IR 05000271/1990002

Insp Rept 50-271/90-02 on 900313-0507.Violations Noted But Not Cited.Major Areas Inspected:Plant Operations, Radiological Controls,Maint/Surveillance,Emergency Preparedness,Security Engineering/Technical Support

ML20043G775
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/12/1990
From:	Gray E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20043G772	List: IR 05000271/1990002 ML20043G771
References
50-271-90-02, 50-271-90-2, NUDOCS 9006210120
Download: ML20043G775 (28)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-271/90-02 Docket No.

50-271 License No. DPk-28 I

f Licensee:

Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Brattleboro, Vermont 05301 Facility:

Vermont Yankee Nuclear Power Station Inspection At: Vernon, Vermont t

Inspection Conducted: March 13 - May 7, 1990 Inspectors:

Harold Eichenholz.. Senior Resident Inspector Thomas G. Hiltz, Resident Inspector Richard S. Barkley, Project Engineer Jim T. Yerokun, Reactor Engineer Approved by:

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C/9u E, H. Gray, Acting Cyjp*1 Reactor Projects Section 3A Date Areas Inspected:

Resident safety inspection of the following areas:

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operations, radiological controls, maintenance / surveillance, emergency pre-paredness, security, engineering / technical support, safety assessment / quality i

verification, Licensee Event Reports, special reports, and open item followup.

Results:' Inspection results are summarized in the attached executive summary,

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inclu3Ing one Vermont Yankee identified non-cited violation relating to the failure to collect 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of Containment Integrated Leak Rate Test data and two unresolvea items.

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9006210120 900613 PDR ADOCK 05000271-Q PDC

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EXECUTIVE SUMMARY VERMONT YANKEE INSPECTION rep 0RT 50-271/90-02

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MARCH 13 - MAY 7. 1990 Plant Operations A mid-cycle maintenance outage was conducted between March 16-21.

Noted strengths of planning ami communications resulted in no adverse personnel errors or events. A reactor trip on March 21 during plant startup was high-lighted by intensive Vermont Yankee efforts to identify the root cause(s) of

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equipment malfunctions in the generator excitation system and turbine mechanical hydraulic control (MHC) system. A weakness in the reactor operator's level of

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knowledge involving the MHC system was observed, and the procedure covering turoine startup= operations failed to provide the needed guidance. The plant

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personnel response to an HVAC buildtop roof fire demonstrated licensee strengths t

in the area of fire protection.

Faciaity housekeeping and the continuing in-

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st llation of new floor treatment material within the reactor building reflects

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strong performance in this area, e

Radiological Controls T

Radiological controls were generally effective in meeting the objectives of the radiological protection program.

LER 90-05 was issued by the licensee to re-

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port a violation of Technical Specification requirements associated with an incorrect evaluation of a containment air sample and subsequent venting of the

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containment without processing the release through the Standby Gas Treatment System.

Maintenance and Surveillance An enhanced Maintenance Request procedure was developed which provided clarity-r

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The Vermont Yankee effort was

responsive to an NRC Maintenance Team Inspection identified weakness in the

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area of post-modification testing. An Unresolved Item was identified involving

- the apparent electrical inoperability of a motor operated valve following its

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manual operation. An Unresolved Item was closed that involved Vermont Yankee changes to its Emergency Diesel Generator Overhaul Program.

Good performance

was noted in completing overhaul activities of the "B" EDG between April 18-22.

Surveillance activities were effective in meeting the safety objectives of the program. However. a non-cited violation involving inability to meet a 10 CFR

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50, Appendix J requirement to conduct a full 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Containt. ant Integrated Leak Rate Test was noted.

Emergency Preparedness

A specia1' population drill and exercise involving the States of Vermont, New l

Hampshire, and Massachusetts was conducted on April 4 and 25, respectively.

The latter was evaluated by FEMA,'and was determined to have been successful, t

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Executive Summary

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Security-

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Events involving inaccurate background investigations and a public demonstra-tion were reviewed.

Noteworthy inspection findings included strong licensee i

oversight of security contractor activities, timely and comprehensive security event reports, attention to detail, the development of good relations and com-

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munications with offsite local law enforcement agencies, professional security

staff conduct, and proper nuclear security focus on protection of the plant's

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Protected Area.-

j Engineering / Technical __ Support Temporary Instruction 2M0/27 addressing licensee actions in response to NRC Compliance Bulletin 87-E was_ closed based upon adequate controls being main-

tained for safety-related fasteners and licensee actions to address conformance

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with material specifications, i

Safety Assessment / Quality Verification An Unresolved-Item involving the licensee's overtime control procedure was closed. The Plant Safety Review Committee performed a good self assessment as_

part of its comprehensive review of plant conditions prior to the startup from the mid-cycle maintenance outage.- A clear demonstration by Vermont Yankee man--

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agement involving quality over production was demonstrated in response to-equipment problems during the startup of turbine and generator systems.

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TABLE OF CONTENTS

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Summary of Operations................................................

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Plant Operations (IP 71707,93702,92700,90712*)....................

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2.1 Inspection Activities...........................................

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Inspection Fincings an' Signfficant Plant Events................

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Mid-cycle Maintenance 0utage...............................

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B.

Reactor Trip and Primary Containment Isolation System i

Actuation Due to a Turbine MHC-System Failure (LER 90-04)

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HVAC Building Roof Fire.....................................

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Unexpected Reactor Power Increase...........................

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Operational Safety Observations............................

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Radiological Controis-(IP 71707,92700,90712).......................

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3.1 Inspection Activities..........................................

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3.2 Inspection Findings and Review of Events........................

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LER-90-05: Incomplete Evaluation of Containment' Sample Due to Failure to Foilow Procedures (0 pen / Unresolved Item i

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90-02-01)................................................

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-Routine. Inspection Findings................................

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Maintenance / Surveillance.............................................

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4.1 Maintenance Inspection Activity (IP 62703,92701)................ -8:

l 4.2 Maintenance Observations........................................

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Development of Enhanced Maintenance Request Procedure......

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RHR Valve 388 Failure (0 pen / Unresolved Item 90-02-02)......

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(Closed) Unresolved Item 90-01-01: Review Chan C.

EDG Overhaul Program........................ges to the

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" B" E DG 0v e r h a u l...........................................

-4.3 Surveillance Inspection Activity (IP 61726, 92700, 90712, 92701, 70323)........................................................

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4.4-Surveillance Observations.......................................

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Main Steam Line Radiation Monitors Scram-Isolation Functional Test..........................................

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(Closed) Unresolved Item 89-02-01: Review 90 Day CILRT Report for Test Methodology Adequacy.....................

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Table of Contents

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EmergencyPreparedness(IP 71707. 93702).............................

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5.1 Special Population Exercise.....................................

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Security (IP 71707,93702,90712,92700).............................

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6.1-Observations of Physical Security...............................

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6.2 Inaccurate Background Investigations............................. 19 l

l 6.3 Anti-Nuclear Demonstration......................................

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Engineering / Technical Support........................................

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7.1 TI 2500/27: " Fastener Testing to Determine Conformance with

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Applicable Material Specifications"...........................

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Safety Assessment / Quality Verification (IP 40$00,71707,92701)......

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8.1 (Closed) Unresolved Item 89-21-01: Review Licensee Overtime

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Procedures....................................................

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8.2 PORC Activities.................................................

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8. 3 ' I n s pec to r Ob s e rva t i on s..........................................

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Licensee Event Report (LERs), Special Reports, and Open Item Followup i

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(IP 92700, 90712, 90713, 92701)....................................

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9.1.LERs.............................................................--22

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9.2 Periodic and Special Reports....................................

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9.3 'Open Item Fo11owup....-................'..........................

10. Management Meetings (IP 30703,94702)................................

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..*The NRC: Inspection Manual inspection procedure (IP) or temporary instruction

(TI).that was used as inspection' guidance is listed for each applicable report

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DETAILS 1.

SUMMARY OF OPERATIONS Vermont Yankee Nuclear Power Station (VYNPS or the plant) was at full power

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at the beginning of this report period.

A mid-cycle maintenance outage,

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with its primary focus being the repair of two drywell air cooling units,

was conducted March 16-21. This shutdown completed a continuous 340 day period of operatian, which represented a new plant record.

During plant startup activities on March 21, an automatic reactor trip and primary con-i tainr.ent isolation system actuation occurred as a result of a malfunction of the turbine's Mechanical-Hydraulic Control (MHC) system, Duritg this

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startup, problems with the main generator's excitation system were en-countered.

Following repairs to the MHC and excitation systems, full power operation was achieved on March 29.

Short term scheduled power reductions i

to 80-94% of full rated power were conducted weekly to perfore routine

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surveillknees of control rod drives, main turbine vsives and bypass valves.

During the report period Vermont Yankee was notified that the New England i

Coalition on Nuclear Pollution and the State of Massachusetts have with-drawn from the Spent Fuel Pool expansion NRC licensing proceeding. On April 27 the Vermont legislature approved a comprehensive low-level waste siting bill, whien gives VYNPS property preferential site status for a disposal facility. A demonstration by approximately 130 anti-nuclear ac-

tivists occurred on April 28.

Some of the demonstrators conducted civil disobedience that involved blocking the mein gate, scaling the owner con-trolled area fence, and climbing the plant stack.

No challenges to the plant's Protected Area occurred.

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A meeting was held in Rockville, MD on April 30 between representatives of Vermont Yankee, staff of the NRC's Office of Nuclear Reactor Regulation

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.(NRC:NRR), the resident inspectors, and representatives of the State of

Vermont, to discuss licensing issues involved with proposed hardened wet-

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well vent and toxic gas monitoring equipment performance.

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2.

PLANT OPERATIONS 2.1 Inspection Activities

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The inspectors verified that the facility was operated safely and in conformance with regulatory requirements.

Management control was evaluated by direct observation of activities,. tours of the facility, interviews and discussions with personnel, independent verification of safety system status and Limiting Conditions for Operation, and review of facility records.

The inspectors performed 309 hours0.00358 days <br />0.0858 hours <br />5.109127e-4 weeks <br />1.175745e-4 months <br /> of normal and back shift inspection including weekend, holiday, and deep backshift inspections on:

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Date Time

E March 17, 1990 7:00 a.m. - 4:30 p.m.

March 18. 1990 4:30 a.m. - 1:45 p.m.

March 20, 1990 11:30 p.m. - 12:00 a.m.

l March 21, 1990 12:00 a.m. - 2:45 a.m.

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March 22, 1990 4:30 a.m. - 6:00 a.m.

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March 25, 1990 9:00 a.m. - 7:30 p.m.

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April 14, 1990 11:00 a.m. - 6:00 p.m.

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April 21.-1990 11:30 a.m. - 6:15 p.m.

April ?8, 1990 2:00 p.m. - 7:00 p.m.

Operators and shift supervisors were alert, attentive and responded appropriately to annunciators and plant conditions.

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2.2 Inspection Findings and significant Plant Events

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A.

Mid-cycle Outage

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At 12:00 p.m. on March 16. Vermont Yankee commenced a shutdown to cold condition to conduct a four to five day mid-cycle main-tenance outage. Although the primary purpose for the outage was to repair two of the four drywell air cooling units (RRUs) other corrective maintenance, preventive maintenance, surveillance testing, and inspection activities were planned and conducted.

The equipment malfunctions associated with RRU-1 and RRU-4 fail-ures were previously documented in inspection reports 89-17 and 89-22, respectively.

Vermont Yankee actions to repair the RRVs were necessary to preclude a plant shutdown that would have ultimately been required with high air temperature due to sea-sonal conditions later in the year.

During this operating cycle,:the plant has experienced fuel failures, which caused Vermont Yankee to give consideration dur-ing this outage to:

(1) conducting work activities that would minimize steam leaks in various systems to preclude or reduce plant contamination problems;-and (2)' preplan shutdown. startup, and equipment operating strategies to minimize the impact of-existing radiological conditions on work activities and possibly prevent further fuel failures. Vermont Yankee's plann4ng efforts.

also included maintenance activities that would support continued good plant performance (e.g. condenser cleaning) for the re-

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mainder of the operating cycle and reduction in the number of projects anticipated to be conducted during the September 1990 refueling outage. On March 21, reactor startup activities com-menced at 1:38 a.m. with criticality being achieved at 3:10 a.m.

the same day.

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Excellent planning and communications continued to be demon-strated by Vermont Yankee in outage management.

Planners, co-ordinators, and implementing personnel all performed well, as

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indicated by no personnel errors or events that would show periods of diminished control occurring between the initiation of the shutdown and the return of the reactor to low power con-ditions. Work efforts were properly.prioritized, staffed, and

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controlled.

Plant operators were observed to display proper attention to detail and a good questioning attitude in carrying out their licensed responsibilities. Plant evolutions were ob-

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served to be conducted in accordance with approved plant proce-t dures.

The inspector also noted that following the outage, a

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" lessons-learned" meeting was conducted by Vermont Yankee to

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review and document their experience for the benefit of enhanc-ing future performance of cutage related activities.

B.

Reactor Trip, LER 90-04 On March 21 the reactor automatically scrammed due to reactor pressure exceeding the reactor high pressure setpoint.

Prior to the scram the reactor was. operating at approximately 25% power.

Directly prior to the scram, the licensee was bringing the tur-bine up to speed in preparation for synchronizing the generator onto the grid. Approximately two minutes after the reactor scram a Primary Containment Isolation System (PCIS) Group I isolation occurred due to steam pressure falling below the low steam pressure setpoint (800 psig) with the mode switch in the

"RUN" position.

The licensee conducted an investigation to determine the failure

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mechanism and root cause of the scram and subsequent PCIS Group I isolation. The licensee determined the root cause of the reactor scram was the lack of response of the #1 turbine control valve at low hydraulic oil pressure. The root cause of the PCIS

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Group I isolation was determined to be the failure of the #1 bypass valve to completely close.

l The inspector reviewed licensee documentation of this event analysis and root cause determination in Plant Information Re-port (PIR) 90-02, vendor manuals associated with the turbine

mechanical hydraulic control (MHC) system, turbine operating

procedures, and the Licensee Event Report (LER) 90-04.

In addi-tion, the inspector inspected licensee activities associated

with corrective maintentnce and troubleshooting of-the failure of the,MHC system and subsequent attempts to accelerate the tur-bine to operating speed.

The inspector noted findings in several areas.

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The licensee's initial troubleshooting and corrective measures were inconclusive in identifying proper corrective action.

It appears that the cause of this reactor scram directly relates to the reactor scram which occurred on October 3, 1987 (Inspection Report 87-16).

The cause of that scram was determined to be insufficient oil pressure supplied by the auxiliary oil pump.

The licensee in-itially attributed the scram on March 21, 1990 to insufficient

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control oil pressure and again pointed to the auxiliary oil pump L

in their preliminary assessment. An unrelated failure of the turbine excitation circuit provided the' licensee with an addi-tional opportunity to analyze the event and gather data gene-rated from trend recorders and temporary control oil pressure monitors. Analysis of this data resulted in the licensee in-vestigation of the return header relief valve lift setpoint for the control valve hydraulic actuators. The as found setpoint of the return header relief valve was approximately 20 psi above the vendor recommended setpoint.

The high setpoint restricted the relief flow path for the control oil and thus reduced the driving differential pressure across the contrei valve actu-ators. The setpoint of the relief valve was adjusted to slightly above the vendor recommended setpoint.. On March 25 the turbine was successfully accelerated to 1800 rpm, however, control valve

1. 1 still responded erratically from 14% to 18% full open posi-tion af ter the main shaf t oil pump output dominated hydraulic control oil pressure.

The licensee determined the root cause of the scram to be a

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failure of the MHC control system to respond as required.

Specifically, turbine control valve #1 did not respond as re-quired due to low differential pressure across the actuator piston. The licensee considers their root'cause analysis to be incomplete pending receipt of the turbine vendor analysis and

future inspections of MHC components.

However, the inspector

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. questioned the licensee about the low differential pressure con-l ditions across.all control valve actuator pistons, not just con-trol valve #1, in the final analysis, the failure of all con-trol valves to actuate in a manner that could have prevented the reactor scram may primarily be due to the improper setpoint of the control. oil return header relief valve.

LER 90-04 remains open pending further licensee analysis.

The inspector also noted discrepancies in the turbine startup and synchronization procedure, OP 0101 Rev.19, " Reactor / Genera-tor System Heatup to Low Power." The reactor pressure guide-lines contained in the procedure prior to rolling the turbine do i

not accurately reflect current operating practice.

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r practice appears to be the result of previous control valve and MHC problems associated with bringing the turbine on line fol-lowing an outage.

Finally, the inspector noted a weakness in the operator's level of knowledge in fundamental MHC system feedback signals.

The inspector determined that operators did not fully appreciate ex-

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pected system response to adjustmer,t of the load limit during

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turbine startup. A lack of understanding of the MHC system L

appears to have been one of the major contributors to three reactor scrams over the past 2 U2 years.

The licensee has re-cently recognized this concern and established administrative control over load limit manipulation during turbine startup.

The licensee also identified the need for addittonal training on MHC control-system feedback signals.

C.

. HVAC Building Roof Fire At approximately 1:25 p.m. on March 22, licensee contractor per-sonnel disc 9vered a fire on the heating, ventilation, and air conditioning (HVAC) fan room roof.

The fire erupted in the vicinity of roofing repair operations involving propane flame heaters.

The flame heaters were being used to help apply asphalt type roofing material.

The fire was reported to the control room and the shift super-visor declared a plant fire emergency. The fire brigade was immediately assembled.

Contractor and licensee personnel on the scene acted by applying dry chemical extinguishers.

Two hoses were charged and used to extinguish the fire.

The fire was ex-tinguished and plant fire emergency terminated at approximately 1:30 p.m.

The inspector reviewed fire protection procedures associated with the roof repair and found them adequate.

Precautions taken by the licensee and contractor personnel exceeded minimum re-quirements. Due to a similar fire in late 1984, additional _ pre-cautions were taken which includeo :.utioning an additional fire watch inside the fan room and staging a hose in the vicinity of the hot work.

The inspectors monitored licensee activities during th'e fire emergency from-the control room and at the scene of the' fire.

The inspector determined the licensee response to the fire to be excellent.

Control room personnel acted resourcefully, calmly, and conservatively is assessing impact of the fire on plant-per-sonnel and plant operations.

Plant operations were not affected.

This' incident involved no radiological hazards.

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Personnel at the scene of the fire were knowledgeable and aggressive in fire fighting techniques. The fire brigade re-sponded immediately with the proper equipment and adequate per-sonnel.

The inspector concluded that the licensee was well pre-

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pared to combat the fire. As a result of this event.the 11cen-see plans that for hot work in areas with roof penetrations, a fire watch in the room below will continue two hours after the

hot work has been completed. The licensee response to this

event is indicative of a strong fire safety perspective.

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D.

Unexpected Reactor power Increase An unerpected power excursion from 65% to 85% of rated power

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occurred on March 27 as a result of a malfunction in the recir-culation system master flow controller.

Specifically, plant was continuing startup operations that began on March 25 and had-(

just completed a power reduction from 89% to 65?; of rated power to facilitate adjustment of control rods for the full power i

patterns, when an unexpected momentary core flow spike. occurred at 9:51 a.m.

Plant operators observed the speed of both recir-culation pumps to be erratic and placed the individual recircu-

lation loop flow controller in the manual mode. Within three-minutes, core flow was returned to the pre-transient value.

Bypass valves opened for approximately six seconds in response

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to the 20?e transient increase in core power, In response to the transient, all plant equipment operated properly, Recirculation flow was subsequently increased at 1:30 p.m. at the completion of the rod pattern adjustment.

The Instrumentation and Control (l&C) Department initiated cor-rective maintenance under Maintenance Request (MR) 90-0786.

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control potentiometer for.the master flow' controller was deter-i mined to be worn and was replaced.

Directly following the transient, the Reactor and Computer Engi-neering Department coordinated the event analysis, which in-cluded the participation of Yankee Nuclear Services Division project and engineering representatives.

The conclusions drawn from the technical review of the short duration power transient were:

(1) fuel mechanical or thermal limits were not exceeded;

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(2) Technical Specifications (TS) were not exceeded; (3) activi-ties remained within all existing analyses; and (4) no abnormal

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increases in offgas were observed.

In accordance with plant procedure AP-0010, " Occurrence Reports," the event was docu-mented in a Potential Reportable Occurrence report and deter-mined not to be a reportable event.

The' response to this event by operations, maintenance, and engi-neering support personnel was appropriate and well coordinated.

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Operational Safety Observations

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Facility housekeeping conditions during this inspection period continued to be maintained by Vermont Yankee at a high level and L

reflects strong performance in this area.

The licensee is con-tinuing its efforts to install new floor treatment material on.

reactor building floors to enhance-cleanliness and contamination e

control. This upgrading effort did not adversely affect opera-tional readiness conditions.

3.

RADIOLOGICAL CONTROLS 3.1 Inspection Activitiet Effectiveness with the radiological protection program was verified t

on a ptriodic basis in accordance with NRC inspection procedure 71737.

3.2 Inspection Findings and Review of Events i

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LER 90-05

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On March 15 a primary containment air sample.was obtained to e

ascertain if venting-to the stack was permissible. This acti-i vity by the Radiation Protection Department (RPD) and Chemistry Department was in support of the scheduled mid-cycle maintenance outage that commenced on March 16.

The sample was evaluated and

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venting to the stack was permitted.

Subsequently, on March 28, Vermont Yankee discovered tnat an incomplete evaluation of the

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containment air sample was performed prior to venting the con ~

tainment directly to the stack. 'Further licensee review deter-G mined that due to the failure of Chemistry Department personnel to follow procedural requirements, the conditions of TS 3.8,L.1 were not' met.

This TS requires venting of the primary contain-

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ment through the Standby Gas Treatment-System whenever the; air-borne radioactivity levels in' containment exceed specified

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values.

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event will-be reviewed during a future Radiological protection Program review by the NRC Region I office (Unresolved Item

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50-271/90-02-01).

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Routine Inspection Findings The inspector observed RPD personnel activity involved in plan-c-

ning and coordinating activities that required radiation pro-tection (RP) oversight.

Licensee recognition of appropriate' Rp concerns involving the need to use Beta shields when venting

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primary system due to failed fuel was evident.

Inspector tours

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of the plant resulted in observations of generally good radio-

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logical housekeeping.

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The inspector reviewed the minutes of the April 5 ALARA Commit-tee Meeting, 90-02, and concluded that they were representative of an active and well functioning committee.

This meeting in-

cluded the participation of the plant manager. Good discussions

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on plant operation items of interest to ALARA concerns and re-

cent exposure experience was noteworthy.

Recent inspector ob-

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servations of the misuse and inconsistent use of RP clothing,

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suggest the need for Vermont Yankee to review personnel perform-ance in this area.

During this inspection period, the licensee conducted a mid-cycle maintenance outage.

The RPD supplemented its normal-staffing to support outage activities.

The assignment of a.

primary containment entry coordinator, and efforts to optimize the Radiation Work Permit process to support outage activities, were notabl.e efforts of the RPD. Inspectors observed appropriate

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radiation protection' measures in place during the outage.

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MAINTENANCE / SURVEILLANCE TESTING 4.1 Maintenance Inspection Activity

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The inspectors observed selected maintenance activities on safety-related equipment to ascertain that these activities were conducted

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in accordance with approved procedures, Technical Specifications, and appropriate industry codes and standards. Additionally, the_inspec-tors performed reviews of licensee changes to the maintenance program and followed up on an outstanding NRC issue.

t 4.2 Maintenance Observatiens

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Development of Enhanced Maintenance Request Procedure

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Vermont Yankee's method for maintenance work order control is the Maintenance Request (MR); which is controlled by plant pro-cedure AP-0021, " Maintenance Requests." The NRC last reviewed

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and documented the established process in 1989 in Inspection Report 89-80. Although the MR process was found to be compre-hensive, the lack of a procedural requirement for post-mainten-ance testing (PMT) was considered a weakness in the licensee's

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maintenance program.

The process and criteria of PMT was not presented in the MR procedure.

In addition to this item, the licensee had informed the inspector that various improvements in the MR process were identified as being necessary'as part of

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corrective actions to address various self-identified deficien-cies.

These included documentation of maintenance activities

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fi4 performed; the safety classification of the work being performed; and control and communicatica of support work provided to the

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initiating repair department. On August 11, 1989, the licensee informed the NRC in their letter BVY 89-75, that AP-0021 is being

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revised, which will include formalization of the PMT process and criteria.

l During this inspection period, the inspector reviewed the status of licensee efforts to address the above enumerated issues.

In January 1990, a Vermont Yankee Task Force comprised of members

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of the operations, maintenance, I&C, and engineering support

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departments was assigned the responsibility of:

(1) reviewing

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the conduct of work versus the prescribed procedural methods and (2) addressing outstr.nding issues associated with the m W ten-

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ance work centrol process. According to tne task force leader,

the addition of administrative and technic.al controls to the MR i

work control process over time has unnecesser.ily cluttered up the process description and MR form.

Revision 17 to AP-0021 was approved by the Plant Operations Review Committee (POAC) on April 27 (attended by the inspector). Training on the new MR process procedure was planned for all applicable p' ant staff and j

the new process was to be implemented on June 1,1990.

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The major changes to the MR procedure include:

(1) providing

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separate instructions for corrective and preventive maintenance; (2) specifing the responsibilities of.the Operations Planning

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Coordinator; (3) providing detailed directions for Maintenance Work Package (MWP) development; (4) incorporating a support work request process to aid the coordination and communication be-tween the departments involved in the work effort; and (5) pro-viding a process and criteria for PMT. The MWP development pro-cess is supported in the procedure with a listing of-adminis-trative and technical controls (e.g., fire permits, housekeep-i ing, lifting equipment inspections, etc.-) that should be con-

sidered during planning effort.

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.One inspector concern that warrants additional licensee atten-tion involves the need for process guidelines for the use of other-than-identical parts.

The licensee in.this case performs f

an evaluation; and if it determines this is to be a one-for-one

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replacement, the MR process may install the part in lieu of a design change.

In summary, the ir.pector determined that the licensee's efforts in this area provide enhanced clarity and substantial process control improvement to the existing process.

The notable strengths exhibited by Vermont Yankee in their ac-

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tions to enhance the MR process involved; good coordination and-

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control between plant departments, a proper level of management

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oversight, and sound technical and safety review by PORC.

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RHR Valve 38B Failure On March 27, while performing residual heat removal (RHR) system monthly ~ valve operability surveillances, the licensee declared

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the "B" containment cooling loop inoperative after failure of

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MOV10-38B (suppression pool chamber spray valve) to successfully stroke.

Subsequently, in accordance with Technical Specifica-

tions, the "A" containment cooling loop was tested satisfar.torily.

MR 90-0782 was generated and licensee personnel investigated the failure of MOV10-38B. The valve operator was disassembled and i

inspected. Minor component degradations found were unrelated to

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the root cause failure of MOV10-38B.

Licensee maintenance per-scrael recreated the failure mode by manually seating the valve.

When the valve wa:, operated in the " hand" mode and driven into

its seat, the tripper fingers remained on the adjustment arm.

This corn!ition prevented motor operation of the valve. When the

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valve was manually backed-off its seat 1/8 to 1/4 turn, subse-

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quent motor rotation engaged the operator in the " motor" mode.

The valve was declared operable on March 31.

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Operations Department caution tagged the valve to help ensure

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operators ere cognizant of valve operability characteristics i

following manual operation.

The licensee continues to investigate this issue.

Results of i

discussions with the vendor (Limitorque) and a repair service company (Movats) are inconclusive.

Currently the licensee has no evidence of generic implications.

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The inspector concluded that a more detailed analysis of failure of MOV-38B is warranted.

The valve is not designed to be elec -

trically inoperable following manual' operation.

The licensee plans additional testing of similarly designed plant valves to identify similar valve anomalies.

Pending the results of this testing and further investigation this item reu.ains unresolved (UNR 50-271/90-02-02),

C.

(Closed) Unresolved Item 90-01-01:

Review Changes to the Emeroency Diesel Generator (CDG) Overhaul program

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This item reflected Vermont Yankee efforts to redirect the EDG Preventive Maintenance (PM) Program by extending the periodicity

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of major overhauls to every 22 to 26 months and to include the ability to conduct the activity during full power operation.

Inspection Report 89-21 documented the NRC's review of the lic-ensee's basis for a one time extension of the overhaul peri-odicity from 12-18 months to 22-24 months.

This included con-currence of the EDG vendor (Colt Industries-Fairbanks Morse) for.

the one time chang e

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Subsequently, Vermont Yankee maintenance department developed a safety eval.mtion that proposed that the routine scheduling of EDG PM be performed on the extended periodicity. This safety evaluation indicated that the developed enhanced PM program.

(although exceeding vendor manual recommendations on periodicity but modeled after the vendor procedures used to grant the one time extension), would allow a permanent extension of the peri-odicity of overhauls. This safety analysis noted that the EDGs have been reliable, with no failures to start, and only one series of problems associated with start times having occurred.

Additionally, it indicated that the inclusion of diesel over-hauls within the busy refuel outage greatly tasks the mainten-ante department's ability to properly control and manage the high volume of safety related work performed simultaneously with the EDG work.

The inspector's review of EDG everhaul activity in the next section of this report indicated that a well managed and controlled activity was accomplished by Vermont Yankee with 1 I the plant in a full power condition.

Also, no unusual degrada-tion or wear was identified during the April, 1990 "B" EDG over-haul.

The major features of the enhanced PM program which is intended by the licensee to provide a combined overall availabiPty for I-both EDGs of 97% annually, includes:

(1) increase diesel oil

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sampling and analysis from semi-annual to quarterly; (2) monthly I

trending of engine operatin0 cata; (2) perform quarterly vibra-tion analysis; (4) conduct vendor type mini-inspections 16-18 months after overhaul and as appropriate opportunities arise to enhance predictive snd preventive actions to identify and cor-

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rect unusual wear or deterioration; and (5) perform the major

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overhaul /PM inspections on a 22-24 month basis during operations and with alternate engines scheduled 12 months apart.

On April 11, 1990, the PORC reviewed and approved the aforemen-tioned enhanced PM program as specified in procedures OP-5223, Revision 8 and OP-5225. Revision 3.

The safety evaluation for EDG PM was also reviewed and approved.

This PORC meeting did address the advisability of incorporating the 4160 Volt Vernon hydro station tie line (i.e., a dedicated i

line with the capacity of supplying all the emergency power

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loads to safely shutdown the plant) availability as a procedural prerequisite prior to commencement of the overhaul activities.

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It was their view that it was not necessary to add this pre-

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requisite as it was more appropriate for the shift supervisor to

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consider the matter as part of the equipment release protocols u

established in procedure AP-0125.

Subsequent to this PORC meet-

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ing, the inspector questioned senior station management as to whether preplanned and routine activities should be controlled by procedures that include appropriate conservative measures i

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that can compensate for safety related equipment being removed from service.

Subsequently on May 4,1990, procedures OP-5223 and OP-5225, Revisions 9 and 4 respectively, incorporating the j

prerequisite to verify the availability of the Vernon hydro s

station tie line were reviewed and-approved by the PORC.

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The inspector concluded that, althought the intentional entry into the Limiting Condition for Operation (LCO) allowed by TS 3.5.H.1 to facilitate the conduct of the overhaul with the plant i

at power, posed a noteworthy risk, it was authorized by the facility Technical Specifications and the maintenance was con-ducted satisfactorily within the action statement time frame, The NRC's review of this licensee's design features and commit-n ments associated with the Vernon Hydro Station tie line, indi-cated that an acceptable level of safety would be maintained while the licensee was overhauling ths EDG at power. This item is closed.

The NRC will continue to review voluntary entry into i

LCO action statements for performing PM, during routine facility

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inspections.

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D.

"B" EDG Overhaul i

During the period of April 18-22, 1990, the "B" EDG was removed from service to facilitate the conduct of mechanical and elec-o

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trical PM activities per Vermont Yankee procedures OP-5223, l

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" Emergency Diesel Generator Maintenance," and OP-5225, "Emer-

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gency Diesel Generator Electrical Maintenance," which were last performed approximately 23-months ago.

This represents a change in periodicity for this EDG. The NRC's review of this condition

is documented in Section 7.3 of Inspection Report 89-21.

j The inspector reviewed Vermont hwee's conduct of PM activities that were described in the above

.umerated procedures, as well

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as the applicable equipment release and work control practices

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in use.

In addition, the inspector reviewed the corrective maintenance performed on the EDG's collector slip rings, i

Selected portions of post-maintenance testing activities were witnessed by the inspector.

The PM activities associated with the "B" EDG overhaul were con-ducted in accordance with e'stablished procedures, with one minor i

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exception.

The issue involved the use of a gauge on the nozzle

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injection test equipment. and the question of its celibration

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status.

Licensee maintenance personnel were able to demonstrate to the inspector that an acceptable test gauge was in use.

On February 2, 1990, during the performance of maintenance on this EDG, Vermont Yankeb identified the need to resurface the collector slip rings due to observed grooving and pitting of the rings. MR 90-0980 was generated on April 16, 1990 to effect the

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repairs. The inspector reviewed the MR and attached documenta-tion, and a separate guideline to control this work activity.

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This guideline was developed to provide detailed instructions for setup and operation of the EDG'to-implement resurfacing by grinding of the generator's collector slip rings. Maintenance

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personnel informed the inspector that these guidelines were used i

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U in the past.

The inspector reviewed licensee records and con-firmed this fact.

One issue of concern identified by the in-spector involved the lack of an acceptance criteria to control'

the minimum surface thickness of the slip rings. The licensee's maintenance personnel acknowledged the inspector's concerns, and

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indicated that it would be appropriate on a long term basis to i

control the minimum diameter dimension of the resurfaced slip rings.

No immediate safety concern was identified by the in-i spect0r, and post-maintenance testing demonstrated the ability-of the EDG to carry full load.

The licensee adequately resolved this issue by obtaining the appropriate dimension from their vendor, and committing to incorporate the resurfacing instruc-tion in procedure OP-5225 prior to the next scheduled major overhaul of an EDG, The licensee indicated that their correc-tive actions would be controlled by their procedure AP-0028 com -

mitment tracking system.

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Licensee performance in the conduct of these activities was

good.

Coordination and communications between the operations and maintenance department was observed to be excellent, A

i proper level of QA oversight was provided by a QA Engineer,.who I

conducted frequent assessments of licensee performance as part of the licensee's QA Surveillance Program. A vendor technical

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representative was present to support the activities conducted.

Housekeeping conditions, supervisory and craf tspeople perform-ance, and conduct of post-maintenance testing activities all

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continue to reflect strong-licensee performance.

Proper job i

planning and execution resulted in the "B" EDG overhaul activity t

being completed well within the seven day allowed outage time of

the TSs, while at the same time being performed in a quality

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manner.

4.3 Surveillance Inspection Activity l

i The inspectors performed detailed. procedure reviews, witnessed in-progress surveillance testing, and reviewed completed surveillance i

packages, The inspectors verified that the surveillance tests were l

performed in accordance with Technical Specifications, approved pro-i cedures, and NRC regulations. Additionally, events involving this functional area were reviewed.

The surveillance testing activities inspected were effective with respect to meeting the safety objectives of the surveillance testing program.

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4.4 Surveillance Observations A>

Main Steam Line Radiation Monitors Scram-Isolation

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Functional Test On May 7, 1990, the inspector witnessed the conduct of the MSL radiation monitor scram-isolation functional test.

This activity was conducted in accordance with Revision 16 of procedure OP-4315,

" Main Steam Line Radiation Monitor Scram - Isolation Functional /

Calibration." The inspector observed proper caution displayed

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by the I&C technicians, as the conduct of this procedure results in a half scram and half primary containment isolation system j

channel trip.

Procedures were in use and the I&C technicians answered the inspector's questions about the test in a knowledge-able and competent manner.

One concern was identified by the inspector, which involved the use of a Revision 15 procedure Data Sheet. Although the I&C technicians had recognized that a difference between the proce-dure and the data sheet existed, as indicated by their annotat-ing this condition in the " Discrepancies / Remarks" section of the Data Sheet, they did not recognize the reason for the discrep-ancy was an out of date Data Sheet.

The inspector brought this matter to the attention of the I&C Supervisor, who indicated he was concerned-about this occurrence and would pursue this issue.

Immediate corrective actions by the I&C department involved re-viewing the 160 individual working procedure files used by the I&C technicians to ensure file integrity.

One other Revision 15 Data Sheet for OP-4315 was found mixed in with Revision 16 Data Sheets.

The remainder of the'other files showed no discrepan-cies.

The I&C department records clerk, who is the only indi-vidual currently allowed to place procedures within the file was instructed to increase surveillance of procedures in use to help ensure proper revisions are available.

Additionally, the I&C Supervisor indicated that at the next department meetiao he would re-instruct all department personnel to the established controls for the procedure file in question.

The inspector determined that the use of an out-of-date proce-dure data sheet is contrary to procedure AP-6805, " Document Con-trol." One prior NRC identified (March, 1989) finding similar to this, but involving the maintenance department, was discussed in Inspection Report 89-80, and is currently an item requiring NRC followup (VIO 50-271/89-80-04).

The prior NRC finding in-volved three unrelated examples of failure to-follow procedure in support of a' Level V violation.

Since this occurrence was corrected immediately received appropriate licensee corrective actions to preclude recurrence, was of minimal safety signi-

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ficance, and appears to be an isolated incident, the inspector e

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-informed the licensee that the matter will be considered further as part of NRC followup to licensee corrective actions for violation 50-271/89-80-04.

B.

(Closed) Unresolved Item 89-02-01:

Review 90 Day Containment Integrated Leak Rate Test (CILRT) Report for Test Methodology Adequacy.

The inspector reviewed the licensee's 1989 CILRT results docu-mented in accordance with 10 CFR 50, Appendix J,. paragraph en-titled " Primary Containment Leak Rate Test" and attached to the licensee's letter dated July 7 1989 to the NRC.

The report contains a test summary and general test description, presenta-tion of test results, and other data; such as, description of plant and computer software, and data analysis techniques.

The Mass Point calculation method of ANSI /ANS 56.8-1987 was utilized.

This method is acceptable per 10 CFR 50, Appendix J

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requirements which endorse the Mass Point Method when used with

.j a test duration of at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

'The purpose of the test was to demonstrate that leakage through the primary containment building and systems penetrating the containment does not exceed that allowed by plant technical specifications. The test was conducted with containment isola-

-l tion valves and containment pressure boundaries in the post-

accident positions.

The containment met the leakage criterion in the "as-left" condition.

The "as-found" criterion was also met.

The test was witnessed by a reaion-based inspector.

In-spection findings are documented in inspection Report 89-02.

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The inspector requested additional information from the licensee providing justification for using a 20.5 br. data analysis for a.

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24 hr. test.

The inspr.>or also asked that verification test l

. calculations be reperformed. The licensee provided this infor-

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mation attached to the licensee's letter, dated March 26, 1990

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to the NRC.

The supplemental information has been reviewed and found to be adequate, y

c, Results of the test are presented below:

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Type A Test Parameters 1.

Test Method Absolute 2.

Calc. Method Mass Point 3.

Test Duration:

Stabilization 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Test Period 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (see discussion

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below)

Verification 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />

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Test Pressure 44 psig

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Test Results j

i wt % / day

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Maximum Allowable Leak Rate (La)

0.8 2.

Acceptance Criteria

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0.75 La 0,6 3.

Measured Leak Rate

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Lam; "As-Found" 0.531

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Measured Leak Rate Lam; "As-Left" 0.527

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Conclusion Acceptable

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The inspector performed independent calculations of the contain-ment leakage rate and concluded that the containment has met its

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acceptance criteria for leakage in both the "as-left" and "as-

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found" conditions.

While the test period was 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> long, the leakage rate calcu-lation was based on data collected during the first 20.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> u

of the test period.

The licensee experienced problems with the-l plant process computer which affected the values of the last 3.5 l

hours test data. An evaluation of the data, the calculated leak rate and the trending of the leakage rate versus time prior to I

the computer problem indicates that the-leakage rate had stabil-ized with the acceptance criteria for over six hours.

Had the computer problem not occurred, the leakage rate at the end of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would have been essentially the same as that at 20.5'

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hours, therefore, the technical significance is minimal.

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Based on this information, the inspector concluded that this licensee identified deviation from 10 CFR 50, Appendix J (III.A.3) was an isolated occurrence with minimal safety signi-ficance.

Therefore, this violation (NCY 50-271/90-02-03) is not being cited in accordance with section V.A of 10 CFR part 2 Appendix C (General statement of policy and procedure for NRC enforcement actions).The NRC's disposition of this matter closes unresolved item 50-271/89-02-01.

Following discussions with the licensee management, it is the NRC's understanding that in future similar situations, the licensee will formally request NRC con-currence for an exemption to the applicable regulation.

5.

EMERGENCY PREPAREDNESS 5.1 Special Population Exercise On April 4 Vermont Yankee and the States of Vermont, Massachusetts, and New Hampshire participated in a special population drill.

Special population is defined as the population associated with elementary and secondary schools (in Massachusetts this included some special needs individuals') within the 10 mile Emergency Planning Zone (EPZ).

Sixteen schools participated. The purpose of the drill was to demon-strate the ability and resources of the states to implement emergency planning procedures pertaining to schools located within the EPZ.

The actual movement of school children did not take place.

On April 25 a special population exercise was conducted.

This exer-cise was evaluated'by the Federal Emergency Management Agency (FEMA),

The only significant difference between this exercise and the April 4th drill was that the bus company responsible for Vermont and New Hampshire schools was involved only with communications during the drill.

During the exercise and drill, Vermont Yankee manned a con-trol ce'll and simulated all emergency response facilities activities and actions. The control cell also simulated numerous offsite organizations which were not required to participate.

The exercise was minimally disrupted by a non-scenario bomb threat at one'of the-participating Massachusetts schools.

FEMA evaluated several areas including notification of school super-L'

intendent's offices, specific school notifications and the notifica-tion of school bus companies and drivers.

Vermont Yankee evaluated this exercise as a success.

Preliminary feedback provided by FEMA during the exercise critique evaluated the exercise as a success.

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SECURITY 6.1-Observations of Physical Security i

Compliance with the security program was verified on a periodic basis, including the adequacy of staffing, entry control, alarm sta-tions,- and physical boundaries.

No unacceptable conditions were identified.

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6.2 Inaccurate Background Investigations

Two security events occurred during this inspection period. The first event occurred on April 10 when Vermont Yankee identified that

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unescorted access authorization for an onsite contractor had been

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prematurely granted (Security Event Report 90-02S). The second event occurred on April 23 when access authorization of a contractor em-ployee was terminated following the completion of the FBI criminal history check (Security Event Report 90-03S).

As a result of the event on April 10, twenty-two authorizations for unescorted access were terminated.

The audit revealed that the con-Ltractor was representing the background investigations (BI) as com-plete when they were not.

The requirements-of the Vermont Yankee

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authorization program were reviewed by the licensee with the contrac-

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tor (Mercury-Company of Norwood, Massachusetts) and within six days a

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review of the necessary bis was completed and access authorization I

restored. No information which would have precluded granting access

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was discovered.

'The second event concerned the granting of unescorted access to an individual based upon Vermont. Yankee's receipt of written documenta-

' tion from-the contractor (Quadrex). stating that the individual had met the requirements for unescorted access..-A complete BI had not

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been completed and a criminal record check of an individual revealed L

a pending felony charge.

Consequently, six authorizations for un-

-l escorted access were immediately terminated.

Like the previous i

event, unescorted access was granted prior to completion of a BI.

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After review of the rubject bis and verification that all require-

.i ments of the Vermont Y o kee authorization program were met, access authorization was restored.

The licensee determined the cause of these events to be lack of i

familiarization by the contractor with Vermont Yankee policy VYP:

l 325, " Contractor Screening Requirements for Unescorted Access." This a

policy clearly describes the requirement that a satisfactory BI must I

be completed prior to applying for access authorization. As part of i

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corrective actions, Vermont Yankee reviewed applicable sections of

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VYP 325 with contractor representatives responsible for review and approval of the contractor's bis.

Vermont Yankee distributed a letter i

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to all plant contractors and vendors reemphasizing the' requirements for background certifications. All contractors and vendors were re-quested to provide recertification by June 1990 for their personnel L

currently badged for unescorted access at the site.

The inspector determined that security management continued to pro-vide strong oversight of security contractor activities.

Security event reports were timely, accurate, and comprehensive.

The inspec-tor concluded that corrective actions were acceptable.

6.3 Anti-Nuclear Demonstration A

On April 28, 1990, a demonstration occurred at 3:30 p.m. at the main gate of the Vermont Yankee owner controlled area (OCA) b approxi-mately 130 members of anti-nuclear citizen groups.

By 4:50 p.m.

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demonstrators entered the OCA at various locations by scaling the OCA

fence using an "A-frame" wooden ladder, or directly climbing over or

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under the fence. fabric. A total of 34 demonstrators crossed into the OCA, most of them in the vicinity of Gate 1.

Eight demonstrators entered the OCA near the plant stack and immediately proceeded to climb the stack. A group of four demonstrators that entered the OCA made'their way to Gate 2, the main entrance to the plant's Protected-Area (PA).

The inspector observed the demonstration from Gate 1, and noted that demonstrators that were confronted within the OCA by lic-ensee security personnel or local law enforcement agency (LLEA)

officials were taken into custody without active resistance and

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appeared to cooperate with authorities. Those demonstrators that

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congregated by Gate 2 were moved away from the Gate 2 area and placed into-LLEA. custody.

The only damage to plant property involved one of i

the strobe lights located on the plant stack. When requested by LLEA officials, six members of the group that climbed the stack agreed to

.come down at approximately 5:54 p.m.

The:two that refused remained on the second tier of the stack until 7:55 a,m. on April.29, at which-time they were taken into custody by the LLEA for unlawful trespass and unlawful mischief.

The licensee responce_to this event was noteworthy. The security staff performed in a professional manner and were observed to have displayed restraint and respect in dealing with the demonstrators.

The licensee briefed the inspector on their contingency planning for the announced demonstration, and provided evidence that they had a

good understanding of the situation and for the need to prioritize the security response to focus on the PA. Good cooperation and com-munications were noted between security and operational personnel, i

An appropriate review of the event for security notifications was -

made by the licensee.

The communications and coordination between the licensee's security organization and the LLEA was excellent, and reflect a high degree of preparation.

No challenges to the plant PA occurred apd no impact on plant operations occurred as a result of this demonstration.

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7.

ENGINEERING / TECHNICAL SUPPORT

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7.1 TI 2500/27 (Closed)

Temporary Instruction 2500/27 addresses inspection requirements for NRC Compliance Bulletin 87-02, " Fastener Testing to Determine Con-formance with Applicable Material. Specifications."

The inspector reviewed Vermont Yankee's response to Bulletin 87-02, dated January 12, 1988 as well as their response to Bulletin Supple-ments 1 and.2 dated July 15, 1988.

Vermont Yankee identified three safety-related fasteners, out of a sample of 20 fasteners, and four non-safety-related fasteners, out of total of 21, which had either i

chemical or hardr ess deviations from their required material. As a result, an engineering evaluation of each'of these fastener devi-ations was performed which determined that none of the deficiencies affected the safety-related function of the fasteners.

An additional sample of fasteners was taken in response to one of the safety-related fasteners failing to meet chemistry requirements. Of that sample, five of the fasteners failed to meet chemistry-requirements; all the chemistry deviations were minor in nature and had no impact on the safety-related function of the fasteners.

However, the NRC-

incorrectly reported these additional fastener deviations in NUREG-j 1349, " Compilation of Fastener. Testing Data Received in Response to

NRC Compliance Bulletin 87-02" as being part of the original sample

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of 20 fasteners selected. As a result, Vermont Yankee appearad to

hava more serious problems with fasteners than actually existed.

Vermont Yankee contacted the NRC:NRR-in mid-February and notified l

them of the error. The inspector confirmed that the NRC:NRR was aware of the error and that as a result, the performance of TI l

2500/27 Section 4.2 was no longer necessary.

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C The inspector reviewed Vermont Yan.kee's January 12, 1988 response to l

the bulletin as well as the NRC's initial review of this issue in

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-inspection report 87-23.

This inspection also reviewed the most

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serious material deficiencies noted with one of the safety-related

fasteners and determined that the fastener, designed to hold a cover

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over a lifting lug on a shipping cask, was more than adequate for its

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design function.

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The-inspector toured Vermont Yankee's warehouse and reviewed the

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administrative controls on safety-related and non-safety-related

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's f a s teners'. Overall, the controls and segregation of safety-related

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and non-safety-related fasteners appeared adequate.

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h In summary, Vermont Yankee identified only a small number of defi-i ciencies with safety-related bolting materials, all of which were minor and presented no safety concerns.

No additional actions on g

this matter are warranted or planned.

The inspector considers

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Vermont Yankee's actions in response to this bulletin and its sup-plements to be timely and acceptable.

TI 2500/27 1s considered closed.

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8.

SAFETY ASSESSMENT / QUALITY VERIFICATION

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8.1 (Closed) Unresolved Item 89-21-01:

Review of Licensee Overtime Procedures

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This item reflected NRC identification of discrepancies between

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worker overtime controls established in GL 82-12 and the licensee

k overtime control procedure.

The inspector and the NRC:NRR Project.

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Manager for Vermont Yankee held discussions with the licensee on this issue. The licensee agreed to review the matter using all pertinent-NRC guidance on the issue and provide a timely resolution.

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t The licensee developed procedure AP-0894, Revision 0, " Shift Staff-

ing/0vertime Limits that contained the specific requirements for limiting. staff overtime as these described in GL 82-12.

Administra-tive controls were incorporated in the procedure to ensure a good level of oversight and involvement would be provided by plant and department supervisors when individuals are required to work outside

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the established administrative limits.

This item is closed.

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8.2 PORC Activities The inspectors attended meetings on March 20, April 11 and 27, and-reviewed meeting minutes to ascertain that provisions of TS 6.2.A were met.

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The'PORC continues to provide an effective safety oversight function.

. Good self-assessment attributes were demonstrated as part of the com-prehensive review of plant conditions prior to startup from the mid-cycle maintenance outage.

Issues or areas reviewed included:

(1) NRC-

-commitments; (2) quality assurance / surveillance items; (3) non-con -

-formance reports, potential reportable occurrence evaluations, and-LERs; (4) design changes implemented; (5) temporary modifications;

-(6) shielding / scaffolding status; (7) equipment qualification con-

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cerns; (8) special testing performed and results; (9) preventive /

corrective maintenance issues; (10) security; (11) chemistry; (12) procedures; (13) housekeeping; (14) deferred work; (15) operator readiness issues; and (16) startup plans.

As documented in Section 4.2.C of this report, one inspector concern was identified that in-

.volved the reluctance of the p0RC to incorporate a procedural pre-requisite'in an area involving safety related maintenance.

The in-

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spector viewed this matter as an isolated departure from the conser-

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vative safety perspective typically exhibited by the committe.

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8.3 Inspector Observations Vermont' Yankee plant _ staff support of plant operations continues to be noteworthy.

Good involvement in day-to-day activities by the.on-site quality assurance group is routinely noted. Their involvement in important safety-related activities indicated they have a proper-prioritization perspective.

Plant management is effectively involved in determinations' involving safety and quality.

Clear evidence of licensee concern for quality was demonstrated on March 23, when con-

.tinuing equipiaent problems prevented the operators from implementing

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main generator excitation, which prompted the plant manager stop fur-ther startup efforts. This action was concurrent with the assignment by the Plant Manager to designated groups to:

(1) focus on the tur-bine MHC System and excitation system performance; (2) attempt to o

identify root cause(s) of their performance; and, (3) develop an i

appropriate corrective action plan for each system.

The inspector has already observed improved equipment performance benefits that was derived by the demonstration by Vermont Yankee management for quality--

i over production values.

9.

LICENSEE EVENT REPORT (LERs), SPECIAL REPORTS, AND OPEN ITEM FOLLOWUP 9.1 LERs

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The inspector reviewed the licensee event reports listed below to determine that with respect to the general aspects of the events:

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

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the event was accurate; (3) root cause analysis was performed;

(4) safety implications were considered; and (5) corrective actions implemented or planned were sufficient'to preclude recurrence of a similar event.

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LER 90-04 March 21, Reactor Scram Due to Pressure Control System Failure and Primary Containment Isolation System Actuation (Section 2.2.B)

LER 90-05 March 28, Incomplete Evaluation of Containment Sample Oue to Failure to Follow Procedures (Section 3.2.A)

NRC evaluation of these events is discussed in the section noted.

.9. 2 Periodic and Special Reports The plant submitted _the following periodic and special reports which were reviewed for accuracy and the adequacy of the evaluation.

Monthly Statistical Report for plant operations for the months-I

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of' March and April 199 y

_.' Q W.gG

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L Feedwater leakage detection system monthly performance summary

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for January - April 1990,

Annual Operating Report for 1989.

This report was. submitted in

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accordance with 10 CFR 50.59 and describes facility changes,

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tests, and experiments conducted for which NRC' approval was not required.

Personnel Monitoring Report for 1989.

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Personnel Exposure Report for 1989.

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No deficiencies were noted in this review, f

l-9.3 _Open Item Followup

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A.

The following previous inspection items were followed up during

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this inspection and are tabulated below-for cross reference pur-i poses.

Closed 89-02-01 (Section 4.4.8)

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L Closed 89-21-01 (Section 8.1)

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Closed 90-01-01 (Section 4.2.C)

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,10.. MANAGEMENT MEETINGS

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During the inspection period, the following management meetings were' con-

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ducted or attended by the inspectors as noted below:

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On April 30 the inspectors attended a meeting held between the NRC.

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and Vermont Yankee to discuss licensing issues associated with~the hardened wetwell vent and toxic gas monitors.

This meeting was also attended by representatives of the State of' Vermont..

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'The inspectors met with senior. facility management and other VYNPS

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personnel periodically and at the end of the. inspection report period

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to summarize the scope and findings of their inspection activities.

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