IR 05000029/1985007

Insp Rept 50-029/85-07 on 850321-0426.Violation Noted: Failure to Provide Adequate Procedure for Conducting Required Surveillance of Meteorological Equipment

ML20126H998
Person / Time
Site:	Yankee Rowe
Issue date:	06/04/1985
From:	Eichenholz H, Elsasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20126H885	List: IR 05000029/1985007 IR 05000321/2004026 ML20126H883
References
50-029-85-07, 50-29-85-7, NUDOCS 8506100480
Download: ML20126H998 (14)

Text

.' 1 U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-07 Docket N Licensee N DPR-3

. Licensee: Yankee Atomic Electric Company

.1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Yankee Nuclear Power Station Inspection at:. Rowe, Massachusetts Inspection Condu ed: March 21-April 26, 1985 Inspector: -[.N b 83 Eic drfholz, Senior Resident Inspector date Approved By: [. Adi$ 83

. ElsaHer, Section Chief, Reactor Projects 3C 'date Inspection mmary: Inspection on March 21-April 26, 1985 (Report No. 50-29/85-07)

Areas Inspected: Routine onsite regular and backshift inspection by the resident inspector (114 hours0.00132 days <br />0.0317 hours <br />1.884921e-4 weeks <br />4.3377e-5 months <br />). Areas inspected included: Review of licensee action on previous findings, operational safety verification reviews, reviews of events re-quiring telephone notification to the NRC, review of plant events, surveillance observations, review of radiological controls, maintenance observations, Plant Operations Review Committee activities, reports to the NRC, review of changes to the licensee organizational structure, and review of design changes 'and modifica-tion Results: One violation was found involving failure to provide an adequate proce-dure for conducting TS required surveillance of meteorological equipment (Section 6). Improvements were noted in the areas of adherence to administrative controls for off normal equipment conditions and control room access features (Section 4).

Exemplary performance was noted in the areas of housekeeping (Section 4) and main-tenance (Section 9). Areas needing increased licensee attention involve the Public Notificatior. System (Section 5), and an incomplete safety evaluation relating to Plant Design Change Request (PDCR)85-005, Addition of Syringe Sample Point in the COMSIP K-111 Hydrogen Analyzer (Section 13).

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DETAILS

. li :PersonsContact5d-Plant Operations

8.' Drawbridge, Assistant Plant Superintendent T.

Henderson, Technical Director Ni St. Laurent,' Plant. Superintendent The inspector:also interviewed other licensee employees during the inspection, including members of the Operations, Radiation Protection, Chemistry,.Instru- ~

ment and Control, Maintenance, Reactor Engineering, Security, Training, Tech-nical Services, and General Office. Staff . ; Summary of ~ Facility Activities

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At the beginning of the inspection period, the plant was operating at-full power. Throughout the period plant operation was relatively uneventful and remained at full power (162 days since the last shutdown).

~ Licensee Action on Previous Inspection Findings (Closed) Unresolved-Item-(50-29/84-19-01) Review station' operating procedures to provide operator guidance for protection of the class 1E system under de-graded grid voltage conditions.without a concurrent postulated Loss of Coolant Accident. -The licensee provided the required procedures (OP-3838, 3844, and 3845) to the NRC on March 28, 1984 in it's transmittal FYR 84-39. These pro-cedures were reviewed in NRC Safety Evaluation dated March.11, 1985, and found Lto provide the necessary protection for class 1E systems. This item is closed.-

-(Closed) Inspector Follow Item (50-29/84-20-03) This item reflected the NRC~

concerns relating to proper procedura1' adherence and record keeping by the

. .onshift operations staff. The licensee's performance in this area was dis-

. cussed in Inspection Report 50-29-02 Section 3, with an update of licensee performance provided in paragraph 4.A(1) of this report. This item is close .(Closed) Violation (50-29/84-20-07).JFailure-to implement a Technical Spect-fication-(TS) required surveillance on a containment isolation valve. The licensee responded to.this violation in it's letter FYR 85-25 dated March 6, 1985. The immediate corrective action was to perform the TS 4.6.1.1.a re-quired surveillance, which found the valve to be closed and locked. The lic-ensee stipulated that they reviewed the applicable procedure OP-4203, Monthly Valve and TK; Penetration Check, found no further problems, and added the valve,:VD-V-917, to the procedure listing. To preclude further recurrence of this type of violation, the licensee committed to add line numbers to each line. item of OP-4203 (over 300 items) and therefore eliminate inadvertent dropping of valves from the list. This item is close .

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(0 pen). Inspector Follow Item (50-29/84-20-09) Follow Dose Equivalent Iodine L(DEI) levels due to apparent fuel cladding failure in core XVII. During this-inspection period, fluctuations in DEI were noted to vary from 6.29 to 12.8% -

of.the allowable TS. limit. The licensee is maintaining maximum bleed and charging flow rates (50 GPM) to maintain the steady state DEI levels at a minimu (0 pen) Inspector-Follow Item (50-29/85-02-01). Review management action re-garding.the. respirator fit program. This item reflected NRC concern associ-Lated with the misalignment of a three-way valve in the respirator fit boot This ~ allowed for the -simultaneous sampling of the air inside the mask and of the booth through:a Scott' cartridge which resulted in a derived protection

' factor that was in error. -The inspector requested the licensee to evaluate the1 consequences of this event as if it had occurred during past fit testin ~

The licensee provided the inspector with an evaluation dated April 5, 198 This evaluation documents the licensee's review 'of all. respirator fits per-

- formed from January 1984 through February 1985 that resulted in protection factors of 1000 or-less, as well as describes the evaluation technique, ein-

.clusions,: and recommendations. The lowest protection factor received by sny

' individual tested was 121. When the protection factor was adjusted according to the results of the evaluation, the individual still has a protection factor of 77.6 which is greater than the NRC limit of 50. A review of the licensee's respirator fit records was performed by the inspector for the time period

~specified above. This review confirmed the licensee's conclusio .This item remains open pending the licensee's revision to procedure AP-8422 to address the position of the valve and the consequences of valve misalign-

. ment and provide retraining of technican ~(Closed) . Inspector Follow Item (50-29/85-04-01). Revise OP-4666 to include-a pre-installation resistance check of 10-30 ohms for Electro Thermal Links (ETLs). The' inspector reviewed Op-4666,.Rev.2, Functional Test of the Fire ..

Suppression and Detection Systems, and noted that the appropriate prerequi- ,

, sites to perform the resistance checks as part of replacing ETLs have been l specified. This item is close l (Closed) Inspector Follow Item (50-29/85-04-03). Verify that radiation areas are appropriately posted. This item. reflected NRC concern for licensee post-ing practices. -The inspector determined that on March 25, 26, and 27 a total of thirteen-Radiation Protection (RP) Department personnel involved in posting activities at the plant attended a specially developed training session on posting requirements and techniques. The inspector noted during routine tours of the facility,-that, the licensee has sucessfully increased sensitivity of RP Department personnel to posting requirements as evidenced by 1) an. increase in the number of postings and barricades at the 2mr/hr threshold, and 2) in-creased clarity in the information conveyed by the postings. Additional com-

-ments pertaining to posting and barricades for the Radiation Controlled Area

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are contained in Section 8 of this report. This item is close ~

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4. Operational Safety Verification Reviews Daily Inspection During routine facility tours, the following were checked: manning, ac- E cess control, adherence to procedures and LC0's instrumentation, recorder .j traces, protective systems, control rod positions, containment tempera- :

ture and pressure, control room annunciators, radiation monitors, radi- .

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ation monitoring, emergency power source operability, control room and ,

shift supervisor logs, tagout logs, and operating order '

(1) During routine reviews of control room activity in this inspection 5 period, personnel attention to detail to off normal conditions, in J the areas of record keeping and logs, was reviewed by the inspecto M A consistent high level of performance was observed and reflects ;

adherence to established administrative requirements of station procedures. The Operations. Department management has provided positive feedback to operations personnel relative to the improved performance in this area. Additionally, as stated in the most re-cent SALP Report 50-29/85-99, improvement in adherence to admini-

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strative requirements involving off normal conditions was being a

M observed toward the end of the assessment perio (2) The licensee has been responsive to NRC expressed concerns in the above enumerated SALP report relative to the control room environ-ment. Signs at the control room entrances have been recently added that stipulate entrance of personnel for official business onl In addition, signs within the control room direct personnel to not -

utilize the control panel / operator stations areas for pass-through purpose:,. In effect the licensee has provided administrative means for effectively limiting access to the control room and important operational areas withi Na violations were identifie System Alignment Inspection Operating confirmation was made of selected piping system trains. Ac-cessible valve positions and status were examined. Power supply and breaker alignment was checked. Visual inspections of major components were performed. Operability of instruments essential to system perfor-mance was assessed. The following systems were checked-

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Emergency Diesel Generator (EDG) unit standby verified during tours of the EDG rooms and control board status revie '

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Containment Hydrogen Monitor's verified during tours of the Stack -l i Building, Switchgear Room, and control board status revie I

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Safety injection Systems verified during tours of the Safety In-jection Building and control room board status revie a

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Emergency Steam Driven Feedwater Pump standby verified during tours *g of the Auxiliary Boiler Roo No violations were identifie S l Biweekly And Other Inspections During plant tours, the inspector observed shift turnovers; compared ii boric acid tank samples and tank levels to the Technical Specifica- -M tion; and reviewed the use of radiation work permits and Health Physics procedures. Area radiation and air monitor use and opera- -

tional status was reviewed. Plant housekeeping and cleanliness were 4 evaluated. Verification of tagouts indicated the action was pro-perly conducte In this inspection period, the licensee's housekeeping efforts ad- -

dressed the areas of the Spent Fuel Pool, and expanded upgrading 3 activity within the turbine building. These activities continue ,

to demonstrate the license's strong commitment to a comprehensive j housekeeping and appearance upgrade progra g l

J The inspector identified no inadequacies in this are _ Observations of Physical Security

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Checks were made to determine whether security conditions met regu-latory requirements, the physical security plan, and approved pro-cedure Those checks included security staffing, protected and vital area barriers, vehicle searches, and personnel identification, access control, badging, and compensatory measures when require No violations were identifie . Review of Events Requiring Telephone Notification to the NRC The circumstances surrounding the following events requiring NRC notification .

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via the dedicated ENS-line were reviewed. A summary of the inspecttr's review findings follows:

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At 2:40 P.M. on March 18, 1985, the NRC was notified in accordance with ,

73.71(c) that a loss of Safeguards Information incident was discovered -

at 7:20 P.M. on March 17, 1985. Although the licensee's security man- -

agement reviewed the missing material and determined that the information ;

did not contain Safeguards Information, a 24-hour report to the NRC was %

made. On March 21, 1985, the licensee issued Physical Security Event j Report No.85-01 to document the event and describe their immediate and

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i long term corrective measure This report will be reviewed by an NRC: -;

Region I specialist inspector during a routine inspection of the licen-see's security activitie At 5:45 a.m. on April 18, 1985, the NRC was notified in accordance with (3

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50.72(b)(1)(v) that a major loss of emergency communications capability  ;

j had occurred as a result of an unknown problem with the Ames Hill (Marl- '

boro, Vermont) tone alert transmitter of the Public Notification System

. (PNS). A subsequent call by the licensee to the NRC at 7:15 a.m. this same day was made to declare the PNS in operation once it was determined that although the primary activating system of the tone alert transmitter .

had failed, the backup system was operabl l A letter dated March 26, 1985 from the repair contractor for the PNS to (

the licensee's corporate Emergency Preparedness Coordinator (EPC) con- _

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tains guidance for on-call repair personnel to notify the plant's control --

room upon certain failures of the PNS. No notification is presently re- -

t quired on a failure of the Primary Notification System provided the "

backup system is available. In this case, the repair contractor could

not initially ascertain which of the PNS systems were functional at the ) F

Ames Hill transmitter. Therefore, based on the preliminary information -

from the repair contractor, the licensee conservatively declared a " major y loss of emergency communications capability" had occurred until it was g determined that the backup system of the PNS tone alert feature was u l availabl _--

• -i Upon reviewing this occurrence with the licensee, the inspector disco- 4 vered some potential problems which could affect the ability of the PNS  ;

F to perform its intended functio J

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5 The PNS repair contractor is not required to notify the control room 1 h or any other organization involved with the PNS on a failure of the i l primary system of the tone alert featur This could result in un- F L

necessary delays in communicating to the public should an event re-f

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quiring public notification occu If system users were unaware +

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of the primary system failure their attempts to use the primary

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system would be unsuccessful. Public notification would then be e b delayed until system users (e.g., States of Massachusetts and Ver- -

[ mont) were informed of the failure and then properly directed to -s

use the backup syste I

? The licensee acknowledged the inspectors concern to clearly identify i

? when use of the backup system is appropriate and also the need to  ;

(- establish a notification mechanism to alert the appropriate organi- -

t y zations when it is required to use the backup system of the tone

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alert transmitte >

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[ The inspector determined the licensee's emergency plan (E-Plan) Y

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description of the tone alert radio feature to be minimal. When i f questioned about this feature of the PNS, site personnel (including I L b F

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. plant operators) did not appear to be knowledgeable on the subject.

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uA licensee representative-indicated that a future update to the E-

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TPlan, or it's implementing procedures, would provide-an expanded

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descriptio The. inspector will follow the -licensee's actions to resolve NRC concerns-rela'ted to the tone ~ alert radio feature of the PNS (50-29/85-07-01). ,

' ' Inspector Review of-Plant Events

-- a . 'At 11:30 P.M. on-March 22', 1985, the control room operators noted an-increase from 100 cpm to 200 cpm on the Primary Vent Stack Noble Gas and

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Particulate Monitors. A check of the charging pumps in the cubicle. area of the Primary Auxiliary Building resulted in a determination that charging pump No. I was exhibiting excessive leakage from ram and head gasket areas. Operators determined that the identified main coolant

. system _ leakage'from this' charging pump was 1,080 gallons per day; which.

, _ is within TS limits. The licensee issued Maintenance Request (MR) 85-350~

to control the safety related maintenance. The charging-pump was re- .

paired and returned to service following post work operability testing at 10:05'A.M. on March 23, 198 ,

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Inspector observations and-comments pertaining to charging pump mainten-ance are contained in Section 9 of this report.

g" . At 10:15 A.M. on April 4, 1985, the plant's Emergency Preparedness Coor-dinator (EPC) notified control room personnel that the primary meteoro--

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logical-tower's Delta T readings were incorrect. The recorded Delta T information in'the control room indicated that the problem with this equipment occurred between 9 and 10 P.M. the previous evening. The in '

spector verified that once informed of the problem control room personnel recognized that the inoperability of the Delta T instrumentation' channel l had.a specified action statement in TS Section 3.3. This information was' contained in control room and shift turnover logs. Based upon the

.TS~ requirements,-the licensee-has seven days to' repair the required l- meteorological monitoring channel or provide a report to the NRC stipu-lating.their corrective actions to restore the channel to operable statu Control room personnel submitted MR 85-403 to initiate corrective action.

, Repairs to the 195 - 33 foot tower elevation air temperature DELTA T in-i strumentation were completed by the licensee's repair contractor on April 10, 1985 at'2 P.M. However, the fact that the instrumentation was oper-able was not transmitted by the plant's EPC to the control room. On L April 11,~'1985 at 3:45 P.M. the Technical Services Supervisor discovered l: the discrepancy and notified the control room. The control room person-p:

nel up to this time were still logging the TS off normal condition in l the shift turnover log since they were unaware the instrument had been L fixed. The plant's EPC was counseled by the licensee management as to

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'the'importance of transmitting relevant information to the control room-that pertains to TS required instrumentation operabilit , - . ~ . . . - - . - - . . - - - - - . - - , , , . - - . , . -

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The inspector reviewed this event for reportability, determined that it-was not a major loss of emergency assessment capability, and therefore did not require the licensee to make an ENS call per 10 CFR 50.72. The basis for this determination involved licensee procedural guidance that allows use of the operable secondary meteorological monitoring syste A review was conducted by the inspector of the licensee's procedure and records associated with the implementation of the daily channel check surveillance for meteorological monitoring instrumentation required by

TS 4.3.3.3. Station Procedure AP-2007, Revision 15, Maintenance of Operations Department Logs, . Attachment "A", requires the control room operators to perform a once per shift channel operability check on the Meteorological Monitoring Panels that consists of verifying power on, and charts operating and indicating. This surveillance is documented on Rowe Station Log Sheet No. When reviewing the actual records for this event, the inspector noted that the meteorological monitoring.in-i- -strumentation was indicated as being operable on the log sheet for the 12 Midnight to 8 a.m. checks on April 4, 1985. However, this entry was in error since the equipment became inoperable on April 3,198 The TSs define a channel check as a qualitative assessment of channel behavior during operation by observation. The determination shall in-clude,-where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameters. A knowledgeable licensee obser-ver discovered the anomalous instrumentation behavior after.two prior checks by control room operators on April 4 failed to discover the in-operable conditio This would indicate that the required TS qualitative assessment was not being adequately implemented by control room operators

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due to inadequate' procedure guidance. Additionally, apparently.no train-ing mechanism existed to provide the control room operators with the knowledge necessary to perfonn the required surveillance. Failure to estab1)sh a written procedure in sufficient detail to insure the proper performance of an operability channel check of the meteorological moni-toring instrumentation is considered a violation (50-29/85-07-02).

On April 24, 1985, the inspector held a meeting with the Assistant Plant Superintendent to discuss his concern Subsequent to the close'of the inspection period, the inspector was notified by licensee representatives  !

that additional instructions, in the form of a special order, were to be implemented on May 16, 1985 that would assist the operators in com-plying with the surveillance reoJiremen . Monthly Surveillance Observation  !

l The inspector observed tests and parts of tests to assess performance in ac- <

, - cordance with approved procedures and LCO's, test results (if completed), re- I

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moval and restoration of equipment, and deficiency review and resolutio The'fo11owing tests were reviewed:

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DP-4509, Daily Check of Charging Pump Leak Rate

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OP-4604, Steam Generator Water Level Channel Monthly Functional Test

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OP-4201, Power Range Channel Calibration Heat Balance

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0P-4210, Fire System and Diesel Fire Pump Weekly Operability Checks

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' 0P-4217, Testing of the Charging Pumps

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OP-4207, Weekly Surveillance Test of the No.3 Emergency Diesel Generator

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and.the AC Power Distribution Systems

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OP-4202, Control Rod Operability Check

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OP-4232, Vapor Container Inspection Regarding the performance of OP-4232, Vapor Container Inspection on April 18, 1985,:the personnel who conducted the inspection noted large boron deposits on the main coolant piping and_ decking near Loop 2 Cold Leg Motor Operated Valve No. 302. No steam leaks were observed. This condition was-brought to the attention of Senior. Station management, who determined that a containment entry wo'uld be made on' April 19, 1985 to perform an inspection in Loop N as a conservative measure. The Plant Superintendent informed the inspector of the licensee's plans. The subsequent Loop 2 inspection determined that the boron deposits, which were dry, appear to be due to an intermittent pack-ing leak.on valve MC-MOV-302. The inspector observed that the licensee's ac-Ltions related to indications of main coolant system laakage usually results in thorough review by station management personnel and conservative subsequent action.to ensure that the integrity of the main coolant system is being main-

-taine No inadequacies were discovere . Radiological Controls Radiological Controls were observed on a routine basis during the reporting perio Standard industry radiological work practices, conformance to radio-logical control procedures and 10 CFR Part 20 requirements, were observe Independent surveys of radiological boundaries and random surveys of non-radiological points-throughout the-facility were taken by the inspecto The inspector observed the licensee's activities associated with implementing temporary _ changes to the boundaries of the plant's Restricted Area. The lic-

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.ensee took this action to facilitate unrestricted access by construction-workers to portions of the west yard areas effected by plant modification effort !

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, . Rugged' temporary chain _ link fences,. barricades by building entrances, and clearly marked signs provided demarcation and instructions to workers ~ relative to. entrance requirements into the revised restricted areas. Previously con-trolled areas that were potentially or actually' contaminated were evaluated, and decontamination implemented, if required,; prior to releasing the areas-to: unrestricted acces ~These observations are considered to be positive evidence of appropriate prio'r l planning;and prioritization of activities involving controlled areas of the

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plant.~ No' inadequacies were identified by the inspecto . : Monthly' Maintenance Observation

The: inspector observed and reviewed maintenance and problem investigation ac--

tivities.to verify. compliance with regulation, administrative.and maintenance procedures, codes and-standards,. proper-QA/QC involvement, safety tag use,

. equipment alignment, jumper use,: personnel qualification, radiological con-trols for worker protection, fire protection, retest requirements, and re-

. portability.per Technical Specification. The-following activities were in-clude MRs85-350,~-379, -386, and -461, No. I charging. Pump Excessive Leakage,

.  : dated ' March '23, . 29, April 1,19,- respectivel .

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MRs85-406, -413, and.-447,.No. 3 Charging: Pump Excessive-Leakage, dated April 5,6, and 16, respectively,.

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MR 85-358, Nuclear' Recorder on~MCB Panel 1F-Spurious Pen Movement

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MR 85-400, No. 3 Service Water Pump Packing Leak

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MR 85-417, Fire Main between Waste Disposal and Fan Room Broken

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.MR 85-443, No. 3. Intermediate Range Level Indication - Remote & Local Indications Do Not Agre Regarding the performance of maintenance on Charging Pumps Nos. I and 3, the

' inspector has noted'an increasing trend in excessive leakage conditions. Plant procedures require the issuance of an MR if total ~ leakage from the three pumps-exceed a 400 GPD limit. TSs identified operational leakage from the Main Coolant' System (MCS) is 5,760 GPD. -Routinely, due to the conservative nature of theilicensee. in the maintenance area, MR's will 'be issued prior to the 400 GPD. limi The. inspector reviewed the maintenance-records-for charging pumps Nos. 1 and-

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y 3, and determined that 7 and 9 events, respectively, have' involved excessive leakage since-January 1, 1985. Increased MCS letdown, charging, and purifi-

-cation system flows to mitigate fuel cladding degradation experienced during ;

this. operating cycle have required the use of both variable speed charging,

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-11 pumps (Nos. I and 3) on a full time basis. This, in part, will result in higher maintenance activity for these pumps. Worse case leakage conditions on an individual pump basis have been on the order of 20% of the TS limi Based upon discussions with the Maintenance Department Supervisor and review of maintenance records, the inspector learned that leakage conditions have primarily been attributed to problems with wear on the pump seals and ram Extensive Maintenance Department review of the repetitive maintenance required for these charging pumps has been evident. Licensee actions have included:

1) development of failure analysis reports, 2) identification of the existence of rough surface finish on one lot (19) of rams in excess of the established requirement and issuance of a Non Conformance Report (85-8) to document and correct the deficiency, 3) review the service life of seals and hold discus-sions with_ the seal manufacturer to ascertain if changes in materials have occurred, and 4) conduct a review to ascertain if a new coating process could be used in the rams to extend service life. Inspector review of maintenance actions in this area-has demonstrated that appropriate immediate and long term corrective measures have been identified and implemented by the licensee in response to charging pump performance involving excessive leakag As a result of reviewing the maintenance activities involving the charging pumps, one minor concern by the inspector was addressed with the licensee which involved maintenance personnel manipulating additonal valves on the charging pump drain line not specified in procedure DP-4509. Following dis-cussions with the Maintenance Department Supervisor on April 23, 1985, the inspector was informed that maintenance personnel will only manipulate the one valve specified in their procedure. Should additional charging' pump drain valves require manipulations, Operations Department personnel will perform the actions. The inspector understood that these tenditions will be in effect until procedure DP-4509 is revise >

No violations were identified as a result of the inspector's review of main-tenance activit . Onsite Review Committee On March 21, April 2, and April 9, 1985, the inspector observed meetings of the Yankee NPS onsite review committee to ascertain that the provisions of TS 6.5.1 were me Other than the inspector's observations documented in Section 13 of this in-spection report relating to the Committee's review process, no additional in-adequacies were identifie . Review of Periodic and Special Reports Periodic and special reports submitted to the NRC pursuant to Technical Specification 6.9 were reviewed. The review ascertained: Inclusion of in-formation required by the NRC; test results and/or supporting information; consistency with design predictions and performance specifications; adequacy

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of planned corrective action for resolution of problems; determination whether any information should be: classified as an abnormal occurence; and validity

'of reported information. The following periodic reports were reviewed:

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1984 Annual Report submitted per TS 16.9.2.b and 10 CFR50.59(b), FYR 85-37, dated March 15, 1985

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Mcrch,1985 Monthly Statistical Report submitted per TS 6.9.3, FYR 85-42, dated April.2, 198 The inspector noted that the licensee requested, and received, a two week extension from NRC: Region I for the submittal of the 1984 Annual Repor No inadequacies were identifie . Organization and Administration During the inspection period, the inspector reviewed changes to the licensee's

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staff or organization structure as described below. The review included:

verification that licensee's onsite organization structure is as described in the facility TS, and verification that personnel qualification levels are in conformance with ANSI N18.1-1971, as described in TS Section 6. On April 5,1985, the licensee announced the appointment of their Senior Licensing Engineer to a new position of Technical Services Manager (TSM),

and in that capacity will report to the Plant's Technical Directo Tiie inspector was informed that the TSM will incorporate the responsibilities of the existing Technical Services Supervisor (TSS). The TSS is a facility staff member specified in TS Sections 6.2, 6.3, and The licensee indicated, that, a Proposed Change to the TSs will be sub-mitted to the NRC to reflect the reorganized technical services organi-zatio On April- 19, 1985, the inspector was informed by the licensee, that, the Radiation Protection Manager (RPM) had resigned with a termination date set for May 24, 1985. The licensee indicated that active consideration of candidates for appointment to the RPM position was in progres No inadequacies were identifie . Design Changes and Modifications The design changes and modifications described below which were approved for implementation were reviewed to determine that: (1) the changes were appro-

! priately reviewed and approved in accordance with the effective administrative procedures and technical specifications; (2) these changes were being ade-quately controlled during implementation; (3) the installation and testing

, procedures were adequate and appropriate to assure an acceptable design; and

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'(4) the safety impact of these changes was evaluated as required by 10 CFR L

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50.59. Additionally, the inspector field-checked portions of one of these Lchanges reviewed to assure that installation activities were consistent with their governing procedure Engineering Design Change Request (EDCR)84-326, Vent Stack High Level Iodine Sampler l This EDCR-installed a new grab sample system to monitor high range iodine and particulate effluent from the Primary Vent Stack (PVS). This system will replace the present bubbler system with an in-line particulate ,

filter / cartridge sampler, which was installed by PDCR 81-12. The new system will ensure the sample is obtained isokinetically, and the us of smooth sample line runs will assure representative sampling of the PVS effluent. This improved grab sample system will meet the require-ments of NUREG 0737, Item II.F1, Attachment 2, Sampling and Analysis of Plant Effluent The PORC approved EDCR contained a safety a aluation, as required by 10 CFR 50.59, which specified that tne proposed sample system and its location have been reviewed to assure that personnel taking samples will not be exposed to radiation doses in excess of the limits defined by

'NUREG-0737. The EDCR, in one of its enclosures, contained the required habitability evaluatio The inspector witnessed portions of installation of the EOCR, as per-formed by licensee contractor personnel, and verified the activity was in accordance with an approved plant procedur No violations were identified, Plant Design Change Request (PDCR)85-005, Addition of Syringe Sample Point in the COM51P k-III Hydrogen Analyzer This modification will add a syringe type of sample point on the inlet line of the Comsip III Hydrogen Analyzer. Implementation will provide compliance with NUREG 0737, Item II.B.3, which requires that samples taken from the containment be returned to the containment or to a closed system. The present sampling point is on the hydrogen purge piping in the switchgear room which vents directly to the PV This PDCR package was reviewed and approved by the PORC at its Meeting 85-13 on April 9, 1985, which was attended by the inspector. The in-spector reviewed the design change package. Enclosure B consisted of a licensee memorandum, YRP 141/85 dated February 11, 1985, Systems En-gineering NUREG-0737 Compliance Audit Resolutions, and contained con-clusions as a result of the review of the in-house audit findings. Con-clusion No. 2 stated "A syringe sample point should be added to the Com-sip Analyzer for containment grab samples. Also, REG must evaluate operator doses when obtaining this sample".

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The inspector reviewed the PDCR's safety evaluation, and noted that it failed to address the aspect of the design basis associated with con-tainment atmosphere sampling and analysis that assumes it's possible to obtain and analyze a sample without radiation exposure to any individual exceeding the criteria of GDC-19. The PORC did not address this issue, develope an open item, or conditionally approve the PDCR awaiting the results of the required radiological habitabilit Based upon this finding, the inspector held discussion with plant management represen-tatives who were informed of the inspector's concerns relating to the incomplete safety evaluation review of a plant modification. Weaknesses in safety analysis review were identified in the recent-SALP Report (50-29/85-99) as an NRC concer Subsequently, the licensee informed the inspector that PDCR,85-005 was

- placed on hold, that a new safety evaluation would be developed, and the PORC would review the revised PDCR. The licensee has issued Service Re-quest No.85-051 that request the Radiation Engineering Group at YNSD to perform the required analysi No additional deficiencies were identified by the inspector as a result of reviewing this PDC . Management Meetings During the inspection period, the following management meetings were conducted or attended by the inspector as noted below:

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The inspector attended an exit meeting held on March 22, 1985, by a re-gion-based specialist at the conclusion of Inspection 50-29/85-06, review of the licensee's Startup Physics Testing Program, onsite inspectio At periodic intervals during the course of the inspection period, meet-ings were held with senior facility management to discuss the inspection scope and preliminary findings of the resident inspecto .