IR 05000348/1997010
| ML20211Q951 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/06/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211Q937 | List: |
| References | |
| 50-348-97-10, 50-364-97-10, NUDOCS 9710230074 | |
| Download: ML20211Q951 (26) | |
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U.S. NUCLEAR REGULATORY COMMISS)0N (NRC)
P,EGION 11 l
Docket Nos.
50-348 and 50-364
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License Nos:
50-348/97-10 and 50-364/97-10 Licensee:
Southern Nuclear Operating Company, Inc.
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Facility:
Farley Nuclear Plant (FNP), Units 1 and 2 Location:
7388 North State Highway 95 i
Columbia AL 36319 Dates:
August 3 through September 6, 1997 Inspectors:
T. Ross, Senior Resident Inspector (SRI)
J. Bartley. Resident Inspector R. Caldwell, Resident Inspector R. Freudenberger, SRI - Catawba G'. Kuzo Health Physics Inspector (Sections R1, R3 and RS)
Approved by:
P. Skinner. Chief, Reactor Projects Branch 2 Division of Reactor Projects Enclosure 2 9710230074 971006 PDR ADOCK 05000348 G
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EXECUTIVE SUMMARY Farley Nuclear Power Plant. it 'ts 1 and 2 NRC Inspection Report 50-348/97-10, 50-364/97-10 This integrated inspection included aspects of licensee operations.
engineering, maintenance, and plant support.
The report covers a 5-week period of resident and specialist inspections.
Doerations Operator attentiveness to main control board (MCB) annunciator alarms e
and response to changing plant conditions were prompt.
Management's
)ersistent ef forts to reduce the number of MCB deficiencies and achieve
)lackboard were evident.
Operating crews demonstrated a high level of awareness of plant conditions and ongoing activities (Section 01.1).
Control Room professionalism and communications were good.
e Operator demeanor, teamwork, and conduct of business were a)propriate.
Unnecessary activities and business were kept out of t1e " Controls Area." Shift supervisor command and control functions and operations management oversight were evident (Section 01.1),
Crew response to a dilution event was prompt and effective.
Operators'
o attentiveness to their panels resulted in identifying the event without receiving any annunciators prior to or during the event (Section 01.2).
Safety system walkdowns and tours verified that accessible portions of
selected systems were adequately maintained and operational (Sections 02.1 and 02.2).
Maintenance
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Maintenance and surveillance testing activities were generally conducted e
in a thorough and competent manner by qualified individuals in accordance with plant procedures and work instructions (Section M1.1).
A Non-cited Violation (NCV) was issued for problems associate, with the e
implementation of the Technical Specification 6.8.3.a program due to a lack of attention to the correction of program deficiencies and inadequate procedural guidance.
After issues regarding primary coolant leakage from sources outside containment, including corrosion concerns, were raised by the inspectors. licensee corrective actions were broad and aggressive (Section M8.5).
Enclosure 2
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Plant Suonort Radiation protection activities were properly implemented with effective e
oversight and controls.
Current radiological environmental monitoring program (REMP) activities were in accordance with Offsite Dose Calculation Manual (0DCM) recuirements.
Responsible technicians displayed proficiency in concucting the current field sampling program.
An issue was identified regarding adequacy of extended wet resin storage (Section R1.1).
Guidance for implementing 49 CFR Parts 100 through 179 and 10 CFR Part e
71 regulations was general in nature and dependent on extensive training of individuals.
An NCV was identified for failure to follow 10 CFR 71.5 requirements for not meeting 49 CFR 172.200 shipping paper documentation requirements.
Radwaste volume reduction efforts for process resins and for dry active waste were effective (Section R1.2).
Surveillances for the inoperable U1 RE-60C monitor were completed in e
accordance with approved procedures.
A violation was identified for inadequate configuration control and design concerns regarding installation of the U1 RE-29A and R-68 sample lines (Section R1.3).
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Licensee programs to control and document liquid and airborne
i radionuclide effluent releases were maintained and implemented
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effectively.
Projected offsite doses to the maximally exposed individual were well within the limits specified in the ODCM and i
40 CFR 190.
In general, sampling, analysis, and reporting requirements l
of the REMP were implemented effectively and demonstrated minimal l
environmental impact from facility operations.
However, an NCV was identified for inadequate 3rocedures to ensure surface water samplers
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operated in accordance wit 1 00CM requirements (Section R3.1).
Appropriate hazardous material (hazmat) training was provided to o
personnel handling and packaging radioactive materials for transport, with the exception of inconsistencies in maintenance of hazmat training and test records (Section R5.1).
Security personnel observed during the inspection period were attentive
to their responsibilities.
Site security systems were adequate to ensure physical protection of the plant (Section S1.1).
A violation was identified for installing one 1-inch thick wrap of e
Kaowool on raceways BDE-9 and BDE-15 in lieu of two 1-inch wraps, as required by Appendix 9B of the Updated Final Safety Analysis Report (Section F8.1).
Enclosure 2
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Reoort Details Summary of Plant Status Unit 1 operated continuously at 100% power for the entire inspection period.
Unit 2 operated continuously at 100% power for the entire inspection period.
I. Doerations
Conduct of Operations 01.1 Routine Observations of Control Room Doerations a.
Insoection Scone (71707)
Inspectors conducted frequent inspections of ongoing plant operations in
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the Main Control Room (MCR) to verify proper staffing, operator
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attentiveness, adherence to approved operating procedures.
l communications, and command and control of operator activities, inspectors reviewed operator logs and Technical S)ecification (TS)
Limiting Conditions of Operation (LCO) tracking sleets, walked down the Main Control Boards (MCBs), and interviewed members of the operating shift crews to verify operational safety and compliance with TSs.
The inspectors attended morning plant status meetings and shift turnover meetings to maintain awareness of overall facility operations,
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maintenance activities, and recent incidents. Morning reports and Occurrence Reports (OR) were reviewed on a routine basis to assure that the licensee properly reported and resolved potential operations safety concerns.
b.
Observations and Findinas Overall control and awareness of plant conditions during the inspection
]eriod remained a strength.
Ins)ectors observed that the Unit 1 (Ul)
iCB annunciators and Balance of 31 ant (BOP) alarm panels were frequently
" blackboard." However, the Unit 2 (U2) MCBs and BOP panels, and the emergency power board (EPB) continued to have a few persistent annunciators for known equipment problems.
Management efforts to maintain MCB deficiencies at very low levels continued.
The combined MCB deficiencies on U1 and U2 had dropped below 15, with most being on U2.
Most of the deficiencies involved nonsafety-related instrumentation or equipment, and none resulted in a TS LCO.
0]erator attentiveness to MCB annunciator alarms and resoonse to clanging plant conditions and transients were prompt and effective (see also Section 01.2).
Interviews with members of the operating crew verified that they were consistently aware of plant conditions and ongoing activities. Operator knowledge was very good.
Operator logs w r e of sufficient detail and scope.
Shift staffing was verified to be
.a compliance with procedural and TS requirements.
Enclosure 2
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Pre-shift briefings of the operating crews by the shift supervisors (SS)
were generally concise, informative, and provided operators with shift direction and-priorities.
Shift turnovers were accomplished in an orderly manner, following a board walkdown by the off-going and on-coming operators and SSs.
Operators responded appropriately to alarm conditions and used the alarm response procedures.
The inspectors observed that neither the overhead alarm window nor the alarm res)onse procedures addressed alarm reflash capability.
This o)servation was discussed with Operations management.
Routine reactivity manipulations by the reactor operators (R0s)
were observed by the inspectors.
These manipulations included dilutions using the Chemical Volume and Control System and control rod movements. The operators notified the applicable SS prior to each manipulation as required by Administrative Procedure FNP-0 AP-16. " Conduct of Operations - Operations Group." Revision (Rev.) 26. and management exoectations, c.
Conclusions Control Room professionalism and communications remained good.
Operating crew demeanor, team work and conduct of business were effective.
Unnecessary activities were kept out of the " Controls Area." Unit SS command and control, and operations management oversight were evident.
0)erator attentiveness to MCB annunciator alarms and response to clanging plant conditions were prompt.
Management's efforts to achieve blackboard conditions and reduce the number of MCB deficiencies were evident.
The operating crew consistently demonstrated a high level of awareness of existing plant conditions and ongoing plant activities.
01.2 Letdown Temoerature Dilution Event a.
Scoce The inspectors interviewed the operators on-shift and reviewed OR 1-97-325 and plant data for volume control tank temperature, letdown heat exchanger (Hx) outlet _ temperature, and reactor power, following a dilution event which occurred on August 27, 1997.
b.
Observations and Findinos The dilution event that occurred on August 27, 1997 was caused by erratic operation of Q1P17TCV3083. Letdown Hx Temaerature Control valve.
The temperature control valve went further open tlan normal causing the temperature of letdown to decrease about seven degree.s Fahrenheit ( F)
below its normal value.
The cooler fluid caused the demineralizers to Enclosure 2
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have a greater affinity for absorption into the boron, resulting in a dilution of the reactor coolant system (RCS).
The inspectors reviewed the trend recorder traces and determined that 01P17TCV3083 went further open than normal at about 10:40 a.m.
At about 10:50 a.m.. reactor power went above 100% and the operators first noted the elevated power level (-100.2%) and increasing RCS temperature at about 1057 a.m.
Operators identified and responded to the event prior to receiving any annunciator indications.
The crew responded promptly to the event by borating and inserting control rods, and observing indicators to identify the cause.
After eliminating sources of increased steam flow, an operator was dispatched to check for problems with the chemical volume control system.
The operator identified the problem with TCV3083.
Reactor power peaked at 100.5% at 11:02 a.m.
This peak was 2655 megawatts, slightly above the licensed thermal power level of 2652 megawatts.
Reactor power was below 100% by 11:05 a.m.
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Conclusions The shift crew res3onse to the event was prompt and effective.
Operators' attentiveness to their panels resulted in identif"ing the trend without receiving any annunciators prior to or during the event.
Operational Status of Facilities and Equipment 02.1 General Tours of Soecific Safety-Related Areas (71707)
General tours of safety-related areas were performed by the inspectors throughout both units to examine the physical condition of plant equipment and structures, and to verify that safety systems were properly aligned. These general walkdowns included the accessible portions of safety-related structures, systems, and components (SSC).
Overall material conditiors for U1 and U2 SSCs were good. Almost all
)lant areas were clear of trash and debris.
Some minor equipment and lousekeeping problems ider.tified by the inspectors during their routine tours were reported to the responsible SS and/or maintenance department for resolution.
These problems included improper storage of combustible r.iaterials, minor boric acid leaks and/or deposits, unsecured items located near safety-related eqaipment, corroded components, etc.
None of the problems constituted a significant safety or compliance issue.
Enclosurc 2
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02.2 Biweekly Insnections of Safety Systems (71707)
Inspectors verified the operability of the following selected safety systems and/or equipment:
e U2 Penetration Room Filtration (PRF)
U1 and U2 Hot Shutdown Panels U1 A & B Train Boration Flow Paths and Supply e
U2 A & B Train Boration Flow Paths and Supply e
Accessible portions of the systems listed above were verified to be properly aligned.
The inspectors also observed them to be well maintained and in good operating condition.
For the Hot Shutdown Janels. FNP-0-EIP-16.0 Checklist X. " Emergency Equipment and Supplies."
Rev. 31. was used to verify that all required equipment and documentation was on station.
The inspectors did not identify any issues that adversely affected system operability.
02.3 Verification of Safety Taqaina a.
Inspection Scope (71707)
The inspectors verified that selected tagouts were implemented in accordance with procedural requirements.
The inspectors reviewed and walked down selected devices tagged by the following tag orders (TOs):
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TO# 97-1952-1. lA Containment Spray Pump TO# 97-2132. U1 Turbine Driven Auxiliary Feedwater (TDAFW) pump i
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Observations and Findinas The inspectors verified that devices identified on the tag orders were properly tagged.
The device identifications were correct. tags were conspicuously placed on the devices and the tags did not obscure control room panel indications.
The administrative aspects of filling out the tagging order forms were complete and correct.
The tags placed were adequate for personnel safety and equipment protection, c.
Conclusion The inspectors concluded that the reviewed safety tagging activities were correct and met the procedural requirements.
The administrative aspects of the tagging orders were complete and accurate. The tags placed were adeauate for personnel safety and equipment protection.
02.4 TS LCO Trackina (40500 and 71707)
The inspectors routinely reviewed the TS LCO tracking sheets filled out by the shift foremen.
All tracking sheets for Units 1 and 2 reviewed by Enclosure 2 l
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5 02.4 TS [C0 Trackina (40500 and 71707)
The inspectors routinely reviewed the TS LCO tracking sheets filled out by the shift foremen.
All tracking sheets for Units 1 and 2 reviewed by the inspectors were consistent with plant conditions and TS requirements.
II. Maintenance M1 Conduct of Maintenance M1.1 General Comments a.
Inspection Scope (61726 and 62707)
Inspectors observed and reviewed portions of various licensee corrective and preventive maintenance activities, and witnessed routine surveillance testing to determine conformance with plant procedures, work instructions industry codes and standards. Technical S3ecifications (TSs), and regulatory requirements.
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oaserved all or portions of the following maintenance and surveillance l
activities, as identified by their associated work order (WO). work
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authorization (WA) or surveillance test procedure (STP):
e WO#M00548108:
1A CS Pump Drain Valve (V032C) Leak Repair e WO#S97006029:
1A CS pump seal leak, vent leak, and drain valve (V038A) leak repairs e WO#S97006017:
Clean and inspect 1A CS system containment sump suction valve (01E13V004A)
e FNP-1-STP-24.7:
Service Water Valve Inservice Test Rev. 21 I
e FNP-1-STP-226.1:
B1F Sequencer Operability Test. Rev. 6 e FNP-0-RCP-326:
Operation and Calibration of the Eberline RAS-1 (Low Volume Air Sample). Rev. 8 e FNP-2-STP-2.3:
Boron Injection Flow Path Verification and Boric Acid Transfer Pump Operability Test. Modes 1.2.3
& 4. Rev. 16 e FNP-2-CCP-335:
Zinc Aodition System (ZAS) Rev. 4 e WO#479362 Calibrate U1 TDAFW Pump Speed Control Loop. FNP-1-IMP-209.12. Rev. 12 e WO#080478 Install Interposing Relay on 1C SA Compressor e FNP-1-STP-20.2 Penetration Room Filtration System Train A Monthly Operability Test e FNP-2-STP-2.3 Boron Injection Flow Path Verification and Boric Acid Transfer Pump Operability Test. Modes 1, 2.
3 & 4. Rev. 16 Enclosure 2
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Observations. Findinas and Conclusions All observed maintenance work and surveillance testing was performed in accordance with work instructions, procedures, and applicable clearance controls.
In general, safety-related maintenance and surveillance testing evolutions were well planned and executed.
Responsible personnel demonstrated familiarity with administrative and radiological controls.
Surveillance tests of safety-related equipment were co tistently performed in a deliberate step-by-step manner by personnel in close communication with the Main Control Room (MCR).
Overall, operators, technicians and craftsman were observed to be knowledgeable.
experienced, and well trained for the tasks performed.
M8 Miscellaneous Maintenance Issues (90712 and 92902)
M8.1 (Closed) Insoector Followuo Item (IF1) 50-348. 364/96-06-03. EDG Reliability Problems Associated with End-of-Life Hxs This item was opened to review the licensee's efforts to correct the deteriorating condition of all the emergency diesel generator (EDG) Hxs due to tube leaks.
The licensee has replaced 13 of the 15 EDG Hxs. The l
remaining two Hxs. on the 1-2A EDG are scheduled for replacement in October 1997.
The inspector observed the installation of the new Hxs
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for the 2B EDG on September 9. 1997 The licensee coated the inlet tubesheet of all the new Hxs with epoxy to reduce SW erosion and minimize tube leaks.
Based on the licensee's actions, this IFI is closed.
M8.2 (Closed) Licensee Event Report (TERT 50-348/96-03. Actuation of Engineered Safety Feature Equipment Due to an Apparent Relay Contact Failure Licensee Event Report 50-348/96-03 addressed an unplanned engineered safety feature actuation that occurred during surveillance testing of the 1B diesel generator on June 2. 1996. The licensee concluded that the most likely cause of the equipment actuation was a non-repeatable failure of a relay contact to open.
The suspected relay was replaced and a licensee review of maintenance history indicated that a generic problem with this type of relay did not exist.
The inspector reviewed the LER and the licensee's incident report 1-96-150.
The cause evaluation a)propriately considered and eliminated potential causes other than tie failure of the relay contacts to open.
Based on this revision, this LER is considered closed.
M8.3 (Closed) Unresolved Item (URI) 50-348. 364/97-05-04. EDG 50% Load Rejection Surveillance Testing Even though existing STPs only recuired a 1200KW load rejection test of the EDGs. a review of historical cata since 1982 by the licensee and an inspector revealed the actual load rejected during testing was Enclosure 2
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considerably more, and much closer to the 50% value discussed in the NRC's safety evaluation re? ort (SER).
The actual load rejected during the TS 4.8.1.1.2.e required surveillance testing ranged from 32% to 72%
of the design rating: with the average load rejected being 47% (1-2A and IB EDGs). 56% (28 EDG) and 60% (1C EDG) of the design rating.
In order to resolve the inconsistency between the NRC SER and plant surveillance procedures. the Operations department revised all applicable STPs to require a load rejection of at least 2050 KW for the 1B, 28. and 1-2A EDGs and 1450 KW for the 1C EDG, The inspector reviewed the revised STPs.
This URI is considered closed.
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M8.4 (Closed) URI 50-364/97-05-06. Painting Effects on PRF Operability This iten was closed in Inspection Report (IR) 50-348. 364/97-06.
however, it was incorrectly identified as URI 50-348/97-05-05.
M8.5 (Closed) URI 50-348. 364/97-08 04. Primary Coolant Leakage Outside Containment This Unresolved item (URI) is discussed in Section E2.1 of IR 50-348.
364/97-08, in which the inspectors discussed numerous containment spray system leaks, which constituted primary coolant sources outside containment in U1 and U2.
These leaks were not being actively worked to reduce leakage as low as practical.
During further review of this issue, the inspectors reviewed TS 6.8.3.a which requires the licensee to maintain a program for identifying.
evaluating, and repairing primary coolant leaks outside containment.
This program is required te include:
(1) Preventive maintenance and periodic visual inspection requirements, and (2) Integrated leak test requirements for each system.
Aspects of this program, and program efforts to limit corrosion from boric acid leaks. were not well defined in implementing procedures.
The Engineering Support (ES) department committed in Occurrence Report (OR) 1-97-274 to develop a new " summary" procedure, to assess bolt wastage from boric acid leaks and track total emergency core cooling system (ECCS) leakage to ensure that the Updated Final Safety Analysis Report (UFSAR) limit is not exceeded, by December 1, 1997.
Also. FNP-0-ETP-4303. " Evaluation and Prevention of Damage From Borated Water I.eakage." and the ECCS leak assessment engineering
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test procedures (ETP) will be revised by December 1 to reflect enhanced guidance and management expectations.
A subsequent review of outstanding W0s by the Planning department determined that there were apprcximately 60 identified minor boric acid-leaks in the plant.
Planning personnel inspected each of these leaks for cleanup. expedited repair or referral to engineering support (ES)
to evaluate the leakage per TS 6.8.3 for corrosion effects.
In addition. the Operations department conducted training sessions, primarily for system operators, and issued additional guidance in night orders regarding the need to report any and all leaks.
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Table 6.3-8 of the UFSAR specifies that the maximum potenti '
recirculation loop leakage external to containment will be 3760 ml/hr from various sources (e.g., pumps, valves. Hxs etc.).
This leakage amounts to approximately one gallon per hour from all ECCS components.
including the containment spray system, inside the penetration room boundary.
The subsequent review of all existing primary ccolant leaks outside containment by the licensee and resident inspectors concluded that the total leakage was a small fraction of the FSAR limit.
However, current ETP guidance was unclear regarding the integrated leak rate
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requirements.
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Resident inspectors have observed the increased sensitivity by system operators for identifying and reporting leaks using deficiency reports.
OR No. 1-97-274 was issued to initiate and document the licensee's corrective actions.
An inspector met with ES. Operations. Maintenance, and Planning department management and supervision on several occasions to discuss the licensee's-plans to address primary coolant leaks from a TS 6.8.3.a program perspective and corrosion concern.
After the issues regarding primary coolant leakage from sources outside containment, including corrosion concerns, were raised by the inspector, licensee corrective actions have been broad and aggressive.
The licensee's TS 6,8.3.a program implementation initially exhibited a lack of attention and inadequate procedural guidance.
This was a violation of minor significance and is identified as noncited violation (NCV)
50-348, 364/97-10-01. Lack of Attention and Inadequate Procedural Guidance for Addressing Primary Coolant Leaks Outside Containment, consistent with Section IV of the NRC Enforcement Policy.
Based on issuing the NCV. Unresolved Item (URI) 50-348, 364/97-08-04 Primary Coolant Leakage Outside Containment is closed.
III. Enoineerino
E7 Quality Assurance In Engineering Activities (37551)
E7.1 UFSAR Reverification Procram The licensee initiated an Updated Final Safety Analysis Report (UFSAR)
reverification in July 1996 in response to Information Notice (IN) 96-17.
The reverification was completed in December 1996 and the discrepancies were entered into a computer database as documented in Inspection Report (IR) 50-348. 364/97-06.
The resident ins]ectors are reviewing the database and will also evaluate and inspect t1e corrective actions for selected di.screpancies as they are completed. This is identified as IFI 50-348, 364/97-10-02. UFSAR Reverification Corrective Actions.
Enclosure 2
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Jk. Plant Suonort R1 Radiologica' Protection and Chemistry Controls Rl.1 Radioloaical Controls a.
Inspection Scoce (83750)
Radiation protection (RP) program controls and activities associated with routine operations and radioactive waste (radwaste) and radioactive material processing and storage operations were reviewed and evaluated by the inspectors.
Reviewed program areas included general housekeeping and cleanliness area postings, container labels, high and locked-high radiation area controls, and procedural guidance.
Frequent tours of the site radiologically controlled areas (RCAs) were made.
Radiation work permit (RWP) guidance was reviewed and discussed with workers entering the RCA.
In particular the inspectors discussed radiation and contamination surveys and surveillances associated with disposable containers, i.e., liners holding contaminated processing resins. The liners are maintained in concrete overpacks adjacent to the outside east wall of the Unit 1 (U1) and Unit 2 (U2) auxiliary buildings.
In addition, tours of offsite environmental monitoring stations were conducted to review operational status of equipment and to observe technicians performing the collection and processing of environmental samples.
Established RP controls and activities were compared against Updated Final Safety Analysis Report (UFSAR) details and documented procedural guidance established to meet a3plicable sections of Technical Specifications (TSs) and 10 CFR Part 20.
Licensee surveillance programs for extended storage of the contaminated resins maintained in shielded overpacks were com)ared to guidance detailed in Generic Letter (GL) 81-38. Storage of _ow-level Wastes at Power Reactor Sites, dated November 10. 1981.
Environmental monitoring program activities were reviewed against applicable surveillance procedures.
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Observations and Findinas High and locked-high radiation area controls were verified to be implemented in accordance with TS and procedural requirements.
Specifically, the inspectors verified implementation of key controls associated with locked and locked-high radiation areas.
Posting for RCAs was proper and in accordance with TS or 10 CFR 20 Subpart J rec uirements. Although some labels were fading, containers holding racwaste. contaminated materials, or equipment were labeled in accordance with 10 CFR 20.1904 requirements.
Faded labels were upgraded prior to the end of the inspection.
Enclosure 2
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From direct observation and discussions, workers were verified to be following the established radiological controls for RCA entry.
The inspectors observed continuation of licensee oversight of workers'
knowledge regarding radiological conditions, RWP guidance, and individual dose margins prior to RCA entry.
The inspectors identified concerns regarding controls and surveillances for contaminated resins in four disposable carbon steel liners maintained in concrete overpacks adjacent to the outer east wall of the U1 and U2 auxiliary buildings.
Documented contact dose rates for the unshielded liners ranged from 0.5 to 400 millirem per hour (mrem /hr).
Review of selected licensee records and radiation surveys indicated that resins were initially placed in two of the overpacks on August 8.1992, i.e., more than five years ago.
Licensee representatives stated that the resins were used for selected cleanup operations and were being maintained in wet storage for subsecuent use.
Limited vendor documents provided to the inspectors indicatec that the internal containers were unlined.
No additional vendor specifications regarding applicability of the carbon steel liners for extended wet resin storage nor wet resin chemical characteristics, e.g., pH, which may affect container integrity were known by the licensee.
Licensee representatives stated that the l
concrete overpacks were opened occasionally for visual inspection of the i
internal containers.
However, no formal surveillances were available documenting evaluations of the physical condition of the liners, the interaction of wet resins with the liners, and the potential of gas generation within the resins, all of which could affect structural integrity of the liners.
Licensee representatives stated that the use of the liners for extended storage of the wet resins would be discussed with vendor representatives and reviewed against details provided in applicable vendor documents and the recommendations for long-term radwaste storage detailed in GL 81-38. The inspectors stated that the licensee evaluations and subsequent actions, as appropriate, regarding extended storage of the contaminated wet resins, would be identified as
Inspector Followup Item (IFI) 50-348, 364/97-10-03:
Review Licensee Evaluation for Extended Onsite Storage of Contaminated Wet Resin.
No concerns were noted for the offsite radiological environmental monitoring program (REMP) equipment.
For the environmental monitoring stations visited, thermoluminescent dosimeters (TLDs), surface water and air sampling equipment were verified to be in place, er operational and calibrated properly.
Technicians were knowledgeable of procedures and general Offsite Dose Calculation Manual (00CM) environmental monitoring requirements and specifications, and demonstrated proficiency in sample collection and processing.
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Conclusions Licensee oversight and controls for RP activities were effectively implemented.
Current REMP activities were in accordance with ODCP requirements and technicians displayed proficiency in conducting the field sampling program.
Licensee evaluations and subsequent actions regarding extended storage of contaminated wet resins were identified as IFl 50-348. 364/97-10-03:
Review Licensee Evaluation for Extended Onsite Storage of Contaminated Wet Resin, i
Rl.2 Radiodctive Waste and Material TransDortation Activities (86750.
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11251S/133)
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InsDec'ipn Stone I
The inspectors evaluated and discussed the licensee's current guidance for radwaste storage and for radioactive material and radwaste packaging and transportation activities.
The toilowing procedures were reviewed and discussed during the inspection:
FNP-0 RCP-811. Shipment of Radioactive Material " Revision e
(Rev.) 19. dated November 19. 1996 FNP 0-RCP-819. " Shipment of Radioactive Waste to Barnwell Burial e
Site." Rev. 29. dated Decenber 6.1996 Also, selected records associated with processing, packaging and shipping of radioactive material and waste to either vendor processing facilities or directly to a licensed burial facility were reviewed and evaluated against recently revised 10 CFR Part 20. 49 CFR Parts 100 through 179 and 10 CFR Part 71 regulations.
Copies of shipping records for the following transportation activities were reviewed and discussed in detail, Radwaste Shi) ment Number (No.) 96-02. Reportable Quantity (RQ)
e Radioactive iaterial. Low Specific Activity (LSA): N.0.S., 7:
UN-2912. Fissile Excepted, containing dewatered bead resin.
shipped October 10. 1996, Radioactive Material Shipment (RMS) No. 96-36. Radioactive e
Material. Surface Contaminated Object (SCO): N.O.S. 7: UN-2913.
contaminated steam generator equipment in strong tight containers, shipped December 5. 1996.
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RMS No.97-017 Radioactive Material. Low Specific Activity l
(LSA). N.0.S. 7: UN-2912. contaminated laundry, shipped March 21.
1997.
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e RMS No. 97-39, Radioactive Material. Surface Contaminated Object l
(SCO). N.O.S., 7: UN-2913: 14 strong tight metal boxes of contaminated reactor vessel ISI equipment; shipped April 17. 1997.
e RMS No. 97-57 Radioactive Material. LSA. N.0.S. 7: UN-2912.
contaminated laundry shipped May 14. 1997.
The inspectors noted that the packaging and shipping procedures relied 3rimarily on flow diagrams, shipping checklists. and individual worker (nowledge to identify applicable sections and requirements of 10 CFR
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Parts 20. 61, and 71. and 49 CFR Parts 100 through 179, to process and prepare each shipment. The current licensee guidance did not caution staff members regarding recent changes, i.e.. use of international system (SI) of units on shipping papers, but relied upon continuing training and each individual's knowledge of regulatory changes to ensure compliance.
From discussion of routine shipping activities with responsible people, the inspectors noted that workers appeared to be knowledgeable of the current applicable regulations.
From review of selected records, the inspectors noted that documentation for shipments made subsequent to April 1. 1997. did not meet the detailed r(quirements specified in 49 CFR 172.200.
Identi fied documentation errors included examples of failure to consecutively number shipping pages and failure to use the Sl of units for selected data entries.
Licensee representatives provided a preliminary copy of Occurrence Report (OR) No. 97-1035 which documented self-assessment findings including the failure to consecutively number shipping paper continuation pages and failure to use SI units for documenting radiation and contamination levels for shipments.
Licensee represmtatives noted that since identification of the identified issues, no shipments were made. The licensee also implemented a change to Health Physics Record Form 111 to verify proper use of SI units and page numbering for each shipment.
From discussion and review of licensee documents, the inspector verified that proper isotopes and their quantities, material volumes, and radiation and contamination survey results were used in determining transportation categories, shi > ping container types and waste classifications, as applicable, for t7e reviewed shipments.
From review of procedures, discussion, and review of training provided to responsible licensee representatives, the inspectors determined that the recent revisions to 49 CFR Parts 100 through 179. Department of Transportation (DOT) regulations were incorporated appropriately into the transportation program.
The identified issues resulted from personnel errors in implementing the revised DOT regulations.
The inspectors identified the failure to complete shipping paper documentation in accordance with 49 CFR 172.200 as a violation (VIO) of Enclosure 2
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10 CFR 71.5 requirements.
However, the inspectors noted that these failures constituted a V10 of minor safety significance and consistent with Section IV ct the kkC Enforcement Policy is identified as NCV 50 348. 364/97-10-04. Failure to Meet 49 CFR 172.200 Shipping Paper Documentation Details in Accordance with 10 CFR 71.5.
Review of selected processing and shipping data demonstrated effectiveness of licensee initiatives to reduce radwaste material.
Process rystns shipped for burial decreased from 1,168 cubic feet (ft')
to 243 ft from 1993 through 1996, respectively.
For the same review period,contamipateddryactivewaste(DAW)volumewasreducedfrom 1.186 to 520 ft sent for burial.
The reduction in resin volume was attributed to increased liquid waste volume processed per volume of media and the segregation of liquid waste streams to minimize processing.
For DAW material, selected initiatives included providing current information to workers regarding radwaste costs and effective reduction techniques. increased decontamination efforts, and increased use of reusable bags and containers.
c.
Conclusions Licensee guidance for implementing'49 CFR Parts 100 179 and 10 CFR Part 71 regulations was general in nature and dependent on extensive training of individuals.
NCV 50-348, 364/97-10-04 of 10 CFR 71.5 requirements for failure to meet 49 CFR 172,200 shipping paper documentation details was identified.
Radwaste volume reduction efforts for process resins and for contaminated DAW have been effective.
R1.3 Radiation Monitorina System Doerability and Desian (84750)
a.
Insoection Scone Radiation monitoring system (RMS) operability and design issues were reviewed and discussed during the insaection.
The inspectors reviewed and discussed Special Report 97-001, J1 Inoperable Radiation Monitor (RE)-60C (main steam relief and atmospheric steam dump discharge) status and reviewed July 14 through August 25, 1997, records regarding implementation of the applicable surveillances and compensatory sampling F
required by the TS action statement.
The inspectors discussed licensee-identified RMS concerns identified in OR 973094, dated July 28, 1997.
In particular. RMS configuration
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control and design issues and the potential affect on system operability were reviewed and discussed.
The inspectors reviewed the identified issues and corrective action, and subsequently walked down the RMS equipment for both units.
Field installed equipment was compared with selected configuration control drawings, where available.
Further the Enclosure 2
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installed equipment was evaluated against recommendations specified i1 American National Standards Institute (ANSI) N13.1-1969. American National Standard Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities.
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b.
Q._serva t i gn,5 The inspectors verified that for the inoperable U1 RE 60C monitor, surveillances verifying U1 Steam Jet Air Ejector (SJAE) monitor R-15A l
operability were conducted in accordance with the applicable procedures.
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Backu) samples were not required for the period reviewed based on
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opera)111ty of the SJAE monitor during the reviewed period.
The following specific issues and concerns regarding installation and construction of RMS sample lines to meet 10 CFR Part 50. Appendix B.
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Criterion V. and ANSI 13.1 recommendations were identified:
The installed sample line for the U1 backup post accident sampling o
systeru (PASS) plant vent particulate sampler (RE-68) was constructed using flexible stainless steel tubing rather than smooth pipe having minimum bend radii in accordance with drawing N-1-Dll(B79 554) dated February 23, 1984.
Further, observations determined that the inside of tha flexible tubing was corrugated.
Licensee representatives acknowledged that the corrugated surface potentially could affect air flow and result in a nonrepresentative distribution of particulates reaching the sample filter.
The inlet sample line for the U1 containment aurge exhaust system e
monitor (RE-69) was constructed of plastic tuaing.
Removal and subsequent gamma spectroscopy analysis of the sample line tubing identified particulate radionuclide contamination.
Although, no configuration control drarngs for this system were provided to the inspectors prior to the end of the onsite inspection, cognizant licensee representatives noted that the use of plastic tubing did not meet industry standards and, most likely, contributed to the deposition of the measured particulate radionuclides, For the U1 main plant vent particulate sampler (RE-29a). Drawing e
N-1-Dll-RE-29-E. Sheet 3. Rev 3. dated April 4.1997, specified
' filter unit furnished by APCo." The licensee identified that several feet of flexible tubing similar to tubing installed on the Ul RE-68 monitor also was used in construction of the inlet sample line for the U1 RE-29a plant vent particulate sampler.
Use of tubing having a corrugated inside surface could adversely affect the representativeness of particulate samples collected.
Enclosure 2 l
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The inspectors noted that licensee actions to evaluate properly, and to mitigate or correct the apparent sample line deficiencies were not timely. As of August 25. 1997 the inspectors noted that in addition to subsequent U1 and U2 RMS walk-downs, immediate corrective actions regarding the identified concerns consisted only of replacing the l
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damaged inlet RE-68 sample line sample tubing with identical flexible stainless steel tubing.
The licensee had not taken action to determine if the inlet line to the U1 RE 29a sampler was corrugated on the inside s'arfaces and continued to use the location for ODCM-required weekly U1 plant vent particulate samples.
In addition, although the U1 RE-29a samale line appeared similar in design to the im)royer tubing installed on J1 RE 68 inlet the licensee did not use the 'J1 Jackup plant vent sampling point (RE-29b) to complete ODCM-required weekly sampling.
Similar design concet ns were not identified for the same U2 sampling lines.
On August 27. 1997. licensee repre entatives stated that Deficiency Reports (DRs) were initiated to upgrade the RE-68 backup PASS plant vent and the RE 69 containment ) urge sample lines to recommended industry standards, in addition, t1e licensee initiated the collection of the U1 weekly plant vent particulate samples from the U1 RE-29b particulate sampler. The inspectors noted that the identified issues were contrary l
to acceptable industry practicos.
Further, the RE-68 sample line was installed contrary to an approved configuration control drawing and the details provided in Drawing N-1 011 RE-29-E. Sheet 3. Rev 3. dated April 4.1997 were inadequate to ensure proper installation of a proper inlet sample line for the U1 RE-29a particulate sampler.
These RMS sample issues were identified as violation (VIO) 50-348/97-10 05:
Inadequate Configuration Control of U1 RMS Particulate Sample Lines.
c.
C.pnclusions Surveillances for the inoperable U1 RE-60C monitor were completed in accordance with approved procedures.
Configuration control and design concerns for the RMS were identified as V10 50-348/97-10-05:
Inadequate Configuration Control of U1 RMS Particulate Sample Lines.
R2 Status of RP&C Facilities and Equipment (71750)
R2.1 Zinc Addition System (ZAS) Start-un On 16 August. 1997, inspectors observed the start-up of the U2 ZAS per FNP-2-CCP-335. " Zinc Addition System." Rev. 4.
Test personnel controlled the evolution carefully and kept the control room informed of the start-up process.
Initial startup was delayed at times due to some minor equipment problems and unexpected alarms.
The U2 Shift Supervisor (SS) was not familiar with the new computer alarms related to ZAS operation. System experts subsequently provided him with adequate Enclosure 2 j
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information concerning these new alarm points and the start-up was continued.
Inspectors monitored ZAS operation on several occasions and discussed system performance with responsible chemistry personnel.
On September 3. the J2 3rimary coolant concentration of dissolved zinc reached the establisled control band of 35 to 50 ) arts per billion ()pb). with a target value of 40 ppb.
Overall, t1e inspectors concluded tiat system start-u) was conducted in a slow, conservative manner with proper oversight.
3ut specific training for the Main Control Room (MCR)
operators on the new computer alarms associated with ZAS operation coulo have been better.
R3 Radiation Protection and Chemistry Documentation (83750, 84750, 86750)
R3.1 Radioloaical Effluent and Environmental Monitorina Renor11 a.
Insnection Scone Results of the 1995 and 1996 Annual REMP Reports required by TSs , 6.9.1.6 and 6.9.1.7 and submitted in accordance with the Section 7 of
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the ODCM were reviewed and discussed with licensee representatives.
Also reviewed were the results of the 1995 and 1996 Annual Radioactive Effluent Release Reports required by TSs 6.9.1.8 and 6.9.1.9.
In particular, the inspectors reviewed and discussed results of interlabratory comparisons, land use census, dose estimates, and program deviations.
b.
Observat',ans and Findinas The inspectors verified that the 1995 and 1996 REMP reports were 3repared and submitted in accordance with TS and ODCM specifications.
10 discernible offsite effect was demonstrated from plant discharges to the envi wns.
The inspectors verified that the licensee properly determined th9 controlling receptor to evaluate the maximum dose to a member of the oublic beyond the site boundary based on releases and current land use census data.
The inspectors reviewed and discussed deviations from the 1995 and 1996 REMP sampling program documented in accordance with ODCM Section 7.1.2. 4.
The inspectors noted two separate periods from May 18, 1987, through August 1. 1995, and again on December 27, 1995.
where surface water sampling did not meet the sample collection frequency specified in ODCM Table 4-1.
From review and discussion of the duration of initial sampling deviation, ie.
greater than eight years, the occurrence of the second event and applicable procedures, the ins)ectors noted that the sampling deviations resulted from the failure to lave appro)riate procedural guidance to ensure pro)er equipment operation.
T1e inspectors noted that the failure to lave adequate procedures to meet the surface water sampling requirements specified in ODCM Table 41 was a violation of TS 6.8.1.h.
During the onsite inspection, procedure FNP-0-Surveillance Test Procedure (STP)-793. River Enclosure 2
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Water Samples Rev.11. was revised to verify that an adequate number of composite samples and sample volumes are collected to prevent recurrence.
The inspectors noted that these failures constituted a violation of minor safety significance and, consistent with Section IV
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of the NRC Enforcement Policy, is identified as NCV 50-348,364/97 10 06:
Inadequate Procedures for Operation of Surface Water Samplers for ODCM Sampling Requirements.
- In addition, the 1995 and 1996 Annual Radioactive Effluent Release Reports were submitted in accordance with TS and ODCM requirements.
For both 1995 and 1996, calculated doses from effluent releases were less than one percent of the ODCM limits.
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Conclusions Licensee programs to control and document liquid and airborne radionuclide effluent releases were maintained and effectively implemented.
Projected offsite doses to the maximally exposed individual were well within the limiti specified in the ODCM and 40 CFR 190.
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In general, the REMP sampling, analysis and reporting requirements were
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effectively implemented and demonstrated minimal environmental impact from plant operations.
The failure to have adequate procedural guidance to ensure surface water composite sampler operation was identified as NCV 50-348,364/97-10 06:
Inadequate Procedures for Operation of Surface Water Samplers for ODCM Sampling Requirements.
R5 Radiation Protection and Chemistry Training (86750, TI 2515/133)
R5.1 Hazardous Material Trainina a.
Inspection Scone The inspectors reviewed and discussed initial and recurrent hazardous material (hazmat) training provided to personnel involved in packaging and preparing hazardous material for transport.
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Hazmat training content, frequency, and record keeping were evaluated against the requirements specified in 49 CFR Part 172 Subpart H.
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Observations and Findinas From review and discussion of selected vendor and licensee hazmat courses, the inspectors determined that appropriate topics to meet training requirements specified in 49 CFR 172.704 were presented.
From review of training material presented, the inspectors confirmed that recent DDT changes to shipping and packaging requirements were included in the training.
However. inconsistencies in maintaining hazmat training and test records we e identified.
For example, complete hazmat test records for one individual authorized to sign shipping papers were not entered in the current licensee training database system nor in the site training files.
However documentation was maintained by the individual.
Further. several individuals authorized to review and sign for radioactive material and waste shipments as listed in FNP-0 RCP 811 had not received hazmat training in accv dance with 49 CFR 172.700.
Review of January 1.1996, through August 25. 1997, shipment records verified that none of the untrained individuals had been responsible for oversight and final authorization of hazardous material shipments.
Licensee representatives stated that potential upgrades for the training department database were in preliminary review and that, at a minimum, actions to revise and upgrade the hazmat training and test files and licenset procedure FNP-0 RCP 811 would be initiated in a timely manner.
The inspectors identified this issue as IFl 50-348.364/97-10-07:
Review Licensee Actions to improve Maintenance of Hazmat Training and Testing Records, c.
Conclusions Appropriate hazmat training was provided to personnel handling and packaging radioactive materials for transport.
IFI 50-348. 364/97-10-07:
Review Licensee Actions to improve Maintenance of Hazmat Training and Testing Records, was identified to review inconsistencies in maintenance of Hazmat.
P3 Emergency Plan Procedures and Documentation P3.1 Fmeraency Eauinment and Supolies Checklist Verification On February 27, 1997, an emergency planning (EP) technician admitted to falsifying many of the EIP-16.0. " Emergency Equipment and Sup) lies."
checklists required to be accomplished on a routine basis.
Tle licensee's immediate corrective actions and resident inspector followup were documented in IR 50-348, 364/97-03.
Following the completion of an internal investigation, the EP technician's employment was terminated.
Furthermore, the site EP Coordinator provided each plant department manager with information to be used in briefing onsite employees regarding the specific incident, reinforcing the Southern Nuclear Enclosure 2 l
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Operating Com)any and NRC policy on falsification of data.
Inspectors interviewed t1e EP Coordinator regarding licensee corrective actions and reviewed the briefing materials provided to the department managers.
The NRC Of fice of Investigations also conducted an independent i
investigation of the circumstances involved.
Their conclusions were
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issued under a separate report.
S1 Conduct of Security and Safeguards Activities (71750)
l Sl.1 Routine Observations of Plant Security Measures During routine inspection activities, inspectors verified that portions l
of site security program plons were being properly implemented.
This was generally evidenced by:
proper display of picture badges by plant personnel: appropriate key carding of vital area doors: adequate stationing / tours in the protected area by security personnel: proper searching of packages / personnel at the primary access point and service water intake structure; and adequate maintenance of security systems.
Security personnel activities observed during the inspection period were performed well.
Site security systems were adequate to ensure physical protection of the plant.
S8 Miscellaneous Security and Safeguards Issues S8.1 IClosed) V10 50-364/96-13 06. Failure to Search Truck Trailer Prior to Entering the Protected Area By letter dated January 14. 1997 Southern Nuclear Operating Company provided a response to the violation describing its corrective actions.
Corrective Action Report (CAR) No. 2234 was initiated to accument and i
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track completion of these corrective actions, inspectors reviewed the licensee's letter and CAR package. and interviewed the Security Chief.
Inspectors also verified licensee that corrective actions were accomplished by reviewing FNP-0 SP-14. " Search and Seizure." Rev. 11.
and applicable training records.
The inspectors have observed the conduct of security force members in implementing the new SP-14 instructions during the last U1 outage.
Corrective actions by the Security department were thorough.
This V10 is closed.
F8 Miscellaneous Fire Protection Issues (92904)
F8.1 (Closed) URI 50-348/97-05-08. Installation of Half-hour Kaowool Fire Barriers Without Appendix R Exemption This URI was concerned with the installation of half-hour rated fire barriers (i.e.. one 1-inch wrap of Kaowool) around the B train
)ower cable trays (BDE-9 and BDE-15) and B train control cable tray (3HF-24)
for the high head safety injection pumps in fire area 1-004 room 160.
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instead of the one-hour rated barriers required by 10 CFR 50.
Appendix R.
Further reviews by the inspectors and licensee staff have Enclosure 2
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not identified any additional information nor a specific Appendix R exemption request for these installations.
Cable trays BDE-9 and BDE 15 are clearly identified in UFSAR. Appenc,x 9B. Fire Protection Program, as requiring two 1 inch thick layers of Kaowool (i.e., the equivalent of a 1-hour barrier).
UFSAR Appendix 9B.
Attachment B. Section 21.3 states that "the redundant charging pump
)ower cables are provided with a barrier (two 1-inch thick wraps of (aowool blanket) laving a fire rating greater than that of the projected
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fire in the following rooms in fire area 1-004:
train A in rooms 161.
162. 163, and 168: train B in rooms 175. 160. and 159." There was no such statement specifically for BHF-24.
This URI is being upgraded into a violation of License Condition 2.C(4) and is identified as VIO 50 348/97-10 08. Installation of Half-hour Kaowool Fire Barriers Without Appendix R Exemption.
Based on this action this URI is closed.
V. Manaaement Meetinas and Other Are g X1 Review of Updated Final Safety Analysis Report Commitments A recent discovery of a licensee o)erating its facility in a manner contrary to the UFSAR description lighlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR descriptions.
While performing the inspections discussed in this re> ort, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected.
The inspectors verified that the UFSAR wording was consistent with the observed plant practices. procedures and/or parameters, except for the use of fire barriers which was not consistent with UFSAR. Appendix 98.
Fire Protection Program (3ee Section F8.1).
X2 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management on September 9,1997, after the end of the inspection period.
The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
Enclosure 2
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PARTIAL LIST OF PERSONS CONTACTED Licensee R. Badham. Safety Audit and Engineering Review (SAER) Supervisor W. Bavne. Chemistry Superintendent R. Coleman Maintenance Manager S. Fulmer. Technical Manager D. Graves. Health Physics Supervisor D. Grissette. Operations Manager P. Harlos. Plant Health Physicist C. Hillman. Security Chief M. Mitchell. Health Physics Superintendent R. Martin. Operations Support Superintendent R. Monk. Engineering Support Supervisor C. Nesbitt. Assistant General Manager. Plant Support B. Patton. Senior Technical Specialist. Safety Audit and Engineering Review (SAER)
M. Stinson. Assistant General Manager. Operations J. Thomas. Engineering Support Manager J. Walden. Technical Training. Senior Instructor G. Waymire Plant Administration Manager P. Webb. Technical Training Supervisor NRC J. Zimmerman. NRR Project Manager INSPECTION PROCEDURES (IP) USED IP 37551:
Onsite Engineering IP 40500:
Effectiveness of Licensee Controls in Identifying. Resolving, and Preventing Problems IP 61726:
Surveillance Observations IP 62707:
Maintenance Observations IP 71707:
Plant Operations IP 71750:
Plant Support Activities IP 83750:
Occupational Radiation Exposure IP 84750:
Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 86750:
Solid Radioactive Waste Management and Trar;portation of Radioactive Materials IP 90712:
In-Office Review of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92902:
Followup - Maintenance IP 92903:
Followup - Engineering IP 92904:
Followup - Plant Support T12515/133 Implementation of Revised 49 CFR Parts 100-170 and 10 CFR Part 71 Enclosure 2
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ITEMS OPENED, CLOSED, AND DISCUSSED 00fDad l
Iypa Item Numbqt Status Descriotion and Reference
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NCV 50 348, 364/97-10-01 Open lack of Attention and Unclear Procedural Guidance for Addressing l
Primary Coolant Leaks Outside l
Containment (Section M2.1)
IFI 50-358. 364/97-10-02 Open UFSAR Reverification Corrective Actions (Section E7.1)
IFl 50 348. 364/97-10 03 Open Review Licensee Evaluation for Extended Onsite Storage of
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Contaminated Wet Resin (Section R1.1).
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NCV 50 348, 364/97-10-04 Open Failure to Meet 49 CFR 172.200 Shipping Paper Documentation Details in Accordance with 10 ",FR 71.5 (Section R1.2).
VIO 50-348/97-10-05 Open inadequate Configuration Control of U1 RMS Particulate Sample Lines (Section R1.3)
NCV 50-348, 364/97-10-06 Open Inadequate Procedures for Operation of Surface Water Samplers for ODCM Sampling Requirements (Section R3.1)
IFI 50 348, 364/97-10-07 Open R Niew Licensee Actions to improve Maintenance of Hazmat Training and
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Test Records (Section R5.1)
VIO 50-348/97-10-08 Open Installation Of Half-hour Kaowool Fire Barriers Without Appendix R Exemption (Section F8.1)
Closed Iyp3 Item Number Status Description and Reference NCV 50 348, 364/97-10-01 Closed Lack of Attention and Unclear Procedural Guidance for Addressing Primary Coolant Leaks Outside Containment (Section M8.5)
Enclosure 2
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IFI 50-348. 356/96-06-03 Closed EDG Reliability Problems Associated With End of-Life Hxs (Section M8.1)
LER 50-348/96-03 Closed Actuation of Engineered Safety Feature Equipment Due to an Apparent
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Relay Contact Failure (Section M8.2)
URI 50 348. 364/97-05-04 Closed EDG 50% Load Rejection Surveillance Testing (Section M8.3)
URI 50-348. 364/97-08 04 Closed Primary Coolant Leakage Dutside Containment (Section M2.1)
V10 50-348, 364/96-13 06 Closed Failure to Search Truck Trailer Prior to Entering the Protected Area (Section 58.1)
NCV 50-348, 364/97-10-04 Closed Failure to Meet 49 CFR 172,200 Shipping Paper Documentation Details in Accordance with 10 CFR 71.5 (Section R1.2)
NCV 50 348. 364/97-10 06 Closed inadequate Procedures for Operation of Surface Water Samplers for ODCM Sampling Requirements (Section R3.1)
URI 50-348/97-05-08 Closed Installation Of Half-hour Kaowool Fire Barriers Without Appendix R Exemption (Section F8.1)
Enclosure 2
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