IR 05000321/1997011: Difference between revisions

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{{Adams
{{Adams
| number = ML20217D233
| number = ML20199F541
| issue date = 03/17/1998
| issue date = 01/23/1998
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-321/97-11 & 50-366/97-11 on 980123
| title = Insp Repts 50-321/97-11 & 50-366/97-11 on 971116-1227. Violations Noted.Major Areas Inspected:Operations, Engineering,Maint & Plant Support
| author name = Skinner P
| author name =  
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name = Sumner H
| addressee name =  
| addressee affiliation = GEORGIA POWER CO., SOUTHERN NUCLEAR OPERATING CO.
| addressee affiliation =  
| docket = 05000321, 05000366
| docket = 05000321, 05000366
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-321-97-11, 50-366-97-11, NUDOCS 9803270357
| document report number = 50-321-97-11, 50-366-97-11, NUDOCS 9802040036
| title reference date = 02-20-1998
| package number = ML20199F462
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 3
| page count = 52
}}
}}


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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 l
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 3882188n 3 8683u    l 0 PDR
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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 inspectio Doerations e 0)erator response to the transient and manuci scram resulting from t1e Unit 2 Condensate Booster pump check vilve problems were goo Performance during the subsequent unit sta' tup was excellent (Section 01.2).
o Maintenance and engineering provided excellent support to operations for the Unit 2 system and component damage assessment and re3 air activities resulting from the Unit 2 condensate booster pump cleck valve problem 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),
e Operations personnel were knowledgeable and generally professional. Interaction with other grou minimize distractions in the control room.psHowever, was controlled to inconsistent three-part communications by the operators was observed (Section 01.3).
e Operator performance during the Unit 1 startup following the 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 identifie 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 identifie 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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o Operator actions were appropriate and timely for the power excursion due to the 2A recirculation pump spurious speed increase on Unit 2. Engineering and maintenance support was good (Sectinn 04.2).
Maintenance e Maintenance activities were generally completed in a thorough and professional manner (Section M1.1).
e 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).
e Poor work practices and a lack of attention to detail by craft 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),
e The licensee's preparation for cold weather was good. The 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 satisfactoril 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 requirement 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 tubin Licensee Event Report 50-321/97-06, was detailed and thorough (Section M8.1).
Enoineerina e  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. 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 thoroug Maintenance and engineering recommendations reflected a good interface with the vendor (Section E2.2).
e  The Maintenance Rule periormance criteria for the EDGs were being 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).
e  Improvements were noted in the radwaste facility housekeeping and 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).
e  Inspector Followup Item (IFI) 50-321. 366/97-11-05 was identifie 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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e    packaging, and Licensee program transporting radwaste guidance for processing,l to a licensed buria site met 10 CFR Parts 20, 61. 71: and 49 CFR Parts 100-179 requirements (Section RI.3).
e Radwaste processing. packaging and transportation activities were implemented effectively (Section Rl.3).
e General Health Physics activities observed during the report 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).
o Hazardous material training for personnel processing, handling, 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
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implemented appropriately (Section R7.1).
< e A lack of attention to detail by responsible personnel for 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).
e Licensee root cause analyses to identify causes of an increasing 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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e 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)
(Section S2,1).
e Protected and vital area access controls met the requirements of the Physical Security Plan (Section S2.1).
e Physical Security Plan changes submitted by the licensee under the 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
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outage. On November 18, unit power was increased to about 20% Rated 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 gri The unit achieved 100% RTP on November 2 The unit o l  report period, perated at this routine except during power level testingforactivitie the remainder of the i
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 2 tied to the grid on November 27 and achieved 100% RTP on November 2 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%
RT The pump speed controller was repaired. The unit operated at 100%
RTP for the remainder of the report period, except during routine testing activities.
l    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 belo .2 Unit 2 Transient and Manual Scram Due to a Condensate Booster Pumo (CBP) Check Valve Failure 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 observeddamage, correctivereviewed the licensees maintenance, assessment and obrerved operator of the performance during unit startup activitie 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'attempt pumps to (RFPs)
restartactuated in the the 2A CBP main control faile 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 designe Operators locally at the 2A CBP reported that the pump was rotating backward 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
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pump suction line just before each booster pump was misaligned by about 2 to 3 inche 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 uni 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 proble Management decided to develop a shutdown plan repair plan, and conduct a controlled unit shutdown to implement repair )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 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 damage 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 scra ;
Corporate engineers were being dispatched to the site the following day to assess the damage and make recommendations for repair Operations began actions to bring the unit to hot shutdow ,
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 problem 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 maintenanc 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 recommendatio )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 2 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 proble .3 Observations of On-Shift Doerations Performance 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 manual 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 procedure Evolution pre-briefings were observed to be performed per procedure with the attendees actively participating. Actions.fo unex)ected situations and plant conditions were discussed as part of t1e pre-briefin Enclosure 2
 
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March 17;'1998
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The inspectors observed that the plant operators were knowledgeable and well-informed of activities in the plan 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.
lSouthernNuclearOperatingCompany.In ATTN: Mr. H.:L. Sumner.:.Jr..
 
L .Vice President. Plant Hatch Nuclear Operations P.O. Box 12951 Birmingham-AL.35201-1295
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   $UBJECT: 'NRC. INSPECTION REPORT NO 50-321/97-11 AND 50-366/97-11
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
! ladders in use not tied off correctly. The housekeeping l observations were discussed with plant managemen 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 concern 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 communication 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 manipulation Operator response to a manual reactor scram was observe The operators were well-prepared and familiar with the required scram Enclosure 2
 
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6 action Procedures were used and overall performance was satisfactor 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 expectation .4 Observations of Unit 1 Startuo Activities Followina Refuelina 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 activitie V-SUV-018-15. "ECCS Status Checks."
 
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Rev. 6. 34G0 0PS-003 15. "Startup System Status Checklist." Re , 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 me 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 observe 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 servic The inspectors reviewed completed system valve lineups and system status checks associated with these evolutions. No deficiencies were observed and TS requirements were met, t    Enclosure 2 w    _
 
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7 Conclusions      ,
The inspectors concluded that operator performance during the Unit 1 startup following the refueling outage was good. Systems
 
arvi components observed operated and responded as expected. TS
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and regulatory requirements were met for the unit startu Operations Proceciures and Documentation 0 Failure to Follow Procedure and inadeouate Procedure Results in Groun 1 isolation Sianal on Unit 1 Due to Low Condenser Vacuum Insoection Scone (717021 roc The inspectors reviewed 34G0-0PS-013-IS  " Normal Plant general operating Shutdown, t )ev,edure 23 and abnormal  .
procedure 34AB C71-001 lS " Scram Procedure " Rev. 7. These    '
arocedures were used on November 18 during the normal shutdown of    '
Jnit 1 for corrective maintenance. Discussions were also conducted with licensee personne 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    i 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 valv This problem is discussed in Section M1.2 of this repor 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-013-1 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 013-1 step 7.6.8. instructed the operator to place the low vacuum bypass switches in the " Bypass" position when reactor pressure is approximately 500 psi 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 breaker Placing the switches in )ypass had been discussed earlier during the pre job briefin 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 revise These
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procedures had not been revised as of the end of this report perio . (cnclusiorn Operator error and procedural inadequacy resulted in the receipt of an Engineered Safety Feature (ESF) Group 1 1 solation signa This violation constitutes a violation of minor safety
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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 Isolatio .0 Operator Knowledge and Performance 04.1 Late 10 CFR 50.72 Report for a Valid Enoineered Safetv Feature Actuation on Unit 1
, 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 repor 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 maintenanc 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 rese Operators initiated a deficiency car 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
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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.
 
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The inspectors determined that the identification of this deficiency was good performanc 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 hour 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 hours late. This is identified as Violation 50 321/97-11 02 Late 10 CFR 50.72 Notification for Unit 1 Engineered Safety Feature Actuatio 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 . This problem is documented in IR 50-321, 366/97-0 Appendix B of 10 CFR 50 requires in part, ccrrective actions to preclude repetition of significant conditions adverse to qualit 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 Actuatio 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 Criterion XVI. Corrective Action. The failure to implement adequate corrective actions was identified as V10 50-321. 366/97-Enclosure 2 l
 
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1103. Inadequate Corrective Actions for Late 10 CFR 50.72 Notification .2 Unit 2 Power Excursion be to Sourious Soeed increase of the 2A Reactor Recirculation ( N) Pumo 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 001-2 " 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 reviewe 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 personne 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 tim 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 even The inspectors verified no TS entry conditions existed through an independent TS revie 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 2-97-334 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 c bias button per instructions provided in MWO 2-97-334 Enclosure 2
 
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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' spee 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 bia 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 knowledg &C personnel had changed the type of lubricant used and believed the problem was correcte Following 1&C troubleshooting and repair activities, the unit was returned to 100% aower and the 2A controller was returned to the automatic mod further problems were observe 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 operation 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 Actuation 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 close Enclosure 2
 
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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 3 Based upon the inspectors' review of licensee actions and the issuance of a NCV. this LER is close .3 (Closed) URI 50-321.366/96 13 02: EOP Deviation From EPG Sten RC/P- ,
This Unresolved item is discussed in IR 50 321, 366/96 1 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 exis Based upon the additional review, this Unresolved item is close .4 (Closed) VIO 50-321. 366/97-02-02: Failure to Follow Procedure -
Multinle Examnle 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 clarit The inspectors observed that the procedures for both units were revised as stated in the licensee's response to the violatio 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 meeting *
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 checklist The fourth example dealt with maintenance work being performed that was outside the scope of the approved maintenance work orde Enclosure 2 l-
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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
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workert inv0lved. The involved worker was coached concerning restrictin9 their work activities to those explicitly described on
,
the MW Bardd upon the inspectors review of licensee actions, i  this violation is close ;
a 08.5 Mlpeg Q.J1Q p 366/97 02-03: Late 10 CFR 50.72 Notification For    !
]  $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 erro 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 close .6 1 Closed) VT,50-321. 366/97-05-02:  Failure to Follow Procedure;.
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Multiole Ex moles.
 
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The licensee responded to this violation in documentation dated August 22. 199 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
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  ,
   . Gentlemen:
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
Thank you for your. response of February 20. 1998. to our Notice of Violation
>
  ' issued on January 23. 1998, concerning activities conducted at your Hatch -
drawing had been revised as indicated in the licensee's respons The second example was caused by inadecuate procedur Fire protection personnel.did not perform acditional surveillances for rejected fire penetrations. The inspectors verified that the f
  -facility. During a March 10. 1998 teleconference concerning your response to
procedures for both units were revised as stated in the violation respons The third example was caused by personnel error. Workers failed
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Violation 97-11-06. your staff clarified that in addition to the personnel error which caused the initial violation.~ inadequate communication among the Health Physics technicians responding to the event contributed to their failure =to take adecuate actions. We have evaluated your response and. upon amplification, founc that the response meets the requirements of 10 CFR 2.20 :We will. examine the implementation of your corrective actions during-future inspection We appreciate your cooperation'in this matte Sincerel (Original signed by Pierce H. Skinner)
to inform Health Physics (HP) personnel when work conditions were  i
Pierce H. Skinner. Chie Reactor Projects Branch 2 g    Division of Reactor Projects
,   not as previously identified. This resulted in personnel
,' Docket Nos. 50-321'. 50-366
:   unnecessary contaminations. As corrective actions, the licensee made personnel aware of the event. its consequences, and cause Proper communication and a questioning attitude were stresse The fourth example was caused by personnel error. Poor communications resulted in personnel contaminations when workers  '
  . License Nos. DPR-57. NPF-5 cc: LJ. D..Woodard Executive Vice President    O Southern Nuclear Operating Company. In .P O. Box 1295 g Birmingham. AL 35201-1295 cc cont'd: .(See Page 2)
disassembled a contaminated structure without proper HP oversigh A multi-disciplined Problem Solving Team was formed to c  investigatethis and other similar problems and make Enclosure 2
9903270357 980317 L  PDR ADOCK 05000321 G  PDR
't
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recommendations for further actions and improvemen Based upon the inspectors' review of licensee actions, this violation is close II. Maintenan M1 Conduct of Haintenance M1.1 General Comments 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 Observations and Findinas The inspectors found that the work was performed with the work packages present and being actively used, 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 identifie M1.2 Restart Problems on Unit 1 FolkMn.gfall n 97 Refuelino Outaae 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 outag Discussions were also held with various licensee personnel, 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
 
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encountered during the startup and subsequent shutdown of the uni . The extraction relay dump valve (IN32-F021) was disassembled
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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 activit 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 abov 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-F02 This problem was attributed to poor workmanshi 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 discover For additional corrective actions, the use of GE's guidance and work activity monitoring for these valves in the future will be enhance * 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 dela 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
 
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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 compresse 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).
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The inspectors reviewed TS Section 3.4.3. " Safety / Relief Valves."
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and the a)plicable section of the Unit 1 Updated Final Safety
  .: 1 b e TSNCj    2'
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s    ..
Analysis Report (UFSAR). No discrepancies were identified.
  'cc:. Continued 1
 
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    :P; H.-Wells'
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,   General Manager--Plant' Hatch-
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 F022 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 goo M2 Maintenance and Materiel Condition of Facility and Equipment M2.2 Cold Weather Prenarations Inspection Stone (71714)
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The inspectors reviewed maintenance procedure 52PM MEL-005-0 " 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 preparation Observations and Findinas Among the areas observed and reviewed were the following:
h    -Southern Nuclear Operating Company. In U. S. Highway l' Nort P. 0. Box'2010
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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
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Enclosure 2 j
 
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  . 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 check 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 insulatio 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 system These areas contain systems tlat are important to safety and/or could cause a plant transien 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 area 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 personne 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 problem The inspectors also observed that once identified, these items were promptly correcte Conclusions The inspectors concluded that the cold weather preparation program was goo The procedures for performing equipment operability checks were appropriate and maintenance corrected the identified cold weather preparation deficiencies in a timely manne .
M2.3 Jnsulation Removal Durina Snubber Work Activity 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
 
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:  V   Baxley. GA 31515
 
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
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conjunction with MWO l-97-1676. Additionally, the removal of the      i insulation was discussed with licensee personne Observations and Findinas During a routine plant tour on December 5. the inspectors
 
observed insulation on the floor of the Unit I reactor 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 remove 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.
 
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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 late 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
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removed insulatio 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 supervisio The inspectors were informed that the insulation work for the outage was performed on blanket MWO 1-97-090 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 remova 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 organizatio The craftsman that was tasked with the removal of snubber lEll-H227 also removed the insulation. A Enclosure 2
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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 remove 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 installatio This procedure explained the site process for insulation work activities, 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 Tes 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, Re CP-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 satisfactoril The performance of the operators and crews conducting the surveillances was generally professional and competent. No deficiencies were identifie Enclosure 2
 
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M4 Maintenance Staff Knowledge and Performance M4.1 Observation of Online Loaic System Functional Test of Main Control r loom Pressurization System 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-21-0386 " 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 requirement 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 requirement 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, 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 retrieva acement, and removal of required jumpers were well-controlled, 3rocedures were correctly use The systems responded as expected and all test acceptance criteria were me The 10 CFR 50.59 +
evaluation was appropriat Enclosure 2
 
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M8 Hiscellaneous Maintenance Issues (92700) (92902)
M (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 Leakag The LER was detailed and thorough. Based upon the ins)ectors review of licensee actions and the issuance of the 1CV. this LER is close 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 Repor The LER presented no new informatio Based upon the inspectors review of licensee's actions, this LER is close M8.3 (Closed) IFl 50 321/97-10-01: Review of Unit 1 RCIC Testina Artivities from the Remote Shutdown Pane 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 outag This problem is discussed in Section 02.1 of IR 50 321. 366/97-1 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 iequirement Based upon the inspectors' review of licensee activities for RCIC corrective maintenance and the results of the required RCIC testing activities, this IFI is close 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 excellen Enclosure 2
 
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E2 Engineering Support of Facilities ard Equipment E2.1 Review of Unit 2 Torus-to-Reactor Building Vacuum Bre2ker Design, 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
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'
meet containment isolation requirements. This had been identified as a potential problem at other Boiling Water Reactor (BWR) site The inspectors reviewed Unit 2 drawing H26084. " Primary Containment Purge and Inerting System." and discussed the issue with site management personnel, 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 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
 
.. - , - . . - - . . -  -- - -
.
.
,
 
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 permi 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 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 desig 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 atmospher This problem was identified as Unresolved Item 50-366/97-11-0 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 _ 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 personne Observations and Findinas On November 24. the 2C EDG was tagged out for maintenance er.tivitics to calibrate a cooling water temperature control valv 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 failur Enclosure 2
 
. _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ __  _ - _ _ _ _ _
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,
 
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 ru The inspectors observed ongoin EDG operability surveillance and g work activities verified that and parts of the 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 ED .
l    The licensee issued Significant Occurrence Report (SOR) C9706228 l    documenting the 2C EDG start failure and subsequent failure t
l analysis. The inspectors reviewed the SOR for appropriate 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.199 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 necessar 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 periodicall Enclosure 2
        ]
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    -
 
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E8 Hiscellaneous Engineering Issues (92700) (92903)
E (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 startu 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 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) implementatio 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 verifie 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) 097-001 Procedural guidance and established radiological controls were compared against applicable sections of the Updated Final Safety Enclosure 2
 
. _ _ . . - . - . --. . -- . - . . -
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'
.
 
Analysis Report (UFSAR) and the applicable requiremeats specified in Technical Specifications (TSs): 10 CFR Parts 20 and 71: and
  .49 CFR Parts 100-179.
 
j Observations and Findinas
'
'
  .
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
D.:M. Crowe Manager Licensing - Hatch N
'
cleanliness within observed work areas and the U2 radwaste tank rooms relative to previous inspection 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 requirement Improvements were noted in the radwaste facility housekeeping and cleanlines R1.2 Liauid Radwaste Effluent Processina. Analysis and Release
- Insoection Scooe (84750)
Ongoing liquid effluent release program activities were evaluate 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. respectivel 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) releas The effluent release program review included equipment operability, procedural adequacy and staff proficienc Detailed reviews were conducted of the pre-release sample collection and Enclosure 2
 
.
.
 
radiological analyses. liquid effluent monitor setpoints, and valve line u) operations associated with a subsequent liquid release to t1e environmen 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, 199 . 64CH-SAM-024-05 Liquid Radwaste Sampling and Analysi Rev. O, effective December 11, 199 . 3450-G11-021-25. Radwaste Sample Tank Operating Procedure, effective July 31. 199 Personnel observed and interviewed regarding the FDST liquid radwaste processing and release included radwaste operators and chemistry technician 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 requirement 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 capacitie All sampling and quantitative radionuclide analyses were conducted in accordance with the approved procedur e 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 practice 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
 
. . _ _ _ __ . . . . ___ . _ _ . _
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   .
Southern Nuclear Operating Company. In P. 0.. Box'1295 o    ~ Birmingham. AL: 35201-1295
.
''
,
Ernest L. Blake. Es Shaw, Pittman. Potts and
 
+
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 1 . 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
.
.
    '. Trowbridge:
2300 N Street. NW Washington. D. C. 20037 Office.of Planning and Budget Room 610
  '
270' Washington Street, SW Atlanta..GA 30334
_ >
Director' .. -
    : Department'of Natural Resource Butler Street..SE. Suite 1252-
    ' Atlanta, GA 30334-
,.  -Manager.. Radioactive Materials Program-Department of Natural l Resources
'
    ~4244-International. Parkwa '
    . Suite <114
,    ~ Atlanta,-.GA .30354-y
  "
Chairman
'
    ' Appling County Consnissioners-
    . County Courthous '
Baxley, GA '31513'
Program Mana er F
'
'
  >
su) sequent to the release. Thus the detector response to a source of increased radioactivith immediately preceeding the
    . Fossil &Nuckear. Operations-   o Oglethor3e Power Corporation
: 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, 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 requirement 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
,  Requirement Rl.3 Radioactive Waste and Material Transoortation Activities
, Insoection Scoce (86750)
The-inspectors reviewed radiation protection (RP) and transportation program activities associated with radioactive
 
~
Enclosure 2


2100 E. Exchange. P1 ace
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  -
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LTucker. GA 30085-1349 L  fcc cont'd: -(See Page 3)
 
h L
waste (radwaste) characterization, packaging, transportation, and subsequent burial of licensed materia 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.1 effective June 23. 199 . 62RP-RAD-040-05. Pacific Nuclear Resin Drying Syste Rev. 5. effective July 31, 198 . 62RP-RAD-042-05. Solid Radwaste Scaling Factor Determination. Rev 3. effective March 26. 199 On December 9, 1997, the inspectors directly observed packaging, loading, and preparation of condensate phase separator (CPS)
  .,
resins for shipment to a licensed burial facilit 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:
h L  ^
. Shipment No. 97-1024. Radioactive material. Low Specific Activity (LSA). n. . UN 2912. Fissile Excepte Dewatered Resins. Solid Metal 0xides, shipped on October 15, 199 . 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 6.199 . 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 4,199 . Shipment No. 97-1031. Radioactive material . LSA. n.o.s. UN 2912. Fissile Excepted Reportable Quantities (RO) -
  /
Radionuclides. Dewatered Resins. Solid Metal 0xides, shipped on December 9. 199 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 regulation Enclosure 2
 
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.
l 30 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 revision The processing, packaging, and preparation of the CPS resins for trans)ortation and subsequent burial were implemented effectivel 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, Conclusions Licensee program guidance for processing, packaging, and transporting radwaste for subsequent burial met 10 CFR Parts 2 . and 71: and 49 CFR Parts 100-179 requirements, as applicabl Radwaste processing, packaging and transportation activities were implemented effectivel R1.4 Ob ervation of Routine Radioloaical Controls Insoection Scoce (71750)
General HP activities were observed during the report perio This included locked high radiation area doors, proper radiological posting, and personnel frisking upon exiting the RC The inspectors made frequent tours of the RCA and discussed radiological controls with HP technicians and HP managemen Minor deficiencies were discussed with licensee managemen R5 Staff Training in Radiation Protection and Chemistry R5.1 Hazardous Material Trainina 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
 
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  .
 
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, 198 Hazmat training guidance and frequency were compared against requirements of 49 CFR 172.70 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 172.70 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 172.70 Conclusions f Hazmat training for personnel processing, handling, and shipping CPS resins was conducted in accordance with 49 CFR 172.702 requirement R7 Quality Assurance in RP & C Activities R7.1 Countina Room Ouality Control (OC) Activities 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 discusse The review included t1e most recent 1997 semiannual inter-laboratory cross-check analyses, selected daily control chart parameters, and weekly background check dat 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."


;p , ,';' <
Rev. Enclosure 2
SNC    3 cc: Continued-Charles A. Patrizia. Es Paul. Hastings, Janofsky & Walker 10th Floor 1299 Pennsylvania Avenue    {
Washington, D. C. 20004-9500    ,
i Senior Engineer - Power Supply Municipal Electric Authority _
of Georgia 1470 Riveredge Parkway NW Atlanta, GA 30328-4684
        \
Distribution:      !
  'P. H. Skinner RII R.'P. Carrion. RII      l W..P. Kleinsorge, RII    j M. E. Ernstes. RII      I L.'01shan. NRR      '
PUBLIC      l NRC Resident Inspector    )
  .U.S. Nuclear Regulatory Comission 11030 Hatch Parkway North Baxley, GA 31513      y I
         ;
         ;
  }
 
I t
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  ...-
32 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 dat 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 agreemen 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, 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 fie R8 Miscellaneous RP&C Issues (83750) (84750)
R8.1 Unit 1 Outaae Radiation Control Performance Indicators 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 evaluatico As applicable, results were reviewed against TS and 10 CFR Part 20 requirement Enclosure 2
 
9
 
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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 Judgete The inspectors noted a significant decline in worker contamination 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 activitie 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
'
'
UFFICE RII:DRP RII:DRP, ,
U1 RF0 17 activities, 32 instances of potential radionuclide intakes were identified by routine or investigative WBC analyse Excluding two individuals involved in a November 14, 1997,
Ril:DRs RW ,
,  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 1 , 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 "
5NM . (\{ (gj ;4 (g4 [f ip~
Rev. 8, and 60AC-HPX-004-OS, " Radiation and Contamination Control," Rev.15. following identification of facial contamination on two laborers on November 14, 199 At that time, extensive personnel decontamination activities and hand frisking were required to allow the subject individuals to exit the RC 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)
af5E W:Sa utilothrip - GuKuro qbrr .
to the lung of 534 mrem. Based on available data, the doses were based on conservative assumptions and were within regulatory Enclosure 2
DATE 3/ Q g 3/ p /95 3g /95 3/ l } /95 3/ /95 3/ /95 3/ /95 wn r - .nz (ug us no (ns) up rus) no us no us no ns no
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!- ortscIAL aECEAD CGPY 00CLNEEmi mAME: G:\NATCR\ACK9/-11.LTN
 
_-_ ___ _ _ ______ _ -.
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    .
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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 Activitie Conclusions Licensee initiatives to manage exposure and reduce worker contamination events during the U1 RF017 activities were effectiv Excluding a November 14, 1997, personnel contamination even controls for minimizing exposure from intakes of radionuclides ,
were effective and potential radionuclide intakes were evaluated '
; properl 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 Activitie 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 Soecification 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 requirement Enclosure 2 i
 
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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 manual 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)
Adherenc 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 activitie The root cause analysis summary, dated June 25, 1997, was reviewed and discussed with responsible licensee representative 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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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 Implementatio 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 Contaminatio 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 contamination 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 contamination 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 event Corrective actions included the reassignment of performance team HP technicians reporting to the HP department organizatio 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 communication Enclosure 2
 
9
 
.
.
 
establishing and communicating a goal of "zero" unplanned PCR 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 close 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 7 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
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-_______- - - _ _ _ _
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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 la If the EAP 3rofessional determined that the emplo threat to t1emselves or to the safety of others. yee was a serious
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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 dutie If the employee authorized the release of the inform 6. ion to another party or individua 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 referra The inspectors reviewed the following FFD procedures currently in place to determine if information regarding mandatory FFD evaluations was incorporated:
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Corporate Policy 720. " Fitness for Duty," dated November 19, 1997
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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, 199 ,
All procedures reviewed adequately described the mandatory FFD evaluation as pact of the licensee's EA 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 evaluation 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
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_ _ _ _ - _ - _ _ _ - _ _ _
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and keeping the FFD onsite staff informed about the mandatory FFD evaluation process would be beneficia 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 utilize 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 purpose ,
The inspectors reviewed Section 5.4.3 of the licensee's PSP. which specified the re protected area. quirements Section 5. forofthe thecontrol of vehicles PSP stated in part.inside the
      " 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 PS 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 199 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 followe Incividuals who are favorably terminated are entered in the Training and Qualification System (TRA05) by the appropriate department. Termination Enclosure 2
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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. Additionall contractor badges are deleted from the security computer system after 30 days of non-us c. Conclusions The licensee's practice of utilizing designated vehicles for offsite use, as proposed in their December 1996 PSP change, was discusse 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 PS S3 Security and Safeguards Procedure:: and Documentation
,
S3.1 Security Procram Plans 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 sigh 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 PS 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 chang Enclosure 2 I
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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 chang 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, 199 The following findings and recommendations were documented:
-
Unannounced drills, as required by the PSP, were not being
,  conducte The SAER recommended that a change to the plan be L
'
submitted; however, security made a determination to continue the practice of conducting unannounced drill An administrative non-com)liance was identified. When a procedure needed revision, rather tlan stop and revise the procedur Security would 'line out" the portion that was inadequate and continue to use the procedur 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 PS The inspector determined that audit reports were appropriately documented and distributed to upper management for revie Findings were adequately addressed for closur The inspector noted that the licensee had a Continuous Improvement Suggestion Program, which tracked suggestions from the security staf As of November 20, 1997, 31 suggestions had been implemented year-to-dat 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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determined that security audits were being conducted in accordance with the-licensee's PS Miscellaneous Security and Safeguards Issues (92904)
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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 2 ; The licensee adequately addressed, through procedures and
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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 violatio V. Manaaement Meetinas 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 parameter 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 presente Interim exits were conducted on November 21 and December 12. 199 The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie 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
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the plant general manager to discuss plant performance and other regulatory issue PARTIAL LIST OF PERSONS CONTACTED Licensee Anderson, 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
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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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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
 
and Inadequate Procedure
:
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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).
 
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 Sourc 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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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 Notificatio 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
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50-321/97 207 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).
 
(
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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
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}}
}}

Revision as of 02:35, 8 December 2021

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)
v • d • e


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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 l

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 3882188n 3 8683u l 0 PDR

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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 inspectio Doerations e 0)erator response to the transient and manuci scram resulting from t1e Unit 2 Condensate Booster pump check vilve problems were goo Performance during the subsequent unit sta' tup was excellent (Section 01.2).

o Maintenance and engineering provided excellent support to operations for the Unit 2 system and component damage assessment and re3 air activities resulting from the Unit 2 condensate booster pump cleck valve problem 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),

e Operations personnel were knowledgeable and generally professional. Interaction with other grou minimize distractions in the control room.psHowever, was controlled to inconsistent three-part communications by the operators was observed (Section 01.3).

e Operator performance during the Unit 1 startup following the 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 identifie 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 identifie 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).

.

o Operator actions were appropriate and timely for the power excursion due to the 2A recirculation pump spurious speed increase on Unit 2. Engineering and maintenance support was good (Sectinn 04.2).

Maintenance e Maintenance activities were generally completed in a thorough and professional manner (Section M1.1).

e 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).

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

e The licensee's preparation for cold weather was good. The 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 satisfactoril 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 requirement 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 tubin Licensee Event Report 50-321/97-06, was detailed and thorough (Section M8.1).

Enoineerina e 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. 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 thoroug Maintenance and engineering recommendations reflected a good interface with the vendor (Section E2.2).

e The Maintenance Rule periormance criteria for the EDGs were being 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).

e Improvements were noted in the radwaste facility housekeeping and 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).

e Inspector Followup Item (IFI) 50-321. 366/97-11-05 was identifie Review Adequacy of Revised Liquid Effluent Release Procedures to Meet Offsite Dose Calculation Manual (0DCM) Monitor Check Source Requirements (Section Rl.2).

Enclosure 2

A w arhLaL_rLJN\  % '

A .

8'

f'#

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e packaging, and Licensee program transporting radwaste guidance for processing,l to a licensed buria site met 10 CFR Parts 20, 61. 71: and 49 CFR Parts 100-179 requirements (Section RI.3).

e Radwaste processing. packaging and transportation activities were implemented effectively (Section Rl.3).

e General Health Physics activities observed during the report 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).

o Hazardous material training for personnel processing, handling, 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).

< e A lack of attention to detail by responsible personnel for 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).

e Licensee root cause analyses to identify causes of an increasing 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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e 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)

(Section S2,1).

e Protected and vital area access controls met the requirements of the Physical Security Plan (Section S2.1).

e Physical Security Plan changes submitted by the licensee under the 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

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outage. On November 18, unit power was increased to about 20% Rated 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 gri The unit achieved 100% RTP on November 2 The unit o l report period, perated at this routine except during power level testingforactivitie the remainder of the i

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 2 tied to the grid on November 27 and achieved 100% RTP on November 2 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%

RT The pump speed controller was repaired. The unit operated at 100%

RTP for the remainder of the report period, except during routine testing activities.

l 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 belo .2 Unit 2 Transient and Manual Scram Due to a Condensate Booster Pumo (CBP) Check Valve Failure 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 observeddamage, correctivereviewed the licensees maintenance, assessment and obrerved operator of the performance during unit startup activitie 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

_ _ - _ _ _ _ _ _ _ _ _ _ - _ _ __ _ _ _ _ _ _ .. _

_

-4

for the reactor feed room. The operators'attempt pumps to (RFPs)

restartactuated in the the 2A CBP main control faile 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 designe Operators locally at the 2A CBP reported that the pump was rotating backward 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 inche 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 uni 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 proble Management decided to develop a shutdown plan repair plan, and conduct a controlled unit shutdown to implement repair )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 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 damage 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 scra ;

Corporate engineers were being dispatched to the site the following day to assess the damage and make recommendations for repair Operations began actions to bring the unit to hot shutdow ,

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 problem 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 maintenanc 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 recommendatio )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 2 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 proble .3 Observations of On-Shift Doerations Performance 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 manual 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 procedure Evolution pre-briefings were observed to be performed per procedure with the attendees actively participating. Actions.fo unex)ected situations and plant conditions were discussed as part of t1e pre-briefin Enclosure 2

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The inspectors observed that the plant operators were knowledgeable and well-informed of activities in the plan 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

! ladders in use not tied off correctly. The housekeeping l observations were discussed with plant managemen 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 concern 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 communication 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 manipulation Operator response to a manual reactor scram was observe The operators were well-prepared and familiar with the required scram Enclosure 2

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6 action Procedures were used and overall performance was satisfactor 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 expectation .4 Observations of Unit 1 Startuo Activities Followina Refuelina 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 activitie V-SUV-018-15. "ECCS Status Checks."

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Rev. 6. 34G0 0PS-003 15. "Startup System Status Checklist." Re , 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 me 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 observe 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 servic The inspectors reviewed completed system valve lineups and system status checks associated with these evolutions. No deficiencies were observed and TS requirements were met, t Enclosure 2 w _

._ _____ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ . _ ._--

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7 Conclusions ,

The inspectors concluded that operator performance during the Unit 1 startup following the refueling outage was good. Systems

arvi components observed operated and responded as expected. TS

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and regulatory requirements were met for the unit startu Operations Proceciures and Documentation 0 Failure to Follow Procedure and inadeouate Procedure Results in Groun 1 isolation Sianal on Unit 1 Due to Low Condenser Vacuum Insoection Scone (717021 roc The inspectors reviewed 34G0-0PS-013-IS " Normal Plant general operating Shutdown, t )ev,edure 23 and abnormal .

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

arocedures were used on November 18 during the normal shutdown of '

Jnit 1 for corrective maintenance. Discussions were also conducted with licensee personne 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 i 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 valv This problem is discussed in Section M1.2 of this repor 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-013-1 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 013-1 step 7.6.8. instructed the operator to place the low vacuum bypass switches in the " Bypass" position when reactor pressure is approximately 500 psi 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 breaker Placing the switches in )ypass had been discussed earlier during the pre job briefin 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 revise These

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procedures had not been revised as of the end of this report perio . (cnclusiorn Operator error and procedural inadequacy resulted in the receipt of an Engineered Safety Feature (ESF) Group 1 1 solation signa This violation constitutes a violation of minor safety

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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 Isolatio .0 Operator Knowledge and Performance 04.1 Late 10 CFR 50.72 Report for a Valid Enoineered Safetv Feature Actuation on Unit 1

, 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 repor 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 maintenanc 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 rese Operators initiated a deficiency car 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

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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.

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The inspectors determined that the identification of this deficiency was good performanc 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 Actuatio 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 . This problem is documented in IR 50-321, 366/97-0 Appendix B of 10 CFR 50 requires in part, ccrrective actions to preclude repetition of significant conditions adverse to qualit 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 Actuatio 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 Criterion XVI. Corrective Action. The failure to implement adequate corrective actions was identified as V10 50-321. 366/97-Enclosure 2 l

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1103. Inadequate Corrective Actions for Late 10 CFR 50.72 Notification .2 Unit 2 Power Excursion be to Sourious Soeed increase of the 2A Reactor Recirculation ( N) Pumo 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 001-2 " 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 reviewe 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 personne 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 tim 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 even The inspectors verified no TS entry conditions existed through an independent TS revie 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 2-97-334 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 c bias button per instructions provided in MWO 2-97-334 Enclosure 2

.

.

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' spee 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 bia 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 knowledg &C personnel had changed the type of lubricant used and believed the problem was correcte Following 1&C troubleshooting and repair activities, the unit was returned to 100% aower and the 2A controller was returned to the automatic mod further problems were observe 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 operation 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 Actuation 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 close Enclosure 2

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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 3 Based upon the inspectors' review of licensee actions and the issuance of a NCV. this LER is close .3 (Closed) URI 50-321.366/96 13 02: EOP Deviation From EPG Sten RC/P- ,

This Unresolved item is discussed in IR 50 321, 366/96 1 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 exis Based upon the additional review, this Unresolved item is close .4 (Closed) VIO 50-321. 366/97-02-02: Failure to Follow Procedure -

Multinle Examnle 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 clarit The inspectors observed that the procedures for both units were revised as stated in the licensee's response to the violatio 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 meeting *

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 checklist The fourth example dealt with maintenance work being performed that was outside the scope of the approved maintenance work orde Enclosure 2 l-

- n n, - , - - - -. - -,,,--,---mmn- - ., , - - . --,,n,--,- --,-n - . , . ,-

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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

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workert inv0lved. The involved worker was coached concerning restrictin9 their work activities to those explicitly described on

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the MW Bardd upon the inspectors review of licensee actions, i this violation is close ;

a 08.5 Mlpeg Q.J1Q p 366/97 02-03: Late 10 CFR 50.72 Notification For  !

] $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 erro For corrective actions the licensee counseled the Shift Supervisor

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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 close .6 1 Closed) VT,50-321. 366/97-05-02: Failure to Follow Procedure;.

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Multiole Ex moles.

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The licensee responded to this violation in documentation dated August 22. 199 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

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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 respons The second example was caused by inadecuate procedur 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 respons 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 cause Proper communication and a questioning attitude were stresse The fourth example was caused by personnel error. Poor communications resulted in personnel contaminations when workers '

disassembled a contaminated structure without proper HP oversigh A multi-disciplined Problem Solving Team was formed to c investigatethis and other similar problems and make Enclosure 2

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recommendations for further actions and improvemen Based upon the inspectors' review of licensee actions, this violation is close II. Maintenan M1 Conduct of Haintenance M1.1 General Comments 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 Observations and Findinas The inspectors found that the work was performed with the work packages present and being actively used, 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 identifie M1.2 Restart Problems on Unit 1 FolkMn.gfall n 97 Refuelino Outaae 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 outag Discussions were also held with various licensee personnel, 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

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encountered during the startup and subsequent shutdown of the uni . The extraction relay dump valve (IN32-F021) was disassembled

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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 activit 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 abov 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-F02 This problem was attributed to poor workmanshi 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 discover For additional corrective actions, the use of GE's guidance and work activity monitoring for these valves in the future will be enhance * 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 dela 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

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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 compresse 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

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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 F022 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 goo M2 Maintenance and Materiel Condition of Facility and Equipment M2.2 Cold Weather Prenarations Inspection Stone (71714)

The inspectors reviewed maintenance procedure 52PM MEL-005-0 " 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 preparation Observations and Findinas Among the areas observed and reviewed were the following:

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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

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. 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 check 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 insulatio 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 system These areas contain systems tlat are important to safety and/or could cause a plant transien 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 area 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 personne 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 problem The inspectors also observed that once identified, these items were promptly correcte Conclusions The inspectors concluded that the cold weather preparation program was goo The procedures for performing equipment operability checks were appropriate and maintenance corrected the identified cold weather preparation deficiencies in a timely manne .

M2.3 Jnsulation Removal Durina Snubber Work Activity 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

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a w

i

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

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conjunction with MWO l-97-1676. Additionally, the removal of the i insulation was discussed with licensee personne Observations and Findinas During a routine plant tour on December 5. the inspectors

observed insulation on the floor of the Unit I reactor 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 remove 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 late 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 insulatio 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 supervisio The inspectors were informed that the insulation work for the outage was performed on blanket MWO 1-97-090 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 remova 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 organizatio 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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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 remove 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 installatio This procedure explained the site process for insulation work activities, 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 Tes 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, Re CP-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 satisfactoril The performance of the operators and crews conducting the surveillances was generally professional and competent. No deficiencies were identifie Enclosure 2

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M4 Maintenance Staff Knowledge and Performance M4.1 Observation of Online Loaic System Functional Test of Main Control r loom Pressurization System 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-21-0386 " 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 requirement 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 requirement 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, 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 retrieva acement, and removal of required jumpers were well-controlled, 3rocedures were correctly use The systems responded as expected and all test acceptance criteria were me The 10 CFR 50.59 +

evaluation was appropriat Enclosure 2

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M8 Hiscellaneous Maintenance Issues (92700) (92902)

M (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 Leakag The LER was detailed and thorough. Based upon the ins)ectors review of licensee actions and the issuance of the 1CV. this LER is close 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 Repor The LER presented no new informatio Based upon the inspectors review of licensee's actions, this LER is close M8.3 (Closed) IFl 50 321/97-10-01: Review of Unit 1 RCIC Testina Artivities from the Remote Shutdown Pane 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 outag This problem is discussed in Section 02.1 of IR 50 321. 366/97-1 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 iequirement Based upon the inspectors' review of licensee activities for RCIC corrective maintenance and the results of the required RCIC testing activities, this IFI is close 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 excellen Enclosure 2

_ - _____ _ - .

E2 Engineering Support of Facilities ard Equipment E2.1 Review of Unit 2 Torus-to-Reactor Building Vacuum Bre2ker Design, 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

,

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meet containment isolation requirements. This had been identified as a potential problem at other Boiling Water Reactor (BWR) site The inspectors reviewed Unit 2 drawing H26084. " Primary Containment Purge and Inerting System." and discussed the issue with site management personnel, 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 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

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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 permi 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

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later informed that the licensee was developing an exemption request for the GDC 56 requirements for Hatch Unit 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 desig 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 atmospher This problem was identified as Unresolved Item 50-366/97-11-0 Unit 2 Failure to Meet General Design Criteria 56 for Proper Automatic Containment Isolation Valve Outside Containment. pending additional review.

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E2.2 Emeroency Diesel Generator (EDG) 2C Failure to St?rt _ 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 personne Observations and Findinas On November 24. the 2C EDG was tagged out for maintenance er.tivitics to calibrate a cooling water temperature control valv 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 failur Enclosure 2

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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 ru The inspectors observed ongoin EDG operability surveillance and g work activities verified that and parts of the 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 ED .

l The licensee issued Significant Occurrence Report (SOR) C9706228 l documenting the 2C EDG start failure and subsequent failure t

l analysis. The inspectors reviewed the SOR for appropriate 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.199 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 necessar 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 periodicall Enclosure 2

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E8 Hiscellaneous Engineering Issues (92700) (92903)

E (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 startu 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 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) implementatio 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 verifie 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) 097-001 Procedural guidance and established radiological controls were compared against applicable sections of the Updated Final Safety Enclosure 2

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Analysis Report (UFSAR) and the applicable requiremeats specified in Technical Specifications (TSs): 10 CFR Parts 20 and 71: and

.49 CFR Parts 100-179.

j Observations and Findinas

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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

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cleanliness within observed work areas and the U2 radwaste tank rooms relative to previous inspection 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 requirement Improvements were noted in the radwaste facility housekeeping and cleanlines R1.2 Liauid Radwaste Effluent Processina. Analysis and Release

- Insoection Scooe (84750)

Ongoing liquid effluent release program activities were evaluate 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. respectivel 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) releas The effluent release program review included equipment operability, procedural adequacy and staff proficienc Detailed reviews were conducted of the pre-release sample collection and Enclosure 2

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radiological analyses. liquid effluent monitor setpoints, and valve line u) operations associated with a subsequent liquid release to t1e environmen 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, 199 . 64CH-SAM-024-05 Liquid Radwaste Sampling and Analysi Rev. O, effective December 11, 199 . 3450-G11-021-25. Radwaste Sample Tank Operating Procedure, effective July 31. 199 Personnel observed and interviewed regarding the FDST liquid radwaste processing and release included radwaste operators and chemistry technician 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 requirement 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 capacitie All sampling and quantitative radionuclide analyses were conducted in accordance with the approved procedur e 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 practice 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

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+

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

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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 1 . 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

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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

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i Offsite Dose Calculation Manual (00CM) Monitor Check Source i Requirements, Conclusiom Proficiency of chemistry technicians and radwaste operators during conduct of a December 11. 1997. U2 FDST release was demonstrated.

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

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Adequacy of Revised Liquid Effluent Release Procedures to Meet Offsite Dose Calculation Manual (ODCM) Monitor Check Source

, Requirement Rl.3 Radioactive Waste and Material Transoortation Activities

, Insoection Scoce (86750)

The-inspectors reviewed radiation protection (RP) and transportation program activities associated with radioactive

~

Enclosure 2

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waste (radwaste) characterization, packaging, transportation, and subsequent burial of licensed materia 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.1 effective June 23. 199 . 62RP-RAD-040-05. Pacific Nuclear Resin Drying Syste Rev. 5. effective July 31, 198 . 62RP-RAD-042-05. Solid Radwaste Scaling Factor Determination. Rev 3. effective March 26. 199 On December 9, 1997, the inspectors directly observed packaging, loading, and preparation of condensate phase separator (CPS)

resins for shipment to a licensed burial facilit 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. . UN 2912. Fissile Excepte Dewatered Resins. Solid Metal 0xides, shipped on October 15, 199 . 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 6.199 . 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 4,199 . Shipment No. 97-1031. Radioactive material . LSA. n.o.s. UN 2912. Fissile Excepted Reportable Quantities (RO) -

Radionuclides. Dewatered Resins. Solid Metal 0xides, shipped on December 9. 199 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 regulation Enclosure 2

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l 30 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 revision The processing, packaging, and preparation of the CPS resins for trans)ortation and subsequent burial were implemented effectivel 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, Conclusions Licensee program guidance for processing, packaging, and transporting radwaste for subsequent burial met 10 CFR Parts 2 . and 71: and 49 CFR Parts 100-179 requirements, as applicabl Radwaste processing, packaging and transportation activities were implemented effectivel R1.4 Ob ervation of Routine Radioloaical Controls Insoection Scoce (71750)

General HP activities were observed during the report perio This included locked high radiation area doors, proper radiological posting, and personnel frisking upon exiting the RC The inspectors made frequent tours of the RCA and discussed radiological controls with HP technicians and HP managemen Minor deficiencies were discussed with licensee managemen R5 Staff Training in Radiation Protection and Chemistry R5.1 Hazardous Material Trainina 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

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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, 198 Hazmat training guidance and frequency were compared against requirements of 49 CFR 172.70 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 172.70 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 172.70 Conclusions f Hazmat training for personnel processing, handling, and shipping CPS resins was conducted in accordance with 49 CFR 172.702 requirement R7 Quality Assurance in RP & C Activities R7.1 Countina Room Ouality Control (OC) Activities 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 discusse The review included t1e most recent 1997 semiannual inter-laboratory cross-check analyses, selected daily control chart parameters, and weekly background check dat 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. Enclosure 2

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32 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 dat 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 agreemen 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, 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 fie R8 Miscellaneous RP&C Issues (83750) (84750)

R8.1 Unit 1 Outaae Radiation Control Performance Indicators 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 evaluatico As applicable, results were reviewed against TS and 10 CFR Part 20 requirement Enclosure 2

9

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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 Judgete The inspectors noted a significant decline in worker contamination 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 activitie 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 analyse 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 1 , 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, 199 At that time, extensive personnel decontamination activities and hand frisking were required to allow the subject individuals to exit the RC 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

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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

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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 Activitie Conclusions Licensee initiatives to manage exposure and reduce worker contamination events during the U1 RF017 activities were effectiv Excluding a November 14, 1997, personnel contamination even controls for minimizing exposure from intakes of radionuclides ,

were effective and potential radionuclide intakes were evaluated '

properl 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 Activitie 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 Soecification 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 requirement Enclosure 2 i

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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 manual 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)

Adherenc 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 activitie The root cause analysis summary, dated June 25, 1997, was reviewed and discussed with responsible licensee representative 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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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 Implementatio 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 Contaminatio 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 contamination 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 contamination 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 event Corrective actions included the reassignment of performance team HP technicians reporting to the HP department organizatio 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 communication Enclosure 2

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establishing and communicating a goal of "zero" unplanned PCR 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 close 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 7 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:

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

dated November 19. 1997

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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

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in accordance with federal and state law, and would not be revealed to anyone outside the LAP program except under the following circumstances-:

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If disclosure was required by la If the EAP 3rofessional determined that the emplo threat to t1emselves or to the safety of others. yee was a serious

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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 dutie If the employee authorized the release of the inform 6. ion to another party or individua 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 referra The inspectors reviewed the following FFD procedures currently in place to determine if information regarding mandatory FFD evaluations was incorporated:

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

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

November 19. 1997

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Corporate Procedure 727, " Employee Assistance Program," dated November-19, 1997

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

dated November 26. 1997

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Fitness for Duty Procedure SH-FFD-013. " Mandatory Fitness for Duty Evaluations," dated November 26, 199 ,

All procedures reviewed adequately described the mandatory FFD evaluation as pact of the licensee's EA 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 evaluation 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

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and keeping the FFD onsite staff informed about the mandatory FFD evaluation process would be beneficia 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 utilize 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

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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 purpose ,

The inspectors reviewed Section 5.4.3 of the licensee's PSP. which specified the re protected area. quirements Section 5. forofthe thecontrol of vehicles PSP stated in part.inside the

" 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 PS 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 199 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 followe Incividuals who are favorably terminated are entered in the Training and Qualification System (TRA05) by the appropriate department. Termination Enclosure 2

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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. Additionall contractor badges are deleted from the security computer system after 30 days of non-us c. Conclusions The licensee's practice of utilizing designated vehicles for offsite use, as proposed in their December 1996 PSP change, was discusse 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 PS S3 Security and Safeguards Procedure:: and Documentation

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S3.1 Security Procram Plans 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:

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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 sigh 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 PS 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 chang Enclosure 2 I

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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 chang S7 Quality Assucance in Security and Safeguards Activities

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S7.1 Sgcuritv,Procram Audits a. Insoection Scone (81700)

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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, 199 The following findings and recommendations were documented:

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

, conducte The SAER recommended that a change to the plan be L

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submitted; however, security made a determination to continue the practice of conducting unannounced drill An administrative non-com)liance was identified. When a procedure needed revision, rather tlan stop and revise the procedur Security would 'line out" the portion that was inadequate and continue to use the procedur 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 PS The inspector determined that audit reports were appropriately documented and distributed to upper management for revie Findings were adequately addressed for closur The inspector noted that the licensee had a Continuous Improvement Suggestion Program, which tracked suggestions from the security staf As of November 20, 1997, 31 suggestions had been implemented year-to-dat 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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determined that security audits were being conducted in accordance with the-licensee's PS Miscellaneous Security and Safeguards Issues (92904)

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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 2 ; The licensee adequately addressed, through procedures and

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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 violatio V. Manaaement Meetinas 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 parameter 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 presente Interim exits were conducted on November 21 and December 12. 199 The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie 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

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the plant general manager to discuss plant performance and other regulatory issue PARTIAL LIST OF PERSONS CONTACTED Licensee Anderson, 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

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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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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

and Inadequate Procedure

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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).

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 Sourc 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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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 Notificatio 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

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50-321/97 207 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).

(

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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

,

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