IR 05000424/1997007
ML20210S060 | |
Person / Time | |
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Site: | Vogtle ![]() |
Issue date: | 08/28/1997 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20210S052 | List: |
References | |
50-424-97-07, 50-424-97-7, 50-425-97-07, 50-425-97-7, NUDOCS 9709040377 | |
Download: ML20210S060 (26) | |
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U. S. NUCLEAR REGULATORY COMMISSION (NRC)
REGION 11
Docket Nos. 50-424 and 50-425 License Nos. NPF-68 and NPF-81 Report No:
50-424/97-07, 50-425/97-07 Licensee:
Southern Nuclear Operating Company, Inc.
Facility:
Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Location:
7821 River Road
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Waynesboro, GA 30830 Dates:
July 6 through August 2. 1997 Inspectors:
C. Ogle, Senior Resident Inspector M. Widmann. Resident Inspector K. O'Donohue. Resident Inspector (in training)
P. Harmon. License Examiner (05.1 - 05.3)
G. Kuzo. Health Protection Inspector (R1.1 - R8.1)
L. Stratton Safeguards Inspector (Section S2.1)
Approved by:
P. Skinner. Chief Reactor Projects Branch 2 Division of Reactor Projects Enclosure 2
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9709040377 970828 PDR ADOCK 05000424 G
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EXECUTIVE SUMMARY Vogtle Electric Generating Plant Units 1 and 2 NRC Inspection Report 50-424/97-07, 50-425/97-07 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support.
The report covers a four-week period of resident inspection.
It also includes the results of announced inspections by a regional operator license examiner, health physics inspector, and a safeguards inspector.
Operations In general, the conduct of operations was professional and
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safety-conscious (Section 01.1).
A violation was identified for entry into the incorrect action condition
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during maintenance on the Unit 1 airlock (Section 02.2).
A poor practice was identified for attempting to start the auxiliary
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building supply fan number 1 with limited troubleshooting guidance (Section 03.2).
The Requalification Program was adequate to ensure that licensed
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operators are trained to operate the facility safely (Section 05.1).
A program weakness was identified in the documentation of individual
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performance during simulator operating examinations (Section 05.2).
The Written Examination was considered discriminating and valid, and
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closely followed the examination plan (Section 05.3).
The Operating Examination was considered to be marginally adequate due
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to a low discrimination level in the dynamic simulator scenarios and in Job Performance Measures (Section 05.3).
Plant Review Board (PRB) discussions were thorough and appropriately
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focused on safety (Section 07.1).
Maintenance Maintenance and surveillance activities were generally completed i
e thoroughly and professionally (Section M1.1 and M1.2).
Enaineerina A non-cited violation was identified for the improper storage of a
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monorail beam immediately adjacent to centrifugal charging pump 2A (Section E8.2).
Enclosure 2
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Plant Support Radiation and contamination controls for radwaste processing and storage
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areas, and chemistry laboratory operations were appropriate and in accordance with TS and 10 CFR Part 20 requirements (Paragraph R1.1).
Doses to workers resulting from contamination events were evaluated
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properly, and were within limits and recorded in accordance with 10 CFR Part 20 requirements (Section R1.2).
Licensee guidance and training incorporated recently revised
49 CFR Parts 100-179 and 10 CFR Part 71 regul6tions (Section R1.3).
A non-cited violation was identified for failure to meet 49 CFR 172.200
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shipping paper documentation details in accordance with 10 CFR 71.5 requirements (Section R1.3).
The primary and secondary coolant chemistry programs were managed and
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implemented effer.tively (Section R1.4).
Chemistry and HP self-assessments were performance based with no
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programmatic issues identified.
Identified issues were tracked by licensee representatives and resolved appropriately. (Section R1.4).
In general, licensee OC primary and secondary OC activities verified
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accuracy of analytical measurements (Section R7.2).
One Inspector Followup Item was identified to review licensee actions to
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improve chemistry QC data trending and Anomaly Report issuance (Section R7.2).
A non-cited violation was identified for failure to conduct Containment
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High Range Monitor calibrations in accordance with NUREG 0737 Table II.F.1-3 as specified in Final Safety Analysis Report Section 7 (Section R8.1).
A violation was identified for failure to take proper compensatory
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action in response to a degraded vital area barrier (Section S2.1).
Enclosure 2
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Reoort Details Summary of Plant Status
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Unit 1 The unit began the inspection period at 100% power.
On July 7. power was reduced to supprt condenser water box maintenance.
On July 8. power was stabilized at 80% power. At the completion of maintenance activities, on July-8. 100% reactor power was achieved.
The unit operated at full power for the remainder of the inspection period.
Unit-2 The unit operated at full power throughout the inspection period.
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OoeratioDS
Conduct of Operations 01.1 General Comments (71707)
Using Inspection Procedure 71707. the inspectors conducted frequent reviews of ongoing plant operations.
In general, the reviews indicated that the conduct of operations was professional and safety conscious.
Operational Status of Facilities and Equipment 02.1 Safety-Related Walkdowns a.
Insoection Scooe (7170]l The inspectors walked down Diesel Generator ESF Heating Ventilation and Air Conditioning (HVAC) systems for Units 1 and 2 as part of the routine inspection effort to verify availability and overall condition of the systems, b'.
Observations and findinas The ins)ectors verified proper system configurations both electrically and mec1anically for the above ESF systems through accessible portions in the plant, a walk down of main control room boards, and a review of system drawings and plant lineup procedures.
The inspectors also observed overall material condition of system components during the walk downs.
Enclosure 2 l
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Conclusions The inspectors concluded that the systems reviewed were available to aerform their design function and that systems were properly aligned.
io discrepancies were noted during these inspections.
02.2 Documentation Associated With Att ock Maintenance l
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Insoection Scooe (71707F The ins)ectors reviewed the licensee's actions associated with repairs to the Jnit 1 containment airlock on July 8.1997. The inspectors reviewed Technical Saecification (TS) 3.6.2. Containment Airlocks:
precedure 24905-C. "3ersonnel Air Lock Leak Rate Test." Revision 12:
procedure 25236-C. " Personnel Airlock Maintenance," Revision 10:
3rocedure 10008-C. " Recording Limiting Conditions for Operations."
Revision 19: the Unit Shift Supervisor (USS) Log: and Limiting Condition for Operation / Technical Recuirements (LC0/TR) Status Sheets.
The-inspectors also interviewec selected operations personnel regarding this issue.
b, Observations and Findings
=On July 8. 1997. maintenance personnel had disassembled and reassembled-the shaft seal assembly on the inner airlock bulkhead, associated with the inner door operating mechanism.
Log entries indicated that the repairs started at approximately 1:40 p.m.-and had finished for the day at 3:25 o.m, lhe ;nspectors were informed that the shaft seal assembly leakage h3d not been determined following the reassembly. The licensee--
also indicated that additional repairs to this seal were planned _for July 9.=1997.
Procedure 10008-C requires documentation of entry into an LC0 acticq statement which will continue past a shift turnover.
After shift turnover. the inspectors noted that the licensee had documented entry into Action Condition "A" of TS LC0 3.6.2 as opposed to Action Condition
"C."
Action Condition "A" provides required actions in the event that
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an air lock door is rendered inoperable. Action Condition."C" applies when an airlock is rendered inoperable for reasons other than Condition A or 8 [ interlock mechanism).
The inspectors determined that since the repairs were not made to the inner door, entry into Action Condition "C" was more appropriate.
Following discussions with the Operations Manager and Shift Superintendent, the licensee commenced repairs to the shaft seal that evening.
During additional reviews, the inspectors determined that-the airlock was restored to service on July 9.1997, prior to the expiration of the Action Statement "C" time limits. At approximately 5:00 a.m. on July 9.1997, the licensee also documented entry into Action Statement
"C" retroactive to the start of the initial shaft seal' maintenance.
Enclosure 2
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c.
Conclusion The initial failure to document entry into nction Condition "C" was contrary to the requirements of procedure 10008-C.
This is identified as Violation (VIO) 50-424/97-07-01. Failure To Document Entry Into Proper Action Condition Following Airlock Maintenance.
02.3 Containment Penetrat)ons Walkdown a.
Inspection Scone (71707)
The inspectors walked down accessible portions of the following containment penetrations to verify proper valve lineups:
Penetratign Unit Title
1.2 Boron Injection Line to Cold Leg
1.2 Residual Heat Removal (RHR) Pump Discharge to Hot Leg b.
Observations and Findinas Proper valve lineups were observed for all penetrations, c.
Conclusion No discrepancies were identified.
Operations Procedures and Documentation 03.1 Walkdown of C harances (71707)
During the inspection period, the inspectors walked down the following clearances:
19700542 Control room HVAC filter units - planned outage 19700554 Diesel oil storage tank pump #2 b.
Observations and Findinos The inspectors did not identify any problems during these walkdowns.
Enclosure 2
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.03.2 Slave State protection System Slave Relav K614 a.
Insnection Scone (71707)
The inspectors reviewed a performance anomaly (slower than expected operation) of the auxiliary building supply fan number 1 during the 3erformance of procedure 14655-2. " Solid State Protection System Slave Relay K614 Train B Containment Ventilation Isolation." Revision 4 on July 14. 1997. The inspectors reviewed maintenance work order 2971673:
electrical drawing 1-1551-A7-001-M01, elementary diagram auxiliary i
building outside air supply and normal HVAC system: deficiency card (DC)
2-97-195: the Unit 2 Control Room Reactor Operator and Shift Supervisor log entries; and Institute of Electrical and Electronics Engineers.-Inc.
(IEEE) Std 383-1977 " Standard Criteria for Periodic Testing."
Operations and maintenance personnel were also interviewed.
b.
Observations and Findinas On July 14. 1997. operations personnel performed arocedure 14655-2.
This procedure tests safety related slave relay (614. to satisfy portions of the surveillances in TS 3.3.2. 3.3.6 and 3.7.13.
Both safety related and non-safety related components of the auxiliary building normal ventilation and piping penetration ventilation area filtration and exhaust systems are actuated during this surveillance.
During the performance of the test, an operator noted that auxiliary building supply fan number 1. a non-safety related component, did not immediately trip as expected.
Instead, the fan tripped approximately three minutes after the relay actuation. The licensee stated that all other components repositioned as expected.
During troubleshooting efforts, after reviewing the fan control circuit, the control room operators attempted to restart the auxiliary building supply fan number 1 with the K614 relay still energized.
The fan did not start and an amber trouble-light was received at the control handswitch for the fan.
The inspectors were informed that this activity was accomplished to determine the state of the K614 relay contact in the fan control circuit.
The initial surveillance was signed and logged as completed satisfactory with comments about the fan stopping after approximately 3 minutes.
0)erations aersonnel then performed procedure 14655-2 a second time.
T11s time t1e auxiliary building supply fan number 1 tripped immediately, as expected.
The surveillance was again signed off as completed satisfactorily. The surveillance traveler, used to document accomplishment of the surveillance for TS tracking, was also signed.
A DC 2-97-195 was written addressing the failure of auxiliary building supply fan number 1 to stop immediately during the first performance of procedure 14655-2. in addition, a work order was written.
Enclosure 2 Y
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The inspectors discussed with licensee management that the inspectors'
review identified that no procedure or other written instruction existed directing the attempted restart of the auxiliary building supply fan number 1.
Another point was that the failure of the fan to restart during this troubleshooting effort provided limited information (i.e.,
the existing state of the K614 contact in the fan control circuit: it did not provide any information on why the 3-minute delay in fan operation occurred).
Management was aggressivt in their efforts regarding this issue the follcwing day. Additional extensive troubleshooting was performed but failed to reveal the cause of the delayed operation. The licensee indicated that they are currently enhancing their procedures regarding troubleshooting, c.
Conclusions Attempting to start the auxiliary building supply fan number 1 with limited troubleshooting guidance was identified as a poor practice.
Operator Training and Qualification (71001)
The inspectors assessed the licensee's Requalification Program using NRC Inspection Procedure 71001, " Licensed Operator Requalification Program."
The inspectors visited the facility during the week of July 14-18, and on July 29 and 30. 1997, to further evaluate this aspect of the program.
During the second visit to the facility, the inspectors determined that operating tests were documented in an adequate manner, but identified a program weakness in this area (Saction 05.2). A second Exit Interview was conducted on July 30 with members of licensee management.
05.1 Review of Facility Operating History a.
Insoection Scoce The inspectors reviewed the licensee's operating history using Licensee Event Re) orts (LERs), NRC' inspection reports, and the Plant Integration Matrix (31M).
The inspectors also reviewed the licensee's feedback mechanisms to determine whether deficiencies below the threshold for generation of an LER or a Notice of Violation were adequately addressed by the training program, b.
Qb.servations and Findinos The plant's operating history did not indicate that operator training was a factor in identified performance issues. A concern involving operator performance has been the continued mispositioning of valves and incorrect equipment operation.
Root cause analysis )erformed by the licensee concluded that training deficiencies or wea(nesses were not involved in this area.
Enclosure 2 l
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The inspectors reviewed lesson plans derived from two LER-identified performance issues.
The inspectors determined that minor deficiencies received adequate notice and response by the training program.
Specifically. Management Observation forms, particularly from the 0)eration Department, provided direct feedback to the training program.
T1e inspectors: reviewed lesson plans developed and presented to the operations personnel to address specific deficiencies identified by this method.
Independent assessment of the Requalification Training Program was provided-by the licensee's Quality Assurance Program. Audits conducted in August 1996, and July 1997 concluded that the program was adecuately.
implemented.
Minor deficiencies identified in the 1996 audit hac been addressed and corrected.
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Conclusions The requalification program provided a mechanism for identifying areas
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of operator performance problems. The identified deficiencies were addressed by appropriate changes in the training curriculum.
05.2 Simulator Evaluation a.
Insoection Scong The inspector reviewed the licensee's-evaluation for the dynamic
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simulator examinations on July 15 and July 29.
The crew consisted of five licensed operators in the Balance of Plant Operator (RO). position of Reactor Operator' (RO).
Extra or Common Operator (RO). Shift Supervisor (SRO) and Unit Shift Supervisor (SRO).
The licensee evaluators consisted of three training staff and one management-representative.
b.
Observations and Findinas Dynamic simulator evaluations were conducted in accordance with plant procedure 60007-C. " Licensed Operator Requalification Examination Guidelines." Revision 3.
This procedure re (section 6.4), and Individual evaluations (quired Crew evaluations section 6.5) during the-operating test. The licensee recorded only the results of Crew competencies unless performance deficiencies were noted.
Data sheet 7.
" Team Evaluation Summary." was the. record for performance and documented grades as (Satisfactory / Unsatisfactory) for six separate crew competencies matrixed by individuals.
Comments or observations concerning.an individual were not recorded except for those operators identified as having deficiencies.
The individual evaluations recorded performance in eight competencies or categories.
Enclosure 2
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During the week of July 14. the inspectors observed two dynamic simulator exercises administered to a single crew, and attended the post-examination critique (debrief) presented to the crew by the evaluators. The inspector observed several instances of communications by the individual operators which did not meet the requirements of the licensee's communications standard, procedure number 00004-C. " Plant Communications." The standard required the use of repeat backs and verification that the message was 3roperly received (three-part communications).
The inspectors oaserved that each of the operators exhit'ited several deficiencies in performing communications in accordance with the established site standards.
However, since there were no instances where communications caused a crew critical task to be missed, the licensee evaluators marked all operators as " Satisfactory" for the Communications competency. A satisfactory mark with no comments implied that there were no deficiencies.
Therefore, there were no requirements to document comments or observations in the evaluation records.
The licensee's evaluators * critique did not develop the specific instances of improper or incom)lete communications, but generalized that communications should ae improved.
The simulator examination documentation evaluations did not address improper communications. The lack of individual evaluations failed to provide direct. objective feedback to the concerned operators.
The evaluation process took approximately 15 minutes followed by a debrief of the crew, which lasted approximately 10 minutes.
The inspectors noted marked improvement in communications by crew members during the scenarios performed on July 29.
The evaluation process for the crew evaluated the morning of July 29 took.approximately 1-3/4 hours. The evaluators explained that this evaluation took longer
than the previous evaluations due to an observed deficiency which
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required further analysis and discussion by the evaluators.
j During the scenario a crew critical task, emergency borating in excess of 30 gpm, was not performed satisfactorily.
The operator had allowed the flow rate to drift slightly below 30 gpm to approximately 28 gpm for several minutes.
The evaluators discussed whether the 30 g)m minimum limit constituted a true limit below which the task should )e considered as failed. After deciding to mark the operator competency
" Unsatisfactory" in the area of system response, the evaluators agreed to evaluate the task further.
The inspectors found that the scenarios were not designed to ensure that neither the Common R0 nor the Shift Suaervisor were sufficiently challenged in all competency areas. T1ese individuals provided oversight or supported the three individuals directly concerned with shift duties and, as a result, there was little opportunity to evaluate those individuals.
The licensee stated that these individuals are rotated to one of the more actively involved positions on one of the two scenarios, allowing ample opportunity for evaluation.
Enclosure 2
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The simulator scenarios were written to test crew competency.
There was no systematic process to construct the scenarios to ensure that each of the crew positions could be evaluated to demonstrate competency in each evaluation category.
This could result in an individual receiving an incomplete evaluation.
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Conclusions The Requalification Program adequately evaluated licensed crews and operators during the dynamic simulator portion of the operating tests.
However, the program only required individual evaluation comments and observations to be recorded in instances where deficiencies were associated with a crew critical task. This process discriminates against recording (and tracking and trending) individual performance deficiencies below the level which would cause an " Unsatisfactory" competency rating.
The process of evaluating and documenting competencies was not effective in identifying deficiencies below the threshold which causes a critical crew task to be missed. When individual mistakes were identified, developed, and presented at the criticues, documentation of those deficiencies were not developed to aic in trending.
This precluded identification of weaknesses or inadequacies until a critical failure occurred.
The combination of crew-oriented simulator scenarios and weaknesses in evaluation and documentation could result in an individual not being thoroughly and objectively evaluated, and does-not provide the feedback to properly implement the Systems Approach To Training (SAT).
A program weakness was identified in the documentation of individual performance during simulator operating examinations.
Documentation-did not include specifics of. minor-deficiencies, nor details that ensured that all relevant competencies are evaluated for each individual.
05.3 Examination Develcoment a.
Insoection Scope The ins)ector reviewed the written examination administered to two R0s and eig1t SR0s on June 12, 1997.
The examinations consisted of-25.
. questions, and administered with plant reference materials available.
-.The inspectors audited two dynamic simulator (DS) scenarios (2Z and 3Y),
administered to two R0s and two SR0s in one crew on July 15. 1997.
The inspectors also witnessed DS 11 and DS 33 administered July 29.
On July 16. the inspector accompanied the licensee evaluator who administered three simulator and four in-plant Job Performance Measures (JPMs) to a single SRO.
The seven JPMs constituted a single " set."
Enclosure 2 l
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The inspector did not attend any sessions involving static simulator evaluations.
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Observations and Findinas The written examinations were satisfactory and tested on the appropriate level of comprehension and analysis.
The examination items closely followed the sample plan. There were no instances of " direct look-up" identified.
All failed individuals were remediated.
The JPM set contained two JPMs which were not complex enough to demonstrate an understanding of the operation being performed due to their simplistic nature. JPM RQ-JP-23101-002-01. " Place Control Room HVAC in Smoke Purae Mode." only required locating the appropriate control room Janel, and aligning two switches identified in the
)rocedure.
J)M RQ-JP-60322-001-01. " Establish SFP Feed Path Following
_oss of CCW." only required the operator to locate and manipulate two valves.
The remaining JPMs were appropriately discriminating, and constituted a minimally adequate examination tool.
One individual failed a JPM set.
The failed individual was remediated.
The simulator scenarios met the minimum standards for demonstrating operator competency.
Scenario DS #13Y contained only two events that effectively challenged the crew: " Charging Flow Control valve FV 121 Fails Closed", and a " Steam Generator Tube Rupture" complicated by a loss of a single Auxiliary Feedwater (AFW) pump. The scenario's single required instrument failure. " Turbine : Impulse Channel Failure." did not initiate a transient requiring action by an operator.
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failure only disabled the Steam Dumfs arming circuit.
This only required that the operator select tle Steam Dump Control to " Steam Pressure-Mode" to allow the system to respond to any future load reduction transients. Another scenario event. " Failure of the Safety
' Injection System to Automatically Actuate." was addressed by activating a manual actuation switch. This problem involved fairly simple
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recognition and response. Another weakness in the developed scenario involved the lack of a challenging malfunction after entering the E0P.
There was a malfunction. but the malfunction did not create a condition which influenced the operators' choice of mitigation strategy.
An E0P transition was not required.
In effect, the exercise did not provide an opportunity to evaluate the crew's ability to determine which mitigation strategy should be used, which E0P should be used, or to transition between E0Ps.
Since the dynamic simulator evaluation was biased toward crew evaluations, scenarios were not developed with a full consideration of ensuring that the Shift Supervisor and Common RO receive challenges which were adequate to fully evaluate them while in that position.
This required careful consideration in rotating assignments and full documentation of how those competencies are observed.
The inspectors considered the dynamic simulator scenarios deve'oped as part of the Enclosure 2
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operating examination to be minimally adequate.
No crew critical tasks were failed, Four R0, three shift SRO, and 2 Staff SR0 individual failures were identified and remediated.
c.
Cta.clusions The written portion of the Requalification examination was considered discriminating and valid.
The JPH set observed by the inspector contained examples of JPMs that were not sufficiently discriminating to ensure that individuals with performance deficiencies could be identified.
The JPM portion of the examination was considered minimally adequate, but did not contain a high level of difficulty or discrimination.
The simulator scenarios were considered minimally adequate, but did not contain a high level of difficulty or discrimination.
Each scenario was not fully developed to adequately evaluate each crew member's competency, but together they were adequate as long as rotation of assignments between scenarios was carefully controlled.
Quality Assurance in Operations 07.1 Plant Review Board (PRB) Meetinas (40500)
The inspectors attended PRB meetings on July 8 and 11, 1997.
The meeting on July 8 was a normally scheduled PRB and the majority of the items discussed were routine in nature, included in the July 8 PRB meeting was a review of an NRC question regarding lowering the pressurizer safety valve setooint and the resultant effect on the plant analysis concerning bulk boiling.
The meeting of July 8 also discussed the licensee's proposed response to inspection report violations 50-424, 425/97-05-01 and 50-424, 425/97-05-02, concerning the unexpected behavior of the Unit 2 containment sump level transmitter and the appropriate LCO entered by the USS.
The-PRB discussions were thorough and appropriately focused on safety.
In particular, ine inspectors noted that questions raised by the PRB enhanced the quality of the reviews.
Enclosure 2
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Maintenance M1 Conduct of Maintenance M1.1 Maintenance Work Order Observations
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Insoection Scoce (62707)
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The. inspectors observed portions of maintenance activities involving the following work orders:
196015B6 Heater contact cutoff switch verification of proper installation on control room heating, ventilating and air conditioning (HVAC) filter unit 19602419 Inspect / lube air filter air handling unit 11531N7001M01 19702189 Spent fuel pool skimmer pump replacement 29502715 Auxiliary feedwater heat trace troubleshoot
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29701262 Motor driven auxiliary feedwater (MDAFW) discharge to steam generator number 2 29701673 Auxiliary building sup)ly fan 29701735 Replace handswitch on )oron thermal regenerative system 29701802 Changeout power supply on 2RE12444: plant vent radiation monitor b,
Observations and Findinas The observed maintenance activities were satisfactorily performed.
M1.2 Surveillance Observation a.
Insnection Scone (61726)
The inspectors observed the performance or reviewed the following surveillances and plant procedures:
14415-C Fuel handling building post accident ventilation actuation logic test 14546-2 Turbine driven auxiliary feedwater pump operability test 14805-1 Residual heat removal inservice test (IST) and response time test 14809-2 Engineered safety feature chill water pump IST b.
Observations and Findinas The observed surveillance activities were satisfactorily performed.
Enclosure 2
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Enaineerina E3 Engineering Procedures and Documentation (37551)
E3.1 h stina of Containment Soray (CS) Pumo Loaic The inspectors reviewed the licensee's disposition of Deficiency Card (DC) 1-97-311.
This DC was generated to address potential shortcomings in the surveillance testing of the CS Jumps identified during the licensee's review pursuant to Generic _etter (GL) 96-01. " Testing of Safety-Related Logic Circuits." dated January 10, 1996.
The DC documented several sequencer contacts in the CS pump control circuit e
which were not tested by the licensee, These contacts represented supplemental starting times after the first sequencer starting time for the pumps, The inspectors reviewed documentation provided by the licensee which documented that these contacts were not required and that there was no
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impact in terms of the licensee's accident analysis.
No additional followup is planned, j
i E8 Miscellaneous Engineering Issues (37551)
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E8.1 (Closed) Unresolved Item (URI) 50-424/95 27-02: Adequacy of Nuclear Service Cooling Water (NSCW) Valve as Closed System Isolation Valve Following additional review of this issue in response to Task Interface Agreement (TIA) 96-05, this item is closed.
E8.2 (Closed) URI 50-425/97-06-01:
Monorail Beam Stored On 2A Centrifugal
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Charging Pump (CCP)-Bedplate,
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Insoection Scoce This item documented inspectors' concerns associated with the July 3, 1997, identification of a portion of the overhead monorail beam placed
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in close proximity to the CCP 2A motor.
The inspectors reviewed procedure 00352-C " Control of In-Process Materials " Revision 6. the resulting DC, and an engineering evaluation of the as found condition, b. 10bservations and Findinos The beam was documented as being returned to its storage location shortly after the inspectors * observation.
Tha inspectors independently confirmed that the beam was removed from the motor area during a later tour of the auxiliary building. The licensee's review of the event failed to conclusively determine how the beam came to be placed by the motor.
Enclosure 2
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The engineering evaluation concluded that the CCP remained operable with the beam in its as-found condition.
The inspectors reviewed the b sis-for this-conclusion and found it to be adequate.
Procedure 00352-C required actions-to protect against damage to safety-related equipment during seismic events.
The procedure requires an engineering evaluation or restraint / separation of equipment stored adjacent to safety-related equipment.
The licensee was unable to provide documentation that the observed beam location was previously
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Likewise, the separation of the beam did not meet the restraint / separation requirements of procedure 00352 C.
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Conclusion Storage of the monorail beam in close proximity to CCP 2A was contrary to the requirements of procedure 00352-C.
However, consistent with Section IV of the NRC Enforcement Policy this was identified as Non-Cited Violation (NCV) 50-425/97-07-02, Improper Storage of Monorail Beam Adjacent to CCP 2A Motor. Based on this action, URI 50-425/97-06-01 is closed, E8.3 (Closed) URI 50-424. 425/97-06 02: Testing of Parallel Circuits For Main Steam isolation Valves (MSIVs)
This issue documented a potential-deficiency in the testing of MSIV circuits identified during a review conducted pursuant to GL 96-01.
Based on a review of the MSIV electrical circuit design, the ins determined that each valve handswitch (1/2-3007-A and 1/2-30078)pectors contains two redundant parallel control circuits that close four MSIVs (a total of eight valves per unit).
However, a review of system design requirements indicated no requirement to have redundant circuits for closure of the MSIVs. Technical Specifications (TSs) required that the MSIVs close within a specified time and do not consider the method by which they close.
However, as a result of this issue the licensee plans to revise procedure 14240-1, " Manual Trip Actuation Device Operability Test (TAD 0T)." Revision 1 and procedure 14240-2, " Manual Steamline
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Isolation," Revision 2.
Based on this review, the inspectors concluded that the licensee's actions are appropriate, This item is closed.
E8.4 Unclanned/Unmonitored Release from Unit 1 Eauioment Buildina On July 28. 1997, an unplanned /unmonitored release from the Unit 1 equiament building occurred.
The release was due to an opening in the fan 3elt housing of the containment mini-purge exhaust system.
Due to sampling being performed on the volume control tank, elevated levels of Enclosure 2
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activity were present in the plant ventilation ductwork.
The mini-purge system exhausts to the plant ventilation.
However, due to system operation with positive pressure and a resultant back flow through the plant ductwork, the activity was released at the mini-purge fan opening.
This-release was recognized by thz licensee as a result of an alarm on a portable monitor located inside the equipment building. A release permit was subsequently generated as a result of this event.
This issue is identified as inspection Followu) Item (IFI) 50-424/97-07-03. Unplanned /Unmonitored Release from Unit 1 Equipment Building.
IV.
Plant Suppott R1 Radiological Protection and Chemistry Controls R1.1 Radioloqical Controls a.
Insoection Scone (83750. 84750. 86750)
Radiological controls associated with radwaste processing and storage areas, and primary chemistry laboratory facilities were reviewed and evaluated by the inspectors.
The reviewed controls included area
)ostings, radioactive waste (radwaste) and material container labels.
ligh and locked-high radiation area controls and procedural guidance.
Established guidance and physical controls were compared against Final Safety Analysis Report (FSAR) Section (S) 12 details and documented recairements in applicable sections of Technical Specifications (TSs)
anc 10 CFR Part 20.
The inspectors made tours of the radiologically controlled areas (RCAs)
associated with radwaste processing and storage facilities.
Procedural guidance for on-going activities and associated survey records also were reviewed and discussed with responsible Health Physics (HP) staff. The inspectors directly observed technician Jerformance and discussed radiation and contamination controls witlin the primary chemistry laboratory, b.
Observations and Findinas Physical controls associated with radwaste storage areas were in accordance with TS requirements. Area postings were proper and in accordance with TS or 10 CFR 20 Subpart J requirements.
Containers holding radwaste contaminated materials and equipment were labeled in accordance with 10 CFR 20.1904 requirements.
Pro)er contamination and radiation control practices were observed for teclnicians conducting analyses within the priwy chemistry laboratory.
Enclosure 2
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Conclusions Radiation and contamination controls for radwaste processing and storage areas and primary chemistry laboratory operations were appropriate and in accordance with TS and 10 CFR Part 20 requirements.
R1.2 Dose Assessments a.
Insnection Scooe (83740)
Licensee assessments and assignment of whole body or extremity shallow dose equivalent (SDE) associated with selected contamination events from January 1. 1996 through July 25. 1997, were reviewed and discussed.
Applicable records of exposure assumptions. radionuclide gamma spectroscopy data and com)leted euluations fw the five maximum SDEs assigned to workers for t1e reviewed period were evaluated and discussed with cognizant licensee representatives.
In addition, dose records for individuals involved in the reviewed contamination events were evaluated for completeness and accuracy.
Licensee actions, assigned SDEs and records were compared against established procedural guid6nce and 10 CFR-Part 20 dose limits and reporting requirements.
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Observations and Findinas The SDE assessments were conducted in accordance with procedure 44019 C.
" Dose Assessment Font F 9tamination and Immersion in Noble Gas."
Revision 10. dated l'ay 44, 1997.
Licensee assumptions regarding location of radioactivt contamination or particles. shielding. exposure times and radioisotope mixtures were appropriate.
Assigned doses for the five maximum calculated SDEs were with 10 CFR Part 20 limits and ranged from 2451 to 24.098 millirem (mrem).
The maximum doses were associated with outage work conducted during the fall of 1996.
The inspectors verified that the individuals' assigned SDEs were included in-the appropriate NRC Form 5 records.
c.
Conclusions The SDEs to workers from contamination events were evaluated properly, were within 10 CFR Part 20,1201 limits and were recorded in accordance with 10 CFR 20.2106. requirements.
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R1,3 Radioactive Waste and Material Transnortation Activities a.
Insnection Stone (86750. T12515/133)
The inspectors evaluated and discussed the licensee's current guidance for radioactive material and waste packaging and transportation arogram activities.
Selected procedures and records associated with paccaging 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 100 179 and 10 CFR Part 71 regulations.
Copies of shipping records for the following transportation activities were reviewed in detail.
Radwaste Shipment (RWS) Number (No) 97 001. Reportable Quantity
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(RO) Radioactive Material, Low Specific Activity (LSA). n.o.s 7 UN-2912, Fissile Excepted, containing dewatered Ion Exchange Resin (Bead) from Plant Demineralizer System, shipped July 14, 1997.
Radwaste Volume Reduction Shipment (RWVS) No.97-007. Radioactive
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Material. Low Specific Activity. n.o.s.
7. UN 2912, 14 Drums of High Rad trash, paper cloth, metal and filter media in a Type A Package, shipped February 7, 1997.
RWVS No.97-015. Radioactive Material. LSA, n.o.s 7: UN-2912. Non-
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compacted trash: shipped June 13, 1997.
Radioactive material shipment 97-01 002. Radioactive material.
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Surface contaminated object, n.o.s. 7: UN-2913: Reactor coolant pump, shipped January 10. 1997.
Radioactive material shi) ment 97-06-004. Radioactive material.
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SCO 2, n.o.s 7. UN2913:
RCP Box: shipped June 19, 1997 Radioactive material shi > ment 97-07-002. Radioactive material.
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SCO 2 n.o.s 7 UN2913: _ong-handled tools: shipped July 8. 1997.
The inspectors noted that for five of the six shipments reviewed, licensee documentation did not meet the detailed shipping paper requirements as specified in 49 CFR 172.200, Identified documentation errors included an example of failure to consecutively number shi) ping pages; inconsistencies in shipment volume and in listed isotopes Jetween separate pages of a shipping document: incorrectly including "LSA-2" and
"SCO 2" as part of the proper shipping names contrary to 49 CFR 172.101, and failing to document LSA-Il for one shipment.
The inspectors verified that for all shipments with documentation errors. the proper isotopes and their quantities, material volumes, and radiation and contamination surveys were used in determining transportation categories, shipping containers and waste classifications, as applicable.
From review of procedures and discussion of training with
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responsible licensee representatives, the inspectors determined the recent revisions to 49 CFR Department of Transportation (DOT)
regulations were incorporated appropriately into the transportation program activities and that the identified issues resulted from personnel errors in updating licensee computerized database spreadsheet programs.
The inspectors identified the failure to complete shipping paper documentation in accordance with-49 CFR 172.200 as a violation of 10 CFR 71.5 requirements. However, the inspectors noted that these failures constituted a violation of minor safety significance and consistent with Section IV of the NRC Enforcement-Policy are being identified as NCV 50 424.425/97 07 04. Failure To Meet 49 CFR 172.200 Shipping Paper Documentation Details in Accordance with 10 CFR 71.5 Requirements.
Licensee representatives reviewed additional shipments made since January 1997 and found no significant document errors affecting transportation or wast classification, in addition, the licensee was implementing use of an approved vendor computerized system to generate radioactive material / waste ship)ing documents and burial manifest records.
Initial training on t1e system was scheduled for August 7.
1997.
In addition, the licensee stated that the accuracy of shipment records would be double verified for all shipments until the computerized system is fully implemented.
c.
Conclusions Licensee guidance and training incorporated recently revised 49 CFR Parts 100-179 and 10 CFR Part 71 regulations.
NCV 50 424.425/97-07-04 taas identified for failure to meet 49 CFR 172.200 shipping paper documentation details in accordance with 10 CFR 71.5 requirements.
R1.4 Primary and Secondary Coolant System Cold Chemistry a.
Insnection Scone (84750)
Licensee activities for monitoring and managing primary and secondary coolant cold chemistry parameters were reviewed and discussed.
The inspectors toured primary and secondary chemistry laboratories, secondary chemical addition room, and directly observed technicians completing selected chemical analyses.
In addition, selected January 1.
1997 through July 25, 1997, primary and secondary cold chemistry data trends were reviewed and discussed.
Parameters reviewed included Unit 1 (U1) and Unit 2 (U2) reactor coolant system (RCS) dissolved hydrogen.
lithium, dissolved oxygen, feedwater hydrazine. and steam generator sodium and sulfate concentrations.
Licensee program activities and results were reviewed against applicable TS. procedural requirements and industry standards.
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Observations and Findinas Housekeeping and cleanliness of the primary and secondary chemistry laboratories and within the secondary chemical addition room were adequate.
As required, secondary system on line analytical chemistry instrumentation was verified to be operable.
Technicians in both the primary and secondary chemistry laboratories were knowledgeable of procedures and demonstrated proficiency in completing the selected chemical analyses observed, in general, the inspectors verified that primary and secondary coolant analysis results were reviewed by technicians and management with appropriate actions taken to maintain the chemical concentrations within established limits.
Licensee representatives discussed chemistry program initiatives and presented chemistry trend data demonstrating improvements for steam generator sodium to chloride molar ratio control, and reductions in potassium, sodium and iron transport, c.
Conclusions The primary and secondary coolant chemistry program was managed appropriately and activities were implemented effectively.
R7 Quality Assurance in Radiation Protection and Chemistry Activities R7,1 Audits and Self assessments a,
Irdoection Stone (83750. 84750)
The inspectors reviewed and discussed results of health physics and chemistry program assessments conducted since January 1, 1997.
The inspectors evaluated the scope, thoroughness and status of corrective actions for selected issues identified.
Health Physics (HP) and Chemistry self-assessments. HP weekly area status checklists; chemistry internal assessments, and performance monitoring reports were revieu d, In particular, the inspectors reviewed and discussed the HP Department February 3-7, 1997 Self-assessment and followup actions, b,
Observations and rind _i_0_qi The assessments consisted of interviews, record review and direct observations by qualified personnel.
In particular, the inspectore noted that the HP self-assessment team consisted of qualified site and outside personnel, and involved review of separate HP program areas including ALARA, contamination control, external radiation, personnel dosimetry, Radiation Work Permit, Posting, labelling, solid radioactive waste, and surveys and documentation.
The assessment was performance based and the contents were appropriate sam)les of the program attributes.
The inspectors verified that t1e findings were
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characterized appropriately % the report and were being tracked to closure.
The inspectors noted that no programmatic issues were identified within either the HP or chemistry self assessment activities, c. -Conclusions Chemistry and HP self assessments were performance based with no programmatic issues identified.
Identified issues were tracked by licensee representatives and resolved appropriately.
R7.2 Primary and Secondary Chemistry 00ality Control Activities a.
Insoection Scone (84750)
The inspectors reviewed selected calibration and January 1. through July 25. 1997, quality control (0C) data records associated with primary and in-line secondary system chemistry measurements.
Program implementation and adecuacy of results were compared against specifications detailec in approved procedures and schedules, b.
Observations and Findinas in general, licensee activities to verify analytical instrument accuracy were conducted in accordance with approved schedules and procedures 31001-C. " Chemistry Control Charts.
Revision 5. 34000-C. "0)eration and Calibration of Process Monitors." Revision 8, and 31010-C. ")rocess Analyzer Calibration Scheduling Program." Revision 12.
Completion of acceptable calibrations of selected analytical instruments used for oxygen, hydrazine and sodium analyses were verified.
To demonstrate in-line instrument accuracy comparisons of in-line monitors with grab sample bench-top analysis results were conducted at the required frequencies or subsequent to instrument recalibration.
However, during review of QC trend data records for the primary chemistry and laboratory counting room, the inspectors noted that OC trending and anomaly reports were inconsistently implemented by the technician staff.
For example, in use boron analyses control charts were missing data and selected gamma-spectroscopy systems QC trend data which trended above the established mean did not result in Anomaly Reports being issued on a consistent basis.
From review of selected data and discussions with technicians and supervisors. the inspectors verified that the required OC analyses and re analyses were Jerformed and met estchlished procedural acceptance criteria, lowever, the inspectors identified the lack of consistently implementing all details of the QC program as an area for improvement.
The inspectors informed licensee representatives that OC program implementation would be considered an IFl 50 424.425/97-07-05. Review Licensee Actions to Improve Implementation of Chemistry QC Program Details.
Enclosure 2
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Conclusions in general, licensee OC primary and secondary OC activities verified accuracy of analytical measurements.
One IFl was identified to review implementation of chemistry QC data trending and Anomaly Report issuance.
R8 Hiscellaneous Radiation Protection and Chemistry Issues (84750)
R8.1 (Closed) URI 50-424.425/97-02-03: evaluate commitments and radiation monitor sensitivity to meet NUREG 0737 Table ll.F.1-3 Containment High Range Monitor Requirements.
Licensee audit findings documented in Safety Audit Engineer Review (SAER) audit report VSAER 97-016, dated February 7, 1997, documented that electronic calibrations of the containment high range monitors were not conducted for all range decades above 10 Roentgens per hour (R/hr)
as specified in NUREG 0737, Table ll.F.31.
Subsequent reviews also identified that the strength of the in situ calibration source exceeded the specified range of 1 -10 R/hr, and the inspectors cuestioned whether the monitors met the required sensitivity, (i.e.,1 rac per hour, s )eci fied. ) The inspectors noted that FSAR Section 7,5,4-2 specified t1at containment area radiation monitors were in conformance with NUREG-0737, ll.F,1, Attachment 3.
From review and discussion of applicable vendor documents, the inspectors verified that the containment high range monitor sensitivity met NUREG 0737 Table ll.F.1-3 requirements and the calibration source was in accordance with vendor specifications. Although, documentation errors in electronic signal limits were noted, data for completion of electronic signal calibration testing were accurate and testing was completed successfully in February 1997 for both units.
Current revisiens to surveillance procedures 24625-1, " Containment High Range Area Monitor 1RX-005 Analog 0)erational Test and Channel Calibration." and 24625 2. " Containment High Range Area Monitor 2RX-005 Analog Operational Test and Channel Calibration,"
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specify the appropriate electronic calibration limit values.
The licensee initiated licensing Document Change Request FS97-047. which would update FSAR Table 7,5,4-2 to allow source calibration of the CHRMs in accordance with the vendor recommendations.
Consistent with Section IV of the Enforcement Policy and based on corrective actions taken prior to the end of the inspection, the identified issues regarding the containment high range monitor calibration was identified as a non-cited violation (NCV) 50-424.425/97-07 06. Failure to Meet NUREG-0737 Requirements for Containment High Range Monitors.
Enclosure 2
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S2 Status of Security Facilities and Equipment S2.1 Vital Area Barriers a.
Insoection Scone (81700) (71750)
The inspector evaluated the licensee's com)ensatory actions for a degraded vital area barrier at the Unit 1 Jiesel Generator (DG)
Building.
The inspector reviewed the Physical Security Plan (PSP).
specific building drawings, and security procedures associated with the DG building.
b.
Observations and Findinas On July 7, 1997, maintenarce activities on the DG controls inadvertently caLsed a fuel oil spill to occur.
Maintenance Work Order 19702156 was generated on July 8, 1997, to request support and equipment to clean up_
the fuel oil outside DG 18 and from inside the IB day tank vent room.
The licensee's PSP, Amendment 34, dated April 28, 1997, Table 4 1, designates the Unit 1 and 2 DG buildings and their controls as vital areas.
Licensee Drawing AX1002FA06, Revision 0, dated 1988, designates the outermost boundary of the Unit 1 and 2 OG buildings as a vital barrier.
Licensee procedt're 90106-C. Revision 22. dated August 6,1996, Section 4.7 states in part, that decreased effectiveness of physical barriers shall be compensated for by posting armed nuclear security officers.
On July 8, a vital area barrier to the IB day tank vent room was removed to allow efficient cleanup of the fuel oil in this area.
The barrier consisted of steel louvers and rebar, The inspector determined that on July 8. prior to removing the day tank vent room vital area barrier, security pre posted the area with an armed officer. However, approximately 15 minutes later, upon inspection by the licensee, it was determined that "no unauthorized entry could be gained to the components of the building," The compensatory post was released upon this determination.
However, increased surveillance checks were initiated on the building.
Subsequently, the licensee failed to compensate for a decrease in effectiveness of a vital area barrier for approximately 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> with an armed security officer.
On July 24 the inspector performed a walkdown of the Unit 1 DG building and verified there were no openings in the IB day tank vent room greater than allowed by the PSP.
The inspector noted that the area was secured and all barriers were in place.
The licensee initiated a Request for Engineering Review (97-0264) dated July 16.-1997. to determine whether all protected and vital area barriers currently in place were required by security commitments in addition to ensuring appropriate plant drawings reflect actual barrier locations.
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Conclusion Through observation. discussion with licensee representatives, and document review the inspector identified a violation for failure to compensate for a decrease in effectiveness of the IB day tank vent room barrier.
This is identified as VIO 50 424/97-07-07. Failure To Take Compensatory Actions For A Decrease in Effectiveness Of A Vital Area Barrier.
Y. Manacement Meetinas and Other Areas X
Review of Updated Final Safety Analysis Report (UFSAR)
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 verifled that the UFSAR wording was consistent with the observed plant practices, procedures and/or parameters.
X1 Exit Meeting Summary The inspectors ) resented the inspection results to members of licensee management at t1e conclusion of the inspection on August 7.1997.
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.
X2 Other NRC Personnel On Site On July 16 and 17. Mr. L. Wheeler and Mr. H. Berkow of NRR. met with the licensee to discuss various topics.
X3 NRC Interface Meeting with Southern Nuclear On July 31. 1997, the NRC met with representatives of Southern Nuclear Company (SNC) management in Birmingham. Alabama, to discuss the plant status and major issues for the three nuclear power plants: Farley.
Hatch, and Vogtle.
In addition.
Mr. L. Reyes, presentations by the NRC Regional Administrator.
and the Director of Reactor Projects. Mr. J. Johnson, were made.
Enclosure 2
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X4 Local Public Document (PDR) Review On July 9, 1997, the inspectors visited the Vogtle PDR located at the Burke County Public Library in Waynesboro, Georgia.
During the visit, the inspectors reviewed the status of the collection and discussed the operation of the PDR with the local custodian.
Using available indexes in the PDR, the inspectors retrieved several randomly selected documents, The microfiche printer was in good working order and produced legible copies. The inspectors noted that there were five unopened envelopes from the NRC on the shelves of the collection.
The oldest envelope was postmarked June 27, 1997.
The inspectors also noted ten unfiled NRC weekly accession lists. The custodian indicated that she files NRC documents as time permits and that there was no other unopened mail.
She also indicated that visitors to the PDR are rare and are usually NRC personnel.
The custodian indicated that she contacts NRC headquarters personnel responsible for the PDR when questions arise.
-The custodian demonstrated the library's internet link to the NRC home page.
PARTIAL LIST OF PERSONS CONTACTED Licensee J. Beasley. Nuclear Plant General Manager J. Gasser, Plant Operations Assistant General Manager S. Chestnut, Operations Marager W. Burmeister, Manager Engineering Support K. Holmes, Manager Maintenance 1. Kochery, Health Physics Superintendent A. Parton, Chemistry Superintendent K. Duquette, Plant Health Physicist M. Sheibani, Supervisor, Nuclear Safety and Compliance C. Stinespring Manager Plant Administration M. Griffis, Manager P1 ant Modifications and Maintenance C. Tippins, Jr., Nuclear Specialist 1 INSPECTION PROCEDURES USED IP 37551:
Onsite Engineering IP 40500:
Effectiveness of Licensee Controls In Identifying, Resolving, and Preventing Problems
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IP 61726:
Surveillance Observation IP 62707:
Maintenance Observation IP 71707:
Plant Operations IP 71750:
Plant Support Activities IP 81700:
Physical Security Program For Power Reactors IP 83750:
Occupational Radiation Exposure Enclosure 2
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IP 84750:
Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 86750:
Solid Radioactive Waste Management and Transportation of Radioactive Materials Tl 2515/133:
Implementation of Revised 49 CFR Parts 100-170 and 10 CFR Part 71 ITEMS OPENED AND CLOSED Onened 50-424/97-07-01 VIO Failure to Document Entry into Proper Action Condition following Airlock Maintenance (Section 02.2).
50 425/97-07-02 NCV Improper Storage of Monorail Beam Adjacent to CCP 2A Motor (Section E8.2).
50 424/97-07 03 IFl Unplanned /Unmonitored Release From Unit 1 Equipment Building (Section E8.4).
50 424, 425/
NCV Failure To Meet 49 CFR 172.200 Shipping Paper 97-07 04 Documentation Details in Accordance With 10 CFR 71.5 Requirements (Section Rl.3).
50 424. 425/
IFl Review Licensee Actions To im Chemistry QC Program-Details prove implementation Of 97 07 05 (Section-R7.2).
50-424, 425/
NCV Failure To Meet NUREG 0737 Requirements For 97-07 06 Containment High Range Monitors (Section R8.1).
50-424/97 07-07 V10 Failure to Take Compensatory Actions For A Decrease In Effectiveness of A Vital Area Barrier (Section S2,1).
Closed-50-424/95-27-02 URI.
Adequacy of Nuclear. Service Cooling Water Valve as Closed System Isolation Valve (Section E8.1).
50-425/97 06-01 URI Monorail Beam Stored On-2A Centrifugal Charging Pump-(CCP) Bedplate (Section E8.2).
50-425/97-07-02 NCV Improper Storage of Monorail Beam Adjacent to CCP 2A Motor (Section E8.2).
50-424. 425/
URI Testing-of Parallel Circuits For MSIVs (Section E8.3).
97-06 02 50-424. 425/
NCV Failure To Meet 49 CFi,172.200 Shipping Paper 97-07-04-Documentation Details In Accordance-With 10 CFR 71.5 Requirements (Section R1.3).
Enclosure 2
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50-424. 425/
URI Evaluate Licensee Commitments And Monitor 97 02 03 Sensitivity To Meet NUREG 0737 Table II.F.3-1 Containment High Range Monitor Requirements (Section R8.1).
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NCV Failure To Meet NUREG 0737 Requirements For 97-07-06 Containment High Range Monitors (Section R8.1).
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