ML20199F541

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Insp Repts 50-321/97-11 & 50-366/97-11 on 971116-1227. Violations Noted.Major Areas Inspected:Operations, Engineering,Maint & Plant Support
ML20199F541
Person / Time
Site: Hatch  Southern Nuclear icon.png
Issue date: 01/23/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20199F462 List:
References
50-321-97-11, 50-366-97-11, NUDOCS 9802040036
Download: ML20199F541 (52)


See also: IR 05000321/1997011

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION 11

Docket Nos:

50 321 and 50 366

License Nos:

OPR 57 and NPF-5

Report No:

50-321/97-11. 50 366/97 11

Licensee:

Southern Nuclear Operating Company. Inc. (SNC)

Facility:

E. 1. Hatch Units 1 & 2

Location:

P. O. Box 2010

Baxley, Georgia 31515

Dates:

November 16

December 27, 1997

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Inspectors:

B. Holbrook. Senior Resident inspector

J; CLnady. Resident inspector

L. Stratton Safeguards inspector (Sections S1,

S2.1 S3. S7. and S8)

G. Kuzo. Senior Radiation Specialist (Sections

R1.1 R1.2 R1.3. R5. R7. and R8)

K, O'Donohue. Resident Inspector (Section 01.3)

Accompanying Inspectors:

T. Fredette. Resident inspector

S. Rohrer, Radiation Specialist

Approved by:

P. Skinner. Chief. Projects Branch 2

Division of Reactor Projects

Enclosure 2

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EXECUTIVE SUMMARY

Plant Hatch. Units 1 and 2

NRC Inspection Report 50 321/97-11, 50 366/97-11

This integrated inspection included asp? cts of licensee operations,

engineering. maintenance, and plant support.

The report covers a 6 week

period of resident inspection and region based specialist inspection.

Doerations

0)erator response to the transient and manuci scram resulting from

e

t1e Unit 2 Condensate Booster pump check vilve problems were good.

Performance during the subsequent unit sta' tup was excellent

(Section 01.2).

Maintenance and engineering provided excellent support to

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operations for the Unit 2 system and component damage assessment

and re3 air activities resulting from the Unit 2 condensate booster

pump cleck valve problems.

Management was actively involved in

the activities and provided excellent oversight and diret. tion

(Section 01.2).

Plant operators' observation and attention to the Unit 2

condensate booster pump system response resulted in excellent

control of the problem (Section 01.2),

Operations personnel were knowledgeable and generally

e

professional.

Interaction with other grou

minimize distractions in the control room.ps was controlled to

However, inconsistent

three-part communications by the operators was observed

(Section 01.3).

Operator performance during the Unit 1 startup following the

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refueling outage was good.

Systems and components observed

operated as expected.

Technical Specification and regulatory

requirements were met for the startup (Section 01.4).

e

Non-Cited Violat,an (NCV) 50-321/97 11-01. Failure to Follow

Procedure and inadequate Procedure Results in Group 1 Isolation,

was identified (Section 03.1).

Violation 60-321/97-11-02. Late 10 CFR 50.72 Notification for

Unit 1 Engineered Safety Feature (ESF) Actuation, was identified.

Operators failed to make the req'.iired 4-hour report that the

drywell pneumatic system had isolated (Section 04.1).

e

Violation 50-321, 366/97-11-03. Inadequate Corrective Actions for

Late 10 CFR 50.72 Notifications, was identified.

The previous

corrective actions failed to prevent four late 10 CFR 4 hour

required reports that occurreo within the past two years

(Section 04.1).

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2

Operator actions were appropriate and timely for the power

o

excursion due to the 2A recirculation pump spurious speed increase

on Unit 2. Engineering and maintenance support was good

(Sectinn 04.2).

Maintenance

Maintenance activities were generally completed in a thorough and

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professional manner (Section M1.1).

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The decision by licensee management to shutdown Unit 1 for

corrective maintenance following the restart problems was

appropriate.

Poor maintenance work practices contributed to the

unit shutdown. Maintenance response and support of the work

activities were good (Section M1.2).

Poor work practices and a lack of attention to detail by craft

e

personnel during the work activity on the Unit 1 extraction relay

dump valve during the Fall 1997 Refueling Outage contributed to

the unit being shutdown for corrective maintenance (Section M1.2).

e

A poor maintenance work practice resulted in a leak from the

nitrogen supply line to the Unit 1 "B" inboard main steam

isolation valve (Section M1.2),

The licensee's preparation for cold weather was good.

The

e

procedures for performing equipment operability checks were

appropriate and maintenance corrected the identified cold weather

preparation deficiencies in a timely manner (Section M2.2).

Plant Modification and Maintenance Su) port response to removed

insulation on Unit 1 was prompt.

Wea<nesses were identified in

site supervisory ovarsight of loaned personnel for this work

activity performed during the Unit I refueling outage

(Section M2.3).

e

For the surveillances observed, all data met the required

acceptance criteria and the equipment performed satisfactorily.

The performance of the operators and crews conducting the

surveillances was generally professional and competent

(Section M3.1).

e

The overall performance of the Main Control Room Pressurization

System test activity was excellent

Personnel performing the test

were knowledgaable of the systems and test requirements.

Procedures were correctly used.

Tie systems responded as expected

and all test acceptance criteria vere met.

The 10 CFR 50.59

evaluation for procedure changes was satisfactory (Section M4.1).

Enclosure 2

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e

Non cited violation 50 321/97-11-04 Failure to Meet Unit 1

Technical Specification Actions for Primary System Pressure

Boundary leakage, was identified.

Corrective actions were

appropriate for the leaking Transversing incore Probe tubing.

Licensee Event Report 50-321/97-06, was detailed and thorough

(Section M8.1).

Enoineerina

The Hatch Unit 2 torus-to-reactor building vacuum breaker design

e

does not meet General Design Criteria 56 for acceptability of a

single passive component to meet containment isolation

requirements.

This issue was identified as Unresolved item (URI)

50-366/97 11-08. Unit 2 Failure to Meet General Design Criteria 56

for Proper Automatic Containment Isolation Valve Outside

Containment, periing additional NRC review (Section E2.1).

e

Maintenance and engineering actions in response to the 2C

Emergency Diesel Generator (EDG) start failure were appropriate

and thorough.

Maintenance and engineering recommendations

reflected a good interface with the vendor (Section E2.2).

The Maintenance Rule periormance criteria for the EDGs were being

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met and performance data was being tracked and updated

periodically (Section E2.2).

Plant Suonort

e

Radiological controls, area postings and container labels

associated with radwaste processing storage and transportation

activities were maintained in accordance with Technical

Specifications: 10 CFR Parts 20 and 71: and 49 CFR Parts 100-179

requirements (Section R1.1).

Improvements were noted in the radwaste facility housekeeping and

e

cleanliness (Section Rl.1).

o

Proficiency of chemistry technicians and radwaste operators during

the conduct of a Unit 2 (U2) liquid Floor Drain Sample Tank

effluent release was demonstrated (Section Rl.2).

e

Excluding source check requirement concerns. liquid effluent

procedures were satisfactory and im)1emented effectively in

accordance with 10 CFR Part 20. Tec1nical Specification and

Offsite Dose Calculation Manual requirements (Section Rl.2).

Inspector Followup Item (IFI) 50-321. 366/97-11-05 was identified.

e

Review Adequacy of Revised Liquid Effluent Release Procedures to

Meet Offsite Dose Calculation Manual (0DCM) Monitor Check Source

Requirements (Section Rl.2).

Enclosure 2

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Licensee program guidance for processing,l site met 10 CFR

packaging, and

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transporting radwaste to a licensed buria

Parts 20, 61. 71: and 49 CFR Parts 100-179 requirements

(Section RI.3).

Radwaste processing. packaging and transportation activities were

e

implemented effectively (Section Rl.3).

General Health Physics activities observed during the report

e

period included locked high radiation area doors, proper

radiological posting and personnel frisking upon exiting the

Radiological Controlled Area.

Minor deficiencies were discussed

with licensee management (Section Rl.4).

Hazardous material training for personnel processing, handling,

o

and shipping Condensate Phase Separator resins was conducted in

accordance with 49 CFR 172.702 requirements (Section R5.1).

Counting room gamma spectroscopy Quality Control activities were

implemented appropriately (Section R7.1).

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A lack of attention to detail by responsible personnel for

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<

selected laboratory Ouality Control activities was identified

(Section R7.1),

o

Licensee initiatives to manage exposure and reduce worker

contamination events during the Unit 1 Refueling Outage 17

activities were effective (Section R8.1),

o

Excluding a November 14. 1997 personnel contamination event,

controls for minimizing exposure from intakes of radionuclides

were effective and potential radionuclide into ws were evaluated

properly (Section R8.1).

e

Violation 50 321, 366/97-11-06 was identified for failure to

follow procedures for radiation and contamination control and for

personnel decontamination in accordance with Technical Specification 5.4.1.a (Section R8.1),

o

Violation 50 321, 366/97-11-07 was identified for failure to

follow procedures for Radiation Work Permit system implementation

in accordance with TS 5.4.1.a (Section R8.3).

Licensee root cause analyses to identify causes of an increasing

e

trend in worker contaminations and corrective action

recommendations were appropriate (Section R8.4).

The licensee adecuately addressed, through procedures and training

of the EAP provicers, the process and conditions in which a

mandatory EAP referral will be utilized (Section S1.3).

Enclosure 2

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The licensee's practice of utilizing designated vehicles for

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offsite use, as proposed in their December 1996 PSP change, was

discussed.

The licensee agreed to evaluate the difference between

the December 1996 plan change and 10 CFR 73.55(d)(4)

(Section S2,1).

Protected and vital area access controls met the requirements of

e

the Physical Security Plan (Section S2.1).

Physical Security Plan changes submitted by the licensee under the

e

provisions of 10 CFR 50.54(p) did not decrease the effectiveness

of the PSP.

The licensee agreed to clarify the inconsistent

issues identified in the December 1996 plan change (Section S3.1).

e

Security audits were being conducted in accordance with the

licensee's Physical Security Plan (Section S7.1).

Enclosure 2

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RepfrtDetaih

Summary of Plant Status

Unit 1 began the report period in day 37 of a scheduled 37 day refueling

outage.

On November 18, unit power was increased to about 20% Rated

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Thermal Power (RTP).

However, the unit was manually scrammed the same

day to implement corrective maintenance for equipment problems

identified during the startup. On November 21, the unit was taken

critical and tied to the grid.

The unit achieved 100% RTP on November

24.

The unit o

report period, perated at this power level for the remainder of the

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except during routine testing activities.

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Unit 2 began the report period at 100% RTP.

On November 20. the unit

was manually scrammed from about 70% RTP due to a condensate booster

pump check valve failure. The unit was taken critical on November 26.

tied to the grid on November 27 and achieved 100% RTP on November 29.

On December 2 the unit experienced a power increase transient due to a

reactor recirculation pump controller problem.

Power increased to about

107% RTP for a short period of time and was immediately restored to 100%

RTP.

The pump speed controller was repaired.

The unit operated at 100%

RTP for the remainder of the report period, except during routine

testing activities.

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I. Operations

01

Conduct of Operations

01.1 General Comments (71707)

The inspectors conducted frequent reviews of ongoing plant

operations.

In general, the conduct of operations was

professional and safety-conscious; specific events and observation

are detailed below.

01.2 Unit 2 Transient and Manual Scram Due to a Condensate Booster Pumo

(CBP) Check Valve Failure

a.

Inspection Scone (71707) (93702)

The inspectors reviewed operator and unit response following a

plant transient and manual scram.

The inspectors assessed system

and com

damage,ponent damage, reviewed the licensees assessment of the

observed corrective maintenance, and obrerved operator

performance during unit startup activities.

b.

Observations and Findinas

On November 20. Unit 2 o>erators placed the 2B CBP in service in

order to remove the 2A C3P from service to investigate and repair

a previously identified lobe oil problem,

immediately after the

2A CBP was removed from service, the-low suction pressure alarm

Enclosure 2

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for the reactor feed

room. The operators' pumps (RFPs) actuated in the main control

attempt to restart the 2A CBP failed.

The 2A

RFP tripped on low suction pressure and initiated a reactor

recirculation pump runback (both

Reactor

power decreased to about 70% RTP, pumps), as designed.

Operators locally at the 2A CBP reported that the pump was

rotating backwards.

When the 2A CBP was removed from service, the pump discharge check

valve failed to seat pro)erly.

The flow from the 2B and 2C CBP

passed through the 2A CB) discharge check valve and caused the

pump to rotate backwards.

This pressurized the CBP discharge,

pump casing and pump suction line to about 500-550 psig.

A

flexible metal bellows, designed to allow pipe movement. in the

,

pump suction line just before each booster pump was misaligned by

about 2 to 3 inches.

The inspectors walked down the booster aump piping and components

and assessed the leakage and damage.

T1e inspectors observed that

the bellows was intact and there was no leakage.

However, a

bolted flange on the suction _ side of the pump appeared to be

stressed and was leaking slightly. Operations. maintenance and

engineering personnel viewed the piping and components and began

discussing actions to shutdown the unit.

A portable camera was setup to monitor the bellows and the area

was barricaded to prevent personnel entry.

Site management

contacted corporate engineering and discussed the problem.

Management decided to develop a shutdown plan repair plan, and

conduct a controlled unit shutdown to implement repairs.

0)erators began decreasing reactor power at about 8:30 p.m. for

tie planned unit shutdown.

When a reactor feedpump was removed

from service at about 75% RTP. the CBP header pressure

significantly increased.. Due to the difficulty in preventing

increased CBP pressure. the operators manually scrammed the

reactor at 8:52 p.m.

A subsequent licensee walkdown of the )iping following the reactor

scram revealed that additional damage lad occurred to the piping

- and components.

The licensee suspected damage to the pump suction

valve, pump discharge check valve, and possibly the pump discharge

isolation valve.

Additionally, the licensee planned to inspect

the minimum flow valve and re) lace the suction bellows that had

ruptured.

The booster pump t1 rust bearing was suspected to be

severely damaged.

During additional walkdowns, the inspectors observed that the

metal bellows had ruptured and was leaking-slightly (the

Enclosure 2

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condensate system was shutdown), the piping and bellows were

significantly misaligned (by about 1 foot), and the CBP piping had

come in contact with one fire protection line.

Some hangers (two,

as observed from the floor) for the fire protection )iping were

bent and two valves were leaking slightly.

Two or t1ree hangers

on the CBP piping were also bent or stressed.

The ins)ectors

verified that operations management was aware of the o] served

damage.

An event review team was assigned to review and assess

the response to the scram.

Corporate engineers were being dispatched to the site the

following day to assess the damage and make recommendations for

repairs.

Operations began actions to bring the unit to hot

shutdown.

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The licensee and the NRC held a conference call on November 21 and

discussed the unit's response, system and component damage, and

planned actions to further assess the problems. A followup

conference call was made on November 25 to discuss the results of

the licensees walkdown and assessment of the damage and proposed

actions to correct the problems.

Maintenance completed repairs on the 2A CBP suction valve,

discharge valve, minimum flow valve, and pump discharge check

valve.

A new manual isolation valve was installed in the CBP

minimum flow line.

Following the maintenance activities,

operations verified a clearance boundary for the damaged booster

pump.

The condensate system was placed in service and a unit

startup began.

The remaining repairs were scheduled to be

completed while the unit is operating.

The inspectors observed

parts of the maintenance work and later verified that there was no

system or component leakage,

The licensee identified that the valve hinge pin and a retaining

lug for the valve disc spring assembly were broken. All parts of

the damaged valve were located and collected.

Maintenance also

disassembled, inspected and replaced the spring and hinge pin for

the 2B CBP.

The spring was broken and some slight wear was

observed on the hinge pin.

The 2C pump discharge check valve was

replaced during the spring 1997 refueling outage and was not

inspected at that time.

Operations personnel had previously

reported a strange noise in the vicinity of the failed check valve

several days before the failure.

This problem was documented and

was being tracked for future maintenance.

The licensee reviewed other systems and determined that similar

check valves were used only in the condensate system of both

units.

The licensee also reviewed the routine preventive

maintenance (PM) for the check valve inspection to determine if

the inspection frequency should be changed.

The inspectors were

Enclosure 2

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later informed by maintenance management that a recommendation was

made to significantly reduce the existing ins)ection frequency

specified in the Inservice Testing Program.

Engineering and

corporate personnel were to review the recommendation.

0)erations began unit startup on November 26.

The inspectors

o) served parts of the unit startup on November 26 and 27 and did

not observe any deficiencies.

Management personnel were observed

in the control room providing oversight and direction.

The unit

achieved 100% RTP on November 29.

c.

Conclusions

The inspectors. concluded that operator response to the transient

and manual scram was good.

Performance during the unit startup

was excellent.

Maintenance and engineering provided excellent

support to operations during the system and component damage

assessment and repair and replacement activities.

Management was

actively involved in the activities and provided excellent

oversight and direction.

0)erators' observation and attention to

system response when the CB) was removed from service resulted in

excellent control of the problem.

01.3 Observations of On-Shift Doerations Performance

a.

Inspection Scone-(71707)

The inspectors observed control room activities plant operator

rounds, and shift turnovers.

The inspectors interviewed plant

operators, reactor operators, and senior reactor operators.

The

procedures reviewed included AG MGR-54-0592N. " Plant

Communications." Revision (Rev.) 1. 30AC-0PS-003-05. ' Plant

Operations.' Rev. 18. AG MGR 21-0386N. ' Evolution Pre-Test Brief

Requirements.' Rev. 0, and 34AB-C71-001-1S. " Scram Procedure."

Rev. 7.

The inspectors also reviewed portions of the job

performance manuals.

b.

Qbservations and Findinal

The inspectors observed on-going plant operations during the

5,tartup phase of the Unit 1 refueling outage,

in general, the-

observations indicated that the conduct of o)erations was safety-

conscious and actions were in accordance wit 1 the technical

specifications (TS) and plant procedures.

Evolution pre-briefings were observed to be performed per

procedure with the attendees actively participating.

Actions.for.

unex)ected situations and plant conditions were discussed as part

of t1e pre-briefing.

Enclosure 2

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The inspectors observed that the plant operators were

knowledgeable and well-informed of activities in the plant.

During plant walkthroughs with plant equipment operators, random

sampling of knowledge and performance items indicated that they

were familiar with actions required in the plant during emergency

conditions.

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Items identMied during the 31 ant walkthroughs included poor

housekeeping, such as trash )ehind control panels unused hoses

left taped to the ceilings ladders not stored correctly, and

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ladders in use not tied off correctly.

The housekeeping

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observations were discussed with plant management.

The inspectors reviewed the status of deficiency cards attached to

or located near equipment controls and indications on the Unit 1

control board. The small number and recent date of the deficient

items presented no major safety or inspector concerns.

Controi room operators were observed acknowledging annunciator

alarms without verbally announcing the alarms.

Occasionally, when

an annunciator alarm was called out, there was no formal response

from another operator acknowledging the announced alarm.

When

asked about management expectation of annunciator alarm response,

licensee management stated that if the alarm is ex)ected and

verified to be of a known cause, such as a test. tie senior

reactor operator could allow the reactor cperators to acknowledge

the alarms without oral response. The inspectors stated that

these alarms were not called out since the relief of the previous

shift.

The Senior Reactor Operator stated that he did not think

operator performance was appropriate and he would address the

matter with the operators involved. Also, some annunciator alarms

were left without acknowledgment for longer periods of time than

usual. Although two way communications were observed, the final

acknowledgment by the first comunicator was often dropped.

Some

operators called out information, received no &sponse, and did

not repeat the information.

The inspectors observed that some

communications did not meet management's expectations for three-

part communications.

Control room noise level was generally good; individuals near the

control boards were there for specific work.

Most conversations

held at the control boards were discussions addressing the work at

that board.

The inspectors observed that the unit supervisor took

action to remove the personnel when the operators manipulating

controls would be distracted.

An example of this was the removal

of all extra reactor operators during control rod manipulations.

Operator response to a manual reactor scram was observed.

The

operators were well-prepared and familiar with the required scram

Enclosure 2

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actions.

Procedures were used and overall performance was

satisfactory.

c

CQuplusions

The inspectors concluded that operations personnel were

knowledgeable and generally professional.

Interaction with other

groups was controlled to minimize distractions in the control

room.

The operators' communications style, inconsistent three-

part communications, was not consistent with management

expectations.

01.4 Observations of Unit 1 Startuo Activities Followina Refuelina

a.

insoection Secoe (37828) (60710) (71707)

The inspectors observed operator and system performance from the

control room during startup activities.

The inspectors observed

systems and components that had corrective maintenance or design

change work performed during the refueling outage.

The inspectors

reviewed the following procedures and observed selected portions

of ongoing activities.

345V-SUV-018-15. "ECCS Status Checks."

Rev. 6. 34G0 0PS-003 15. "Startup System Status Checklist." Rev.

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9, 3450 E11-010-15. "RHR System." Rev. 24, 3450 N30-001-15. " Main

Turbine Operation," Pov. 19, 34SV-N30 001-15. "Hain Turbine Weekly

Surveillance Test." Rev. O, 3450 N21-003-1S, " Condensate Polishing

Demineralizer System," Rev. 11, and 3450 N21-007-1S, " Condensate

and Feedwater System." Rev. 27. Additionally, the inspectors

reviewed completed procedures which verified that TS requirements

were met.

b.

Observations and Findings-

The inspectors observed that pre evolution briefings were

routinely held and the activities met the requirements of the

procedure.

The activities were gencrally well controlled and

supervisory oversight was evident.

Operators monitored the

control board and were well aware of plant system configuration

and status.

Communications were generally three part

communications but at times only two-part communications were

observed.

The inspectors observed operators roll the main turbine to rated

speed, place the RHR system in the torus cooling mode, place

condensate and feedwater components in service, and place

feedpumps in service.

The inspectors reviewed completed system valve lineups and system

status checks associated with these evolutions.

No deficiencies

were observed and TS requirements were met,

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Enclosure 2

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c.

Conclusions

,

The inspectors concluded that operator performance during the

Unit 1 startup following the refueling outage was good.

Systems

4

arvi components observed operated and responded as expected. TS

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and regulatory requirements were met for the unit startup.

03

Operations Proceciures and Documentation

03.1

Failure to Follow Procedure and inadeouate Procedure Results in

Groun 1 isolation Sianal on Unit 1 Due to Low Condenser Vacuum

a.

Insoection Scone (717021

The inspectors reviewed general operating )ev,edure

roc

34G0-0PS-013-IS " Normal Plant Shutdown,

t

23 and abnormal

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procedure 34AB C71-001 lS " Scram Procedure " Rev. 7.

These

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arocedures were used on November 18 during the normal shutdown of

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Jnit 1 for corrective maintenance.

Discussions were also

conducted with licensee personnel.

b.

Observations and Findinns

Unit I was manually scrammed on November 18 to perform corrective

maintenance for problems encountered during startup following the

17th refueling outage. The operating crew performed the scram

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actions of procedure 34AB C71-001-1S,

The inboard and outboard

main steam isolation valves (MSIV's) in the 'A' main steam line

(MSL) were manually closed following the scram to isolate a leak

on valve 1B21-F025A MSIV LLRT Test Connection valve.

This

problem is discussed in Section M1.2 of this report.

Due to low

decay heat, the operating crew closed the remaining inboard MSIVs

(B. C. and D) to reduce the cooldown rate in accordance with step

7.5.6.5 of piocedure 34G0 0PS-013-15.

The o)erating crew was performing th( 3ctions of procedure

34G0 0PS-013-15 concurrently with pr m are 34AB-C71 001-15 when a

Group 1 isolation occurred.

The ink

tors determined from a

review of procedure 34AB-C71-001-15. ,aat step 4.14.3 provided

instructions to the o)erator for opening the main condenser vacuum

breaker valves when tie MSIVs are closed for reasons other than

high radiation.

The inspectors did not identify any procedural

guidance for placing the Condenser Low Vacuum Trip Bypass switches

to the " Bypass"

yosition.

This was the correct action and would

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have prevented tie Group 1 isolation.

Procedure 34GO-0PS 013-15.

step 7.6.8. instructed the operator to place the low vacuum bypass

switches in the " Bypass" position when reactor pressure is

approximately 500 psig.

Enclosure 2

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The inspectors discussed this issue with operations management and

were informed that the operators should know from training and

experience that the condenser low vacuum trip by) ass switches are

to be placed in the " Bypass" position prior to t1e o)ening of the

condenser vacuum breakers.

Placing the switches in )ypass had

been discussed earlier during the pre job briefing.

For corrective actions. the licensee counseled the personnel

involved regarding their oversight and stated that procedures

34AB C71 001-15 and 34AB-C71-001-25 would be revised.

These

procedures had not been revised as of the end of this report

,

period.

(cnclusiorn

.

Operator error and procedural inadequacy resulted in the receipt

of an Engineered Safety Feature (ESF) Group 1 1 solation signal.

This violation constitutes a violation of minor safety

significance and is identified as Non Cited Violation (NCV) 50-

'

321/97 11-01, failure to follow Procedure and inadequate Procedure

Results in Group 1 Isolation.

04.0 Operator Knowledge and Performance

04.1 Late 10 CFR 50.72 Report for a Valid Enoineered Safetv Feature

Actuation on Unit 1

a.

insoection Stone (71707) (92901)

,

The inspectors reviewed procedure 00AC-REG 001-05. " Federal and

State Reporting Requirements." Rev. 5. and discussed their

observations with operators and o)erations management concerning

the Unit 1 ESF actuation on Novem)er 18 and the operators' failure

to make the required NRC 4-hour report.

b.

Observations and Findinas

On November 18. Unit 1 was being started up following a refueling

outage. The reactor was at about 20% RTP when equipment problems

required the unit to be shutdown to implement corrective

maintenance.

This issue is discussed in Sections 03.1 and M1.2 of

this Inspection Report (IR).

The unit was manually scrammed at

about 4:20 p.m.

At about 4:55 p.m.. operators received a control

room alarm for a Group 1 isolation and an isolation of the drywell

aneumatic system.

The isolation signal could not be reset.

Operators initiated a deficiency card.

The inspectors' review indicated that the Operations

Superintendent on Shift (SOS) and the Shift Supervisor (SS) were

aware that the-drywell pneumatics supply had isolated.

Each had

Enclosure 2

-

-

--

__

_

_

_

._ _

_

.

.

9

made log entries to document that the system had isolated on high

flow. Nuclear Safety and Compliance (NSAC) personnel later

reviewed the Safety Parameter Display System (SPDS) tapes to

verify valves that may have closed and identified that the drywell

-

pneumatic system had isolated and had not been reported as an ESF.

The inspectors determined that the identification of this

deficiency was good performance.

Procedure 00AC REG 001 05, item 53 of Attachment 1. Reporting

Requirements - Four Hour Reports, specifically identified the

reporting requirements for an automatic actuation of an ESF and

further identified that the containment isolation system was an

ESF system. The procedure identified that the SOS as one of the

individuals responsible for making the re) ort. . In this case,

o)erations supervision failed to ensure t1at the ESF actuation for

t1e containment isolation was re)orted within the required 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

4

time period. As a result, the 4-lour NRC notification was made at

12:58 p.m. on November 19, which was about 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> late.

This is

identified as Violation 50 321/97-11 02 Late 10 CFR 50.72

Notification for Unit 1 Engineered Safety Feature Actuation.

The inspectors reviewed licensee performance with respect to late -

NRC notifications during the last two years.

The ins)ectors

documented an NCV for a late 10 CFR 50.72 report in 11 50-321,

366/96 06,

The inspectors concluded that the reason for this late

notification was due to deficiencies in operations personnel

interpretation and understanding of the reporting requirements. A

second late notification was identified and a violation was issued

on August 30, 1996. in IR 50 321, 366/96 10.

A third late

notification was identified and a violation was issued on May 5.

1997.

This problem is documented in IR 50-321, 366/97-02.

Appendix B of 10 CFR 50 requires in part, ccrrective actions to

preclude repetition of significant conditions adverse to quality.

The inspectors concluded that the licensee's correctivo actions to

prevent late 10 CFR 50.72 notifications were not adequate to

prevent recurrence.

This is identified as VIO 50-321,

366/97-11-03. Inadequate Corrective Actions for late 10 CFR 50.72

Notifications,

c.

Conclusions

The inspectors identified VIO 50-321/97 11-02. Late 10 CFR 50.72

Notification for Unit 1 Engineered Safe.y Feature Actuation.

Also, the inspectors concluded that ,.evious corrective actions to

prevent recurrence of late 4-hour reports to the NRC were not

adequate to meet the requirement of 10 CFR 50. Appendix B.

Criterion XVI. Corrective Action.

The failure to implement

adequate corrective actions was identified as V10 50-321. 366/97-

Enclosure 2

l

-.

.

10

1103. Inadequate Corrective Actions for Late 10 CFR 50.72

Notifications.

04.2 Unit 2 Power Excursion be to Sourious Soeed increase of the 2A

Reactor Recirculation ( N) Pumo

a.

Insnection Scone (71707) (62707)

The inspectors reviewed Unit 2 TS 3.4.1. " Recirculation Loops

Operating" and 3.4.2. " Jet Pumps." and procedures 34AB B31 001-25.

" Trip of Or.e or Both Reactor Recirculation Pumps, or Recirc l. oops

Flow Mismatch." Rev. 5. 34G0 0PS 022 05. " Maintaining Rated

Thermal Power." Rev. 7.- and 34S0 B31-001-2S. " Reactor

Recirculation System." Rev 23.

Maintenance Ucrk Orders (MW0s)

associated with the troubleshooting and repair activities of

Instrumentation and Control (l&C) personnel were also reviewed.

These reviews were associated with the spurious increase of the

2A RR pump to the high spced stop.

The inspectors also discussed

the event with reactor engineering. 1&C. and operations personnel.

b.

Observations and Findinas

On December 2. the s)eed of the 2A RR pump on Unit 2 spuriously

increased to the hig1 speed stop (105% of rated speed).

Reactor

power increased from 100% RTP to 107% RTP and subsequently

stabilized at 104%.

Upon discovery of the cause of the power

excursion, the shift operating team placed the 2A ) ump controller

in manual and reduced the speed to match that of t1e 'B'

RR pump

per the direction of the Shift Supervisor.

Reactor power was

a) proximately 96% with the RR pump speeds matched.

The unit was

a)ove 100% RTP for approximately two minutes.

The "immediate exit

region" of the power to-flo+ map was entered for this length of

time.

The inspectors were informed by operations and reactor engineering-

personnel that a thermal limits review indicated that no thermal

limits had been exceeded. -Operations personnel also informed the

inspectors that no TS entry conditions existed during the event.

The inspectors verified no TS entry conditions existed through an

independent TS review.

- Deficiency Cards '(DCs) were written for I&C technicians to

investigate the cause of the controller's speed ramp to the high

s)eed stop.

The inspectors reviewed MW0s 2 97-3343 and 2-97-3344.

T1e inspectors observed from the MWO review that I&C personnel

discovered that the speed bias button was stuck with a slight

increase signal.

The I&C technicians cleaned and lubricated the

bias button per instructions provided in MWO 2-97-3343.

c

Enclosure 2

.

.

11

The inspectors discussed the adjustment of the bias button with

the operators and operation supervision.

The inspectors were

informed that the bias had not been recently adjusted prior to the

speed excursion of the 2A RR pump.

It was further stated by

operations personnel that bias adjustmentt on the RR speed

controller were performed on an infrequent basis for maintaining

100% RTP.

Bias manipulation allows for precise control of the RR

pumps' speed.

The inspectors reviewed procedure 3450 831-001 2S

for the RR system and did not find instructions for using the bic;

buttons.

This nas discussed with operations management who stated

that the procedure would be revised to include the necessary

instructions for adjusting the pump bias.

The inspectors were informed by 1&C supervision that a similar

button sticking problem had been observed with the older

controllers on at least one occasion but that this was the first

time that this type of speed control problem had occrred with the

new Yokogawa controller

The inspectors were aware that similar controller button sticking

problems had occurred on the feedwater system controllers. The

inspectors had observed that deficiencies were written and caution

tags were placed to remind operators of the problem,

The problems

were discussed at shift meetings and the caution tags were later

removed.

The inspectors discussed the button sticking problem

with operations personnel.

Each operator questioned was aware of

the problem.

The inspectors concluded that the button sticking

problem was common knowledge.

1&C personnel had changed the type

of lubricant used and believed the problem was corrected.

Following 1&C troubleshooting and repair activities, the unit was

returned to 100% aower and the 2A controller was returned to the

automatic mode.

10 further problems were observed.

c.

Conclusions

The actions of operations personnel were appropriate for the power

exursion due to the 2A RR pump spurious speed increase to the

high speed stop.

Reactor engineering and I&C personnel provided

good support to operations.

08

Hiscellaneous Operations Issues (92700) (92901) (92904)

08.1

(Closed) LER 50-366/97-10:

Manual Reactor Shutdown Results in

Water Level Decrease and Group 2 and 5 PCIS Actuations.

The licensee issued this Licensee Event Report (LER) dated

December 8. 1997.

This issue is documented in Section 01.2 of

this IR.

The LER presented no new information. Based upon the

inspectors' review of licensee actions, this LER is closed.

Enclosure 2

_- - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

- _ _ _ _ _ _ _ _ _

.

I

12-

08.2 (Closedi LER 50 321/97 08:

Personnel Error and Inadeauate

Procedure Results in Groun 1 lsolation on Low Condenser Vacuut

-

The licensee issued this LER dated December 8. 1997. This issue

is discussed in Section 03.1 of this IR.

The LER presented na new

information.

The inspectors verified that the procedures were

-revised on December 30.

Based upon the inspectors' review of

licensee actions and the issuance of a NCV. this LER is closed.

08.3 (Closed) URI 50-321.366/96 13 02:

EOP Deviation From EPG Sten

RC/P-3.

,

This Unresolved item is discussed in IR 50 321, 366/96 13.

Section 03.2.

The NRC staff reviewed this issue under Task

Interface Agreement (TIA) 96 020 and concluded that an E0P

deviation from the Emergency Procedure Guidelines did not exist.

Based upon the additional review, this Unresolved item is closed.

08.4 (Closed) VIO 50-321. 366/97-02-02:

Failure to Follow Procedure -

Multinle Examnles.

The licensee res)onded to this violation in documentation dated

May 30, 1997,

11e first of the four examples dealt with the

failure to follow a procedure which resulted in the automatic

start of an emergency diesel generator. The licensee identified

the cause as personnel error and less-than adequate procedural

guidance.

For corrective actions, the licensee counseled the

individusls involved and revised procedures for better clarity.

The inspectors observed that the procedures for both units were

revised as stated in the licensee's response to the violation.

The second example dealt with maintenance activities being

performed on equipment with an inadequate clearance boundary.

The

cause was personnel error. As corrective actions the licensee

counseled the personnel involved and the issue was discussed in

Maintenance tool box meetings.

The third example dealt with the failure to recognize that the

removal of bolts during a design change resulted in a degraded

fire barrier.

The cause was )ersonnel error and a less-than-

adequate fire protection checclist.

For corrective actions.-the

personnel involved were counseled and the fire protection

checklist was revised to aid personnel in identifying a breach of

fire barriers.

The inspectors observed that the procedures were

revised as stated in the licensee's response.

Additionally, a

departmental directive was issued reinforcing management's

expectations for reviewing fire protection checklists.

The fourth example dealt with maintenance work being performed

that was outside the scope of the approved maintenance work order.

Enclosure 2

l-

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-

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-


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_ _ _ _ _ _ _ _ _ _

__ _

_ _ _ . _ _ _ _ _

.

1

-

i

13

.

t

The cause was personnel error. The foreman involved was

disciplined in accordance with the Positive Discipline Program

regardirg his fbilure to provide adequate supervision of the

workert inv0lved.

The involved worker was coached concerning

'

restrictin9 their work activities to those explicitly described on

the MWO.

Bardd upon the inspectors review of licensee actions,

,

i

this violation is closed.

08.5 Mlpeg Q.J1Q p 366/97 02-03:

Late 10 CFR 50.72 Notification For

!

a

]

$1G/g(Agdafety Feature Actuation for Containment Jsolation.

1

The licensce res)onded to this violation in documentation dated

May 30. 1997.

T u cause of the violation was personnel error.

For corrective actions the licensee counseled the Shift Supervisor

involved.

The operations manager issued a policy letter on

-

'

A)ril 3.1997 specifying how such actuations are to be handled in

tle future.

Based upon the inspectors' review of licensee

actions, this violation is closed.

08.6 1 Closed) VT,50-321. 366/97-05-02:

Failure to Follow Procedure;.

Multiole Ex moles.

'

The licensee responded to this violation in documentation dated

'

August 22. 1997.

This violation contained four examples of

failure to follow procedure.

The first example dealt with a

failure to correctly identify a clearance boundary. The cause was

personnel error.

As corrective actions, the licensee counseled

,

the personnel involved.

The problem was also discussed at

beginning of shift meetings.

An inadequate system drawing

contributed to the problem.

The inspectors verified that the

drawing had been revised as indicated in the licensee's response.

>

1

The second example was caused by inadecuate procedure.

Fire

protection personnel.did not perform acditional surveillances for

rejected fire penetrations.

The inspectors verified that the

f

procedures for both units were revised as stated in the violation

response.

The third example was caused by personnel error. Workers failed

to inform Health Physics (HP) personnel when work conditions were

>

i

not as previously identified.

This resulted in personnel

,

unnecessary contaminations. As corrective actions, the licensee

made personnel aware of the event. its consequences, and causes.

Proper communication and a questioning attitude were stressed.

The fourth example was caused by personnel error.

Poor

communications resulted in personnel contaminations when workers

'

disassembled a contaminated structure without proper HP oversight.

A multi-disciplined Problem Solving Team was formed to

investigatethis and other similar problems and make

c

Enclosure 2

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.

.

14

recommendations for further actions and improvement.

Based upon

the inspectors' review of licensee actions, this violation is

closed.

II. Maintenanc.g

M1

Conduct of Haintenance

M1.1 General Comments

a.

Inspection Stone (62707)

The inspectors observed or reviewed all or portions of the

following work activities:

MWO 1 97-2533:

repair leak on valve IB21-F025A

.

.

MWO l-97-3297:

tighten valve packing on valve 1821-F025A

MWO 1 97-3299:

repack main turbine stop valves 1N30 F006

.

and F007

MWO 1-97-0585:

repair air relay dump valve IN32-F021

.

.

MWO l-97-3320:

disassemble air relay dump valve IN32-F021

and investigate for air leakage

b.

Observations and Findinas

The inspectors found that the work was performed with the work

packages present and being actively used,

c.

Conclusions on Conduct of Maintenance

Maintenance activities were generally completed in a thorough and

professional manner.

However, two examples of poor work practices

during maintenance activities were identified.

M1.2 Restart Problems on Unit 1 FolkMn.gfall 97 Refuelino Outaae

n

a.

Insoection Scone (62707)

The inspectors reviewed ap)licable procedures. Technical

Specifications (TSs), and iaintenance Work Orders (MW0s)

associated with problems encountered during the Unit I restart and

subsequent shutdown following the Fall 1997 refueling outage.

Discussions were also held with various licensee personnel,

b.

Observations and Findinas

The Unit I reactor was brought critical on November 16.

Power was

increased to approximately 20% RTP with the main turbine at 1800

RPM before the unit was manually scrammed on November 18 due to

equipment problems.

The following equipment problems were

Enclosure 2

.

.

15

encountered during the startup and subsequent shutdown of the

unit.

The extraction relay dump valve (IN32-F021) was disassembled

.

end inspec'.ed during the Fall 1997 Refueling Outage.

The

four piston rings in the valve were found to be worn during

'

the inspection. The valve was cleaned and the four worn

piston rings along with 0-rings were replaced.

The valve

was assembled following the maintenance activity.

Durit'g unit startup on November 18. prior to turbine-

generator synchronization to the grid, air was discovered

leakir.g from the valve.

A decision was made to shutdown the

reacto? to support repair o' this valve, in addition to the

main st0p valves (IN30 F006 and 1N30 F007), and the MSIV

drain lire valve (IB21-F025A) discussed above.

The extraction relay dump valve was disassembled and

inspected during the unit shutdown. The inspectors were

informed by the responsible performance team leader that one

of the four piston rings replaced during the refueling

outage was found to be installed with the improper

orientation (upside down).

This problem allowed air to leak

by the piston.

The orientation of the piston ring was

corrected and the valve was reassembled.

The inspectors

reviewed MWO's 1-97-0585 and 1-97-3320 for the work

activities associated with the original repair of valve

!N32-F021.

This problem was attributed to poor workmanship.

The inspectors were further informed by maintenance

personnel that the oiston ring replacement was still of the

craft with General

Electric (GE) guidance.

A deficiency

card was written for the improperly placed piston ring upon

its discovery.

For additional corrective actions, the use

of GE's guidance and work activity monitoring for these

valves in the future will be enhanced.

Following the manual scram for the plant shutdown and the

closing of the inboard MSIV for pressure control, a nitrogen

supply line isolation valve to t1e drywell closed.

The

drywell pneumatic header isolation solenoid valve IP70-F004

closed on high nitrogen flow after a ten-minute time delay.

Operators suspected that something came loose during the

closing of the inboard MSIVs. The subsequent investigation

determined that the nitrogen supply line to the 'B' inboard

MSIV was leaking.

The nitrogen leak was caused by an

impro)er seal between the pneumatic manifold and actuator

for t1e 'B' inboard MSIV.

This was caused by a poor work

practice for tightening the bolts.

Bolts were not randomly

selected for tightening.

This resulted in some bolts on one

Enclosure 2

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -

,

.

16

side of the manifold reaching the bottom of the bolt hole

while other bolts reached their torque limit prior to

ensuring the 0 ring seal was properly compressed.

The licensee made a 10 CFR 50.72 notification to the NRC and

submitted LER 50-321/97 007. " Pneumatic Leak Results in Closure of

Primary Containment isolation Valve." This LER is discussed in

Section M8.2 of this Inspection Report (IR).

The inspectors reviewed TS Section 3.4.3. " Safety / Relief Valves."

and the a)plicable section of the Unit 1 Updated Final Safety

.

Analysis Report (UFSAR).

No discrepancies were identified.

i

Additionally, the inspectc?s reviewed MWO 1-97-3330 and MWO

'

l-97-3342, associated with the repairs performed on the nitrogen

supply line to MSIV IB21 F0228.

c.

Conclusions

l

The decision by licensee management to shutdown Unit 1 for

corrective maintenance following the restart problems was

appropriate.

Poor maintenance work practices contributed to the

unit shutdown.

Maintenance response and support of the work

activities were good.

M2

Maintenance and Materiel Condition of Facility and Equipment

M2.2 Cold Weather Prenarations

a.

Inspection Stone (71714)

The inspectors reviewed maintenance procedure 52PM MEL-005-05.

" Cold Weather Checks." Rev. 9. 0)erations Department Instruction

Dl-0PS 36-0989N. " Cold Weather C1ecks." Rev. 9. and the associated

data package for procedure 52PM-MEL-005 05. _The inspectors

performed system and component walkdowns, and reviewed documents

associated with cold weather preparations.

b.

Observations and Findinas

Among the areas observed and reviewed were the following:

Review of procedures used to calibrate and test equipment

.

a ociated with heat tracing, space heaters, and thermostats

System walkdowns to observe heat tracing, space heaters and

insulation installed on systems susceptible to cold weather

conditions. Walkdowns were also performed to observe the

material condition of automatic and manual louvers

Enclosure 2

j

.

.

17

Review of instructions and checklists used to implement

.

responses to actual cold weather conditions

Review of defici m cies and corrective maintenance associated

with the licen

most recent cold weather checks.

The procedure and inst, action provided for testing and repair of

equi) ment associated with cold weather protection as well as a

chectlist to ensure that exposed equipment was adequately

protected during cold weather conditions.

The data package was

the

,mpleted checklist.

This checklist was the cold weather

check for operability of the listed space heaters, heat traced

components, and insulation.

The inspectors performed walkdowns of the emergency diesel

generator (EDG) building, intake structure, fire pum) building,

service water valve pit. fire water storage tanks, t1e condensate

storage tanks and transfer pump pits, the circulating water pumas,

and above ground piping systems.

These areas contain systems tlat

are important to safety and/or could cause a plant transient.

During the walkdowns on December 8 the inspectors observed that

several heat trace indicating light lens were missing on the fire

pump house storage tanks and the EDG building areas.

T*

inspectors also observed that about one third of the

trace

indicating lights in the service water valve pit areu ..ere not

illuminated during a walkdown when the ambient temperature was at

or below freezing.

These deficiencies were discussed with

licensee personnel.

The inspectors reviewed a representative sampling of MW0s

associated with the Deficiency Cards (DCs) identified in the data

Jackage review,

The inspectors observed from this review that the

)Cs were concerned mostly with heat trace problems.

The

inspectors also observed that once identified, these items were

promptly corrected.

c.

Conclusions

The inspectors concluded that the cold weather preparation program

was good.

The procedures for performing equipment operability

checks were appropriate and maintenance corrected the identified

cold weather preparation deficiencies in a timely manner.

.

M2.3 Jnsulation Removal Durina Snubber Work Activity

a.

In.nectionStone(62707)(92902)

The inspectors reviewed procedure 52GM-MNT-019-05. " Removal,

Storage and Installation of Thermal Insulation." Rev. 1. and

departmental instruction DI-MMS-01-0292N. " Plant Modification and

Encicsure 2

- --

. - . - - . - - - -

. . - _

. -

- -

- - -

- -

,

.

a

w

i

18

Maintenance Support (PMMS) Em)loyee Orientation and Procedure

Awareness Program." Rev. 7.

iW0s 1 97-0900 and 1 97 1676 were

also. reviewed. Worksheet S 97 020 M003 was reviewed in

-

conjunction with MWO l-97-1676.

Additionally, the removal of the

i

insulation was discussed with licensee personnel.

b.

Observations and Findinas

During a routine plant tour on December 5. the inspectors

observed insulation on the floor of the Unit I reactor

4

building at the 118 foot (ft) elevation.

The insulation had

been removed from around a snubber lower support that was

welded to the Residual Heat Removal (RHR) heat exchanger

bypass piping.

The snubber at this location had been

removed.

A tag attached to the snubber lower support

indicated that the support was " retired" in place per the

design change associated with the licensee's snubber

reduction program.

The small amount of insulation that was

removed did not affect the operability of the system or area

coolers.

'

The routine plant tour by the inspectors was performed following a

plant-wide housekeeping inspection and cleaning tour by plant

personnel / management.

The inspectors observed that the insulation

was on the floor during a followup inspection several days later.

The inspectors at this time informed PMMS supervision of the

removed insulation.

The inspectors observed from their review

that the insulation was removed on about November 4 and had not

been replaced as of December 5.

The inspectors discussed this

problem with PMMS and maintenance personnel.

Personnel in neither

department were aware that the insulation had been removed and

needed to be replaced. PMMS personnel promptly replaced the

removed insulation.

.

From a review of MWO 1-97-1676 and Worksheet S-97-020 M003 the

inspectors observed that neither document provided instructions

for the removal or installaticn of the insulation.

This issue was

discussed with PMMS supervision.

The inspectors were informed

that the insulation work for the outage was performed on blanket

MWO 1-97-0900.

The ins)ectors reviewed this MWO and observed that

the work activity for t1e removal and replacement of the

insulation on the RHR heat exchanger bypass piping for snubber

IEll H227 was not documented until af ter the inspectors informed

personnel of the insulation removal.

The inspectors were informed by the PMMS supervisor that the

insulation was removed by a loaned craftsman.

The loaned

craftsman vas from another electric utility within the Southern

Company organization.

The craftsman that was tasked with the

removal of snubber lEll-H227 also removed the insulation. A

Enclosure 2

-

---

,

.--

- .-...--....%.

. . . - -

_ - - . , _ _ - - - , . - - - , .

~

,

. ~ , - - ,

.

. . . . -

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. - - ,

-

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.

.

19

Southern Com)any supervisor was 3roviding oversight of the loaned

craftsman. 17e craftsman should lave checked with the su)ervisor

prior to the removal of the insulation. The supervisor s1ould have

completed an insulation removal and Installation request. As a

result of the documented request the insulation would have been

entered into a computer tracking data base for replacement. Since

this was not done, there was no record to indicate that the

insulation had been removed.

The inspectors reviewed training records for loaned personnel and

observed that, in this case, the loaned person did not receive

training on the procedure for insulation removal or installation.

This procedure explained the site process for insulation work

activities,

c.

Conclusions

PMMS response to the staff's notification of the removed

insulation was prompt. Weaknesses were identified in supervisor

oversight of loaned personnel work activities for this problem. y

H3

Maintenance Procedures and Documentav an

M3.1 Surveillance Observations (61726)

Insnection Scooe and Conclusions

The inspectors observed all or portions of the following Unit 1

and Unit 2 surveillance activities:

345V-B21-001-25:

MSIV Closure Instrument Functional Test.

Rev. 6

341T-E51-003-lS-

RCIC Turbine Speed Control Test. Rev. 3

+ 345V-E51-005-IS:

Operation of RCIC From the Remote Shutdown

Panel. Rev. O

e 34SV-E51-002-lS:

RCIC Pump Operability. Rev. 18

34SV-E51-001-1S:

RCIC Valve Operability. Rev. 16

575V Gll-005 2S:

Drywell Floor Drain Sump Level FT&C, Rev.

4

57CP-CAL-103-IS:

ITT Barton Model 764 Differential Pressure

Transmitter. Rev. 16

345V R43 003-2S:

Diesel Generator 2C Monthly Test. Rev.19

For the surveillances observed, all data met the required

acceptance criteria and the equipment nerformed satisfactorily.

The performance of the operators and crews conducting the

surveillances was generally professional and competent.

No

deficiencies were identified.

Enclosure 2

-..

. -

- _ -

...

.- - - .

- -

_ - - -

.

.

20

M4

Maintenance Staff Knowledge and Performance

M4.1 Observation of Online Loaic System Functional Test of Main Control

r

loom Pressurization System

a.

Insoection Stone (92902) (92902).

The inspectors reviewed procedure 42SV-Z41-001 05, " Main Control

Room Pressurization LSFT," Rev. 8. the applicable 10 CFR 50,59

evaluation for a recent procedure change. Unit 1 and Unit 2 TSs 3.7.4.3 and 3.3.7.1.4, Unit 1 Updated Final Safety Analysis Report

(UFSAR) section 10.17. and Unit 2 UFSAR sections 6.4. 7.3.5, and

9.4.

The inspectors also reviewed procedure AG MGR-21-0386N.

" Evolution Pre Test Briefing Requirements," Rev. O Department

Instruction DI 0PS-0596N " General Guidelines for Use of Jumpers

and Links," Rev. 0, and observed selected portions of the testing

activities to verify that actions were completed in accordance

with procedure and regulatory requirements.

b.

Observations and Findinns

The inspectors attended the pre-job briefing for the testing

activiues.

The test affected bott units and required manual

manipulation of system components.

The test also required

automatic system actuation and realignment.

The briefing was

conducted by engineering personnel responsible for the test.

The

inspectors observed that the procedural recuirements for the

pre-job briefing were met.

Engineering anc operations personnel

were knowledgeable of the system and test requirements.

The inspectors observed that the retrieval, placement, and removal

of required jumpers were well-controlled.

Procedure steps

completed were initialed, second person verifications were

correctly performed, and peer checks were implemented. The test

was completed with no deficiencies. The systems responded as

expected and all test acceptance criteria wera met,

c.

Conclusions

The inspectors concluded that the overall performance of the test

activity was excellent.

Engineering and operations personnel were

knowledgeable of the system and test requirements.

The retrieval.

31acement, and removal of required jumpers were well-controlled,

3rocedures were correctly used.

The systems responded as expected

and all test acceptance criteria were met.

The 10 CFR 50.59

+

evaluation was appropriate.

Enclosure 2

_

.

.

21

M8

Hiscellaneous Maintenance Issues (92700) (92902)

M8.1

(Closed) LER 50 321/97-06: ansarent LPRM TIP Calibration Tube

f ailure Results in >rimary System Pressure Boundry Leakace

The inspectors reviewed licensee actions to replace the TIP tubing

and the TIP post maintenance and operability test.

No

deficiencies were identifled.

The inspectors observed that the

licensee's corrective actions were appropriate.

This licensee-

identified violation constitutes a violation of minor safety

significance and is being identified as Non-Cited Violation

50 321/97-11-04. Failure to Meet Unit 1 Technical Specification

Actions for Primary Systen Pressure Boundary Leakage.

The LER was

detailed and thorough. Based upon the ins)ectors review of

licensee actions and the issuance of the 1CV. this LER is closed.

M8.2 (Closed) LER 50-321/97-07:

Pneumatic Leak Results in Closure of

Primary Containment Isolation Valve

The licensee issued this LER dated December 10, 1997. following a

manual scram of Unit 1 to complete corrective maintenance. The

unit was just exiting a refueling outage.

This problem is

discussed in Sections 04.1 and M1.2 of this inspection Report.

The LER presented no new information.

Based upon the inspectors

review of licensee's actions, this LER is closed.

M8.3 (Closed) IFl 50 321/97-10-01:

Review of Unit 1 RCIC Testina

Artivities from the Remote Shutdown Panej.

This IFl wa, identified following a failure of the Unit 1 Reactor

Core Isolation Cooling (RCIC) system to operate from the Remote

Shutdown Panel (PSP).

The system failed to meet the required

testing acceptance criteria during a routine surveillance test

conducted just before the regularly scheduled refueling outage.

This problem is discussed in Section 02.1 of IR 50 321. 366/97-10.

The inspectors reviewed the results of the tests completed during

the unit startup and verified that the system operated properly

from the RSP.

All test results met the acceptance iequirements.

Based upon the inspectors' review of licensee activities for RCIC

corrective maintenance and the results of the required RCIC

testing activities, this IFI is closed.

III. Enoineerina

El

Conduct of Engineering

On-site engineering activities were reviewed to determine their

effectiveness in preventing, identifying, and resolving safety

issues._ events, and problems.

In general, engineering support to

operations and maintenance was excellent.

Enclosure 2

_ - _____

_

-_.

.

22

E2

Engineering Support of Facilities ard Equipment

E2.1 Review of Unit 2 Torus-to-Reactor Building Vacuum Bre2ker Design,

a.

In mection Scone (37551)

The inspectors reviewed Unit 2 Torus-to-Reactor Building Vacuum

Breaker des 4gn for acceptability of a single passive component to

meet containment isolation requirements. This had been identified

,

'

as a potential problem at other Boiling Water Reactor (BWR) sites.

The inspectors reviewed Unit 2 drawing H26084. " Primary

Containment Purge and Inerting System." and discussed the issue

with site management personnel,

b.

Observations and Findinas

The inspectors reviewed this design issue as to whether the torus-

to-reactor building vacuum breaker design problem identified at

another facility was applicable for Hatch. The concern was whether

or not a single check valve could be relied upon to provide

containment isclation during a loss-of-coolant accident (LOCA).

The design at the other facility and at Hatch consist of two

redundant vacuum relief lines from the reactor building to the

torus, each containing two valves in series: an air-operated

butterfly valve and a check valve. The lines are normally 20

inches in diameter. The purpose of these lines and associated

vacuum breakers is to limit a vacuum in the containment.

Because

the lines penetrate primary containment, the vacuum breaker serve

a dual function:

vacuum relief and containment isolation.

The

air-operated butterfly valves are normally closed and are designed

to open upon a diffarential of 0.5 pounds per square inch gage

(psig) between the reactor building and the torus.

The

air-operated valves have been designed to fail open upon a loss of

air or electrical power.

Other post-accident conditions may also

cause the valves to open as designed.

Open is the safe position

for the vacuum relief function.

Therefore, given an event during

which the air supply or the electrical power cannot be assumed to

be operable, or accident conditions call for the valves to be

open, the single check valve in each line must perform the

containment isolation safety function.

This does not meet the

General Design Criteria (GDC) 56 requirements of 10 CFR 50

Appendix A.

The NRC reviewed several other BWRs with Mark I containments that

employ a similar design.

Part of the conclusions from the review

was that the safety risk from this design is low; therefore, the

staff concluded that a safety enhancement backfit would not be

cost-beneficial .

The conclusion was also based upon the fact that

most sites did meet their current licensing basis. This position

Enclosure 2

1

..

-

, - .

. - -

. .

-

--

-

-

.

.

23

,

also applied to other BWRs with Mark I containments-with the

exception of Hatch Unit 2.

Hatch Unit 2 is desianed similar to

the other design configurations reviewed, however, the

construction permit for Hatch Unit 2 was issued after May 21,

1971, and is required to explicitly comply with the GDC of

Appendix A of 10 CFR part 50.

Hatch Unit I was not affected based

upon the-date of the construction permit.

The inspectors reviewed the problem with licensee management.

The

inspectors were informed that the problem would be reviewed to

determine what actions were appropriate.

The inspectors were

later informed that the licensee was developing an exemption

request for the GDC 56 requirements for Hatch Unit 2.

-

c.

Conclusions

The inspectors concluded that the Hatch Unit 2 torus-to-reactor

building vacuum breaker design does not meet General Design

Criteria 56 for acceptability of a single passive component to

meet containment isolation requirements. The corrent design.

under certain conditions, relies upon a simple check valve as an

automatic containment isolation valve outside containment for a

line which is directly connected to the containment atmosphere.

This problem was identified as Unresolved Item 50-366/97-11-08.

Unit 2 Failure to Meet General Design Criteria 56 for Proper

Automatic Containment Isolation Valve Outside Containment. pending

additional review.

'

E2.2 Emeroency Diesel Generator (EDG) 2C Failure to St?rt

_

a.

Inspection Scoce (37551) (92902) (92903)

The inspectors reviewed maintenance trouble shooting and

corrective maintenance activities associated with a failure to

start on the 2C EDG on November 24.

The inspectors observed part

of-the post-maintenance testing and verified test acceptance

criteria.

The inspectors discussed this failure and other EDG

issues with maintenance and engineering personnel.

b.

Observations and Findinas

On November 24. the 2C EDG was tagged out for maintenance

er.tivitics to calibrate a cooling water temperature control valve.

Following the maintenance activity, surveillance procedure

345V-R43-003-25. " Diesel Generator 2C Monthly Test." Rev. 19, was

being aerformed by operations personnel.

The EDG failed to start

when t1e local start push button was depressed.

This was the

second EDG failure to start within the past three months. The

licensee experienced a failure of the 1A EDG to start in

September,1997. due to a suspected fuel oil check valve failure.

Enclosure 2

. _ _ _ _

_ _ _ _ - _ _ _ _ _ - _ _ _ __

_ - _ _ _

_

_

.

,

24

Maintenance personnel were assigned to trouble shoot and correct

the 2C EDG problem.

Following maintenance trouble shooting a new

governor booster servomotor was installed.

The EDG performed

satisfactorily during a subsequent post-maintenance run.

The inspectors observed ongoin

EDG operability surveillance g work activities and parts of the

and verified that the test

acceptance criteria were met. The inspectors verified that

a)plicable TS required action was being tracked for the inoperable

EE.

The inspectors reviewed MWO 2-97-2435 used to trouble shoot

and repair the EDG.

.

l

The licensee issued Significant Occurrence Report (SOR) C9706228

documenting the 2C EDG start failure and subsequent failure

l

t

analysis. The inspectors reviewed the SOR for appropriate

l

corrective action recommendations. All EDG booster servomotors

had been replaced in 1990-1991 as part of a then 5-year preventive

maintenance program for governors and associated equipment.

Plant

Hatch has no history of failed booster servomotors, and the

. licensee concluded that this was an isolated failure.

After

discussions with the vendor, maintenance and engineering personnel

recommended that the booster servomotors be placed on a 6-10 year

replacement schedule, based on service history.

Implementation

was scheduled for January.1998.

Based on the 1A and 2C EDG start failures, the inspectors examined

actions implemented by systems engineering with regard to

Maintenance Rule (10 CFR 50.65) requirements for the EDGs.

The

inspectors found that reliability and availability data for each

EDG is currently compiled and updated monthly.

Performance

criteria for each EDG had been established as required by

10 CFR 50.65(a)(2).

The availability and reliability aerformance

criteria for each EDG is 98% and 95%. respectively.

T1e

inspectors verified that the updated performance data reflected a

1A EDG availability of 99.92% and a reliability of 98.39%.

The

2C EDG performance data was verified to be 99,85% and 98.28%.

respectively. The recent start failures represented the only

start failures for these engines over the past three years.

The

licensee determined that no additional testing was necessary.

c.

Conclusions

Licensee maintenance and engineering actions in response to the

2C EDG start failure were appropriate and thorough.

Maintenance

and engineering recommendations reflected a good interface with

the vendor. The inspectors verified that Maintenance Rule

performance criteria for the EDGs were being met, and that

performance data was being tracked and updated periodically.

Enclosure 2

]

-

-

_

_

_

_

.

.

25

E8

Hiscellaneous Engineering Issues (92700) (92903)

E8.1

(Closed) LER 50-366/97-04:

Inaccurate List of Primary Containment

Isolation Valves Results in Missed Surveillance

The licensee reported this problem in correspondence dated

April 29,1997. The cause cf the problem was that two valves were

not listed in a Unit 2 Updated Final Safety Analysis Report

(UFSAR) table as primary containment isolation Vahe positions

that were considered qualified post-accident monitoring

instruments.

The list was carried forward to the Technical

Requirements Manual (TRM) and surveillance procedures were

developed using the TRM as the basis. The licensee corrected the

UFSAR and TRM table and verified they were all-inclusive.

The

missed surveillance were completed prior to the unit startup.

Based upon the inspectors review of licensee actions, this LER is

closed

IV Plant Suor, ort

R1

Radiological Protection and Chemistry Controls

Rl.1 Conduct of Radioloaical Protection Controls

a.

Insoection Scoce (83750. 85750)

Radiological controls associated with on-going routine Unit 1 (U1)

and Unit 2 (U2) operations were reviewed and evaluated by the

inspectors.

Reviewed program areas included area postings and

radioactive waste (radwaste) and material container labels high

and locked-high radiation area controls, and procedural and

radiation work permit (RWP) implementation.

The inspectors made frequent tours of Radiological Control Areas

(RCAs) and observed work activities in orogress.

In particular,

radiation control

3ractices and Health physics (HP) staff

proficiency were o) served. Where applicable, results of ongoing

radiation and contamination survey results were verified.

Radiological controls and housekeeping practices in selected U1

turbine building areas. U1 resin processing building. U2 liquid

radioactive waste (radwaste) tank rooms. and in the C1 and U2

spent fuel pools (SFPs) were observed and discussed. On December

9.1997, the inspectors directly observed and evaluated the final

processing

Jackaging and subsequent shipping preparations for U1

condensate plase separator (CPS) System resins conducted in

accordance with Radiation Work Permit (RWP) 097-0017.

Procedural guidance and established radiological controls were

compared against applicable sections of the Updated Final Safety

Enclosure 2

.

_

_.

__.

-- . . -

-

.

--.

.

--

.

-

. . -

.

.

'

.

26

Analysis Report (UFSAR) and the applicable requiremeats specified

in Technical Specifications (TSs): 10 CFR Parts 20 and 71: and

.49 CFR Parts 100-179.

b.

Observations and Findinas

j

'

All area postings and container labels were dettrmined to be

adequate for the associated radiological conditions.

Controls for

high and locked high-radiation area doors were implemented

effectively. Observed controls for irradiated / contaminate (1

materials suspended in the U1 and U2 SFPs were appropriate with

lanyards labeled and positive controls established to prevent

inadvertent removal of materials from the pools.

For the

December 9, 1997, radwaste processing and shipping activities

observed, appropriate radiological controls were established and

dose rate and contamination survey results were conducted with

appropriate calibrated instrumentation. Survey and contamination

results met procedural and regulatory requirements.

The

inspectors noted continued improvement in housekeeping ar

'

cleanliness within observed work areas and the U2 radwaste tank

rooms relative to previous inspections.

c.

Conclusions

Radiological controls, area postings, and container labels

associated with radwaste processing storage, and transportation

activities were maintained in accordance with TSs: 10 CFR Parts 20

and 71: and 49 CFR Parts 100-179 requirements.

Improvements were noted in the radwaste facility housekeeping and

cleanliness.

R1.2 Liauid Radwaste Effluent Processina. Analysis and Release

-a.

Insoection Scooe (84750)

Ongoing liquid effluent release program activities were evaluated.

Licensee actions for liquid effluent releases made subsequent to

the U1 liquid radiation monitor being declared out of service

(DOS) were reviewed and discussed.

Liquid effluent release data

were reviewed and evaluated for two U1 chemical waste sample tank

(CWST) releases made on December 8 and 9, 1997. respectively.

Also, the inspectors directly observed and evaluated sampling,

quantitative radionuclide an61yses, processing, valve line-uas,

and U2 radwaste control room operator activities for a Decem]er

11, 1997 U2 floor drain sample tank (FDST) release.

The effluent release program review included equipment

operability, procedural adequacy and staff proficiency.

Detailed

reviews were conducted of the pre-release sample collection and

Enclosure 2

.

.

27

radiological analyses. liquid effluent monitor setpoints, and

valve line u) operations associated with a subsequent liquid

release to t1e environment.

The following procedures were reviewed and evaluated during direct

observation of the U2 FDST radwaste sampling. processing and

release:

64CH-RPT-006-OS. Liquid Effluent Reports. Rev. 2. effective

.

October 3, 1996.

64CH-SAM-024-05 Liquid Radwaste Sampling and Analysis.

.

Rev. O, effective December 11, 1997.

3450-G11-021-25. Radwaste Sample Tank Operating Procedure,

.

effective July 31. 1997.

Personnel observed and interviewed regarding the FDST liquid

radwaste processing and release included radwaste operators and

chemistry technicians.

License program guidance, actions and results were evaluated

against applicable sections of 10 CFR Part 20. TSs 5.4.1 and

5.5.1: Offsite Dose Calculation Manual (ODCM): and approved

procedural requirements.

b.

Observations and Findinas

Both chemistry laboratory technicians and raJwaste operators

demonstrated appropriate knowledge of arocedural requirements, and

proficiency in completing assigned tascs.

Technicians conducting

pre-release sampling and radionuclide analyses were knowledgeable

of equipment and procedures.

Radwaste operators demonstrated

appropriate knowledge of required valve line-ups, system

capabilities. U2 radwaste control room operations, expected

effluent release rates, dilution flows, and tank capacities.

All sampling and quantitative radionuclide analyses were conducted

in accordance with the approved procedur es.

For U1 CWST releases

made subsequent to the U1 liquid effluent monitor being declared

00S. the pre-release samples were collected and analyzed in

duplicate in accordance with the approved procedure and ODCM

requirements.

For the December ll. 1997. U2 FDST release. tank

recirculation times. radionuclide 6nalyses, and sample compositing

and preservation were conducted in accordance with procedural

requirements and accepted industry practices.

During observation and review of data collected during the

December 11.1997. U1 FDST release, the inspectors identified a

concern regarding the procedural adequacy of the source check used

Enclosure 2

. .

_

_

_

__

.

. .

.

_._

___

._.

_ _ . _

.

.

28

,

to demonstrate monitor operability. The inspectors noted that

+

liquid effluents discharge 3ermit. Form HPX-0149. Rev.12,

completed in accordance witi 64CH-RPT-006-OS and 3450-G11-021-25

used the background count rate to complete the release instrument

source check, prior to each liquid batch release.

Licensee

representatives stated that the procedure implemented "footnate e'

to ODCM Table 2-2 which specifies that the " Source check shall

consist of verifying that the instrument is reading onscale." The

inspectors noted that although the instrument reading was onscale.

-

the intent of the source check was to verify monitor operability

<

immediately prior to making an actual effluent release and that

.

ODCM Section 10.2 defined the source check as the qualitative

assessment of channel response when the channel sensor is exposed

to a source of increased radioactivity.

During the December 11.

1997. U2 FDST liquid effluent release, the inspectors noted that

the effluent monitor count rate remained relatively constant,

ap3roximately 800 counts per second (cps), prior to, during and

.

su) sequent to the release.

Thus the detector response to a

source of increased radioactivith immediately preceeding the

'

release was not readily observable.

Following review and

discussion of applicable licensing documents, licensee

,

re]resentatives stated that procedural changes would be made to

-

enlance demonstration of the detector source check response prior

to each liquid effluent release.

This issue was identified as

inspector followup item (IFI) 50-321. 366/97-11-05. Review

Adequacy of Revised Liquid Effluent Release Procedures to Meet

'

i

Offsite Dose Calculation Manual (00CM) Monitor Check Source

i

Requirements,

c.

Conclusiom

Proficiency of chemistry technicians and radwaste operators during

conduct of a December 11. 1997. U2 FDST release was demonstrated.

.

Excluding source check requirement concerns for liquid effluent

releases, procedural guidance was adequate and implemented

effectively in accordance with 10 CFR Part 20. TSs and ODCM

requirements.

Inspector followup item was opened: 50-321.-366/97-11-05 Review

Adequacy of Revised Liquid Effluent Release Procedures to Meet

Offsite Dose Calculation Manual (ODCM) Monitor Check Source

'

Requirements.

,

Rl.3 Radioactive Waste and Material Transoortation Activities

a.

Insoection Scoce (86750)

,

The-inspectors reviewed radiation protection (RP) and

transportation program activities associated with radioactive

4

~

Enclosure 2

4

.

.

29

waste (radwaste) characterization, packaging, transportation, and

subsequent burial of licensed material.

The following radwaste processing and characterization, and

radioactive material shipping procedures were reviewed and

discussed with cognizant licensee representatives:

62RP-RAD-011-0S Shipment of Radioactive Material . Rev.10.

.

effective June 23. 1997.

62RP-RAD-040-05. Pacific Nuclear Resin Drying System.

.

Rev. 5. effective July 31, 1989.

62RP-RAD-042-05. Solid Radwaste Scaling Factor

.

Determination. Rev

3. effective March 26. 1996.

On December 9, 1997, the inspectors directly observed packaging,

loading, and preparation of condensate phase separator (CPS)

resins for shipment to a licensed burial facility.

In addition,

processing records, shipping papers, and supporting documentation

were reviewed and evaluated for accuracy and completeness.

The

following shipments made between July 1 and December 9. 1997, were

reviewed and discussed:

Shipment No. 97-1024. Radioactive material. Low Specific

.

Activity (LSA). n.o.s.

7. UN 2912. Fissile Excepted.

Dewatered Resins. Solid Metal 0xides, shipped on October 15,

1997.

Shipment No. 97-1027 Radioactive material. LSA

n.o.s., 7

.

UN 2912. Fissile Excepted. - Radionuclides. Dry Aqueous

Filters. Solid Metal 0xides, shipped on November 6.1997.

Shipment No. 97-4004 Radioactive material. LSA, n.o.s.

7

.

UN 2912. Fissile Excepted. Five Metal Boxes of Uncompacted

DAW Solid Metal 0xides, shipped on November 4,1997.

Shipment No. 97-1031. Radioactive material . LSA. n.o.s.

7.

.

UN 2912. Fissile Excepted Reportable Quantities (RO) -

Radionuclides. Dewatered Resins. Solid Metal 0xides, shipped

on December 9. 1997.

Program guidance and implementation were evaluated against 10 CFR Parts 20 and 61. and the recently revised 10 CFR Part 71 and

Department of Transportation (DOT) 49 CFR Parts 100-179

regulations.

Enclosure 2

- - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ -

.

.

l

30

b.

Observations and Findinas

I

!

1The licensee's )rocedural guidance met a)plicable regulatory

l

requirements.

Recent revisions to 10 CFR Part 71 and 49 CFR

Parts 100-179 regulations were incorporated into approved

procedural revisions.

The processing, packaging, and preparation of the CPS resins for

trans)ortation and subsequent burial were implemented effectively.

For tle December 9. 1997. CPS resin shipment, the inspectors

verified that resin drying process memorandum results. Part 61

scaling factor analyses, shipping paper data and supporting

!

documents, were completed in accordance with established

procedures.

From direct observation of shipping activities and

discussions with contractor and licensee personnel involved in-

radwaste o)erations, the inspectors noted that staff members were

knowledgeaale and proficient in completing selected job

evolutions.

Shipping paper documentation for the consignments

reviewed were accurate and complete,

c.

Conclusions

Licensee program guidance for processing, packaging, and

transporting radwaste for subsequent burial met 10 CFR Parts 20.

61. and 71: and 49 CFR Parts 100-179 requirements, as applicable.

Radwaste processing, packaging and transportation activities were

implemented effectively.

R1.4 Ob ervation of Routine Radioloaical Controls

a.

Insoection Scoce (71750)

General HP activities were observed during the report period.

This included locked high radiation area doors, proper

radiological posting, and personnel frisking upon exiting the RCA.

The inspectors made frequent tours of the RCA and discussed

radiological controls with HP technicians and HP management.

Minor deficiencies were discussed with licensee management.

R5

Staff Training in Radiation Protection and Chemistry

R5.1 Hazardous Material Trainina

a.

Insoection Scooe (86750)

Hazardous material (Hazmat) training was evaluated and discussed

for selected personnel involved in the December 9. 1997. CPS resin

shipment processing, packaging, and consignment activities. The

evaluation included verification of training and testing

Enclosure 2

_ _ _ - _ - _ _ _ - _ _ _ - _ _ _ _ _ - _ - _ .

4

.

31

frequency, and a review and discussions of selected topics

presented in General Em)loyee Training, and in Function Specific

and Safety training.

T1e ins)ectors reviewed and discussed the

current General Employee Hand)ook dated July 28, 1997, and ME-

61800 Radwaste Shipment, Rev. 2, dated March 1, 1989.

Hazmat training guidance and frequency were compared against

requirements of 49 CFR 172.702.

b.

Observations and Findinos

For the selected Hazmat workers reviewed, the training topics

presented met the general awareness, function specific, and safety

training requirements and were conducted at the required

frequency, During review of training topics provided to selected

workers, the inspectors noted difficulties in verifying testing

for all required training topics explicitly required by

'

49 CFR 172.702.

Licensee representatives stated that this issue

would be reviewed and actions implemented to consolidate or

refererue training and testing documents needed to meet the

explicit requirements of 49 CFR 172.702.

c.

Conclusions

f

Hazmat training for personnel processing, handling, and shipping

CPS resins was conducted in accordance with 49 CFR 172.702

requirements.

R7

Quality Assurance in RP & C Activities

R7.1 Countina Room Ouality Control (OC) Activities

a.

Insoection Scone (83750) (84750)

The inspectors reviewed implementation of selected counting room

effluent measurement quality control (OC) 3rogram activities and

associated results achieved from June 1 t1 rough December 12,

1997. In particular. OC activities for the gamma spectrosco)y

systems were reviewed and discussed.

The review included t1e most

recent 1997 semiannual inter-laboratory cross-check analyses,

selected daily control chart parameters, and weekly background

check data.

Program implementation was evaluated against 10 CFR Part 20. TSs

and procedural requirements specified in procedure

64CH-0CX-001-OS, " Quality Control for Laboratory Analysis."

Rev. 3.

Enclosure 2

.

32

b.

Observations and Findinas

For the in-service gamma spectroscopy cystems, no significant

concerns or negative trends were ident1fied from review of the

counting room QC parameter and background check data.

However,

during review of the 1997 second half inter-laboratory cross-check

program results for liquid gamma isotopics, the inspectors noted a

Cerium (Ce)-141 comparison ratio. i .e. , licensee radionuclide

concentration results to the vendor's laboratory's known value of

7.36, which was identified as ' agreement" on the vendor's

comparison sheet. The inspectors noted that based on the expected

standard deviations normally associated with radionuclide

concentrations in the vendor's ligtid sample, the documented ratio

most likely identified disagreement between the licensee and

vendor values and required supplemental licensee investigation of

the noted differences.

From subsequent review of licensee data, a

significant transcription error in the Ce-141 results originally

supplied to the vendor was identified.

Further, upon receipt of

the comparison results in October 1997, responsible licensee

.

representatives did not identify that the vendor had incorrectly

l

identified the Ce-lal comparison ratio as being in " agreement ~

Followup of the identified issue using the proper licensee Ce-141

concentration data determined that the results were in agreement.

The inspectors noted that the identified errors, including the

improper transcription of gamma spectroscopy cross-check data and

inadequate licensee review of vendor analysis comparison results

upon their receipt, resulted from a lack of attention to detail by

responsible personnel,

c.

Conclusions

In general, counting room gamma spectroscopy OC activities were

implemented appropriately. A lack of attention to detail by

responsible personnel for selected laboratory DC activities was

identi fied.

R8

Miscellaneous RP&C Issues (83750) (84750)

R8.1 Unit 1 Outaae Radiation Control Performance Indicators

a.

Insoection Scoce

The inspectors reviewed and discussed selected performance

indicators regarding the recently completed U1 refueling outage

(RFO) 17 activities.

Performance indicators reviewed and

discussed included person-rem exposure, skin dose assessments. and

internal exposure evaluaticos.

As applicable, results were reviewed against TS and 10 CFR Part 20

requirements.

Enclosure 2

1

9

-

.-

..

-

~ ~ .

--

-

_

- .

.

.

33

b,

Observations and Findinos

For completion of the October 11 through November 21. 1997. U1

.

RF0 17 activities, the preliminary dose ex)enditure of 311 person-

rem was slightly above the 300 person-rem Judgeted.

The

inspectors noted a significant decline in worker contaminations.

For the outage period, a total of 58 Personnel Contamination

Events (PCEs), i.e., contamination less than 10,000

disintegrations per minute per probe area, and 39 Personnel

Contamination Reports (PCRs), i.e., any facial, or skin or

_

clothing contamination levels equal to, or greater than 10,000 dpm

3er probe area, were reported.

The results were significantly

Jelow the 698 PCEs and 85 PCRs reported for U2 RF0 13 activities.

Further, from discussion with cognizant licensee representatives

and review of contamination reports, the inspectors verified that

no skin dose ex)osures from discrete particles were recuired,

For

licensee whole-Jody counting (WBC) analyses conducted curing the

U1 RF0 17 activities, 32 instances of potential radionuclide

'

intakes were identified by routine or investigative WBC analyses.

Excluding two individuals involved in a November 14, 1997,

contamination event, evaluations for the potential intakes were

,

completed in accordance with the approved procedures,

Intake

>

estimates were less than 0.2 percent of the annual limit of intake

(All), procedurally requiring the internal exposure to be added to

an individual's official exposure records in accordance with

approved licensee procedures,

From review of selected results and discussion of deficiency card

commitment tracking system number C09705936 issued on November 15.

1997, the inspectors noted that responsible HP technicians failed

to Jerform nasal swipes and conduct WBC analyses in accordance

wit 1 RP procedures 62RP-RAD-004-OS, " Personnel Decontamination "

Rev. 8, and 60AC-HPX-004-OS, " Radiation and Contamination

Control," Rev.15. following identification of facial

contamination on two laborers on November 14, 1997.

At that time,

extensive personnel decontamination activities and hand frisking

were required to allow the subject individuals to exit the RCA.

No additional evaluations were conducted to evaluate intake or to

identify the possible source of contamination.

The deficiency

card was initiated when one of the individuals again alarmed a

Jersonnel contamination monitor (PCM) early in the shift on

lovember 15, 1997.

Following additional WBC analyses, one

individual was estimated to have a maximum total intake of

approximately 617 nanocuries (nC1) including radionuclides of

Manganese-54 (91 nCi). Iron-59 (104 nCi). Co-60 (241 nCi) and

Zinc-65 (181 nC1). Assuming inhalation as the mode of intake,

licensee representatives estimated a committed effective dose

equivalent (CEDE) of 95 mrem and a committed dose equivalent (CDE)

to the lung of 534 mrem.

Based on available data, the doses were

based on conservative assumptions and were within regulatory

Enclosure 2

-

.

_-_ ___ _

_ ______ _ -.

.

.

.

.

.

.

.

34

limits.

The inspectors noted that if nasal swipes and immediate

whole-body analyses were conducted following identification of

facial contamination, a more probable mode of radionuclide intake

-

and accurate assessment of intake and potential internal exposure

for the involved workers could have been made.

Further, the

inspectors noted that immediately preceding identification of the

facial contamination, the workers were conducting decontamination

!

activities in the U1 torus bay 87-foot (ft) elevation but were not

expected to encounter any significant contamination.

Followup

surveys of the U1 torus 87-ft elevation identified unexpected

contamination levels, up to 140 millrad Jer hour per 100

centimeters square, resulting from a leac in a pipe draining a

highly contaminated area in the steam chase above the torus. The

inspector noted that the failure to identify the source of the

unexpected contamination in a timely manner could have resulted in

additional and unnecessary worker exposure.

The failure to follow

licensee RP procedures for radiation and contamination control and

for personnel decontaminat hn in accordance with TS 5.4.1.a was

identified as VIO 50-321, 366/97-11-06, Failure to Follow

Procedures for Radiation and Contamination Control and for

Personnel Decontamination Activities.

c.

Conclusions

Licensee initiatives to manage exposure and reduce worker

contamination events during the U1 RF017 activities were

effective.

Excluding a November 14, 1997, personnel contamination event.

-controls for minimizing exposure from intakes of radionuclides

,

were effective and potential radionuclide intakes were evaluated

'

properly.

The failure to follow RP procedures fnr radiation and

contamination control and for personnel decontamination in

accordance with TS 5.4.1.a was identified as VIO 50-321, 366/97-

11-06. Failure to Follow Procedures for Radiation and

Contamination Control und for Personnel Decontamination

Activities.

R8.2 LClosed) Unresolved Item (URI) 50-321. 366/96-10-09:

Review

Licensee Evaluation of Samole Line Particulate Samolina Adeauacy

and Main Stack Accident Monitor Environmental 00eratina

Soecifications.

Completion of this item involved verification that the current

fission product monitor (FPM) sam) ling line configurations met

vendor design specificatiens and JFSAR commitments regarding

Regulatory Guide (RG) 1.45 leak rate requirements.

Enclosure 2

i

. _ _ _ _ _ _ _ _ _ -

_ _ _ _ _ _ _ _ _ _ _ -

..

.

35

On October 13. 1997. licensee representatives provided

documentation indicating that both of the FPMs and sample lines

(011-P010 and 011-P011) for both units were consistent with the

current Piping and Instrumentation Diagrams (P&lDs) H 16274 and

H-26016, respectively; and also met the ap)licable guidance

provided in the Radiation Monitor System (RMS) vendor manuals.

Subsecuently.- the inspectors requested licensee representatives to

provice data demonstrating that the monitors would respond to a

minimum unidentified leakage of approximately one gallon )er

minute within one hour.

Detailed information regarding c1anges in

the identified (equipment drain) and unidentified (floor drain)

leak rates and corresponding particulate, iodine, and noble gas

detector readouts were reviewed and discussed for both the U1 and

U2.FPM systems. Although changes in leak rate and monitor

respcnses were not available to demonstrate significant changes in

detector responses during a discrete one hour interval, the-

inspectors noted that discernible changes in detector response

rates were observed for unidentified leak rates less than one

,

l

gallon per minute.

Based on the verification of the installed

l

systems' configurations and the presentation of detailed U1 and U2

FPM data to demonstrate qualitative monitor responses to

unidentified drywell leak rates of one gallon per minute or less,

this item is closed.

!

R8.3 (Closed) Unresolved Item (URI) 50-321. 366/97-02-07:

Review-

Licensee Followun and Results of Staff Radiation Work Permit (RWP)

Adherence.

This item was opened to review results of expanded licensee

followup subsequent to the identification that several individuals

rigned in to the RCA on improper RWPs during the March 15 through

April 20.1997. U2 RF013 activities.

The issue originally was

identified when ins)ectors noted an individual signed in to the

RCA on an improper RWP to conduct U2 outage condensate

demineralizer valve maintenance activities.

The root cause analysis summary, dated June 25, 1997, was reviewed

and discussed with responsible licensee representatives.

Ap)licable outage quality checks. outage and non-outage RWPs, and

RW) access control reports.were reviewed and analyzed to determine

the extent of condition and identify appropriate corrective

actions.

The review identified numerous examples specifically

between March 31 and April 7,1997, of workers impro)erly signed

in on non-outage RWPs to perform work ecu1 valent to t7e proper

outage RWP. The licensee review also icentified three separate

instances where workers entered radiation areas exceeding 100

millirem per hour (mrem /hr) on RWPs not intended for use in high

radiation areas, i.e., areas having dose rates equal to or

exceeding 100 mrem /hr.

The inspectors r.oted that Administrative

Control (AC) Health Physics procedure 60AC-HPX-004-OS " Radiation

Enclosure 2

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..

. .. .

.

..

.

.

.

..

.

___

- - _ -

---

.

36

and Contamination Control." Rev. 14. Section 4.6. requires plant

personnel to read and comply with the requirements of the RWP

whenever their duties require such authorization.

The inspectors

identified the failure to follow procedures for RWP system

implementation in accordance with TS 5.4.1.a as VIO 50 321,

366/97-11-07 Failure to Follow Procedures for RWP System

Implementation.

Licensee initial corrective actions included continuation of

numerous quality checks during the outage and notification to

appropriate departments to address access control issues.

In

addition, for upcoming outages, several outage RWPs were to be

initiated before contractors begin in-processing and

reinstallation of access control

detection of improper RWP usage. printers and check-in to promote

R8.4 (Closed) Inspector Followuo item (IFI) 50-321. 366/97-05-03:

Review Licensee's Root Cause Determination and Corrective Actions

for Personnel Contamination.

This item was opened to review results of licensee root cause

analyses and corrective actions for several recent contamination

events and a noted overall increase in personnel contaminations.

The inspectors reviewed and discussed Significant Occurrence

Report (SOR) Number C09703158, dated August 7. 1997. A problem

solving team (PST) reviewed and analyzed personnel contamination

event (PCE) and personnel contamination report (PCR) data bases to

investigate and determine trends regarding worker contaminations.

The report concluded that personnel contaminations were increasing

during both outage and non-outage periods,

Causes were attributed

to the recent implementation of performance teams, each of which

included a HP technician reporting directly to the performance

team leader.

The PST determined that the performance team

structure blurred responsibility for radiation and contamination

control programs, diluted worker accountability, and created a

false sense of security among team workers. Workers were not

required to report to a Health Physics (HP) technician prior to

beginning RCA work, and work planning and assignments were

sometimes inadecuate.

Lack of a permanent decontamination team

also contributec to " walk around' contamination events.

Corrective actions included the reassignment of performance team

HP technicians reporting to the HP department organization.

increasing personnel accountability for avoidable contamination

events requiring workers to re3 ort to HP office prior to

beginning RCA work, requiring t1e HP department to provide RWP

selection and contamination control input for maintenance work

orders prior to work being performed, emphasizing multidiscipline

and timely investigation of PCRs separately from the deficiency

control system, improving nerformance team communications.

Enclosure 2

1

9

.

.

37

establishing and communicating a goal of "zero" unplanned PCRs.

and reinforcing performance team supervision responsibilities

concerning work prioritization for multiple jobs requiring HP

coverage.

The inspectors noted that the root cause determinations

and proposed corrective actions wer. appropriate.

Further, the

inspectors verified by direct obser.ation of worker practices and

from discussions with workers, supervisors, and HP technicians

that licensee corrective actions were being implemented,

Based on

completion of the SOR root cause analysis and implementation of

corrective actions, this item is closed.

S.

General Comments

The inspectors discussed future security requirements with licensee

representatives and the Office of Nuclear Reactor Regulation (NRR) for

the proposed independent spent fuel storage installation (ISFSI).

The

licensee was planning to construct this facility outside the protected

area, beginning late 1998.

The discussion included all facets of

security under the provisions of 10 CFR 72.

S1

Conduct of Security and Safeguards Activities

S1.3 Fitness for Duty

a.

Insoection Scooe (81502)

t-

The inspectors reviewed corrective actions at the licensee's corporate

offices on November 17, 1997, to Violation 50-321, 50-366/97-04-01 with

respect to their failure to establish policies and procedures to

adequately implement the Employee Assistance Program (EAP).

This lack

of procedural guidance was a contributing factor in which information

was released without written permission from an employee, due to

utilization of a mandatory Fitness for Duty (FFD) referral,

b.

Observations and Findinas

The inspectors reviewed and evaluated the following newly established

procedures to determine if the mandatory FFD evaluation process was

adequately addressed:

Corporate Guideline 720-035. "The Employee Assistance Program."

-

dated November 19. 1997

Corporate Guideline 720-036. " Mandatory Fitness for Duty

-

Evaluations." dated November 19. 1997

The referenced procedures clearly described the process and

circumstances under which a mandatory FFD evaluation would be in done:

thereby, limiting an employee's right of confidentiality.

Information

concerning an employee's counseling through the EAP would be protected

Enclosure 2

)

-_______- - - _ _ _ _

.

,

38

in accordance with federal and state law, and would not be revealed to

anyone outside the LAP program except under the following circumstances-:

If disclosure was required by law.

-

If the EAP 3rofessional determined that the emplo

threat to t1emselves or to the safety of others. yee was a serious

-

If the EAP professional determined that the employee's condition

-

was such that the employee should not be allowed access to

protected and vital areas. access to safeguards information, or to

perform certain safety-related job duties.

-

If the employee authorized the release of the inform 6. ion to

another party or individual.

The role of supervisors with respect to referral of employees for

mandatory FFD evaluations was also clearly documented in the procedures,

along with a form to document the circumstances that resulted in the

referral.

The inspectors reviewed the following FFD procedures currently in place

to determine if information regarding mandatory FFD evaluations was

incorporated:

-

Corporate Policy 720. " Fitness for Duty," dated November 19, 1997

Corporate Guideline 720-001, " Fitness for Duty." dated

'

-

November 19. 1997

-

Corporate Procedure 727, " Employee Assistance Program," dated

November-19, 1997

Fitness for Duty Procedure SH-FFD-005. " Medical Review Officer,"

-

dated November 26. 1997

Fitness for Duty Procedure SH-FFD-013. " Mandatory Fitness for Duty

-

Evaluations," dated November 26, 1997.

,

All procedures reviewed adequately described the mandatory FFD

evaluation as pact of the licensee's EAP.

Prior to Violation 50-321, 50-366/97-04-01, it appeared that a mandatory

FFD evaluation /EAP process was utilized: however, employees were unaware

of _the program, because distribution of the procedures and guidelines

was limited, The licensee has now informed employees and their

supervisors of the conditions, process, and expectations with respect to

mandatory FFD evaluations by revising the Supervisory Annual Behavioral

Observation Trair,ing Handouts and EAP brochures.

Employees also will

receive this information during annual FFD refresher training.

The

licensee met with the vendor EAP providers on October 29, 1997 and

discussed the process and circumstances surrounding mandatory FFD

evaluations.

During further discussion with licensee representatives, the inspectors

determined that the role of the FFD onsite staff regarding the mandatory

FFD evaluation process was minimal. The inspectors noted that training

Enclosure 2

J

.

_ _ _ _ - _ - _ _ _ - _ _ _

.

.

39

and keeping the FFD onsite staff informed about the mandatory FFD

evaluation process would be beneficial.

c.

Conclusions

The inspector determined that the licensee adequately addressed, through

procedures and training of the EAP providers, the process and conditions

in which a mandatory FFD evaluation /EAP referral will be utilized.

52

Status of Security Facilities and Equipment

S2.1 P_rotected Area / Vital Area Access Controls

a.

Inspection Scone (8170Q1

The inspectors reviewed and observed protected and vital area access

controls to determine if the provisions of the licensee's Physical

Security Plan (PSP) were being met. Additionally, the inspector

discussed the licensee's proposed implementation of biometrics to

,

!

control protected area access,

b.

Observations and Findinas

l

10 CFR 73.55(d)(4) allows licensee vehicles to be limited in their use

to onsite plant functions and shall remain in the protected area except

1or operational, maintenance. repair, security, and emergency purposes.

,

The inspectors reviewed Section 5.4.3 of the licensee's PSP. which

specified the re

protected area. quirements for the control of vehicles inside the

Section 5.4.3 of the PSP stated in part. " designated

vehicles are generally operated within the protected area but may also

be used outside the protected area and/or owner controlled area." The

licensee's December 1996 PSP change allowed the use of designated

vehicles outside the owner controlled area. The inspectnrs discussed

with licensee representatives the use of designated vehicles outside of

the owner controlled area and the limited use of vehicles as stated in

10 CFR 73.55(d)(4).

The licensee agreed to evaluate the need for a

clarification of this section of the PSP.

Discussions were held during the course of this inspection with res]ect

to the proposed implementation of biometrics to control access-to t7e

licensee s protected area. The licensee had submitted a revision to the

PSP to incorporate the use of biometrics.

The planned implementation

date is April 1998.

The inspectors reviewed the 31-day access lists for the periods of

September. October, amJ November 1997, and determined that the

recuirements of Section 5.1.1 of the PSP were being followed.

Incividuals who are favorably terminated are entered in the Training and

Qualification System (TRA05) by the appropriate department.

Termination

Enclosure 2

.

____

____ _ __ ___ _ -___ _

-

.

.

40

reports are run daily from TRAQS. which are used to remove badges from

the Access Control System (ACS). The inspectors determined that if a

failure to take the badge out of the ACS occurred and the indiviuual

takes the badge offsite, a " twilight report" will apprise Security that

a missing badge did r.ot card out of the protected area. Additionally.

contractor badges are deleted from the security computer system after 30

days of non-use.

c.

Conclusions

The licensee's practice of utilizing designated vehicles for offsite

use, as proposed in their December 1996 PSP change, was discussed.

The

licensee agreed to evaluate the difference between the December 1996

plan change and 10 CFR 73.55(d)(4).

Th-e implementation of biometrics

was discussed and is scheduled to begin in April 1998.

Protected and

vital area access controls met the requirements of the PSP.

S3

Security and Safeguards Procedure:: and Documentation

,

S3.1 Security Procram Plans

a.

Insoection Stone (81700)

The inspector reviewed the last three PSP changes submitted under

10 CFR 50.54(p) to determine if the requirements were met,

b.

Observations and Findinos

l

During a review of the PSP changes, the inspectors noted the following:

-

An inconsistency in one chapter of the PSP allowed for the use of

a posted officer or a roving patrol for a partial security system

degradation, whereas another chapter of the plan required using a

posted officer.

Upon further discussion, the inspector learned

that the licensee's intention for the use of a roving patrol for

the pur30se of compensatory measures was within a degraded area

where t1e entire degradation was in full view of the officer,

rather than a patrol of two or more areas that were not in sight.

In the event of a total security system failure, an effort to call

-

in more officers to iully compensate for the failure would be

required. The licensre would use the available officers onsite as

a temporary measure to compensate for the system failure, until

the required number of officers could be called. These actions

were not clearly specified in the PSP.

The licensee informed the inspector that a letter of clarification to

the NRC would be forthcoming to clarify these issues identified in the

December 1996 PSP change.

Enclosure 2

I

o

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..

..

41

c.

Conclusioni

The ins)ector determined that the PSP changes submitted by the licensee

under t1e provisions of 10 CFR 50.54(p) did not decrease the

effectiveness of the PSP.

The licensee agreed to clarify the

inconsistent issues identified in the December 1996 plan change.

S7

Quality Assucance in Security and Safeguards Activities

,

S7.1 Sgcuritv,Procram Audits

a.

Insoection Scone (81700)

'

The inspector reviewed 1997 required annual security audits conducted by

the Safety Audit and Engineering Review (SAER) group,

b.

Observations and Findinos

Security Audit 97-SP-1 was conducted during the period of January-

February 1997, and Security Audit 97-SP-2 was conducted June-July,

1997.

The following findings and recommendations were documented:

Unannounced drills, as required by the PSP, were not being

-

conducted.

The SAER recommended that a change to the plan be

,

L

submitted; however, security made a determination to continue the

'

practice of conducting unannounced drills.

An administrative non-com)liance was identified. When a procedure

-

needed revision, rather tlan stop and revise the procedure.

Security would 'line out" the portion that was inadequate and

continue to use the procedure.

-

Four examples of. procedural non-compliance were noted, to include

an example of a failure to test the walk-through metal detectors

once per shift as required by the PSP.

The inspector determined that audit reports were appropriately

documented and distributed to upper management for review.

Findings

were adequately addressed for closure.

The inspector noted that the licensee had a Continuous Improvement

Suggestion Program, which tracked suggestions from the security staff.

As of November 20, 1997, 31 suggestions had been implemented year-to-

date.

c.

Conclusions

Security audits were detailed, findings were adequately addressed, and

the level of management review was appropriate.

The inspectors

Enclosure 2

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_ ______ _ .___

.

.

42

determined that security audits were being conducted in accordance with

the-licensee's PSP.

-S.8

Miscellaneous Security and Safeguards Issues (92904)

'

58.1- (Closed). VIO 50-321. 50-366/97-04-01: Failure to Maintain

Confidentiality of Pers_ anal Information

The licensee responded -to the violation in correspondence dated June 20.

1997; The licensee adequately addressed, through procedures and

training of- the EAP providers, the process and conditions in which a

.

mandatory EAP referral will~be utilized.

(See Paragraph S1.3 for

-additionally-information). The corrective action is considered adequate

to close tnis violation.

V. Manaaement Meetinas

X.2

Review of UFSAR Commitments

A recent discovery of a 1icensee operating its 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 practices, procedures and/or parameters

to the UFSAR description. -While performing the ins)ections

discussed in this re] ort, the inspectors reviewed t1e applicable

portions of the UFSAl that : elated 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-

'

January 8. 1998.

The_ license acknowledged the findings presented.

Interim exits were conducted on November 21 and December 12. 1997.

The inspectors asked the licensee whether any materials examined

during the inspection should be considered proprietary.

No

proprietary information was identified.

X.'2-

Other NRC Personnel On Site

'On November 18-19. Mr. P.H. Skinner. Chief. Reactor Projects

Branch 2. Division of Reactor Projects, visited the site. He met

with the resident inspector staff to discuss licensee performance,

and regulatory issues. He toured the facilities to observe

equipment in operation and general plant conditions.

He attended

the morning management meeting for plant status and later met with

Enclosure 2

_

_ __ _ ___-__ - _ __.

.

.

43

the plant general manager to discuss plant performance and other

regulatory issues.

PARTIAL LIST OF PERSONS CONTACTED

Licensee

Anderson, J.

Unit Superintendent

Betsill, J., Assistant General Manager - Operations

Breitenbich, K., Engineering Support Manager - Acting

Curtis, S,, Unit Superintendent

Davis

D., Plant Administration Manager

Fornel

P., Performance Team Manager

Fraser

O,, 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

l

Moore, C.. Assistant General Manager - Plant Support

'

Reddick, R., Site Emergency Preparedness Coordinator

Roberts, P., Outages and Planning Manager

Thompson, J., Nuclear Security Manager

Tipps

S., Nuclear Safety and Compliance Manager

j

Wells, P., General Manager - Nuclear Plant

INSPECTION PROCEDURES USED

IP 37551:

Onsite Engineering

IP 37828:

Installation and Testing of Modifications

IP 60710:

Refueling Activities

IP 61726:

Surveillance Observations

IP 62707: Maintenance Observations

IP 71707: Plant Operations

IP 71714:

Cold Weather Preparations

IP 71750:

Plant Support Activities

IP 81700:

Physical Security Program for Power Reactors

IP 81502:

Fitness for Duty for Power Reactors

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 92804: Action on Previous Inspection Items

IP 92901:

Followup - Operations

IP 92902:

Followup - Maintenance / Surveillance

IP 92903:

Followup - Followup Engineering

IP 92904:

Followup - Plant Support

Enclosure 2

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. -. -

-

.

-

-.

- . - - ..

._

.-

. - . -

__ - . - ..

.

.

44

'

IP 93702:

Prompt Onsite Response to Events at Operating Power

Reactors

ITEMS OPENED AND CLOSED

Opened

50-321/97-11-01

NCV

Failure to Follow Procedure

1

and Inadequate Procedure

Results in Group 1 Isolation

'

(Section 03.1).

50-321/97-11-02

VIO

Late 10 CFR 50.72 Notification

for Unit 1 Engineered Safety

Feature Actuation (Section

l

04.1).

50-321, 366/97-11-03

VIO

Inadequate Corrective Actions

,

!

for Late 10 CFR 50.72

Notifications (Section 04.1).

4

50 321/97-11-04

NCV

Failure to Meet Unit 1

Technical Specification

Actions for Primary System

Pressure Boundary Leakage

(Section M8.1).

50-321, 366/97-11-05

IFI

Review Adequacy of Revised

Liquid Effluent Reiease

Procedures to Meet Offsite

Dose Calculation Manual.(00CM)

Monitor Check Source.

Requirements (Section R1.2).

50-321. 366/97-11-06

VIO

Failure to Follow Procedures

for Radiation and

Contamination Control and

Personnel Decontamination

Activities (Section R8.1).

50-321, 366/97-11-67

VIO

Failure to Follow Procedures

for RWP System Implementation

(Section R8.3).

"

50-366/97-11-08

URI

Unit 2 Failure to Meet General

Design Criteria 56 for Proper

Automatic Containment

Isolation Valve Outside

Containment (Section E2.1).

Enclosure 2

.

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..

.-

45

Closed

50-321/97-11 01

NCV

Failure to Follow Procedure

and Inadequate Procedure

Results in Group 1 Isolation

(Section 03.1).

50-366/97-10

LER

Manual Reactor Shutdown

Results in Water Level

Decrease and Group 2 and 5

<

PCIS Actuations

(Section 08.1).

50-321/97-08

LER

Personnel. Error and Inadequate

Procedure Results in Group 1

Isolation on Lvr. Condenser

Vacuum (Section 08.2).

50-321. 366/96-13-02

URI

E0P Deviation From EPG Step

RC/P-3 (Section 08.3).

50-321, 366/97-02-02

VIO

Failure to Follow Procedure -

Multiple Examples (Section

08.4)

50-366/97-02-03

VIO

Late 10 CFR 50.72 Notification.

For An Engineered Safety

Feature Actuation for

Containment Isolation (Section

08.5).

50-321, 366/97-05-02

VIO

Failure to Follow Procedure -

Multiple Examples (Section

08.6).

50-321/97-06

LER

Apparent LPRM TIP Calibration

Tube Failure Results in

Primary System Pressure

Boundary Leakage (Section

M8.1).

50-321/97-11-04

NCV

Failure to Meet Unit 1

Technical Specification

Actions for Primary System

Pressure Boundary Leakage

(Section M8.1).

Enclosure 2

1

o

_ _ .

.

46

2

50-321/97 07

LER

Pneumatic Leak Results in

'

Closure of Primary Containment

Isolation Valve (Section

M8.2).

50 321/97-10-01

IFI

Review of Unit 1 RCIC Testing

Activities from the Remote

Shutdown Panel (Section M8.3).

50-366/97-04

LER

Inaccurate List of Primary

Containment Isolation Valves

Results in Missed Surveillance

(Section E8.1).

(

50-321, 366/96-10-09

URI

Review Licensee Evaluation of

'

Sample Line Particulate

3

Sampling Adequacy and Main

i

Stack Accident Monitor

'

Environmental Operating

Specifications (Section R8.2).

e

[

50-321. 366/97-02-07

URI

Review Licensee Followup and

Results of Staff Radiation

Work Permit Adherence (Section

R8.3).

50-321. 366/97-05-03

IFI

Review Licensee's Root Cause

Determination and Corrective

Actions for Personnel

Contaminations (Section R8.4).

50-321, 366/97-04-01

VIO

Failure to Maintain

Confidentiality of Personal

.Information (Section S8.1).

Enclosure 2

,