IR 05000272/1980023

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IE Insp Repts 50-272/80-23 & 50-311/80-18 on 801012-1115. Noncompliance Noted:Failure to Lock Access Doors Into High Radiation Areas
ML18085A862
Person / Time
Site: Salem  PSEG icon.png
Issue date: 12/03/1980
From: Hill W, Keimig R, Norrholm L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18085A857 List:
References
50-272-80-23, 50-311-80-18, NUDOCS 8102230295
Download: ML18085A862 (15)


Text

Report No Docket Nos.*

License No Licensee:


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U. s*. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 50-272/80-23

. 50-311/80-18 50-272 50-311 DPR-70 DPR-75

REGION I

~~~~~~~~~~-

Public Service Electric and Gas Company 80 Park Plaza - 15A Newark, New Jersey 07101 Facility Name:

Salem Nuclear Generating Station - Units 1 and 2 Inspection At:

Hancocks Bridge, New Jersey 1980

.

~

W. M. Hi

, Jr~, Resident Reactor Inspector Approved By: r14.cz ~

~

R~~ keinrtief:eactor Projects Section No. 1, RO&NS Branch Inspection Summary:

Inspections on October 12 - November 15, 1980 (Combined Report Numbers 50-272/80-23 and 50-311/80-18)

.

Unit 1 Areas Ins§ected: Routine inspections by the resident inspectors of plant operations inclu ing tours of the facility; log and record reviews; review of licensee events; operational safety verification; IE Bulletins; Lessons Learned implementation; refueling activities; and followup on previous inspection item The inspections involved 103 inspector-hours by the resident inspector Results:

One item of noncompliance was identified (Infraction - Failure to Secure High Radiation Areas; Details paragraph 7).

Unit 2 Areas Inseected: Routine inspections by the resident inspectors of plant startup testing including tours of the facility; operating license conditions; Lessons Learned implementation; IE Bulletins; and, followup on previous inspection

  • items. The inspections involved 53 inspector-hours by the resident NRC inspectors-.

Results:

No items of noncompliance were identified *

1--

  • DETAILS 1. Persons Contacted J. Driscoll, Chief Engineer J. Gallagher, Assistant Maintenance Engineer S. LaBruna, Maintenance Engineer H. Midura, Manager - Salem Generating Station P. Moeller, Nuclear Licensing Engineer W. Reuther, Site QAD F. Schnarr, Sta ti on Operating Engineer R. Silverio, Assistant to the Manager J~ Stillman, Station QA Engineer R. Swetnam, Senior Performance Supervisor-HP The inspector also interviewed and talked with other licensee personnel during the course of the inspections including management, clerical, main-

.. tenance, operations, performance ~nd qua 1 i ty assurance personne 1 *

2. Status of Previous Inspection Items (Closed} Unresolved Item (272/80-11-01) SORC alternate and quorum require- *

ments. The inspector reviewed Revision 7, dated October 8, 1980 to AP-4, Station Operations Review Committee. The following aspects of previous concern have been incorporated; assignment of alternates for specific members, prohibition of voting quorum through use of members with identical titles (e.g. Senior Main-tenance Supervisor), deletion of quorum completion through telephone contact with assembled member The inspector had no further questions on this ite (Closed) Unresolved Item (272/78-29-01) Vital Instrument inverter failure The: licensee's evaluation of Vital instrument inverter failures previously reviewed resulted in an inverter improvement progra The inspector reviewed OCR 1 EC 563 issued for implementation on September 10, 1980. The design change adds boost/buck transformers for improved input regulation and provides forced, filtered cooling to each vital instrument and essential controls inverter.*.Work is in progress to complete prior to conclusion of the outag Comparable design change 2 EC 564 has been initiated for Unit The inspector had no further questions on this ite (Open}

Unresolved Item (272/80-20-03)

Response to IE Bulletin 80-11, Masonry Wall By correspondence dated November 4, 198u, the licensee modified the original response indicating that safety related control air piping is attaGhed to one masonry block wall which divides the two units. The licensee stated that a complete analysis will be prepared by December 3, 1980. The inspector confirmed a licensee co11111ittment to resolve this item prior to heat. up of either unit. Subsequently, a prompt report (LER 80-56/

OlP) was submitted on November 7, 198u, when it was discovered that* reinforcement inside the wall did not meet design criteria, further degrading the expected performance under upset condition This item will be reviewed further when evaluations are complete and prior to unit heat u *

(Open)

SITE

.*

Unresolved Item {272/80-20-04) Evaluation of non-contaminated systems in accordance with IE Bulletin 80-10. The inspector re-

. viewed Revision 3 of safety evaluation SGS/M-SE-057, dated October 2, 1980. The evaluation concludes that present sampling and

monitoring of other systems precludes any requirement for sampling si.te storm drains. The inspector stated his position that a periodic

. sampling system for storm drains would be an effective confirmation that no unmonitored pathway to the environment had develope Licensee representatives stated that a periodic sample would be taken and measured for activity levels. This item remains open pending confirmation that such a sampling program is in plac. Shift Logs and Operating Records a. The inspector reviewed the following plant procedures to deterinine the licensee established requirements in this area in preparation for a review of selected logs and record AP-5, Operating Practices, Revision 10, May 21, 1980; AP-6, Operational Incidents, Revision 6, February 22, 1979; AP-13, Control of Lifted Leads and Jumpers, Revision 4, February 11, 1980; Operations Directive Manual; and, AP-15, Tagging Rules, Revision 0, April 13, 197 The inspector had no questions in this are b. Shift logs and operating records were reviewed to verify that:

Control room log sheet entries are filled out and initialled; Auxiliary log sheets are filled out and initialled; Log entries involving abnormal conditions provide sufficient detail to communicate equipment status, lockout status, correction and restoration; Log book reviews are being conducted by the staff; Operating orders do not conflict with Technical Specitication requirements; *

Incident reports detail no violation of Technical Specification LCO or reporting requirement; and,

Logs and records were maintained in accordance with Technical Specifications and the procedures in 3.a abov c. The review included the fol lowing plant shift logs and operating records as indicated and discussed with licensee personnel:

Log No. 1 - Control Room Daily Log, October 12 - November 15, 1980 Log No. 6 - Primary Plant Log, October 12 - November 15, g:eao Log No. 7 - Secondary Plant Log, October 12 - November 15, 1980 Log No. 8 - Unavailable Equipment Status Log, October 12 - November 15, 1980

.

.

Tagging Requests - All active (SSS file)

Night Orders, October 11 - November 14, 1980 Lifted* Lead and Jumper Log - All active Nonconf ormance Reports for September and October 198u The inspector had no questions relative to logs reviewed during this inspection perio. Plant Tour a. During the course of the inspections, the inspector made observations and conducted multiple tours of pl ant areas, including the following; tl) Control Room (daily)

(2) Relay Rooms (3) Auxiliary Building (4) Vital Switchgear Rooms (5) Turbine Building*

(6) Yard Areas (7)

Radwaste Building (8) Penetration Areas

'

(9) Control Point (10) Site Perimeter

(11) Fuel Handling Building (12) Containment b. The following determinations were ~ade:

Monitoring instrumentation: The inspector verified that selected instruments were functional and demonstrated parameters within Technical Specification limit Valve positions. The inspector verified that selected valves were in the position or condition required by Technical Specifications for the applicable plant mode. This verification included control board indication and field observation of valve *position (Charging/

Safety Injection, Auxiliary Feedwater, and Containment Spray systems).

Radiation Controls. The inspector verified by observation that control point procedures and.posting-requirements were being followed~

Plant housekeeping conditions. Observations relative to plant housekeeping identified no unsatisfactory condition Fluid leaks. No-f1uid leaks were observed which had not been identified by station personnel and for which corrective action had not been initiated, as necessar Piping vibratio No excessive piping vibrations were observed and no adverse conditions were note Selected pipe hangers and seismic restraints were observed and no adverse conditions were note *

Equipment tagging. The inspector selected plant components for which valid tagging requests were in et*fect and verified that the tags were in place and the equipment in the condition specifie Control room annunciators. Selected lit annunciators were discussed with control room operators to verify that the reasons for them were understood and corrective action, if required, was being take By frequent observation through the inspection, the inspector veri-*

fied that control room manning requirements of 10 ~FR 50.54 (k) and the,Technical Specifications were being me In addition, the in-spector observed shift turnovers to verify that continuity of system status was maintained. The inspector periodical IY questioned shift personnel relative to their awareness of plant conaitions and know-ledge of emergency procedure *

.t'..

Release On a sampling basis, the inspector verified that appro-priate documentation, sampling, authorization, and monitoring instrumentation, were provided for effluent release Technical Specifications. Through log review and direct observations during tours, the inspector verified compliance with selected Techni-cal Specification Limiting Conditions for Operation. The following parameters were sampled frequently:

RWST level, BAST level and temperature, containment temperature, boration flow path, shutdown margin, offsite powe In addition, the inspector conducted periodic visual checks of protective instrumentation and inspection of elec-trical switchboards to confinn avai !ability of safeguards equipmen Security. During the course ot these inspections, observations relative to protected ana vital area security were made, including access contra Is, boundary integrity, search, **escort, and badgin No notable conditions were identifie c. The following acceptance criteria were used for the above items:

Technical Specifications Operation Directives Manual Inspector Judgement d. The inspector had no questions relative to tours made during this inspectio. Plant Maintenance:

The Unit 1 high and three low pressure turbines were opened and inspected during this outage. Part of the turbine inspection program involved Non-DestructiYe Examination lNDE) ot the turbine rotors. The tests revealed a crack in the second stage rotor of ~13 LP turbine. The rotor was removed and a collar installed around the shaft to maintain spacing between the adJacent rotors. A new rotor is scheduled tor installation at the next outag A baffle was installed in the casing to* effect a pressure drop which had been caused by the second stage before removal. This baff.le will pennit the pressure drops across the remaining stages to remain within the design limit The inspection, repairs, and reinstallation were performed by the turbine manufacture The inspector had no further questions.

  • 6. Refueling Activities a *. The reactor fuel shuffle was completed during this inspection perio To preclude grid strap interaction problems experienced the previous year, the core was entirely offloaded to the spent fuel pool and then reloaded with 64 new assemblies. Off-load was conducted between October
  • 18 and 23, 1980. The core was re-assembled between October 28 and November 4, 198 Inspection activities included verification o-f Technical Specifi*cation requirements for fuel handling, observation of several shifts during fuel moves, verification of periodic tes~ing, containment integrity, housek~eping, procedure adherence, tool control, and adequate staffing during refueling operations. Fuel handling was conducted by Westinghouse personnel under the direction of a licensee supervisor qualified as an SR At the conclusion of this inspection period, fuel handling was complete and the reactor pressure vessel head was in place with bolt tensioning in progres *

Specific comments are provided below relative to activities observe One fuel assembly grid strap was discovered damaged during the refuelin The particular assembly was selected.for monitoring because the face of the adj a cent assembly had grid strap damage noted during the previous*

refueling outage (NRC Inspection Reports 50-272/79-15, 79-18, and 79-32).

The size of the damage was small and within the criteria established as acceptable by the safety evaluation performed during the last refueling outage when.grid strap damage was observed. Partial repairs to the grid strap were effected. The integrity of the fuel element cladding was not affected. The damage appears to have occurred during the previous refueling. The refueling procedures have since been changed to further minimize the possibility of interface between adjacent fuel assemblies'

grid straps during fuel movement. A continuous surveillance program is performed each refueling outage to monitor the condition of the fuel assemblies. The program consists of a detailed study of closeup video tapes*. Grid straps are included in this stud The inspector had no further questions relative to the fuel assembly surveillance. program and the reuse of the assembl c. After-reassembly of the upper internals, each control rod was manually withdrawn and inserted to determine the extent of "drag" or resistanc Two rods experienced higher than anticipated "drag.

The high resistance readings were localized at the bottom of rod travel. Detailed measure-ments taken to determine the extent of the resistance were evaluated by vendor representatives. Following additional tests and exercising, it was concluded that continued use of the fuel assembly and control rod was acceptable; h'owever, testing of these rods would be performed as soon as possible after reassembly of the vessel head, rod drive mechanisms, and ventilation equipment *

Control rod testing will be performed on all rods after plant heatup and prior to power _op*eration-;.

Excessive drag coul cj cause the rod

"drop time" to exceed the maximum acceptaole value. The conouct am:~

.results of rod drop time testi'ng will tre reviewed during a subsequent

  • inspection. This item is unresolved, pending evaluation of rod drop times (272/80-23-02}. As a followup to repair work done during the 1979 outage resulting from IE Bulletin 79-13 considerations, radiography of all Unit 1 steam generator feedwater nozzle to piping welds was performed during this outag On October 29, 1980 a radfograpfr. of # 13 nozzle to elbow weld was evaluated as unaccepta~le due to a 1-1~ inch linear indicatio Ultrasonic examination confirmed the preser:ice of a 6-7 inch linear indication in the weld area. The weld was excavated and a *crack from the inside diameter was confirmed using dye penetrant techniques. The total length was less than 7 inches and the crack was confined to the root of the butt weld on the elbow side (Approximately 20% of wall thickness}. The licensee's evatuati'on concludes the cause to be lack of fusion during the 1979 repair. Following excavation of the indication, a weld repair was made. Subsequent radiography and ultrasonic testing identified no reportable indicatio~ in the repaired wel Licensee Event Report 50-272/80-55 has been subm1tted. Final documentation ot the weld repair will be reviewed during a subsequent inspection l272/80-23-06}. The inspector had no further question on this item at this time. *

7. Radiation Protection On two separate occasions the inspector observed open access doors to HIGH RADIATION AREA One high radiation area on elevations 55' and 45* contains the Auxiliary Building Drain Tank and the Residual Heat Removal System com-ponents. The radiation levels near the drain tank exceed 1000 mrem/hr as confirmed by a review of the most recent survey. The inspector found this door open on November 3, at 12:45 The radioactive liquid waste processing area on e'tevation 100' in the Auxiliary Building contains areas where the radiation levels exceed 1000 mrem/hr as confirmed by a review of the mos~ recent survey. Access to this area is controlled by a chain link fence and a locked doo On November 7, at 7:00 a.m., the inspector found this door unlocke The above findings constitute_ apparent noncompliance with Techni ca 1 Speci-fications 6.12.1 (272/80-23-01}.

.9 8. Design Changes and Modifications The inspector observed that refueling progress was frequently impaired by mechanical problems with the Spent Fuel Assembly Handling Tool~ When the Spent Fuel Assembly Handling Tool was positioned to engage the spent fuel assemblies, a problem with the locator pins would not allow the tool to grip the assemblies. The vendor had issued a field modification to correct the problem, but the licensee had not installed the equipment modificatio The modification was installed and no further problems were encountered

<wjth the Spent Fuel Assembly Handling Too A fonnal design change package for the modification to the handling tool was not available for review prior to the conclusion of this inspectio This is an unresolved item l272/80-23-03).

9. Fire Protection The inspectors conducted a continual review of site fire protection and suppression systems during routine plant tours. Included were verification that selected fire extinguishers were accessible and inspected on schedule, that fire alann stations were unobstructed, that cardox systems were operable, that adequate control over ignition sources and fire hazards was maintained, and that appropriate compensatory steps such as fire watches were taken when fire systems were rendered inoperabl Particular emphasis during the above inspections was placed on those critical fire areas in which augmented fire detection and suppression had not_yet been*

installed as specified in the fire protection Safety Evaluation Report (included in Supplement 4 to the Salem SER). These areas include; Auxiliary Feedwater Pumps, Charging Pumps, Relay and Switchgear rooms,. and the Component Cooling room Augmented fire protection 1s being installed during the current outage and prior to full power operation of Unit On November 7, the inspector observed two open fireebarrier doors permitting maintenance cables to extend from one area to anothe One door was completely removed from it's hinges and placed against a nearby wal On other daily tours, additional fire doors were observed open with no personnel or mainten-ance activities nearb The doors were apparently opened*for access, but failed to close automatically. This item was identified in NRC Inspectiorr Report 50-272/80-27. This area will be continually reviewed during subsequent inspections to confinn effectiveness of licensee 'corrective action. IE Bulletin Followup The IE Bulletins discussed below were reviewed to determine that:

Licensee management forwarded copies of the response to the bulletin to appropriate ons.i te management representative Information discussed in the licensee's reply was supported by facility records or by visual examination of the facility.

  • Corrective action taken was effected as described in the repl The licensee's reply was prompt and within the time period described *

in the bulleti The reviews included discussions with licensee personnel and observation and review of items discussed in the details belo By correspondence dated April 17, 1980, the licensee responded for both units to IE Bulletin 80-04, Analysis of a PWR Main Steam Line Break With Continued Feedwater Additio The licensee refers to prior correspondence (January 31, 1980) with NRR relative to Unit 2 on this subject.. Th.

licensee's analysis, which is applicable to both units, concludes that adequate consideration has been provided for mass flow input from continue auxiliary feedwater addition in the safety analysis already provided in the licensing basi No corrective action was required.-as *a* result of this revie The inspector had no further questions on* this ite By correspondence dated June 30, 1980, the licensee responded for both units to IE Bulletin 80-08, Examination of Containment Liner Penetration Weld Twenty two penetrations in each unit were identified as having a containment boundary butt weld. *Three penetrations in Unit 1 and one penetration in Unit 2 had not been radiographe One of these in each unit (Penetration 18) was determined to be unsuitable for radiography due to the presence of five pipes, a cooling coil, and cooling fin Jhe inspector reviewed radiograph reading reports for the two remaining penetrations in Unit one conducted in September 1980 with no notable problems identified. Penetration 18 in each unit was re-examined using magnetic particle techniques and no problems were*ide"'t1fied *.

The inspector had no further questions on this ite By correspondence dated June 9, 1980 and July 18, 1980, the licensee responded for both units to IE Bulletin 80-12, Decay Heat Removal System Operability. The Salem design precludes duplication of the sequence of events described in the Bulletin, however, the license~ acknowledges that loss of decay heat removal events can and have occurred at Sale The licensee has instituted procedural and administrative controls to maximize the availability of decay heat removal capabilitie By correspondence to NRR dated October 15, 1980, a request for Unit 1 license amendment was transmitted to incorporate Technical Specification changes on this subject as requested by NRR in correspondence dated June 11, 1980. For Unit 2, the licensee, in \\correspondence dated October 15, 1980, states his understanding that the issue is being addressed by NRR in the full power license revie To promptly institute administrative controls over decay heat removal, the licensee has elected

  • to impose the proposed Technical Specifications in station operations effective immediatel No conflict with existing Technical Specifications result from this action *

The inspector had no further questions on this ite '

....

11 By correspondence dated September 5, and October 14, 1980, *the licensee responded for both units to IE Bulletin 80-20, Failures of Westinghouse Type W-2 Spring Return to Neutral Control Switche The original response indicated only the diesel generator 4 KV output breaker control

.switch as applicable under this Bulletin. Neutral contacts on these switches (one per diesel generator) are not used. Subsequent review by the inspector and station personnel identified Westinghouse W-2 switches in use on the diesel generator manual speed and voltage control for each diesel. These switches were addressed in the later response to the Bulletin. The speed and voltage control switches are used only for manual operation of the generator and the neutral position contacts are bypassed during safeguards operation of the diesel generators; No other application of W-2 switches in the Salem plants was identified by the licensee, nor by the inspector's revie The inspector had no further questions on this ite. Verification of Short Term Lessons Learned (NUREG~0578)

During this inspection, the inspector verified certain TMI Lessons Learned Category "A" items (NUREG-0578) as further detailed in the Action Plan (NUREG-0660).. In addition to the above documents, the inspector used the licensee's responses to NRR relative to the scope and schedule for implemen-tation. A number of the Task Action Plan items had be.en previously confirmed as part of the Near Term Operating License process for Salem Unit Listed below are the items confirmed, and* comments as to implementation statu Item 2.1. Shift Technical Advisors LA. Comment As detailed in Inspection Report 50-311/80-04, interim STA's for both units were on duty as of*

January 1, 198.2. Shift Supervisor Responsibilities This item was reviewed and found*

I.A.1~2

acceptable in Inspection Report 50-311/80-07, and applies to all shift supervisors in both unit I.A. Shift Manning-Overtime

" This item was discussed and found acceptable in Inspection Report 50-311/80-0 By correspondence dated August 20, 1980, the licensee details shortfalls in operator manning and the need for 12-hour scheduled shifts until Spring 1981. This sub-mittal is under NRR review and will be addressed in the Full Power license SE *

  • Item I. Accident and Procedure Review 2.2. Shift Relief and Turnover I. **Comment This item was reviewed and found acceptable in Inspection Reports 50~311/80-03 and 80-16. This finding is applicable to both unit This item was reviewed and found acceptable in Inspection Report 50-311/80-07. This finding is applicable to both unit.2. Shift Supervisors Responsibilities This item was reviewed and found I. acceptable in Inspection Report 50-311/80-07. This finding is applicable to both unit.2. Control Room Access I.. l. Post-Accident Sampling II..1. Valve Position Indication II..1. AFW Initiation and Flow 2.1. II.E. This item was reviewed and found acceptable in Inspection Report
  • 50-311/80-07. T_his finding is applicable to both unit This item was reviewed and found acceptable in Inspection Reports 50-311/80-16 and 80-17 relative to RCS sampling. This finding applies Q

to both units. Relative to contain-ment sampling, temporary measures and procedures for* Unit 1 were verifie Sampling capability for the Unit 2 containment will be installed prior to operation above 5% power. This item will be confirmed by inspection

.

prior to power ascension (311/80-18-01)

Temporary limit switches were installed*

in Unit 1 on the Category "A 11 schedule and in Unit 2 prior to startu Qualified limit switches will be in-stalled and verified~by inspection prior to restart of either uni (272/80-16-02) (311/80-18-02)

The AFW system on both Units 1 and 2 initiates automatically on low steam generator level by design. Single channel flow indication to each steam generator is provided on the control*

board. The licensee's responses to this item state that flow indication is safety grade.

"**r-tem

,.._...,.......

2,1 *.l Emergency Power for Pressuri.,.

  • II,E.3.1 zer Heaters 2.1, Recombtners 2. Il.E..1.3,b II.F,2 2. II..2..2. UI.A. Isolation Dependability

!nstrumentation to Detect Inadequate Core Cooling Power Suppltes for Pressurizer Reli'ef Valves and Level Emergency Support Facil ifi es lTSC and OSCl.

2.1. Primary Coolant Outside III.D.1.1 Containment

    • comment Plant desig'n for both units included a bank of heaters available from vital powe Design modifications have ~een accomplished to add a heater group from another vital bu Original design for both units in-cludes permanently installed hydrogen recombi"ners. Action levels and pro-cedures for use of the recombiners are included in ~tation operating and emergency instruction *

Initial review of this area identified two valve control circuits in each unit requi"ring modification. These were modifi-ed on the Category "A" schedule in Unit 1 and prior to start-

  • up for Unit 2. Subsequent reviews pursuant to IE Bulletin 80-06 have identified additi*onal ESF components
  • requiring modification. These will be accomplished prior to restart of..

the respective units. Verification*

will be accomplished during closeout of Bulletin corrective action Both uni'ts had ins ta 11 ed subcoo 1 ing meters pri"or to the Category 11A 11 date or startup, as applicable. Currently i'nstalled meters utilize plant com-puter tnput By design in both units, power supplies to these components are served by vital powe Tflese faci'l i*ttes were reviewed and found acceptable in Inspection Report 50-311/80-04. This finding applies to f;oth units s foce the faci 1 i ti es are share ".

This item was reviewed in Inspection Reports 50-272/80-20 and 50-311/80-16 relative to the leak reduction program.*

Leak rate measurements of systems will be completed prior to restart of the respective units. These measurements will be verified by inspection when completed (272/80-23-04) (311/80-18-03).

  • rtem 2.1. Inplant Radiation Monitoring 2.1. IlI.D. * * COtimlent This item was reviewed and found acceptable in Inspection Reports*

50-311/80-07 and 50-311/80-1 This finding applies to both units *

. The inspector had no further questions relative to short tenn items at this *

tim. Full Power*trcense*conditions*(unit 2}

Staff reviews for full-power licensing are continuing. Related to this effort, the inspector reviewed certain aspects of action items detailed in NUREG-0694 and proposed licensee resolution. The following comments apply to the areas reviewed:

Tasl< II.E.1.1 - Auxiliary Feedwater System Reliability. The inspector confirmed the following licensee actions:

Valves lAFl and 2AF1 have been welded in the open position and dist position verified by radiography. The handwheels have been remove Overall operating Instruction I-3.2 specifies the use of AFW For Steam Generator makeup during startup. This practice has been observed by the inspecto SP(Q}4.7.1.2ta}, Revision 5 lists all AFW valves included in the licensee's November 1, 1979 submittal to NR In addition, on-the-spot change P-2 to the procedure requires a second verification valve lineup on return to servic The inspector had no further questions in this are. Shipment-of Radioactive Material The inspector reviewed licensee procedures and practices with respect to the shipment by US Mail)UPS, and common carrier of limited quantities of radio-active materials (e.g. liquid samples sent for laboratory analysis).

The governing procedure, PD-15.7.004, Shipment of Radioactive Material, con-tains a brief reference to the requirements for shipping exempt quantitie The discussion in the procedure is incomplete and does not include all consid-erations for packaging such material. Interviews with personnel indicated that the procedure is not routinely applied in making a determination that a particular shipment qualifies as a limited quantity under 49 CFR 173.39 No record of such detenninations, nor quantitative confirmation that the applicable limits had been met, could be identified *

  • Based on the character of shipments made *in this *way, and the mode.of pack-aging used, the inspector could not conclude in any case that the licensee failed to comply. The inspector stated his position that station procedures should be modified to confirm compliance with applicable regulations prior to offering limited quantities for shipment by approved methods. This item is unresolved pending further review of licensee practices in this area (272/80-23-05).

14. Unresolved I.terns Areas for which more information is required to determine acceptability are considered unresolved. Unresolved items are contained in Paragraphs.6., ?

  • an.cl.J? At 19Js~.r~p9r. Exit Interview At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss inspection scope and findings *