ML20217N131

Insp Repts 50-321/98-01 & 50-366/98-01 on 980208-0321. Violations Noted.Major Areas Inspected:Licensee Operations, Engineering,Maint & Plant Support

ML20217N131
Person / Time
Site:	Hatch
Issue date:	04/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20217N092	List: ML20217N088 ML20217N110 ML20217N131
References
50-321-98-01, 50-321-98-1, 50-366-98-01, 50-366-98-1, NUDOCS 9805050232
Download: ML20217N131 (39)

See also: IR 05000321/1998001

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos: 50-321. 50-366

License Nos: DPR-57 and NPF-5

Report No: 50-321/98-01. 50-366/98-01

Licensee: Southern Nuclear Operating Company. Inc. (SNC)

Facility: E. I. Hatch Units 1 & 2

Location: P. O. Box 2010

Baxley Georgia 31515

Dates: February 8 - March 21, 1998

Inspectors: B. Holbrook. Senior Resident Inspector

J. Canady. Resident Inspector

W. Kleinsorge. Reactor Inspector. Sections M1.3.

M1.4. and M2.1

G. Wiseman. Reactor Inspector. Sections F1.1.

F2.1, and F5.1

G. Kuzo. Senior Radiation Specialist. Sections

R1.2 and R2.1

Accompanying Inspector: T. Fredette. Resident Inspector

Approved by: P. Skinner Chief. Projects Branch 2

Division of Reactor Projects

Enclosure 2

9805050232 980421

PDR ADOCK 05000321  ;

G PDR b

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EXECUTIVE SUMMARY

Plant Hatch. Units 1 and 2

NRC Inspection Report 50-321/98-01, 50-366/98-01

1his 6-week integrated inspection included aspects of licensee

operations, engineering, maintenance, and plant support. The report is

a compilation of observations and findings by the resident inspection

staff and region-based specialist inspection staff. ,

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Doerations i

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e Operator use of three-part communications and the phonetic

alphabets during the power reduction for the sequence exchange on

Unit I was good (Section 02.1).

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Maintenance

e Site management was kept informed of the number of outstanding and

backlogged work items. A documentation review indicated that work

items were being identified and corrected within a reasonable time

(Section M1.2).

e The licensee's plans for performing periodic evaluations and

assessments met the requirements of the Maintenance Rule.

However, several weaknesses were identified in the periodic

assessment procedure (Section M1.3).

• For Maintenance Rule (a)(2) systems, structures and components

(SSCs). performance criteria had been established, suitable

trending had been performed and corrective actions were taken ,

when SSCs failed to meet performance criteria or experienced i

failures. Industry wide operating experience had been considered

(Section M1.4).

e Personnel performance during surveillance activities was

excellent. Procedures were used: communications were generally

three-part; and supervisory oversight was evident. All test

results reviewed met the procedure and Technical Specification

acceptance criteria (Section M3.1).

e Violation 50-366/98-01-02. Failure to Follow Maintenance

Procedures, was identified. Maintenance work was performed that

was not specified on the maintenance work order and was outside

the approved clearance boundary. (Section M4.1).

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e Apparent Violation EEI 50-321. 366/98-01-08. Plant Operation

Outside of the Design Basis for an Engineered Safeguard System,

was identified, associated with design issues that resulted in the

Main Control Room Environmental Control System being unable to

perform a design safety function. The corrective actions were

effective in returning the system to its design condition

(Section E2.1).

e Violation 50-366/98-01-03. Failure to Follow Engineering Test

Procedures. was identified. This violation was for the failure to

follow procedures for review, approval, and signature authority of

the responsible engineer for a pressure test (Section E3.1).

Plant Sucoort

e Excluding the Unit 1 Condensate Pump Turbine Building 112-foot

elevation high radiation area, radiological controls for normal

operations and for radwaste and radioactive material storage areas

were implemented properly and maintained in accordance with

procedural Technical Specification (TS), and 10 CFR Part 20

requirements (Section R1.2)

e Radiological surveys were inadequate and established controls were

not implemented properly for routine Unit 1 Condensate Pump

vibration analysis measurements conducted in the Turbine Building

-112-foot elevation high radiation area (Section R1.2).

e Violation 50-321/98-01-04 was identified for failure to follow

3rocedures in accordance with TS 5.4.1 for Entry into a High

Radiation Area (Section R1.2)

e Violation 50-321/98-01-06 was identified for Failure to Conduct

Adequate surveys to Evaluate the Extent of Radiation Levels and

Potential Hazards to Workers Conducting Condensate Pump Vibration

Analysis Measurements within a High Radiation Area on the Unit 1

Turbine Building 112-foot elevation (Section R1,2).

o Numerous examples of poor facility housekeeping and cleanliness,

and poor contamination control practices were identified (Section

R1.2).

e The. material condition of the Main Control Room Environmental

. Control ventilation ductwork insulation was degraded (Section

R2.1).

Enclosure 2

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e 'A lack of supervisory' oversight of chemistry activities and

chemistry interface with the operations department resulted in a

violation of a failure to follow surveillance procedures (Section

R4.1).

e Chemistry technicians used proper equipment and sampling .

technigues while' obtaining fuel oil samples of the Security Diesel

g fuel oil (Section R4.2).

e The installation and repair procedures ~ for penetration seals

provided adequate guidance to ensure materials were installed per

design requirements (Section F1.1).

' e The licensee's fire barrier penetration report evaluations-

conducted for penetration seals that were inaccessible for visual

inspections were adequate (Section F1.1).

e Brand Industrial Services Company silicone foam penetration seal

designs were not supported by available vendor qualification test

reports. The licensee did not perform engineering evaluations that

satisfied the guidance of NRC GL 86-10 for deviations from fire

barrier configurations qualified by tests. These were considered

fire protection engineering program weaknesses (Section F1.1).

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e The fire brigade leader demonstrated good leadership' abilities

during the performance of the unannounced fire drill conducted on-

March 3. The overall performance and effectiveness of the fire

brigade was satisfactory (Section F4.1).

e The fire barrier penetration seal installers were appropriately

trained to accomplish fire barrier penetration seal installation

work and Quality Control inspectors were qualified to perform the

appro)riate verification for installation and repairs made to the

fire Jarrier penetration seals (Section F6.1).

Enclosure 2

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Report Details

Summary of Plant Status

Unit 1 began the report period at 100% rated thermal power (RTP).

Reactor 30wer was reduced to about 60% RTP on February 21 to

troubles 1oot and repair the control valves on the ~B" reactor feedwater

pump turbine (RFPT). Reactor power was returro ' to rated the following

day. The unit remained at 100% RTP for the rem " r of the reporting

period except during routine testing activities.

Unit 2 operated at 100% RTP for the report period, except during routine

testing activities.

I. Operations

01 Conduct of Operations

01.1 General Comments (71707)

Using inspection procedure 71707. the inspectors conducted

frecuent reviews of ongoing plant operations. In general, the

concuct of operations was professional and safety-conscious;

specific events and observation are detailed in the section below.

02 Operational Status of Facilities and Equipment

02.1 Power Reduction for Unit 1 Control Rod Seauence Exchance and

Balance of Plant Reoairs

a. Insoection Scopo d'O ll

The inspectors observed a Unit 1 power reduction for the

performance of a control rod sequence exchange, repair of the

control valve linkage for the IB RFPT. and the repair of leakage

in the condenser bay.

b. Observations and Findinas

On February 21 reactor power was reduced to approximately 75% RTP

for a scheduled control rod sequence exchange. The inspectors

observed control room operators reducing power in accordance with

general operating procedure 34G0-0PS-005-15. " Power Changes."

Revision (Rev.) 21. Another operator was present at the control

board to verify rod movement in accordance with the procedure.

Power was later reduced to approximately 60% RTP for the removal

of the 1B RFPT from service for repairs and the repair of leaks in

the condenser bay.

Enclosure 2

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Maintenance personnel found that the 1B RFPT control valve linkage

was binding. Speed on the 1B RFPT could be increased, but

intermittent problems were encountered when trying to reduce

speed. Maintenance personnel completed repairs on February 21.

c. Conclusions

Operator use of three-part communications and the ahonetic

alphabet was good during the power reduction for t1e sequence

exchange on Unit 1. Supervisory oversight and Shift Technical

Advisor support were evident.

08 Miscellaneous Operations Issues (92901)(92700)

08.1 (Closed) Violation (VIO) 50-321. 366/97-06-01. Failure to Prevent

Recurrence of Imorocer Eauioment Storace in Control Room.

The licensee responded to this violation in documentation dated

August 8. 1997. The inspectors questioned several operators

during a routine tour of the control room about storage of

material in the control room. All operators questioned were aware

of the seismic requirements for the storage of material in the

control room. The inspectors also performed a general tour of the

control room, including the back panel areas, and did not identify

any improperly stored material. Based upon the inspector's review

of the licensee's action, this violation is closed.

08.2 (Closed) LER 50-366/97-02. Grounded Jumoer Causes Blown Fuse _and

ESF actuation.

This problem is discussed in Section 4.1 of IR 50-321, 366/97-02.

No new information was presented. Based upon the inspectors

review of licensee actions, this LER is closed.

08.3 Safety Related Overtime (OT) Review (71707) (92901)

The inspectors reviewed the Unit 1 and Unit 2 OT records for the

months of September to November 1997. Included in the review was

OT worked during the 1997 Fall Refueling Outage on Unit 1.

The inspectors concluded that site management maintained good 1

control of overtime for the 1997 Refueling Outage on Unit 1. I

Technical Specification and procedural requirements were met.

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Enclosure 2

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II. Maintenance

l M1 Conduct of Maintenance

M1.1 General Comments (62707)

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The inspectors observed or reviewed all or portions cf the

following work activities:

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. MWO 1-98-0217: Repair Reactor Feedwater Pump Turbine

(RFPT) IB control valve linkage

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e MWO 1-98-0233: Repair oil leak on IB RFPT main oil pump

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• MWO 2-98-0128: Core Spray preventive maintenance

• MWO 2-97-2053: Remove old valve 2C41-F033B and install a

new valve

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! lhe inspectors four.2 that the work was performed with the work

l packages present and being actively used. Maintenance activities

! were generally completed thoroughly and professionally. No

deficiencies were identified by the inspectors.

M1.2 Review of Maintenance Backloa

a. Insoection Scooe (62707)

l The inspectors reviewed licensee documentation for maintenance

items completed and the existing maintenance backlog including a

Unit I refueling outage for a 5-month time period.

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b. Observations and Findinas

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The inspectors observed that Outage and Planning personnel tracked

work items and routinely submitted a Backlog Report to management

personnel.

The inspectors observed during a control room walkdown that the

l number.of work items placed on equipment that might affect the

operators' ability to use equipment was low. At the time of the

control room walkdown, there were no instruments out of service.

l The reviewed documents indicated there were no overdue preventive

maintenance (PM) items and the specific PM items the inspectors

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reviewed were not overdue,

c. Conclusions

The inspectors concluded that management personnel were kept.

informed of the number of outstanding and backlogged work items.

A documentation review indicated that work items were being 4

identified and corrected within a reasonable time. l

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M1.3 Maintenance Rule - Periodic Evaluation

a. Insoection Scooe (62706)

Paragraph (a)(3) of 10 CFR 50.65, the Maintenance Rule, required

that performance and condition monitoring activities and

associated goals and preventive maintenance activities be

evaluated taking into account, where practical, industry-wide

operating experience. This evaluation was required to be

performed at least one time during each refueling cycle not to

exceed 24 months between evaluations. The inspectors reviewed the

licensee's periodic evaluation process.

b. Observations and Findinos

At the time of this inspection, the licensee was not required to

have completed the first periodic evaluation.

Periodic maintenance assessment was addressed in licensee

procedure 40AC-ENG-020-05. " Maintenance Rule (10 CFR 50.65)

Implementation." Rev. 3. The procedure guidance did not

adequately address the NUMARC 93-01 topics of sections 12.2.1.

" Review of Goals (a)(1)." 12.2.2. " Review of S.C. Performance

(a)(2)." 12.2.3 ~i<eview of Effectiveness of Corrective Actions."

and 12.2.4. " Optimizing Availability and Reliability for SSCs."

The licensee indicated that Procedure 40AC-ENG-020-05 was in the

process of revision, and the new revision will completely address

the topics of section 12 of NUMARC 93-01. l

The licensee planned to complete a periodic maintenance assessment

for both units by June 1, 1998. This assessment was planned to

cover at least that portion of the Unit 1 Fuel Cycle 17 after the

implementation of the Rule (July 10. 1996. to October 11. 1997),

and that portion of the Unit 2 Fuel Cycle 13 after the

implementation of the Rule (July 10. 1996, to March 14. 1997).

Inspector Followu) Item (IFI) 50-321, 366/98-01-01. Review of

Maintenance Rule )eriodic Assessment Procedure, was opened to

review the revisions to procedure 40AC-ENG-020-0S.

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c. Conclusions

The inspectors concluded that the licensee's plans for performing

periodic evaluations and assessments met the requirements of the

Maintenance Rule. However, the inspectors identified several

weaknesses in the periodic assessment procedure, which the

licensee planned to correct in a subsequent procedure revision.

Enclosure 2

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M1.4 Maintenance Rule - Preventive Maintenance and Trendina for

Paraaraoh (a)(2)

a. Insoection Scooe (62706)(62002)

Paragraph (a)(2) of the 10 CFR 50.65 states that monitoring as

required in paragra)h (a)(1) is not required where it has been

demonstrated that tie performance or condition of a system

structure or component (SSC) is being effectively controlled

through the performance of appropriate preventive maintenance,

such that the SSC remains capable of performing its intended

function. The licensee utilizes conditioning monitoring for

structures within the scope of the Maintenance Rule.-

The inspectors examined the below-listed structures to verify that

a)propriate preventive maintenance was being performed, such that

t1e structures remained capable of performing their intended

function. The inspectors verified that industry-wide operating

experience was considered, where practical, that appropriate

trending was being performed, that safety was considered when

performance criteria were established, and that corrective action

was taken when structures failed to meet performance criteria.

The inspectors reviewed program documents and records for the

structures that the licensee had placed in the (a)(2) category in

order to evaluate this area. The inspectors also discussed the

program with licensee management, the Maintenance Rule

coordinator, engineering and maintenance personnel, and other

licensee personnel

b. Observations and Findinas

, The licensee had completed the last section of its " Structural

Monitoring Baseline Inspection" in May 1997.

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The inspectors

reviewed the " Structural Monitoring Program for the Maintenance

l Rule." Rev. 3. dated December 1997. (SMP) to assess the adequacy

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of the acceptance criteria and performance criteria for the

evaluation of the concrete and structural steel. The licensee

uses the SMP at all three of their licensed sites. The inspectors

noted that the SMP did not address roof system ponding and only

addressed concrete cracks in terms of width. As a result of the

January 1998 inspection in the area of 10 CFR 50.65, at the

licensee's Vogtle site. NRC Inspection Report 50-424. 425/98-01.

the licensee had initiated Vogtle Plant Action Item C00037982 to

evaluate this issue and initiate appropriate corrective actions.

As the SMP is a company-wide program, the Vogtle action item will

address this issue at Hatch. ,

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The inspectors conducted a walkdown inspection of several

structures and noted the following discrepant condition: hich had

not been documented in the structural baseline database.

• Concrete cracking at all cooling tower riser pipe thrust

blocks.

• Long diagonal cracking on the diesel generator and

recombiner building walls.

• Extensive corrosion at the interface of the precast panels

and the 228'-0" floor, around the perimeter of refueling

deck floor.

. Missing large diameter connection nut at TA/T13 Turbine

Building Elevation 164'-0"

. Severely corroded bolt in large X-bracing connection between

Columns T22/TI and T21/TI of the Turbine Building.

. Significant wastage reducing the diameter of some Unit 2

condensate storage tank hold down bolts.

The inspectors discussed the above with licensee personnel,

indicating that without detailed baseline information, trending of

minor discrepant conditions was not possible. The licensee i

personnel concurred and indicated that they would amend the f

" Structural Monitoring Baseline Inspection" to include the above  !

and similar items.

The inspectors concluded that the surface cracking in the concrete

structures and the corrosion discussed above was minor in nature

and that the structures appeared to be sound. No unacceptable

conditions were noted During the walkdown inspection, the

inspectors were accompanied by civil engineers who were

knowledgeable and qualified to perform structural evaluations.

c. Conclusions

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For Jaragraph (a)(2) SSCs. performance criteria had been

esta)lished, suitable trending had been performed and corrective

actions were taken when SSCs failed to meet performance criteria

or experienced failures. Industry-wide operating experience had

been considered. Procedure weaknesses (lack of detail) were

identified in the areas of structural monitoring.

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M2 Maintenance and Material Condition of Facilities and Equipment

M2.1 Material Condition Walkdowns

a. Insoection Scooe (62706)

The inspectors performed walkdowns of selected portions of the

following structures and plant areas, and observed the material

condition of SSCs: intake structure; diesel generator building:

offgas recombiner building: Units 1 and 2 turbine buildings:

control building: Units 1 and 2 condensate storage tanks: Units 1

and 2 reactor buildings: and the cooling towers.

b. Observations and Findinas

Housekeeping in the general areas around equipment was good.

Piping and components were painted, and few indications of

corrosion, oil leaks, or water leaks were evident. During the

walkdown inspection of structures, the inspectors noted several

material condition deficiencies:

. Caulk associated with the interior rubber seal on the

vertical seismic gap on the east wall of the reactor

building above the refueling deck was significantly degraded  ;

and could. but had not affected, secondary containment. i

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. Metallic material was degraded at the precast panel to slab

interface adjacent to HPCI roof (exterior).

. The large diameter blowdown pipe at the Unit 1 flume has

corrosion rosettes at the saddle interface of the pipe to

the concrete thrust block E1.164'-0.

.' Wastage of anchor bolts and stringers was located on the

stairs associated with Unit 1 condensate storage tank.

. Several of base plates and anchor bolt / nuts exhibiting

flaking expansive rust.

These conditions were identified to the licensee personnel for j

appropriate corrective actions. '

c. Conclusions

In general. plant material condition and housekeeping observed

during walkdowns were good. Preservation of equipment by painting

! was considered to be good.

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M3 Maintenance Procedures and Documentation

M3.1 Surveillance Observations (61726)

The inspectors observed all or portions of six Unit 1 and Unit 2

surveillances which included the following surveillance

activities:

. 34SV-SUV-008-2S: Primary Containment Isolation Valve

Operability Test

. 34SV-R43-004-15: Diesel Generator 1A Semi-Annual Test

The inspectors observed that personnel performance during the

surveillance activities was excellent. Procedures were used:

communications were generally three-part: and supervisory

oversight was evident. All test results reviewed met the

procedure and TS acceptance criteria.

M3.2 Unit 2 Reactor Core Isolation Coolino (RCIC) System Post

Maintenance Testina

a. Insoection Scooe (62707)(71707)

The inspectors observed personnel perform sections of the RCIC

surveillance test procedures.

b. Observations and Findinas

The inspectors attended the pre-test briefings conducted prior. to

the RCIC surveillances. The briefings were conducted by

o)erations personnel with representatives from maintenance, health

p1ysics, and operations management.in attendance.

The inspectors observed that the maintenance personnel conducted

their activities in a deliberate. professional' manner using the '

respective procedure and noted that the activities were well

planned and controlled. ,

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c. Conclusions j

For the RCIC surveillance activities observed, all data met the

required acceptance criteria and the equipment performance was

satisfactory. The performance of the personnel conducting the

surveillance test procedures was good.

Enclosure 2

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M4 Maintenance Staff Knowledge and Performance

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l M4.1' Maintenance Work Renders Both Trains of the Unit 2 Standby Liouid

Control (SBLC) System Inocerable.

l a. Insoection Scoce (62707)

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On March 5. a maintenance error. rendered both trains of the Unit 2

SBLC system inoperable. The. inspectors reviewed the maintenance

work package. applicable procedures, and circumstances surrounding

l the error. Procedures reviewed included the following:

* 30AC-0PS-001-05. " Control of Equipment Clearances and Tags."

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Rev. 16

. 50AC-MNT-001-05. " Maintenance Program." Rev. 26

• 34SV-C41-002-2S. "SBLC Pump Operability." Rev. 17

b. Observations and Findinas

On March 5. operations personnel placed the "B" train of SBLC

under clearance to support the 18-month PM activities and to

repair check valve 2C41-F033B. The inspectors reviewed the

clearance used to isolate the SBLC train and determined that it

satisfactorily established the isolation boundaries during the

maintenance activities.

However, when maintenance personnel cut the pump discharge line to

remove 2C41-F033B the cut was made outside the clearance boundary

rendering both trains of the SBLC system inoperable. Maintenance

3ersonnel recognized the error and contacted operations personnel.

Jnit 2 control room supervision declared both trains of the SBLC

system inoperable and entered the TS required action statement

(RAS). TS section 3.1.7 requires that at least one of the SBLC

systems be restored to operable status within eight hours or the

unit placed in Mode 3 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Maintenance 3ersonnel repaired the incorrect system breach. The

inspectors o) served that the weld for the incorrect cut was

completed and inspected and operations personnel completed the-"A"

l train post-maintenance operability surveillance test in about five

hours. Maintenance completed the check valve replacement and

l operations com)leted the post-maintenance operability surveillance

l test for the "3" train about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the system was

initially removed from service. The inspectors reviewed procedure

34SV-C41-002-2S and concluded that all TS surveillance

requirements were met for both trains of SBLC.

Enclosure 2

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During the review, the inspectors observed that step 4.2.5 of

procedure 50AC-MNT-001-0S identified that personnel were

! responsible to ensure that plant maintenance is performed and

controlled within the clearance boundaries. Additionally. step

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6.2.3 stated, in part, that personnel performing work shall not

l exceed the scope of work as authorized in the work instructions

and work requested in the MWO. Also, procedure step 8.5.11.3

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required personnel performing the work to verify clearance

boundaries. In this case, work was performed that was not

saecified in the MWO work package and a system breach occurred

tlat was outside the established and approved clearance boundary.

The inspectors reviewed the licensee's performance of the ]rior

two years and noted an instance where work was performed tlat was

not specified on a MWO. This resulted in a violation that was

documented in IR 50-321. 366/97-02. The inspectors identified the

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most recent problem for maintenance work performed that was not

specified on work instructions and performed outside the

established clearance boundary as a repeat VIO 50-366/98-01-02:

Failure to Follow Maintenance Procedures.

The inspectors review of engineering performance and procedures

associated with this issue is discussed in Section E3.1 of this

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Inspection Report.

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c. Conclusions

VIO 50-366/98-01-02. for a failure to follow maintenance

procedures, was identified. Maintenance work was performed that

was not specified on the maintenance work order and was outside

the approved clearance boundary.

M8 Miscellaneous Maintenance Issues (92902)

M8.1 (Closed) Violation 50-321. 366/96-12-01: Failure to Include All

Structures. Systems, and Components in the Scope of the

Maintenance Rule as required by 10 CFR 50.65. By letter dated

March 5.1997. the licensee identified its corrective actiont . As

a result, the licensee included the communications, non-Appendix R

emergency lighting. Appendix R emergency lighting, and cooling

tower systems in the Maintenance Rule program. The inspectors

determined that the licensee had conducted an appropriate survey

and determined the extent of the noncompliance, and took

appropriate actions to correct the condition and prevent its

recurrence. This issue is closed.

M8.2 (Closed) Violation 50-321. 366/96-12-02: Failure to Establish

Adequate Performance Criteria for SSC Risk-significant Functions.

By letter dated December 19. 1996. and March 5. 1997, the licensee

provided their corrective actions. As a result, the licensee

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established appropriate additional performance criteria for the

following systems: AC and DC electrical and analog transmitter

trip, primary containent and primary containment isolation. <

feedwater and condensate. circulating water, electro-hydraulic l

control, and 3rimary containment chilled water. The inspectors j

determined tlat the licensee had conducted an appropriate survey

and determined the extent of the noncompliance, and took l

appropriate actions to correct the condition and prevent its

recurrence. This issue is closed.

M8.3 (Closed) IFI 50-321. 366/96-12-04: Failure to Provide Adequate

Procedure for Implementation of Maintenance Rule Requirements.

The licensee opened Action Item Tracking (AIT) No 96-261 with a

due date of January 5. 1998. Regulatory Guide (RG) 1.160. l

" Monitoring the Effectiveness of Maintenance at Nuclear Plants."

Rev. 2. issued March 1997. paragraph 1.2. provided specific {

guidance in the area in question, that of the role of ,

organizations, other than the Maintenance department, as it

relates to Maintenance Preventable Functional Failures (MPFF)s.

The licensee has revised Administrative Control Procedure ACP i

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40AC-ENG-020-05. Rev. 2. " Maintenance Rule (10 CFR 50.65)

Implementation." Procedure ACP 40AC-ENG-020-0S Rev. 3. dated

October 10. 1997, incorporated the definition of maintenance as

stated in RG 1.160. Rev. 2. paragraph 1.2. verbatim. This issue I

is closed. l

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M8.4 (Closed) IFI 50-321.366/96-12-05: Followup on Licensee Actions to

Provide Performance Criteria for Structures After Industry

Resolution of this Issue. The licensee opened AIT No 96-262 with l

a due date of January 7. 1998. RG 1.160. Rev. 2. issued March {

1997, paragraph 1.5. provides specific guidance in the area in

question. that of monitoring structures. The licensee issued the

SMP and has completed their " Structural Monitoring Baseline

Inspection" as discussed in paragraph M1.2 above. This issue is -

closed.

III. Enaineerina

E2 Engineering Support of Facilities and Equipment

E2.1 Unit 1 and Unit 2 Main Control Room Environmental Control (MCREC)

Systems Outside Their Desian Basis

a. Insoection Scooe (37551) (92903)

On February 16. the licensee identified that two temperature

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switches, one switch on each of the MCREC subsystems, were not

l installed. This allowed system bypass flow into the main control

i room that would not be fully filtered or treated. The inspectors l

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reviewed the impact of the missing switches on the MCREC system

Enclosure 2

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operability. The inspectors also discussed the problem with

licensee personnel

b. Observations and Findinos

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On February 16, during charcoal filter testing and )lanned

calibration of temperature switch associated with t1e charcoal of i

.the "B" MCREC filter subsystem, engineering personnel discovered

the temperature switch to be missing. The missing temperature

switch left an approximately one-half inch diameter hole in the i

MCREC filter train that was opened to a conduit containing the

wiring for the missing temperature switch. The wiring from the

conduit at the location of the missing temperature switch was

connected with a wire nut thereby providing circuit continuity and l

! allowing the carbon drying heater to function. The hole left by

the missing temperature switch allowed bypass flow to enter the

control room without filtration by the charcoal in the affected

MCREC filter train. .The two MCREC filter trains are shared by the J

main control room for each unit. The purpose of the charcoal in

l the filter train is to remove a very high percentage of the iodine

that is postulated to be present following various design basis

,

accidents (DBA). This removal of iodine ensures that the

,

requirements of 10 CFR 50, Appendix A. Criterion 19 are met.

l

l

Within about two hours of the first identified problem on the "B" l

subsystem, an investig6 tion of the "A" subsystem revealed that its

l associated temperature switch was also missing. Both MCREC filter

'

trains were declared inoperable and the Required Action Statements

i (RAS) of TS 3.0.3 were entered for each unit.

L Two rubber plugs (a plug within a plug) were installed in place of

i the temperature switch for the "A" MCREC subsystem. The system

!

was declared operable at about 4:30 p.m. on February 16 and

TS 3.0.3 was exited. The inspectors reviewed the 10 CFR 50.59

evaluation and Temporary Modification to complete this work

I

activity. The inspectors concluded that the 10 CFR 50.59

evaluation was satisfactory.

A temperature switch was installed ulibrated, and tested for the

"B" MCREC subsystem. Following p. 'intenance testing. the

system was declared operable on Feto wry 17. On February 18, the

temporary rubber plugs were removed from the "A" MCREC subsystem

and a new temperature switch was installed. The subsystem was

tested and returned to service on February 20.

The licensee considered the failure to install or the removal of

the temperature switches an isolated event and that plant

process-es and procedures in place were adequate to maintain proper

plant configuration. As part of the licensee's immediate

corrective actions, the Standby Gas Treatment Systems for both

Enclosure 2

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units, which have a simila' configuration as the MCREC systems,

were verified to have no missing temperature switches. i

TS 5.5.7 requires that the MCREC be tested in accordance with

.

Regulatory Guide 1.52. Revision'2. Section 5d, and ASME N510-1989,

!~

Section 11. The ins)ectors reviewed procedure 42SV-Z41-002-0S,

" Testing of. Control Room Habitability Filter Trains." Rev. 7, and -

determined that the previous test acceptance criteria for the

MCREC system were acceptable.

On February 17, the licensee performed an initial review of

calculations for the thyroid doso nf iodine'to control room

< operators following a DBA. The licensee concluded that the

l

Jotential existed that the holes in the MCREC filter trains would

lave allowed sufficient contaminated air to bypass the carbon

filters allowing the control room personnel to exceed the NRC

,

iodine limit to the thyroid of 30 rem. This wn outside of the

design basis for an engineered safeguard systern (MCREC). This is

an apparent vf olation of 10 CFR 50, Appendix B. Criterion III.

Design Controls, which requires that measures be established to

verify adequacy of design.

The licensee requested the architecture / engineering company for

the plant to perform additional quantitative calculations for the

thyroid iodine exposure to control room personnel during and

following a DBA. The analysis were performed using actual main

steam isolation valve and containment leakage rates as inputs, to

determine the projected dose. The results of these calculation

identified that a thyroid dose of 30 rem would have been exceeded

using conservative, deterministic assumptions. ,

The licensee completed Licensee Event Report (LER)

50-321/1998-001. Inoperable MCREC System Filter Trains Result in

Entry Into LCO 3.0.3, dated March 18. The licensee was not able

to determine the cause for the missing temperature switches from j

this review. *

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,

TS 5.5.7 requires that the MCREC be tested in accordance with

Regulatory Guide 1.52. Revision 2. Section 5d and ASME N510-1989.

Section 11. The inspectors reviewed the above documents and

arocedure 42SV-Z41-002-05, " Testing of Control Room Habitability

ilter Trains." Rev. 7. and determined that the previous test

acceptance criteria for the MCREC system for the past two years

was acceptable.

f' A review by the inspectors of UFSAR Table 6.4-2 (sheet 1 of 2)

indicated that a failed electric carbon drying heating coil

control (missing temperature switch) resulted in constant coil

operation which was not sufficient to cause damage and heater coil

Enclosure 2

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operation was not essential to the operation of the filter during

a LOCA.

The inspectors were informed by engineering personnel that a

request for calibration of the temperature switches was initiated

in 1993. A review by the licensee of FSAR Table 6.4-2 (sheet 1 of

2) indicated that a failed electric carbon drying heating coil

control (missing temperature switch) resulted in constant coil

operation which was not sufficient to cause damage and heater coil

operation was not essential to the operation of the filter during

a LOCA. 'As a result.-little emphasis was placed on calibrating '

the temperature switches. The MWO that was initiated in 1993 was

not performed and was replaced with another MWO in 1996. The

inspectors reviewed the applicable MW0s to verify the. information

provided by engineering personnel. The missing temperature

switches would have been discovered sooner had the MW0s been

worked earlier.

c. Conclusions

An Apparent Violation (EEI) 50-321. 366/98-01-08. Plant Operation

Outside of the Design Basis for an Engineered Safeguard System,

was identified, associated with design issues that resulted in the

Main Control Room Environmental Control System being unable to

perform a design safety function. The corrective actions were

! effective in returning the system to its design condition.

E3 Engineering Procedures and Documentation

,

E3.1 Review of Enaineerina Activities Associated with Unit 2 Standby

Liauid Control (SBLC) System

l

a. .Insoection Scooe (37551) (92903)

' On March 5. a maintenance error rendered both trains of the Unit 2

SBLC system inoperable. The inspectors reviewed applicable

l procedures and reviewed engineering performance associated with

L the activities.

The inspectors * review of maintenance activities is discussed in

Section M4.1 of this inspection Report.

b. Observations and Findinas

The maintenance work scope included routine preventive maintenance  ;

activities and repair of a SBLC pump check valve. The inspectors '

were informed that the initial work plan was to cut pipe supports

and remove the check valve. Workers reviewed the physical piping ,

layout and. identified a method of repair that did not require  !

Enclosure 2

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cutting the pipe supports. The responsible engineering personnel

who revised the weld isometrics.to accommodate the new repair plan

did not recognize that the revised work plan called for pipe cuts

outside the clearance boundary and authorized the pipe cut. This

oversight contributed.to both trains of the Unit 2 SBLC system

'

i

l being. rendered inoperable. The maintenance work plan changes were

!

not reviewed and discussed with maintenance or operations

i supervision.

!

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The inspectors reviewed procedure 42IT-TET-004-0S, " Operating

Pressure Testing of Piping and Components " Rev. 5 used to test

the SBLC welds following the maintenance activities. The

inspectors observed that procedure step 7 2.4 stated, in part.

l that the resaonsible engineer will indicate if test results are

l acceptable. 3ased on no evidence of leakage from welds pipes, or

j components bodies. A note preceding the procedure step stated. in

l

'

part, that the VT-2 inspector may sign for the responsible

,

engineer when verbal concurrence is given by the responsible

, engineer for pressure tests which contain neither valve

!

manipulations nor leakage. The inspectors noted that a VT-2

inspector had signed the test acceptance sheets for the . i

responsible engineer for the three weld inspections completed i

during the maintenance repair activities. When questioned by the-

, inspectors, the responsible engineer stated that he had not

!

reviewed the test nor given verbal approval for the VT-2 inspector

to sign for his responsibility. The VT-2 inspector presented a

computer E-Mail dated January 20. from the ISI engineer stating. l

in part. that "This memo may be used to satisfy procedural

requirements when the ISI pressure test engineer is unavailable.

When an ISI pressure test is performed by the VT-2 inspector and

no leakage or valve manipulation is required. the VT-2 inspector

may sign.for the responsible engineer (ISI pressure testing

engineer or designated personnel). This memo serves as verbal

"

concurrence.

- The inspectors discussed this issue with Nuclear Safety and

Compliance and engineering management. The inspectors' concern

was that the E-mail gave blanket approval for test review. j

Additionally, the E-mail gave approval to not follow procedures in  ;

that the intent of the procedure step was not being met and the j

procedure had not been revised. The following day, the inspectors  !

l were informed that engineering management had rescinded the E-mail '

memo and informed all involved personnel that verbal approval was

required for each test. The inspectors identified this failure to

follow procedure as VIO 50-366/98-01-03: Failure to Follow

j. Engineering Test Procedures.

i

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Enclosure 2

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c. Conclusions

A violation for a failure to follow engineering test procedures,

was identified. This violation was for the failure to follow

procedure for. review.- approval, and signature authority of the

responsible engineer for pressure testing.

E8 Miscellaneous Engineering Issues

l

E8.1- (Closed) LER 50-321.98-01. Inocerable MCREC System Filter Trains

Result in Entry Into LCO 3.0.1.

This issue is' discussed in Section E2.1 of this Inspection Report.

This LER is closed.

!

IV Plant SuDoort

R1 Radiological Protection and Chemistry (RP&C) Controls

R1.1 Observation of Routine Radiolooical Controls (71750)

l General Health Physics (HP) activities were observed during the

report period including: locked high radiation area doors, proper

'

radiological posting, and personnel frisking upon exiting the

radiologically-controlled area (RCA). The inspectors made

frequent tours of the RCA and discussed radiological controls with

, HP technicians and HP management. Minor deficiencies identified {

were discussed with HP management. I

R1.2 Conduct of Radiological Prot'ection Controls

a. Insoection Scooe (83750) (84750)

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

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

inspectors. Reviewed program activities 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 observed radiation protection activities were compared against

anlicable sections of the Updated Final Safety Analysis Report

-

(FSAR) and against approved procedures Technical Specifications

(TSs) and 10 CFR Part 20 requirements.

l b. Observations and Findinas

All high radiation area postings and container labels were

determined to be adequate for the associated radiological

conditions. Calibrations for "in use" direct radiation and air

l Enclosure 2

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sampler instrumentation were current. Excluding worker and HP

actions required for surveillances conducted on the U1 Condensate

Pump equipment on the Turbine Building 112-foot (') elevation.

radiation controls for high and locked high radiation areas were

adequate and implemented appropriately.

Several concerns regarding radiological controls were identified

during direct observations on March 10, 1998, and from subsequent

followup, of established practices for engineer / maintenance

workers conducting vibration analysis measurements on the U1

Condensate Pump cquipment located in the posted high radiation

area on the 112' elevation of the Turbine Building. The concerns

involved the adequacy of radiological surveys and implementation

of 3rocedural controls based on discussions with the involved

worcer cognizant HP staff and engineering managers and

verification of applicable RWP and associated )rocedural

requirements. From review and discussion of t1e current and the

three previous U1 Condensate Pump vibration analysis measurements

made on October 7. 1997. January 13, 1998, and February 10. 1998,

the inspectors noted that detailed radiation surveys to identify

the specific radiation levels and the potential hazards to workers

performing the measurements were not conducted. Licensee

representatives stated that general radiation surveys of the work

area conducted on May 15. 1997. December 15. 1997, and

December 31, 1997, within the U1 Condensate Pump ecuipment high

radiation area, were used in lieu of performing adcitional surveys ,

for each of the four vibration analysis measurements conducted

between October 7, 1997 and March 10, 1998. However, the

inspectors noted that these surveys failed to identify the maximum

contact and general area dose rates associated with specific

locations where the vibration analysis measurements were conducted

and the documented dose rates varied significantly. For example,

the March 10. 1998, radiation survey indicated maximum contact and

general area dose rates of 300 and 260 millirem per hour

(mrem /hr), respectively: whereas, the May 15, 1997, survey

documented a maximum general area dose rate of 700 mrem /hr but no

contact values. The inspectors identified the failure to conduct

adecuate radiation surveys in accordance with 10 CFR 20.1501 for

concen. sate pump vibration analysis tests as violation (VIO)

50-321/98-01-06. Failure to Conduct Adequate Surveys to Evaluate

the Radiation Levels and Potential Hazards to Workers Conducting

U1 Condensate Pump Vibration Analysis Measurements. j

i

In addition. procedural adherence concerns were identified for the  ;

, March 10, 1998, entry into the high radiation area. The

inspectors noted that procedure 60AC-HPX-004-0S. Radiation and

i

Contamination Control. Rev. 15. required, in part, plant personnel

to comply with all radiation protection postings, rules,

regulations and 3rocedures: to notify Health Physics (HP) prior to

the start of worc authorized in any RWP: and to read and to comply

.

Enclosure 2 l

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with the requirements of the RWP whenever their duties require

l such authorization. For jobs within a high radiation area. HP is

!

D

required to perform pre-job surveys or enter the area with the

workcrew to perform surveys while the job is worked to document

the survey-data. and to adjust RWP requirements. if necessary.

Radiation Work Permit.98-0003. Rev. 0.-starting January 1. 1998.

required. in part, workers to notify HP of work scope prior to the

l

'

start of the job and HP personnel to determine or verify radiation

conditions for each specific work location. The inspectors noted ~

-that the worker failed to notify HP personnel of the work scope

prior to the start of the job nor were surveys conducted

,

immediately preceding, or during conduct of-the testing in the

area. The inspectors identified the failure to follow procedures

in accordance with TS 5.4.1 as VIO 50-321. 366/98-01-04 Failure

to Follow Procedures for Entry into a High Radiation Area.

General facility housekeeping and cleanliness concerns were also

noted during the week of March 9. 1997. Numerous examples of used

protective clothes, including cloth and paper coveralls. cloth

liners and rubber gloves discarded outside of established

collection receptacles and examples of potentially contaminated

PCs overflowing collection receptacles were observed. Numerous

examples of discarded paper trash were noted throughout the

facility. Also.- abandoned tools identified as having fixed

contamination and several instances of tools and equipment

'

extending across established contamination boundaries were

observed.

c. Conclusions

Excluding the U1 Condensate Pump Turbine Building 112' elevation

high radiation area. radiological controls for normal operations

and for radwaste and radioactive material storage areas were

implemented )roperly and maintained in accordance with procedural.

TS and 10 CFR Part 20 requirements.

A violation of 10 CFR 20.1501 requirements was identified for

failure to conduct adequate surveys to evaluate the extent of

radiation levels and potential hazards to workers conducting

condensate pump vibration analysis measurements within a high

radiation area.

A violation was identified for failure to follow procedures in

accordance with TS 5.4.1 for entry into a High Radiation Area.

l- A negative observation of numerous examples of poor facility

housekeeping and cleanliness, and poor contamination control

practices was identified.

l

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R2.1 Status of RP&C Engineered Safety Feature (ESF) Ventilation Systems

(84750)

a. Insoection Scoce

Operability of the Main Control Room Environmental Control (MCREC)

Engineered Safety Feature (ESF) ventilation system was reviewed.

The review included system walk-downs. verification and analysis

of results from selected surveillances, and evaluation of

resultant data for the previous two refueling cycles.

Results of this review were compared against recuirements

specified in TS Section 3.7.4 and TS Program anc Manual.

Section 5.5. Ventilation Filter Testing Program.

b. Observations and Findinas

All MCREC ESF ventilation system surveillances were conducted at

the required frequencies and the results met established

acceatance criteria. However, the inspectors questioned whether

the MCREC chiller units would meet the established acceptance

criteria during periods of elevated service water temperatures.

For the most recent chiller capacity tests, conducted in November

1996 when service inlet water temperature was relatively low,

approximately 60 degrees Fahrenheit. the documented cooling

capacities for two of the three chiller units were only slightly l

above the control room cooling load acceptance criteria of 311.011

'

British Thermal Units. Licensee representatives stated that

modifications made to the chiller piping after completion of the

November 1996 surveillance test were expected to improve the

cocling capacity results. Licensee representatives stated that

'

the next MCREC cooling capacity test was scheduled for

approximately May-June 1998.

Concerns were also noted for the material condition of the MCREC

ductwork and ventilation equipment. Specifically, the inspectors

noted insulation missing from sections of the ventilation

ductwork. Licensee representatives acknowledged the degraded

condition of the insulation but noted that a decision was made to

delay repairing the insulation until completion of a potential

modification to the system. However, no dates had been scheduled

for actual modification work on the system nor dates when the

insulation would be repaired if the modification was not

implemented.

As a result of questions regarding the MCREC chiller capacity test

results and ductwork insulation, the inspectors opened Inspector

Followup Item (IFI) 50-321, 366/98-01-07 Review of May-June 1998

Main Control Room Ventilation Cooling Capacity Test Results and

Evaluate Material Condition of System Components.

f

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c. Conclusions

l

l Main control room environmental control (MCREC) Engineered Safety

( Feature (ESF) subsystem surveillance tests were conducted in

accordance with TS requirements and results met established

acceptance criteria to establish operability.

'

Results for the

l MCREC chiller cooling tests showed marginal cooling capacity.

l

l A negative observation of the material condition of the

l ventilation ductwork insulation was identified.

1

R4 Staff Knowledge and Performance

,-

'

R4.1 Failure to Analyze Unit 1 Drywell (DW) Containment Atmosohere Grab

Samole

!

a. Insoection Scone (71750) (92904)

The inspectors reviewed procedure 64CI-0CB-005-0S " Fission i

Product Monitors." Rev. 2. ED 1. TS 4.4.5, RCS Leakage Detection i

Instrumentation. and chemistry personnel performance for DW

containment sampling activities.

b. Observations and Findinas

, On February 8, 1998, operations personnel declared both the

! gaseous and the particulate channels of Unit 1 Fission Product

Monitor (FPM) system inoperable to implement corrective

j maintenance. With both channels inoperable. TS 4.4.5 requires

that personnel analyze grab samples of primary containment

atmosphere once per every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Grab samples of the primary

containment atmosphere must be taken and analyzed to provide

periodic leakage information. Procedure 64CI-0CB-005-05.

Subsection 7.20. Inoperable Monitoring System (s), provided the

required actions to complete the sampling and analysis for

particulate, iodine, and noble gas. - Chemistry personnel were

responsible for implementing the requirements of the surveillance

procedure.

0)erations personnel had declared the FPM system inoperable at

a)out 1:25 a.m. The grab sample was taken at about 8:00 a.m..

however, the sam)le was not analyzed within the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

A subsequent gra) sample and analysis, completed at about 6:30

p.m.. did not indicate any leakage and met the procedure

acceptance criteria. The technician obtained the first grab sample

but analyzed for oxygen concentration only. This did not meet the

requirements of the surveillance 3rocedure. A TS violation did

not occur due to a subsequent gra) sample being analyzed within

the required time.

Enclosure 2

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l

The inspectors identified other factors that are associated with

l

the failure to follow a surveillance test procedure. For example,

o)erations personnel generally inform the chemistry department

w1en surveillance procedures or TS-required actions are to be

completed. -However, operations personnel do not routinely discuss

,

or review chemistry surveillance procedure results.

Additionally operations approval for the beginning or completion

of chemistry surveillance test procedures was not required. In

this case, chemistry personnel reported the oxygen concentration

of the grab sample to the control room. However, control room ,

t o)erations personnel did not ask for or cuestion the results of

t1e analysis for particulate. iodine, anc noble gas, which were

required by the procedure and TS. The chemistry procedure did not )

provide specific guidance for chemistry personnel to inform '

operations of the grab sample results.

Procedure 64CI-0CB-005-05. Subsection 7.20. required the chemistry

technician to complete the grab sam)le, document the results on

y procedure attachments and present t1e attachments. to the

l chemistry foreman for review and approval. In this case the

technician did not. complete the attachments because an oxygen

concentration was the only analysis obtained. The Health Physics

(HP)/ Chemistry foreman on duty did not question why the technician

did not.present the attachments for review and ap)roval. HP

supervision informed the inspectors that the HP/Clemistry foreman

on duty during the shift had expertise in HP activities and relied

i- upon the knowledge and abilities of the chemistry technicians to

correctly perform their required duties.

c. Conclusions l

Failure to completely analyze the grab sample as required by I

procedure 64CI-0CB-005-0S subsection 7.20 is identified as VIO

50-321.-366/98-01-09. Failure to Analyze Grab Samples. The

inspectors-concluded that poor supervisory oversight of chemistry

activities and chemistry department interface with operations-

personnel contributed to a failure to follow procedure.

R4 2 Fuel Oil Samolina Technioues

i a. Insoection Scooe (71750)

The inspectors reviewed procedure 64CH-SAM-002-0S. " Diesel Fuel

Oil. Sampling and Analysis." Rev. 5. and observed chemistry

personnel obtain samples of the Security Diesel fuel oil.

Enclosure 2

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b. Observations and Findinas

The inspectors observed that chemistry technicians had the

,

procedure and all equipment recommended by the procedure in their

. possession. The equipment used and the sampling techniques

'

observed met the requirements of the procedure.

c. Conclusions

The inspectors concluded that chemistry technicians used proper

equipment and sampling techniques while obtaining fuel oil

samples.

R8 Miscellaneous RP&C Issues (83750, 84750)

'

R8.1 (Closed) VIO 50-321. 366/97-10-05: Failure to Meet 10 CFR 20.1904

Labelina Reauirements for Containers of Radioactive Materials

Temocrarily Stored in the Unit 1 Torus Pool .

The inspectors reviewed and verified that training guidance was

modified to better define and provide examples of the term

" container" as used within the context of 10 CFR 20.1904. Based

on revisions to training modules. review of this issue during

completion of continuing training by the "in-house" technicians,

and provisions to provide the enhanced guidance to contractor HP

technicians, this item is closed.

R8.2 (Closed) VIO 50-321. 366/97-11-06: Failure to Follow Procedures

for Radiation and Contamination Control and Personnel

Decontamination Activities.

The inspectors reviewed and discussed the identified root causes

l' and verified corrective actions documented in Significant

L Occurrence Report Number (No.) C09705936. dated January 5. 1998.

Corrective actions were incor) orated into lesson plan details

'

l provided to "in-house" HP tec1nicians during continuing training

and contractor HP technicians. Training was completed for the

in-house" staff by the end of the inspection period. Based on

licensee actions. this item is closed.

L

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R8.3 (Closed) VIO: 50-321. 366/97-11-07: Failure to Foll.ow Procedures

for RWP Imolementation

Licensee initial corrective actions included continuation of

numerous quality checks during the outage and notification to

appropriate departments to address access control issues. Also,

for subsequent refueling outages, several outage RWPs were

initiated before contractors began in-processing. In addition,

the licensee reinstalled access control printers and required

Enclosure 2

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L check-in at HP control points to detect improper RWP usage. Based

l on licensee action, this item is closed.

P8 Miscellaneous Emergency Preparedness Issues (92904)

l P8.1 (Closed) Insoector Followuo Item (IFI) 50-321. 366/96-10-07. Lack

I

of Guidance for Inocerable Instrumentation Used for Offsite Dose

Calculations.

The inspectors reviewed the licensee's actions to perform timely

offsite dose calculations in the event that radiological-

l instrumentation was not functional. Section 7 2 of

! 73EP-ElP-015-05. Offsite Dose Assessment. Rev. 4. and Sections 7.3

and 7.4 of 73EP-EIP-018-0S. Prompt Offsite Dose Assessment. Rev.5,

were revised to include guidance in performing offsite assessments

,

in the event that normal range effluent radiation monitors are

l offscale and accident range monitors are unavailable.

Based upon the inspectors' review of the licensee's actions in

response to this item, it is closed.

l

l S2 Status of Security Facilities and Equipment (71750)

!

The inspectors. toured the protected area and observed that the

l perimeter fence was intact and not compromised by erosion or

!- disrepair. The fence fabric was secured and barbed wire was

angled as required by the licensee's Plant Security Program (PSP).

l Isolation zones were maintained on both sides of the barrier and

were free of objects which could shield or conceal an individual'.

l The inspectors observed that personnel and packages entering the

protected area were searched either by special purpose detectors

'

or by a physical patdown for firearms, explosives, and contraband.

Badge issuance was observed, as was the processing and escorting

of visitors. Vehicles were searched, escorted, and secured as-

l

described in applicable procedures.

The inspectors concluded that the areas of security inspected met

the applicable requirewnts.

F1 Control of Fire Protection Activities

F1.1 Desian Basis of Fire Barrier Penetration Seals

! a. Insoection Scooe (64704)

The inspectors reviewed the fire barrier penetration seal designs

and testing for compliance with the facility's licensing

requirements identified in the Updated Final Safety Analysis ,

Report-(UFSAR) Section 9.5.1 " Fire Protection Systems." and i

Enclosure 2

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Sections 9.4 and 9.9 of the Hatch Fire Hazards Analysis, and Fire

Protection Program.

The inspectors compared selected as-built fire barrier 3enetration

seals to fire 2ndurance test configurations to verify tlat those

seals were qualified by appropriate fire endurance tests and

representative of the design and construction of the fire

endurance test specimens-. During plant walkdowns, the inspectors

observed the installation configurations of selected accessible

fire barrier penetration seals to confirm that the licensee had

established an acceptable design basis for those fire barriers

used to separate safe shutdown functions for a fire event,

b. Observations and Findinas

Laboratory testing of fire barrier materials is done only on a

limited range of test assemblies. In-plant installations can vary

from the tested configurations. Under the provisions of Generic

Letter (GL) 86-10. " Implementation of Fire Protection

Requirements." licensees were permitted to develop engineering

evaluations justifying such deviations.

The inspectors reviewed the fire barrier penetration seal design

records. Hatch Nuclear Plant Management Information System

computer database design records, cuality assurance and quality i

control (0A/0C) installation recorcs penetration seal typical l

detail drawings and testing records.

For the review, the inspectors used UFSAR Section 9.5.1. " Fire

,

Protection Systems *" the Hatch " Fire Hazards Analysis and Fire

l' Protection Program." Rev. 12B, Section 3.4. " Establishment of Fire

I

Area / Zones." Section 4.3 " Fire Barriers." Section 9.4.

" Appendix A Compliance Matrix." and Section 9.9. " Fire Barrier

Penetration Report:" Hatch Fire Protection Procedure No.

42FP-FPX-014-0S. " Installation and Repair of Silicone Foam Seals."

Rev. 1: Hatch Fire Protection Procedure No. 42FP-FPX-003-05.

" Installation of Nelson Electric Fire Stops." Rev. 3: Hatch

nuclear safety reviews concerning NRC Information Notices

(ins) 88-04. IN 88-56. and IN 94-28: selected penetration seal as-

built location drawings. B-19631 series: selected Fire Rated

Penetration Seal Qualification Data. S-52429. Brand Industrial

Services Company (BISCO) silicone foam products. S-52480/52483.

Chemtrol Corporation silicone foam products, and S-52439/52482.

Nelson Electric Firestop Products: and recognized industry fire 1

penetration seal testing guidance of American Society for Testing

and Material (ASTM) Standard E814-1988. " Standard Test Method for

Fire Tests of Through-Penetration Fire Stops." and Institute of

Electrical and Electronics Engineers (IEEE) Standard 634-1978.

"IEEE Standard Cable Penetration Fire Stop Qualification Test."

Enclosure 2

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25

Using the UFSAR Fire Hazards Analysis (FHA) and the composite fire

wall delineation drawings H-15907 through H-15911 to determine the

location and description of the plant fire areas, the inspectors

conducted walkdowns and inspected penetration seal installations.

The inspectors' review focused on verifying that the following

design and installation Jarameters for the as-built configurations

were adequately bounded ]y tests or ju.stified by licensee's

engineering evaluations:

e penetration type and opening size:

e seal material type and depth:

e damming material type and orientation:

e types and thermal mass of penetrating items;

e clearances of penetrating items; and

e fire test results for unexposed surface temperatures

The following penetration seals were visually inspected and the

OA/0C engineering and construction penetration procedure data

package records for these seals were reviewed to determine that

the as-built plant seal configurations were representative of

those utilized in fire seal qualification tests:

_

PENETRAT1001 SEAL SUtst4ARY SEAL DAMGENG

GAATEIRAL BAATENAL

EMNTRCATIOtil LOCATIOtt i SIZE DESIGN DEPTH I TYPE 1YPE / ORIENTATION FIRE TEST REPORTS /

NuttBEll DNCHES) DETAAL QUALIFICATIOtt

COVERED UNIT 2 CONTROL CT 7 11" - CT 18 CT-23 CHEMTROL S 52483

ELECTRICAL CABLE BUILDING / FLOOR CHEMTROL DAMMING ~ BOTTOM CTP 0303

TRAY BETWEEN FIRE SILICONE FOAM SIDE 3 HOURS

PENETRATION ZONES 0024A AND

2243H014F 2104 / 72 X36

OPEN ELECTRICAL UNIT 2 CONTROL CT-7 11* CT 18 CT 23 CHEMTROL S-52480

CABLE TRAY AND BUILDING / FLOOR CHEMTROL DAMMING -BOTTOM FC-225

CONDUIT BETWEEN FIRE SILICONE FOAM SIDE 3 HOURS

PENETRATION ZONES 0024A AND

2243H016F 2104 / 42 X18

COVERED UNIT 2 CONTROL CT 7 11" - CT 18 CT-23 CHEMTROL S 52483

ELECTRICAL CABLE BUILDING / FLOOR CHEMTROL D AMMING -BOTTOM CTP 0303

TRAY AND BETWEEN FIRE SILICONE FOAM SIDE 3 HOURS

CONDUIT ZONES 0024A AND

PENETRATION 0040 179 X68

2Z43H033F

ELECTRICAL UNIT 2 CONTROL P-7 12". SF 20 NONE TEST REPORT

CONDUli INTERNAL BUILDING / FLOOR BISCO

l

NOT AVAILABLE i

PENETRATION BETWEEN FIRE SILICONE FOAM j

2243H091F ZONES 0028 AND i

2023 / 4

MECHANICAL PIPE UNIT 2 CONTROL XP-3 NOT AVAILABLE NOT AVAILABLE FIRE BARRIER

PENETRATION BUILDING / WALL PENETRATION REPORT

WITH TWO PIPE BETWEEN FIRE EVALUATION 0-13

PENETRANTS ZONES 0001 AND

2243H111C 2003 / 8

Enclosure 2

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26

PenETnAima BEAL BuMMAny BEAT -

MATE 8EAL IBATEfuAL

WBNTW4CA110Ie/ LOCA1MMI / SIZE - DEFFH I TYPE TYPE / OIENTAftoel FWE TEST REPORTS /

IRNM WIC0ESI DETAE. nuas agCAygong

MECHAMCAL PIPE UNIT 2 CONTROL P7 12"- SF.20 NONE TEST REPORT

PENETRAYlON BUILDING / WALL B!SCO SILICONE NOT AVAILABLE

2243rt092D BETWEEN FIRE FOAM

ZONES 2023 AND

0014L / 4

ELECTRICAL UNIT 1 CONTROL E7 11* CT-1B CT 23 CHEMTROL S-62480

CONDUIT BUILDING FLOOR / CHEMTROL DAMMING -BOTTOM FC-225

PENETRATION BETWEEN FIRE SILICONE FOAM SIDE 3 HOURS

1243 HOB 3J ZONES 0024A AND

00240 /87 X 2 6

SPARE BLOCKOUT UNIT 2 CONTROL XSP-1 NOT AVAILABLE NOT AVAILABLE FIRE BARRIER

PENETRATION BUILDING / WALL PENETRATION REPORT

2243H073C BETWEEN FIRE EVALUATION 1-13

ZONES 2003 AND

2101 A /28 X 24

MECHANICAL FIRE UNIT 2 CONTROL XH-7 NOT AVAILABLE NOT AVAILABLE FIRE BARRIER

DAMPER BUILDING / WALL PENETRATION REPORT

PENETRATION SETWCEN FIRE EVALUATION l-15

2243HO92C ZONES 2003 AND

2101A /18 X 18

1

ELECTRICAL UNIT 2 CONTROL E3 0.5". NELSON 2.0"- NELSON S-62439

CONDuli BUILDihiG / WALL ELECTRIC ELECTRIC RSW SWR-86-2-10

PENETRATION BETWEEN FIRE FIRESTOP CAULK FIRESTOP DAMMING 3 HOURS

I 2243H0103F ZONES 0028 AND

>

2023 1 4

!

! MECHANICAL PIPE UNIT 1 CONTROL P-7 9"- SF-20 NONE TEST REPOflT

[ PENETRATION BUILDING / WALL BISCO SILICONE NOT AVAILABLE

1

,

1243H029C BETWEEN FIRE FOAM

'

ZONES 0001 AND

1004iB l

!

l- MECHANICAL PIPE DIESEL GENERATOR P-7 12*- 3F-20 NONE TEST REPORT

I PENETRATION BUILDING / WALL BISCO SILICONE NOT AVAILABLE

! 1Y43H077D BETWEEN FIRE FOAM

ZONES 1409 AND

1411 /8

MECHANICAL PIPE REACTOR AUXILIARY P5 0.6". NELSON NONE S-52482

PENETRATION BUILDING / WALL ELECTRIC ULC SP 68-

1T43H623J BETWEEN FIRE FIRESTOP 3 HOURS

2ONES 1203K AND SPEEDPLUG

1205 / 20 PILLOWS

The inspectors' visual inspections did not identify any missing seals

and verified that the installed fire barrier penetration seals were

continuous with no gaas, cracks, or holes in the barrier material that

would indicate that tie seals were inoperable. The installation and

repair procedures for penetration seals provided adequate guidance to

ensure materials were installed per design requirements. The fire

barrier penetration report evaluations conducted for penetration seals

that were inaccessible for visual inspections were adequate.

1

l

Enclosure 2 i

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27

The inspectors conducted a review of the Brand Industrial Services

Company and Chemtrol Company silicone foam mechanical prototype design

detail P-7 and electrical prototype design detail CT-7. The inspectors

found that penetration seal as-built field verification documentation

was maintained by the licensee. However, the vendor penetration seal

l

qualification test report documentation and the vendor data for the

tested prototype silicone foam configurations for the Brand Industrial

Services Company silicone foam prototype fire barrier configurations

were not readily available for review. Also, the as-built documentation

did not identify important design parameters with respect to cable tray

fill the maximum or minimum clearances of penetrating items and their

thermal mass and the maximum free area of unsupported penetration seal

material installed within the silicone foam penetration. Because the

test report documents were not available for all silicone foam

penetration seal configurations. the licensee had not compared the

design and installation details with tested configurations nor performed

GL 86-10 engineering evaluations to determine the adequacy of any

deviations from tested fire barrier configurations. This did not

satisfy the guidance of GL 86-10 and was considered to be a program

weakness.

Licensee personnel stated that industry and vendor qualification test

report documentation was available to support these silicone foam

penetration seal installations at Hatch and was being procured under

requisition No. HPBH-980695. The licensee initiated Request for

Engineering Assistance (REA) No. HT-98617 to expand the as-built

penetration seal database to incorporate a higher level of detail

concerning penetration seal design parameters and to document

a)propriate engineering evaluations. Licensee Jersonnel stated that

t1is work was scheduled for completion by Decem)er 1998. The silicone

foam penetration seal qualification testing documentation, penetration

seal design parameters, and evaluations of deviations from tested fire

barrier configurations will be reviewed during a subsequent NRC

inspection. This item is identified as Inspector Follow-up Item (IFI)

50-321, 366/98-01-05. Review of Licensee Records and Engineering

Evaluations to Establish the Fire Resistant Capabilities of Fire Rated

Silicone Foam Penetration Seals.

c. Conclusions

The inspectors concluded that the installation and repair procedures for

penetration seals provided adequate guidance to ensure that materials

were installed per design requirements. The fire barrier penetration

report evaluations conducted for penetration seals that were

inaccessible for visual inspections were adequate. However, the Brand

Industrial Services Com)any silicone foam penetration seal designs were

l

not supported by availa)le vendor qualification test reports.

Engineering evaluations to satisfy the guidance of GL 86-10 for

deviations from the silicone foam fire barrier seal configurations

Enclosure 2

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qualified by tests had not been performed and was considered to be a i

program weaknesses.

I

F2 ' Status of Fire Protection Facilities and Equipment "

F2.1 Surveillance of Fire Protection Features and Equipment

a. Insoection Scooe (64704)

The inspectors reviewed procedures 42SV-FPX-019-1S/25. " Penetration Seal

Surveillance." Revision 2. and the penetration seal surveillance results

records for the surveillance procedures which were completed April 15.

1997. These were reviewed for compliance with the requirements of FSAR

Section 9.5.1 and Fire Hazards Analysis, Ap)endix B. Section 2.1.1.c.

.

" Fire Equipment Operating and Surveillance Requirements."

b. Observations and Findinas I

Surveillance procedures 42SV-FPX-019-1S/2S required a visual inspection

i

each 18 months of a random sample of ten percent of each type of fire

barrier penetration seal. The sample inspections were required to

' include fire barrier seals that had not been inspected within the past

15 years. Each seal was inspected for any apparent change in

l

'

appearance, noticeable damage, signs of abnormal degradation, and

pulling away from wall or penetrating item.. If any abnormality was

found, an additional ten percent of seals was required to be inspected.

,

'

.The inspection and selection process was to continue until an acceptable

sample was found.

The inspectors reviewed Procedure 42SV-FPX-019-1S/2S and concluded that

the procedure met the frequency requirements of Fire Hazards Analysis,

Appendix B. Section 2.1.1.c. " Fire Equipment Operating and Surveillance

Requirements," and met the commitments made to the NRC.

The results of penetration seal surveillance inspections completed

April 15,1997, were reviewed by the inspectors. No discrepancies were

noted.

c. Conclusion

The surveillance inspection procedures for the fire barrier penetration

seals were adequate and the 18-month surveillance requirements were

established appropriately to verify operability. The April 1997

penetration . seal inspections had been satisfactorily implemented.

Enclosure 2

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F4 Fire-Protection Staff Knowledge and Performance

F4.1 Unannounced Fire Drill and Triennial Audit

a. Insoection Scoce (71750)

In March the inspectors reviewed procedure 42FP-FPX-005-05. " Drill

Planning. Critiques and Drill Documentation " Rev.1. drill objectives,

and audit observations. They also observed fire brigade performance

during an unannounced fire drill.

b. Insoection Findinas

On March 3. the ins)ectors observed an unannounced fire drill for a

simulated fire in t1e Unit 1 reactor building. The inspectors observed

that the procedure requirements for the drill planning and critique were

completed satisfactorily. Drill objectives were clearly defined prior

to the drill. All drill objectives except one were met. That drill

objective was for all fire brigade members responding to the fire to be

fully qualified. Two persons that responded were not fully qualified,

i however neither of the individuals was part of the required five-person

fire brigade.' The inspectors observed that seven licensee evaluators

'

observed and evaluated the fire brigade performance. Some of the

'

evaluators, who performed the triennial audit function, were from

another site and outside of the Hatch organization.

The inspectors also observed that the fire brigade leader set up a

command post, used pre-fire plans, and demonstrated good leadership

abilities during the drill. The overall performance and effectiveness

of the fire brigade was satisfactory.

L c. Conclusions

! The ins)ectors concluded that the fire brigade leader demonstrated good

i leaders 11p abilities during the unannounced fire drill conducted on

!

March 3. The overall performance and effectiveness of the fire brigade

was satisfactory.

F5 Fire Protection Staff Training and Qualification

l

l F5.1 Fire Barrier Penetration Seal Installers and OC Inspectors

a. Insoection Scooe (64704)

The inspectors reviewed training records for three contractor employees

designated to install and repair fire barrier penetration seals and the

'

. OC inspectors designated to inspect the penetration seals for compliance

with the requirements of UFSAR Section 9.5.1.

Enclosure 2

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

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30

b. Observations and Findinas

The inspectors reviewed training records for the contractor employees

and the OC inspectors designated on three maintenance work orders

-(MW0s), MWO-1-94-5079, MWO-1-95-4304 and MWO-0-6901. The contractor

employees had received initial classroom training and practical

application in the installation of the types of fire barrier penetration

seals used at the Hatch facility. This training was conducted by the

vendor who supplied the . seal material for the various fire barrier

penetration seals installed at the facility. The inspectors verified l

that the contractor and OC employees had received appropriate outage

retraining and recertification to maintain up-to-date knowledge and

installation techniques for these seals prior to performance of field l

work,

c. Conclusion

The fire barrier penetration seal installers were appropriately trained l

to accomplish fire barrier penetration seal installation work and the OC i

inspectors were qualified to perform the a)propriate verification for l

installation and repairs made to the fire Jarrier per 2 ration seals. i

i

'

.F8 Miscellaneous Fire Protection Issues (92904)

F8.1 (Closed) IFI 50-366/97-02-06. Review of Qualifications and Trainina for

Fire Watch Personnel. '

The licensee reviewed its GET training material for revision to ensure

that fire watch issues (types and expectations) would be more clearly

communicated to all of its em)loyees. The inspectors reviewed the

revised General Employee Hand)ook and noted that it included a section <

on Fire Watch Duty, which addressed the issues. Based upon the

inspectors' review, this item is closed.

V. Manaoement Meetinas

X.2 Review of UFSAR Commitments

A recent discovery of a licensee 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 descri) tion.

While performing the inspections discussed in this report tie

inspectors reviewed the applicable portions of the UFSAR that related to

, the areas inspected. The inspectors verified that the UFSAR wording was

consistent with the observed plant practices, procedures, and/or

parameters.

Enclosure 2

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

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31

X.3: Exit Meeting Summary

The inspectors presented the inspection results to members of the

licensee management at the conclusion of the inspection on March 27,

1998. The license acknowledged the findings presented. Interim exits

were conducted on February 27 and March 13, 1998.

The inspectors asked the licensee whether any materials examined during

the inspection should be considered proprietary. No proprietary

information was identified.

PARTIAL LIST OF PERSONS CONTACTED

Licensee

Anderson J. , Unit Superintendent

Betsill. J., Assistant General Manager - Operations

Breitenbach. C. . Engineering Support Manager - Acting i

Curtis S. Unit Superintendent

Davis. D., Plant Administration Manager

Ellgass. L., Maintenance Rule Coordinator

Fornel P., Performance Team Manager

Fraser. 0.. Safety Audit and Engineering Review Supervisor.

Hammonds, J. , Operations Support Superintendent

Kirkley. W., Health Physics and Chemistry Manager

Lewis, J., Training and Emergency Preparedness Manager

Madison. D., Operations Manager

Moore C.. Assistant General Manager - Plant Support

Reddick. R., Site Emergency Preparedness Coordinator

Roberts. P., Outages and Planning Manager

,

Thompson. J. , Nuclear Security Manager

Tipps. S. Nuclear Safety and Compliance Manager

Wells. P., General Manager - Nuclear Plant

INSPECTION PROCEDURES USED

IP 37551: Onsite Engineering

IP 61726: Surveillance Observations

IP 62002: Inspection of Structures, Passive Components. and

Civil' Engineering Features at Nuclear Power Plants

IP 62706: Maintenance Rule

IP 62707: Maintenance Observations

IP 64704: . Fire Protection Program

IP 71707: Plant Operations

IP 71750: Plant Support Activities

IP 83750: Occupational Radiation Exposure

IP 84750: Radioactive Waste Treatment, and Effluent and

Environmental Monitoring

IP 92700: Onsite Followup of Written Reports of Non-routine i

Events at Power Reactor Facilities l

Enclosure 2

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IP 92901: Followup - Operations

IP 92902: Followup - Maintenance / Surveillance

IP 92903: Followup - Engineering

IP 92904: Followup - Plant Support

ITEMS OPENED. CLOSED, AND DISCUSSED

Ooened

50-321, 366/98-01-01 IFI Review of Maintenance Rule Periodic

Assessment Procedure (Section M1.3)

50-366/98-01-02 VIO Failure to Follow Maintenance

Procedures (Section M4.1).

50-366/98-01-03 VIO Failure to Follow Engineering Test

Procedures (Section E3.1).

50-321/98-01-04 VIO Failure to Follow Procedure for

Entry into a High Radiation Area

(Section R1.2).

50-321, 366/98-01-05 IFI Review of Licensee Records and

Engineering Evaluations to Establish

the Fire Resistant Capabilities of

Fire Rated Silicone Foam Penetration

Seals. (Section F1.1).

50-321/98-01-06 VIO Failure to Conduct Adequate Surveys

to Evaluate the Radiation Levels and

Potential Hazards for Workers

Conducting Unit 1 Condensate Pump

Vibration Analysis Measurements

(Section R1.2).

50-321, 366/98-01-07 IFI Review of May-June 1998 Main Control

Room Vent 11ation Cooling Capacity

Test Re ults and Evaluate Material

Condit wn of System Components i

(Section R2.1)

50-321, 366/98-01-08 EEI Plant 0)eration Outside of the

Design 3 asis for an Engineered

Safeguard System (Section E2.1).

50-321/98-01-09 VIO Failure to Follow Procedure for

Analysis of a Grab Sample (Section

R4.1).

Enclosure 2

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32

IP 92901: Followup - Operations

IP 92902: Followup - Maintenance / Surveillance

IP 92903: Followup - Engineering

IP 92904: Followup - Plant Support

ITEMS OPENED. CLOSED. AND DISCUSSED

Ooened

50-321, 366/98-01-01 IFI Maintenance Rule Periodic Assessment

l (Section M1.3)

50-366/98-01 02 VIO failure to Follow Maintenance '

Procedures (Section M4.1).

50-366/98-01-03 VIO Failure to Follow Engineering Test

Procedures (Section E3.1).

! 50-321/98-01-04 VIO Failure to Follow Procedure for

Entry into a High Radiation Area j

,

(Section R1.2).

l

50-321. 366/98-01-05 IFI Review of Licensee Records and

Engineering Evaluations to Establish

the Fire Resistant Capabilities of

l Fire Rated Silicone Foam Penetration

! Seals. (Section F1.1).

l

50-321/98-01-06 VIO Failure to Conduct Adequate Surveys

l to Evaluate the Radiation Levels and

l Potential Hazards for Workers 1

l Conducting Unit 1 Condensate Pump

Vibration Analysis Measurements

(Section R1.2).

l

I

50-321. 366/98-01-07 IFI Review of May-June 1998 Main Control

l

'

Room Ventilation Cooling Capacity

Test Results and Evaluate Material

Condition of System Components

l (Section R2.1)

i

i

'

50-321. 366/98-01-08 EEI Plant 0)eration Outside of the

Design Basis for an Engineered

Safeguard System (Section E2.1). 1

50-321. 366/98-01-09 VIO Failure to Follow Procedure for

Analysis of a Grab Sample (Section 1

R4.1).

l

Enclosure 2 1

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i

Closed

i

50-321, 366/97 O'6-01 VIO Failure to P'revent Recurrence of

L Improper Equipment Storage in

Control Room (Section 08.1).

50-366/97-02 LER Grounded Jumper Causes Blown Fuse

and ESF actuation (Section 08.2)

50-321, 366/96-12-01 VIO Failure to Include All Structures.

'

Systems, and Components in the Scope

of the Maintenance Rule as Required

by 10 CFR 50.65 (Section M8.t).

50-321, 366/96-12-02 VIO Failure to Establish Adequate

, Performance Criteria for S.C. Risk-

l-

'

Significant Functions (Section

M8.2).

,

50-321, 366/96-12-04 IFI Failure to Provide Adequate

Procedcre for Implementation of

'

Maintenance Rule Requirements

(Section M8.3). i

! 50-321. 366/96-12-05 IFI Followup on Licensee Actions to

Provide Performance Criteria for

Structures After Industry Resolution

of this Issue (Section M8.4).

50-321/98-01 LER Inoperable MCREC System Filter

Trains Result in Entry Into LCO

l 3.0.3 (Section E8.1). 4

l ]

, 50-321. 366/96-10-07 IFI Lack of Guidance for Inoperable

l

Instrumentation Used for Offsite

i Dose Calculations (Section P8.1).

50-366/97-02-06 IFI Review of Qualifications and

Training for Fire Watch Personnel

(Section F8.1).

50-321, 366/97-10-05 VIO Failure to Meet 10 CFR 20.1904

, Labeling Requirements for Containers

i of Radioactive Materials Temporarily

Stored in the Unit 1 Torus Pool

(Section R8.1).

i

Enclosure 2 l

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50-321, 366/97-11-06 VIO Failure to Follow Procedures for

Radiation and Contamination Control

and Personnel Decontamination

, Activities (Section R8.2).

!

l 50-321, 366/97-11-07 VIO Failure to Follow Procedures for RWP

l

Implementation (Section R8.3).

l

!

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[

Enclosure 2

.