ML20196J743
| ML20196J743 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 07/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20196J633 | List: |
| References | |
| 50-361-97-05, 50-361-97-5, 50-366-97-05, 50-366-97-5, NUDOCS 9708050042 | |
| Download: ML20196J743 (40) | |
See also: IR 05000321/1997005
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U.S. NUCLEAR REGULATORY COMMISSION
REGION II
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Docket Nos:
50-321. 50-366
License Nos:
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Report No:
50-321/97-05'. 50-366/97-05
Licensee:
Southern Nuclear Operating Company. Inc. (SNC)
Facility:
E. I. Hatch. Units 1 & 2
Location:
P. O. Box 439
Baxley Georgia 31513
Dates:
May 18 - June 28, 1997
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Inspectors:
B. Holbrook. Senior Resident Inspector
E. Christnot. Resident Inspector
J. Canady Resident Inspector
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W. Kleinsorge. Reactor Inspector (Sections M1.2.
M2.1, M7.1. and M8.4 - M8.9)
G. Kuzo. Senior Radiation Specialist. (Sections
R1.2. R1.3. R2, R3 R5. R7. and R8)
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Approved by:
P. Skinner. Chief. Projects Branch 2
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Division of Reactor Projects
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Enclosure 2
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EXECUTIVE SUMMARY
E. I. Hatch. Units 1 and 2
NRC Inspection Report 50-321/97-05. 50-366/97-05
This integrated inspection included aspects of licensee operations.
engineering, maintenance, and plant support.
The report covers a 6-week
period of resident ins)ection; in addition. it includes the results of
announced inspections )y a regional reactor inspector and a radiation
protection / chemistry specialist.
Doerations
Plant procedures provided adequate instructions and Unit 2 operators
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took prompt and correct actions in response to a feedwater control
circuit swap from three element control to single element control.
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Engineering actions to troubleshoot the problem were appropriate
(Section 01.2).
The inspectors concluded that the failure to include Unit 1 plant
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service water strainer differential pressure instruments and their
associated setpoints in the instrument index was an oversight.
Equipment alignment, component operability, material conditions, and
housekeeping observed during an Engineered Safety Feature walkdown, were
acceptable.
Housekeeping for the diesel generator rooms was excellent
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(Section 02.1).
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An example of a violation for failure to follow procedure was identified
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for a clearance writer and two reviewers.
The clearance writer and
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reviewers failed to identify that the established clearance boundaries
affected other Emergency Core Cooling and support systems (Section
04.1).
The audit of Operations performance during the Unit 2 startup was
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conducted by trained ana qualified personnel.
Procedure requirements
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and audit techniques were clearly identified in the audit checklist
(Section 07.1).
Site management maintained good control of overtime.
Technical
Specification and procedural requirements were met (Section 08.1).
Maintenance
Routine maintenance activities observed were generally completed in a
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thorough and professional manner. Appropriated engineering and
supervisory oversight was provided (Section M1.1).
Equipment failures examined were generally appropriately addressed.
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item relating to the installation of an incorrect type of connector on
wide range monitor D11K621A was identified (Section M1.2).
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The licensee had made little progress in correcting the material
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condition deficiencies identified during the Maintenance Implementation
Inspection of October 1996.
As noted in October, the discrepant
material condition items were indicative of a lack of attention to
detail on the part of Operations and Engineering personnel who make
frequent tours to the areas (Section M2.1).
For the surveillances observed, all data met the required acceptance
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criteria and the equipment performed satisfactorily.
The surveillance
tests were conducted in accordance with procedures and with appropriate
oversight from supervisors and system engineers.
All involved personnel
were knowledgeable of the test and system performance requirements.
Overall performance was generally professional and competent (Section
M3.1).
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An example of a violation was identified for a failure to follow
procedure associated with sampling of fire-rated assemblies arid
penetration devices. Additional weaknesses were identified for the lack
of clarity of some surveillance procedural requirements and
administrative aspects of the fire protection program (Section M3.2).
A review of a licensee Safety Audit and Engineering Review audit reports
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'ndicated the audit was conducted by well qualified and trained
individuals (Section M7.1).
The licensee's actions taken or planned for other maintenance rule
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implementation inspection findings, were generally appropriate (Section
M8.9).
Enaineerina
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lne inspectors concluded that in general. engineering activities to
support plant operation were adequate (Section E1).
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Licensee personnel were actively pursuing a resolution of the concerns
discussed in Information Notice (IN) 92-18. Potential for Loss of Remote
Shutdown Capability During a Control Room Fire.
The established fire
watch patrols were appropriate (Section E2.1).
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The operation of Unit 2 with zero or low drywell-to-torus differential
pressure does not impact any safety function associated with the Primary
Containment.
All Technical Specification and Final Safety Analysis
Report requirements associated with torus-to-drywell vacuum breakers
were met (Section E2.2).
Plant Support
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In general, radiological controls and health physics activities were
adequate.
Minor deficiencies were discussed with technicians and
management personnel (Section R1.1).
Enclosure 2
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Radiological controls for high arid locked-high radiation areas were
maintained in accordance with Technical Specification requirements
(Section R1.2).
Contamination control associated with plant operation and maintenance
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activities continued to be a program weakness.
An example of a
violation for failure to follow procedure was identified for failure to
implement contamination control practices (Section R1.2).
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Transportation activities for radwaste and material shipments met
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10 CFR 71.5 and DOT 49 CFR 100-179 requirements (Section R1.3).
In general, the radiation monitoring system equipment was calibrated
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appropriately (Section R2).
Licensee programs to control, monitor and document liquid and airborne
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radionuclide effluent releases were maintained and implemented properly
(Section R3).
The Radiological Environmental Monitoring Program (REMP) sampling,
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analysis and reporting requirements were implemented effectively and
demonstrated minimal environmental impact (Section R3).
Projected offsite doses resulting from effluents were well within the
limits specified in the Offsite Dose Calculation Manual and 40 CFR 190
(Section R3).
An example of a violation was identified for the failure to implement
maintenance procedures to ensure that Radiological Work Permit
requirements and Health Physics coverage were adequate for the assigned
work activity.
A negative observation was identified for Health Physics
personnel failure to demonstrate a questioning attitude to ensure
radiological controls were adequate for an assigned work activity. A
negative observation was also identified for the failure of personnel to
identify and document several deficiencies surrounding a personnel
contamination due to poor radiological controls (Section R4.1).
Appropriate hazardous material training was provided to personnel
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handling and packaging radioactive materials for transport (Section R5).
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Audits of chemistry, radwaste and radiological control activities were
performance based with identified issues tracked and corrected
appropriately (Section R7.1).
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Counting room Quality Control activities were conducted in accordance
with approved procedures and demonstrated detector and analysis system
operability (Section R7.2).
Observed supervisory oversight by the inspectors of REMP activities by
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onsite personnel was minimal (Section R7.~2).
Enclosure 2
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The areas of security inspected met the applicable requirements (Section
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S2).
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Enclosure 2
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Report Details
Summary of Plant Status
Unit 1 began the report period at 100% rated thermal power (RTP).
Power was
reduced to about 80% RTP on June 21 to complete corrective maintenance for a
leak on a turbine extraction steam valve.
Power was returned to 100% RTP the
same day. The unit operated at 100% RTP for the remainder of the report
period, except for routine testing activities.
Unit 2 operated at 100% RTP throughout the report period, except for routine
testing activities.
I. Operations
01
Conduct of Operations
C1.1 General Comments (71707)
Using Inspection Procedure 71707. the inspectors conducted reviews of
ongoing plant operations.
In general, the conduct of operations was
professional and safety-conscious; specific events and observation are
detailed in the section below.
01.2 FeedWater (FW) Flow Control Unit 2
a.
Insoection Scooe (71707)
The inspectors were informed that Operations personnel had observed
sudden step changes in FW flow indications for channel A and channel B
on Unit 2.
During a routine tour of the control room on June 17. 1997
the inspectors also observed a sudden FW flow step change.
The
inspectors observed the operators' res)onse to the FW flow step change
and monitored licensee actions to trou)le shoot the problem.
The
ins)ectors also reviewed the applicable plant procedures for this
pro)lem.
b.
Observations and Findinas
Design Change Request (DCR)95-055 for the new FW control system was
installed on Unit 2 during the spring 1997. refueling outage. As a
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result of this DCR if a mismatch of about .5 million pounds mass per
hour between the FW flow sensing channels occurs. the FW control circuit
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shifts from three element control (reactor vessel water level. feedwater
flow, and steam flow) to single element control (reactor vessel water
level only).
The shift from three element to single element was
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designed to mitigate a transient following a FW flow transmitter
failure.
The DCR is scheduled to be installed on Unit 1 during the fall
1997, refueling outage.
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The shift did not result in a plant transient and reactor level change
was negligible.
The inspectors observed that Operations personnel
res)onded using applicable plant procedures.
A review of procedures
34Al-603-132-2S. "Feedwater Control System Trouble." Revision (Rev) 2.
and 34-S0-N21-007-25. " Condensate and Feedwater System." Rev.29.
revealed that the procedures provided adequate instructions for
operators to respond to the problem.
The inspectors discussed the occurrences with Operations personnel and
were informed that the amount of time that the mismatch was present
varied. The FW flow variations lasted from about seven to forty-five
minutes.
The mismatches appeared to occur on a random bases and
included both increasing and decreasing changes.
Due to multiple occurrences, the operators placed the FW control system
in single element control.
The licensee formed a problem solving team
to review the mismatch. identify possible causes and make
recommendations for corrective actions.
Instrumentation to monitor
system performance was installed.
Near the end of the inspection period. Engineering personnel informed
the inspectors that the problem solving team was still evaluating the
problem and had not made recommendations to site management.
The team
concluded that actual FW flow differences existed.
The problem solving
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team determined that the difference in the A and B channel flow
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increased when Reactor Water Cleanup System (RWCU) was not in service.
These observations were made by the problem solving team when the RWCU
was out of service for corrective maintenance.
The RWCU was placed in
service following corrective maintenance and the FW control problem of
shifting from three element to single element control, due to a FW flow
mismatch, did not recur.
Operations personnel also observed a swap to FW single element control
during Main Steam Isolation Valve (MSIV) testing.
During this
surveillance test. the MSIVs were closed about 10%. resulting in a flow
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mismatch between the main steam lines that cas sensed by the FW control
circuit.
General Electric and corporate engineering personnel were
evaluating a change to the FW control circuit setpoints to lessen the
possibility of spurious swaps from three element to single element
control.
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The inspectors discussed with Operations management. the number of
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surveillance procedures that could cause a FW control circuit swap.
The
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inspectors were informed that some surveillance 3rocedures had been
identified and a review of other procedures was
aeing conducted.
The inspectors observed that all Operations personnel had not received
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specific instructions on what actions to take when surveillances were
identified that may cause a swap of the FW control circuit.
This was
discussed with Operations management.
Operations management later
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informed the inspectors that more detailed instructions were provided to
all Operations personnel.
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The inspectors discussed with Engineering personnel whether or not the
swapping of the FW control circuit had been identified during the DCR
review process or whether this-problem was unexpected.
The inspectors
were informed that the problem was unexpected and had not been discussed
.previously. -Engineering personnel planned to evaluate the results of
the problem . solving team's findings to determine what corrective actions
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will be required
c.
Conclusions-
Plant procedures provided adequate instructions and Unit 2 operators
took prompt and correct actions in response to the feedwater control
circuit swap from three element to single element control. The swap did
not result in a plant transient.
Engineering actions to troubleshoot
the problem were appropriate.
02
Operational Status of Facility and Equipment
02.1 Enaineered Safety Features (ESF) System Walkdowns
a.
Insoection Scooe (71707)
The inspectors used Inspection Procedure 71707 to walk down accessible
portions of the following ESF system:
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Plant Service Water (PSW), Divisions 1 and 2 (Unit 2)
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PSW for 1A. 1B. and 1C Emergency Diesel Generators (EDG).. Unit 1
The walkdown included a verification of valve alignment, condition of
components in service, and general housekeeping for the associated
areas.
b.
Observations and Findings
The ins)ectors reviewed applicable drawings and Instrument Setpoint
Index. Revision (Rev.) 47 for instruments that actuate control room
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alarms and automatic actions of the PSW strainers.
The inspectors
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observed that the set 3oint index for Unit 2 contained the necessary
instrumentation for t1e PSW motor operated strainers and indicated
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applicable instrument setpoints.
However, the inspectors could not
locate the Unit 1 corres)onding instruments and their applicable
instrument setpoints.
T1e inspectors discussed this issue with
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03erations and Engineering personnel.
The inspectors were informed that
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t1e Unit 1 instruments should have been included in the setpoint index.
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Enclosure 2
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The inspectors observed that the setpoints for strainer differential
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pressure instruments for both units were different.
The inspectors were
informed that the strainers for Unit 1 were of a different manufacturer
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than Unit-2 and that the instrument setpoints were different.
The
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inspectors verified that the Unit 1 instruments' setpoints were
consistent with engineering and vendor recommendations.
The inspectors were later informed that the onsite engineering group
issued As Built Notification (ABN)97-181 to add the applicable Unit 1
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instruments to the setpoint index.
c.
Conclusions
The inspectors concluded that the failure to include Unit 1 PSW strainer
differential pressure instruments and the associated setpoints in the
instrument index was an oversight.
Equipment alignment and com)onent
operability, material conditions, and housekeeping were accepta]le in
all areas inspected.
Housekeeping conditions for the EDG rooms were
excellent.
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04
Operator Knowledge and Performance
04.1 Clearance Deficiency for Unit 1 Core Soray (CS) System
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a.
Insoection Scooe (71707)
The inspectors reviewed procedure 30AC-0PS-001-OS. " Control Of Equipment
Clearances and Tags." Rev.15. equipment clearance 1-97-159. for the B
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loop of Unit 1 CS and reviewed licensee actions with respect to a
clearance deficiency.
b.
Observations and Findinas
On June 9,1997. Nuclear Safety and Compliance (NSAC) management
informed the inspectors that Unit 1 had entered TS action 3.0.3 due to
both loops of CS being considered inoperable.
The inspectors reviewed
operator logs, equipment clearance sheets and discussed the CS clearance
with clearance writers and Operations management.
The inspectors
observed from their reviews that clearance 1-97-159 was placed for
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maintenance activities on the IB loop of CS.
The clearance was placed
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and the required TS action statement was entered at 7:30 a.m.
At about
1:40 p.m.. control room operators received an alarm that indicated that
the 1A CS Jockey Pump system, which maintains the CS system full and
pressurized, had a low level.
This indicated that the A loop of CS
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might not be properly filled and vented.
Operators immediately declared
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the A loop of CS inoperable and initiated actions to fill and vent the
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system.
During the time both loops were declared inoperable. TS 3.0.3
was entered.
This TS action required that the unit be in Cold Shutdown
within the next 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Following fill and venting activities, at
about 2:00 p.m. . operators declared the 1A loop operable and exited TS 3.0.3.
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The inspectors observed t at part of the clearance required closing the
1B CS pum) suction valve am racking out its electrical supply breaker.
Closing t1is valve isolated the inservice jockey pump suction source.
The correct action should have been to realign the jockey pump system to
the other CS loop and place the standby pump in service prior to
isolating the inservice jockey pump.
The clearance was developed by personnel from a maintenance team which
included experienced clearance writers.
The clearance form did not
contain, in Section 3. Amplifying Instructions. any caution or note
concerning a review of the inservice jockey pump suction source prior to
closing the CS pump suction valve.
The inspectors brought this problem
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to the attention of the personnel who write and modify computer
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generated clearances and a note was added for the computer generated CS
clearance form.
The inspectors observed that the computer generated clearance for the CS
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loop 1B was identical to the clearance that was implemented by
Operations personnel.
Neither contained any precautions concerning the
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jockey pump system. The inspectors discussed the clearance review
process with clearance writers.
The inspectors were informed that the
common practice and )rocedural recuirement for computer generated
clearances was for tie clearance crafter to verify the clearance using
plant drawings to confirm the clearance boundaries were accurate.
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this case. the review process was not adequate to identify the inservice
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jockey pump suction would be isolated and system alignment should be
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changed.
The clearance was reviewed and approved by two Senior Reactor
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Operators prior to being placed and the deficiency was not identified.
The licensee initiated an engineering review of the problem to determine
if the 1A loop of CS should have been declared inoperable.
Engineering
determined the 1A loop was not inoperable and applying TS 3.0.3 was a
conservative decision.
Engineering based their decision on a review of
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the TS required o)erability surveillance for the CS system fill and vent
and a review of t1e instrument design configuration.
Engineering
determined that about 2 gallons of water may have escaped from the 1A CS
loop between the time the inservice jockey pump was isolated and the
standby jockey pump was started.
The inspectors reviewed drawings of
the alarm piping with Engineering personnel and observed that the low
level alarm switch configuration was above the high point of the CS
system pipir,g.
A low water level in the alarm system piping occurred
and actuatt.d the low level alarm prior to any level decrease in the
primary system.
The inspectors concluded the licensee's determination
that the 1A CS system was operable was reasonable.
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The inspectors reviewed licensee performance for the past two years with
respect to clearance problems.
Clearance deficiencies were identified
in Inspection Report (IR) 50-321, 366/97-03 and a VIO was identified in
IR 50-321. 366/97-02 for operators' failure to identify correct
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cle5rance restoration steps.
The inspectors concluded that the
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circumstances surrounding the most recent clearance problem were
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different from the previous problems and would not have reasonably been
prevented by previous licensee corrective actions.
For the most recent clearance problem, the clearance drafter and two
clearance reviewers failed to implement steps 8.4.5 and 8.5.2 of
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procedure 30AC-0PS-001-0S.
The procedure ste)s required in part, that
the drafter of the clearance will determine tle required isolation
boundaries and fill out the equipment clearance sheet and that
appropriate system Drawings. Electrical Diagrams. Load Lists, and System
Operating Procedures will be used to determine the adequacy of the
proposed clearance.
In this case the clearance boundaries were not
adequate with respect to ensuring other Emergency Core Cooling Systems
(ECC) and support systems were not affected.
The inspectors were informed that Operations management established a
problem solving team to evaluate this and other recent clearance
problems.
They were to determine root causes and make recommendations
to prevent recurrence. Additionally, the clearance procedure was being
revised to clarify some steps and provide an overall general
enhancement.
c.
Conclusions
The clearance drafter and two clearance reviewers failed to properly
implement procedures to identify the correct clearance boundary for the
Unit 1 B loop of Core Spray.
As a result, other ECCS and support
systems (1A loop of Core Spray and the jockey pump system) were affected
by the clearance.
This failure to follow procedure was identified as an
example of Violation (VIO) 50-321. 366/97-05-01. Failure to Follow
Procedure - Multiple Examples.
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07
Quality Assurance in Operations
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07.1 Review of Safety Audit and Engineerina Review (SAER) Audit Report
a.
Insoection Scooe 71707
The inspectors reviewed SAER Report 97-SA-2 which was conducted by
licensee personnel to verify compliance with and the effectiveness of
the Quality Assurance program as applied to Reactor and Plant Startup of
Unit 2. following the spring refueling outage.
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b.
Observations and Findinas
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Licensee personnel conducted the audit between April 16 and April 23,
1997.
The audit focused on reactivity control, startup activities,
surveillances, communications, control room manning, and team
observations.
Operations management provided input for specific items
to be audited.
The audit was conducted for around-the-clock shifts
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during startup activities.
No audit findings or audit comments were
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identi fied.
The inspectors reviewed auditor training requirements and training
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records and verified the auditors were qualified to conduct the audit.
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The inspectors observed that the audit checklist and specific audit
items were based upon current plant procedures and department
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instructions.
Procedure requirements and audit techniques were clearly
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identified in the audit checklist.
The inspectors reviewed each audit element and assessed the audit
conclusions.
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c.
Conclusions
The inspectors concluded that the SAER audit of operations during the
Unit 2 startup activities was conducted by trained and qualified
personnel.
Procedure requirements and audit techniques were clearly
identified in the audit checklist.
08
Miscellaneous Operations Issues
08.1 Use of Overtime (OT)
a.
Insoection Scooe (71707)(92901)
The inspectors reviewed Unit 1 and Unit 2 TS Section 5.0, Administrative
Controls, which establishes the requirements for OT use: Procedure 10AC-
MGR-020-0S. " Overtime," Rev.0: and the licensee's use of OT during the
spring 1997. Unit 2 refueling outage. The inspectors also conducted
reviews of OT for selected portions of the years 1995. 1996, and 1997.
The selected review for these years did not include OT used during
refueling outages.
The departments reviewed were Engineering, Security,
Maintenance. and Operations.
The inspectors discussed the results of
the OT review with applicable management personnel.
b.
Observations and Findinas
The review of OT during the spring refueling outage did not identify any
deficiencies.
The OT was controlled in accordance with TS and plant
procedures.
c.
Conclusions
The inspectors concluded that site management maintained good control of
overtime. Technical Specification and procedural requirements were met.
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II. Maintenance
M1
Conduct of Maintenance
M1.1 General Comments
a.
Insoection Scone (62707)
The inspectors reviewed the applicable procedures, work packages and
observed or reviewed all or portions of the work activities under the
following maintenance work orders:
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1-97-1077:
install seismic support for Residual Heat Removal
(RHR) Pump 1D electrical breaker
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1-97-0787:
change oil and meggar RHR Pump 1D motor
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1-97-1078:
install seismic support for RHR Pump 1B electric
breaker
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1-97-0507:
inspect end turn windings on the generator for the 1C
Emergency Diesel Generator (EDG)
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1-97-0270:
repair small fuel oil leak on 1C EDG
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2-97-1506:
change out Plant Service Water (PSW) Pump C mechanical
seal
b.
Observations and Findinas
The licensee removed loop 1B of the RHR system from service to perform
preventive maintenance. inspections, and implement a design change on
the RHR pump electrical breakers.
The inspectors observed that the design changes for breaker seismic
supports were im)lemented using work process sheets 97-011-E005 and
E006. items 33 t1 rough 38 only.
The installation and improvement of
seismic supports is an ongoing initiative for system upgrade.
The
implementation was performed with engineering and supervisory oversight.
The inspectors observed partial performance of and reviewed selected
maintenance work orders.
Applicable procedures were used and were
present at the work areas.
The inspectors discussed the activities with
workers. maintenance supervisors. and engineers.
All personnel were
knowledgeable of the work activities.
The required action statements
for Technical Specifications (TSs) out-of-service time were met.
The inspectors observed the routine generator end-turn winding
inspection of the 1C EDG.
The inspectors documented in previous
inspection reports that the inspections were routinely made due to
spacers between the windings becoming loose.
The inspection was
performed using the procedurally prescribed fiber optic and video
system.
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During the'last Unit I refueling outage the generator portion of the 1A
EDG was replaced.
The generator was sent offsite for a detailed
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inspection to determine if other EDGs should also be replaced.
The
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inspectors were informed that the results of the ins)ection indicated
that the removed generator was in good condition. T1e inspectors were
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also informed that, based upon the results of the offsite inspection of
EDG 1A there were no plans to replace the generators associated with
the 1C and the IB EDGs at this time.
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c.
Conclusions
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The inspectors concluded that maintenance activities completed were
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generally thorough and professional.
The inspectors observed
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engineering and supervisory oversight was provided when necessary.
No
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deficiencies were identified by the inspectors.
M1.2 Eauioment Failures
a.
Insoection Scoce (62700)
To evaluate the licensee's actions related to equipment failures, the
inspectors selected six Significant Occurrence Report (SOR) items.
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indicated below, to review for adequacy of: root cause determination;
determination of the extent of the problem: 10 CFR 50.65 evaluation; and
corrective actions taken and results achieved.
Commitment No.
Descriotion
C09700109
Failure of Reactor Core Isolation Cooling Valve
1E51F045 to open with control switch
C09700124
Standby Liquid Control Pump 1A tripped while
performing 34SV C41-002-1S
C09700130
Drywell Radiation Monitoring Wide Range Monitor
D11K621A spiking intermittently
C09700372
Cracked 3/4-inch RHR system socket weld adjacent
to 1E11-F3017/F3018
C09700771
Traversing Incore Probe (TIP) control unit 2C51-
1
J600-50 periodically fails the self test
l
C09701516
Valves 2G11-F003 and 2G11-F004 failed local leak
rate test
b.
Observation and Findinas
'
Drywell (DW) Radiation Monitoring Wide Range Monitor D11K621A was
reported, in C09700130. to be spiking intermittently. The licensee
4
Enclosure 2
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determined that spurious spiking was the result of corrosion on
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electrical connectors.
The connectors were subsequently replaced.
SOR
'
C09700130 stated in part: "The connectors outside the DW penetration for
i
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2D11-K621A were found to be of the wrong type and were replaced in
01/97." When asked by the inspectors. how the wrong type of connectors
!
were installed. the licensee indicated that they did not know but would
i
find out.
Pending the outcome of~the licensee's investigation. this is
identified as Ins)ection Followup Item (IFI): 50-321, 366/97-05-02.
i
Installation of t1e Wrong Type of Connectors on Drywell Wide Range
Monitor D11K621A.
t
Equipment failures examined were appropriately addressed except as noted
above.
c.
Conclusions
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Equipment failures examined were generally appropriately addressed.
!
M2
Maintenance and Material Condition of Facilities and Equipment
M2.1 Housekeeoino and Material Condition
a.
Insoection Scone (62700)
During the Maintenance Rule Implementation Ins)ection, conducted in
October 1996 (NRC IR 50-321, 366/96-12). a num)er of housekeeping and
,
material condition discrepant items were noted. The team concluded that
'
these were indicative of lack of attention to detail by Operations and
Engineering personnel who frequently tour the areas.
To evaluate the
licensee's actions relative to those discrepant conditions, the
inspectors conducted a walkdown inspection of a portion of the plant
l
areas examined during the October 1996 inspection.
The specific areas
,
l
included: Diesel Generator Building 1B and 2A 4160 VAC Switch Gear
I
Rooms: Intake Structure: and Units 1 and 2 Cooling Tower Batteries.
b.
Observation and Findinas
The inspectors noted the following
The majority of the insulation associated with the traveling
.
l
screens was still in the same damaged / crushed condition noted in
October 1996.
The missing insulation noted in October 1996, had
been replaced. The licensee indicated that they were in the
process of generating a Modification that will replace the damaged
i
insulation and reroute the piping such that the piping will become
less attractive stepping locations. thus affording the new
insulation a better chance of remaining undamaged.
A number of fasteners continued to be missing or loose on the
!
guards and covers on the Traveling Screens.
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Enclosure 2
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Several electrical cabinet doors associated with the traveling 'r
screens continued to be improperly secured such that the weathe
'
stripping / environmental seal was not compressed thereby
i
potentially compromising the integrity of the components within.
Both Unit 1 service water strainers continued to leak., although to
1
=
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,
a lesser extent than noted in October 1996.
~ Verdigris was-again noted on a number of terminals on the Unit 2
,
e
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Cooling Tower Batteries 2R425005.
L
l
In the switch gear rooms located in the EDG building the
l
inspectors noted ap3roximately ten panels that were improperly
l
secured such that t1e weather stripping was not compressed thus
l
not affording a proper seal
In addition, there were
approximately ten panel closure plate bolts that were not snug
tight, about four were stripped such that the bolt could be
removed without turning.
c.
Conclusions
The licensee had made little progress in correcting the material
condition deficiencies identified during the Maintenance Rule
Implementation Inspection of October 1996. As noted in October 1996,
the discrepant material condition items were indicative of a lack of
attention to detail by Operations and Engineering personnel who
frequently toured the areas.
M3
Maintenance Procedures and Documentation
M3.1 Surveillance Observations
'
a.
Insoection Scope (61726)
The inspectors reviewed the applicable procedures and observed all.or
portions of the following Unit 1 and Unit 2 surveillance activities:
e
High Pressure Coolant Injection (HPCI) Pump
Operability
e
HPCI Pump Operability
e
Battery Charger Capacity Test
b.
Observations and Findinas
l
The inspectors documented in previous inspection reports observations of
s)eed fluctuations for the HPCI turbine during surveillance testing.
i
!
Tlese observations were documented as Inspection Followup Item (IFI) 50-
!
321. 366/96-15-03.
Additional information is documented in Section M8.3
of this report.
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Enclosure 2
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During the recent surveillance activities, the inspectors observed
similar speed fluctuations.
Operators were aware that speed
fluctuations may occur and had discussed the issue during the pre-job
brief. The system engineer discussed system speed responses and stated
r
that some s]eed changes were normal and were to be expected.
The
inspectors lad discussed the speed changes with the system engineer and
Operations personnel prior to the surveillance and concluded that the
system engineer's explanation was reasonable.
The inspectors observed the battery charger test was for both chargers
for the EDG 1B battery.
The test was conducted in accordance with an
approved procedure and with oversight from the system engineer. All
involved personnel were knowledgeable of the system and test
requirements.
c.
Conclusions
For the surveillance activities observed, all data met the required
acceptance criteria and the equipment performed satisfactorily. The
surveillance tests were conducted in accordance with procedures and with
oversight from supervisors and system engineers.
All involved personnel
were knowledgeable of the test and system performance requirements.
Overall performance was generally professional and competent.
No
deficiencies were identified.
M3.2 Review of Unit 1 and Unit ? Fire Penetration Surveillances
a.
Insoection Scooe (61726)
The inspectors reviewed procedure 42SV-FPX-019-1S. Rev. 2 and 42SV-FPX-
019-2S. Revision (Rev.) 2. Penetration Seal Surveillance, and reviewed
licensee actions to complete the surveillance requirements. The
inspectors reviewed Units 1 and 2 Fire Hazards Analysis (FHA) to verify
correct implementation of the fire protection surveillance requirements.
b.
Observations and Findinas
The inspectors observed that Quality Control (OC) personnel generally
performed the surveillance procedures and fire protection engineers
reviewed and approved the procedures for acceptability.
The inspectors
observed that surveillance requirement 2.1.1 of the FHA required that
certain fire-rated assemblies and penetration sealing devices shall be
verified operable at least once per 18 months by performing a visual
inspection.
Section 7.7 ;f surveillance ]rocedures 42SV-FPX-019-1S/2S. stated in
part. that if any item in su)section 7.4 of the
3rocedure is marked
" Reject" or any other degradations were noted, t1e 10% sample of the
seals being surveyed is rejected, and a second 10% sample must be
requested from Fire Protection Engineering.
The second sample will be
Enclosure 2
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inspected in accordance with the steps of this procedure.
If the second
l
10% sample fails the surveillance procedure, additional 10% samples will
be inspected until a sample meets the acceptance criteria.
The inspectors observed that subsection 7.4 of the procedures included
the visual inspection acceptance criteria that was required to be met
for satisfactory completion of the surveillance.
The acceptance
criteria was identified in subsections 7.4.3.1 through 7.4.3.7.
Any
deficiencies were to be noted on Attachment 1 of the procedure and a
Deficiency Card (DC) was to be initiated.
The inspectors observed that
l
Attachment 1 contained a column where acc.cpted or rejecteo penetrations
'
were identified.
The inspectors reviewed the surveillance procedures for Unit 1 and Unit
2 that were completed between Jar;uary 30 cod April 21. 1997.
The
inspectors observed that four different types of penetrations were
identified as " rejected. " The inspectors ver1 M d that DCs and MW0s
were initiated to implement corrective actions f3r the rejected
penetrations. One penetration seal was misslag, one was not sealed on
one side, one contained holes and one contained spaces between the seal
and penetration boundary.
The inspectors reviewed surveillance procedures for both units since
A]ril 1991..
Each of the surveillance procedures identified degradations
tlat rendered some penetrations inoperable and required corrective
maintenance to restore the penetrations back to aerable status. The
inspectors verified that the correct Fire Actioi. Statement (FAS), for
penetrations that required FAS were implemented.
The inspectors were not provided ary documentation that a second 10%
sample of fire protection penetrations was no . conducted.
The
inspectors discussed this with fire protection engineering personnel.
The licensee stated that a second 20% sample had never been conducted.
The fire protection engineers interpretation of the procedurt step was
if the fire protection engineer detected a trend of a particular type of
penetration seal, a second 10% surveillance sample would be completed.
The inspectors concluded that this interpretation was not consistent
with the wording of the procedure.
The inspectors also identified everal procedure weaknesses. These
included the following:
-
Procedure 42FP-FPX-014-05. " Installation and Repair of Silicone
Foam Seals." contained specific irstallation requirements and
identified the required spacing ' atween multiple penetrations.
The procedure also identified tt
if penet ations were too
congested to complete a rejectici form.
The surveillance
procedure did not identify the s 'paration criteria requirement as
an item to review for surveillar,ce acceptance criteria.
.
(
Enclosure 2
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Step 7.4.1 of procedure 42SV-FPX-019-1S/2S stated in part that
i
visual' inspection of each type seal includes, but will not be
,
l
limited to the items noted in steps 7.4.3.1 through 7.4.3.7.
The
I
procedure implied that other items may be observed for acceptance
i
'
criteria but provided no guidance for such items.
'
-
Step 7.4.3.2 of ' procedure 42SV-FPX-019-1S/2S stated in part.
(observe that) no apparent change in appearance or abnormal
degradation of seals and/or damming material.
The procedure
offered no guidance as to what constituted changes in appearance
l
or what abnormal degradation may include'.
-
Step 7.11 of procedure 42SV-FPX-019-1S/2S indicated the Fire
Protection Engineer will review the surveillance results and
perform a walkdown sample of penetration seals listed on
Attachment 1.
There were no procedure requirements to document
l
the sample walkdown, how many or which seals were reviewed or the
i
results of the review. The procedure did not indicate whether or
not seals that were identified as rejected or degraded should be
reviewed.
The inspectors observed that the last surveillances were com)leted for
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Unit 1 and Unit 2 on abcat April 19. 1997.
The inspectors o) served that
3rocedure 42SV-FPX-019-IS for Unit 1. and 42SV-FPX-019-2S for-Unit 2.
-
l_
1ad incorrect cover sheets for the data package.
Unit 1 cover sheet was
'
on Unit 2 data and vice versa.
Inspectors brought this to the attention
of a fire protection engineer who corrected the problem.
l
As'of June 6.1997. fire protection engineers had not reviewed the
!
surveillances completed on A)ril'19.
The inspectors discussed with
Engineering management how t1e FHA reporting requirement to submit a
special report to the Safety Review Board within the next 30 days if an
inoperable penetration is not repaired within 14 days, was being met.
The-inspectors were informed that penetrations were usually repaired in
a timely manner however, this could be a potential vulnerability. The
problem was to be reviewed by Engineering personnel. The inspectors did
not identify problems caused by the delayed reviews.
The inspectors attempted to locate the previous 18 months surveillances
in document control. The document control clerk was unable to locate
,
the documents.
Fire protection engineering personnel had a copy of the
!
mrveillances in the office work location.
The inspectors were not able
L
to determine if the previous surveillances were ever submitted to
i
document control.
The inspectors documented a weakness in the administrative aspects of
the fire protection program in IR 50-321. 366/97-01. A Notice of
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Violation was also identified for failure to implement the FHA
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Enclosure 2
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requirements for transient combustible permits. The above problems were
identified as additic.9el concerns of the administrative aspects of the
FP program implementation.
c.
Conclusions
The inspectors concluded that the failure to complete additional 10%
i
samaling of fire-rated assemblies and penetration devices in accordance
wit 1 section 7.7 of surveillance procedures 42SV-FPX-019-1S/2S and
section 2.1.1 of the Fire Hazards Analysis and Fire Protection Program
,
Surveillance requirements did not meet requirements. This was
,
identified as an example of VIO 50-321, 366/97-05-01, failure to follow
a
t
procedure - multiple examples.
Additional concerns were identified with
,
the clarity of some su'rveillance procedure requirements and with some
.
administrative aspects of the fire protection program.
4
M7
- Quality Assurance in Maintenance Activities
i
M7.1 .Audils
i
a.
Insoection Scoce (62700)-
'
To evaluate the licensee's Audit Program as it relates to maintenance,
the inspectors requested copies of all audits and self assessments
conducted in the maintenance area during the previous year.
The
inspectors reviewed the three audits provided.
l.
b.
Observations and Findinos
Audit 96-SPR-1. Audit of Special Processes, findings included.
incomplete weld sketches: Temporary Repair procedure not used; and Post
'
Weld Heat Treatment problems.
t
Audit 96-SA-4. Contractor Control
findings included: administrative
controls not satisfied: errors in the specification of ANSI Standards:
contractor pre-job briefings did not meet OSHA requirements: and
contractor Work Order procedural problems.
Audit 96-SA-8. Plant Housekeeping and Material Condition. findings
included: housekeeping deficiencies noted in U1 & U2 Turbine Buildings.
U2 Reactor Building. Control Room, and Laundry Storage Area: and tools
'
including wheeled carts were improperly stored in proximity of safety
related e
Appropriate corrective actions were taken or
planned. quipment.
.
c.
Conclusions
I
4
Maintenance was subjected to indcpendent audits, with appropriate action
'
taken for identified weaknesses.
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>
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Enclosure 2
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M8
Miscellaneous Maintenance Issues (92902)
M8.1
(Closed) IFI 50-321. 366/96-14-04: Potential Deficiencies in the HPCI
l
Surveillance Procedure.
This item was opened pending additional
observations of operator and HPCI system performance during surveillance
,
l
activities.
The inspectors observed that the use of the Safety
l
Parameter Display System (SPDS) to monitor suppression pool temperature
during surveillance activities was consistent among the operating crews.
Engineering personnel informed the inspectors that the SPDS gives a more
accurate su)pression pool temperature indication than the safety related
recorder.
Based upon the inspectors' review of licensee's actions and
observations of the operators' consistent use of the SPDS. this item is
closed.
. Closed) Violation 50-321. 366/96-14-03: Failure to Implement
M8.2
(
Configuration Control Requirements - Multiple Examples.
The licensee
responded on February 4. 1997. by correspondence.
Additional examples
of this violation are discussed in Section E8 of this report.
The
licensee's res)onse indicated that a misleading label on the trip device
selector switc1 contributed to the incorrect setting.
Initial
corrective actions were discussed in IR 50-321. 366/96-14 (Section E2).
DCR 96-058 was implemented as part of the followup corrective actions.
Based upon the inspectors' review of licensee's actions, this violation
example is closed.
M8.3 (Closed) IFI 50-321. 366/96-15-03: Resolution of Reactor Core Isolation
Cooling (RCIC) and High Pressure Coolant Injection (HPCI) turbine speed
control drift.
During the report period the inspectors observed the
operation of the Unit 1 and Unit 2 HPCI system.
Part of the test was
for Inservice Testing (IST) purposes.
One requirement of the test was
to maintain the speed of the turbine at 3900 rpm plus or minus 1%.
The
inspators concluded, based on this observation and previous
observations, that during tests of the HPCI and RCIC systems the speed
will drift and did not result in a system operability concern.
The
inspectors observed that the plant operators had been made aware of
speed drifts.
Based on the inspectors' observations and review of
licensee actions, this item is closed.
M8.4 (Ocen) Violation 50-321. 366/96-12-01: Failure to Include All
Structures. Systems, and Components in the Scope of the Maintenance Rule
as Required by 10 CFR 50.65.
By letter dated December 19, 1996. the
licensee denied this violation.
Subsecuently, by letter dated March 5.
1997, the licensee stated that they hac determined that it was necessary
to resolve the issues discussed in their initial response of December
19. 1996.
The NRC responded by letters dated February 10. and April 2.
1997. As a result, the licensee indicated that they would include the
communications, non-appendix R emergency lighting. Appendix R emergency
l
lighting. and cooling tower systems to the maintenance rule program.
The licensee indicated that they would be in full compliance by
'
September 1. 1997.
This item remains open.
j
l.
Enclosure 2
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M8.5 (Ooen) Violation 50-321. 366/96-12-02: Failure to Establish Adequate
l
Performance Criteria for SSC Risk Significant Functions.
By letter
dated December 19, 1996, the licensee admitted that additional
performance criteria could have been established for the primary
containment and primary containment isolation, feedwater and condensate,
circulating water, electro-hydraulic control, and primary containment
i
'
chilled water systems.
The licensee has provided availability
performance criteria for those systems.
The licensee's letter dated December 19, 1996, denied that the
performance criteria for the AC and DC electrical and analog transmitter
trip systems were not 3roperly established.
Subsequently, by letter
dated March 5, 1997, t1e licensee stated that they had determined that
it was necessary to resolve the issues discussed in their initial
response of December 19, 1996.
The NRC responded by letters dated
February 10, and April 2,1997.
As a result, the licensee indicated
that they would establish appropriate additional performance criteria
for the AC and DC electrical and analog transmitter trip systems. The
licensee indicated that they would be in full compliance by September 1,
1997.
This item remains open.
M8.6 (Closed) Violation 50-321. 366/96-12-03: Failure to Follow Procedure for
.
Implementation of the Maintenance Rule.
By letter dated December 19,
1996, the licensee admitted to the violation and attributed it to
personnel error.
The licensee identified the failures as required by
the Maintenance Rule and conducted a root cause analysis on the
incident. The licensee determined that this was an isolated occurrence
and that the individual responsible. is no longer a licensee employee.
The inspectors determined that the licensee had conducted an
appropriate survey and determined the extent of the noncompliance, and
took appropriate actions to correct the condition and prevent its
recurrence.
M8.7 (Ocen) IFI 50-321. 366/96-12-04: Failure to Provide Adequate Procedure
for Implementation of Maintenance Rule Requirements.
The licensee
opened Action Item Tracking (AIT) No 96-2t>1 with a due date of January
j
5. 1998. AIT No 96-261 stated: Monitor the resolution of this issue by
)
the NRC and EPRI and once a position has been taken evaluate this
position and implement any corrective actions as necessary to bring
plant Hatch into compliance with regulatory requirements.
Regulatory
'
Guide (RG) 1.160, " Monitoring the Effectiveness of Maintenance at
Nuclear Plants." Rev.2, issued March 1997 paragraph 1.2. provided
specific guidance in the area in question. that of the role of
organizations, other than the Maintenance department, as it relates to
Maintenance Preventable Functional Failures (MPFF)s.
The licensee was
currently in the process of revising Administrative Control Procedure
ACP 40AC-ENG-020-05 Rev.2, " Maintenance Rule (10 CFR 50.65)
Implementation. " The licensee indicated that the guidance of RG 1.160,
Rev.2 Paragraph 1.2. will be incorporated in this revision.
This item
remains open.
Enclosure 2
.
1
18
!
M8.8 (00en) IFI 50-321.366/96-12-05: Followup on Licensee Actions to Provide
Performance Criteria for Structures After Industry Resolution of this
Issue. The licensee opened AIT No 96-262 with a due date of January 7.
l
l
1998.
AIT No 96-262 stated: Monitor the resolution of the structural
'
monitoring issue by the NRC and EPRI.
Once a position has been taken
i
evaluate this position and implement any corrective actions as necessary
l
to bring plant Hatch's program into compliance.
RG 1.160. Rev.2. issued
'
March 1997, paragraph 1.5. provides specific guidance in the area in
question that of monitoring structures.
The licensee indicated that a preliminary draft of RG 1.160. Rev.2. was
used for guidance to write licensee document. Structural Monitoring
Program for the Maintenance Rule. Rev.1. dated September 1996.
It
should be noted that this document was available at the time of the
October 1996 Maintenance Rule Implementation Inspection.
notwithstanding. this IFI was opened as a result of that inspection.
Of concern to the inspectors was the fact that Structural Monitoring
Program for the Maintenance Rule. Rev.1, provides condition monitoring
acceptance criteria in vague terms e.g., potential significant
structural impact, considered serious, potentially significant, possible
structural impact, and structural integrity may eventually be
compromised. Where as Regulatory Guide 1.160. Rev. 2 provides guidance
in terms of the structure's ability to meet its design basis.
This item remains open.
M8.9 Licensee Actions Associated With Other Adverse Maintenance Rule
Imolementation Inspection findings
l
a.
Insoection Scooe (40500) (62700)
'
To evaluate the licensee's actions related to identified weakness and
other negative Maintenance Rule Implementation Inspection findings, the
'
inspectors examined the following:
b.
Observations and Findings
A weakness was identified in NRC Inspection Report 50-321, 366/96-
.
12 Section M1.6, associated with fragmented documentation for
review of problems and corrective actions for the Unit 2 primary
Containment Chilled Water System.
To address this issue the
licensee included in the monthly Maintenance Rule Report reference
)
to applicable documents for the (a)(1) systems e.g.
Clearance
'
No. . Deficiency Card No. . Significant Operating Report No. .
Maintenance Work Order No.. and Licensee Event Report No.
IR 50-321, 366/96-12, Section M1.4 identified that the licensee
.
had not established adequate performance criteria for several risk
significant SSC functions. balancing reliability and
!
Enclosure 2
.
19
unavailability for those functions would not be possible.
To
address this issue, the licensee reviewed all risk significant
SSCs and assured that each system included performance criteria
i
for both reliability and availability.
The systems to which
availability criteria was added included: primary containment
isolation, feedwater and condensate. circulating water electro-
1
hydraulic contiol. primary containment chilled water, primary
containment, ansi main steam.
Many findings or deficiencies discussed in audit notes were not
.
documented as findings or entered into the licensee's corrective
action program.
The lack of documentation of findings or
deficiencies was considt. red a weakness in the lice .ee's audit
process.
Comments in tne licensee's audit space were items that
were of only minimal significance for which no response was
expected.
To address this issue the licensee stopped the practice
of including comment:3 in audit reports.
The omission of two risk significant functions from the matrix was
.
considered a weakness.
The licensee indicated that they had
evaluated the two systems. and determined that the scoping of the
Remote Shutdown Panel (RSP) was appropriate.
They indicated that
they would amend the Maintenance Rule Scoping Manual to explain
the differences between the PRA assumptions for the RSP and the
scoping of the RSP.
The diesel generator building exhaust fan
system was still under evaluation.
The licensee indicated that
this issue would require a procedure modification.
The lack of assessments for non-risk significant SSC function
.
combinations was considered a weakness.
The licensee indicated
that they were comfortable with the situation as it now exists and
anticipate no changes in this area.
Misleading guidance regarding priorities following emergent
.
failures was considered a weakness.
The licensee indicated that
with their existing software, the existing guidance was the best
available.
The failure to perform a sensitivity analysis when initially
establishing reliability performance criteria was considered a weakness.
In addition, the failure to perform additional risk ranking using
Maintenance Rule performance criteria new data was considered a minor
weakness.
The licensee indicated that after they re-analyze their
safety assessment risk model they will re-do the risk ranking and
sensitivity analysis, currently planned to be completed in the first
quarter of 1998.
1
Enclosure 2
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c.
Conclusions
The licensee's actions taken or plance associated with other adverse
maintenance rule implementation ,nspectwn findings, were generally
appropriate.
III. Enaineerina
El
Conduct of Engineering (37551)
On-site engineering activities were reviewed to determine their
effectiveness in preventing, identifying, and resolving safety issues,
events and problems.
The inspectors concluded that in general, engineering activities to
support plant operation were adequate.
E2.1 Engineerina Followuo Concerning Electrical Short Circuits
a.
Insoection Scooe (92903) (71707)
Engineering personnel informed the inspectors that a recent additional
review of control room electrical systems for motor operated valves
revealed conditions described in Information Notice (IN) 92-18:
" Potential for Loss of Remote Shutdown Capability During a Control Room
.
Fire." The inspectors observed and reviewed the activities initiated by
corporate engineering, onsite engineering and Operations personnel to
i
correct the problem,
b.
Observations and Findinas
The licensee's initial evaluation of the IN was completed on May 15.
1992, and was very limited.
This inspector observation was documented
in Inspection Report 50-321, 366/97-01.
On November 25, 1996, the
licensee initiated an engineering request to perform a reanalysis of the
IN.
The most recent findings were a result of the reviews conducted
during the reanalysis.
The IN discusses control room short circuits, referred to as hot shorts,
that could result in valve actuation during some postulated fire
conditions.
The inspectors observed that two Design Change Requests (DCR). one per
unit, were developed and 16 Fire Action Statements (FAS) were
implemented.
The inspectors observed that DCR 97-016. for Unit 1 and
97-017 for Unit 2. identified the fire area / zones, the valves, by master
parts list designation, and the electrical circuits that were affected
as described in the IN.
The DCRs were scheduled to be implemented
during the next refueling outage for each unit.
Enclosure 2
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21
The inspectors reviewed the scope of the DCRs and observed that
corrective actions were to reroute cables to eliminate the possibility
of hot shorts occurring within a cable.
The inspectors were informed
that corporate engineering was still reviewing systems and components
that were affected and that the list of concerns would be adjusted as
necessary, based upon the additional reviews.
Additional actions of the
DCR's were the following:
DCR 97-016: correct six fire area / zones.15 valves, and 16
electrical circuits for Unit 1
DCR 97-017: correct seven fire area / zones. 34 valves, and 52
electrical circuits for Unit 2
The inspectors observed that in the scope of the modifications were
valves and electrical circuits in the Residual Heat Removal (RHR), High
Pressure Coolant Injection (HPCI) Reactor Core Isolation (RCIC), and
Plant Service Water (PSW) systems.
The inspectors observed that nine of the FASs were for Unit 1. 1-97-24
25, 26. and 43 through 48. and seven for Unit 2. 2-97-59 through 65.
The inspectors observed that FAS 1-97-24, 25 and 26 were issued on April
1
10, 1997, to address the control, cable spreading. and computer rooms
,
and the remainder of the FASs were issued on May 16.
The inspectors reviewed the FASs and observed that they were issued to
cover specific fire area / zones of the plant and contained both safety
and non-safety related equipment.
Among the FAS reviewed were the
'
following:
e
1-97-025:
the FAS was issued for fire area / zone 0024B. the
computer room, and was one of the initial FAS
e
1-97-043:
the FAS was issued for fire area / zone 1203F. the 130
foot (ft.) elevation of the reactor building south,
and contains circuits for valves in the Unit 1 RHR.
e
1-97-048:
the FAS was issued for fire area / zone 1205N. the 164
ft. elevation of the reactor building heating,
ventilation, and air conditioning room, and contains a
circuit for a valve in the Unit 1 RHR system
e
2-97-062:
the FAS was issued for fire area / zone 2205N. the 164
ft. elevation of the drywell chiller room, and
contains circuits for valves in the Unit 2 RHR and
RCIC systems
!
e
2-97-065:
the FAS was issued for fire area / zone 2205F
the 130
ft. elevation of the reactor building soutt. and
!
Enclosure 2
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22
I
contains circuits for valves in the Unit 2 RHR and
j
RCIC systems
The inspectors observed that the FAS required a one hour fire watch
patrol.
The inspectors reviewed the applicable Fire Hazards Analysis
and Fire Protection Program requirements and verified that the correct
FAS were implemented.
l
The inspectors discussed this item with cor) orate and onsite management
in terms of the 31 ant being outside design ) asis.
The inspectors also
'
inquired as to t1e reportability of this item under 10 CFR 50.72 or 10 CFR 50.73.
The licensee determined the deficient conditions were not
reportable. The inspectors reviewea the licensee's non-reportability
evaluation which stated in part, that "there is no indication that the
NRC intends licensees to report under this paragraph" (paragraph
'
(a)(2)(ii) of 10 CFR 50.73 and an additional reference to NUREG-1022
Part V), " events which are merely hypothesized to occur, particularly
when the hypothesis depends upon multiple layers of incredible
assumptions." Similar rationale was used for paragraph (a)(2)(v)/(vi)
of 10 CFR 50.73.
Pending the inspectors' detailed review of the reporting requirements,
this issue is identified as Unresolved Item (URI) 50-321. 366/97-04:
Determine the Reportability of Licensee Identified Deficiencies With
Respect to IN 92-18. Potential for Loss of Remote Shutdown Capability
During a Control Room Fire.
c.
Conclusions
.
The inspectors concluded that licensee personnel were actively pursuing
a resolution of the concerns discussed in Information Notice 92-18:
Potential for Loss of Remote Shutdown Capability During a Control Room
Fire.
Unresolved Item (URI) 50-321, 366/97-04: Determine the
Reportability of Licensee Identified Deficiencies With Respect to IN 92-
18. Potential for Loss of Remote Shutdown Capability During a Control
Room Fire, was identified.
The established fire watch patrols were
appropriate.
E2.2 Review of Unit 2 Drywell-to-Torus (DW/T) Differential Pressure
a.
Insoection Scooe (37551) (71707)
The inspectors reviewed documentation and held discussions with licensee
personnel concerning the circumstances associated with the zero or low
differential pressure (DP) between the Unit 2 drywell and torus.
b.
Observations and Findinas
The operating crew on Unit 2 observed that the DW/T DP was zero or very
low compared to its value prior to the Unit 2 spring refueling outage of
l
Enclosure 2
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t
.
23
1997. A historical pattern of containment pressurization followed by
venting existed.
Based upon questions raised by the operating crew,
Nuclear Safety and Compliance (NSAC) conducted an evaluation to
l
determine the im]act of operating with a zero or discernibly small DW/T
DP.
Including w1 ether or not containment integrity existed based upon
the zero DP.
The inspectors reviewed the results of the NSAC's evaluation dated April
24. 1997.
The evaluation concluded the following:
The vacuum breakers between the drywell and torus were operable
e
with acceptable leakage characteristics,
There was no leakage from the primary containment that exceeds 10
e
CFR 50. Appendix J requirements, and
e
Low or zero DW/T DP does not impact any safety function associated
with the Primary Containment.
The NSAC's evaluation also indicated that a review of data confirmed
that the historical pattern of containment pressurization followed by
venting was observable until the drywell was inerted following the
recent Unit 2 refueling outage.
Since this refueling outage, the
drywell pressure remained fairly constant.
The licensee believes that
the fairly constant drywell pressure was due to less nitrogen leaking
into the drywell from the drywell pneumatic system as a result of the
maintenance performed on various drywell pneumatic valves during the
Spring 1997 refueling outage.
The inspectors reviewed the bases for Technical Specification (TS)
Surveillance Requiremerits 3.6.1.8.1 for the Suppression Chamber-to-
Drywell Vacuum Breakers.
The bases stated that with a closed indication
for the vacuum breakers and the DW/T DP remaining steady at zero, then
an alternate method for verifying that the vacuum breakers are closed
must be performed as outlined in the Technical Requirements Manual
(TRM), T3.6.1. , " Suppression Chamber to Drywell Vacuum Breaker Position
Indication." A review of TRM T3.6.1 by the inspectors indicated that
the alternate method was to demonstrate that the drywell-to-suppression
chamber (torus) DP can be maintained greater than 0.5 psid for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />
without makeup.
The TS 3.6.1.8 required action time for this
confirmation was within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of discovery of the condition (zero DP)
and every 14 days thereafter.
The inspectors reviewed Surveillance Procedure 34SV-T48-004-25, "Drywell
to Suppression Chamber Leakage Test." Revision (Rev.) 2.
This procedure
had temporary change 97-168 incorporated on April 24, 1997, to add the
14 day requirement for DW/T torus vacuum breaker leakage test when
i
operating at zero DP between the drywell and torus.
The license is
l
performing this surveillance recommended every 14 days due to the zero
or discernibly l w drywell to torus DP.
!
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Enclosure 2
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[
24
The inspectors discussed with Operations supervision the use and testing
'
of the drywell/ torus differential pressure system. This system was
sometimes referred to as the " pump back" system. The pump back system
l
was originally designed to maintain the drywell pressure slightly higher
than the torus in order to lower the water column in the downcomer pipes
that. extend into the water in the torus.
The pump back system is not
,
used now due to the installation of additional reinforcements on the
-
torus.
-
!
Engineering personnel informed the ins)ectors that Design Change Request
4
(DCR)81-109 provided information on t1e additional reinforcements
installed on the torus that reduced its-susceptibility to the higher
.
L
loadings caused by the jet forces during initial: vent clearing following
i
l
a LOCA.
The inspectors verified that this DCR implemented
.,
reinforcements of the DW/T vent header and the downcomer legs.
Engineering also stated that the components necessary for automatic
o)eration of the system were " retired in place" on Unit 2 and was
plysically removed on Unit 1 under DCR 84-316.
L
The inspectors reviewed Unit 2 Final Safety Analysis Re) ort (FSAR).
!
Sections 3.8.2.8.2.3. DryweT1 to Pressure Suppression C1 amber Bypass
Area Tests. Supplement 3.88. Plant Unique Analysis of Mark 1 Containment
i
System and.6.2.1.2.1.6.1. Drywell to Suppression Pool Vacuum Breakers.
'he FSAR review provided no indications of requirements for the DW/T DP
(pump back) system.
i
c.
Conclusions
The inspectors concluded that the Unit 2 operation with zero or low DU/T
differential pressure does not impact any safety function associated
-
with the Primary Containment. All TS requirements associated with
torus-to-drywell vacuum breakers were met.
E8
Hiscellaneous Engir.eering Issues (92700) (92903)
E8.1
(Closed) Violation 50-321. 366/96-14-03: Failure to Implement
Configuration Control Requirements - Multiple Examples. The licensee
,
responded to this violation by correspondence dated February 4, 1997.
Based upon the inspectors' review of licensee actions, this item is
'
closed.
<
E8.2 1 Closed) LER 50-321/97-02: Less than Adequate Procedure Results in a
Condition Prohibited by the Technical Specifications (TS). This issue
,
was discussed in irs 50-321, 366/97-01 and 50-321. 366/97-03.
Based on
the inspectors' review of licensee actions. this LER is closed.
!
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Enclosure 2
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IV Plant Support
R1
Radiological Protection and Chemistry Controls
R1.1 Observation of Routine Radioloaical Controls
a.
Inspection Scooe (71750)
General Health Physics (HP) and radiological control activities were
observed during the report period.
This included locked high radiation
area doors, proper radiological posting, and personnel frisking upon
exiting the Radiological Control Area (RCA).
The inspectors made
frequent tours of the RCA and observed activities.
The inspectors concluded that in general, radiological controls and HP
activities were adequate.
Minor deficiencies were discussed with
technicians and management personnel.
R1.2 Radioloaical Controls
a.
Insoection Scone (83750)
j
Radiological controls associated with ongoing Radioactive Waste
(radwaste) processing operations and storage areas were reviewed and
evaluated by the inspectors.
Reviewed 3rogram areas included container
labels, area postings, high and locked-ligh radiation area controls, and
procedural and Radiation Work Permit (RWP) guidance.
Established
program controls and their implementation were compared against Updated
Final Safety Analysis Report (UFSAR) details and documented requirements
in ap)licable sections of Technical Specifications (TSs), and
During the week of June 23. 1997, the inspectors made frequent tours of
the RCAs.
External and internal exposure controls and contamination
i
controls associated with specific radwaste processing and storage areas
were observed and evaluated in detail.
In particular, radiation control
activities associated with inspection and replacement of the Unit 1 (U1)
condensate filter elements performed in accordance with Maintenance Work
Order (MWO) Number (No.) 19701437. and RWP No. 097-0021. Rebuild \\ Replace
Filter Demins and Support. Revision (Rev.) 0, dated January 3. 1997.
were reviewed and discussed with responsible Health Physics (HP) staff
and supervisors.
The inspectors directly observed worker performance
and discussed results of radiation and contamination surveys conducted
for selected equipment and facility areas.
b.
Observations and Findinas
High and locked-high radiation area controls were verified to be
implemented in accordance with TS requirements.
Postings for
radiologically controlled areas were proper and in accordance with TS or
j
Enclosure 2
_ _ _ _ . _ _ . _ . _ _ _ _ . _ _ _ _ _ . . _ _
.
,
26
10 CFR 20 Subpart J requirements.
Containers holding radwaste,
contaminated materials and equipment were labeled in accordance with
,
10 CFR 20.1904 requirements.
Excluding U1 condensate maintenance
activities, radiation controls associated with ongoing radwaste.
processing, storage and shipping operations were adequate and conducted
in accordance with ap)licable RWPs and procedures.
In addition,
cleanliness and houseceeping within the radwaste processing and storage
1
areas.were considered to be acceptable.
i
During-facility tours on June 26. 1997, the inspectors observed the
'
following poor radiological and contamination control practices
associated with the U1 condensate demineralizer filter maintenance.
During disassembly of a containment tent used as an engineering control
tc prevent spread of airborne contamination. two workers were observed
.
standing in two 55 gallon drums located within the roped-off
contaminated work area.
The workers were physically stomaing on the
materials within the barrels to enhance com) action.
At t7e same' time,
!
rollup door T15 to the area was open, there)y allowing air flow into and
across the potentially contaminated work area into a non-coritmiiinated
t
area.
No engineering controls were established, no representative air
samples were collected, nor was the work performed under continuous HP
coverage.
Cognizant licensee representatives informed the inspectcrs
that the materials within the drums consisted of potentially
.
contaminated fabric which had been used to construct the tent
,
surrounding the U1 condensate filter maintenance area.
Subsequently,
'
the inspectors were informed that eight workers associated with the U1
condensate filter work activities were determined to be contaminated
externally, 3000 to 30000 disintegration per minute per probe area,
,
after conducting RCA exit surveys.
No' internal contamination was
detected for whole body counts conducted on the affected workers.
Gross
I
contamination surveys, large area masslin wipes, for areas outside of
'
the U1 condensate work area indicated contamination levels of 1000 to
.
100000' disintegration per minute per masslin wipe.
,
Review of the applicable RWP guidance and discussions of worker
knowledge with responsible HP personnel indicated that maintenance
!
workers were expected to be aware of potential contamination of the
enclosure material based on previous work experience.
Thus, disassembly
of the enclosure prior to completion of contamination surveys and decon
activities was not expected by the HP staff.
Based on their previous
similar work experience, the involved workers were expected to
understand precautions to minimize spread of contamination including
)
proper compaction of-contaminated material and preventing air flow
across a contaminated area.
In addition, the HP technician providing
i
'
intermittent coverage in accordance with the RWP was not informed that
the workers were going to dismantle the enclosure.
TS 5.4 recuired that written procedures be established implemented, and
maintainec covering activities delineated in Ap3endix A of Regulatory
Guide (RG) 1.33. Rev. 2. dated February 1978.
Enclosure 2
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27
Appendix A " Typical Procedures for Pressurized Water Reactor and Boiling
Water Reactors " Paragraph 7.e required radiation protection proradures
for Radiation Work Permit System and for Contamination Control.
Hulth
Physics procedure 60AC-HPX-004-05 " Radiation and Contamination
Control." Rev. 14. effective October 15, 1996, specified that HP will
take measures to minimize migration of high contamination to low or
uncontaminated areas: will initiate controls, to ensure the spread of
contamination is minimized: will perform non-routine radiation and
contamination surveys as required, to support operation and maintenance:
and will perform airborne surveys during radioactive work which is
expected to cause airborne radioactivity unless constant air monitors
are provided.
The inspectors identified the failure to implement proper
contamination controls, surveys and HP coverage for dismantling of the
U1 condensate demineralizer filter tent as an example of Violation (VIO)
50-321/97-05-01: failure to follow procedures - multiple examples.
c.
Conclusions
Radiological controls for high and locked-high radiation areas were
maintained in accordance with TS requirements
Contamination control associated with plant operation and maintenance
activities continued to be a program weakness with a violation of NRC
requirements identified.
The violation was an example of violation 50-
321, 366/97-05-01. Failure to Follow Procedure - Multiple Examples.
R1.3 Radioactive Waste and Material Transoortation Activities
'
a.
Insoaction Scope (86750. TI2515/133)
The incpectors reviewed RC program activities associated with packaging
and shipping of radioactive material and waste to either vendor
processing facilities or directly to a licensed burial facility.
The
review included evaluation and verification of radwaste classification
activities, and review of shipping documents.
In addition. the
inspection verified and evaluated implementation of revised 49 CFR Parts
100-179 and 10 CFR Part 71 regulations.
Records for radwaste and material shipments made between April 1 through
June 23, 1997, were reviewed and discussed.
In particular. selected
documentation associated with the following shipments were reviewed and
discussed with responsible licensee representatives.
e
Shipment No. 97-6007. Radioactive material. Low Specific Activity
(LSA). n.o.s.
7 UN2912. Fissile Excepted. April 28, 1997.
e
Shipment No. 97-1010. Radioactive material. LSA, n.o.s. 7. UN2912.
l
Fissile Excepted RQ. April 30, 1997.
l
Enclosure 2
.
28
e
Shipment No. 97-1012, Radioactive material . LSA. n.o.s. 7. UN2912.
Fissile Excepted. May 7. 1997,
e
Shipment No. 97-1014 Radioactive material . LSA
n.o.s. 7. UN2912.
Fissile Excepted R0. May 23. 1997.
Procedural guidance specified in Radiation Protection (RP) procedure.
62RP-RAD-011-05. " Shipment of Radioactive Material ." Rev.10. effective
June 23. 1997, was reviewed and evaluated against ap]licable
requirements in 10 CFR Part 20, 10 CFR Part 61. 10 C R Part 71 and the
revised 49 CFR Parts 100-179 and 10 CFR Part 71 regulations.
b.
Observations
The licensee's procedural guidance met applicable regulatory
requirements.
Recent revisions to 49 CFR Parts 100-179 and 10 CFR Part 71 regulations were implemented as required.
The inspectors verified
that changes to 49 CFR Parts 100-179 and 10 CFR Part 71 regulations were
incor] orated into approved procedures and implemented as required.
For
the slipping records reviewed, the inspectors verified that shipping
paper documentation was completed arid maintained as specified.
c.
Conclusions
Transportation activities for radwaste and material shipments met
10 CFR 71.5 and recently revised Department of Transportation (DOT)
1
49 CFR 100-179 requirements.
R2
Status of Radiological Protection and Chemistry Facilities and Equipment
R2.1 Radiation Monitor System Calibrations
a.
Insoection Scone (84750)
The inspectors reviewed and evaluated the adequacy of calibration
guidance and resultant data for selected Radiation Monitoring System
(RMS) process and area detectors.
Selected source and electronic
calibration data were reviewed and discussed for the following Unit 2
systems: drywell wide range monitor A and B. i.e., the Containment High
Range Monitors (CHRMs): liquid process: main steamline monitors and
main stack gaseous effluents.
The RMS calibration guidance and results were evaluated against
applicable sections of the FSAR, Technical Specification (TS) and
Offsite Dose Calculation Manual (ODCM) requirements.
In addition,
guidance for the CHRMs was compared against special calibration
requirements specified in NUREG 0737. Clarification of Three Mile Island
I
(TMI) Action Plan Requirements. Table II.F.1-3 Containment High Range
l
Monitors (CHRMs).
l
Enclosure 2
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29
l
b.
Observations and Findinas
Excluding the CHRMs. no calibration concerns were identified.
Surveillances were conducted at the required frequencies and the
reported results were acceptable.
For the CHRMs data, the inspectors noted that the source used to conduct
the in situ calibration met the 1 -10 R/hr range specified in NUREG 0737. Table II.F.1-3.
However, the in situ calibration by electronic
signal substitution as specified in procedure 57SV-CAL-007-2S "Drywell
High Range Radiation Monitor Loop Calibration." Rev.1. was conducted
for four and not all of the six range decades above 10 Roentgens per
hour (R/hr) as specified in NUREG 0737. Table II.F.1-3.
Based on a
review of a similar issue at another Southern Nuclear Operating Company
nuclear facility, licensee representatives concluded that their test
data for four ranges demonstrated operability of the monitor.
Further.
no changes were made to meet the explicit requirements outlined in
,
NUREG 0737. Table II.F.1-3.
Licensee representatives were unaware if an
exemption was requested from meeting the specific requirements of
NUREG 0737. Table II.F.1-3. but planned to review appropriate licensing
information, and provide that information to the inspectors.
The
inspectors noted that the adequacy of their review of procedure guidance
to meet the ex) licit recuirements of NUREG 0737. Table II.F.1-3 would be
considered an Jnresolvec Item (URI) 50-321, 50-366/97-05-05, evaluate
adequacy of CHRMs electronic signal substitution calibrations following
additional review of the licensee response to Generic Letters 82-05 and
82-10 dated March 17, 1982 and May 5. 1982. respectively.
c.
Conclusions
In general. RMS equipment was calibrated appropriately.
The adequacy of the licensee's review to meet the CHRMs electronic
signal substitution to meet NUREG 0737 requirements was identified as an
URI: 50-321, 366/97-05-05: evaluate adequacy of CHRMs electronic signal
substitution calibrations following additional review of the licensee
commitments.
R3
Radiation Protection and Chemistry Documentation (83750, 84750)
a.
Insoection Scooe (83750. 84750)
The 1996 Annual Radiological Environmental 0)erating Report required by
TSs 5.6.2 and conducted in accordance with tie Section 4 of the ODCM
were reviewed and discussed with licensee representatives.
In addition,
results of the 1996 Anriual Radioactive Effluent Release Report submitted
in accordance with 5.6.3 were discussed in detail.
l
l
l
Enclosure 2
30
In addition, the inspectors reviewed recent licensee evaluations
regarding a potential unmonitored liquid release pathway through the
Residual Heat Removal Service Water (RHR SW) heat exchanger system.
b.
Observations and Findinas
The inspectors verified that the 1996 Annual Radiological Environmental
Monitoring Program was implemented appro)riately and the report was
3repared and submitted in accordance witi TS and ODCM specifications.
- or two radionuclides. Manganese-54 and Cobalt-60. measured in shoreline
sediment a few miles downstream of the plant discharge, doses were
insignificant fractions of the ODCM limits and represented
inconsequential doses to the environment and public.
No discernible
offsite effect was demonstrated from plant discharges to the environs.
The 1996 Annual Radioactive Effluent Release Report was submitted in
accordance with TS and ODCM requirements.
In general
1996 calculated
doses from effluents were less than 3 percent of the ODCM limits.
No
unplanned releases were identified in the report.
A licensee 10 CFR 50.59 screening evaluation was conducted for a
Jotential unmonitored liquid effluent release pathway through the RHR SW
leat exchanger system.
The licensee's evaluation determined that
potential release pathway would have negligible effect on offsite dose
results for both normal ard accident conditions.
The inspectors
verified ' hat appropriate administrative controls and sampling were
established to ensure any releases were monitored properly and were
within 10 CFR limits.
c.
Conclusions
,
Licensee programs to control, monitor and document liquid and airborne
radionuclide effluent releases were maintained and implemented properly.
'
The Radiological Environmental Monitoring Program sampling analysis and
reporting requirements were implemented effectively and demonstrated
minimal environmental impact.
Projected offsite doses resulting from effluents were well within the
limits specified in the Offsite Dose Calculation Manual and 40 CFP, 190.
R4
Staff Knowledge and Performance in Radiation Protection and Chemistry
R4.1 Maintenance Worker Contamination - Unit 1
a.
Inspection Scooe (92902) (92904l
On May 23. 1997, a maintenance worker became contaminated while
!
l
performing work activities in the Unit 1 torus area.
The inspectors
reviewed MWO 1-97-1186. Repair Leak per Attached Weld Sketch, radiation
work permits 097-0002 and 097-0003. procedures 51GM-MNT-025-05. " General
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Enclosure 2
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31
Welding Requirements For Pressure Boundary Applications," Rev. 4. ED 1,
50AC-MNT-001-05 " Maintenance Program." Rev. 24, 60AC-HPX-004-05.
" Radiation and Contamination Control." Rev. 14, 42FP-FPX-004-05, " Fire
Protection Reviews,~ Rev. 5, and Significant Occurrence Report, SOR
C09702718.
b.
Observations and Findinas
A welder was assigned to conduct a welding repair for a 1.5 inch crack
on a clean radiological waste pipe in the Unit 1 torus area. The
craftsman contacted HP personnel and was told that the area was
contaminated.
The craftsman and a fire watch dressed out in full anti-
contaminated clothing and proceeded to conduct the welding repairs.
After about 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of work the personnel exited the area for lunch.
Both workers conducted a contamination check using the personnel
contamination monitors.
The monitors alarmed indicating both workers
were contaminated.
A short time later, one worker was able to exit with
no contamination indicated.
The second worker was given a whole body
frisk which indicated contamination levels of 95,000 disintegrations per
minute (dpm) on his left shoe, 58,000 dpm on his face and 29,000 dpm on
his forearms.
After four showers, the contamination levels were reduced
to 6,000 dpm on his face. 4,000 dpm on his forearms and his shoes were
disposed of in radioactive trash.
The worker was excluded from the site and was allowed to go home with no
further decontamination.
HP personnel completed a personnel
contamination report and conducted bioassay analysis.
The analysis and
dose calculations revealed that the committed effective dose equivalent
was less than 1 millirem.
The post-event area survey report showed that
smearable contamination levels were as high as 120 mrad /100 square
centimeters.
HP personnel concluded that the smearable levels clearly
exceeded the capacity of single cotton protective clothing considering
the wet working conditions.
l
The inspectors observed that MWO 1-97-1186 specified that the work be
l
performed using RWP 097-0002.
The inspectors reviewed the RWP and
observed that the work conditions specified were routine breach, minor
i
mechanical / electrical /I&C support work.
The inspectors observed that
i
another section of the RWP indicated that no breach was allowed using
l
the protective clothing listed on the RWP.
It was management's
!
expectation that workers contact HP to discuss their specific job to
ensure HP coverage is correct.
The inspectors observed that the RWP was
'
not adequate for the specific work that was identified on the MWO
(welding under wet conditions).
i
l
The inspectors also observed that the RWP was written to cover multiple
!
conditions.
For example, the RWP specified that under certain
conditions booties, gloves, scrubs and hard hat may be appropriate.
Other work conditions listed were boots and gloves to inspect, if
conditioris allow, no protective clothing required for clean areas, and
Enclosure 2
l
1
_
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,
.
32
scrubs and single protective clothing may be appropriate for other work.
The inspectors observed that the RWP was written to cover multiple work
conditions and the individual worker was to determine if his specific
work condition was covered by the RWP. The inspectors observed that
broad based RWPs were a common practice.
The inspectors observed that the maintenance personnel who performed the
i
work did not use RWP 097-0002, which was specified on the MWO.
Instead.
l
RWP 097-0003 was used.
The inspectors observed that the work specified
on this RWP. in part, miscellaneous maintenance (no breach), inspection,
vibration readings, oil samples / add oil, crane movement, shaft voltage
reading, fire watch in high radiation / contamination areas. The
inspectors observed that the "WP was not adequate for the welding work
that was identified on MWO 1-97-1186. This RWP was also written in
broad terms similar to RWP 097-0002.
l
The inspectors were informed that HP staff personnel reviewed MW0s and
!
determined what RWPs should be used to conduct the specified work
l
activity.
In this case, an RWP update survey was requested by
,
!
scheduling personnel about two days prior to the scheduled work. The
i
updated survey was not performed and updated results were not available
i
for use. The inspectors were informed that the maintenance personnel
contacted the HP office and inquired about the radiological conditions
of the torus area.
HP personnel used a survey completed on May 19 and
j
informed the maintenance personnel that the contamination levels were
i
less than 1000 dpm per 100 square cm and that a single dress out of
j
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protective clothing would be sufficient. The inspectors were informed
'
that the maintenance personnel did not inform HP about the ty)e of work
j
to be performed (welding) or the extent of the job scope and iP
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personnel did not inquire about the work. The inspectors concluded that
poor communications may have contributed to the problem.
j
The inspectors were informed that the HP technician usually assigned to
this maintenance team was not at work on the day these maintenance work
activities occurred and that this may have contributed to the problem.
l
The inspectors concluded that obtaining radiological work conditions to
ensure proper HP coverage for the assigned work was a fundamental work
'
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requirement that was not performed.
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,
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The inspectors considered maintenance personnel failure to discuss the
planned work and job scope with HP personnel. to ensure that correct
radiological controls and processes were inplace for the ' signed work,
a failure to follow ste) 4.2.19 of procedure 50AC-MNT-001-oS.
" Maintenance Program."
Rev.24.
The procedure step required in aart.
that part of the responsibilities to implement the Maintenance
3rogram
.
was to identify the requirements for RWPs for authorized work.
Additionally. HP personnel failed to demonstrate a questioning attitude
with respect to determining what work was to be performed to ensure HP
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coverage and RWP requirements were adequate.
This was identified as a
negative observation.
Enclosure 2
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33
The inspectors reviewed Significance Occurrence Report (SOR) C09702718
and observed that the report included root cause determination and
recommended corrective actions.
The root cause section of the report
stated in part, that the root causes were 1) inadequate communications
on the nature of the work between Maintenance and HP personnel. 2) upon
finding wet conditions, the worker did not notify HP personnel to
reassess the dress requirements. 3) HP technician assigned to the shift
team was on vacation contributing to the communications barrier.
The
inspectors concluded that the root causes identified were reasonable.
The inspectors followed up on deficiencies identified during their
review of the problem to determine if the deficiencies were identified
during the licensee's review for the SOR.
The ins)ectors observed that
l
no deficiencies were written for the following pro]lems.
The craftsman did not use the RWP specified on the MWO.
e
The RWP used by the craftsman was not adequate for the job.
e
The RWP specified on the MWO was not adequate for the job.
e
Although the SOR adequately identified the root cause of the
,
contamination problem, the reviewers failed to identify and document
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other deficiencies. This was identified as a negative observation in
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the use of the deficiency card program.
The inspectors observed that there has been several recent individual
contamination events.
The inspectors questioned management personnel
about the 3erformance of HP personnel assigned to the maintenance teams.
A recent clange, since the implementation of maintenance teams, was that
HP coverage for maintenance work is generally provided by HP technicians
assigned to the particular maintenance team.
However, additional HP
personnel are available to provide additional support if needed.
The
inspectors were informed that an Event Review Team (ERT) was assigned to
review this particular contamination problem as well as other recent HP
and contamination problems.
The ERT was to determine if programmatic or
common problems exist for the events and to make recommendatior..; to
management for corrective actions.
This aspect of personnel
contaminations was identified as IFI 50-321, 366/97-05-03: Review of
Licensee's Root Cause Determination and Corrective Actions for Personnel
Contaminations.
c.
Conclusions
The inspectors concluded that a failure to implement maintenance
procedures to ensure that Radiological Work Permit requirements and
Health Physics coverage was adequate for the assigned work activity was
a violation for failure to follow procedure.
This violation was
identified as an example of VIO 50-321, 366/97-07-01: Failure to Follow
Procedure - Multiple Examples.
A negative observation was identified
for Health Physics personnel failure to demonstrate a questioning
attitude to ensure radiological controls were adequate for an assigned
l
Enclosure 2
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34
,
,
work activity and for the failure of personnel to identify and document
.
several deficiencies surrounding the personnel contamination.
R5
Staff Training and Qualifications in Radiological Protection and
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Chemistry
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R5.1 Hazardous Material Trainino
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a.
Insoection Scone (86750. TI 2515/133)
l
Training provided to meet the requirements of 49 CFR Part 172 Subpart H
were reviewed and discussed with licensee representatives.
,
b.
Observations and Findinas
From review of training records, the ins)ectors verified that hazmat
training was provided to a new radwaste iP foreman.
From review of
training material presented. the inspectors confirmed that recent DOT
changes to shipping and packaging requirements were included in the
,
i
training.
c.
Conclusions
Appropriate hazmat training was provided to personnel handling and
,
packaging radioactive materials for transport.
R7
Quality Assurance in Radiation Protection and Chemistry Activities
.(83750, 84750)
R7.1 Audits
a.
Insoection Scooe (83750)
The inspectors reviewed and discussed audits of Health Physics.
Chemistry and Radioactive Waste program areas.
l
The inspectors reviewed and discussed the following Safety Audit and
Engineering Review (SAER) reports:
e
Audit Report 97-CH-1. Audit of Chemistry, dated March 12, 1997.
l
e
Audit Report 97-RW-1. Audit of Radioactive Waste Program, dated
March 25, 1997.
e
Audit Report 97-HP-1. Audit of Health Physics & Radiation
Protection Program dated June 2. 1997.
I
i
The inspectors assessed the scope, thoroughness and status of corrective
1
actions of the audits.
.
I
Enclosure 2
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1
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b.
Observations and Ft,dinas
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Audits consisted of interviews. record review and direct observations by
l
qualified audit personnel.
Audits were performance-based and the audit
contents were adecuate samples of program attributes.
The inspectors
verified that fincings were characterized appropriately in the reports,
were reviewed by licensee management and corrective actions appeared
adequate and timely.
c.
Conclusions
Audits of chemistry, radwaste and radiological control programs were
thorough and findings were corrected in a timely manner.
R7.2 Effluent Measurement and Radioloaical Environmental Monitorina Proaram
Ouality Control Activities
a.
Insoection Scooe (83750)
Counting room instrumentation quality control checks were reviewed and
discussed.
Minimum Detectable Concentrations (MDCs) for selected gaseous and
particulate radionuclides in airborne effluents were verified against
limits detailed in the ODCM.
Pesults of the 1996 Inter-laboratory Comparison Program for the
Radiological Environmental Monitoring Program (REMP) as required by
Section 4 of the ODCM were reviewed and discussed.
b.
Observations and Findinas
Quality control daily checks to verify system performance were conducted
for counting room instrumentation in accordance with licensee
procedures.
Based on detector efficiencies, sample volume and counting
'
time, the MDCs for the radionuclides reviewed met the established
detection criteria for airborne effluent measurements.
The inspectors noted and discussed the poor performance in REMP OC
analysis results. The report documented numerous examples of the cross-
check samples which were processed by an approved off-site laboratory
which exceeded normalized range or deviation warning and control limits.
The inspectors noted that no site representatives were knowledgeable of
the specific corrective actions being taken in regard to the REMP OC
sample analysis results.
Subsequent discussions indicated that
corrective actions appeared appropriate.
l
Enclosure 2
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c.
Conclusions
Counting room QC activities were conducted in accordance with approved
procedures and demonstrated detector and analysis system operability.
Supervisory oversight of the REMP OC activities by site personnel were
minimal.
R8
Miscellaneous Radiation Protection and Chemistry Issues (92904)
R8.1
(Closed) Insoection Followuo Item (IFI) 50-321. 366/96-10-10: review
licensee evaluations regarding gas geometry QC sample analyses and main
steam line monitor response biases.
In response to a lack of a gas QC
analysis in the laboratory QC program, procedure 64CH-0CX-001-05.
~ Quality Control for Laboratory Analysis." Rev. 3. Attachment 10 was
revised to include quantitative analysis of a gas quality control cross-
check sample on a biennial frequency.
For identified biases regarding
the main steamline monitors, the licensee procured a new NBS traceable
calibration source for calibration activities.
Results of the most
recent U2 MSL calibrations verified a significant reduction in the
identified bias.
Licensee representatives stated that additional
modifications to existing equipment were being evaluated to allow
adjustments to the system thereby improving accuracy of the readings.
Based on licensee actions, the inspectors noted this item would be
considered closed.
S2
Status of Security Facilities and Equipment (71750)
The inspectors toured the protected area and observed that the perimeter
'
fence was intact and not compromised by erosion nor disrepair.
The
fence fabric was secured and barbed wire was angled as required by the
licensee's procedures.
Isolation zones were maintained on both sides of
the barrier and were free of objects which could shield or conceal an
individual.
The inspectors observed that personnel and packages
entering the 3rotected area were searched either by special purpose
detectors or )y a physical patdown for firearms, explosives and
Badge issuance was observed. as was the processing and
escorting of visitors.
Vehicles were searched, escorted and secured as
described in applicable procedures.
The ins)ectors concluded that the areas of security inspected met the
applica)1e requirements.
V. Manaaement Meetinas
X.2
Review of UFSAR Commitments
1
A recent discovery of a licensee operating their facility in a manner
contrary to the Updated Final Safety Analysis Report (UFSAR) description
highlighted the need for a special focused review that compares plant
Enclosure 2
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37
practices, procedures and/or parameters to the UFSAR description.
While
performing the inspections discussed in this re) ort, the inspectors
reviewed the applicable portions of the UFSAR tlat related to the areas
inspected.
The inspectors verified that the UFSAR wording was
consistent with the observed plant practices, procedures, and/or
parameters.
X.3
Exit Meeting Summary
The inspectors presented the inspection results to members of the
licensee management at the conclusion of the inspection on July 11.
1997. The license acknowledged the findings presented. An interim exit
was conducted on June 6 and 27, 1997.
The inspectors asked the licensee whether any materials examined during
the inspection should be considered proprietary.
No proprietary
information was identified.
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4
Enclosure 2
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
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Anderson, J. , Unit Superintendent
Betsill. J.
Assistant General Manager - Operations
!
Breitenbach, C. Engineering Support Manager - Acting
Curtis. S.
Unit Superintendent
{
.
Davis., D.
Plant Administration Manager
Fornel. P.
Performance Team Manager
J
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Fraser. 0.. Safety Audit and Engineering Review Supervisor
Hammonds. J. , Operations Support Superintendent
Kirkley.
W.. Health Physics and Chemistry Manager
Lewis, J., Training and Emergency Preparedness Manager
Madison. D., Operations Manager
Moore
C.. Assistant General Manager - Plant Support
l
Reddick. R.. Site Emergency Preparedness Coordinator
'
Roberts. P., Outages and Planning Manager
Thompson,
J., Nuclear Security Manager
'
Tipps.
S., Nuclear Safety and Compliance Manager
Wells. P.. General Manager - Nuclear Plant
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 40500:
Effectiveness of Licensee Controls in Identifying. Resolving, and
Preventing Problems
IP 61726:
Surveillance Observations
IP 62700: Maintenance Implementation
IP 62707:
Maintenance Observations
IP 71707:
Plant Operations
IP 71750:
Plant Support Activities
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IP 83750:
Occupational Radiation Exposure
IP 84750:
Radioactive Waste Treatment, and Effluent and Environmental
Monitoring
IP 86750:
Solid Radioactive Waste Management and Transportation of
Radioactive Materials
IP 92700:
Onsite Follow-up of Written Reports of Nonroutine
Events at Power Reactor Facilities
IP 92901:
Followup - Operations
IP 92902:
Followup - Maintenance / Surveillance
IP 92903:
Followup - Followup Engineering
IP 92904:
Followup - Plant Support
TI 2515/133:
Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71
Enclosure 2
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ITEMS OPENED. CLOSED. AND DISCUSSED
Ooened
50-321. 366/97-05-01
Failure to Follow Procedure - Multiple Examples
50-321. 366/97-05-02
IFI
Installation of the Wrong Type of Connector on
Wide Range Monitor 011K621A
50-321, 366/97-05-03
IFI
Review of Licensee's Root Cause Determination
and Corrective Actions for Personnel
Contaminations
50-321, 366/97-04
Determine the Reportability of Licensee
Identified Deficiencies With Respect to IN 92-
18. Potential for Loss of Remote Shutdown
Capability During a Control Room Fire
50-321, 366/97-05-05
Evaluate licensee review and actions regarding
current CHRMS electronic calibration against
licensee commitments to meet NUREG 0737 Item
II.F.3-1
Closed
50-321. 366/96-14-04
IFI
potential deficiencies in the High Pressure
Coolant Injection (HPCI) surveillance procedure
50-321. 366/96-14-03
failure to implement configuration control
'
requirements - multiple examples
50-321, 366/96-15-03
IFI
resolution of RCIC HPCI turbine speed control
drift
50-321. 366/96-12-03
Failure to Follow Procedure for Implementation
of the Maintenance Rule.
50-321, 366/96-10-10
IFI
Review Licensee Evaluations Regarding Gas
Geometry QC Sample Analyses and Main Steam Line
Monitor Response Biases.
50-321/97-02
LER
Less than Adequate Procedure Results in a
Condition Prohibited by TS.
Discussed
50-321. 366/96-12-01
Failure to Include Ali Structures. Systems, and
Components in the Scope of the Maintenance Rule
!
as Required by 10 CFR 50.65
1
Enclosure 2
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50-321, 366/96-12-02
Failure to Establish Adequate Performance
Criteria for S.C. Risk Significant Functions
50-321. 366/96-12-04
IFI
Failure to Provide Acequate Procedure for
Implementation of Maintenance Rule Requirements
j
50-321. 356/96-12-05
IFI
Followup on Licensee Actions to Provide
Performance Criteria for Structures After
Industry Resolution of this Issue
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Enclosure 2
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a