98 RESPONSE TO THE NOV. LICENSEE'S ALDlf taixiTtn owuctn wx>a asum vu.z anu;. a waua wm MP-97 A12-02. COMPLETED IN DECEMBER.1997. ADDRESSED ALL REGULATORY ITEMS IN 10 CFR 50.54ff).

ORIGINATING IR NUMBER: 98 80 SEQUENCE NUM8ER: O !l ! ITEM TTPE CODE: N!C!V1 m (IF FOLLOW-UP TO ENFORCEMENT 8CT!DN [[IIg3 VIOLATION): *EA NUMBER : and *NOV ID: UPDATE / CLOSEOUT ACTUAL W.l,ilL STATUS ,1R NUMBER,.__ CL,0SEO{ A L 98 80 2/ 26/ 98

L 98 80 2/ 26/ 98 C L 98-80 2/ 26/ 98

• COMMENTS: LICENSEE CORRECTIVE ACTIONS C0hPLETED PRIOR TO THE INSPECTION AND LICENSEE CORRECTIVE ACTIONS COMMITTED BY THE talalTED CMaRACT[RS M0WED-If 400tilchat 5 PACE NEED[D. USE 5[PdAAT( 5H([T)

EMERGENCY PLANNING SERVICES "*"^E MENT TO PURSUE RESPIRATOR QUALIFICATIONS FOR THE STATION EMERGENCY RESPONSE ORGA4fZATl0N ARE CONSIDERED ADEQUATE FOR CLOSURE OF THIS NCV.

Yf bl O ! ORIGINATING IR NUMBER:

1. I 7 - $ I SEQUENCE NUMBER: O1)f ITEM TTPE CODE:

m (IF FOLLOW-UP TO ENF0itCEMENT 8CTION L[IIgg VIOLATION): *EA NUMBER : and *NOV ID: UPDATE /CLOSE0UT ACTUAL . UNIT STATUS 1R NL3tBER CLOSEQUT nMW a J Im a m d LMM U JIM #6 J [ cl T 70 2 /u / 9T A B L.

n T. Fu hk/ fT C C 6 Vv M / 'It i

• COMMcNTS:

L% w EvereAn u dt,a elesude E a/Jes5 43c ec n/%We b IAM*/ w et m ItTto omcitu uma u -um vaa mara. ua anun um v we n >- n see} k el% h n R* yin ec j* \\ TA T A 17-Tl Ere rm fe V.me. b d f.$e $ o ' ' A& u a wd ' ' ' CONTINUATION $NEET TO REGION 1 FORM 325 (NOV 1997) R:\\lFs\\lF5,CDNT.FRM j

a CONTIMATION SHEET. PACE 10F 4 '

'

mEACTOR IeWPSCTIGE FIstees IPS MTA 13ffW peut. MActeE/fML HCII.ITT Ietepectlass SECTION 8 aarrie_nnes or na.s wonismr=>

--. N TI SESENCE IRAGER: O IV I ITEM TYPE CODE V! Il C l CRIGINATING IR 4RMBER: and '80V 10: "EA IR4eER : CE (IF FOLLOW-UP 70 PFORCEMENT 6CT10N LETTER VIOLATION): ACTUAL UPDATE /rstw ari m.o.sF0t/T Ct ,,iRMsER IR - UNIT.. STATUS . . C_ T - 74 2/uifr

8 L 'lT - 70 % 51 fT A ,,,, ' C WD TfN IA N nl0 r $n < l. v e n J A t n /,n'r k emswr A A van b *r 't 0"S S ** e C a < - s '_ComEwiss_. -. _ _ _ ~ _. _ _. _ - do[[ ~ h f cervrie y ccs N% k cltsW 5 vtelA - N pre /Yr Iv ?~rl1e,e k l l0 Se ., ' ' ' d ./ { _ f, *** A s/M n f &b s* h

SEQUENCE WLM8ER: ! ! ITEM TYPE CODE: ! ! ! CelGINATING 1R Nt.MBER: and "NOV ID: - 'EA NUM6ER : OR (IF FOLLOW-UP TO PFORCEMENT 6CTION LETTTR VIOLATION): ACTUAL UPDATE /CLOSEQUT m. LOSE 0VT C UNIT STATUS 1R NUMBFR u suwei N suw43 A - / / _ / / -

_ / / - C _

• CD MENTS:

m e.m.

- w m w . s en - ORIGINATING IIMdUMBER: - SEQUENCE NUMBER: ! I ITEM TYPE CODE: I ! l 'EA NUMBER : and *NOV ID: OR (IF FOLLOW-UP 10 PFORCEMENT 6CTION LETTER V10LAfl0N): ACTUAL UPDATE / CLOSEOUT CLOSE007 i=4 y UMBfR 1R N TWIT STATUS me y sum.o =%4 / / - A _ - / /

_ / i - C _ 'CO MENTS: cano m . .. .a.um._ n .n D \\lF$\\lFL, CONT.8 alm CON 11NUA110N SHEET TO REG 1084 I F0FM 325 (OCT 1995) }}