ML20003G002

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IE Insp Rept 50-271/81-02 on 810102-30.No Noncompliance Noted.Major Areas Inspected:Action Taken on Previous Insp Findings,Ie Bulletin Followup & Insp Requirements to Review Licensee Actions in Response to IE Bulletin 80-24
ML20003G002
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 03/18/1981
From: Collins S, Gallo R, Raymond W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20003F999 List:
References
50-271-81-02, 50-271-81-2, IEB-80-21, IEB-80-23, IEB-80-24, NUDOCS 8104280024
Download: ML20003G002 (29)


See also: IR 05000271/1981002

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

' TERA

Region I

50-271/800214 80-03-01

50-271/801121 IEB 80-24-

Report No.

81-02

50-271/801114 IEB 80-23

50-271/801106_ IEB_80-21_ .

Docket No.

50-271

-50-271/8.10126J1RL81-0.2-02

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50-271/801130 LER 80-40

License No.

DPR - 28

Pri6Mty

category ~-C

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50 27F/B00905 CER 80-28

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50-27r/800630 CER o'T-21

Licensee:

Yankee Atomic Electric Company

50-271/800707 LER 80-21

50-271/800107 LER 80-03

1671 Worcester Road

50-271/800617 LER 80-20

50-271/800424 LER 80-17

Framingham, Massachusetts 01701

50-271/800307 LER 80-10

50-271/801205 T/I2515/4G

Facility Name:

Vermont Yankee

50-271/801218 T/I2515/47

Inspection at:

Vernon, Vermont

Inspection conduct d-,

January 2 - January 30, 1981

Inspectors:

M

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7 J. Raymon

SenifResidentInspector

date signed

MO

3&dal

S/ J. Collins, Resident Inspector

date signed

date signed

Approved by:

A

3 h g, h (

R. M. Gallo, Chief Reactor Projects

date signed

Section 1A, Projects Branch #1

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Insoection Surimary:

Inspection On January 2 - January 30, 1981 (Report No. 50-271/81-02)

Areas Inspected:

Routine unannounced inspection on regular and backshifts by Resident

Inspectors of:

action taken on previous inspection findings; IE Bulletin followup;

review of shift logs and operating records; plant tours; surveillance testing;

operational safety verification; maintenance activities; followup of everts; in-office

review of licensee event reports; review of periodic and special reports, observation

of physical security; and inspector actions based on T/I 2515/47 Inspection Require-

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m:nts to Review Licensee Actions in Response to IE Bulletin No. 80-24, T/I 2515/46,

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Survey to Determine Existence of Adequate Emergency Procedures for Coping with ATWS

Events at Operating Power Reactors, and IE HQ Request for Licensee Status of TMI-2

Action Plan Item implementation. The inspection involved 98 hours0.00113 days <br />0.0272 hours <br />1.62037e-4 weeks <br />3.7289e-5 months <br /> onsite by two

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resident inspectors.

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Results: Within the areas inspected no items of noncompliance were identified.

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Region I Form 12

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(Rev. April 77)

8104280024

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DETAILS

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1.

Persons Contacted

The below listed technical and supervisory level personnel were among

those contacted:

Mr. R. Branch, Assistant Operations Supervisor

Mr. P. Donnelly, Instrument and Control Supervisor

Mr. L. Goldthwaite, Instrument and Control Foreman

Mr. S. Jefferson, Reactor Engineering Supervisor

Mr. R. Kenny, Technical Assistant

Mr. M. Lyster, Operations Supervisor

  • Mr. W. Murphy, Plant Superintendent
  • Mr. J. Pelletier, Assistant Plant Superintendent

Mr. W. Penniman, Security Supervisor

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Mr. D. Reid, Engineering Support Supervisor

Mr. S. Vekasy, Technical Assistant

Mr. G. Weyman, Chemistry and Health Physics Supervisor

Mr. W. Whittmer, Maintenance Supervisor

The inspector also interviewed other licensee employees during the

inspection, including members of the Operations, Health Physics,

Instrument and Control, Maintenance, Reactor Engineering, Security

Contractor and General Office staff.

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'(* denotes those present at management meetings held periodically during

theinspection)

2.

Action Taken on Previous Inspection Findings

(Closed) Noncompliance (50-271/80-03-01): Licensee delivered package of

LSA radioactive waste to a carrier for transportation with a radiation

dose rate from its surface exceeding 200 millirem per hour.

In response

to the subject item of noncompliance, the licensee stated in letter

VY-5675, dated May 27, 1980, that the Vermont Yankee Administrative

Procedure AP 0504 covering shipment of radioactive waste had been re-

vised to require surveys of all areas of shipment.

In addition, the

licensee reported the procedure was revised to clarify the instructions

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necessary to maintain exclusive use shipment controls. The licensee

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stated that full compliance was achieved by February 15, 1980.

The inspector reviewed Chem and H.P. Department Instruction (DI) 80-1,

dated February 15, 1980.

Subject DI incorporated changes to AP 0504,

Shipment and Receipt of Radioactive Materials, in that additional surveys

underneath the Exclusive use Shipment were required and a Note was added

to VYAPF 0504.02, (VYNPS Radioactive Shipment Record, Exclusive Use

Radioactive Material Shipment, Truck Survey), requiring that the carrier

not permit loading, unloading, or rearranging of the cargo or changing of

the tractor or fifth wheel movement without prior permission from the

licensee.

The inspector had no further questions in this area.

This item

is considered closed.

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3.

IE Bulletin Followup

For the IE Bulletins listed below, the inspector verified the following:

that the written response was within the time period stated in the

bulletin, that the written response included the information required

to be reported, that the written response included adequate corrective

action commitments based on information presented in the bulletin and

the licensee's reviews, that licensee management forwarded copies of

the written response to the appropriate onsite management representatives,

that information discussed in the licensee's written response was accurate,

and that corrective action taken by the licensee was as described in the

written response. The following bulletins were reviewed:

(a)

IEB 80-24, Prevention of Damage Due to Water Leakage Inside Contain-

ment, dated November 21, 1980

The inspector reviewed licensee response FVY 81-1, dated December 31,

1980, and verified that subject IEB requirements have been addressed.

Further followup in this area was conducted in conjunction with per-

formance of T/I 2515/47, see section 13.b. of this report.

No inadequacies were identified.

(b)

IEB 80-23, Failure of Solenoid Valves Manufactured by Valcor

Engineering Corporation, dated Novenber 14, 1980

The inspector reviewed licensee response WVY 80-169 dated

December 11, 1980.

The inspector verified that subject IEB require-

ments have been completed in that the licensee reported that Vermont

Yankee does not utilize Valcor Engineering Corporation solenoid

valves having part numbers V709000-21-1 or V90900-21-3 in any safety

related systems or for any safety related function.

No inadequacies were identified.

(c)

IEB 80-21, Valve Yokes Supplied by Malcom Foundary Company, Inc.,

dated November 6, 1980

The inspector reviewed licensee response WVY 80-168, dated

December 5, 1980. The inspector verified that subject IEB require-

ments have been completed in that the licensee reported that Vermont

Yankee does not use or plan to use valve parts cast by Malcom

Foundary Company, Inc. in any safety related system.

No inadequacies were identified.

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4.

Shift Logs and Operating Records

a.

The inspector utilized the following plant procedures to determine

the licensee established administrative requiraments in this area

in preparation for review of various logs and records.

AP 0001, Plant Procedures, Revision 6, dated September 25, 1979.

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AP 0150, Responsibility and Authority of Operations Department

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Personnel, Revision 14, dated December 19, 1980.

AP 0153, Maintenance of Operations Department Logs, Revision 8,

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dated December 31, 1979.

AP 0140, VY Local Control Switching Rules, Revision 4, dated

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December 19, 1980.

AP 0020, Lifted Lead / Installed Jumper Request Procedure,

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Revision 4, dated October 16, 1980.

AP 0021, Maintenance Requests, Revision 9, dated September 25, 1980.

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AP 0154, Control Room Night Order Book, Revision 5, dated

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January 7, 1980.

AP 0030,- Plant Operations Review Committee, Revision 6,

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dated January 7, 1980.

The above procedures, Technical Specifications, ANSI N18.7-1972

" Quality Assurance Requirements for Nuclear Power Plants" and

10 CFR 50.59 were used by the inspector to determine the acceptability

of the logs and records reviewed.

b.

Shift logs and operating records were reviewed to verify that:

Control Room logs and surveillance sheets are properly

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completed and that selected Technical Specification limits

were met.

Control Room log entries involving abnormal conditions

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provide sufficient detail to communicate equipment status,

lockout status, correction, and restoration.

Log Book reviews are being conducted by the staff.

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Operating and Special orders do not conflict with Technical

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Specifications requirements.

Jumper (Bypass) log does not contain bypassing discrepancies

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with Technical Specification requirements and that jumpers

are properly approved prior to installation.

c.

The following plant logs and operating records were reviewed:

Shift Supervisor's Control Room Log: January 2-January 30, 1981.

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Night Order Book Entries: January 2-January 30, 1981.

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Control Room Operator Round Sheet:

Periodic reviews during

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inspection period.

Manager of Operations Directives:

80-01, Policy on Material

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Purchase Requests for Calibration Services (Revision 1),

dated February 29, 1980.

80-02, Change in RPS Delay Time,

dated March 12, 1980.

Plant Information Reports: 79-01, Repeated Wiping of #5 and #6

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Main Turbine Bearings, dated May 9, 1979.

80-01, Hydrogen

Recombination before A0G recombiners, dated June 25, 1980.

No items of noncompliance were identified.

5.

Plant Tour

The inspector conducted a tour of accessible areas of the plant including

the Control Room Building, Turbine Building, Reactor Building, Diesel

Rooms Intake Structure, Security Gate Houses 1, 2 and Alarm Stations,

and Control Point Areas.

a.

Monitoring Control Room Panels

Routinely during the inspection period, the inspectors conducted

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reviews of the centrol room panels. The following items were reviewed

to determine the licensee's adherence to Licensee Technical Specifica-

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tion - Limiting Conditions for Operation and to verify the licensee's

adherence to approved procedures.

Switch and valve positions required to satisfy LCO's, where

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applicable.

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Alarms or absense of alarms. Acknowledged alarms were

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reviewed with on shift licensed personnel as to cause and

corrective actions being taken where applicable.

Review of " pulled alarm cards" with on shift perso mel.

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Meter indications and recorder values.

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Status lights and power available lights.

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Front panel bypasses.

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Computer printouts.

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Comparison of redundant readings.

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No items of noncompliance were identified.

b.

Radiological Controls

Radiation controls established by the licensee, including:

posting of radiation areas, radiological surveys, condition of

step-off pads, and disposal of protective clothing were observed

for conformance with the requirements of 10 CFR 20 and AP 0503,

Establishing and Posting Controlled Areas, OP 4530, Dose Rate

Radiation Surveys and OP 4531, Radioactive Contamination Surveys.

Confinnatory surveys were conducted in the following areas to

verify licensee posted results:

HPCI Room, Floor Elevation 213'.

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The inspector noted a High Radiation Area setup in the Northeast

corner of the HPCI room.

Posting indicated the area was utilized

for storage during the refueling outages at the time of the

inspection the area was empty. The observation was noted to

Control Point Health Physics personnel who indicated that the

area would be surveyed and removed.

The following Radiation Work Pennits were reviewed by the inspector

to verify conformance with licensee procedure AP 0502, Radiation

Work Permits:

81 No. 00093, A0'S Rounds, dated January ~23, 1981

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81 No. 00092, General Entry to Cask Room, dated January 23, 1981

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81 No. 00091, Compact Trash, dated January 23, 1981

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81 No. 00072, A0 Access to NRHX Room, dated January 19, 1981

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81 No. 00073. A0 Access to RCU Demin. Piping, dated

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January 19, 1981

81 No. 00071 A0 Access to RCU A and B. Pump Rooms, dated

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January 19, 1981

81 No. 00140, Repair RCU Pump, dated January 28, 1981

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81 No. 00103, Remove Blade Guides from SFP, dated January 28, 1981

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81 No. 00106, Insp. FP Heat Exch. Room for RCU Pipe, dated

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January 28, 1981

81 No. 00105, Decon. Pump Parts (RCU), dated January 28, 1981

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Except as noted below, the inspector had no further questions in

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this area.

During the inspector review of the above RWP's, it was noted that

Radiation Work Permits Nos. 00072, 00073, and 00071 contained the

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names of two Auxiliary Operators who had signed in on the subject

RWP's but had not recorded the time or dosimeter readings in and out

of the work area. Since the subject RWP's required signing both in

and out, this did not appear consistent with AP 0502 requirements.

The inspector noted his finding to Health Physics control point

personnel who indicated they would contact the Auxiliary Operators

to determine if they had in fact performed work in accordance with

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the subject RWP's.

Following discussions with Health Physics

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personnel, it was detennined that the individuals had inadvertently

signed in on the subject RWP's when reviewing the weekly posted RWP's

which authorize routine A.0. actions and require initial signing

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only. The licensee determined that the individuals had not entered

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the work areas authorized by RWP's Nos. 00072, 00073 and 00071,

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their names were deleted from the subject RWP's and they have been

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reinstructed in the requirements of AP 0502.

c.

Plant Housekeeping and Fire Prevention

Plant housekeeping conditions, including general clearliness and

storage of materials to prevent fire hazards were observed in all

areas toured for confonnance with AP 0042, Plant Fire Prevention,

and AP 6024, Plant Housekeeping.

No inadequacies were identified.

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d.

Fluid Leaks and Piping Vibrations

Systems and equipment in all areas toured were observed for the

existence of fluid leaks and abnormal piping vibratien.

No inadequacies were identified.

e.

Pipe Hangers / Seismic Restraints

During routine tours of the plant, pipe hangers and restraints

installed on various piping systems were observed for proper

installation, tension, and condition.

No inadequacies were identified.

f.

Control Room Manning / Shift Turnover

Control Room Manning was reviewed for conformance with the require-

ments of 10 CFR 50.54 (k), Technical Specifications, AP 0152, Shift

Turnover, AP 0150, Responsibility and Authority of Operations Depart-

ment Personnel and AP 0036, Shift Staffing.

The inspector verified,

during the inspection, that appropriate licensed operators were on

shift. Manning requirements were met at all times.

Several shift

turnovers were observed during the course of the inspection. All

were noted to be thorough and orderly.

No items of noncompliance were identified.

6.

Surveillance Testing

The inspector reviewed the following surveillance test to verify that

testing was performed in accordance with technically adequate procedures,

that results were in conformance with Technical Specifications and

procedure requirements, that the results were reviewed by personnel

other than the individual directing the test, that any deficiencies

management _ personnel, and ~that activ_roperly reviewed and resolved _b

identified during the testing were p ies were in comp _liance with

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AP 4000, Surveillance Testihg Control.

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OP 4386, Liquid Process Radiation Monitor System Calibration, Revision 7,

dated April 16, 1980.

The inspector reviewed instrument No.17-350,

Radwaste Water Effluent, calibration data as recorded on VYOPF 4386.01

for the following dates: April 7-8, 1980, July 8, 1980, October 7, 1980

and January 6, 1981. The inspector noted that the calibration attempt

of January 6 resulted in replacement of the effluent monitor detector

and crystal, and recalibration of the instrument. The inspector verified

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by review of OP 2610 (Liquid Waste Disposal, Revision 7, dated

November 13,1980), discharge permits for the period of

October 7, 1980 to January 7, 1981, that the licensee had not per-

formed an ef*1uent discharge to the Connecticut River utilizing

instrument No.17-350. The inspector also notr* that OP 2610 re-

quires sampling of the effluent prior to discharge and resetting of

the effluent monitor setpoint utilizing the most recent calibration

data and known background activity.

The inspector determined that

licensee compliance with T.S. Section 4.B.A which states in part,

Radioactive effluents shall be continuously monitored and alarmed,

was adequate. The inspector further detemined that the last

licensee discharge to the Connecticut River utilizing Radwaste

Effluent Water was on September 11, 1979, utilizing discharge

permit No.79-686.

No items of noncompliance were identified.

The inspector had no

further questions in this area.

7.

Operational Safety Verification

A detailed review of the High Pressure Coolant Injection System (HPCI)

was conducted during the period of January 26-27, 1981, to verify that

the system was properly aligned and fully operational in the standby

modo.

Review of the above system include the following.

verification that each accessible valve in the flow path was in the

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correct position by either visual observation of the valve or remote

position indication.

Plant procedure OP 2120, Revision 12, dated

November 24, 1980, and drawing G-191169, Revision 19, was used to

verify proper HPCI system lineup.

verification that accessible power supplies and breakers were pro-

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perly aligned for components that are required to actuate upon

receipt of a safety injection signal.

visual inspection of major components in the selected system for

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leakage, proper lubrication, cooling water supply, general condi-

tion and other factors that might prevent fulfillment of their

functional requirements.

verification by observation that the instrumentation essential for

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system actuation and performance was operational and/or within

calibration requirements.

No items of noncompliance were identified.

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8.

Maintenance Activities

The inspector reviewed portions of the following maintenance activity

to verify compliance with LC0 requirements where applicable, that re-

dundant components were operable, administrative approvals and tagouts

were proper, approved procedures were utilized, activities were con-

trolled by qualified personnel, equipment certification, proper equip-

ment return to service, and compliance with AP 0021, Maintenance Requests,

and AP 0200, Maintenance Program.

The following activities were reviewed

by the inspector:

MR 83-249, Replacement of MSIV 80A guide pins and installation of

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new spring plate, dated February 27, 1980.

No items of noncompliance were identified.

9.

Inspector Followup of Events

The inspector responded to events that occurred during the inspection

period to verify continued safe operation of the reactor in accordance

with the Technical Specifications and regulatory requirements. The

following items, as applicable, were considered during the inspector's

review of operational events:

observations of plant parameters and systems important to safety

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to confirm operation within approved operational limits;

description of event, including cause, systems involved, safety

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significance, facility status and status of engineered safety

features equipment;

details relating to personnel injury, release of radioactive

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material and exposure to radioactive material;

verification of correct operation of automatic equipment;

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verification of proper manual actions by plant personnel;

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verification of adherer:e to approved plant procedures;

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verification of conformance to Technical Specification LC0

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requirements; and,

compliance with AP 0010, Occurrence Reports, when applicable.

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Operational events reviewed during this inspection are discussed below.

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a.

Power Reduction for Turbine Generator Unit' Maintenance

During the week of January 12, 1981, the licensee noted higher than

normal vibration readings on 19 bearing of the plant's turbir.e

generator unit.

Investigation by the licensee concluded that the

vibration was originating from the flexible coupling which connects

the shaft from the Main Turbine Generator to the direct-driven

Alternator-Exciter.

The #9 bearing ir.dicated vibration ranged

from 11 to 13 mils as compared to previous readings in the 5 to 9

mil range, the turbine generator vibration setpoint for #9

bearing is 15 mils.

On January 17, 1981, the licensee reduced power and removed the

turbine generator from the grid to support disassembly of the sus '

pect flexible coupling. The inspectors observed disassembly of

the coupling and discussed its repair with cognizant plant

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personnel.

The inspectors had no further questions in this area.

b.

Drywell Entry

On January 17, 1981, reactor power was reduced to approximately

15% to facilitate licensee investigation and repair of indicated

turbir.e generator. bearing vibration originating in the generator

exciter flexible coupling. During the repair period, the licensee

performed a routine primary containment entry to inspect the dry-

well area. The purpose of the drywell entry was an attempt to

locate sources of unidentified drywell leakage.

Reactor coolant

system unidentified leakage for the period of January 7 to

January 15, 1981, ranged from .33 to .16 GPM; the limit for

unidentified leakage is 5 GPM per T.S. Section 3.6.C.

Inspection

of the drywell by licensee personnel revealed three possible

sources of unidentified leakage:

(1) RWCU Valve 99 packing leakage (steady drip)

(2)

'B' Recirc. Motor air cooler condensation from unlagged line

(3) RPR system lower spray ring leakage

Corrective action by the licensee was taken in that CU-99 packing

was tightened and motor air cooler condensation and lower spray

ring leakage was identified.

The inspectors monitored the initial drywell entry for compliance

with licensee procedure VYAP 0507, Primary Containment Entry,

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Revision 3, dated September 25, 1980. Vermont Yankee Radiation

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Work Pemit (RWP) No. 00064, Drywell Inspection, dated

January 17, 1981, was reviewed fer compliance with licensee

procedure VYAP 0502, Radiation Work Permits, Revision 9, dated

June 30, 1980.

Upon completion of the drywell entry, VYAPF 0507.01, Containment

Entry Checklist was reviewed for completeness and RWP No. 00064

was reviewed for proper termination. The inspector noted that

VYAP 0507 requires that when the reactor is operating, a team of

two personnel will be stationed at the drywell entrance to provide

assistance as required. Discussion with licensee personnel indi-

cated that this requirement was necessary only when personnel

entering the containment utilized self-contained breathing

apparatus. The licensee indicated he would look into the basis of

the two-man assistance team requirement and clarify AP 0507,

Section 8 ff deemed necessary (IFI 50-271/81-02-01).

The inspector had no further questions in this area.

No items

of noncompliance were identified.

c.

RADWASTE Transoortation, Shipment No. 81-07

On January 28, 1981, the licensee infomed the inspectors that an

apparent discrepancy had been found in a shipment of dry compacted

LSA waste to Beatty, Nevada disposal site. Review by the

inspectors revealed the following:

VY LSA Shipment 81-07 consisted of 153 55-gallon drums. of

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dry compacted waste contracted to Hittman/ Tristate for

transportation to the Beatty, Nevada disposal site.

The shipment left the site at 10:00 A.M. on January 21, 1981,

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and arrived at Beatty, Nevada on January 26, 1981.

Waste disposal site inspectors discovered a pencil size hole

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approximately one inch from the top of one 55-gallon drum.

The hole was initially covered with a piece of tape.

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The hole was discovered on January 26, 1981, by Nevada state

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inspectors and reported to the licensee on January 27, 1981.

The disposal site suspended VY disposal Permit Number 264 as

a result of the occurrence.

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The subject drum contained a plastic liner which was not

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punctured.

Surveys of the barrel and shipment vehicle re-

vealed no spread of contamination as a result of the container

breach.

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The licensee held a conference on January 28, 1981, with the

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State of Nevada and VY Permit No. 264 was reinstated by the

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State of Nevada based on commitments made by the licensee.-

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Pending further clarification of the commitments made to the State

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of Nevada, and pending completion of USNRC Regionlinvestigation

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into this occurrence, this iten will remain unresolved

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(URI 50-271/81-02-02).

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d.

Leak' Test of Explosion Detector Sources

On January 21, 1981, the inspectors received notification from the

Region of a possible contamination' source in certain models of

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Explosion Detectors manufactured by Ion Track Instruments. Inc..

The inspectors verified that Vermont Yankee utilizes two (2) of-

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the Ion Track Instruments, Model 75. Entry Scan Explosion Detectors.

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The inspectors requested that the licensee perform a leak check

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test of the sources containea in these' devices. The instruments

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contain the active isotope " Electro" (Nickel-63) which is deposited

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on an inert nickel foil and is classified as an unsealed source,

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which is exempt from NRC. licensing.

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On January 23, 1981, the licensee reported that a swipe survey of_

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the source contained in each explosion detector resulted in no

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detectable contamination. These results were forwarded to USNRC

Region I personnel as requested.

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The inspector had no further questions in this area.

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In-Office Review of Licensee Event Reports

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The licensee event reports (LERs) listed below were reviewed in the NRC

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Resident / Regional Office. The reports were reviewed to detemine whether:

the infomation provided was clear in the description of the event and

!

identification of safety significance; the event cause was identified and

'

l

corrective actions taken (or planned) were appropriate; the report satis-

l

fied requirements with respect to information provided and timeliness of

r

submittal per NUREG 0161 and T. S. Section 6.7 criteria. Those reports

annotated with an asterisk (*) concern events that required inspector

'

followup action and inspector review / evaluation of the event is documented

i

elsewhere, in this or other inspection reports.

,

+

a.

Continuous Environmental Air Sample Not Taken:

)

.

. LER 80-40. Event Date November 30, 1980

l-

. LER 80-28, Event Date, September 8, 1980

,t

,

l

3-

'

,m-,r.,.,-,,.,s,.,-.my-.,,mn,

,y,,ymmm-m.ye w r,w m ow -- %

,ew,

.

-,,,-w,-w

,_,m,

..,.mc.

,m-w,_

,

--.cm~ w

.

.

.

14

LER 80-21, Event Dates June 30, 1980 and July 7, 1980

.

LER 80-03, Event Date January 7, 1980.

The inspectors noted

.

that TS Table 3.9.1 requires that containuous air sampling

be performed. As a result of LER 80-04 the licensee is com-

mitted to install surge suppressors on the supply to the

monitoring stations.

LER 80-28 previously reported that "If

feasible, lightening surge suppressors will be installed in

all nine Environmental Sample Stations."' LER 80-21 reports

that due to apparent pump bearing failure modifications of the

puaip and ventilation are being evaluated.

LER 80-03 reports

that due to instances of disconnected tubing, stainless steel

hose clamps were installed to prevent future recurrence.

The licensee is currently evaluating Air Sample Station per-

formance.

The inspectors will follow system evaluation and

implementation of corrective actions.

(IFI 50-271/81-02-03).

b.

PCIS Valve Failure to Close Due to Accumulation of Dirt on Plunger:

LER 80-20, Event Date June 17,1980 (See Inspector Report 271/80-17)

.

LER 80-17, Event Date April 24, 1980

'

.

LER 80-20 reports that' a preventive maintenance program is being

evaluated to preclude potential future events.

The inspectors

will follow program evaluation and implementation of corrective

actions.

(IFI50-271/81-02-04)

c.

Change in RPS Delay Time.

LER 80-10, Event Date March 7, 1980

.

No items of noncompliance were identified.

11.

Review of Periodic and Special Reports

Upon receipt, periodic and special reports submitted by the licensee pur-

suant to Technical Specification 6.7 and Environmental Technical Specifi-

cation 5.4 were reviewed by the inspector to verify that applicable re-

porting requirements had been met.

VYV-5937, Monthly Statistical Report, Month of December 1980, dated

--

January 14, 1981

VYV-5906, Monthly Statistical Report, Month of November 1980, dated

--

December 9,1980

No unacceptable conditions were identified.

,.

--

-

-. _ - .

- _ . .

- - _ _ _

__ -_ -

--. -

_ __

.

.

.

-

15

12. Observations of Physical Security

The inspector made observations, witnessed and/or verified during regular

and offshift hours that selected aspects of plant physical security were

in accordance with regulatory requirements, the physical security plan

and approved procedures.

a.

Physical Protection Security Organization

observations indicated that a full time member of the security

--

organization with authority to direct physical security actions

was present as required.

manning of all shifts on various days was observed to be as

--

required.

-

b.

Access Control

Observations of the following items were made:

identification, authorization and badging.

--

access control searches, including, when applicable, the use

--

of compensatory measures during periods when equipment was

inoperable.

escorting.

--

'

Physical Barriers

c.

selected barriers in the protected area ard vital area were

--

observed and random monitoring of isolation zones was performed.

Observation of vehicle searches were made.

inspector tours of gate house 1 and 2, the Central and Secondary

--

.

Alarm Stations were conducted at random periods.

,

No items of noncompl.iance were identified.

13.

Inspector Actions Based on Performance of Temporary Instruction (T/I)

'

Requirements

a.

Inspector Actions Based on Performance of T/I 2515/46, Survey to

Determine Existence of Adequate Dnergency Procedures for Coping

with ATWS Events at Operating Reactors, dated December 5, 1980

The objective of T/I 2515/46 is to verify that licensees have

emergency operating procedures adequate to respond to ATWS events.

.__

__.

- _ _

_.

_ ___._

.

_ . , _ . _ . _

.

.

l

'

16

l

suriey_was initiated by IE Bull [ tin 80-17, d'ated.Julyj,

~

1980,following. the Brown's F.erry failure to completely scram

event.

This T/I formalizes the actions needed to com-

plete the survey. The results of T/I 2515/46 inspection are

i

summarized below and have been transmitted to IE Headquarters

by memorandum to Mr. W. R. Mills, HQ, I.E., dated January 19, 1981.

References:

(a)

IE Bulletin 80-17, Failure of 76 of 185 Control Rods to

Fully Insert During a Scram at a BWR, dated July 3, 1980

(b) Vemont Yankee Letter to B. H. Grier, WVY-100, dated

July 13, 1980

,

(c) T/I 2515/46, Survey to Determine Existence of Adequate

'

/

Emergency Procedures for Coping with ATWAS Events at

,

Operating Power Reactors, dnted December 5, 1980

(d) T/I 2515/39, Inspection Requirements to Review BWR

Licensee Actions Taken in Response to IE Bulletin

No. 80-17, dated July 3, 1980

(e) Vemont Yankee Inspection Report 50-271/80-10, dated

October 16, 1980

(f) VY OP 2111, Revision 10, Control Rod Ceive System, dated

November 13, 1980

(g) VY OP 2114, Revision 9, Operation of the Standby Liquid

Control System, dated November 24, 1980

(h) VY OP 31J0, Revision 9, Reactor Scram Emergency Procedure,

dated July 11, 1980

(i) VY OP 3109 Revision 1, Anticipated Transient Without Scram

Emergency Procedure, dated November 26, 1980

(j) VY AF 0150, Revision 14, Responsibilities and Authorities

of Operations Department Personnel, dated December 19, 1980

VermontYankeeisaBWR,thereforereference(c)sectionIV

Acceptance Criteria 1. and 3. apply as noted below:

. Acceptance Criterion 1. :

For BWR's, IE Bulletin 80-17, Action No. 4 of " Actions to be

taken by Licensees" and Guidance contained in T/I 2515/39.

-

_

_

- _ - _

..

.-.

.

-

.

-

. -

.

.

.

.

17

" NOTE:

To be effective, if recirculation pumps do not auto-

matically trip. .the procedure must require the op'erator

to do this quickly folicwing an ATWS condition,

Bulletin 80-U, reference (a) Section 4. requires a review of

emergency operating procedures to assure that for a scram,

'

'

operator actions include:

(thefollowin

correspond to reference (a) Section 4.) g paragraph numbers

"4.a. Place the reactor mode switch in a position other than RUN."

'

The inspectors determined that this requirement is contained

--

in reference (h), " subsequent action", to be performed after

verification that steam flow has decreased below .64M#/hr in

each steam line.

"4.b. Detemine whether either of the two conditions below exist:

(1) Five(5)ormoreadjacentrodsnotinsertedbelowthe

06 position.

(2) Thirty (30) or more rods not inserted below the 06

position."

4

The inspectors concluded that the determination of rods not

--

inserted is cor.tained in reference (h), "immediate actions".

Vermont Yankee's detemination is conservative, in that

section 1.b. of reference (h) requires action "if any scram

condition exist for greater than 10 seconds with failure of

two or more control rods to fully insert in response to a

full scram. . ."

"4.c. If either condition 4.b. (1) or 4.b. (2) exists:

(1) Trip the recirculation pumps.

(2)

Insert rods manually.

If rods cannot be inserted manually,

alternately reset the RPS and scram the reactor until all

rods are fully inserted.

(3) Vent the scram air header.

(4) Manually open or bypass the scram instrument volume drain

and vent valves, if possible."

<

,

.

.

.- , - - - - . , ~

--

-,_-

-.-y_,

,.,-r-

, . - - - - - _ _ ,

- . . - - - . - - . - - - - , - . . - .

.m.-

, ,--.

.

.

18

The inspectors determined that reference (h) requires the

--

following operator actions based on rods not inserted:

(1)

If the conditions of 4.b. above exist, the operator is

required to " Trip the recirc pumps by placing their con-

trol switches to pull-to-lock on CRP 9-4 (reference (h)

Step 1.b. (1)).

(2) Reference (h) Step 1.b. (1) requires:

" manually rescram

,

the reactor by depressing both manual scram pushbuttons

'

on CRP 9-5".

Step 1.b. (2) requires additional actions

.

if indication exists that the scram signals have failed

to open the sc.am valves, these actions include:

Step

1.b. (2) (a) and (b), manually opening circuit breakers

or manually securing RPS MG sets provide alternate methods

of scramming the plant.

(3) Reference (h) Step 1.b. (3) requires tne following actions,

"until all control rods are fully inserted, monitor nuclear

instrumentation for decreasing neutron flux and indication

of local areas of high neutron flux while performing the

following:

,

a)

Clear the cause of the scram, bypass the SDV and

'

verify open or manually open the Vent and Drain

valves, place mode switch in shutdown, reset both

i

RPS channels.

l

'

b)

Individually scram those control rods not fully in-

serted from CRP 9-16 starting with those in local

areas of indicated high neutron flux.

Reset each

control rod after it fully inserts and continue to

scre.:a rods until all contrcl rods are fully inserted."

c)

If 3.b. is unsuccessful in scramming control rods,

manually scram the reactor, reset and repeat if in-

sert rod motion is observed until all control rods

are fully inserted,

d)

If 3.c. is unsuccessful in scraming control rods, by-

pass the RWM and attempt to marW ily insert control

rods with the reactor manual control system, starting

with those in local areas of indicated high neutron

l

flux.

"4 d. . If, at any time, either condition 4.b. (1) or 4.b. (2) exists

and either RPV water level cannot be maintained or suppression

pool water temperature cannot be maintained below the

suppression pool water temperature scram limit, initiate the SLCS."

i

.

F'**r

w

w.-

--

y

y

,

--g

ig-

p,-,y.-

-e,

vwr

-yt

y

pp-+

--

- , . , - .

--y-

-

-,-,-y

p--- - - ..--

,y


m---g.-

,,-w

,,,., -

.

.

19

The inspectors determined that reference (g) states that the

--

control room operator will initiate the SLCS, with shift super-

visor approval, should any of the following conditions exist:

O) A gross failure of control rods such that they cannot be

scrammed or manually inserted into the core.

(2) Nomal rod exercise indicates a rod is stuck such that

shutdown margin requirements cannot be met.

(3) The reactor engineer detemines that shutdown margin re-

quirements of the T.S. cannot be met.

(4)

R.V. water level cannot be maintained and the CRD system

is unable to maintain the reactor subcritical as indicated

by the neutron monitors.

The shift supervisor is nromally stationed in the control room and

thus readily available to acknowledge initiation of SLCS operation

without undue administrative delay. Further, per reference (j)

the control room comand function is transferred to the senior

control room operator during shift supervisor temporary absences.

Reference (h) Step 1.b. (4) requires that " initiate injection of

SLC solution into the reactor vessel at any time reactor water

level cannot be maintained or torus water temperature cannot be

maintained below the. torus scram limit (1100F) if simultaneously

the control rod dri,ve system is unable to maintain the reactor

suberitical at existing conditions as indicated by neutron monitors."

Reference (i) notes the concerns associated with an ATWS event,

and details symptoms and actions to be taken. Vermont Yankee

has installed a recire pump trip (RPT) circuit to quickly add

negative reactivity to the core to mitigate the consequences

of an ATWS event.

If RV water level ramins at the low-low set-

point, (-44.5) for > 10 seconds or RV pressure increases to

1150 psip, both recTrc. field breakers will automatically open.

This can also be accomplished manually, using pushbuttons on

CRP 9-4.

Acceptance Criterion 3.:

.

The operator should have complete authority to activate the Standby

Liquid Control System (BWR) or commence emergency boration (PWR),

and he should be responsible for doing this when the situation

requires it.

If the Standby Liquid Control System (SLCS) is key

operated, the key must be readily available to the opera or.

Criteria for the use of SLCS and emergency boration relative to

inability to insert negative reactivity by other means should be

included in emergency procedures.

4

wn-

, - -~,

- ,

e--

,,.me

-e

---n.

,--

, - - ~ - , - . , - - - ~ , - . - , + -

,

w ---- - ,

,-e-,,

- _ _ _ _ _ - _ _

_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ -

_ _

_ _ _ _ _ _ _ _ _ _

__

_ _ _ _ _ .

_ ____ _

_ _ _ - _ _ _ _ _ _ _ _ _ _ _ .

.

.

20

.

..le inspectors determined that at Vermont Yankee the SLCS-is

--

key operated, reference (g) step B.2 requires the key to the

SLC switch be kept in the switch itself.

Reference (h) requires initiation of SLCS any time RV level

cannot be maintained or torus water temperature cannot be

maintained below the torus scram limit (110 F) if simultaneously

the CRD system is unable to maintain the reactor subcritical

at existing cLnditions as indicated by neutron monitors.

Reference (i) requires initiation of SLC system into the RV

if the control rods cannot be scranmed.

Based on the above information, the licensee has addressed IE

Bulletin 80-17 concerns in his procedures for coping with ATWS.

Within the scope of T/I 2515/46 the inspector identified no

exceptions from the acceptance criteria,

b.

Inspector Actions Based on Performance of T/I 2515/47, TI For IE

Dulletin 80-24, Prevention of Damage Due to Water Leakage Inside

Containment

The objective of T/I 2515/47 is to verify that actions required by

IE Bulletin 80-24, dated November 21, 1980, have been satisfactorily

completed, that suitably detailed descriptions of open cooling systems

within containment are provided as required, and that acceptable

4

documentation is provided by the licensee.

The results of T/I 2515/47

inspection are summarized below and have been transmitted to IE Head-

quarters by memorandum to Mr. R. Woods, HQ, I.E. , dated January.7,

1981.

References:

l

(a) Preliminary T/I 2515/47, dated December 18, 1900, TI for IE

Bulletin 80-24, Prevention of Damage Due to Water Leakage

!

Inside Containment.

(b)

IE Bulletin 80-24, dated November 21, 1980, Prevention of

Damage Due to Water Leakage Inside Containment (October 17,

1980, Indian Point 2 Event).

.

. . _ - . .

,

. . , . _ .

_,

_ - . . _ . . . , .

. . _ _ _ _ - . _ _ _ , ,

.

- - - -

. .

_-

-

-

.

.

.

.

i

l

21

(c)

Letter, L. H. Heider to B. H. Grier, dated December 31, 1980,

Response to IE Bulletin 80-24

,

The following tables are provided in response to IE Bulletin 80-24

" Actions to be taken by Licensees." The numbered items correspond

,

i

to the nunbered action in the subject bulletin:

TABLE I LEAKAGE HISTORY, OPEN SYSTEMS

i

IE BULLETIN 80-24. ITEMS 1. (a.-f.)

OPEN

N S

LEAK

WET

REPAIR

SYSTEM

P, F, LOCATION SPOTS DRIPS STREAMS DELUGES METHOD

NONE

1

KEY:

N = Normally used

P = Post - LOCA

S = System uses salt or brackish water

F = System uses fresh water

TABLE II LEAKAGE DETECTION SYSTEMS

IE BULLETIN 80-24. ITEMS 2. (a.), (b.)

i

MEANS OF

INDICATION (I)OR

TYPE OF

FLOW MEAS.

LOCATION OF POTENTIAL

DETECTING

ALARM (A) IN

FLOW

READOUT IN

.

!

WATER ACCUMULATION

WATER

CONTROL ROOM

MEAS. INST.

CONTROL RM.

i

500 GAL. EQUIP. DRAIN

FLOAT

I, (HIGH LEVEL)

TOTALIZER

YES, CHART

SUMP, EQUIPPED WITH

SWITCH

I, A (HIGH-HIGH

IN SUMP

FLOW RECORDER

TWO 50 GPM PUMPS

LEVEL)

DISCH. LINE

AND TOTALIZER

,

(ALTERNATING)

READOUT

'

TEMP.

SENSOR

I, A

l

SUMP LEVEL

l

SWITCHES.

TIMES SUMP

A (< PRESET FILL

FILL RATE

RATE)

'

AND

I FILL TIME)

!

PUMP RUN TIME A > PRESET RUN TIME)

I PUMP OUT TIME)

l

PUMP RUN

'

INDICATION

I

500 GAL. DRYWELL

FLOOR DRAIN SUMP

EQUIPPED WITH TWO

50 GPM PUMPS

(ALTERNATING)

SAME AS AB0VE WITH EXCEPTION OF TEMP. IhDICATION

.

-

. . - -

. .

, - -

-

- . . . -

- - - - . - . - -

'

1

.

.

.

22

' Item 2.(c) Review of the licensee's surveillance procedure, OP 4152 Revision 8

July 11, 1980, Drywell Equipment and Floor Drains Surveillance revealed

.-

no unacceptable conditions.

I' tem '2. (d) Within the scope of the inspectors review, no unacceptable areas were

noted. Reference (c) does not address periodic contaimnent entry.

The inspector discussed periodic entry into containment with the licensee.

Vennont Yankee noted that the requirements to consider periodic entry into

the containment to inspect for leakage is contained in IEB 80-24, section

2.d. which applies to plants with OPEN cooling systems: VY does not have

these systems.

TABLE III, LEAKAGE HISTORY, CLOSED SYSTEMS

IE BULLETIN 80-24, ITEM 3

CLOSED

SYSTEM

DATE

SUMMARY OF EXPERIENCE

CLOSED

4/ 2/74

DRYWELL COOLING UNIT RRU-1, SMALL COOLING COIL

C00 LING

LEAK, SUBSEQUENTLY REPAIRED.

WATER

11/12/74

SMALL COOLING COIL LEAK, 1 GPM, REPLACED

3/24/78

SMALL C0OLER LEAK, RECIRC. PUMP'M0 TOR "B" LOWER

BEARING COOLER.

DETECTED BY MOTOR COOLER LEAK

DETECTION SYSTEM.

LEAK REPAIRED.

8/12/79

RRU-1 DEVELOPED 2 TU8E LEAKS IN THE COOLER.

BOTH ENDS OF THE TUBES WERE CAPPED.

The inspector had no further questions concerning the licensee's

response to IE Bulletin 80-24. No items of noncompliance were

identified.

c.

Status of TMI-2 Action Plan Items with Implementation of January 1,1981

Per IE:HQ request transmitted in a January 2,1981, letter from

J. Sniezek to Regional Directors, the inspectors provided a tabulation,

based on licensee /NRC correspondence, of the actions taken and completion

status of TMI-2 Action Plan Items - January 1,1981

implementation at

Vermont Yankoe. As requested, the information was forwarded to IE:HQ,

E. Blackwood, DROI by memorandum dated January 9,1981. Post-implementa-

tion review of selected li~censee commitments will be conducted. Accord-

ingly, where that review results in the identification of additional or

modified commitments by the licensee, a reinspection will be conducted.

A summary of the inspector findings is provided below:

.

e

-

.,

-

r.--,--r

.ir,

4-

e-s-,

- - -

-y

,e--.

,

w - , - - - -

--,-w.-,

- - + - -

.

.

,

J

23

The following references are utilized:

,

(a) NUREG 0737, Clarification of TMI Action Plan Requirements,

published November 1980.

'

(b) Vermont Yankee letter WVY-170, dated December 15, 1980, Post-TMI

Requirements-Implementation Date Commitments.

(c) Vermont Yankee letter WVY 79-130, dated November 20, 1979,

Followup Actions Resulting from the NRC Staff Review Regarding

the Three Mile Island Unit 2 Accident.

(d) Vermont Yankee letter WVY 80-135, dated September 29, 1980,

STA Implementation Schedule

The item numbers below pertain to reference (a), enclosure 1

clarification items.

.

Item

--

+ 1.A.1.1. ,

Shortened Title

+ Shift Technical Advisor

Action

+... training program implemented

Status

+ Committed Completion Date - January 1,1981

+ Completed - Yes (See Note 1)

+ Scheduled Completion Date - June 1,1981

+ Reason Not Completed - (See Note 1)

Item

--

+ 1, A,l .1,

Shortened Title

+ Shift Technical Advisor

Action

+... degreed engineers on shift

.

. . . . . . - . . .

.

-- , , - - - -

,.,

-

.-

. , _ . . - ,

, _ , .

, , , . , . . - .

..

.

-- .- ..

.

-

.

.

24

Status

+ Connitted Completion Date - January 1,1981

+ Completed - Yes (See Note 2)

+ Scheduled Completion Date - June 1, 1981

+ Reason Not Completed - (See Note 1)

't

Itsn

--

+ I.A.1.3.

Sho6tened Title

+ Shift Manning

Action

.

4

+ .. . overtime limits . implemented

status

,

+ Committed Completion.Date - January 1, 1981

+ Completed - Yes (See Note 5)

+ Scheduled Completion Date - NA

+ Reason Not Completed - NA

Itsn

--

+ I.572.1. (4)

.

Shortened Title

.

+ R0 & SR0 Training Program

Action

+... implementation

Status

j

l

+ Committed Completion Date - January 1,1981

+ Completed - Yes (See reference (b))

+ Scheduled Completion Date - NA

+ Reason Not Completed - NA

r

l

Item

j

--

+ I.C.5.

f

I

-. . - . , . . - - .

. - . , , - _ . . . _ , _ _ - - _

. - , , - . _ _ _ . , _ _ , , , . - , _ _ . . , - - - - . _ , - - - . .

. - - _ _ _ . , - . - - . . . . . , . .

.

.

.

25

.

Shortened Title

+ Feedback of Operation Experience

Action

+... Procedure implemented

Status

+ Committed Completion Dat.e - January 1,1981

+ Completed - Yes

+ Scheduled Completion Date - NA

+ Reason Not Completed - NA

Item

--

+ I.CT6.

Shortened Title

+ Verify Performance of Operating Activities

Action

+... revise performance procedures and implement

Status

+ Committed Completion - January 1,1981

+ Completed - Yes (See Note 3)

+ Scheduled Completion Date - NA .

+ Reason Not Completed - NA

Item

'

.

--

+II.E.4.2.(5)

Shortened Title

+ Containment Isolation Dependability

Action

+... Containment pressure setpoint adjusted

,

5

. . _ . - _ .

_ - _ . . _ . _ . . _ _ . _ . . . . - _ . . .

._

_ . - . . . _ . . . _ . . -

. . _

_ _ . . . . . _ _ , _ _

..-..

___

. _ , _ _ . _ . .

. -.

.

--

.

.

.

26

Status

+ Committed Completion Date - Januar

+ Completed - Yes (See reference (b)y 1, 1981

)

+ Scheduled Completion Date - NA

+ Reason Not Completed - NA

Item

--

+ II.E.4.2. (6)

Shortened Title

+ Containment Isolation Dependability

Action

+... containment purge valves closed and surveillance implemented

Status

,

+ Committed Completion Date - Janucry 1, 1981

+ Completed - Yes (See reference (b))

+ Scheduled Completion Date - NA

+ Reason Not Completed - NA

'

Item

--

+ II.K.3.9.

S.'iortened Title

+ Proportional Integral Derivative Controller Modification

Action

+... Mod Accomplished on Westingl.ouse Plants

Status

+ Committed Completion Date - NA (See Note 6)

+ Completed - NA

+ Scheduled Completion Date - NA

+ Reason Not Completed - NA

Item,

--

_

+ II . K.3.22a.

l

l

1

.-

..

_.

. . - .

.

..

. _- .

.

. - .

- --

.

27

i

Shortened Title

RCIC Suction Switchover from CST to suppression pool

Action

+... procedure implemented for manual method of switchover

Status

,

+ Connitted Completion Date - January 1,1981

+ Completed - Yes (See reference (b))

+ Scheduled Canpletion Date - NA

+ Reason Not Canpleted - NA

Iten

--

+ III.D.3.3.

Shortened Title

+ Inplant Radiation Monitoring

Action

+... improved inplant iodine instrumentation under accident conditions

,

Status

'

+ Committed Completion Date - January 1,1981

+ Completed - Yes (See reference (b) and Note 4)

+ Scheduled Completion Date - NA

+ Reason Not Completed - NA

NOTES:

(1) By reference (c), VY committed to provide STAS on shift by

January 1,1980, initiate STA training in 1980, and have fully

trained STAS in place by January 1, 1981. As of January 1, 1980,

an interim group of STAS were on shift.

The group was formed

from existing plant and engineering staff members and consisted

of 13 degreed individuals with plant experience and specific STA

training provided by GE and VY training staffs. Concurrent with

implementation of the interim STA group, a program was initiated

to hire and extensively train a new group of degreed engineers to

ultimately fill the STA role as a full time permanent job function.

The training program for the permanent STA group was designed to

meet INP0 standards published in May 1L80.

Completion of training

1

.

._

_

.

.

.

.

. , _ _ _ _ _ _ . - . _ _ _ _ _ . _ . _ _ ,,

.

.

.

28

i

and start of shift assignment for the permanent group was

scheduled to occur by January 1, 1981.

However, by

reference (d), VY reported that final implementation for

the permanent STA group could not be completed until June 1,1981.

Delays in the implementation date were attributed to:

(1) difficulties in finding degreed en

nuclear and industry experience, and (gineers with previous 2) schediiTii

the full STA trai.ning program.

The last of seven individuals

fonning the permanent STA group was hired in November 1980-and

the STA training program was begun in October 1980. Reference

(d) specifies the permanent STA group will assume shift duties

at the completion of the training program by June 1,1981.

(2) Operating shifts are now staffed with the interim group of

STAS, all of whom are degreed.

However, as reported above

the permanent, fully trained group of STAS will not assume

shift duties until June 1,~1981.

(3) By reference (b), VY stated that management control systems

already in effect meet the intent of the five clarification

items identified in Item I.C.6. of reference (a).

The

addition of independent verification to the management control

system had been previously considered by VY and rejected as

being less desirable and less effective than existing controls.

VY thus refused to commit to independent verification, but

will do so whenever existing controls are found to not provide

(

assurance of system operability.

(4) By reference (b), VY stated that adequate portable sample and

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analysis capabilities for iodine exist without the use of iodine

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collection media such as silver zeolite.

(5) Administrative procedure AP 0036, Shift Staffing, issued on

January 8,1981, instituted limits on overtime hours in

accordance with the reference (a) requirements, with the

exception of the following:

(1) the limit on the number of

hours that an individual could work in any seven consecutive

days was set at 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />, instead of 72; (2) an it.dividual

is limited to working no more than 18 consecutive days

(instead of 14) without having 2 consecutive days off.

(6) The purpose of this controller modification is to prevent

inadvertent opening of the power-operated relief valve (PORV).

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This modification applies only to Westinghouse plants and is

therefore not applicable to Vermont Yankee.

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No items of noncompliance were identified.

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14. Unresolved Items

Unresolved items are items about which more information is required to

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ascettain whether they are acceptable items, items of noncompliance, or

deviations.

Unresolved items are discussed in Detail 9.c of this

inspection report.

15. Management Meetings

During the period of the inspection, licensee management was periodically

notified of the preliminary findings by the resident inspectors. A summary

was also provided at the conicusion of the inspection and prior to report

issuance.

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