IR 05000271/1992024

Insp Rept 50-271/92-24 on 921129-930102.Unresolved Items Discussed.Major Areas Inspected:Plant Operations, Radiological Controls,Maint & Surveillance & Security

ML20128D048
Person / Time
Site:	Vermont Yankee
Issue date:	02/01/1993
From:	Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128D036	List: IR 05000271/1992024 ML20128D034
References
50-271-92-24, NUDOCS 9302100036
Download: ML20128D048 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N Docket N Licensee N DPR 28 Licensec: Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Ferry Road Brattleboro, VT 05301 Facility: Vermont Yankee Nuclear Power Station Vernon, Vermont inspection Period: November 29,1992 - January 2,1993 Inspectors: Harold Eichenholz, Senior Resident inspector Paul W. Harris, Resident Inspector Neil erry, Senior Resident inspector, Yankee Rowe Approved by: N hr *

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Eugene M. Kelly, Chief Reactor Projects Section 3A Scope: Station activities inspected by the resident staff this period included: plant-operations; radiological controls; maintenance and surveillance; security; and safety assessment and quality verification. Periodic inspections amounting to 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of backshift activities were performed on November 29,30, December 1, 3, 6,15,17, 21, and 3 Interviews and discussions were conducted with members of Vermont Yankcc management and staff as necessary to support this inspectio Findings: The inspection results are summarized in the Executive Summary. Unresolved items involving the adequacy of fire barrier penetrations and the effectiveness ci corrective actions for inservice testing of the reactor core isolation cooling system are discussed in Sections 6.1 and 7.2, respectively. The correction of a problem with an undersized motor heater on a service water pump resulted in a non-cited violation (Section 4.2).

9302100036 930201 1 DR ADOCK 0500

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EXECUTIVE SUMMARY .

Vermont Yankee Nuclear Power Station Report No. 92 24 -

Plant Operations Routine operations were performed well, and good housekeeping and cleanliness were [

maintained. A tour of the reactor building by the Plant Manager as part of the Vermont '

Yankee Observation Program was effectiv :

Radiological ConLols Surveys accurately documented reactor building radiation levels and contamination areas, and appropriately identified several relatively minor posting deficiencie Maintenance and Surveillance Corrective actions associated with replacement of a "B" service water pump motor heater were comprehensive. Testing following corrective maintenance was well controlled and performed by qualified technician Security Effective command and control by the Central Alarm Stailon operator occurred during an onsite medical emergency, although a need for log keeping improvement was identifie Vermont Yankee's new security contractor, Wackenhut, conducted transition activitie Vermont Yankee is resolving NRC questions pertaining to 10 CFR 26.73 fitness for duty _

reporting requirement Engineering and Technical Supped Prompt management response for degraded fire barriers on piping penetrations occurre Reactor Building Recirculation Uni! (RRU) tube replacements reflected a good safety perspective, since the tubes were replaced prior to their performance degrading below acceptable levels. The removtl of the RRUs from service, and the resniting Technical

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Specification operability issues, were properly resolve Safety Assessment and Quality Verification Concerns were identified involving the effectiveness of corrective actions for a repetitive missed Reactor Core Isolation Cooling (RCIC) pump surveillanc ii

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e TABLE OF CONTFNFS EXECUTIVE SUMMARY ......................................il SUMMARY OF FACILITY ACTIVITIES Vermont Yankee Nuclear Power Station (VY) safely operated at approximately 100 percent of rated reactor power throughout this inspection perio , PLANT OPERATIONS (71707,93702,90712) Operational Safety Verification On a daily basis, inspectors verified adequate staffing, adherence to procedures and limiting conditions for operations, operability of protective systems, status of control room annunciators, and availability of emergency diesel generators and uninterruptibic power

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supplies. The inspectors performed a bi weekly review of safety related tagouts, chemli.try

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sample results, use of overtime for control room operators, and the operability of the high pressure core cooling system. During this period, the inspectors also verified that shift tumovers were properly performed and that important plant information was communicated to the oncoming shift. Plant housekeeping and cleanliness were considered goo On December 22, the inspector observed the Plant Manager (PM) inspecting work activities and equipment spaces within the reactor building. The tour included such areas as the torus catwalk and residual heat removal corner rooms, observing that workers were implementing safe work practices and ensuring reactor building cleanliness was commensurate with the maintenance in progress. The PM also observed the engineering field evaluation of a degraded 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barrier peictrat!on (Section 7.1) and questioned various aspects of this issue. The tour was performed b accordance with the Vermont Yankee Observation-Program, which incorporates elen,ents of fire protection, housekeeping, industrial safety, radiation protection, and woik practices. The inspector considered the PM tour an effective practic ' Fuel Performance During this inspection period the inspector reviewed fuel" performance data and noted that the offgas release rates were trending downward at an approximate 500 pCi/sec per month rat Offgas levels ranged in this inspection period between 21,000 and 24,0000 pCi/se Analysis continues to indicate that the activity is 100 percent recoil and there are no current -

fuel failures in the core. The inspector verified that VY is properly completing Level IV actions of their Failed Fuel Action Plan, namely sustained activity at the steam jet air ejectors in the range of 10,000-60,000 pCi/se !

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j RADIOLOGICAL CONTROIS (71707) i

! Inspection Activities

Inspectors routinely reviewed radiological controls including contamination and external radiation exposure control. The inspectors also monitored radiological control practices,

! conformance with radiological procedures, and 10 CFR Part 20 requirements.

' General Radiation Survey of the Reactor Building The inspector performed a general radiation survey of plant equipment areas within the reactor building and verified that posting of contaminated, high airbome radiation, and high i radiation areas were in accordance with plant instructions. A few radiation boundary

! deficiencies were observed in the torus room that were of minor significance and promptly

! corrected by the radiation protection (RP) staff. In addition, two ALARA (As Low As Reasonably Achievable) postings within the torus room were not adequately placed to assure

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optimal reduction in personnel exposure. This observation was acknowledged by the Plant i'

Health Physicist as a potential ALARA concern and corrective actions were initiated. One of the areas was near a high pressure coolant injection steam line and involved radiation levels .

that approached 30 to 70 mR/hr at chest / head level; this radiation level was approximately three times normal background. The inspector noted that the radiation levels were consistent with VY radiation surveys and were posted in accoidance with 10 CFR Part 20. The other l posting was associated with the general radiation level on the catwalk.

Overall, the inspector noted that of the areas surveyed ("A" residual heat removal comer i room, reactor core isolation cooling system room, and the upper and lower torus room areas), no discrepancies were identified with respect to 10 CFR Part 20 or VY posting l requirements, in addition, surveys accurately documented radiation levels and contamination j area .0 MAINTENANCE AND SURVEILLANCE (62703,61726,92700)

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, Maintenance i

L The inspector observed selected maintenance on safety related equipment to determine whether these activities were conducted in accordance with VY Technical Specificaticas -

-(TS), approved procedures, and appropriate industry codes and standard .2 Corrective Actions for Motor Winding llenter Non-Conformance In June 1990, as part of quanerly preventive maintenance testing, the motor winding heater for the "B" service water (SW) pump was found to have not met design requirements.

i Documentation indicated tha't the as-found heater wattage was approximately 135 watts,

whereas the design required 250 watts. During the next "cheduled pump overhaul in i-

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November 1992, VY replaced the heater and performed other preventive maintenance. The inspector observed these activities and documented (Inspection Report 92-22) that the maintenance was of Ngh quality and various improvements had been implemented since this overhaul was last performed. However, VY had not yet ccmpleted their resolution of the undersized motor heater wattage non-conformanc Non Conformance Report (NCR) 92-19 was initiated in November 1992 to address the degraded condition of the motor heater. Vermont Yankee determined the root cause to be a combination of three deficiencies: (1) the vendor failed to install the proper heater despite adequate instruction provided; (2) receipt inspection did not identify the non-conformance prior to installation of the motor; and (3) post maintenance testing did not verify the proper performance of the heaters. Appropriate corrective actions and completion dates were assigned to address each of these deficiencies. In addition, VY plans to evaluate other work performed since 1989 by the vendor (Schul: Electric Co.) to determine if any previously undetected problems exis The inspector noted that Schulz replaced the motor stator winding during the first quarter of 1989, and that no formal and/or documented engineering evaluation was performed in 1990 to assess whether the heater deficiency affected long term pump operation. Maintenance Engineering's informal evaluation did not identify any safety significant issues. The following considerations were employed in determining that the condition did not require a resolution until the next dissassembly opportunity: (1) a full investigation into the situation would require a motor tear-down; (2) some heating during non-operating periods was occurring (i.e.,135 vs. 200 watts); (3) although the area housing the pump does have moisture, it is an environmentally controlled area; and (4) service water pumps do not sit idle

for long periods, which would cause additional concerns about potential co'ndensation buildup.

l Vermont Yankee's actions in response to the as found deficiencies were comprehensive,

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Recent improvements in plant procedures, implementation of the Basis for Maintaining Operation (BMO) guidelines, and the corrective actions implemented as a result of NCR 92-19 indicate improvement in the use of quality processes to assure proper resolu'.lon of deficient conditions. Therefore, this violation of Criterion XVI of Appendix B involving the l failure initially to take timely corrective action for a deficient condition meets the criteria for enforcement discretion of Section VII of the NRC's Enforcement Policy.

I Surveillance

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The inspector performed procedure reviews, witnessed in progress surveillance testing, and reviewed completed surveillance packages. The surveillances which follow were reviewed and found to be adequate with respect to meeting the safety objectives of the surveillance program. The inspector observed that the tests were performed by qualified and knowledgeable personnel, in accordance with TS and approved procedure . . _ . - _

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o OP 4019, Rev. 3, " Surveillance of Vital Fire Liarriers'

o OP 4124, Rev 31, " Residual ficat Removal and Residual licat Removal Service Water Surveillance" e OP 4121, Rev. 29, " Reactor Core Isolation Cooling Syste ' Surveillance"

• OP 5337, Rev. 3. "11PCI Control System Calibration Tet e OP 4120, Rev. 25, "HPCI Surveillance" e OP 4127, Rev 5, " John Decre Diesel Generator Surveillance"

• OP 4181, Rev.17, " Service Water / Alternate Cooling Water Surveillance" SECURITY (71707, 92700, 93702)

The inspector verified that security conditions met regulatory requirements and the physical security plan. Officers properly responded to security perimeter and other equipment deficiencies, complied with procedures, and effectively controlled access to the Protected Are .1 Security Response to an Onsite Medical Emergency On December 12, the inspector observed from the Central Alarm Station (CAS) the performance of the VY security force in response to a medical emergency. The guard force promptly admitted the ambulance and medical personnel into the Protected Area, maintained access control, and followed the requirements of site security procedures. The inspector observed the performance of the officers in CAS and noted that command and control and communications were effective. The CAS operator performed his assigned duties while being cognizant of the actions of the security force. The Security Shift Supervisor (SSS)

maintained an accLyate and descriptive event log, and coordinated event response officers and the prioritization of compensatory measures for ancillary alarm The CAS and Secondary Alarm Station (SAS) officers maintained an informal log of the key events to supplement or backup the information documented by the SSS. This matter was brought to the attention of the Security Manager who acknowledged that a more formal or better controlled method of maintaining security information at CAS and SAS was necessary to assure a complete and accurate security record. The manarr stated that this issue will be evaluated during the security assessment period identified in Section .2 New Security Contractor On December 1, following a process that evaluated five potential security contractors. VY announced that Wackenhut Corporation, Nuclear Services Division, would be awarded the contract for the security responsibilities from the current contractor, Green Mountain Security. Commencing on December 1, Wackenhut and Green Mountain Security began a 30-day transition period to turn over security force responsibilities. In addition, a 90-day assessment period was implemented during which VY and Wackenhut will evaluate and l

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recommend changes to the security plan and program. The inspectors have observed good performance on the part of contract security personnel during this initial phase of the transitio .3 Fitness For Duty - Positise Test Result Vermont Yankee notified the NRC on December 11 that a plant supervisor had tested positive for drugs during a random drug test conducted on December 7. With the exception of 10 CFR 26.73 reponing requirements, the inspector verified that VY properly implemented their Fitness For Duty (FFD) Progrant requirement Following a review of the VY FFD Policy (VYP.222), and discussions with the cognizant department manager of the subject individual, the inspector concluded that a 10 CFR 26.73 report was not warranted, since the individual that had the positive test result did not have the FFD responsibilities required by the policy for supervisors. The cognizant department manager did not consult the FFD policy as part of his developing a reporting recommendation. Since the VY Security Manager makes a reportability determination based upon information provided by the department managr", the inspector determined that the security organization had, in this instance, made appropriate reportability determination Vermont Yankee management representatives acknowledged the inspector's comments and concems on this issue, and indicated that corrective measures are being developed to ensure that only those supervisory personnel assigned to perform 10 CFR Part 26 duties will be considered for the 10 CFR 26.73 reponing requirements for significant FFD event .0 ENGINEERING AND TECIINICAL SUPPORT (71707,62703)

! L)cgraded Fire Barrier Penetrations

! On December 23,1992, VY notified the NRC of inoperable fire barriers f ar approximately l (:0 insulated piping penetrations. The degraded fire barriers were identifitd during l performance of inspections of insulated fire barriers, in response to Corrective Action Report l

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(CAR) 92-10. Three insulated fire barriers were inspected by removing the insulation from the piping at the penetration in question to determine if the p:netration was properly scaled l with a qualified material, in two of the three cases, the penetrations were found inadequately l sealed, in that the as found condition did not conform to the approved design. Since there

! was inadequate documentation concerning the qualification of the insulation as a fire barrier, all similar fire barriers with insulated lines were declared inoperable. Vermont Yankee initially determined that the cause of the inadequate fire barrier seals was attributable to a modifi.ation performed in 1979 80 when the penetrations were sealed by Chemtrol Corporation.

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Plant walkdowns were conducted, a list of all areas with inoperable firu barriers was l compiled, and appropiate compensatory actions were taken. Fire barriers required by technical specifications and Appendix R to 10 CFR Part 50 had a continuous firewatch posted i

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on one side of the affected barrier (s). Fire barders required by Appendix A to NRC Branch Technical Position (BTP) 9.5-1 had a roving firewatch established on an hourly basis. A total of five continuous firewatches and one roving firewatch for five areas were establishe All fire barriers with insulated lines were conservatively declared inoperable because of the difficulties associated vfith visual inspection of the penetrations. Some of the piping is insulatcd with asbestos; some of the piping, such as heating and various exhaust piping, is potentially hot; and other piping is not easily accessibl The inspector toured the areas in the plant where the penetrations are located with the Technical Progmms Supervisor on December 29,1992. All areas observed exhibited good housekeeping (e.g., minimal combustible material), and the firewatches were posted as required. The inspector concluded that VY management's initial response to this issue was appropriate, and communications with the NRC were good. Additionally, during tours of the affected areas, the inspector round the firewatch personnel knowledgeable of their responsibilitie On January 2, additional potential problems with the adequacy of fire barriers for uninsulated piping penetrations were discovered. As of the end of the inspection period, the fire barrier adequacy issues were receiving a high level of VY management attention, and a special Task Force was being formed. Vermont Yankee's determination of root cause and corrective actions for the issue of potential fire barrier inadequacies is an unresolved item (URI 92 24-01). Drywell Reactor Recirculation Unit Replacement / Upgrade During the March-April 1992 refueling outage the four drywell reactor recirculation units (RRU) were replaced with upgraded units. The RRU replacement was initiated due to the inability of the original units to adequately and reliably perform as intended, and due to

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increasing maintenance required on the units, resulting in radiation exposure to worker The RRUs recirculate the containment atmosphere continuously during normal reactor operation, to provide and maintain suitable temperature and humidity within the containmen The RRUs provide no safety-class function and are class'fied as non nuclear safety. The replacement RRUs are larger, higher capacity units, and are more versatile; for instance, they have two separately controlled fans, while the original units had only one fa The inspector reviewed documentation associated with the modification, and interviewed various engineering, operations, and contractor personnel associated with the modification.

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The inspector reviewed the safety evaluation for this modification and found it to be comprehensive. Installation of the RRUs during the relatively short 1992 refueling outage required that personnel work two 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts. The inspector reviewed records of normal and overtime hours worked by management and craft personnel and found that some overtime was used to acco'mplish the work. However, the use of overtime for workers involved in modification work, during the extended shutdown period, is consistent with NRC policy and guidance contained in Generic Irtter No. 83-02. Records of the post modification

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testing performed were reviewed. The inspector identified no concerns with the installation, testing, and subsequent operation of the RRUs Since installaticn, the units have operated reliably. Reaetor Building Reactor Reeltrulation Unit Tube Replacement During the second and third weeks of December 1992, the cooling water tubes for the number 7 and 8 RRUs were replaced. These units, including RRUs 5 and 6 (which were replaced prior to Operating Cycle XVI), experienced degraded heat transfer performance caused by the accumulation of river silt and debris in the cooling :olls Quarterly performance trending as part of the VY Service Water Performance Monitoring Program identified the degrading condition based, in part, on higher than normal tube differential pressures. Vermont Yankee considered the RRUs operable, albelt degraded.

Vermont Yankee considers the operation of these subject RRUs, during a design basis accident, necessary to assure operability of the residual heat removal (RHR) pumps, core spray pumps, RHR service water pumps, and other corner room equipment. This determination was based on engineering evaluaticas of the technical specification denmtion of operability, and discussions with the NRC. One exception, however, is that VY considers the operation of RRUs 7 and 8 as not being necessary to assure operability of the RHR pumps to perform their low pressure coolant injection (LPCI) function, as defined in the TSs and the Final Safety Amlyus Report. As a result, VY appropriately entered the core spray and containment spray TS limiting conditions for operations (LCO) and not the LPCI LCO.

Vermont Yankee considered the replacement of the RRU coils as maintenance necessary to correct a degrading condition identified from system performance testing.

The inspector noted that the function of the reactor building RRUs is to maintain an appropriate temperature and humidity condition for corner room equipment. These large, forced air cooling units are cooled by the service water (SW) system and will auto star *. when any associated core spray, RHR pump, or RHR SW pump on that particular RRU corner room level is started. There is one seismically qualified ERU for each level of the subject reactor building corner rooms.

The inspector performed field inspections and verified proper receipt inspection of replacement parts, quali0 cation of welders, traceability of welding materials, chemical composition of replacement parts, and application of piping design speci0 cations. All documents reviewed were accurate, complete, and reflected proper safety class descriptions.

The inspector also verified that classroom and mock up training was of adequate detail to assure that the mechanics and engineers involved understood the plant safety concerns regarding freeze seals on safety-related piping systems. Vermont Yankee used a life-size mock-up of the freeze seal. The maintenance plans and "one for-one" evaluations were of high quality. The engineering evaluation of the current performance characteristics of the RRUs was comprehensiv _ _ - ,

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The inspector attended Plant Operations Review Committee (PORC) meetings and other maintenance meetings in which station management reviewed and discussed the preparations and actions required to perform the planned coil replacements for RRUs 7 and 8. As a result of the meetings, improvements to the maintenance plans were'incorpomted to address system inspoctions and the protection of safety-related systems in the work area. The inspector also observed department managers performing field assessments of the work', and gcxxl

, communications between all levels of plant management. Overall, the inspector concluded that the pre-job planning and reviews contributed to the well-coordinated maintenance and j that VY exhibited a good safety perspective to corroct the conditions prior to system t

performance degrading below minimum system design requirement .0 SAFETY ASSFSSMENT AND QUALITY VERIFICATION (40500,90712, 90713, 92700) Perledle and Special Reports The Monthly Statistical Report for the month of November 1992 was reviewed for accuracy and found to be the adequat .2 Licensee Event Reports The inspector reviewed the Licensee Event Reports (LERs) listed below and assessed whether: (1) the report was submitted in a timely manner; (2) the description of the event ,

was accurate; (3) a 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 even * LER 92-019, " Control Room Staffing Below Minimum Requirements due to a Control Room Operator being called Home for a Medical Emergency." This event was discussed in NRC Inspection Report 50-271/92-22; corrective actions were appropriat * LER 92-020, " Missed RCIC Pump Surveillance due to Personnel F.r or in Evaluation of Pump Vibration Data." On November 20,1992, during performance of the quarterly surveillance for reactor core isolation cooling pump P4 7-1 A, VY identified that the vibration results from the previous test conducted on July 15,1992, were incorrectly compared to baseline data. Vermont Yankee concluded that the vibration levels from the July test had exceeded the Inservice Test ' Alert" threshold, thereby requiring that the test frequency be doubled. Operability testing of the RCIC pump was satisfactorily performed on November 20, with the results no longer in the

" Alert" range. The root cause for this event was inadequate root cause analysis and corrective action for a previous similar event which occurred in April 1991. The recurrence of similar inservice test deficiencies due to ineffective corrective action is unresolved pending further NRC evaluation (URI 92-24-02).

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9 MANAGEMENT MEETINGS (30702) Preliminary inspection Mndings Meetings were periodically held with plant management during this inspection to discuss oreliminary inspection findings. A summary of findings was slso discussed at the conclusion of the inspection on January 6,1993. No proprietary information was identified as being included in the repor .2 Other Meetings On December 2, managers from the Division of Reactor Projects, NRC Region 1 (NRCtRI),

and the VY resident inspectors attended and presented elements of the NRC Inspection _

Program to the Vermont State Nuclear Advisory Panel (VSNAP). The NRC also described the implementation of the inspection program at'VY, and the recent Systematic Assessment of Licensec Performance (SALP) results. A question and answer period followed the formal presentation. This meeting was open to the public, and minutes were recorded by the VSNAP Secretar On December 14. the VY Security Manager and the Technical Services Superintendent -

attended a meeting with NRC:RI security inspectors. The meeting was initiated by VY, in patt, to discuss the plan for transition of security contractors, and the status of corrective actions for previously identified concems, and the implementation of improvements for security assessment equipment. The meeting was closed to the public due to discussion of Safeguards Informatio ,

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