ML20198N996

Insp Repts 50-348/97-14 & 50-364/97-14 on 971019-1129. Violations Noted.Major Areas Inspected:Operations, Engineering,Maintenance & Plant Support

ML20198N996
Person / Time
Site:	Farley
Issue date:	12/29/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198N914	List: ML20198N909 ML20198N948 ML20198N996
References
50-348-97-14, 50-364-97-14, NUDOCS 9801210292
Download: ML20198N996 (36)

See also: IR 05000348/1997014

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U.S.-NUCLEAR REGULATORY COMMISSION.(NRC); i

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-REGION II ,

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Docket Nos: - 50-348 and 50-364' ,

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License Nost NPF-2 and NPF 8' '

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' Report No: _50-34d/97-14 and 50-364/97-l'4-

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'Licenseci -Southern Nuclear Operating Company (SNC) ,

Facility: Farley Nuclear! Plant (FNP) ' Units ~1 and 2

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~ Locat'an: .7388 North State Highway 95

Columbia. AL 36319-  :

Dates: l0ctober-19_through November'29. 1997

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Inspectors: T. Ross. Senior Resident Inspector (SRI)

J Bartley. Resident-Inspector (RI)

R. Caldwell. RI:

G. Kuzo.. Region II.- Health Physics Inspector _ _

(Sections R1.1. R1.2. R1.3. R1.4.-R1.5, R3.1. -

-R8.1,.R8.2. and:R8.3)

N. Merriweather. Region II, Reactor Inspector

.(Section E8.1)

Approved by: J. Johnson. Director

Division of Reactor Projects

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EXECUTIVE SUMMARY

Farley NLlear Power Plant. Units 1 and 2

NRC fnspection Report 50-348/97 14. 50 364/97-14

This integrated inspection included aspects of licensee operations,

engineering, maintenance, and plant support. The report covers a 6-week

period of onsite resident inspector inspections.

Doerations

e Operator attrntiveness to main control board (MCB) annunciator alarms

and response to changing plant conditions were pronpt. Management's

persistent efforts to reduce the number of MCB deficiencies and achieve

" blackboard" remained evident. Operating crews demonstrated a high

level of awareness of plant conditions and ongoing activities. Shift

supervisor command and control functions and operations management

oversight ware evident (Section 01.1).

e Overall material conditions for Unit 1 and Unit 2 structures. systems

and components (SSCs) were good. However, physical and material

conditions of the service water intake structure (SWIS), especially the

lower level, have degraded (Section 02.1).

• Safety system walkdowns and tours verified that accessible portions of

selected systems were adequately maintained and operational

(Section 02.2).

• Safety tagging activities were correct and met procedural requirements

(Section 02.3).

e A non cited violation (NCV) was identified for inadequate implementation

of the cold weather protection procedures. In addition, an Operations

supervior and management on day shift were not well-informed about the

progress of the procedures (Section 02.7).

Maintenance

o Maintenance and surveillance testing activities were generally conducted

in a thorough and competent manner by qualified individuals in

accordance with plant procedures and work instructions (Section M1.1),

e A NCV was identified for maintenance technicians failing to sign off

steps in " Continuous Use" procedures as they were accomplished

(Section M1.1).

• The 1-2A Diesel Generator maintenance outage was performed oy well

qualified and knowledgeable personnel. Corrective action efforts were

thorough. Post maintenance testing was satisfactorily comp hted

(Section M1.2).

Enclosure 2

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e A violation was identified for failure to take adequate corrective

actions to maintain the main steam valve room cork seal flooding barrier

(Section M8.1).

• Licensee corrective actions to date to address multiple pre-action

s)rinkler system failures identified in 1996 have been comprehensive.

taorough and generally successful. An additional corrective action plan

has been initiated to resolve the small number of remaining failures

(Section M8.2).

• A non cited violation was issued for failure to follov; work control

.rocedures

, which resulted in inoperability of automatic turbine building

isolation (Section M8.4).

Enaineerinq

e Licensee management met with the NRC in Rockville. Maryland to discuss

currer.t progress and schedules c' .he Steam Generator Replacement

Projects fcr the Unit I during Spring 2000 and Unit 2 during Spring

2001. During the meeting the licensee provided a comprehensive summary

presentation of its schedule. scope of work, organization, proposed

licensing submittals, and engineering plans (Section El.1).

• A violation was identified for lack of tornado missile protection for

the Turbira-Driven Auxiliary feedwater (TDAFW) pump vent stack.

(Section E8.1)

Plant Support

e Radiological controls. area postings and container 16 oles were

maintained in accordance wit 1 Technical Specification (TS) and

10 CFR 20. Anpendix J requirements. Improvements were noted for

Radiological Controlled Area housekee)ing and cleanliness and for

Radiological Work Permit practices. Revisions to local area radiation

survey map for the Unit 1 SFP area were timely. For UlRF14 outage,

ALARA program activites were implemented in accordance with approved

procedures. Actual UlRF14 outage dose expenditure exceeded original

estimates and resulted from an increased scope of steam generator

maintenance activities (Section R1.1).

e Worker deep dose equivalent (DDE) and shallow dose equivalent (SDE)

exposures resulting from aersonnel contamination events and work

activities during the UlR 14 outage were evaluated properly and were

within 20 CFR 20.1201 limits (Section Rl.2).

e (.antrols for minimizing workers' internal exposure were effective

(Section Rl.3).

• Surveillance requirements for the inoperable U1 RE-60B monitor were

completed in accordance with approved procedures (Section R1.4).

Enclosure 2

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e Licensee program guidance for transportation of radioactive waste and

materials met 10 CFR 71.5 and recently revised DOT 49 CFR Parts 100-179

requirements. Transportation program guidance was implemented

effectively (Section RI.5).

• Records for <ietermining workers' prior yearly occupational exposures and

granting extensions to administrative exposure limits were established

in accordance with 10 CFR Part 20. Subpart L requirements and

administrative procedures (Section RJ.1).

• A NCV was identified for Failure to Conduct Compensatory Grab Sampling

for inoperable Unit 2 Containment Atmospheric Radiation Monintoring

System in accordance with TS 3.4.7.1 (Section R8.3).

• Licensee corrective actions for failing to staff the Emergency

0)erations facility (EOF) within the required time frame were prompt and

tlorough. The licensee successfully demonstrated the ability to

activate the alternate EOF (Section Pl.1).

e S urity perconnel observed during the inspection period were attentive

tt their res :sibilities. Site security systems were adequate to

ensure physical protection of the plant (Section 51.1).

• A technician willfully failed to corduct at least three required

inspections, and deliberately falsified at least four checklists. This

non repetitive, licensee-identified and corrected violation was

identified as a NCV (Section P8).

Enclosure 2

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Report Details

Sumary of Plant Status

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Unit 1 operated continuously at 100% power for the entire inspection period. '

Unit 2 operated continuously at 100% power for the entire inspection period.

I. Operations

01 Conduct of Operations

01.1 Routine Observations of Control Room Doerations

a. Insoection Scoce (71707)

Inspectors conducted frequent inspections of ongoing plant operationc in

the Main Control Room (MCR) to verify proper staffing. operator ,

attentiveness. adherence to approved operating procedures,

communications, and command and control of operator activities.

Inspectors reviewed operator logs and Technical S)ecification (TS)

Limiting Conditions of Operation (LCO) tracking sleets, walked down the

Main Control Boards (MCBs), and interviewed members of the operating

shift crews to verify operational safety and compliance with TSs. The

inspectors frequently attended morning plant status meetings and shift

turnover n' tings to maintain awareness of overall facility operations,

maintenaru act. . ities, and recent plant evolutions. Horning reports

and Occurrence Reports (OR) were reviewed on a routine basis to assure

that the licensee properly tracked. reported, and resolved potential

operational safety concerns.

b. Observations and Findinas

Overall control and awareness of plant conditions during the inspection

period remained a strength. Inspectors observed that the Unit 1 MCB

annunciators and Balance of Plant (BOP) and emergency )ower board (EPB)

alarm panels were frequently " blackboard." However, tie Unit 2 MCBs and

B0P panels continued to have some persistent annunciators lighted for

known equipment problems. Management efforts to maintain MCB

deficiencies at low levels continued. The combined MCB deficiencies on

Unit I and Unit 2 have dropped below 10. the lowest level in several

years. Most of the deficiencies involved non-safety related

instrumentation or equipment, and none resulted in a TS LCO.

0)erator attentiveness to MCB annunciator alarms and response to

clanging plant conditions were prompt and effective. Interviews with

members of the operating crew verified that they were consistently aware

of plant conditions and ongoing activities. Operator knowledge was very

good. Operator logs were of sufficient detail and scope. Shift

staffing was verified to be in compliance with procedural and TS

requirements. Pre-shift briefings of the operating crews by the shift

supervisors (SS) were generally concise, informative. and provided

Enclosure 2 >

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operators with shift direction and priorities. Shift turnovers were

'omplished in an orderly m:nner, following a board walkdown by the off going

m a on coming operators and SSs.

Routine reactivity manipulations by the o)erators (i.e., boron

dilutions of the reactor coolant system (RCS)) were observed by

the inspectors. The operators notified the applicable SS prior to

each manipulation, as required by procedure.

c. Conclusions

Control Room professionalism and communications remained good

Operatingcrewdemeanor,teamworkandconductwerebusiness-like

and effective. Unnecessary activities were kept out of the

" Controls Area." Unit SS command and control, and operations

management oversight were evident.

0)erator attentiveness to MCB annunciator alarms and response to

clanging plant conditions were prompt. Management's efforts to achieve

• blackboard" conditions and reduce the number of HCB deficiencies

remained evident. The operating crew consistently demonstrated a high

level of awareness of existing plant conditions and ongoing plant

activities.

02 Operational Status of Facilities and Equipment

02.1 General Tours of Specific Safety Related Areas (71707)

General tours of safety-related areas were performed by the inspectors

throughout both units to examine the physical condition of plant

equipment and structures. and to verify that safety systems were

properly aligned. These general walkdowns included the accessible

portions of safety-related structures. systems, and components (SSC).

Overall material conditions for Unit I and Unit 2 SSCs were good.

Almost all plant areas were clear of trash and debris. Minor equipment

and housekeeping problems identified by the inspectors during their

routine tours were reported to the responsible SS and/or maintenance

department for resolution. Tnese problems included improper storage of

combustible materials, minor boric acid leaks and/or deposits unsecured

items located near safety-related equipment, corroded components, etc.

None of the problems constituted a significant safety or compliance

issue. Two such findings identified by the inspectors during routine

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plant tours included the following:

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Physical and material conditions of the service water intake

structure (SWIS), especially the lower level, have degraded

Enclosure 2

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considerably since past efforts to improve this area. Specific

inspector observations included: 1) multiple roof leaks (upper

and lower levels) that resulted in flooding of floor spaces. 2)

service water system (SWS) pump discharge pipe exhibits surface

rust where it penetrates the floor 3) corrosion and pitting of

SWS discharge piping was still evident inside the penetration of

the north wall of SWIS, and 4) physical and material conditions of

the lower level have degraded appreciably - soiled floors, spider

webs system leaks with associated wet floors, and painted over

rust on many system components (especially SWS strainers).

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A minor electro hydraulic control (EHC) fluid leak (1 to 2

drops / minute) from the 28 intercept valve, identified by

Deficiency Resort (DR) 547529, appeared to have gotten worse.

Also, the leac was being captured by adsorbents that were

saturated. resulting in a floor spill. Aside from a slipping

hazard, the use of adsorbents was not consistent with the Material

Safety Data Sheet (MSDS) for Fyrquei, which recommended using

inert material to absorb leaks / spills.

On November 20. 1997, an inspector accompanied a system operator (50) on

a watchstation tour of the Diesel Generator (DG) Building, which

included: all the DG rooms, the switchgear rooms, the fuel oil storage

tank rooms. Unit 1 circulating water pump area, and the Unit 1 and

Unit 2 reactor make up water storage tank (RMWST). The 50 was

knowledgeable of the multiple DG systems and conscientiously completed

his logs. However the 50's attention was focused on taking logs and

did not specifically look for any unt,Jected equipment or material

condition problems.

'12 2 Biweekly Inspections of Safety Systems (71707)

The inspectors verified the operability of the following selected safety

systems and/or equipment:

• Unit 1 spent fuel pool cooling and purification system. Trains A

and B

• Unit 2 spent fuel pool cooling and purification system. Trains A

and B

e Unit 2 auxiliary feed water (AFW) system

Accessible sortions of these systems were verified to be properly

aligned. T1e inspectors also observed that they were adequately

maintained and in good operating condition. The inspectors did not

identifv :ioy issues that adversely affected system operability. Minor

defidencies were loted and discussed with the appropriate shift

sepervisor.

Enclosure 2

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02.3 Verification of Safety Tanaina

a. Inspection Scope (717021

The inspectors verified that selected tagouts were implemented in

accordance with procedural requirements. The inspectors reviewed and

walked down selected components tagged by the following tag orders

(10s):

e TO# 97-2018 1. Incore Detection System

e TO# 97-2726 1. Condensate Storage Tank (CST) Freeze Protection

e TO# 96 2121-1. RMWST Oegas System

o TO# 97-1118-1. RMWST System

e TO# 97-2'73 2. Incore vetection Panel

e TO# 97-2514 1, lA Component Cooling Water (CCW) Pump

e TO# 97 2582 2, Train A SWS Strainer

e TO# 97-2586-2, 2A Residual Heat Removal (RHR) Pum)

e TO# 97-2574-1, Unit 1 Containment Purge and Mini-) urge

e TO# 97-2620-1, lA SWS Pump

e TO# 97-2710 1, lA SWS Pump

b. Observ.ations and findinas

The inspectors verified that the components identified on the tag orders

were pioperly taoged. The iden+ifications were correct and the tags

wereconspicuousTyplaced,anddiJnotobscurecontrolroompanel

indications. The administrative aspects of filling out the tagging

order forms were complete and correct. The tags placed were adequace

for personnel safety and equipment protection,

C. Conclusion

The inspectors concluded that the reviewed safety tagging activities

were correct and met the procedural requirements. The administrative

aspects of the tagging orders were complete and accurate. The tags

placed were adequate for personnel safety and equipment protection.

02.4 TS LCO Trackinn (71707)

The inspectors routinely reviewed the TS LC0 tracking sheets filled out

by the shift foremen. All tracking sheets for Units 1 and 2 reviewed by

the inspectors were consistent with plant conditions and TS

requirements.

02.5 Doeration of Dual Function Containment Isolation Valves (Temocrary

inspection (11) 2515/136)

A list of all containment isolation valves (CIVs) was provided by

Updated Final Safety Analysis Report (UFSAR) Table 6.2-31. Containment

Isolation Valve Information. In Table 6.2-31. duai function CIVs were

Enclosure 2

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identified as those CIVs whose post-loss of coolant accident (LOCA)

position was specified as "Open." These dual function valves were  !

verified with the licensee and no differences were noted. The inspector  !

also verified that all dual function CIVs can be operated from a switch -!

in the MCR. either from the MCBs or the BDP panels. However, in the '

presence of a Containment Spray (CS) or Safety injection (SI) signal, i

these valves will automatically reopen if the operator tries to close  !

them. Once the CS and SI signals are reset, then the dual function CIVs  :

can be closed from the MCR and will remain closed. l

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All dual function CIVs can be closed from the MCR once the CS and SI

signals are reset. However, the licensee has no specific procedural ,

guidance for resetting the CS or SI signal in the presence of a valid

demand. Current emergency response procedures only address resetting CS

and Si signals once the termination criteria are met. The inspector

discussed this arocedure deficiency with plant management. By the

, conclusion of t11s inspection period, management telieved it to be a  !

generic issue and had chosen to pursue resolution through the

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Westinghouse Owners Group.

02f Sg11mic Event in South Alabama (71707)  ;

On October 24. 1997. the National Earthquake Information Center reported i

that an earthquake had occurred in southern Alabama at 7:35 a.m. Central

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Daylight Time (CDT). The magnitude of the earthquake was measured at

4.9 on the Richter scale, and its epicenter was located about 120 miles

due west of the plant near Brewton, Alabama. Plant prsonnel did not i

notice any ground movement. Also, a subsequent walkdown of the site

seismic instrumentation revealed no indication that the earthquake

tremors had been detected. Resident inspector tours verified that

selected seismic detectors appeared operational and there was no

evidence of earthquake damage. ,

02.7 Cold Weather Preoaritions (71714)  :

a. Inspection Scone

from November 15 through November 18. the plant experienced several

, consecutive days where the daily low temperatures dropped below

freezing. The lowest temperatures observed were approximately 28

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degrees Fahrenheit (?F) during the early morning hours before sunrise.

The inspectors reviewed abnormal operating procedure FNP-0-A0P-21.0.

" Severe Weather." Revision (Rev.) 13. toured freeze protection systems

around the plant, and. interviewed responsible personnel.

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b. Observations and Findinas

During this inspection a number of findings were identified, including:

e Operators did not log entry into FNP 0 A0P-21.0 for temperatures

at or below 33 *F.

e Step 11.0 of FNP-0 A0P-21.0 " Extreme Cold Weather Contingencies."

states that Appendix I will be performed as necessary if

tem)eratures are forecast to be at or below 33 F within the next

24 lours. The inspectors discovered that major

Appendix I were still incomplete on Novemberand 17.some

portions of

were not

complete by the end of this report period. In particular, system

operators had not checked the status of freeze protection system

(i.e. , heat tracing) monitor lights during their roundt.. Also,

the maintenance department personnel had not com)leted their

inspections and functiorial testing of the plant leat tracing

systems in accordance with electrical maintenance procedure

FNP-1-EMP-1383.01. " Freeze Protection Inspections." Rev. 5. After

discussions with the acting Operations Manager. S0s were directed

to perform tours of the plant heat tracing circuits per item 2 of

FNP 0 A0P-21.0 Appendix 1. Discussions with the acting

Maintenance Manager revealed that the schedule for completing

EMP-1383.01 would be on or around December 5.

e Tours by the inspectors, and later the 50s, identified numerous

heat tracing indicator lights that were not lighted during cold

weather. These circuits were intended to actuate at or below

40 *F. Between both units there were about 200 heat tracing

circuit indicator lights, of which almost one half were not

lighted during subfreezing temperatures. However, of the

approximately 100 non-functioning indicator lights, about one

111rd of these were partially shielded from the environment and

may nct have experienced suf ficiently low temperatures,

e Operations supervision and management on dayshift were not well-

informed about the progress of FNP 0-A0P-21.0 implementation.

• Even though the latest revision to Appendix I that added Tables 1

through 7 was a considerable improvement over the previous

revision, an inspector noticed that the tabular location lists of

the heat tracing circuits and indicator lights of EMP-1383.01 and

FNP-0-A0P-21.0 were not consistent.

Although the weather was not cold enough for a long enough period of

time to represent a significant problem, licensee implementation of

FNP-0-A0P-21.0 was considered poor, especially in light of the problems

experienced during the previous year. (Refer to Non-Cited Violation

(NCV) 50-348, 364/96-15-02. Inadequate Procedural Guidance For Freeze

Protection. of Inspection Report (IR) 50-348. 364/96-15.) For the

Enclosure 2

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freeze protection program this year. the procedural guidance was

adequate. The inspectors identified that licensee personnel failed to

adequately implement FNP-0-A0P-21.0. Appendix 1. as required by TS 6.8.1.a. This constituted a violation of minor significance and is

identified as NCV 50 348. 364/97-14-01. Inadaquate Implementation of

Cold Water Protection Program, consistent with Section IV of the NRC

Enforcement Policy.

c. Conclusions

Licensee efforts to implement its cold weather protection procedures

prior to subfreezing temperatures were not timely and operations

supervision and management on day shift were not well-informed about the

progress of the procedures. Non Cited Violation 50-348, 364/97-14-01.

Inadequate implementation of Cold Weather Protection Procedures. was

identi fied.

06 Operations Organization and Administration

06.1 Peer Review by World Association of Nuclear Operators (71707 and 40500)

One of the inspectors reviewed the World Association of Nuclear

Operators (WAND) Interim Report dated September 16. 1997. regarding the

peer review conducted onsite during the month of July 1997. The

inspector concluded that the WANO report did not identify any important

safety issues which would require NRC follow-up action. Furthermore,

the WANO findings did not warrant a significant reassessment of NRC

perspectives regarding licensee performance.

11. Maintenance

M1 Conduct of Maintenance

M1.1 General Comments

a. Insnection Scope (61726 and 62707)

The inspectors observed and reviewed portions of various licensee

corrective and preventive maintenance activities and witnessed routine

surveillance testing to determine conformance with plant procedures,

work instructions. industry codes and standards. Technical

S)ecifications (TSs), and regulatory requirements. The inspectors

o) served all or portions of the following maintenance and surveillance

activities, as identified by their associated work order (WO). work

authorization (WA), maintenance procedure, or surveillance test

procedure (STP):

e FNP-2-FSP-63.05. " Visual Inspection of Penetration Fire Barriers"

• FNP-2-STP-11.6. " Residual Heat Removal Valves Inservice Test"

Enclosure 2

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e FNP-0-lMP-226.13. "1-2A EDG Load Stability Test"

e FNP-0-STP-26.08. Revision (Rev.) 12. " Control Room Train B

Ventilation Operability Test"

e FNP-1-STP-20.2 Rev. 8 " Penetration Room Filtration System Train

A(B) Monthly Operability Test"

e FNP-0-EMP-1370.01, Rev. 4. * Cable Termination. Splicing, and

Repair"

e FNP-1-MP-42.0, Rev 8. " Maintenance of Byron Jackson Service Water

Pumps (01P16P001A, 8. C. D. E)"

e FNP-0-EMP-1530.01. Rev. 8. " General Motor Maintenance"

e FNP-0 EMP-1701.01. Rev. 5. " Electrical Equipment Condition Test"

e WA# W00486998, SW Train 'B' Low Pressure Alarm Pressure Switch

e FNP-0-IMP-425.3. Rev 4. " Pressure Actuated Switches (Generic)"

e FNP-2-STP-914. Rev. 5, " Auxiliary Building Battery Charger Load

Test"

e FNP-2 EMP-1341.06, Rev. 5. " Auxiliary Building Battery Charger

Inspection"

e FNP 2-STP 73.1. Rev. 2. " Hot Shutdown Panel Operability

Verification"

e FNP-1-EMP-1383.01. Rev. 5. " Freeze Protection Inspection"

e FNP-0 FSP-57. Rev. 3. " Low Pressure CO2 Systems"

e FNP 0-STP-26.0A. Rev. 11. "Controi Room Train A Ventilation

Operability Test"

e FNP-1-STP-16.1 Rev. 30. " Containment Spray Pump 1A Inservice

Test"

e WO# W000486924. 2A RHR Pump Motor Maintenance and Supply Breaker

Megger Test

e FNP-0-ETP-3616. Rev. 11. " Monthly Surveillance Fiax Map Data

Collection" for Unit 1

e FNP-2-STP 201.18. Rev. 34. " Reactor Coolant System TE412Bl.

TE41282. TE41283 and TE412D Functional Test"

e FNP-0-STP-80.6. Rev.12. " Diesel Generator 1-2A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Load Test"

e WO# M97007636. Unit 2 Power Range Channel NI-42 Isolatior

Amplifier Replacement

e FNP-2-STP 22.2. Rev.10. "2B Motor-driven Auxiliary feedwater Pump

Quarterly inservice Test"

b. Observations and Findinos

All observed maintenance work and surveillance testing was performed in

accordance with work instructions, procedures, and applicable clearance

controls. In general, safety-related maintenance and surveillance

testing evolutions were well-planned and executed. Responsible

personncl demonstrated familiarity with administrative and radiological

controls, Surveillance tests of safety-related equipment were

consistently performed in a deliberate step-by-step manner by personnel

in close communication with the Main Control Room (MCR). Overall,

operators, technicians, and craftsman were observed to be knowledgeable.

Enclosure 2

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experienced, and well-trained for the tasks performed. However, the

inspectors observed the following four instances where personnel were

not signing off procedure steps as they were completed:

e On November 19, 1997, the ins)ectors observed a limited portion of

WA #492443 to calibrate 02E23)lC3532 per FNP 0-lMP-401.2. " Fisher

4150 and 4160 Controller Calibration (Generic)." Rev. 7. The

ins)ectors reviewed the work package and noted that, although the

tecinicians were on step 7.3, they had not signed off the steps

which were already completed, including the sign-off for meeting

the initial conditions. IMP-401.2 was designated as a " Continuous

Use" procedure. One of the procedure usage requirements for a

" Continuous Use" procedure, as stated on the procedure cover page,

was that " Work permitting, each step is to be signed off as

complete before proceeding to the next step." The inspectors

reviewed the procedure and did not identify any work conditions

which would preclude signing off the completed steps as they were

performed. The inspectors did not identify any problems nor

indications that the steps which were not signed off had not been

performed.

• On November 21, 1997, the inspectors observed part of

WA# W00486998. SW Train B Low Pressure Alarm Pressure Switch, per

FNP-0 IMP-425.3 Rev. 4. " Pressure Actuated Switches (Generic)"

for 02P16PS0503 in Unit 2 valve box #1. FNP-0-IMP-425.3 was

defined as a " Continuous Use" procedure. The Confined Space Entry

Sheet was satisfactorily completed. Work was in progress and the

inspectors observed that the procedure steps were not being

initialed as they were accomplished. The inspectors also observed

that WA# W00486947 for TPNS 02P16PS0502 was already completed, but

only the iritial condition step had been signed off. Workers were

knowledgeable of the job and familiar with the requirement to sign

off the steps as they were performed. However, they stated that

they had concentrated on the tasks at hand and had forgotten to

ensure that the steps were properly signed off.

• During the 1-2A Diesel Generator outage, the ins)ectors reviewed

the work package and associated procedures for t1e ongoing job.

During this review, the inspectors identified several minor

administrative discrepancies, including procedure steps that were

complete but not as yet signed off in the MP-14.1 " Continuous Use"

procedure,

e On November 26, 1997 the ins)ectors observed portions of the 1A

SWS pump motor replacement. )uring the review, the inspectors

identified several steps of the EMP-1370.01 data sheet for

termination of the pump motor that were complete, but not signed

off as required by a " Continuous Use" procedure.

Enclosure 2

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. m

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l

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. 10  ;

These observations were brought to the attention of maintenance  :

management who then discussed them with the various maintenance teams,

stressing the requirement to sign off steps as accomplished for

" Continuous Use" procedures. Additionally, maintenance personnel  ;

provided feedback to management concerning the quality and expectations

of procedures.

1

Failure to initial procedure steps as they are performed, before

proceeding to the next step, is contrary to the procedure usage

requirements stamped on " Continuous Use" procedures. This requirement

ensures that critical procedure steps are performed in a deliberate and '

methodical step by step manner. Since no procedure ste)s were missed or

performed out of sequence, the safety significance of t1e observed

examples was minor. As such, this failure to follow 3rocedure <

constituted a violation of minor significance and is aeing treated as-3 -

NCV consistent with Section IV of the NRC Enforcement Policy. This is

identified as NCV 50 348. 364/97-14 02. Failure To Sign Off Steps For

Continuous Use Procedures as They Are Performed.

c. Conclusions

Maintenance and surveillance testing activities were generally conducted

in a thorough and competent mar.ner fiy qualified individuals in

accordance with plant procedures and work instructions. A NCV was

identified for maintenance technicians failing to sign-off steps in

" Continuous Use" procedures as they were accomplished.

M1.2 1-2A Diesel Generator 18 Month Outane

a. Insoection Scone (62707)

The inspectors reviewed the work aackages and observed portions of the

1-2A Emergency Diesel Generator (EDG) 18-month outage, which included:

lobe oil heat exchanger tube bundle replacement; jacket water heat

exchanger tube bundle replacement; fuel injector replacement: exhaust

system repair and replacement: and various other 18-month inspections.

b. Observations and Findinas

Overall work was performed well. with maintenance supervision constantly

on station to oversee work activities and review the work status.

Workers were diligent in maintaining foreign material exclus;9n covers

over oyen components. The licensee continued its practice of having a

COLTECi vendor representative on-site during major EDG outages, witch

aided in rapid resolution of technical issues.

The 1-2A EDG equipment outage progressed without significant difficulty.-

One of the initial equipment problems targeted for repair was the

exhaust system which had several leaks that actually made the EDG room

uninhabitable for extended periods due to fumes. During mainteriance it '

Enclosure 2 .

h

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.

. 11

was determined that the exhaust leaks had seriously damaged the engine

cylinder thermocouples. Mc.st of these thermocou)les were repaired, but

some were left for repair during the next 1-2A EXi outage. All the

exhaust system leaks were repaired.

During the return to service of the 1-2A EDG, mechanics discovered that

the #9 fuel injector pump was not operating and several minor fuel oil

leaks were identified on inje_ctors #2 #3. and #12. In addition to

these minor problems, the EDG output breaker would not close from the

EPB handswitch during the )erformance of the 1-2A EDG o>erability test.

The cause was believed to )e a contact in the handswitc1 circuit that

failed to close when the switch was operated. However, the licensee was

unable to repeat the problem and a conclusive root cause determination

was not made. Also, during a maintenance run, the EDG tripped due to

low lube oil pressure. caused by debris buildup in the strainer. The

debris was believed to be from material that was scrapped off the lube

oil heat exchanger during the tube bundle replacement. Each of these

items was corrected prior to declaring the 1-2A EDG operable.

c. Conclusi20

Maintenance work was performed by well-qualified and knowledgeable

personnel. Corrective action efforts were thorough. Post-maintenance

testing was satisfactorily completed.

M6 Maintenance Organization and Administration

M6.1 Schedulino Of On Line Maintenance (62707)

The inspectors reviewed the Unit 1 Equipment Outage Forecast. Rev. O for

December 1 - 7. 1997, issued on November 25, 1997. The inspectors

noticed that the licensee had scheduled FNP 1-STP-73.1. " Hot Shutdown

P6nel Testing." for December 1. 1997. The planning department had

determined that implementation of certain steps of FNP-1-STP-73.1 would

involve significant risk based on risk-achievement worth (RAW) values i

generated by their equipment out-of-service (E005) risk monitor.

Although the vast majority of hot shutdown panel (HSDP) testing had RAW

values well within the bounds established by ACP-52.1. " Guidelines For

Scheduling of On-Line Maintenance." Rev. 4. there were several steps of

FNP-1-STP-73.1 with RAW values over 10-(one as high as 18.6). These

values were calculated even though 0)erations and Planning personnel had

made efforts (i.e., test procedure c,anges) to reduce the potential

rists associated with on-line HSDP testing. The guidelines of ACP-52.1.

Section 4.2. do not currently allow for conducting on-line maintenance

or testing if the RAW value exceeds 10. Concerns regarding HSDP testing >

with high RAW values were also expressed by Operations personnel. The

inspectors discussed this testing with plant management. including

compensatory measures consistent with ACP-52.1. Plant management

decided to reschedule the high risk portions of FNP-1-STP-73.1 until the

next outage.

Enclosure 2

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H8 Hiscellaneous Maintenance Issues (90712, 92700 and 92902)

M8.1 (Closed) Licensee Event Reoort (LER) 50-348. 364/97-07: Outside Of

Desian Basis Due To Dearaded Cork Material

On June 22, 1996. December 10. 1996, and April 17. 1997. licensee

personnel identified that some of the self expanding cork sealing

material was missing from the area between the main steam valve room

(MSVR) and containment. On each date. Deficiency Reports (DRs) were

written. The areas identified on April 17 in the MSVR. and the amount

of material missing or degraded:

Unit 1: "B" Bay - 2 in by 20 ft

"C" Bay - 4 in by 6 in

Unit 2: "A" Bay - 4 in by 6 ft

"B" Bay - 4 in by 4 ft

"C" Bay - 4 in by 4 ft

Although the missing cnd degraded cork seal had been previously

identified in 1996. its significance as a flood barrier was not

recognized until after April 17. 1997, due to the questioning attitude

of a licensed senior reactor operator. Initial licensee concerns

regarding the cork seal, used elsewhere in the auxiliary building,

centered around its function as a fire barrier and as a pressure seal

for the penetration room boundary (See Inspection Report (IR) 50-348,

364/97-04). On April 22. the iicensee determined that the missing cork

represented a condition outside the design basis and reported this

condition in LER 50-348. 364/97-007.

The missing cork would allow water from a main feed line break to flood

the lower level equipment roo9 (LLER) which contains the turbine-driven

auxiliary feedwater (TDAFW) pum). thus rendering the TDAFW pump

inoperable. This accident, com)ined with a single failure of a motor-

driven auxiliary feedwater (MDAFW) pump, would leave the plant with only

one operable MDAFW pump. The Condition IV - Limiting Faults accident

analysis of UFSAR Section 15.4.2.2. " Major Rupture of a Main Feedwater

Pipe." assumed that two MDAFW pumps would be necessary to provide

adequate AFW flow. Further analysis of the AFW system requirements for

Main Feedwater (MFW) line breaks was documented in As-Built Notice (ABN)

93 0-0224. This analysis concludeo that one MDAFW pump provided

adequate flow to the intact Steam Generators (SGs) once the faulted SG

was isolated. Thus, if a MFW line break had occurred while the cork

seal was degraded, coincident with a single failure of a MDAFW pump, the

current main feedwater line break accident analysis could not be met.

However prompt operator action (i.e.. to isolate the faulted SG) per

the Emergency Operating Procedures (E0Ps) would mitigate this event by

allowing the single MDAFW pump to provide the required AFW flow to the

intact.SGs.

Enclosure 2

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t

The very low probability of a MFW line break occurring coincident with a t

single failure of a MDAFW pump wa calculated by the licensee to be ,

4.75E-5 Jer reactor year. This numoer was based on all failure modes ,

for the ADAFW pump (including electric power). Furthermore. the plant ,

emergency response procedures (ERPs) provide direct instructions for

isolating a faulted steam generator. An inspector reviewed the ERPs and

determined that the faulted SG coeld be identified and isolated promptly

(i.e.. less than 10 minutes). Once the faulted SG was isolated, the

remaining MDAFW pump would have adequate capacity. Considering the very

low probability. and the o)erators' ability to mitigate this accident.

the inspectors concluded tlat the safety impact of degraded cork in the *

MSVR was minimal.

'

When identified in 1996, it was evident that the missing and degraded

cork sealing material had been in this condition for many years. .

Degradation of the cork seal used throughout the auxiliary building has

been recognized as a problem as early as 1985. Numerous DRs have been

written regarding degradation of the cork seal in the auxiliary

building. However. no comprehensive repairs or periodic inspections

were initiated. The oldest outstanding deficiency report (i.e. DR

211386) was written in March 1990 for degraded cork between the

auxiliary building and containment. This and other DRs were still open

when the issue was identified again regarding the MSVR in April 1997.

The missing and degraded cork seal in the Unit 2 MSVR was specifically

identified on December 10. 1996 (DR 96006033). but was not adequately

addressed until a senior reactor operator questioned the problem when it

was re-identified on April 17. 1997. This issue was also similar to the

licensee's failure to recognize and correct degradation of the cork seal

that maintained the penetration room boundary (PRB) as documented in

IR 50 348, 364/97-04. For the PRB issue. a Predecisional Enforcement

Conference was held, resulting in several severity * vel IV violctions,

one of which was for inadequate corrective action.

'

The following corrective actions were described in LLR 50-348, 364/97-07

and verified by the inspectors:

1) Cork seal repairs on Unit 2 were completed by April 21. 1997.

The Unit I cork seal was replaced with a foam seal prior to

restart from its last refueling outage in June 1997.

2) Maintenance procedure FNP-1/2-MP-29.0. " Visual Inspection Of

Auxiliary To Containment Building Seismic Joint Seal (Main Steam

Valve Pscom)." Rev. D. was developed and issued June 6. 1997 to

inspect the MSVR cork seal every 18 months.

3) Personnel reviewing DRs for operability reviewed

LER 50 348. 364/97-007.

Enclosure 2

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4) The entire corrective maintenance backlog was reviewed to

ensure proper prioritization of outstanding DRs/W0s for scheduling ,

work.

Comprehensive inspections of the cork seal have been conducted 1

throughout the auxiliary building and all repair work has been

completed, or scheduled with appropriate compensatory measures in place

(i.e.. fire watches). The licensee is developing additional periodic

cork seal inspection procedures for all auxiliary building areas outside

the MSVR. These procedures are scheduled to be completed by  ;

December 19, 1997.

'

10 CFR Part 50. Appendix B. Criterion XVI: Updated Final Safety Analysis

Report. Section 17.2: and the Operations Quality Assurance Policy

Manual. Chapter 16, require that appropriate measures be taken to assure

that conditions adverse to quality are promptly identified and

corrected. Failure to take adequate corrective actions is identified as

violation (VIO) 50-348, 364/97-14-03. Inadequate Corrective Actions for

Maintaining Main Steam Valve Room Cork Seal Flooding Barrier.

M8.2 (Closed) Insoecto Followuo item (IFI) 50-348. 364/96-02-03: Pre-Action

S.prinkler System Failures

in 1996, two incident reports (FNPIRs) were initiated (i.e.. FNPIRs 1-

96 71 and 2-96 78) and a root cause team was assembled to address the

problems associated with multiple pre-action sprinkler s

Although the root cause was not conclusively identified.ystem failures.

the root cause .

team recommended numerous corrective actions that have been implemented.  !

These corrective actions included system flushes: detailed inspections,

measurements, and cleaning of multimatic valve internals: replacement of

critical mechanical and electrical components; revised surveillance

procedures: and increased surveillance testing. Over the past two

years, the inspectors have observed aspects of these corrective actions

for selected pre-action sprinkler systems. The inspectors reviewed the

completed FNPIRs identified above and a history report of all the

corrective action commitments to confirm that they were completed. The

inspectors also reviewed intracompany memorandum NEL-97-0476, dated

November 17, 1997, that summarized the corrective actions already taken

and established an additional corrective action plan v'th detailed

actions, responsibilities, and a schedule. The inspectors have also

reviewed the history of surveillance test results since August 1996

which demonstrated dramatic reductions in component (e.g.. multimatic

valve - clappers and solenoid valves) failures. However, certain system '

failures have continued to occur that will be addressed as part of the

corrective action plan of NEL 97-0476, scheduled to be finished by

July 31. 1998.

Licensee corrective actions to-date to address multiple pre-action

s)rinkler system failures identified in 1996 have been comprehensive,

tiorough and generally successful. An additional corrective action plan

Enclosure 2

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, .- - -- , , +

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. 15

,

has been initiated to resolve the small number of remaining failures.

This IFI is considered closed.

'

M8.3 (Closed) LER 50-348. 364/96-01: TS Action Statement Reauirement Not Met

for SSPS Testina

Tne circumstances surrounding this LER and associated corrective actions

were previously inspected and verified (see IR 50-348, 364/96 03.  !

'

Section 3.2.c). This LER is considered closed.

M8.4 (Closed) LER 50-348/97 011: Ent y Into TS 3.0.3 Due to the Failure to

follow the Work Control Process >rocedure

a. Insoection Stone (92902)

The inspectors reviewed LER 50 348/97-011 and associated maintenance

,

W0s, Occurrence Reports (ors). LCO Status Sheets. and Training

Attendance Sheets. ,

b. Observations and Findinas

LER 50 348/97-11. documents an event where failure to follow procedure

associated with controlling the work process, caused Unit 1 to enter a

condition prohibited by TS. Technical Specification 3.7.4 requires two

independent Service Water System (SWS) loops be maintained operable.

However, both trains of the automatic isolation capability of the motor

operated valves (MOVs) for supplying service water (SW) to the turbine

building were made inoperable. TS 3.0.3 was entered for 39 minutes,

until operability was restored.

The inspectors reviewed the associated safety assessment and concluded

that it adequately addressed the effects of the SWS inoperability.

During the time that the automatic isolation function was inoperable.

0:>erators were aware of the condition with the SW Motor Operated Valves

(K0Vs). Any turbine building SW leak that could have jeopardized the

heat transfer capability of the SWS or impacted the capability for

running the EDGs would have been identified in a timely manner.

Operators could have manually isolated SW to the turbine building to

ensure adequate SWS flow to safety related systems.

'

Corrective actions taken to resolve the issue and prevent recurrence

were reviewed by the inspectors. Training conce ning the event was

provided to Operations and Maintenance department personnel and they

were instructed on the need to identify and document specific limits for

troubleshooting activities on the work order. This failure to meet the

requirements of TS 3.7.4 is identified as NCV 50-348/97 14-04. Entry

Into TS 3.0.3 Due to the Failure to Follow the Work Control Process

Procedure. consistent with Section VII.B.1 of the NRC Enforcement

Policy.

-

Enclosure 2

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. .

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. 16

c. (pnclusions

A non cited violation was issued for a failure to follow work control

procedures which resulted in inoperability of automatic turbine building

isolation. LER 50-348/97-011 is closed.

III. Enaineerina

El Conduct of Engineering

E1.1 Steam Generator Reolacement Pro.iect (50001 and 37551)

On November 20, 1997. SNC met with the NRC in Rockville Maryland to

discuss current progress and schedules for the Units 1 and 2 Steam

Generator Replacement Projects (SGRPs). A resident inspector attended

the meeting. The existing Westinghouse Model 51 SGs are currently

scheduled to be replaced with the Westinghouse Model 54F design in

S) ring 2000 for Unit 1 and Spring 2001 for Unit 2. During the meeting.

11e licensee provided a comprehensive summary presentation of its

schedule, scope of work, organization, date for proposed licensing

submittals, and engineering plans.

E8 Hiscellaneous Engineering Issues

E8.1 _

( Closed) URL 50 348. 364/97-201-08- Tornado Protection of Turbine.

Driven Aux 1L iary Feed Water (TDAFW) Pumo Vent Stack

The inspectors observed that the safety-related T0AFW pump vent stack

was installed on the roof of the auxiliary building and was not

protected from tornado generated missiles. Updated Final Safety

Analysis Report (UFSAR) Sections 6.5.1. 3.2.1.3. 3.2.1.5. and

Table 3.2-1 state that Auxiliary Feed Water (AFW) system equipment and

piping are identified as Category 1. UFSAR Section 3.5.4 states that

Category I equipment and aiping outside containment are either housed in

Category I structures or )uried underground. The NRC has reviewed this

issue and concluded that the failure to provide tornado missile

protection for the TDAFW pump vent stack, located on the roof of the

Auxiliary Building. is a violation of 10 CFR 50 Appendix B.

Criterion 111. Design Control. This is identified as Violation 50-348.

364/97-14 05. Failure to Provide Tornado Missile Protection for TDAFW

Pump Vent Stack.

Based on the above, the unresolved item is considered closed.

Enclosure 2

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17

IV. olant Support

R1 Radiological Protection and Chemistry Controls

R1,1 Radiological Controls

a. Inspection Scone (83750)

Radiological controls associated with ongoing Unit 1 (U1) and Unit 2

(U2) routine operations were reviewed and evaluated by the inspectors.

Reviewed program areas included general housekeeping and cleanliness,

area postings, radioactive material and waste (radwaste) container

labels. controls for high and loc.ed-high radiation areas, and

procedural.and radiation work permit (RWP) guidance. Established

controls were compared against Updated Final Safety Analysis Report

(UFSAR) details and documented procedural requirements to meet

applicable sections of Technical Specifications (TSs) and

10 CFR Part 20.

The inspectors made frequent tours of the radiologically controlled

areas (RCAs). The inspectors directly observed worker and Health

Physics (HP) technician performance and discussed results of radiation

and contamination surveys conducted for selected ecuipment and facility

locations. Confirmatory radiation surveys of the L2 Spent Fuel Pool

(SFP) heat exchanger areas and radioactive waste storage the U2 truck

bay area were reviewed ano discussed in detail.

The inspectors discussed and reviewed "As low as Reasonably Achievable"

(ALARA) program implementation, individual worker doses, and dose

expenditures associated with the Unit 1 Refueling 14 (UlRF14) outage job

evolutions.

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

10 CFR 20 Subpart J requirements. Containers holding radwaste,

contaminated materials, and equipment were labeled in accordance with

10 CFR 20.1904 requirements. Excluding the U1 SFP heat exchanger area.

radiation survey maps of local areas within the auxiliary building

accurately reflected radiological conditions, For the U1 SFP heat

exchanger and adjacent rooms. the inspectors noted that survey records

maintained at the RCA control point were accurate and indicated recent

changes in radiological conditions for U1 SFP heat exchanger and

adjacent rooms. However. licensee representatives stated that changes

to the survey ma)s posted in the local area were only updated on a bi-

weekly basis. Tie inspectors verified that the subject rooms were

posted and controlled properly but that the identified lack of

timeliness in revising the locally posted map could cause confusion

Enclosure 2

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. 18

regarding the actual radiological conditions within the subject area.

Licensee representatives stated that this concern would be reviewed and .

appropriate actions taken.

From direct observation of work activities, the inspectors verified that

workers followed proper radiological controls specified in selected

RWPs. In addition, the inspectors noted improvements in housekeeping

and cleanliness within the established RCA. Review of licensee data

verified that approximately six percent of the RCA continued to be

considered contaminated floor space. Licensee representatives stated

that continuing decontamination efforts were ongoing to further reduce

the RCA contaminated floor space.

The Farley Nuclear Plant UlRF14 Outage report was reviewed and discussed

with responsible staff. Implementation of ALARA program activities

including initial planning and subsecuent review of lessons learned for

UlRF14 outage activities was verifiec. Dose expenditure for outage

activities, approximately 246 person rem, exceeded the original

projected dose expenditure of 195 person rem. The outage duration

increased from 52 to 81 days as the result of extensive unplanned steam

generator maintenance activities and contributed to the increased dose

expenditure.

c. Conclusions

Radiological controls, area postings and container labels were maintained

in accordance with TS and 10 CFR 20. Appendix J requirements.

Improvements were noted for RCA housekeeping and cleanliness and for RWP

practices.

Revisions to local area radiation survey mn for the U1 SFP area were

timely. '

For U1RF14 outage. ALARA program activities were implemented in

accordance with approved procedures.

Actual UlRF14 outage dose expenditure exceeded original estimates and

resulted from an increased s"pe of steam generator maintenance

activities. ,

R1.2 External Exposure (83750)

a. Inspection Scoo.g

The inspectors discussed and reviewed deep dose equivalent (DDE) and <

shallow dose equivalent (SDE) exposures to workers involved in UlRF14

outage activities. The review included selected workers'

Thermoluminescent 00simeter (TLD) data and personael contaminations.

documented as either Radiation Worker Performance Observations (RWP0s).

Enclosure 2-

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1.e., dispersed contamination less than 5000 disintegration per minute

per 100 square centimeters (dpm/100cm') and specks with less than 100,000

dpm/ probe area, or as personnel contamination events (PCEs) i.e. , 2

dispersed contamination greater than or equal to (a) 5000 dpm/100cm and

specks a 100,000 dpm/ probe area. ,

Dose assessment methods and assumptions, where applicable, were reviewed

for technical adequacy. Dose results were compared against 10 CFR

Part 20 limits,

b. Observations and Findinas

For outage activities, the maximum total effective dose equivalent (TEDE)

was approximately 2386 millirem (mrem) assigned to an Individual involved

in steam generator maintenance activities. For the outage period,

approximately 75 speck and 120 dispersed personnel contaminations were

identified in RWP0 documents. Approximately 14 PCEs were identified,

with only one requiring a skin determination. For the affected

Individual, a not particle located on the upper right forearm resulted in

an assigned shallow dose equivalent of approximately 10.7 rem. Licensee

assumptions and details regarding physical location, length of exposure

and isotopic characteristics of particle were appropriate. The

inspectors noted that all assigned doses were within 10 CFR 20.1201

limits.

c Conclusions

Worker DDE and SDE exposurec resulting from personnel contamination

events and work activities during the U1RF14 outage were evaluated

properly and were within 10 CFR 20.1201 limits

RI.3 internal Exposure (83750)

a. Inspection Scooe

The inspectors discussed program guidance for monitoring and evaluating

)ossible internal exposures. Results of selected investigative whole-

)ody count (WBC) analyses conducted during the U1RF14 outage were

reviewed in detail.

b Observations and Findinas

From review of WBC analysis records of workers' positive radionuclide

intakes, a weakness affecting the accuracy of associated evaluations was

identified. The inspectors noted that farley Nuclear Plant (FNP)

Dosimetry (005) procedure-307. Rev. 20, Operation and Standardization of

the Canberra Nuclear Stand-up Whole Body Counters, dated February 18,

1997, Section (S)4.7.13.2 specified that it,jividuals indicating a

potential intake equal to or greater than 10 millirem (mrem) following

WBC analyses in paper clothing requires (1) initiation of a DGS Form 921.

Enclosure 2

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Investigative Whole Body Count record, and (2) instructing individuals to i

return for another count at the beginning of the next work day. Further. i

the WBC operator was required to ensure that the actual intake date and

time was entered into the computerized system. During the review of WBC

analysis records, the inspectors identified two individuals whose initial 1

WBC analyses data resulted in an assigned committed effective dose ,

equivalent (CEDE) exceeding 10 mrem, but where subsequent WBC analyses

were conducted with improper intake dates and times. That is, for the

workers' WBC analyses conducted subsequent to the initial measurements ,

which initially identified the positive radionuclide intakes. WBC system

operators input the current dates and times rather than the actual intake

dates and times. The inspectors noted that the failure to follow

)rocedures for WBC investigative analyses was a violation of TS 6.8.1.

Juring the week of November 17. 1997. responsible licensee

representatives issued a memorandum to all responsible personnel '

regarding the identified procedural problems and conducted manual

calculations using proper event dates and times for the two impro>er

intake evaluations. No significant changes were identified for tie

calculated CEDES based on the minimal quantities and long effective half-

life of the radionuclides detected. Licensee followup interviews with

responsible technicians identified confusion regarding procedural

directions and requirements for conducting proper intake evaluations

using positive WBC analysis data. Licensee representatives stated that

additional training would be provided and that documentation regarding

intake event dates and times would be evaluated and improved, as *

applicable. The inspectors noted that the failure to follow procedures

constituted a violation of minor safety significance and, consistent with

Section IV of the NRC Enforcement Policy. is identified as Non Cited

Violation (NCV) 50 348. 364/97 14 06: Failure to Follow WBC Analysis

Procedures for EvaluaM on of Workers' Potential Radionuclide Intakes.

The inspectors noted that from March 15 through May 25. 1997, the U1RF14

outage period. approximately 30 investigative WBC analyses were ,

conducted. The analyses were con 6Jcted as a result of specific events,

usually documented in RWP0s, which could cause or indicate potential

radionuclide intakes resulting in internal exposure. The estimated

maximum intake was 309 nanocuries (nr') approximately 7.8 derived air

concentration-hours (DAC hrs), resulting in an assigned CEDE of 20 mrem.

The inspectors verified the 20 mrem CEDE was added to the deep dose

equivalent (DDE) to provide the total effective dose ecuivalent (TEDE)

documented in the individual's official exposure recorcs. No other

- evaluated worker intakes exceeded 10 mrem, i.e. 0,2 percent of the

annual limit of intake (ALI) required to be documented by licensee

procedures.

c. Conclusions

The failure to follow proct;dures for evaluating potential intake of "

radionuclides was identified as NCV: 50-348.364/97-14 06: Failure to

Enclosure 2

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.

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. 21

Follow WBC Analysis Procedures for Evaluation of Workers' Potential

Radionuclide Intakes.

Controls for minimizing workers' internal exposure were effective.

RI.4 Radiation Monitoring System (RMS) Operability Issues (84750)

a. Scoce

Status of the Unit 1 (U1) main steam relief and atmospheric steam dumn

discharge radiation monitor B (RE-60B) operability was reviewed and

discussed. The inspectors reviewed and discussed Special Report

97-03-00. U1 Inoperable Radiation Monitor R60-B. and reviewed selected

records regarding implementation of the applicable surveillances and

compensatory sampling required by the TS action statement.

b. Observations

The inspectors verified that, for the inoperable U1 RE-60B monitor,

required surveillances verifying U1 Steam Jet Air Ejector (SJAE) monitor

R-15A operability were conducted in accordance with the applicable

procedures. Backup grab samples were not required for the period

reviewed based on operability of the SJAE monitor during that period,

c. Conclusions

Surveillance requirements for the inoperable U1 RE-60B monitor were

completed in accordance with approved precedures.

R1.5 Radioactive Waste and Material fransportation Activities (86750.

TI 2515/133)

a. Insoection Scoo_e

The inspectors reviewed RCP program activities associated with packaging

and subsequent trancport of radioactive material and waste from the site.

The review evaluated implementation of revised Department of

Transpcrtation (DOT) 49 CFR Parts 100-179 and 10 CFR Fart 71 regulations.

Program implementation based on the completeness and accuracy of shipping

documents associated with recent shipping activities was evaluated.

Procedural guidance detailed in recently revised Farley Nuclear Plant

(FNP) RCP procedures was reviewed and evaluated against anlicable

requirements in the revised 49 CFR Parts 100-179 and 10 C 4 Part 71

regulations.

e FNP-0-RCP-810. Shipment of Radioactive Waste to Barnwell Burial

Site. Rev. 29. issued January 1. 1997.

Enclosure 2

. .

.

22

e FNP-0-RCP-811. Shipment of Radioactive Material. Rev. 20, issued

October 28, 1997,

i

1

e FNP-0 RCP-888. Health Physics Radwaste Group Forms. Rev. 12, issued

October 15. 1997.

Records of selected radioactive waste and material shipments made between

June 1. and October 22, 1997, were reviewed and discussed.

b. Observations and Findinas

The licensee's )rocedural guidance met a)plicable regulatory

requirements. Recent revisions to 49 CFR Parts 100-179 and 10 CFR

Part 71 regulations were incorporated into approved procedural revisions. i

Shipping paper data entries were accurate and completed appropriately.

c. Conclusions

Licensee program guidance for transportation of radioactive waste and

materials met 10 CFR 71.5 and ru ently revised DOT 49 CFR Parts 100-179

requirements.

Transportation program guidance was implemented effectively.

R3 RP&C P;ocedures and Documentation (83750)

R3.1 Dose Records

a. Inspection Stog

The inspectors reviewed and evaluated licensee program guidance and

implementation for determination of current-year prior occupational

doses. The inspectors reviewed and discussed NRC Form 4. or equivalent,

records for selected contractor personnel involved in U1RF14 outage

maintenance activities. In addition. implementation of procedural

guidance for extensions to administrative dose limits was evaluated for

individuals involved in selected U1RF14 outage activities.

Licensee program guidance and corres)onding records were compared against

approved procedures and 10 CFR 20 Su)part L requirements, as applicable.

b. Observations and Findino;

The inspectors verified that a)propriate records of current-year prior

occupational doses were availa)le for the selected individuals. Initial

estimates of current-year prior doses assigned for deer, skin, extremity,

and lens of the eye for each individual worker were conservatively based.

Enclosure 2

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All documentation required for granting administrative dose extensions in

accordance with approved procedures was complete and maintained.

c. Conclusions

Records for determining workers' prior yearly occupational exposures and

granting extensions to adeinistrative e cosure limits were established in

accordance with 10 CFR Part 20. Subpart . requirements and administrative

procedures.

R8 Hiscellaneous RP&C Issues i83750, 84750)

R8.1 (Ocen) VIO 50-348. 364/96-10 01: Failure to Construct and Maintain an

"As Bui' t' Samole Line in Accordance with Confiouration Control

Procedures and Drawinas.

This violation addressed differe.. as between the installed "as-built" and ,

the applicable configuration control procedures and drawings for the U1

Post Accident Sampling System Particulate detector (RE-67) sample line.

Completion of corrective actions was verified during system walk-downs.

Additional corrective actions documented in a November 15, 1997. response

to violation (VIO) 50 348/97 08 05, which also aie applicable to this

issue, were reviewed and discussed. Licensee commitments addressing

Radiation Monitoring System (RMS) design control issues included

additional system walk-downs. development of a RMS Functional System

Description (FSD) document and subsequent validation by a Self-initiated

Safety System Assessment (SSSA). From discussion with responsible

licensee representatives and review of the FNP Radiation Monitor Plan and

Radiation Monitor Walk down Issues documents, the inspectors verified

completion of the initial RMS equipment walk-downs and preliminary

evaluations. Identified RMS design issues were discussed and determined

to not affect RMS operability. Additional walk-downs of currently

inaccessible RMS equipment located in both U1 and U2 containments were

planned to be completed during future outages. Licensee representatives

provided a preliminary schedule regarding development of the RMS FSD

document and subsequent validation by a $SSA. Additional RMS design

issues identified by the SSSA are to be corrected. Based on the

completed actions and documented commitments for RMS equipment c:rign

issues, this part of the VIO is closed. However, the parts of this

violation which were addressed in Section El.3 of IR 50-348, 364/96-07

and Section El.2 of IR M 348. 364/96-09 remain open, pending future NRC

review.

Enclosure 2

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R8.2 (Closed? VIO 50 340/97-10-05: Inadeouate Confiauration Control of 01 RMS

Particu ate Samole Lines.

r

This violation identified concerns retarding differences between the

installed sample lines constructed with flexible stainless steel tubing

having corrugated internal surfaces and the applicable configuration

control-documents for the U1 backup Post-Accident Sampling System plant -

vent airborne particulate sampler (RE-68) and the U1 main stack

particulate sampler (RE-29A). From direct observation of RMS equipment

and review of licensee records, completion of corrective actions i.e.,

installation of the correct sam)le line for the RE-68 nonitor and use of .

'

a backup sampling system (RE-293) for the U1 RE-29A monitor, was

verified. As documented in Section R8.1, additional corrective actions ,

and commitments detailed in the licensee's November 15. 1997, response to

the violtion were reviewed and discussed. Based on the completed

actions and documented commitments. this VIO is closed.

R8.3 (Closed) Licensee Event Reoort (LER) 50-364/97-04-00: Doeratina Outside '

of Technical Soecifications Due to Recuired Containment Grab Samoles Not

3eina Taken.

i

a. _ Inspection Scone

The inspectors reviewed and discussed with responsible personnel.

Licensee Event Report (LER) 50-364/97-04-00 which addressed the failure

to conduct containment atmosphere grab samples as required by TS 3.4.7.1

when both the U2 containment atmosphere particulate (R-11) and gaseous

(R-12) radiation monitoring systems were inoperable from September 10-12.

1997.

The LER and associated licensee's occurrence report were reviewed and

discussed with cognizant licensee re)resentatives. The affected system

was walked down with responsible teclnicians and corrective procedural

revisions were documented in FNP-2-RCP 27. Operation of Unit 2 RE0011/12

and RE0021/22. Rev. 12, issued November 4. 1997, were discussed.

b. Observations and Findinas

The licensee occurrence report concluded that multiple equipment

failures, inadequate procedural guidance, the failure of personnel to

followup properly, and abnormally low radiation monitor readings

contributed to the failure to identify the need for the TS grab sample

surveillances. The inspectors noted that the failure to conduct grab

samples when the U2 R 11 and R-12 radiation monitoring sampling systems

were inoperable was identified as a violation of TS 3.7.4.1. The

. inspectors noted that.the licensee's evaluation considered all potential

causes contributina to the event and specified appropriate corrective

actions. The implementation of proper corrective actions. including

procedural revisions and associated training was verified. Consistent

4 with Section VII of the Enforcement Policy, this issue was identified as

Enclosure 2

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. NC.V 50-364/97-14-07: Failure to Conduct Compensatory Grab Sampling for

Inoperable Unit 2 Contali ont Atmospheric Radiation Monitoring System in

accordance with TS 3.4.7.1.

c. Conclusions

The inspectors identified NCV 50-364/97-14-07: Failure to Conduct.

C'xnpensatory Grab Sampling for Inoperable Unit 2 Containment Atmospheric

I jdiation Monitoring System in accordance with TS 3.4.7.1.

,

, - P1 Cc luct of EP Activities (71750)

Pl.1 Emeraency Plan Exercises

a.Srm

~

The inspectors observed the conduct of multiple emergency plan drills

including two unannounced off hours drills.

-b. e servations and Findinas

On October 30. 1997. resident inspectors participated in an unannounced

off-hours drill of the licensee's emergency plan. The inspectors were

onsite at 3:00 a.m., to observe the start of the drill and the setup of

the Technical Support Center (TSC) and Emergency Operating Facility

(E0F). The TSC and E0F were setup expeditiously and efficiently. The

majority of the licensee staff was able to respond to the site aromptly.

However. two of the required positions for minimum manning of t1e EOF

were not-manned in time. This resulted in the EOF not being staffed and

ready until 95 minutes after declaration of the Alert. 20 minutes more

.than the required time.

The licensee addressed the staffing deficiency promptly. On October 31.

the licensee began briefing all on-call staff to discuss the delay in

manning the EOF and to reiterate the expectations for staff response to

site emergencies. The inspectors observed the first briefing conducted

.on October 31 and concluded that it clearly identified the licensee's

expectations to plant on-call staff.

On-November 18 the inspectors observed the licensee perform another

unannounced off-hours drill to verify the effectiveness of the corrective

-

actions. The ' drill started at 4:30 a.m., and all required positions were

filled within the required times. Specifically, tne EOF was manned and

ready within'70 minutes of declaring the emergency.

0n . November 12. a resident inspector also observed the conduct of an

. announced. emergency plan exercise that involved activation and manning of

lthealternate'[0F. This facility was located at an Alabama Power Com)any

b -(APC) service center in Headland Alabama . The inspector confirmed t1at

_

emergency response. personnel were able.to locate. setup, and fully

.

_

,

Enclosure 2

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activate the alternate EOF. which would be used anytime the onsite E0F is

unavailable, j

c.Concipsions

-Licensee corrective accions for failing tu staff the EOF within the

required time frame were prompt and thorough. The licensee successfully

deconstrated the ability to activate the alternate EOF.

P8 Hiscellaneous Emergency Preparedness (EP) Issues

During a Safety Audit and Engineering Review audit conducted during the

period of November 25, 1996, to February 19, 1997, the licensee

identified inconsistencies in the documentation associated with the

inventory of emergency planning equi) ment. The inconsistencies were

later determined by the licensee to se falsifications of the inventory

checklists. On June 30. 1997, the NRC Office of Investigations (01)

completed an investigation of the apparent failure of an Emergency

Preparedness Technician to perform required equipment inventories and the

associated falsification of inventory checklists. 01 concluded that,

during the period April 1996 through January 1997, the technician failed

to conduct at least three required inspections, and deliberately

falsified at least four checklists. A copy of the synopsis to 01 Report

No. 2-97-005 is attached.

Based on licensee and O! reviews of this issue, a violation of

10 CFR 50.9. Completeness and Accuracy of Information, was identified in

that the deliberate acts of the technician resulted in records that are

required to be maintained by the licensee were not con.piete and accurate

in all material respects. The licensee identified the inconsistencies,

took prompt actions to investigate the issue, completed follow-up actions

'

to ensure that all emergency preparedness equipment was in place and

operable, and took appropriate remedial action. There was no actual

safety consequence as a result of the falsificaticns, and the violation

involved the isolated acts of a low-level individual. Therefore, this

non-repetitive licensee-identified and corrected violation is being

treated as a Non-Cited Violation (NCV). consistent with Section VII,B.1

of the NRC Enforcement Policy. This is identified as NCV 50-348,

364-97-14-08: Falsification of Emergency Planning Checklists Resulted in

inaccurate Records Being Maintained by the Licensee.

SI Conduct of Security and Safeguards Activities (71750)

51.1 Routine Observationc of Plant Security Measures

During routine inspection activities, inspectors verified that portions

of site security program plans were being properly implemented. This was

evidenced by: proper display of picture badges and use of the biometrics

system by plant personnel: appropriate key carding of vital area doors;

adequate stationing / tours in the protected area (PA) by security

Enclosure 2

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personnel: proper searching of packages / personnel at the primary access

point and service water intake structure (SWIS): and adequate performance

of security systems (i.e., video cameras). Security personnel activities

observed during the inspection period were performed well. Site security

systems were adequate to ensure physical protection of the plant.

Inspector tours of the power block and SWIS PA boundaries verified

structural integrity and condition of PA barriers.

F8 Hiscellaneous Fire Protection Issues (IP 71750)

F8.1.(flased)VIO 50-348/96-410-01013: Failure to Assure that Electrical

Cables Associated with Systems Necesjiary to Actueve and Maintain Hot

Shutdown Conditions Were Enclosed in One-Hour Fire Barriers (92904l

The licensee responded to this VIO in correspondence dated December 4

1996 and initiated Corrective Action Reprt (CAR) 2225. An inspector

reviewed the licensee's letter, completed CAR. and implementation of the

corrective actions. The inspector observed portions of the installation

of one of the fire barriers. This was documented in IR 50-348.

364/97-05. The inspector also verified that the remaining fire barriers

were installed. The corrective actions identified in the CAR were

consistent with those identified in LER 50-348/96-006. This VIO is

closed.

F8.2 (Closed) LER 50-348/96-006-00: Kaowool Fire Barriers Not Installed Der

Desian Drawinas (92700)

This LER reported the issue cited in VIO 50-348/96-410-01013. This LER

is closed based on the licensee's completion of corrective actions

described in Section F8.1.

F3.3 (Closed) VIO R-348. 364/96-410-02014: Inadecuate Periodic Insoection

Procram for Kaowool One-Hogr Fire Barriers (92904)

The licensee responded to this V10 in correspondence dated December 4

1996, and initiated CAR 2226. The inspectors reviewed the licensee's

letter, completed CAR. and implementation of the corrective actions.

Licensee corrective actions included: 1) updating FNP-0-FSP-43. " Visual

Inspection of Kaowool Wraps." to provide more detailed inspection

guidance and identification of specific wraps to be inspected. 2)

training insaection personnel for required Kaowool configurations, and 3)

reviewir.g otler aspects of the fire protection inspection prograra which

were transferred to maintenance for similar problems. The inspectors

verified that the corrective actions were complete. This VIO is closed.

Enclosure 2

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V; Hanaaement-Heetinas-and Other Areas

- X1-- . Review of Updated Final Safety Analysis Report Commitments .  ;

.

'

A recent discovery of a licensee o)erating its facility in a manner ~

' contrary to the UFSAR description lighlighted the need for a special

-focused review that compares plant practices. procedures and/or

parameters to the UFSAR descriptions. While performing the inspections-

discussed in this-report, the inspectors rt. viewed the applicable portions

of the UFSAR that related to the areas inspected. The inspectors

verified that the UFSAR wording was consistent with the observed plant

oractices procedures-and/or parameters.

F X2  : Exit Heeting.Sunnary i

'The inspectors presented the inspection results to members of licensee

management on December 4. 1997; The licensee acknowledged the findings

presented.

The inspectors asked the 1leensee whether any materials examined during .

the inspection should be considered proprietary. No proprietary

information was identified.

PARTIAL LIST OF PERSONS CONTACTED

Licensee

C -Buck. Operations Superintendent - Unit 2  ;

F Coleman. Maintenance Manager

3' C. Collins. Operations Superintendent - Administration

P. . Crone. Engineering Support Performance Supervisor

T. Esteve. Planning & Control Supervisor

R; Fucich. Engineering Support Manager

S. Gates. Administration Manager

D. Gr:ssette. Operations Manager

'P. Harlos. Plant Health Physicist

R. Hill. General Manager

C. Hillman,- Security Chief

R.-Johnson. 0perations Superintendent - Procedures

T. Livingston, Chemistry Superintendent

R. Martin. Maintenance Team Leader

M. Mitchell~, HP Superintendent

-C.-Nesbitt. Assistant Genera 1' Manager Plant Support

W. :Oldfield. Nuclear _0perations Training Supervisor -

C. Reneau. Maintenance Team Leader---Team 5

M, Stinson, Assistant General Manager. Operations -

G. Waymire. Technical ~ Support Manager

R Yance. Plant-Modifications and Maintenance Support Manager

BRC:. .

J.1Zimmerman -NRR~ Project Manager

.=_.

.

Enclosure 2 '

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INSPECTION PROCEDURES (IP) USED

IP:37551:- 1

IP'50001: Onsite Engineering

Steam Generator Rep lacement Inspection- ,

IPL61726: Surveillance Observations- ,

IP 62707:~ - Maintenance Observations- .

>

IP 71707: Plant Operations

'IP'71714i  ! Cold-Weather Preparations *

IP 71750: Plant Support Activities '

JIP 83750: Occupational Radiation Exposure

Radioactive Waste Treatment, and Effluent-and Environmental

IP 84750:-

'

- Monitoring- s

- IP 86750:- - Solid Radioactive Waste Management and Transportation of

- Radioactive Materials ,

IP 90712: In Office Review of Written Reports of Non-Routine Events at:

,

Power Reactor Facilities

~'.- 'IP 92700: Onsite followup of Written Reports = of Non Routine Events at f

Power Reactor Facilities

IP 92901: Followup ~- Operations

IP 92902: Followup - Maintenance  !

-IP 92903: Followup - Engineering

-IP-92904: Followup _- Plant Support-

--TI 2515/133: Im31ementation of Revised 49 CFR Parts 100-179 and 10CFR

-

'

)ar+ 71. .

_

TI-2515/136: Operation of Dual Function Containment Isolation Valves

,

ITEMS OPENED, CLOSED, AND DISCUSSED

- Opened

Iygg Item Number Status Descriotion and Reference

NCV 50-348. 364/97-14-01 Open Inadequate-Imolementation of Cold

Weather Protection Procedures

(Section 02.7)

NCV 50-348, 364/97 14-02 Open Failure To Sign Off= Steps For

Continuous Use Procedures as They Are-

. Performed (Section M1.1)

- VIO 50-348, 364/97-14-03.

_

Open Inadequate Corrective Actions for-

^

Naintaining Main Steam Valve Room Cork -

Seal Flooding Barrier (Section M8.1)-

NCV 50-348/97-14 04- 0 pen Entry Into TS 3.0.3 Due to the Failure 3

to Follow.the' Work Control Process

. Procedure (Section M8.4)

t

Enclosure 2-

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'

VIO? 50 348.-364/97-14-05- Open  !

l Failure _ to Provide: Tornado Missile '

Protection:for TDAFW Pump Vent Stack:

(Section E8.1)

'

,

NCV' 50'-348,' 364/97-14-06'- '

Open Failure to Follow Wholebody Counting _-

-

(WBC) Analysis Procedures for'.

'

i

Evaluation of Workers' Potential:

Radionuclide Intakes (Paragraph R1.3)

NCV'50-364/97-14-07 Open Failure to Conduct Compensatory Grab; .

Sampling for Inoperable Unit 2- e

' Containment Atmospheric Radiation '

' Monitoring-System in accordance with-

TS 3.4.7.1 (Paragraph R8.3)  :

NCV -50-348, 364-97-14-08 Open Falsification of Emergency Planning

Checklists Rcsulted in Inaccurate -

--

Records Being Maintained-by the -

Licensee (Section P8) <

Closed

lypg Item Number. Status -Description and Reference

NCV. 50-348, 364/97-14-_01 Closed Inadequate Implementation of Cold-

Weather Protection Procedures

(Section 02.7)

NCV 50-348, 364/97-14-02 Closed Failure To Sign Off Steps For

Continuous Use Procedures as They Are

Performed (Section M1.1)

.I

NCV' 50-348/97-14-04- Closed Entry Into TS 3.0.3 Due to the Failure

to Follow the Nork Control Process

N cadure (Section M8.4)

LER 50-348, 364/96-01 Closed- TS Action Statement Requirement Not-

.

Met For SSPS Testing (Section M8.3)

u

-LER 50-348/97-11- C W,ed Entry Into TS 3.0.3 Due to the Failure-

, to Follow the Work Control-Process

Procedure (Section M8.4)

IFI 50:348.1364/96-02 03-  : Closed Pre-Action Sprinkler System Failures

(Section-M8.2)-

i

LER 50-348, 364/97-07-00- ' Closed

-

0utside Of Design Basis _ Due To

Degraded Cork Material (Section M8.1)

l

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Enclosure-2._

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LURI '50-348,.364/97-201-08 Closed- Tornado Protection of TDAFW-Pump Vent: i

Stack 'Section E8.1)

. ~LER 450 348/96-006-00- -Closed - Kaowool Fire Barriers Not Installed  !

- per Design Drawings (Section F8.2)-

' ~ VION 50-348/96-410-01013 Closed Failure to Assure that Electrical

Cables Associated with SystemsL

i -

- Necessary to Achieve and Maintain Hot  :

Shutdown Conditions Were Enclosed in -

One-Hour Fire Barriers (Section F8.1)

'

--VIO 50-348,'364/96 410-02014 Closed Inadequate Per. iodic Inspection Program

for Kaowool One-Hour Fire Barriers

(Section F8.3)-

- - -

Failure to FolicW Wholebody Counting; i

NCV 50-348;-364/97-14-06 Closed-

(WBC) Analysis Procedures for i

Evaluatiore of Workers' Potential

Radionuclide Intakes (Paragraph R1.3)

-NCV- 50-364/97-14 07

-

Closed Failure to Conduct Compensatory Grab

Sampling for Inoperable Unit 2

. Containment Atmospheric Radiation-

r Monitoring System in accordance with

TS 3.4.7.1 (Paragraph'R8.3)

NCV 50-348, 364-97-14-08 Closed Falsification of Emergency Planning

Checklists Resulted in Inaccurate

Records Being Maintained by the

Licensee (Section P8) .

VIO 50-348/97--10-05 Closed Inadequate Configuration Control of U1

-

RMS Particulate Sample Lines

(Section R8.2)  ;

LER 50-364/97-04-00 Closed Operating Outside of Technical

E Specifications Due. to Required

Containment Grab Samples Not-Being

>

Taken (Section R8.3)

.

Discussed-

,

Iygg Item Number Status Descriotion and Reference ,

sVIO:150-348. 364/96-10-01~- Open: Failure to Construct and Maintain an-

"As-Built" Sample Line in Accordance

-

.

with Configuration Control Procedures-

m and Drawings (Section R8.1)

.

i

, Enclosure 2-

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a. F

,

.

SYNOPSIS

The Office of Investigations. U.S. Nuclear Regulatory Commission. Region II.

initiated this investigation on March 17, 1997. in order to determine if a

former Emergency Planning (EP) techr.ician at Alabama Powar Company's Joseph m.

Farley Nuclear Plant had failed to conduct required inspections of emergency

equi) ment and supplies, and deliberately falsified EP equipment inspection

checclists.

Based upon the evidence develo)ed in this investigation, it is concluded that,

during the period April 1996 tirough January 1997, the former EP technician

failed to conduct at least three required inspections, and deliberately

falsified at least four checklists.

Case'No. 2-97-005 Attachment