IR 05000302/1999005
| ML20212F326 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/13/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20212F322 | List: |
| References | |
| 50-302-99-05, NUDOCS 9909280120 | |
| Download: ML20212F326 (23) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION ll
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Docket No:
50-302
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License No:
Report No:
50-302/99-05 I
Licensee:
Florida Power Corporation i
Facility:
Crystal River 3 Nuclear Station Location:
15760 West Power Line Street Crystal River, FL 34428-6708 l
Dates:
July 4 through August 14,1999 Inspectors:
S. Cahill, Senior Resdent inspector S. Sanchez, Resident inspector i
L. Hayes, Physical Security Specialist (Sections S1.5, S2.8, S3.1, j
SS.1)
L G. Kuzo, Senior Radiation Specialist (Sections R1.2. R1.3, R2.1, R2.2, R3.1)
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S. Ninh, Project Engineer (Sections 08.2, M1.1)
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Approved by:
A. Boland, Acting Chief, Projects Branch 3 Division of Reactor Projects
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9909290120 990913 PDR ADOCK 05000302 Enclosure C
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EXECUTIVE SUMMARY Crystal River 3 Nuclear Station NRC Inspection Report 50-302/99-05 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 announced inspections by a regional project engineer, a regional security specialist, and a regional radiation specialist.
Ooerations Control room operators consistently used three-way communication techniques,
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maintained high sensitivity to monitoring reactor controls, and demonstrated good control and awareness of plant evolutions. Control of temporary modifications was appropriate.
A decision to reduce plant power on August 12 was preceded by thorough deliberations.
Building operators exhibited good ownership of assigned areas. (Section 01.1)
i Operators performing a surveillance test were not aware that their actions had caused a Technical Specification Limiting Condition for Operation (LCO) for the Decay Heat Closed Cycle Cooling Water System to be applicable. However, the LCO time was not exceeded and the licensee's investigation was prompt and thorough. (Section 01.2)
NRC identified a missing caution tag. A previous licensee audit failed to identify
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associated discrepancies. Issues which resulted in the need for caution tags were not
being prioritized for closure in orde'r to remove the need for the tags for extended periods of time. The licensee's response to two recent clearance danger tag issues was prompt, pro-active, and thorough. (Section 04.1)
Operator requalification training on new emergency operating procedures was effective
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and included a large amount of preparatory work and coordination. Instruction methodologies and materials enhanced student knowledge and involvement. Associated simulator training reenforced classroom topics, and installation of planned plant upgrades on the simulator significantly enhanced the training. (Section 05.1)
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NRC identified that a root cause investigation corrective action had been closed to
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another process, was not completed, and was under consideration for deletion by the
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subsequent process owner. (Section O8.1)
Maintenance Significantly improved coordination between Operations, Maintenance, and Scheduling
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personnel resulted in effective planning and scheduling. Maintenance Rule unavailability results were more widely disseminated, which improved consideration of equipment out of service impacts by alllicensee staff. (Section M1.1)
The inspectors verified that reactor coolant system leakage surveillances were
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performed accurately and leakage was well within Technical Specification limits. Several
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minor administrative deficiencies were observed; however, the deficiencies did not adversely impact the current surveillance results. (Section M1.2)
Enoineerina Engineering support for problems with diesel generator coolant microbiological growth
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was effective. Previous corrective actions were effective and a single accountable engineer was developing long-term solutions. Engineering support for a through-wall raw water leak was timely and provided essential input for an Operations operability determination. (Section E1.1)
Plant Supoort Health Physics staff oversight of radiological control area (RCA) work at the spent fuel
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pool was effective. Oversight was continuous and technicians were knowledgeable of the work and hazard scope. RCA entry point briefings contained detailed information on changes in radiological trends and were improved from previous observations.
(Section R1.1)
Radiological controls were implemented and maintained in accordance with Updated
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Final Safety Analysis Report, Improved Technical Specifications, and 10 CFR Part 20 requirements. (Section R1.2)
Chemistry and operations personnel demons + rated appropriate knowledge of procedural
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requirements, and proficiency in initiating and conducting a July 21,1999, Waste Neutralizer Tank-1 release. Licensee programs to control effluent releases were implemented effectively with effluent radionuclide concentrations and resultant projected offsite doses within established regulatory limits and design objectives. (Section R1.3)
General area radiation monitors were installed properly. Adequacy of calibrations and
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implementation of completion of verification determination for the general area radiation monitors could not be verified and was identified as an unresolved item. (Section R2.1)
The radiological environmental monitoring program for airbome radionuclides and
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drinking water samples, and monitoring of direct radiation was implemented in accordance with the Offsite Dose Calculation Manual. Implementation of liquid drinking water sample preparation activities was inconsistent with previous corrective action guidance, however; the quality of the sample analyses was not affected. (Section R2.2)
The 1998 Annual Effluent Release Report and Annual Radiological Environmental
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Monitoring Report were submitted in accordance with Improved Technical Specifications and documented results demonstrated gaseous and liquid effluent processing and subsequent releases met established regulatory limits. (Section R3.1)
A non-cited violation was identified for the failure to obtain urine specimens under direct
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observation for an individual who was suspected of altering or substituting specimens for fitness for duty tests conducted in 1997 and 1998. (Sec+ ion S1.5)
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The licensee satisfactorily implemented and tested new and reconfigured equipment to
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the existing protected area to encompass the Nuclear Administration Building. The j
licensee conducted an effective search of the new area to ensure against unauthorized
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material and individuals. (Section S2.8)
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A non-cited violation was identified for the licensee's Physical Security Plan submittal,
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Revision 7-0, which decreased the effectiveness of the Plan. (Section S3.1)
The licensee had a satisfactory security training program that incorporates tactical
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training with the required annual task and firearm requalification training. (Section S5.1)
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Summary of Plant Status The plant began the inspection period at full rated thermal power and remained at that level until l
August 12, when power was lowered to 85 percent to remove blockage on the "D" circulating
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water condenser inlet box tubesheet. The plant was restored to 100 percent power on August 13.
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Conduct of Operations 01.1 Routine Conduct of Operations Reviews (71707)
l The inspectors routinely reviewed plant operations, including shift tumovers, operator narrative logs, temporary modifications, and clearance and tagging indexes, and toured safety-related areas. The inspectors verified the alignment and operability of selected, l
risk significant safety systems and verified implementation of Technical Specifications l
(TS) requirements. Noteworthy observations are discussed in subsequent paragraphs.
The inspectors observed that operators demonstrated good control and awareness of plant evolutions. Control room operators consistently used three-way communication techniques, restricted access and distractions in the control room, and exhibited a high sensitivity to monitoring the reactor controls. Temporary modifications were appropriately tracked and controlled and were all scheduled for permanent resolution during the upcoming refueling outage. An offsite review committee meeting was attended and noted to be detailed and to provide effective oversight.
A power reduction was initiated on August 12 when main condenser parameters indicated the possibility of tube sheet blockage and reduced flow in the "D" waterbox.
The evaluation of the indications and the deliberations over possible courses of action
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l were detailed, and included valuable input from various disciplines such as Engineering and Maintenance. The inspectors concluded that the licensee comprehensively evaluated the problem, throughly assessed contingencies, and applied conservatism in the decision to immediately reduce power and inspect the waterbox. The subsequent waterbox inspection identified approximately 30 percent blockage of the tubesheet by marine growth and silt which validated the licensee's decision to reduce power and inspect the waterbox.
l Throughout the inspection period, the inspectors observed building operators cleaning-l up areas after work by other departments had been completed, such as putting away ladders and tools. A similar observation was noted last inspection period. The inspectors also observed operators taking ownership of assigned areas by promptly identifying and correcting plant deficiencies such as burned out indicator bulbs and minor oil and water leaks.
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'01.2 Failure to Recoanize Entry into Limitina Condition for Ooeration (LCO) (71707)
While performing Surveillance Procedure (SP)-340D, RWP-3B, DCP-1B, and Valve Surveillance, the operatin'g crew failed to enter TS 3.7.8, Decay Heat Closed Cycle Cooling Water System (DC), when flow was isolated to air handling fan AHF-15A rendering DCP-1B inoperable. The error was found by the NSS when reviewing the completed procedure. The licensee identified that the failure to enter the LCO was caused by the failure of the building operator to recognize a note in SP-340D which I
stated that an entry into TS 3.7.8 may be required. Other contributing causes identified
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by the licensee included the inclusiveness of the job briefing, the monitoring of the
. evolution by the control room, and distraction of the building operator performing the procedure. The licensee determined that the LCO action had not been required because the estimated time AHF-15A was out of service was less than the one hour required to take action as prescribed by the LCO. The inspectors independently verified the equipment out of service durations, and concluded that a TS violation did not occur. The inspectors concluded that the licensee's event investigation was thorough and the identified causes were appropriate.
Operator Knowledge and Performance
04.1 Clearance ~and Taaaina Issues a.
Insoection Scope (71707)
The inspectors audited the licensee clearance and tagging systems and reviewed the licensee response to two notable licensee-identified problems with the use of clearance tags.
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Observations and Findings The inspectors reviewed the licensee's Personal Danger Tag (PDT) Log, Test Tag Log, i
and Caution Tag (CT) Log to verify proper control and tracking of the tags per procedural requirements. The inspectors also verified selected tags of each type were correctly
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hung in the plant. The inspectors did not identify any notable deficiencies with PDT or Test Tag usage, but on July 21, inspectors found an active CT was missing. The CT had been hung in November 1998 on an energized lead for a removed light fixture. The inspector observed that the light fixture had been partially reassembled, but the leads remained unterminated and the tag was missing. ~ The licensee promptly hung a new CT.
Additionally, the work request that the tag was cross-referenced to in the CT log was incorrect and had been closed in April 1999. In May 1999 the CT Log had been audited by the licensee and consolidated and cts verified hanging in the plant; however, this
. discrepancy was not detected. The licensee initiated precursor card (PC) 99-2355 in
. their corrective action system, but was' unable to determine how the tag was removed or
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I if it was hanging at the time of the audit. The inspector also observed that many cts continued to remain in place for extended periods of time, were not consistently cross-referenced to other processes that would correct the problem, and consequently were not being prioritized for closure.
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The inspectors also reviewed two recent events documented in PCs 99-2469 and 99-2475 involving Operations clearance danger tags to evaluate the effectiveness of current and prior licensee corrective actions. The Operations investigations for both of these problems were prompt and thorough. They focused on the adequacy of their new tagging process which was implemented in September 1998 in response to numerous
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previous similar problems. The licensee determined their clearance process was effective and these latest problems were indicative of poor individual performance. The
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inspectors noted that Operations was aggressively and thoroughly addressing the l
problems and the issue associated with PC 99-2475 was indicative of good questioning by a non-licensed operator. Although previous licensee clearance tagging problems were identified for NRC enforcement, the inspectors determined the licensee conclusion was appropriate and the corrective actions for the previous problems continued to be effective, c.
Conclusions NRC identified a missing caution tag. A previous licensee audit failed to identify associated discrepancies. Issues which resulted in the need for caution tags were not being prioritized for closure in order to remove the need for the tags for extended periods of time. The licensee's response to two recent clearance danger tag issues was prompt, pro-active, and thorough.
Operator Training and Qualification O5.1 Emeroency Operatina Procedure (EOP) Uoarade Trainina
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Inspection Scooe (71707)
The inspectors observed licensed operator requalification training conducted the week of July 26,1999. The sole focus of the training was pending changes to all of the licensee EOPs due to plant modifications, scheduled to be implemented during the October 1999 refueling outage.
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Observations and Findinas
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To enhance the training, the licensee used a military theme and obtained the services of a military drill instructor to start the class. The inspector observed that significant effort had been expended to decorate a dedicated classroom and create analogies between key EOP mitigation actions, challenges, and plant equipment; and military strategies, enemies, and military equipment, respectively. The use of the theme created student interest and enhanced the quality of the training. Regardless nf the theme, the inspector observed that the training was of very high quality. Detailed flow charts of every licensee EOP had been developed and provided the basis of the training presentations. This avoided a previous training practice of reviewing each EOP step-by-step. The use of the flowcharts permitted visualization of the key mitigation strategies in each EOP and enhanced the students' knowledge of the material. Members of the licensee's EOP development team were frequently utilized as instructors, and the inspectors observed
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4-that all instructors had a very detailed knowledge of the EOPs and the revisions.
Simulator training immediately following classroom presentations was well integrated with the classroom material and exercised key strategies and decision points emphasized in the classroom training. The pending plant modifications had been installed on the simulator which significantly enhanced the value of the training. The inspector also observed that significant changes had been made to Administrative Instruction (AI) 505, Conduct of Operations During Abnormal and Emergency Events.
The changes clarified and strengthened licensee expectations and were reiterated throughout the week of training.
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Conclusions Operator requalification training on new emergency operating procedures was effective and included a large amount of preparatory work and coordination. Instruction methodologies and materials enhanced student knowledge and involvement. Associated simulator training reenforced classroom topics, and installation of planned plant upgrades on the simulator significantly enhanced the training.
Miscellaneous Operations issues (92901)
O8.1 (Closed) Licensee Event Reoort (LER) 50-302/98-13-00: Procedural Inadequacy Caused by Personnel Error Results in Missed Surveillance Requirement. This issue
' involved problems with the control of locked valves and was also identified as Violation 50-302/98-10-01. The violation was administratively closed in Inspection Report 50-302/99-02 following recent revisions to the NRC's Enforcement Policy. To close this LER, the inspector reviewed the associated licensee corrective action document, PC 98-5224, to ensure the corrective actions were adequate. The corrective actions were all indicated in the PC as complete, and the PC was identified as ready for final administrative closure. However, the inspector identified that a corrective action to revise specified parts of the TS bases had not been implemented. The revisions were in the licensee's Bases Change Request process to be implemented in Revision 20.
However, Revision 20 had been implemented in June 1999 without the locked valve bases change. The change had been placed on hold by the Licensing group, who was considering voiding the action. The corrective action had been coded closed just prior to the June 1999 due date; however, the PC was not updated or extended to reflect the delay. The licensee initiated PC 99-2602 to perform an extent of condition review. They identified another similar example of inappropriately closing a corrective action to the Licensing process. The inspector determined that the completed corrective actions were appropriate and that the licensee had adequately addressed the remaining action; therefore, the LER is closed.
08.2 (Closed) Inspector Followuo item (IFI) 50-302/98-301-01: Various Procedure Deficiencies Outlined in PC 98-3185. During the initial operator examination in 1998, the NRC examiners were concemed with the number of procedural deficiencies that could present a challenge to candidate performance. PC 98-3185 was generated to document and address the procedure weaknesses. This IFl was opened to trsck the progress of the procedure corrections. The inspector reviewed PC 98-3185 and determined that the
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affected procedures were properly evaluated and revised to ensure proper operator actions. Training lesson plans were revised discussing proper operator actions, and j
Operator Study Book entries were made, as appropriate. Therefore, this IFl is closed.
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11. Maintenance M1 Conduct of Maintenance
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M1.1 Routine Observations a.
Inspection Scoce (62707. 61726)
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The inspectors observed various portions of several corrective maintenance tasks and surveillance tests, evaluated the scheduling and coordination of the work, and reviewed associated documentation. Activities observed included removal of the spent fuel pool missile shields, chemical cleanup of the spent fuel pool coolant by a vendor-run reverse osmosis unit, and monthly surveillance testing and radiator coolant replacement for the
"B" emergency diesel generator.
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Observations and Findinas Maintenance tasks continued to be routinely performed with work packages in active use. Pre-job briefings were conducted thoroughly and covered precautions and limitations, and discussed past and potential problems. Measuring and test equipment was verified as properly calibrated. Maintenance supervision was appropriate, and maintenance component engineers frequently monitored job progress. The inspectors observed a significant improvement in coordination between work groups. Interactions between Operations, Maintenance, and Scheduling personnel were detailed and resulted in effective planning and scheduling. The inspectors observed that Maintenance Rule unavailability data was now included with equipment outage plans and was routinely published by the scheduling group. This increased awareness among the plant staff and resulted in improved consideration of equipment out of service time impacts by all I;censee staff. This action effectively addressed previous deficiencies with the visibility of Maintenance Rule results.
During work observations and tours of buildings, the inspectors observed that plant housekeeping and equipment storage remained a challenge for the licensee, particularly in the Auxiliary Building due to the large amount of preparatory work for the licensee's upcoming refueling outage. Observations included unsecured ladders and equipment not routinely being secured or chocked following work. Inspectors touring the cable spread room found an energized work light and transient combustible work materials at an inactive work site. The improper materials were promptly removed and licensee management had already made equipment storage a plant priority.
On July 22, an inspector observed removal of the spent fuel pool (SFP) missile shield covers per Refueling Procedure (FP)-434, Spent Fuel Pool Missile Shields. Previously this evolution had been performed by Operations staff, but now was to be performed by
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Maintenance crews. The inspector observed good sensitivity to personnel safety and foreign material exclusion requirements by the crew. However, the inspector observed q
the crew was deviating from the prescribed order of shield removal and was preparing to rig shields that would have entailed lifting subsequent shields over an uncovered pool, j
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the correct rigging order and was closely following the FP-434 prescribed storage order.
However, he was located away from the pool in the missile shield storage area and was not aware of the crew's rigging order. The crew at the pool did not have another copy of FP-434. The supervisor corrected the rigging sequence. The inspector determined the supervisor would have immediately detected an error in the order after the first incorrect shield was moved to the storage area, but the crew's actions indicated the restriction to avoid lifting shields over an open pool was not fully understood.
Cleanup of the SFP with the reverse osmosis unit was well controlled. Although all aspects of operating the unit were performed by a contractor, licensee personnel were familiar with the flow paths and bounding limits on its operation and an appropriate temporary licensee procedure had been developed to oversee the contractor actions.
No problems were observed or encountered during the several weeks it was circulating SFP coolant.
The inspectors identified that all four main steam line radiation monitors (RMs) had simultaneously been removed from service for a period of approximately two weeks in July / August. This was contrary to the original work scope which had been to take two RMs out of service one week, and the two others the following week. Although none of the four RMs had any operability requirements, two of the four RMs were Regulatory Guide 1.97 post-accident monitoring instruments and were used as decision variables in EOPs. The inspectors questioned the prudency of removing all four simultaneously, and if appropriate consideration had been given to the schedule deviation. The licensee initiated PC 99-2449 to evaluate the apparent cause. The inspectors considered this an isolated case with respect to the noted improvements in planning and scheduling.
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Conclusions Coordination between Operations, Maintenance, and Scheduling personnel resulted in effective planning and scheduling and was significantly improved. Maintenance Rule unavailability results were more widely disseminated, which improved consideration of equipment out of service impacts by all licensee staff.
M1.2 Primary Leakaae Surveillance a.
Inspection Scope (61726)
The inspectors reviewed Surveillance Procedure (SP)-317, Reactor Coolant System (RCS) Water Inventory Balance, and verified the completed results of five routine surveillances to determine the basis for trends in reported leakage results and to verify calculations were accurat e
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Observations and Findinas SP-317 is performed every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> by control room operators. RCS leakage trends have slowly increased due to some leaking valves. The assigned value of 0.29 gallons per minute (gpm) identified valve leakage for DHV-3, a valve in the reactor building, was based on a June 1999 measurement. This was acceptable since the inspector verified operators were closely monitoring RCS parameters to detect any change and any leakage increase would be accounted at unidentified leakage. The inspectors found the SP-317 results were accurate and well within TS limits for RCS leakage, but identified several minor administrative deficiencies.- The licensee did not have a standard method for quantifying leakage of leaking valves, which caused minor fluctuations in identified leakage results. The SP tag status from the licensee maintenance control system did not flag all of the deficient instruments associated with the SP. Only two of the three inoperable reactor coolant pump seal leakoff dumpster integrators were on the tag status sheet. Without the dumpster integrators, demineralized water flush flow is used to quantify seal leakoff which is obtained from the containment entry inspection SP.
However, that SP did not require flush flow to be verified on any periodicity. The inspector observed that a reading had been obtained at the initiative of a Nuclear Shift Manager on June 15,1999, but the previous performance was December 1998, although the readings were the same. The inspectors also observed inconsistencies in the completed quality record SP packages. Some contained extra data sheets while others were missing required signature pages. The licensee was addressing the deficiencies in their corrective action system, c.
Conclusions The inspectors verified that reactor coolant system leakage surveillances were
performed accurately and leakage was well within Technical Specification limits. Several minor administrative deficiencies were observed; however, the deficiencies did not adversely impact the current surveillance results.
likEngineerina E1 Conduct of Engineering E1.1 Enoineerina Suooort for Eauipment Problems a.
Insoection Scope (37551. 92903)
The inspectors evaluated the support provided by Engineering staff for several equipment problems that impacted essential plant equipment.
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Observations and Findinas These problems included an ongoing microbiological growth problem in the jacket and radiator cooling water of the emergency diesel generators (EDGs). The growth was first evident following the installation of new EDG radiators and feed on the components of
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the coolant corrosion inhibitor. Previously, operational venting problems occurred as the growth created gas pockets in the coolant. This displaced expansion tank liquid and created operability concerns when the EDG was started and the gas pockets flushed out.
The licensee installed several new radiator vent lines which release the trapped gas
. pockets and eliminated the venting problem. However, another problem being created by the growth is frequent failures of the seals on the jacket water circulation pumps which circulate the coolant past lube oil heaters, maintaining the system above TS l
temperature limits. The licensee secured a pump when seal failures occurred to limit coolant loss and expeditiously replaced it before the coolant temperature decreased to operability limits. The inspectors observed good ownership by the component engineer assigned to address this problem. The licensee had devised a filter test to evaluate coolant suspended solids and to attempt to predict seal failures and trends. They also attempted filtration of the coolant with a vendor supplied filter assembly, variation of chemical biocide treatments, and drain and refills of the radiator coolant. The drain and refill evolutions had significantly reduced the microbe problem, and the licensee was considering use of a new corrosion inhibitor to permanently resolve the problem. The inspectors considered that the licensee was appropriately addressing the microbiological growth problems.
Another issue supported by engineering was a through-wall leak on a portion of the nuclear services and decay heat seawater system (RW). On July 20, an approximate half-inch hole developed on an unisolable portion of the low pressure RW piping, downstream of a heat exchanger outlet isolation valve. The inspector observed that Engineering support to Operations was timely and detailed and was essential in supporting the initial operability determination by Operations. The licensee issued PC 99-2346 and developed an associated condition report to evaluate and document the acceptability of continued operation with the flaw. This was also supplied to Operations to support their operability determinations. The inspectors verified the licensee had performed ultrasonic testing to determine the flaw size and to evaluate similar RW piping.
The flaw size was within allowable code limits. The inspector observed the temporary repairs applied to the hole and verified it met the requirements for a temporary repair.
Since the RW piping is ASME Code Class Ill, the licensee was appropriately preparing a relief request per the guidelines in NRC Generic Letter 90-05 for the non-code temporary repair and to document the engineering analysis for the maximum allowable flaw size.
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Conclusions Engineering support for problems with diesel generator coolant microbiological growth was effective. Previous corrective actions were effective and a single accountable engineer was developing long-term solutions. Engineering support for a through-wall raw water leak was timely and provided essential input for an Operations operability determination.
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[V Plant Suonort
R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Routine Resident inspector Observation of Radioloaical Protection Controls (71750)
The inspectors routinely toured the Radiological Control Areas (RCA) and observed work activities, personnel radiological control practices, radiological area and container postings, and worker briefings conducted by Health Physics Technicians (HPT) at the RCA entry. Observed plant personnel demonstrated appropriate application of radiological control practices. HPTr provided positive control and support of work activities in the RCAs. The inspectors observed that coverage for two specific spent fuel pool activities, missile shield removal and reverse osmosis chemical cleanup, was constant and effective. HPTs were questioned by inspectors and were knowledgeable of the work scope and cognizant of potential radiological hazards. Routine worker briefings at the RCA entry control poini provided detailed information on an increasing radiation field trend due to expected crud release at the end of the fuel cycle. The detail of the briefings was much improved from previous inspector observations.
R1.2 Conduct of Radioloaical Protection Controls (83750,84750)
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Inspection Scope During RCA tours, the inspector observed routine maintenance and operational activities, verified selected radiation survey results, and discussed procedural and Radiation Work Permit (RWP) requirements with workers. Radiological controls and housekeeping practices in selected RCA locations including the auxiliary building, spent fuel pool, and outside solid radioactive waste and material storage areas were observed.
Personal dosimetry use, air sampling and quantitative radionuclide analyses, area postings, container labels, housekeeping, and controls for high radiation areas and locked high radiation areas were reviewed and evaluated. In addition, monitoring and analysis of airborne particulate and iodine radionuclides for selected reactor building entries or breaches of primary coolant systems were reviewed and evaluated.
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Radiation protection program activities were compared against applicable sections of the Updated Final Safety Analysis Report (UFSAR), improved Technical Specifications (ITS), and 10 CFR Part 20.
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Observations and Findinas Workers were knowledgeable of radiological conditions and RWP requirements.
Postings and container labels were maintained in accordance with the associated access controls or radiological conditions. High radiation areas and locked high radiation areas were controlled appropriately, in general, housekeeping practices and contamination within the auxiliary building and radioactive waste storage areas were acceptable, with RCA unrestricted areas maintained radiologically clean and uncluttere.
Personal monitoring and surveys for direct radiation and for airborne radioactive particuletes and iodines were satisfactory. During review of procedures and survey records for "at power" reactor building entries, the inspector identified that Health Physics Procedure (HPP) 439, Calibration and Operation of the ANS Oxford Prospector, Revision 0, did not include a correction factor for the charcoal cartridge collection efficiency which could result in non-conservative estimates in calculating airborne iodine concentrations collected by charcoal cartridges and analyzed using the ANS Oxford Prospector. However, discussion and review of selected surveys for iodine analyses conducted since August 1998, verified that quantitative measurements used in the final assessment were conducted using the chemistry laboratory gamma-spectroscopy system which included the appropriate collection efficiency factors. As of July 16,1999, licensee representatives removed the ANS Oxford Prospector system from service and i
identified the procedural changes in the appropriate tracking system for subsequent l
procedural revision.
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Conclusions Radiological controls were implemented and maintained in accordance with UFSAR, ITS, and 10 CFR Part 20 requirements.
R1.3 Liauid Radwaste Effluent Processina. Analysis and Release (84750)
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inspection Scope The inspector directly observed and evaluated radionuclide sampling and quantitative analyses, waste permit processing, and operational activities associated with a July 21, 1999 Waste Neutralizer Tank (SDT-1) liquid release. Procedural adequacy, equipment operability, and staff proficiency were evaluated during discussions and observation of pre-release sample collection, radiological analyses, liquid effluent monitor set-points and dilution calculations. Pre-release valve lineups and control room activities associated with the SDT-1 release were observed. In addition, off-site dose estimates for the first and second quarter of calendar year 1999 were reviewed.
License program guidance, implementation, and results were evaluated against applicable sections of 10 CFR Part 20, Appendix ! to 10 CFR Part 50, ITS, Offsite Dose Calculation Manual (ODCM), and approved procedural requirements.
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Observations and Findinas Chemistry laboratory technicians demonstrated appropriate knowledge of procedural requirements and proficiency in completing assigned tasks. Technicians conducting pre-release sampling and radionuclide analyses were knowledgeable of equipment and procedures. Operators demonstrated detailed knowledge of release pathways, valve lineups, liquid effluent monitor setpoints, and procedural requirements. No concerns were noted for sampling, analysis methods, and calculations performed.
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For 1999, released radionuclide concentrations and resultant doses were a small fraction of 10 CFR Part 20, ODCM, and 49 CFR 190 limits. Further, releases were a small fraction of the radioactive effluent design objectives specified in Appendix I to 10 CFR Part 50.
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Conclusions Chemistry and operations personnel demonstrated appropriate knowledge of procedural requirements and proficiency in initiating and conducting a July 21,1999 SDT-1 release.
Licensee programs to control effluent releases were implemented effectively with effluent
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radionuclide concentrations and resultant projected offsite doses within established regulatory limits and design objectives.
R2 Status of Radiation Protection and Chemistry Facility and Equipment (83750, 84750)
R2.1 Area Radiation Monitors a.
Inspection Scope
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The inspector reviewed and discussed calibration records for selected general area radiation monitors. The inspector directly verified detector installation and compared local and control room readout data.
Operation and calibration of the general area radiation monitors were evaluated agcinst applicable sections of the UFSAR and approved procedures.
b.
Observations and Findinas Observed radiation monitor general area (RM-G) detectors were installed appropriately, and local and remote (control room) read-out data were in general agreement. However, from review and discussion of recent calibrations for the Reactor Building in-core Area (RM-G18) detector, the inspector identified inconsistencies in expected decay-corrected values versus results in the calibration source check data maintained in the Control Room Radiation Monitor Setpoint Log Book and also in completion of Step 4.5, Verification of RMS Gamma Monitors RM-G1 through RMG-18, specified in HPP-404, Area Radiation Monitoring System Calibration and Verification, Revision 10. Specifically, activity data for the calibration sources and verification wand sources did not appear to be decay corrected in accordance with Health Physics Procedure (HPP)-404, Area Radiation Monitor System Calibration and Verification, Revision 10. Licensee representatives stated that the observed data trend may have resulted from installation
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of new detectors and use of different calibration and verification sources. The adequacy of the calibration and verification determinations to ensure proper general area monitor operation was identified as unresolved item (URI) 50-302/99-05-01: Review adequacy of calibration activities and implementation of verification determinations for general area radiation monitor.
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. Qonclusions
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General area radiation monitors were installed properly. Adequacy of calibrations and implementation of completion of verification determinations for the general area radiation monitors could not be verified and was identified as an unresolved item.'
R2.2 Radioactive Environmental Monitorina Instrumentation and Samole Collection a.
Insoection Scope The inspector accompanied a contractor field technician during collection of selected Radiological Environmental Monitoring Program (REMP) samples specified in the ODCM. Particulate and iodine airborne sampling equipment operability and distribution of thermoluminescent dosimeters (TLD) at specific ODCM sample locations was evaluated and verified. Procedural adequacy, equipment operability, and contractor staff proficiency were evaluated during observations of particulate filter, charcoal cartridge, drinking water sample collections.
Equipment location and sampling procedures were evaluated against applicable sections of the UFSAR, ODCM, and approved procedures.
b.
Observations and Findinas Airborne sampling equipment for particulate and iodine radionuclides was installed appropriately, operational, and flow calibrations were maintained in accordance with approved procedures. Although housekeeping within airborne sampling equipment sheds was poor with extra or obsolete charcoal and particulate filters scattered about and expired procedures available in some air-sampling facilities, the inspector verified that all particulate filters were maintained clean prior to change-out, charcoal cartridges had not exceeded their expiration dates, and current procedures were in use.
i From observations and discussion of collection and preparation of drinking water samples, the inspector noted that the failure to preserve one of the drinking water samples in the field as a result of insufficient chemical supplies was inconsistent with i
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corrective actions for a similar issue identified in March 1997 and documented ;n PC 3-C97-1735. At that time, the contractor did not immediately acidify three liquid t,amples in the field prior to transfer to the laboratory. Licensee corrective actions included emphasis to the contractor that procedures should be followed and that adequate supplies must be available for field sampling to assure procedural compliance regarding sample preservation. However, during the current inspection, the contractor provided standard guidance, Environmental Protection Agency Manual for the Certification of Laboratories Analyzing Drinking Water, Criteria and Procedures Quality Assurance,
1977, which recommended immediate preservation of the sample at the time of collection but did allow a five day interval for addition of the acid. Licensee
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representatives noted that the differences in the observed contractor actions, standard guidance, and previous. licensee corrective action guidance for preserving drinking
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water samples would be entered in their corrective action program for additional review and actions, as necessary, to ensure adequacy of REMP sample radionuclide analyses,
c.
Conclusions The radiological environmental monitoring program for airborne radionuclides and drinking water samples, and monitoring of direct radiation was implemented in accordance with the Offsite Dose Calculation Manual. Implementation of liquid sample preparation activities was inconsistent with previous corrective action guidance, however, the quality of the drinking water sample analyses was not affected.
R3 Radiological Protection and Chemistry (RP&C) Documents R3.1 Radioloaical Effluent and Environmental Monitorina Reports (84750)
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Inspection Scope The inspector reviewed and discussed the 1998 Annual Radiological Environmental Monitoring Report and the Radioactive Effluent Release Report submitted in accordance with ITS 5.7.1.1.(b) and 5.7.1.1(c) respectively.
b.
Observations and Findinas For 1998, liquid and gaseous effluent concentrations were significantly less than 10 CFR Part 20 limits, and projected doses were significantly below ODCM limits and design objectives listed in Appendix I to 10 CFR Part 50. The Annual Radiological Effluent Report did not identify significant changes to radioactive waste treatment systems, new dose calculation locations as a result of the land-use census, or effluent monitors as out-of-service for more than 30 days. One unplanned release resulting from a leak from a underground transfer pipe was identified. Licensee actions for this issue, including release termination, release evaluation, system repairs, and inclusion of the affected area in the site decommissioning plan records were deemed appropriate.
The Radiological Environmental Monitoring Report did not identify any long-term
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increasing trends in radionuclide concentrations for media sampled with the majority of results reported as less than the specified lower limit of detection. In addition, the inspector verified that various sample media, including particulate filters, soil and vegetation were included in the interlaboratory comparison program, although only results for liquid interlaboratory comparison program were documented in the report.
Licensee representatives stated that all media analyzed in the intercomparison program i
would be documented in future reports.
c.
Conclusions The 1998 Annual Effluent Release Report and Annual Radiological Environmental Monitoring Report were submitted in accordance with ITS and documented results
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demonstrated gaseous and liquid effluent processing and subsequent releases met established regulatory limits.
S1 Conduct of Security ar.a Safeguards Activities S1.5 Fitness for Duty Proaram a.
' inspection Scooe (81502)
The licensee's Semiannual Fitness for Duty (FFD) Performance Report was reviewed against the requirements specified in 10 CFR 26.
b.
Observations and Findinas Upon review of the licensee's July 1 through December 31,1998, Semiannual FFD Performance Report and review in conjunction with this inspection, the inspector noted that on November 23,1998, a pre-access contract employee submitted a urinalysis test as part of the access authorization process and was determined by the licensee to be a refusal.
On November 24,1998, the laboratory reported the specimen in question as negative; however, the creatinine level of the sample was unusually low. A creatinine level of 0.2 g/L or greater is expected to consider the sample not to be diluted or substituted.
The contract individual's creatinine level was 0.01 g/L. Individuals may have specimeas with creatinine concentrations lower that the 0.2 g/L which are not diluted or substituted; however, the Medical Review Officer (MRO) must make such a determination. Upon receipt of the individual's test results, the MRO ordered another specimen be provided by the individual. This subsequent collection occurred on November 24,1998. The test
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results reported by the clinical laboratory for the sample indicated a creatinine level of 0 g/L for the specimen. Upon review of both test results, the MRO ordered a Limit of Detection (LOD) test be performed on the subject sample to determine the presence of substances. The laboratory determined the result of the LOD test to be negative. Upon discussion with the clinical laboratory's certifying scientist, the MRO determined the contract individual substituted both specimens. The licensee declared the tests as refusals, which were deemed positive by the licensee's procedures. The individual was not granted unescorted access.
Upon review of the individual's previous testing records, the inspector determined that in November 1993 the individual's pre-access urinalysis specimen contained a creatinine concentration of 0.02 g/L, again lower than the 0.2 g/L. The MRO determined the test to be valid, since the individual had two previous tests with acceptable creatinine levels.
Another pre-access drug test was conducted in October 1997, again revealing a creatinine concentration of 0.02 g/L. Since the individual's urine specimen on the previous occasion (November 1993) contained a creatinine concentration below 0.2 g/L, the inspector determined a direct observation test should have been conducted. There was no record that another specimen was collected and tested in conjunction with the October 1997 test. With respect to the November 1998 urine specimen, the inspector t-
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l determined that since the immediate proceeding October 1997 test revealed a creatinine concentration below 0.2 g/L, a direct observed test again should have been conducted.
The requirements specified in 10 CFR 26, Appendix A, Section 2.4(g)(17) state that whenever there is reason to believe that a particular individual may alter or substitute the urine specimen to be provided, a second specimen shall be obtained as soon as possible under direct observation. The requirements further explain circumstances that clarify the meaning of " reason to believe." The provisions of 10 CFR 26, Appendix A,-
Section 2.4(f)(2) state that for purposes of this Appendix, the following circumstances are exclusive grounds constituting a reason to believe that an individual may alter or substitute a urine specimen, i.e., the last urine specimen provided by the individual (i.e., on the previous occasion) was determined by the laboratory to have a specific gravity of less than 1.003 or a creatinine concentration below 0.2 g/L. Contrary to the above, a urine specimen was not obtained under direct observation for the October 1997 test nor the November 1998 tests, as well as the immediately proceeding tests, of the contract individual in question, even though the creatinine levels of both tests were below the expected 0.2 g/L. This Severity IV violation is being treated as a non-citod violation, consistent with Appendix C of the NRC Enforcement Policy,50-302/99-05-02, failure to
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conduct FFD tests under direct observation. This violation is in the licensee's corrective action program as PC-3-C99-2208.
I c.
_Qpnclusion Failure to obtain urine specimens under direct observation for an individual who was suspected of altering or substituting specimens for FFD tests conducted in 1997 and 1998 was idontified as a non-cited violation.
S2 Status of Security Facilities and Equipment S2.8 Protected Area Addition a.
Insoection Scope (81700)
The inspector reviewed the licensee's actions associated with adding the Nuclear Administration Building to the existing protected area.
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b.
Observations and Findinas The inspector performed a walkdown of the newly incorporated territory of the protected area and reviewed related documentation to determine if the licensee complied with requirements specified in the Physical Security Plan (PSP). One existing protected area zone was reconfigured and three additional zones of detection were added to provide physical security coverage of the new protected area. The inspector determined that additional microwave equipment, lighting, and cameras were appropriate to fulfill the requirements of the PSP.
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" Operation Crystal Shield" was implemented and completed January 30,1999, to search the newly added portion of the protected area to ensure unauthorized material or individuals were not present. This search process utilized teams of security officers as well as K-9 dogs from Citrus and Marion Counties. The inspector determined the licensee implemented this search process in an effective manner.
Prior to declaring the new protected area secure, the licensee performed functional testing on the equipment of each new or rec 7nfigured zone. The inspector reviewed Modification Approval Request No. 98-05-02-01, Revision 0, "Nuciaar Administrative Building Security Enhancement," and verified that microwave detection systems, security cameras, video capture, and lighting levels met PSP commitments to detect intrusion attempts, c.
Conclusion
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The licensee satisfactorily implemented and tested new and reconfigured equipment to the existing protected area to encompass the Nuclear Administration Building. The licensee conducted an effective search of the new area to ensure against unauthorized meterial and individuals.
S3 Security Safeguards Procedures and Documentation S3.1 Security Proaram Plans a.
Insoection Scope (81700)
A review was conducted of recently submitted PSP revisions to determine if the i
provisions of 10 CFR 50.54(p) were met.
b.
Observations and Findinas i
The inspector reviewed PSP change revisions 6-15,6-16,6-17, and 7-0.
Revisions 6-15 through 6-17 detailed changes to several areas, to include the addition of hand geometry access readers. No deficiencies were identified. Revision 7-0 was submitted by the licensee on April 22,1998, for the purpose of reformatting the Plan to j
be more consistent with the guidelines established in NUREG 0908, " Acceptance i
Criteria for the Evaluation of Nuclear Power Reactor Security Plans." The inspector compared the commitments established in Revision 6-17 to those submitted in the Revision 7-0 and identified several discrepancies. The provisions of 10 CFR 50.54(p)(1)
require that a licensee make no changes to the PSP which would decrease the effectiveness, without prior approval of the Commission. Although the four discrepancies identified by the inspector appeared to be administrative failures to incorporate previous PSP commitments, the discrepancies were significant in that they would result in a decrease of effectiveriess of the security program if implemented. The inspector did not find any occurrences where the discrepancies were found to have been implemented since the changes were submitted. This Severity Level IV violation is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy,
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50-302/99-05-03, PSP changes that decreased the effectiveness of the Plan. This violation is in the licensee's corrective action program as PC-3-C99-2206.
c.
Conclusion A non-cited violation was identified for the licensee's PSP submittal, Revision 7-0, which decreased the effectiveness of the Plan.
SS Security Safeguards Staff Training and Qualification SS.1 Security Trainina and Qualification i
a.
Inspection Scope (81700)
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The inspector observed a tabletop drill, which was conducted as part of requalification training for security officers.
b.
Observations and Findinas During the course of the inspection, the inspector observed a tabletop drill being conducted as part of the security officers' annual requalification. Two Team Leaders participated as well as other resoonse officers. The inspector observed that the officers were knowledgeable of target sets and the operational significance associated with each J
target set. A beneficial exchange of information with the officers, as well as the trainers, provided diverse challenges and solutions.
I In addition to the required annual task training and firearm requalification, additional advantageous training was conducted during the week of the inspection, which included tactical training exercises, tactical room clearing, and use of force exercises.
c.
Conclusion The licensee had a satisfactory training program that incorporates tactical training with the required annual task and firearm requalification training.
V. Manaaement Meetinas X1 Exit Meeting Summary The inspection scope and findings were summarized on August 16,1999. Proprietary information is not contained in this report. Dissenting comments were not received from the licensee.
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PARTIAL LIST OF PERSONS CONTACTED L'qstnsees S. 8 3rnhoft, Director, Nuclear Regulatory Affairs I
J. Cowan, Vice President, Nuclear Operations R. Davis, Assistant Plant Director, Operations R. Grazio, Director, Nuclear Site and Business Support G. Halnon, Director, Nuclear Quality Programs J. Holden, Vice President and Director, Site Nuclear Operations C. Pardee, Director, Nuclear Plant Operations D. Roderick, Directoi, Nuclear Engineering & Projects M. Schiavoni, Assistant Plant Director, Maintenance T. Taylor, Director, Nuclear Operations Training NRC L. Hayes, Physical Security Specialist, Region ll (July 6-9,1999)
G. Kuzo, Senior Radiation Specialist, Region ll (July 12-16,1999)
S. Ninh, Project Engineer, Region 11 (August 2-5,1999)
l INSPECTION PROCEDURES USED IP 37551:
Onsite Engineering IP 61726:
Surveillance Observations IP 62707:
Conduct of Maintenance IP 71707:
Plant Operations IP 71750:
Plant Support Activities IP 81700:
Physical Security Program for Power Reactors IP 81502 Fitness for Duty Program IP 83750 Occupational Radiation Exposure IP 84750:
Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92901:
Followup - Operations IP 92903:
Followup - Engineering ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-302/99-05-01:
URI Review adequacy of calibration activities and implementation of verification determinations for J
general area radiation monitors (Section R2.1).
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50-302/99-05-02 NCV Failure to conduct FFD observed tests (Section S1.5)
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50-302/99-05-03 NCV PSP changes that decreased the effectiveness of the Plan (Section S3.1).
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50-302/99-05-02 NCV Failure to conduct FFD observed tests (Section S1.5)
50-302/99-05-03 NCV PSP changes that decreased the effectiveness of the Plan (Section S3.1).
50-302/98-13-00 LER Procedural Inadequacy Caused by Personnel Error Results in Missed Surveillance Requirements.
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(Section 08.1)
50-302/98-301-01 IFl Various Procedure Deficiencies Outlined in
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Precursor Card 98-3185 (Section 08.2).
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