IR 05000271/1985025
| ML20198C644 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/30/1985 |
| From: | Meyer G, Raymond W, Silko T, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198C559 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.A.1.3, TASK-2.K.3.13, TASK-2.K.3.15, TASK-2.K.3.22, TASK-TM 50-271-85-25, NUDOCS 8511120136 | |
| Download: ML20198C644 (18) | |
Text
_
.
.
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
85-25 Docket No.
50-271 License No. DPR-28 Licensee: Vermont Yankee Nuclear Power Corporation RD 5, Box 169, Ferry Road Brattleboro, Vermont 05301 Facility Name: Vennont Yankee Nuclear Power Station Inspection At: Vernon, Vermont Inspection Conducted: August 5 - September 20, 1985 M
/D/23 9f Inspectors:
I d
W
. Raymond, nio~ R4sident II.spector
.
CV lo 23
{
/t W. Meyer, Pfoject Eng eer A
/c/23lW
'
T.
. Sil
, Resident Inspector
'
/
4.64 ic/30/8Y W. E. Tripf,' Chief, Reactor Projects
'
/
Section 3A, Projects Branch 3 Inspection Summary:
Inspection on August 5 - September 20, 1985 (ReportNo. 50-271/85-25)
Areas Inspected: Routine, unannounced inspection on day time and backshifts by the resident and region based inspectors of: actions on previous inspection findings; plant power operations, including operating activities and records; plant physical security; surveillance test controls; peer inspection program deficiencies; TMI Action Plan closeout status; surveillance activities; diesel generator brush rigging; emergency preparedness exercise on September 11, 1985; maintenance activities; Operations Supervisor duties; modification plans for the HCU seismic restraints; control room carpeting; and, plans for an onsite low level radioactive waste storage facility. The inspection involved 170 hours0.00197 days <br />0.0472 hours <br />2.810847e-4 weeks <br />6.4685e-5 months <br />.
Results: No violations were identified in 12 of 14 areas inspected. Operational status reviews identified no conditions adverse to safe operation of the facility.
Two apparent violations were identified as follows:
failure to identify discrepant results during surveillance testing - paragraph 3; and, failure to take effective corrective actions to preclude recurrence of deficiencies in the onsite QC peer inspection program - paragraph 4.
l l
8511120154
__.
.-
.
DETAILS 1.
Persons Contacted
,
Interviews and discuss.ons were conducted with staff and management personnel to obtain infonnation per *inent to the areas inspected.
Inspection findings were discussed periodically with the management and supervisory personnel listed below.
Mr. G. Johnson, Operations Supervisor Mr. R. Milligan, Administrative Supervisor Mr. R. Morrisette, Health Physicist Mr. J. Pelletier, Plant Manager Mr. T. Watson, I&C Supervisor NRC Commissioner James Asselstine visited the site on August 14, 1985. During his visit, he was accompanied by his administrative assistant and William Markcrow, member of the Vermont Public Service Board. The Commissioner toured the Reactor
'
Building, the Diesel Generator Rooms, and the recirculation pipe preparation area, including observation of mock-up training. An infomational meeting was held between the Comissioner, licensee management and NRC representatives, which discussed the status and plans for naintenance, operation, training, TMI Action Plan, low level radioactive waste, and quality assurance. The meeting was bene-ficial for both the licensee and NRC staffs in the review of upcoming activities at the plant.
2.
Status of Previous Inspection Findings 2.1 (Closed) Unresolved Item 85-20-09: Revision of Document Control Procedures, The licensee infonned the inspector on August 28, 1985 that the revisions to the Document Control (DCC) procedures were completed but not approved by Plant Manage-ment and the Plant Operations Review Consnittee. The licensee stated the procedures would be approved and issued by October 1, 1985. The inspector noted during a discussion with the Document Control Coordinator on September 20, 1985 that proce-dures OP 6808, 6806 and 0834 were changed to include references to the YAEC DCC j
procedures manual. This item is closed.
2.2 (Closed) Unresolved Iten' 85-20-10:
Review of Stack Gas Calibration Test Results. The failure to detect inadequate test results during the performance and review of OP 4382 is a violation of technical specification requirements, as dis-cussed further in section 3.0 below.
Inspection item 85-20-10 is replaced by
item 85-25-01 for tracking purposes and is thus closed.
2.3 (0 pen)UnresolvedItem 85-20-08:
Installation and Testing of the Health Physics Emergency Communications Network. This item was open, in part, pending I
receipt of written notification from the licensee regarding the installation of a health physics phone network at the new emergency operations facility (EOF).
The statement that the licensee had responsibility for installation of the line
'
was incorrect, in that the health physics and emergency notification system net-works will be installed by the NRC by October 31, 1985. The licensee does have responsibility for periodic testing of both networks after they are installed.
l
!
_
,
.-
=. _ _ -
. -.
.
._.
-...
.-
_-
-
..
.
.
.-
.-
.
-_
.
- _ _ - - --
-..
.
,.
'
,
,
f The inspector noted on September 11, 1985 that the licensee had provided dedicated commercial lines for NRC use at the new EOF as interim emergency communication systems.
l This item remains open pending inspector review of (1) the installation of the permanent emergency comunications networks at the new EOF: and,(ii) subsequent licensee actions to test the emergency comunication systems.
2.4 (0 pen) Unresolved Item 85-10-06: Review of Corrective Actions for Onsite QC Inspection. The failure to adequately corr:::t 6ficiencies in the onsite QC inspection program is a violation of NRC requirements, as discussed in section 4.0 below. A new inspection item (85-25-02) is opened to track this concern.
Inspection item 85-10-06 remains open to review and track completion of licensee
corrective actions to upgrade the onsite Peer Inspection program.
2.5 (Closed) Follow Item 85-23-04: HPCI Alignment. The HPCI system was re-moved from service on August 5,1985 following completion of alternate surveillance testing in accordance with technical specification requirements. Following com-pletion of turbine and pump alignment in the cold and hot conditions per
,
Maintenance Request 85-1474, the HPCI system was satisfactorily tested and re-
,
turned to an operable status on August 8,1985. This item is closed.
'
3.0 Review of Surveillance Test Results The inspector reviewed the test results of OP 4382 for the calibrations completed on Stack Gas Channel I on November 7, 1984. February 4, 1985, April 30, 1985 and July 10, 1985. The test result for November 1984 and July 1985 were acceptable.
The July 1985 calibration was performed following replacement of the channel out-
!
put meter under MR 85-1336 since it was found to be non-linear. The calibration
test results for Stack Gas Channel II during the same period were also acceptable.
!
The Channel I test results for February and April 1985 were acceptable, except
that the stack gas recorder did not meet the acceptance criteria on both dates.
The recorder output is checked at the three test points of 10+3, 10+5 and 10+6 countsperminute(cpm). The recorded test results indicated an output of 9.0X10+5 cpm when an output value of 1.0X10+6 +/- 20,000 cpm was required. The l
inspector noted that the discrepant results for the February and April tests were not recognized by the technician performing the test, the Operations Shift Super-
!
visor, nor the I&C Foreman who reviewed the completed test results.
The inspector reviewed the completed test results for 20 other randomly selected
calibrations and functional tests.
Each test had at least 20 results that must be compared to acceptance criteria for acceptability. No other examples were identified where licensee personnel failed to identify test results that were outside the
,
j acceptance criteria. Thus, the findings related to the February and April test l
_
.
.
-
-
.
...
,
.
-
results for OP 4382 do not appear to be indicative of a broader problem. However, the failure of technicians and supervisors to identify discrepant test results is a matter that warrants licensee management attention.
The failure to identify the test results that were outside the stated acceptance criteria for the February and April 1985 calibrations and initiate appropriate corrective actions is contrary to the requirements of OP 4382 and Technical Specifications 6.5.1 (VIO 85-25-01).
4.0 Peer Inspection Program Deficiencies In response to a licensee management request, the 00A group conducted an audit in March,1985 of the onsite QC inspection process. 0QA Audit 85-11 identified several weaknesses in the peer inspection program.
Four of the deficiencies identified by the 0QA audit represent a recurrence of NRC concerns identified in an inspection completed on July 20, 1983 and documented as inspection item 83-22-05.
Specifically, both the NRC and 0QA audits noted the following relating to the inspection of maintenance activities:
failure to perform a meaningful number of independent inspections of maintenance activities; failure to adequately document independent inspections, and, failure to incorporate guidance in plant procedures regarding maintenance activities to receive independent inspections. The licensee's interim corrective actions included revised instructions to plant personnel that better define and document QC peer inspections. The interim measures appear to be properly implemented based on observations by the NRC inspector of routine plant activities during the inspection period.
Licensee corrective actions for Audit 85-11 have been in progress since April,1985.
The status of these actions were reviewed by NRC management during this inspection period and during a meeting with the licensee on August 7,1985 in NRC Region I.
The licensee's planned actions appear acceptable to correct the identified program deficiencies. The NRC staff acknowledged the licensee's use of the peer inspection approach as an acceptable means to satisfy the 10 CFR 50, Appendix B, Criterion X requirements. However, the licensee must assure that the independence of inspection personnel is demonstrated, and that the process is monitored to verify proper imple-mentation. Further NRC staff review of the OQA 85-11 audit findings and the licensee's response to the audit is required. This area will be reviewed further by the NRC on a subsequent routine inspection.
The identification of peer inspection program deficiencies in 00A Audit 85-11 and subsequent corrective actions meets 4 of the 5 criteria in 10 CFR 2, Appendix C for classifying an item as a licensee identified violation. However, the defi-ciencies could reasonably be expected to have been prevented by the corrective actions from a previous violation cited by the NRC as Item A of the Appendix to Inspection Report 83-22 (Item 83-22-05). The corrective actions for Item A were initially scheduled to be completed by May,1984. Completion of the actions was deferred by the licensee until November 1, 1984 (16 months after identification)
to allow additional time to upgrade the AP 0021 requirements and to train personnel on the proper perfomance of independent inspections for maintenance activities.
-. _ - - _
_
.. _.
.
.
_
.
_.
_
__
_
_ _ _ _
_
___
_ _ _ _
,
r
.
,
>
-
During the August 7,1985 meeting, licensee management acknowledged that the corrective actions taken in response to inspection item 85-23-05 may have been too narrow in scope and focus.
The failure to implement adequate corrective actions to preclude recurrence of deficiencies in the onsite QC inspection program is contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVI and the licensee's QA Topical Report YOQAP-I-A (VIO 85-25-02).
5.0 Observations of Physical Security
Selected aspects of plant 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 the following security
,
!
measures: guard staffing; verification of physical barrier integrity in the l
protected and vital areas; verification that isolation zones were maintained; and implementation of access controls, including identification, authorization.
t badging, escorting, personnel and vehicle searches. No inadequacies were
,
identified.-
l 6.0 Shift Logs and Operating Records Shift logs and operating records were reviewed periodically to detennine the status of the plant and changes in operational conditions since the last log review, and to verify that:
(1) selected technical specification limits were
met; (2) log entries involving abnormal conditions provided sufficient detail to comunicate equipment status and restoration; (3) operating logs and sur-veillance sheets were properly completed; (4) log book reviews were conducted by the staff; (5) potential reportable occurrences were filed as licensee event
'
reports when required; and, (6) Operating and Special Orders did not conflict
'
with Technical Specification requirements.
No unacceptable conditions were identified.
,
i
\\
i 7.0 Inspection Tours and Status Reviews Operational status reviews were performed to verify conformance with the technical
,
.
specifications and approved procedures. The operational status of emergency and l
power generation systems was.confinned by direct review of control room panels.
Control room staffing and protocol were reviewed to assure manning requirements were met and acceptable working conditions were maintained. Licensed personnel were interviewed regarding existing plant conditions and knowledge of recent changes to the plant and procedures, as applicable. Acknowledged alanns were re-
,
viewed with licensed personnel as to cause and corrective actions being taken.
i i
<
i
- -. -
.
.
.-.
--... - -
. - -.
--. -
- - -
_
__
_
_
_
_
_
_..
._
_._
_
._
_
>
.
.
,.
Plant tours were conducted to observe activities in progress and verify compliance with administrative requirements. Systems and equipment in areas toured were observed to confinn operational status and to monitor for fluid leaks and abnomal
<
vibrations.
Pipe snubbers and restraints were observed for proper conditions.
Plant housekeeping conditions were observed for confomance with AP 0042, Plant Fire Prevention, and AP 6024, Plant Housekeeping.
The plant was cperating at 91% full power in end-of-cycle coastdown at the be-ginning of the inspection period. The plant shutdown on September 20, 1985 to begin a 32 week outage to replace the primary loop recirculation piping and to complete routine refueling and maintenance activities. Reviews and findings were as described below.
,
7.1 The actions taken by plant personnel during periods when equipment was inoperable was reviewed to verify technical specification limits were met; alternate surveillance testing was completed satisfactorily; and, equipment return to service upon completion of repairs was proper. The above reviews
were completed for the following items: removal of the HPCI system from service
'
!
on August 5,1985 for turbine-pump alignment; the sequential removal of the A and B diesel generators from service on August 28, 1985 for maintenance; the
,
failure of the service water effluent radiation monitor on August 28, 1985; and,
'
failure of the stack gas channel I radiation monitor detector on Septemler 1, 1985.
No inadequacies were identified.
7.2 The inspector reviewed the feedwater spcrger leakage detection system and the monthly perfomance sumary provided by the licensee in accordance with letter FVY 82-305. The licensee reported that, based on the leakage monitoring data re-duced as of August 31, 1985, there were no deviations in excess of 0.10 from the steady state value of nomalized thermocouple readings, and no failures in the 16 themocouples initially installed on the 4 feedwater nozzles. No unacceptable conditions were identified.
,
i 7.3 The Residual Heat Removal, Residual Heat Removal Service Water, High Pressure Coolant Injection, Core Spray, Standby Liquid Control, Standby Gas treat-ment and Reactor Core Isolation Cooling (RCIC) systems were reviewed to verify the
!
systems were properly aligned and fully operational in the standby mode. The review included:
(1) verification that accessible, major flow path valves were
'
!
and, (3)y positioned; (2) verification that power supplies were properly aligned; correctl visual inspection of major components for leakage, proper lubrication, cooling water supply, and general condition. The RCIC system valve configuration
.
was reviewed for conformance with the positions specified in the system flow diagram and operations procedure. No inadequacies were identified.
7.4 Radiation controls established by the licensee, including radiological
surveys, condition of access control barriers, and postings within the radiation l
l l
-.
- -
-
_
. - -..- - - -
.-.-- - - -
. _.
.-
.
_ _-
_
_. -
-
-.
-
. _
-
i
.
contrclied area were observed for conformance with the requirements of 10 CFR 20 and AP 0503. Work activities were reviewed for conformance with RWP requirements.
No inadequacies were identified, 7.4.1 The licensee infomed the inspector on August 30, 1985 of a request for assistance from Vement State officials to investigate the possible presence of radioactive material at a private residence. Licensee technicians accompanied
^
Vermont State representatives on September 3,1985 to survey three 55 gallon drums at the Brattleboro Salvage Yard in Guilford, Vemont. No contamination or radioactive material was found. The drums had Vemont Yankee shipping labels affixed to them and originally contained Drewsperse, a chemical used to treat river water used.in plant systems. The barrels were most likely received on site several years ago (about 1980) and following use of their contents on site, they j
were released from the site. No inadequacies were identified.
7.4.2 The licensee notified the inspector on August 29, 1985 that a survey completed on August 9th identified contaminated resin material in a 6 ft. by 6 ft.
grass area in the owner controlled area field on the North end of the site. The general area centamination readings were 1000 to 2000 dpm above background. The highest level of contamination was 30,000 dpm in a 1 ft. square area, which was less than 0.1 mrem /hr. The licensee excavated the area on August 9th to reduce the cortmination levels to less than 100 counts above background, as measured
on an RM-14 survey instrument with a HP-210 probe. The licensee resurveyed the area in the presence of the inspector on August 29th and identified another spot of contamination in the dirt reading 1500 dpm above background. The spot was excavated.
Assuming the material was C0-60 with a measured total activity of 0.1 micro-
.
Curies, no federal limits were violated based on the concentratons of material identified in an unrestricted area. No 10 CFR 20 limits were exceeded relating i
to dose rates in an unrestricted area. No criteria were reached that would re-
'
quire fomal reporting of the discovery to the NRC. The levels of radioactivity l
discovered in the area was very small and the presence of the material would not i
create a health hazard for licensee workers or the general public.
\\
,
j The area of contamination was located near a ' trash heepl usedby utility workers to dump grass clippings, river trash cleaned from the intake structure and
>
debris from yard work. The spot where the resin was found was generally over-grown with grass and shrubs such that visual identification of the resin material without the aid of radiation detection instrumentation would be very unlikely.
Based on the above circumstances and a review of the survey techniq'ies used by the licensee following the discovery of contaminated material in the same general area on October 24,1984 (reference Inspection Report 84-21),the inspector l
detemined that the resin material had probably not been released from the plant
'
since the licensee instituted stricter controls over the release of materials.
The licensee's review of the finding determined that the material had probably been in place for several years. The area where.the material was discovered had apparently been used during initial plant operation to dispose of slightly con-
!
taminated material. The licensee's administrative limits at that time would
'
have allow 2d release of material to the unrestricted area if fixed radioactivity
.. - -. - -. - - - -
-.-.-.-
.- -.-.-
- -. - - - -
levels were less than 0.1 mrem /hr. The licensee's current release limits on fixed radioactivity is less than 1000 dpm above background.
The licensee plans to resurvey the owner controlled area using a PRM-6 survey instrument with a NaI detector. The survey will be conducted with the probe held about 3 feet above the ground. Any areas with readings of 10,000 counts per minute above background on the PRM-6 will be investigated further with a RM-14 survey instrument. The resident inspector will follow licensee corrective actions and survey results on a subsequent routine inspection (IFI 85-25-03).
7.5 Implementation of jumper and lifted lead (J/LL) requests 85-20 through E5-49 ':as reviewed to verify that controls established by AP 0020 were met; no conMiet with the technical specifications were created; requests were properly approved prior to installation; and, a safety evaluation in accordance with 10 CFR 50.59 was prepared if required. No inadequacies were identified, except as noted below.
7.5.1 J/LL 85-43 was implemented on August 17, 1985 in conjunction with MR 85-2145 to isolate a ground on circuit #4 of the 125 VDC distribution panel DC-IC, which is powered from the A station battery. The ground was suspected to be caused from a fault in DC control solenoid for the inboard MSIV on the 'B' main steam line. The inspector determined that implementation of the request would not adversely impact plant safety, and that the temporary wiring change was properly installed.
Completion of the jumper request changed the facility as described in FSAR Section 7.3.4.6 and Figurc 7-3.4, and a safety evaluation (SE) of the change per 10 CFR 50.59 was required. The jumper request from VYOPF 0020.01 was checked on step f to indicate that a 50.59 safety evaluation was not required.
However, a note appended to the fom, which was intended to justify why no SE was required, presented the technical justifications as to why no unreviewed safety question would be created by the wiring change.
The inspector discussed this matter with the licensee and determined that the initiators of the request had misinterpreted the criterion in step D.2 of AP 0020.
Following review of the wiring change and the requirements of AP 0020 with the inspector, the Engineering Support Supervisor acknowledged that a safety evaluation was required. The supervisor stated that the request would be amended to include
a properly documented safety evaluation, and that the item would be discussed during subsequent department training sessions.
The inspector had no further comment on this item at the present time. However, the above item constituted the second recent finding (reference inspection item 85-14-01) where the requirements of AP 0020 were not properly implemented by Engineering Support personnel. This matter will be followed during subsequent routine inspections of jumper requests to detemine whether a concern exists re-garding personnel familiarity)with the requirements of AP 0020.This is
'
I inspection item (UNR 85-25-04.
!
!
l
- - - __
..
.
.
The licensee deferred further investigation of the ground on the MSIV DC solenoid circuit until after the plant shutdown scheduled for September 20, 1985. The licensee's actions to identify and correct the ground on DC-1C circuit #4 will be followed by the inspector on a subsequent inspection (UNR85-25-05).
7.6 The A recirculation pump tripped at 12:25 AM on September 10, 1985, for no apparent reason with the reactor operating at 82% power in end-of-cycle coast-down. Plant operators stabilized the plant with the B recirculation pump in accordance with operating procedure OP 2110. Two subsequent attempts to restart the reci:'alation pump were unsuccessful due to a lockout condition on the MG set.
The plant remained at 50% power pending evaluation and repair of the MG set control circuitry. Single loop operation is permitted for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per Technical Specifica-tion 3.6.G.
Plant operators recorded and evaluated jet pump and recirculation loop performance data, which was found consistent with values obtained during previous periods of single loop operation.
The licensee identified a fault with the limit switch circuitry on the A recirculation pump suction valve, V2-43A, which erroneously indicated the valve was less than full open and thereby activated the pump motor trip circuitry.
.
The motor trip on suction valve position is a pump protection featura only and provides no safety function. Following completion of a safety evaluation, the licensee instituted electrical jumper 85-49 to bypass the motor trip on suction valve position, and to deenergize the suction valve motor operator closing coil to preclude inadvertent closure of the suction valve. The A recirculation pump was restarted at 2:49 P.M. on September 10, 1985 and declared operable at 3:35 P.M.
Operation at 82% full power resumed.
Licensee investigation of the valve position circuitry determined that the pro-blem stems from a short between the limit ~ switch cables from the A recirculation suction and discharge valves as the cables pass through a common junction box-inside the drywell. The problem will te investigated further following plant, shutdown for the refueling outage scheduled to begin on September 20, 1985. The resident inspector will follow the licensee's evaluations and corrective action plans on a subsequent routine inspection (UNR 85-25-06).
..
.
7.7 Switching and Tagging activities were reviewed to verify equipment was controlled in accordance with AP 0140, Vermont Yankee Local Control Switching Rules. ' Actions completed under Switching Orders85-423, 85-477 and 85-480 were reviewed. No inadequacies were identified, except as noted below.
-7.7.1 The inspector reviewed the actions taken to tag out the B diesel generator for maintenance on hugust 28, 1985. The order included tagging closed manual air start valves'91C and 91D, which were re-opened when the maintenance was completed.
The tagging authority elected to use post maintenance functional testing of the j
' diesel as the ' independent verification' of proper clearance of the tags and re-
'
positioning of the airtstart isolation valves. The inspector verified that the l
valves were properly positioned following clearance of the tags, but noted that
.
%
'
,
'
l
-
-
-
, --
.
.-
- - -.
.
.
.
i functional testing could not provide the desired verification since the valves are mounted in parallel on the air supply header. This matter was discussed with the SCR0 responsible for clearing the order, who acknowledged the inspector's coments.
'
The above finding constitutes an isolated case based on previous reviews of tagging operations. The correct performance of independent verification will be reviewed further during subsequent routine inspections of tagging activities.
7.8 The inspector attended a meeting of the Plant Operations Review Comittee (PORC)ofAugust 28, 1985, which was held to review routine plant operational matters and activities planned during the forthcoming refueling and recirculation pipe replacement outage. The status listing of PORC follow items were also re-viewed. Technical specification administrative requirements for the meeting were met. The inspector noted a good technical exchange on issues brought before the comittee for resolution. No inadequacies were identified.
7.9 During a routine tour of the Reactor Building on September 9, 1985, the insp;ctor noted a supply of wood on the 252 ft. elevation that was being used for the construction of a raised floor near the drywell entrance. The inspector noted that no new instructions or special equipment regarding the materials had been provided to the roving fire watch for the area. The roving fire watch, previously established as an interim compensatory measure for identified deficiencies related to the Appendix R - safe shutdown fire protection require-ments, passed through the area once every two hours. An additional fire ex-
'
tinguisher was in the area as part of the existing fire watch controls.
The matter was discussed with the licensee's Fire Protection Coordinator, who was aware of the material and the construction activity. The licensee stated that the material was Underwriter Laboratories approved, impregnated fire
!
retardant wood. The material was tested in accordance with ASTM Test E-84 and had a certified fire retardant rating of less than 25 for the properties of flame spread, fuel contribution and smoke generation. The licensee had tried to ignite samples of the wood to verify it would not sustain combustion in the absence of a external combusion source. The licensee had evaluated its use in the Reactor Building, and based on the above, concluded that:
the material was not considered a transient combustible; the material did not negate the radiant heat shield fire barrier installed between MCCs 89B and 9B; and, no additional fire watch controls were needed for the area beyond those already in effect.
The inspector noted the licensee's evaluation and reviewed the purchase order documentation for the wood, the ASTM E-84 Standard Test Method for Surface Burning Characteristics of Building Materials, and the sumary of Fire Retardant Materials provided in the NFPA Handbook,15th Edition. No inadequacies were identified.
I
,
- - - - - - - - - - - - - -
,,.
-
.-
. ~. -
.
.
During a review of this matter with Region I staff on September 17, 1985, it was determined that the wood should be considered a transient combustible. The licensee was requested to establish a continuous fire watch for the area. The licensee disagreed with the staff position of technical grounds, but agreed to establish a fire watch. A continuous fire watch would be established for the area beginning September 17, 1985 and would be continued until the plant entered a cold shutdown condition, at which time the systems protected by the fire watch would no longer be required to be operable. The inspector toured the area during the evenings of September 17 and 18, 1985, and noted that the fire watch was es-tablished and personnel were familiar with their assigned responsibilities. No inadequacies were identified.
8.0 Post Closecut Review of TMI Action Plan Items The inspector reviewed a sample of TMI Action Plan items (NUREG 0737) which had been closed to determine whether subsequent problems have been experienced (e.g., operation, maintenance, procedures,etc.). Based on the specific items
<
reviewed below and discussions with licensee personnel, the inspector found no significant problems being experienced on closed out TMI Action Plan items.
Concerning the overtime limiting requirements of item I.A.1.3, the inspector reviewed the safety evaluation report (SER) which provided the basis for the December 15, 1981 NRC acceptance of the licensee's position. The inspector reviewed AP 0036, Shift Staffing, Revision 4, which specifies requirements consistent with NUREG 0737 and the SER. The inspector reviewed the Reports of Excessive Overtime, which AP 0036 specifies be filled out when projected over-time will exceed the guidelines. The inspector found only six instances since December,1981 when Reports of Excessive Overtime were needed.
The inspector reviewed the SER for the January 15, 1982 NRC approval of item I.A.1.1, STA Training, and licensee procedure AP 0713, Shift Engineer Training.
The inspector found them to be consistent.
The inspector reviewed the SER for the December 15, 1981 NRC acceptance of the licensee's position on item I.C.5.
Feedback of Operating Experience, and AP 0008, Operating Experience Review and Assessment /Comitment Tracking. The inspector found them consistent. The inspector discussed the assessment process with personnel from the assessment group and reviewed Audit Report VY-84-17 dated December 21, 1984, the annual audit of the assessment program required by AP 0028. Based on the above, the inspector concluded that there were no significant problems with the assessment program.
The inspector reviewed the design changes to the Reactor Core Isolation Cooling (RCIC)SystemassociatedwithitemsII.K.3.13,II.K.3.15,andII.K.3.22 (automatic restart after reactor high level trip, 5 second time delay in break detection logic, and automatic suction switch over to suppression pool on condensate storage tank low level, respectively). The inspector reviewed the applicable SERs and operating procedure (0P) 2121, RCIC System, Revision 15.
The inspector discussed the design changes with the licensed operators. The inspector found that the changes reviewed in the SERs were specifically covered in the operating procedure and the licensed operators were knowledgeable of the changes.
.
-
.
The inspector interviewed licensee personnel including a Shift Supervisor, licensed operators, engineering support personnel, and maintenance supervisory personnel concerning TMI Action Plan items in general and the above items in particular. The personnel were not aware of any current problems concerning design, operation, maintenance or testing of completed TMI Action Plan items.
They did note that some problems were initially encountered such as spurious alams from the control room toxic gas monitor and animosity between shift engineers and licensed operators, but that these problems had been resolved, for example, by improved calibration techniques and assignment of shift engineers to a given operating shift, respectively.
The inspector found no current problems in the operation, maintenance or training associated with completed TMI Action Plan items.
9.0 Surveillance Activities The inspector reviewed portions of the surveillance tests listed below to verify that testing was performed in accordance with administrative requirements. The review included consideration of the following:
procedures were technically adequate; testing perfomed by qualified personnel; test data demonstrated confomar,ce with Technical Specification requirements; test data anomalies appropriately resolved; surveillance schedules met; test results reviewed and approved by supervisory personnel; and, proper restoration of systems to service.
+ OPF 4121.01, RCIC Monthly Surveillance, 8/5/85
+ OPF 4121.05, RCIC Pump Operability and Full Flow Test, 8/5/85
+ OPF 4123.02, Core Spray M0V Operability Test, 8/5/85
+ OFF 4123.01, Core Spray Full Flow Data Sheet, 8/5/85
+ OPF 4124.04, RHR Pump Operability Data Sheet, 8/4/85
+ OPF 4124.06, RHRSW Pump & Valve Operability, 8/4/85
+ OPF 4124.01, RHR Valve Operability Test, 8/4/85
+ OPF 4343, Automatic Depressurization System Functional, 8/6/85 No inadequacies were identified.
10.0 Diesel Generator Brush Rigging An inspection of the brush rigging assembly on the VY diesel generators was com-pleted on August 26-27, 1985, based on a request from NRC Region I to determine the similarities between the generator brush holder assembly on the VY machines with a system that failed at Millstone III on August 12, 1985. Access to the components of interest was very limited since the engines were in standby, with the end covers and screens in place.
The inspector noted that there are two brush assemblies per collector ring and there are two collector rinct. The brush holder assembly and mounting configura-tion on the Colt-Beloit engine is similar to the configuration on the Colt-Pilstick
'
machine, except that (1) the length of the brush holder support stud is about 8
. _.
,.
._
.--
- _. _ -_________
.
.
inches instead of 2 feet; and, (ii) the brush-bar rigging uses a disc, rather than a support bar attached to the housing.
The similarities also include the brush holder assembly and the use of a solid brush holder support stud that is threaded on one end and attached to the disc support piece by one nut on the outboard side of the disc. The brush holder assembly failure noted previously occurred at the threaded end of the support stud.
This item is considered open pending further NRC staff review of brush rigging assemblies for Colt diesels and further discussion with the licensee staff regarding ins ection plans for the diesel during the 1985 refueling outage (IFI 85-25-07.
11.0 Emergency Preparedness Drill The licensee conducted a limited scale emergency drill starting at 8:30 A.M.
on September 11, 1985 to test the readiness and operations of the new Emergency
,
Operations Facility (EOF) located at the corporate offices in Brattleboro, Vermont. The States of Vermont, New Hampshire and Massachusetts participated in the drill by sending representatives to the EOF, and by partially activating the State EOCs. The resident inspector observed the licensee conduct the drill from the new EOF on September 11, 1985 and witnessed the licensee's critique of the exercise. Exercise problems and improvement items noted by the inspector were also noted by the licensee. No inadequacies were identified.
By letter FVY 85-82 dated September 12, 1985, the licensee notified NRC Region I that, based on the results of the partial exercise, the new EOF was ready for operation. The emergency plan was revised to incorporate use of the new E0F.
The plan change went into effect on September 16, 1985.
The inspector had no further coment on this item at the present time. NRC staff review of the revised emergency plan will be reviewed further on subsequent routine inspections.
12.0 Maintenance Activities The maintenance request log was reviewed to detennine the scope and nature of work done on safety related equipment. The review confinned: the repair of safety related equipment received priority attention; Technical Specification limiting conditions for operation (LCOs) were met while components were out of service; and, perfonnance of alternate safety related systems was not impaired.
j Maintenance activity associated with the following was reviewr.d to verify (where applicable) procedure compliance and equipment return ta service, in-cluding operability testing.
~
.
.-..
,, - -,
- -. -.
, - _ _,
.-
-
.
I
+ MR 85-1749, ' A' Recirc Pump Suction Valve Limit Switch
+ MR 85-2145, 'A' MSIV DC Solenoid Ground
+ MR 85-1553, RAN-0G-3128 Failure
+ MR 85-1438, ' A' Diesel Generator Fuel Oil Check Valve
+ MR 85-1678, 'B' Diesel Generator Fuel Oil Check Valve
+ MR 85-1699, 'B' Diesel Generator Fuel Oil Check Valve No inadequacies were noted. The inspector had no further connent on this item, except as noted below.
12.1 The licensee replaced the fuel oil header check valves on both diesel generators on August 28, 1985 as part of a preventive maintenance (PM) measure.
The PM practice was established due to previously observed failures of the check valves to seat fully and maintain the diesel fuel oil header partially pressurized.
The diesels will start with no pressure in the fuel oil header, but the starting time could excced the 13 second requirement by several seconds. The 'A' diesel was found satisfactory following repairs.
The performance of the check valve on the 'B' diesel was subsequently found un-
,
satisfactory due to an inability to maintain pressure on the fuel oil header and the diesel was declared inoperable at 10:42 A.M. on August 29, 1985. Upon dis-assembly and inspection, the licensee noted a slight swelling of the BUNA-N seating material, along with a small amount of brass flakes on the seating surface of the check valve.
Either the flake problem or the expanded seat material could have prevented the check valve from seating properly. The brass flakes most likely came from the check valve and probably were in the valve when installed on August 28, 1985. However, the presence of the flakes upon receipt from the vendor could not be verified since che check valves were not disassembled for inspection prior to installation. Actions were t:tken to require valve disassembly and inspection during subsequent receipt of mato f al. The 'B' diesel was returned to an operable status at 5:10 P.M. on August 29, 1985 following cleaning and re-assembly of the check valve.
The licensee worked with the diesel vendor to obtain a replacement check valve having a seat material other than BUNA-N. The diesel was declared inoperable at 12:15 P.M. on August 31, 1985 and a check valve with Viton seats was installed.
The Viton material had previously been determined to not swell in a fuel oil environment. The valves were installed as non-Q material and dispositioned as acceptable for safety class 3 applications based on a safety evaluation provided in Nonconfomance ?eport 85-27. However, the new check valves still could not maintain the header pressurized and the original RUNA-N seats were reinstalled.
The diesel was returred to service at 3:30 P.M. on August 31, 1985. The licensee i
began a program to kee the header pressurized via visual surveillance by the auxiliary operators, who man;,',1y pumped up the header to assure a positive pressure was maintained. The inspector toured the diesel generator room to verify that the header pressure runained pressurized.
The licensee further reviewed the diesel fuel oil header piping configuration relative to the day tank and the header pressure monitoring instrumentation.
This review detemined that even with no pressure indicated on the skid mounted
.
,
.-
,
--.
_
,_.
,. -
..-.-,w
_
_ _
.
_ _
- -
.
._-
.
_.
__
___
-
.
,
'
.
pressure instrumentation, enough ' head' was provided by the tank to maintain
'
the header fell and slightly pressurized as long as the fuel oil day tank level was maintained above 85 inches. The licensee verified during a test on August 30,
,
1985 that the diesel would start in 12.5 seconds with 0 psig measured pressure on
,
the header and at least 85 inches in the day tank. Based on the above, starting
'
on September 5,1985, the licensee allowed the 'B' diesel fuel oil header to de-
,
l pressurize and auxiliary operator surveillance was directed to a verification that day tank level remained above 85 inches, and that noleaks developed in the fuel oil supply lines to the engines.
On September 28, 1985, the inspector reviewed the auxiliary operator round sheets and noted that diesel day tank level had been observed and recorded as required since September 6, 1985, except that all three shifts missed recording the required
infonnation on September 15 and September 17, 1985. The inspector noted that day
'
tank level was maintained greater than 85 inches during the same period. This matter was discussed with the Assistant to the Operations Supervisor, who provided
,
additional instructions to shift personnel on the data recording requirements.
!
Licensee review of the original and replacement check valve design was still in progress at the conclusion of the inspection. The licensee's disposition of this
l item will be followed on a subsequent inspection (UNR 85-25-08).
13.0 Operations Supervisor Duties
,
The recently appointed Operations Supervisor began his assignment on August 5,1985.
The inspector met with the individual on August 6,1985 to review his duties in regard to the requirements listed in Technical Specification 6.1.D.7., which re-quires that a supervisor possessing a senior operators license approve all instruc-
,
!
tions to shift crews involving licensed activities. The licensee explained the measures taken and planned to meet this requirement, which included the identifica-tion of activities by plant procedure which must be approved by the Assistant Operations Supervisor, who possesses a senior operators license. The inspector
,
i reviewed the listing of procedures and activities and identified no concerns.
The inspector noted that the Operations Supervisor plans to complete a senior i
licensed operator certification program. The inspector noted that the individual had previously held a senior operators license for the facility and had held the position of shift supervisor. No inadequacies were identified.
i
.
14.0 Seismic Restraints for HCU Insert / Withdraw Lines
The licensee notified the inspector on September 10, 1985 of his intent to defer modifications to the HCU insert / withdraw lines that were planned to be completed during the. forthcoming refueling outage under EDCR 80-53. The licensee concluded
,
i i
l
....
.
_
_ _.. _ _ _ _ _, _ _
.
-
'
.
that he would not be able to complete the installation during the pipe replace-ment program, even though the design for the HCU supports were complete, since the HCU work would directly interfere with the laydown and staging efforts
associated with the pipe replacement. The licensee proposed completing the HCU work within 5 months of returning to power operation. The licensee stated that his intention to defer the HCU work would be submitted in writing to NRC:NRR for review.
j The inspector noted the above and met with the Technical Services Superintendent on September 10, 1985 to review the licensee's plans. The inspector requested the licensee to provide further information regarding the HCU modifications and why the HCU work would conflict with the recirculation pipe laydown/ staging requirements.
This item is open pending (i) inspector review of the proposed plant activities; and, (ii) the NRR review of the licensee's proposal (IFI 85-25-09).
15.0 Control Room Carpeting i
The licensee notified the inspector en September 18, 1985 of his intent to install carpeting in the main control room. The licensee's evaluation of the carpeting in regard to fire protection requirements was documented in a memo from R. W. Capstick to R. Sojka dated May 8, 1985. A safety evaluation documented in a memo from E. A.
Sawyer to A. C. Kadak dated August 16, 1985 concluded that no unreviewed safety question would be created in the proposed installation.
The licensee will use Tate Industries ' Geneva 2' carpeting, which has a Class I rating per NFPA Standard 253-1978. The licensee reviewed the proposed installation against the commitments made in response to NRC Generic Letter 85-1 and exemption requests for Appendix R to 10 CFR 50, and detemined that installation of the carpeting would not be precluded by the Fire Protection Program, the license or the technical specifications.
The inspector reviewed this item with the Region I and NRR staffs and noted that Section 9.5.1 of the NRC Standard Review Plan states that carpeting is not allowed in the control room. However, the standard review plan is a guidance document >and the NRC staff has previcusly approved plans by facilities to install carpeting in the control room (reference NUREGs 0896, 0989 and 0831). The NRR Project Manager requested the licensee to document his plans in a letter to NRC:NRR. The inspector detemined based on discussions with the NRC staff that the licensee's plans are ceptable.
....s item is open pending (1) the licensee's submittal of a letter to NRR to docu-ment his pians to install carpeting in the control room; and, (ii) further review of the purchase specifications and receipt documentation by the inspector to verify that the carpeting meets the requirements of the NFPA 253-1978 standard (UNR 85-25-10).
l 16.0 Review of Proposed LLRW Facility The inspector met with licensee representatives and the Nuclear Engineer from Vermont State on September 16, 1985 to hear a licensee presentation regarding the
_
_
_
__
.
.
.
r
plans to install a low level radioactive waste (LLRW) storage facility at the site. The inspector also reviewed the preliminary design and safety evaluation for the facility as described in Plant Alteration Request 85-02 and YAEC Memo OPVY 446/85 dated June 19, 1985. The inspector noted that the licensee plans
,
to install the LLRW facility under the provisions of 10 CFR 50.59, and that the licensee was aware of and considered the guidance for the interim storage facilities provided by the NRC staff in Generic Letter 81-38 dated November 10, 1981.
The following coments were discussed with the licensee on September 18, 1985 following the inspector's initial review of the preliminary plans:
+
No operating procedures have been developed for the facility yet, but none
'
are imediately required since the facility will not be used before January 1, 1986 and possibly not until May,1986. The inspector stated that the licensee should begin procedure development soon to allow sufficient time for procedure review and approval prior to use of the facility.
The procedures should address, as a minimum: controls on waste handling opera-tions; orientation of waste modules in the facility to optimize shielding; periodic monitoring and surveillance; periodic liner venting; contingency plans for spills and handling accidents; inventory control; restricted area and access centrols; and generally, administrative limits to assure operation of the facility remains within the assumptions of the safe evaluation (e.g., restrictions on movement of storage containers when loaded.
+
The licensee's safety evaluation presented conclusions and findings in such a manner that it was difficult to compare the radiological impact from normal
,
use of the facility to the limits established in 10 CFR 20 and 40 CFR 192.
'
+
The inspector noted during a review of sitin licensee's plar.s departed from the Section III(c)g for the facility that the
,
guidance of GL 81-38 relating to the manner in which the storage site will be incorporated into the plant physical security program.
The licensee's plans to install a LLRW facility under 10 CFR 50.59 will be kviewed further during a subsequent routine NRC inspection. Resolution of the above items will be addressed at that time. This item is open pending completion of the licensee's design and installation plans for the LLRW facility and subsequent review by the NRC (UNR 85-25-11).
i l
17.0 Management Meetings Preliminary inspection findings were discussed with licensee management periodi-
cally during the inspection. A summary of findings for the report period was also dist:ussed at the conclusion of the inspection and prior to report issuance.
l
.
l
_
_
_
_ _.
_ _, _
.
. -
.
..
.
..
- -
--
-