IR 05000029/1990001

Insp Rept 50-029/90-01 on 900103-0212.Unresolved Items Noted Re 10CFR21 Rept on Safety Class 2 U-tube HX & fitness-for- Duty Program.Major Areas Inspected:Operational Safety, Security,Plant Operations,Maint/Surveillance & LERs

ML20012B764
Person / Time
Site:	Yankee Rowe
Issue date:	03/06/1990
From:	Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20012B762	List: IR 05000029/1990001 ML20012B761
References
50-029-90-01, 50-29-90-1, NUDOCS 9003160239
Download: ML20012B764 (14)

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L U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report No:

50-29/90-01 Dociet No:

50-29 Licensee No:

DPR-3 L

Licensee:

Yankee Atomic Electric Company 580 Main Street

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Bolton, Massachusetts 01740-1398

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Facility Name: Yankee Nuclear Power Station

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Inspection at: Rowe, Massachusetts Inspection Conducted:

January 3 3 February 12, 1990

Inspector:

M. Markley, Senior Resident Inspector Approved By:

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6/PO P. K. Eapen, Chief, Heactor Projects section SA Da tti.

Inspection Summary: Inspection on January 3 - February 12, 1990 (Report No.

30-29/90-01)

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Areas Inspected:- Routine inspection on daytime and backshifts by the senior resident inspector..of: operational safety; security; plant operations; mainten-ance and surveillance; engineering support; radiological controls; actions'on previous inspection findings; licensee event-reports; and, periodic reports.

Results:

1.

General Conclusions on Adequacy,- Strength or Weakness in Licensee Procrams-

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licensee-short-term actions in response =to the safety injection tank weld crack were adequate and ensured no immediate safety hazard existed. Senior

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' licensee management was aggressive in addressing this issue. The Mainten-

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ance Support Department (MSD) supervisor demonstrated noteworthy leader-ship in directing onsite response and keeping the NRC fully-informed.

Plant personnel demonstrated a strong safety perspective, and knowledge of i

plant systems and procedpres in responding to offnormal equipment condi--

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tions.-

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Unresolved Items Two unresolved items were identified during this inspection period:

10 CFR 21 Report on Safety Class 2, U-Tube Heat Exchanger (Section 5.1);

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- The acceptability of the current fitness-for-duty program (Section 8.0).

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TABLE OF CONTENTS t

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Persons Contacted....................................................

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Summary of Facility Activities.......................................

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Operational Safety Verification (IP 71707)...........................

3.1 Plant Operations Review.........................................

3.2 Safety System Review............................................

• 3.3 Review of Temporary Changes, Switching and Tagging..............

3.4 Facility Housekeeping and Fire Protection.......................

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P l a n t Dm. a t i o n s ( I P 717 0 7 )..........................................

4.1 Plant Load Reductions for Condenser Tube Cleaning...............

4.2 Crack in ECCS Safety Injection Tank We1d........................

4.3 Fire in the Primary Auxiliary Building (PAB) Fan Room...........

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5.

Maintenance / Surveillance (IP 61726,62703)...........................

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5.1 10 CFR 21 Report on Safety Class 2 U-Tube Heat Exchanger.......

5.2 Main Steam Line Pressure Switch Outside TS Limits...............

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Security (IP71707)..................................................

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Radiological Controls (IP 71707).....................................

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Fitness-For-Duty Program (TI 2515/104)...............................

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Licensee Event Reports (LERs) (IP 90712).............................

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Status of Previous Findings (IP 92701)...............................

10.1 (Closed) Notice of Violation (88-25-01).........................

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Review of Periodic Reports (IP 90713)................................

12. Management Meetings (IP 30703).......................................

• The NRC Inspection Msnual inspection procedure (IP) or temporary instruction (TI) or the Region I temporary instruction (RI TI) thtt was used as inspection guidance is listed for each applicable report section.

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DETAILS 1.

Persons Contacted Yankee Nuclear Power Station T. Henderson, Plant Superintendent R. Mellor, Technical Director

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Yankee Atomic Electric Company (YAEC)

A. Kadak, President and Chief Operating Officer N. St. Laurent, Manager of Operations J. Thayer, Yankee Project Manager J. Haseltine, Yankee Project Director The inspector also interviewed other licensee employees during the inspection, including members of the operations, radiation protection, chemistry, instrument and control, maintenance, reactor engineering, security, training, technical services and general office staffs.

2.

Summary of Facility Activities Yankee Nuclear Power Station (YNPS, Yankee or the plant) has maintained continuous power operation since August 30, 1990. The licensee reduced power to about fifty percent on January 5-7 and February 2-6, 1990, to perform condenser cleaning, leak testing and tube plugging. The plant

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operated at full rated power for the remainder of the inspection period.

Effective February 4, 1990, Mr. A. Randy Blough, cognizant NRC Region I

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Division of Reactor Projects (DRP) Section Chief for YNPS was promoted to i

Chief of Projects Branch No. 2, DRP.

Pending selection of a new Section Chief, Mr. P. K. Eapen, Special Test program Section Chief in the Region I Division of Reactor Safety (DRS), assumed the cognizant DRP Section Chief responsibilities for YNPS.

On January 30, 1990, Mr. Malcolm R. Knapp, Director for NRC Region I Divi-sion of Radiation Safety and Safeguards, visited YNPS. A brief meeting was held with site management and the senior resident inspector provided a

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site tour.

l On February 7,1990, Yankee President Andrew Kadak and other senior staff members presented the licensee's plant life extension (PLEX) related licensing activities and plans to NRC Region I management.

On February 5-8, 1990, two NRC Region I specialist inspectors conducted a special mechanical inspection of the safety injection tank (NRC Inspection 50-29/90-03).

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P On February 5-9, 1990, two NRC Region I specialist inspectors conducted a special inspection of plant equipment and programs relative to criteria detailed in the NRC Regulatory Guide 1.97 and Generic Letter 82-83 (NRCInspection 50-29/90-02).

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On February 7-9, 1990, a NRC Region I specialist inspector conducted a

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security and safeguards program inspection in the Yankee corporate office in Bolton, Massachusetts (NRC Inspection 50-29/90-05).

3.

Operational Safety Verification 3.1 Plant Operations Review

'i The inspector observed plant operations during regular and backshift tours of the following areas:

Control Room Safe Shutdown System Building L

Primary Auxiliary Building Fence Line (Protected Area)

Diesel Generator Rooms Intake Structure Vital Switchgear Room Turbine Building Cable Tray House Spent Fuel Pit (SFP) Building Safety Injection Building The following items were reviewed during daily routine facility tours: shift staffing, access control, adherence to procedures and Limiting Conditions of Operation (LCOs), instrumentation, recorder traces, protective systems, control room annunciators, area radiation and process monitors, emergency power source operability, operability

of the Safety Parameter Display System (SPOS), control room logs, shift supervisor logs, and operating orders. On a weekly basis, selected Engineered Safety Feature (ESF) trains were verified to be operable. The condition of plant equipment, radiological controls, security and safety were assessed. On a biweekly frequency, the in-spector reviewed safety-related tagouts, chemistry sample results, shift turnovers, portions of the containment isolation valve lineup and the posting of notices to workers.

Plant housekeeping and fire protection were also evaluated.

Inspections of the control room were performed on weekends and back-shifts as follows:= January 3, 6, 7, 9, 17, 24, 31, and February 5.

Holiday inspection was performed from 9:30 a.m. to 3:00 p.m. on January 15. Operators and shift supervisors were alert, attentive and they responded appropriately to annunciators and plant conditions.

Cognizant shift personnel were knowledgeable of plant conditions and ongoing maintenance and surveillance activities.

Shift turnovers

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were conducted professionally with strong personnel access control practices.

Shift documentation adequately characterized operating history and the observed off-normal conditions, such as equipment problems, were resolved in a timely manne.

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In December 1989, the licensee implemented a new five shift rotation schedule where the individuals work twelve hours per shift.

The inspector reviewed operations shift work hours for January 1990.

Personnel overtime was not excessive.

Most operators worked between

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i forty and fifty hours per week.

I No degradation in the quality of performance was observed. Actual

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overtime worked was within Technical Specifications (TS) and station procedure requirements.

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3.2 Safety System Review f

The emergency diesel generators (EDG), EDG fuel oil, Residual Heat Removal, and Safety Injection systems were reviewed to verify align-

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ment and operational status. The review verified that (1) accessible

major flow path valves were correctly positioned, (ii) power supplies l

were energized, (iii) lubrication and component cooling were ade-quate, and (iv) components were operable based on a visual inspection of equipment for leakage and general conditions.

System walkdowns

were performed to assess the material condition of the High Pressure i

Safety Injection (HPSI) and Low Pressure Safety Injection (LPSI) and

the low pressure safety injection accumulator.

Selected accessible valves were verified to be in the correct position and locked as re-quired by plant procedures.

No unacceptable conditions were identified. The material condition

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of the EDGs was good. Minor flange, coupling, and seal leakage ob-served on the HPSI and LPSI system was previously identified by the licensee with maintenance requests issued to effect repairs.

3.3 Review of Temporary Changes. Switching and Tagging Temporary change requests (TCRs), which were approved in support of implementing lifted leads and jumper requests and mechanical by-passes, were reviewed to verify that: controls established by

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AP-0018, " Temporary Change Control," were met; there were no con-flicts with the Technical Specifications; the requests were properly approved prior to installation; and a safety evaluation in accordance with 10 CFR 50.59 was prepared as required.

Implementation of the requests was reviewed on a sampling basis, i

The switching and tagging log was reviewed and tagging activities were inspected to verify that the plant equipment was controlled in

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accordance with the requirements of AP 0017,

" Switching and Tagging

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of Plant Equipment."

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Licensee administrative control of off-normal system configurations by the use of TCR and switching and tagging procedures as reviewed above, was in compliance with procedural instructions and was conducive for plant safety. No unacceptable conditions were identi-fied.

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3.4 Facility Housekeeping and Fire Protection Facility housekeeping during this inspection period was improved.

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The physical condition of the plant was generally good.

The concerns

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identified during the previous inspection were adequately addressed.

The inspector observed consistent post-maintenance clean up of work

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areas. Also, the licensee completed the structural upgrades in the

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Primary Auxiliary Building (PAB). Tools, equipment, and construction

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related debris were promptly removed from the area.

The inspector examined the PAB fan room following declaration of a plant fire on January 26, 1990.

Details of the incident are dis-cussed in Section 4.3 of this report.

The inspector noted that the roof of the PAB fan room was leaking. Although the leakage did not impact plant equipment, it was running down the wall adjacent to an electrical equipment control box.

The licensee was aware of the leakage and the control box was covered with plastic.

Discussion with maintenance supervision indicated that replacement of the fan

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room roof has been budgeted and scheduled for replacement in 1990.

4.

Plant Operations 4.1 Plant Load Reductions for Condenser Cleanino The licensee reduced power to approximately fifty percent on January 5-7 and February 2-4, 1990, to perform condenser cleaning, leak test-ing and tube plugging.

A turbine test was conducted on January 5,1990 per license procedure i

OP-4425, Rev. 22, " Turbine Throttle and Control Valve Surveillance Test " This procedure requires the Number 2 and 3 Main Steam Line Control Valves to close with a certain overlap to avoid power swings during such evolutions.

During this test, Number 2 and 3 control

valves began to close together. The licensee immediately terminated this test.

Corrective actions are scheduled for the 1990 refueling

outage to resolve this and past known control valve issues. The

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licensee completed the condenser work and returned the plant to full power 'at 2:00 p.hi. on January 7.

During main steam line non-return valve (NRV) testing on February 3, the No. 2 NRV Train B flow restrictor test device failed to ade-quately disengage. The licensee declared the NRV inoperable and entered the appropriate TS action statement. Maintenance request No.90-271 was initiated to troubleshoot the flow restrictor. Mainten-ance returned the device to the disengaged position and the NRV was

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returned to an operable status. The preliminary licensee evalt.ation,

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in consultation with the NRV vendor, determined the flow restrictor test device was sticking due to the hydraulic fluid remaining from previous maintenance.

The licensee plans to disassemble and clean the NRV control / test devices during the June 1990 refueling outage.

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s Operators effectively anticipated problems with the No. 2 control valve which has occasionally fast closed since the core XX refueling.

Personnel actions reflected a conservative operating philosophy.

Implementation of long-term corrective actions for the above NRV and i

the control valve are scheduled for the 1990 refueling outage.

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4.2 Crack in ECCS Safety Injection Tank (SIT) Weld L

On January 17, 1990, the licensee identified a longitudinal center-l weld crack (approximately 2.6 inches) on the lower portion of the Emergency Core Cooling System (ECCS) Safety Injection (SI) tank. The leak rate was determined to be approximately one gallon per day i

g (gpd); The SI tank contains approximately 125,000 gallons of 2200 e

ppm borated water. The tank material is aluminum.

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Immediate licensee actions included performing an Event Reportability Evaluation Report (ERER), conducting an engineering evaluation to analyze the defect and determine the potential for crack propagation, containing the-liquid and establishing guidelines pending long-term corrective measures. Operations personnel performed ERER No. 90-02

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and determined it was not reportable.

The engineering evaluation involved an on-site analysis by the Main-l tenance Services Department (MSD), offsite analysis by the Yankee corporate office, and a fracture mechanics analysis by a contractor.

The licensee determined that the flaw size to cause tank failure was approximately twenty-one inches. The licensee concluded that no immediate safety hazard exists. Therefore, the licensee established monitoring and personnel action guidelines pending resolution of long

. term corrective actions, i

The licensee implemented personnel guidance through a procedure l

change to AP-2007, " Maintenance of Operations Department Logs," and Special Order Nos. 90-13, 14, 15 and 24.

The specific directives included: An immediate evaluation by Station Management if the crack propagates an additional 0.25 inch; A Plant Shutdown to Mode 3 (Hot Standby) if the crack propagates an additional 1.0 inch and Notification by the operations Shift Supervisor to the licensee duty.

officer if the leakage reaches 25 ml/5 minutes or 1.9 gpd. The

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initial monitoring was hourly. However, the licensee increased the interval when monitoring verified the crack was not propagating rapidly and the leak rate was stable and established daily monitoring l

on January 26.

l On January 18, 1990, the NRC held a conference call with licensee I

site and corporate management to clarify questions regarding tank L

integrity, operability, previcusly identified metallurgical defects, L

details of the engineering analysis, and planned corrective actions.

A subsequent conference call between the NRC and the licenseo was l-held on January 19 to further discuss the impact on seismic safe l

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o shutdown capabiley and loss-of-coolant accident (LOCA) mitigation.

During these dist.asions, the licensee adequately described the basis

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for continued plant operation, how the SI tank met TS operability requirene ts and how the safety margins were not reduced for LOCA re-sponse and mitigation. The licensee stated that the SI tank is not a:

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seismic tank and provides no seismic shutdown functions.

Seismic

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event response is provided by the Safe Shutdown system which takes suction from the seismically qualified fire water storage tank.

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The NRC found the licensee short-term corrective actions to be acceptable. The licensee was pursuing two long-term corrective measure options at the conclusion of this inspection. One option was

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to determine a corrective action based on failure analysis of the defect during the June 1990 refueling outage. The other option was to replace the SI tank with a new stainless steel t'ank.

The licensee's decision on-final option was pending at the conclusion of this inspection.

-Senior licensee management was aggressive.in addressing this issue.

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The MSO supervisor demonstrated noteworthy leadership in directing on-site response and keeping the NRC fully informed.

Personnel were

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prompt'in responding to the incident.

The senior resident inspector independently verified the crack propa-gation and leak rates on an ongoing basis.

No additional crack

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growth was observed and the leak rates were between 1.1 and-1.5.gpd.

On February 5 - 8, 1990, two region-based specialist inspectors from tne Division of Reactor Safety conducted a special mechanical inspec-

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tion of the SI tank.

The inspection included visual examination of-the SI tank defect, a review of the engineering analysis, and exami-nation of previously identified and/or: repaired defects.

The inspec-ter observations, findings and conclusions were discussed with the

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licensee and documented in the NRC Inspection Report No. 50-29/90-03.

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4.3 Fire-in the Primary Auxiliary Building (PAB) Fan Room At 10:53 a.m. on January 26, 1990, an' aux 111ary operator (AO)

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observed smoke from-the FN-11 PAB ventilation control panel. He informed the control room who directed him to switch PAB ventilation to the FN-19 train.

The control room declared a plant fire emergency rnd assembled the fire brigade. The licensee decermined that the

r;re was caused by electrical smoldering.

The fire was extinguished and the plant terminated the fire emergency at 10:58 a.m.

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4 Although the'FN-11 ventilation train was temporarily rendered in-

operable, the FN-19 was placed in service without interruption of j

plant ventilation.- No unacceptable equipment conditions were identi-

fled.- The licensee initiated maintenance request No.90-227 to effect repairs.

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This incident involved no radiological hazards.

The PAB fan room is located inside a radiologically controlled area (RCA); however,.the FN-11 control box is not located in a radiation or contamination

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area. No radiological control measures were.necessary for personnel to respond to the incident.

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Personal actions taken by the A0 were effective in responding to the incident. The individual demonstrated a strong safety perspective as well as a thorough knowledge of plant systems and procedures, i

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Maintenance / Surveillance The inspector observed and reviewed maintenance and surveillance problem investigation activities to verify compliance with regulations, admini-strative and maintenance and :urveillance proceaures, codes and standards, QA/QC involvement, safety tag use, equipment alignment,-jumper use, per-sonnel qualification, radiological contrsls for worker protection, fire protection, retest requirements, LCOs, evaluation of test results, removal

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and restoration of equipment, deficiency review, resolution and' report-

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ability per Technical Specifications.

5.1 10 CFR'21 Report on Sofety Class 2, U-Tube Heat Exchanger On December 26, 1989, the licensee submitted a 10 CFR 21 report on a Safety Class 2, U-tube heat exchanger purchased from Southwest Engi-neering Company.

The heat exchanger is being installed as part of the Water Clean up system (WCU) designed to remove post-accident iodine and cesium. The licensee' identified the deviation during a

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preservice inspection-.for nondestructive examination (NDE) which re-quired removal of the fasteners on the channel cover. As-found torque conditions were in excess of ASME Boiler and Pressure. Vessel Code,Section VIII, Division I values.

Specifically, the heat ex-

changer channel cover boltir.g (SA-190 B7) was torqued to.approxi-

.mately 800-900 ft./lbs. The licensee determined the proper torque limit was approximately 110 ft./lbs.

Subsequent licensee discussions with the vendor determined that the

' channel cover' fasteners were tightened with no specific procedure and that the torque values were not documented.

Additionally, licensee

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engineering and-quality assurance personnel who witnessed the hydro-static test at the vendor's facility noted that the studs may have been over torqued to successfully complete the hydrostatic test, p

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' Th'e licensee replaced the fasteners and initiated an evaluation. The evaluation concluded that no immediate safety hazard exists because the heat exchanger was undergoing preservice inspection.

Licensee assessment of the vendor and the associated quality controls is on-going.

During the inspection period, the WCU heat exchanger twice failed insitu hydrostatic testing due to channel cover leakage.

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see is currently evaluating the use of different_ gasket materials to

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' improve the seal.

Licensee maintenance personnel were effective in identifying this equipment deviation.

Similarly, the Plant Operations Review Commit-tee (PORC) was effective in questinning 10 CFR 21 applicability.

However, vendor actions, the lack of effective procedures and quality assurance, and technical problems in the preservice testing remains'

unresolved (59-29/90-88-01) pending completion of the licensee's evaluation.

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5.2 Main Steam line Pressure Switch Outside TS Limits On January 25, 1990, the inspector observed instrume itation and con-trol (I&C) personnel. perform OP-4656, Rev. 9, " Functional Test of the NRV Main Steam Line Pressure Channels / Switches." During the surveil-lance test, the main steam lir.e pressure switch MS-PS-22 failed tc.

actuate'at the 300 psig plus or minus 10 psig acceptance criterion.

The:as-found actuation setpoint was determined to be 143.5 psig.

The TS low steam line pressure limit is 262.5 psig.

The licensee de-clared the pressure switch inoperable and-entered the.1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> action statement details.

I&C personnel reset the setpoint to 300 psig-and retested'the switch.

It passed several subsequent surveillance tests.

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within the< acceptance criterion. The licenree exited the TS action

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statement.

.Although MS-PS-22 passed the surveillance test, the licensee was un-able to identify the cause of the setpoint drift.

The licensee issued maintenance request No.90-220 to replace MS-PS-22.

Later in the day, the licensee reentered the TS action. statement and replaced the rassure switch per AP-6007, Rev. 6, "I&C Department Corrective Maintenance." The replacement switch satisfactorily met preservice inspection and operability testing requirements.

No other NRV pressure switch equiprent anomalies were observed. The

other pressure switches satisfactorily passed the surveillance test.

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The licensee sent the rep'.ced oressure switch, Barksdale Model BZ-

R-169 to the vend:;r for failure analysis. At the end of the inspec-tion period, the failure analysis was not available for review.

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I&C personnel acted conservatively in addressing the equipment anomaly.

It was immediately reported to the control room. The-in-

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spector observed excellent safety perspective.

Personnel responded in a prompt and technically sound manner.

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Security

' Selected aspects of plent physical security were reviewed during regular and backshift hours to verify that controls were in accordance with the security plan and approved procedures.

This review included: guard staff-ing, vital and protected area barrier integri'.y, maintenance of isolation zones, and implementation of access controls including authorization,

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badging, escorting, and searches.

No inadequacies were identified.

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Radiological' Controls Radiological controls were reviewed on a routine basis to verify conformance with'indusiry radiological standards, administrative and

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radiological control procedures, and regulatory requirements.

Selected work evolutions were observed to determine the adequacy of program implementation commensurate with the radiological hazards and importance to safety.

Independent surveys were performed by the inspector to verify the adequacy of radiological controls and instructions.to workers.

No unacceptable' conditions were identified.

Radiation protection-personnel were aggressive in providing radiological work controls.

Plant workers were knowledgeable of radiological conditions and radiation work permit requirements.

8.

Fitness-for-Duty Program (TI 2515/104)

On June 7,- 1989, the NRC published the final rule and policy for fitness-for-duty (FFD) programs, with an effective date for program implementation of January 3, 1990..On December 27, 1989, the NRC issued Temporary Instruction No.- 2515/104 to provide inspection guidance for NRC resident-inspectors to verify implementation of FFD training programs relative to the requirements of 10 CFR 26. Areas selected for specific evaluation were policy awareness training for general employees, FFD training for, supervisory personnel and for those required to perform escort duties.

On January 2,.1990, the licensee submitted letter BYR 90-001 to the NRC stating that-Yankee has implemented a FFD program that meets the require-ments of 10-CFR 26, effective January 3,1990. Additionally, the licensee stated that all persons authorized unescorted access to the protected area had received the required training.

The inspector reviewed the FFD program through discussions with cognizant licensee personnel, review of policy guidelines, tour of the sample col-lection facility, and review of FFD training attendance rosters relative

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to the security list of persons granted unescorted access to the protected

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area. Also, the inspector attended a routine general employee training (GET) session on February 12, 1990.

Inspector noted that FFD training for the current plant staff was gene-

rally good. All plant personnel authorized unescorted access to the pro-tected area on January 9,1990, were verified to have attended the FFD training offered.

The training provisions for policy awareness training

were adequately covered in the training program. The licensee addressed the overall FFD program including policy guidelines used for implementa-t tion, hazards associated with the abuse of drugs and. misuse of. alcohol, details of the Employee Assistance Program (EAP), expectations of employees and the consequences that may result from lack of adherence to the policy.

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Also covered was the training for supervisors and personnel performing escort duties.

Specifically, the roles and responsibilities-in implement-ing the program including the recognition of workers needing referral to the EAP and procedures for reporting problems to supervisory or security personnel were covered. The licensee emphasized the.importance of the safety aspects FFD program as a mechanism to help workers needing assist-ance rather than a program to penalize them.

The licensee has implemented the FFD program primarily through the use of company policy guidelines.

Listed below are the guidelines implemented under the FFD program.

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12.1, Fitness for Duty policy;

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12.2, Supervisor Guidelines for Administering;

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12.3, Drug and Alcohol Fitness for Duty Testing Procedure;

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12.4, Collection Site Procedures;

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12.5, Medical Review Officer Qualifications and Responsibilities;

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12.6, Fitness for Duty Program Positive Test;

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12.7, Recordkeeping and reporting Requirements; and

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12.8, Suitable Inquiry.

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-One station procedure, AP-0022, " Recall of Off Duty Personnel," was issued

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through YNPS procedure generation programs. The inspector noted that the

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licensee was implementing regulatory required programs as guidelines

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rather than procedures.

The above procedures were not afforded the reviews for a normal station procedure. The licensee stated that FFD was implemented as a company policy and the guidelir.es constitute formal

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The' licensee's QA department has not yet audited the implemented FFD pro-gram.' The licensee stated that the required annual audit is scheduled to

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be completed by the corporate quality assurance (QA) group following the

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June 1990 refueling outage.

The inspector discussed with the licensee the bases for the conclusions that the FFD program meets the regulatory I

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-requirements without any independent verification or audit.

The licensee

stated that the program does meet the intent of the regulation and that i

the~ purpose of the audit is to focus on the effectiveness of the program.

Inspector review of the GET session conducted by the licensee on February

_12, 1990,-indicated that the individuals attending the training session did not receive the videotape FFD training films or a verbal explanation of the FFD policy.

The-licensee only provided the individuals with a copy of Guidelines 12.1, " Fitness for Duty Policy" and responded to questions.

The acceptability of using company guidelines in lieu of procedures, the lack of an independently verified program which does not receive the same i-defense-in-depth scrutiny afforded to the station procedures, and the limited FFD information provided in GET remains unresolved (50-29/90-01-01) pending further licensee actions.

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Licensee Event Reports (LERs)

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The inspector reviewed Licensee Event Report (LER) 89-09 to determine:

(1) the report was submitted in a timely manner; (2) description of the

'i events was accurate; (3) root cause analysis was performed; (4) safety implications were assessed; and, (5) corrective actions implemented or planned were sufficient to preclude recurrence of a similar event.

a LER 89-09,." Turbine Building Sump Composite Sampler Inoperable,"

addresses the July 18, 1989, identified deficiency where the con-

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tinuous composite sampler was found unplugged.

The licensee deter-mined that the root cause was improper equipment restoration follow-

-ing function check and calibration by a plant chemist. Additionally,

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the-daily channel check performed by the auxiliary operators (A0s)

-failed to detect the inoperable condition. The chemist was re-

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.. instructed.in proper procedure performance. -A0 instructions for daily channel checks were revised to require verification that the sampler was operable and that the instrument was plugged-in.

Licen-see assessment of sump radioactivity before and after the incident verified that no offsite releases occurred. The inspector had no

further questions.

No deficiencies were identified.

10. Status of Previous Inspection Findings (Closed) Notice of Violation (88-25-01): Nonconservative Nuclear Instrumentation Setpoints During Low Power Operation This item is related to the indeterminate number of times prior to November 9, 1988, while the reactor was in Mode 1 (Power Operation)

, at less than 15MWe or Mode 2 (Start-up), where nuclear instrumentation channels were rendered inoperable due to nonconservative ad,iustments by one or more operators.

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The licensee has revised the applicable procedures, retrained lic-

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ensed personnel, and completed the Task Force investigation.

Inspec-n tor discussion tdth operations shift personnel verified that indivi-

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duals were well informed and knowledgeable of the revised procedures.

The subject individual who was known to have made the nonconservative adjustments has since retired. Ongoing licensee. corrective actions include the acquisition of a plant reference simulator to improve-training and identify additional opportunities for improvement. This item is closed.

11.

Review'of Periodic Reports Upon. receipt, the-inspector reviewed periodic reports submftted pursuant to Technical Specifications. This review verified, as applicable:

(1) that the reported information was valid and included the NRC required data; (2) that test results and supporting information were consistent with design predictions and performance specification;.and (3) that

. planned corrective actions were adequate for resolution of the problem.

The inspector also ascertained whether any reported information should be-classified as an abnormal occurrence. The following reports were re-viewed:

Core Operating Limitt Report per TS 6.9.4.4;

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Special Report - Steam Generator Inspection Results from 1988

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Refueling Outage per.TS 4.4.10 and 6.9.6;

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Design Change Plan (DCP) EDCR 89-303 for Safety Parameter Display

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(SPDS) Upgrade.

No unacceptable items were observed.

12. Management Meetings At periodic intervals during this inspection, meetings were held with senior: plant management to discuss the findings. A summary of findings for the report period was-also discussed at the conclusion of the inspec-tion and prior to report issuance. No proprietary information was iden-

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tified as being included in the report.

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