IR 05000271/1985036

Insp Rept 50-271/85-36 on 851021-1125.Violation Noted: Failure to Complete Two Quarterly Calibrs of Refueling Zone Area Radiation Monitors

ML20137B068
Person / Time
Site:	Vermont Yankee
Issue date:	01/03/1986
From:	Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137B044	List: IR 05000271/1985036 ML20137B041 ML20137B047
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-3.D.3.4, TASK-TM 50-271-85-36, NUDOCS 8601150041
Download: ML20137B068 (15)

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U. S. NUCLEAR REGULATORY COMISSION '!

i- REGION'I i- Report'No. 85-36 -

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i h Docket N License No. OPR-28

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- Licensee: Vermont Yankee Nuclear Power Corporation  :

RD 5, Box 169, Ferry Road

Brattleboro, Vermont 05301

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i Facility Name: ' Vermont Yankee Nuclear Power Station

! Inspection At: Vernon, Vermont t

Inspection Conducted

October 21 - November 25,'1985 l

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Inspectors: Williara J. Raymond, Senior Resident Inspector  !

Thomas B. Silko, Resident Inspector i

Glenn.W. Meyer, Project Engineer

i Approved by: 1Tomas).Dragoun,RadiationSpecialist 3.859 h[  !

j E. E. TMpp, Chief  :

! Reactor Projects Section 3A, Projects Branch 3 l

1 Inspection Summary: Inspection on 0ctober 21 - November 25, 1985- I

! (Report No. 50-271/85-36)  ;

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Areas Inspected: -Routine, unannounced inspection on~ day. time and backshifts by-

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the resident and region-based inspectors of: actions en previous inspection find- t

} ings; plant shutdown operations, including recirculation ~ system decontamination I

activities; plant physical security; implementation of the interim Peer Inspection i f Program; followup of events; replacement of the reactor mode switch; control room

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! habitability system design and performance;' shift staffing; implementation of the  !

L new symptom oriented emergency operating procedures; review of Licensee Event Re- i

, ports 85-11 and 85-12; ~ and, the control of material issued for safety related' main-tenance. The inspection involved 189 hour0.00219 days <br />0.0525 hours <br />3.125e-4 weeks <br />7.19145e-5 months <br /> i r

l Results: No violations were identified in 10 of.11 areas inspected. One apparent 1 violation of Technical Specification requirements was identified concerning~the j l failure'to complete two quarterly calibrations ~of the refueling zone area radiation l

! monitors in accordance with OP 4511 requirements (Section 5.1). Reviews of. outage-  !

operational and maintenance activities identified no conditions adverse to safet i Further licensee reviews are needed -to verify that design features and procedures l which assure control room habitability are consistent with the~ assumptions ~in the i safety analysis (Section 6.0). Further licensee action is required to evaluate  !

2 the prior use of commercial grade material in safety related systems, and to up--  !

grade controls for future replacement of safety related materials (Section 11). l

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DETAILS 1. Persons Contacted Interviews and' discussions were conducted with members of the licensee staff and management during the report period.to obtain information pertinent to

- the areas inspected. Inspection findings were discussed periodically with the management and supervisory personnel listed belo Mr. J. Babbitt, Security Supervisor Mr. P. Donnelly, Maintenance Superintendent Mr.- J. Pelletier, Plant Manager Mr. B. Leach, Chemistry and Health Physics Supervisor A meeting was held with the Vermont State Nuclear Engineer on November 11, 1985 in the NRC Resident Office to discuss NRC inspection of outage activities and recent events. The following items were also discussed: the NRC enforce-

ment action for the physical security event of September 20, 1985; the prior NRC discussions / notifications with the licensee on high radiation area proce-

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dures, as related to the enforcement conference for the TIP room exposure on

August 9, 1985; the status of NRC actions related to the identification of

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radioactive material in the North owner controlled area; the NRC actions re-garding written notifications to Vermont State following enforcement confer-ences with the licensee; and, the control of grinding operations on the new piping in the recirculation system. A joint tour was conducted of the re-circulation project work areas to observe activities in progress to begin cutting and removal of the recirculation system. No inadequate conditions were identified during the tour. The meeting and tour were beneficial for the review of items of mutual interes . Plant Status The plant remained shutdown throughout the inspection period for replacement of recirculation system piping. Significant milestones achieved during this-

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period included completion of recirculation, RHR, and RWCU decontaminatio Recirculation pipe cutting ~and removal was initiate . Status of Previous Inspection Findings 3.1 (Closed) Unresolved Item 85-10-05: Inspection of Refueling Bellows Sea The Yankee Atomic Electric Corporation (YAEC) analysis which reviewed the concerns of IE Bulletin 84-03, Refueling Cavity Water Seals, recom-

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mended that the plant insoect the stainless steel refueling bellows seal during the next refueling outage. Subsequent evaluation by YAEC deter-mined that the inspection would be difficult due to welded guard plates and would involve significant doses. Accordingly, YAEC determined that bellows inspection was not appropriate due to'the difficulty and doses of-the inspection, the lack of susceptibility to IGSCC in the bellows, and the existence of leakage detection instruments. The inspector re-viewed YAEC Report No.1493,. Evaluation of Potential Failures of Spent '

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_Fue1LPool Storage System," dated June'18,~1985, and YAEC VYS 95/85 dated August 22, 1985, which presented the!above evaluation. The inspecto '

E had no question 'This' item is close .2 -(Closed)LViolation 84-05-02: Valve Lineup Controls. A violation was

: issued for the revision of a system's intended mode.of operation via- l

, a valve. lineup ~ exception without proper. review. .The licensee's sup- i plemental response letter, FVY 84-142 dated December 4,.1984,1was

reviewed in-Inspection Report 85-26 and was found acceptable. The-

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inspector: reviewed revised procedure, AP 0155, Revision 9, which in-cludes a_ t.ineup-Deviation (LD) Form to provide control of frequently:  !

changed valve positions and to institute a second SRO review of line- ~ l i up changes to technical specification referenced _ systems to prevent  !

i system operation outside of the system's design basis. The inspector- 1 found the procedure revision to'be acceptabl ~

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The inspector-interviewed two staff ' supervisors to assure that they  :

understood the~ revised procedure and reviewed the Current System-  !

!  : Lineup-Books to verify that the LDs had been properly implemented.

The inspector found them.to be acceptable. This item is close .3 (Closed) Unresolved Item 83-17-06: . Technical Specification Correc- l tive Update. .The inspector' reviewed Amendment 90 to License DPR-28  ;

, and the associated NRC Staff Safety Evaluation dated October 9, 198 i

Amendment 90 changed Technical. Specification-Table 3.2.2 (page 41) to j j revise the acceptable setpoint for the low condenser' vacuum trip from >

< "12 inches to Hg absolute" to "12 inches of Hg absolute". This item i is' closed.

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3.4 .(0 pen) Unresolved Item 83-17-10: Service Water System Safety Evalua-  !

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tion. The' inspector reviewed the licensee's safety evaluation as  :

. documented.in a.May 29, 1985 memo to the Operations Superintendent  !

regarding operation with the service water system cross tied with the  !

fire water system. The~ licensee concluded.that safe shutdown and

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! j i cooldown of the plant was assured during operations with the service  !

water system tied to the fire water system through valve SW-8. Even  !

if a complete loss of service water occurs, safe shutdown is assured

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' j through the availability of the Alternate Cooling Tower system. The j evaluation identified no safety disincentives to the proposed infre- [

quent, temporary-operational mode'that would~ allow cross connecting

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the systems, depending on the needs and availability of each syste !

, The inspector had no further question regarding the-itcensee's evalu- -

ation. The licensee's justification for the proposed operational

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F The inspector noted that revision 12 of OP 2186 addressed fire water - ,

system operation with SW-8 open. In a memorandum dated June 3,1985, i

[ the Operations Superintendent directed that changes be made to thr  !

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service water system operating procedure, OP 2181 revision 14, to reflect the operational mode. Based on a discussion with the Operations Engineer, the inspector noted that information had been-added to the OP 2181 change file to incorporate the required changes during the next procedure revision. The inspector stated that the changes to OP 2181 should be inccrporated prior to subsequent opera-tion.in the proposed mode. This item will remain open pending com-pletion of the proposed changes to 07 2181 and subsequent review by the NR .5 (Closed) Violation 85-08-04: Fire System Surveillance Procedur The inspector noted that OP 4020 had been changed in revision 11 dat-ed April 25, 1985 to correct the discrepant valve number. Page 2 of Section P correctly ide.itified the North torus standpipe isolation valve as FP-302. This item is close .6 (Closed) Violation 85-08-01: Procedure Revisions Following Modifica-tions. The licensee's response to' this item stated that plant proce-dures would be changed oy July 1,1985 to require that surveillance procedures affected by a design change be revised and issued prior to turnover of the system. The inspector verified that the appropriate changes were incorporated in revision 9 of OP 6064, revision 10 of OP 6003 and revision 10 of OP 600 Revision 10 of OP 6001 was satis-factory as written and no further changes were required as a result of this violation. The inspector noted further that the appropriate plant personnel were instructed regarding their responsibilities for complete design change descriptions and timely procedure revision This item is close ~3. 7 (Closed) Unresolved Item 85-10-04: Operator Training on New Emergen-cy Procedures. The licensed operators and shift engineers received additional simulator training on the new symptom orientated emergency operating procedures. The licensee reviewed the training effective-ness and the operator's acceptance of using the new procedures. NRC review of the operator's acceptance of the new procedures in dis-cussed further in section 10.0 below. This item is close . Inspection Tours Plant tours were conducted routinely during the inspection period to ob-serve activities in progress and verify compliance with regulatory and administrative requirements. Tours of accessible plant areas included the Control Room Building, Reactor Building, Diesel Rooms, Control Point Areas, the Intake Structure, the Drywell and the grounds within the Protected Area. Control room staffing was reviewed for conformance with the requirements of the Technical Specifications and AP 0036, Shift Staffin Shift staffing is discussed further in paragraph 7.0 below. Inspection reviews and findings completed during the tours were as described below, i

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4.1 The operational status of systems required to be operable to support the present plant configuration was reviewed by direct observation of control room instrumentation. Control room panels and operating logs

were reviewed for indications of operational problems. Licensed per-sonnel were interviewed regarding existing plant conditions and the status of outage activities. Control-board alarms were reviewed with

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licensed personnel as to cause and corrective actions being taken, where applicable. Anomalous conditions were reviewed furthe .2 Selected aspects of plant physical security were reviewed during reg-ular and backshift hours to verify that controls were in accordance with the security plan and approved procedures. This review included the following security measures: guard staffing; verification of physical barrier integrity in the protected and vital areas; verifi-cation that isolation zones were maintained; and implementation of access controls, including identification, authorization, badging, escorting, personnel and vehicle searches. No inadequacies were identifie The inspector reviewed the long term actions taken in response to a security event on 9/20/85 concerning the unauthorized entry into the protected area by a contractor. The inspector attended the exit meet-

_ ing by the Operational Quality Assurance (0QA) group on November 7, 1985 and participated in a conference call between the licensee and NRC Region I staff on November 12, 1985 to discuss and review the re-

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sults of the 0QA audit. The 0QA audit was completed to review the completeness and effectiveness of the licensee corrective actions taken in response to the event, and to review the control of deliveries to the site for compliance with the requirements of 10 CFR 73.55(d)(1).

NRC staff concerns regarding the control of deliveries were discussed during the November 12, 1985 conference call. The licensee subsequently reviewed the NRC concerns and concluded that the provisions of 10 CFR 73.55(d)(1) do not apply to the area of interest since it is not a !

point of site access. The NRC staff' accepted the licensee's position '

. for the present time, based on other measures in place to control de-liveries. Additionally, the licensee proposed and implemented further measures to secure the delivery area. The inspector reviewed the ad-ditional measures and found them completed as committed by the license The inspector had no further commants on this at the present time. This item will be reviewed further on a subsequent inspection (IFI 85-36-01).

4.3 Shift logs and operating records were reviewed to determine the sta-tus of the plant and changes in operational conditions since the last log review, and to verify that: (1) Technical Specification 3.13 limits were met on 11/4/85 when the diesel fire pump was taken out of service for maintenance; (2) log entries involving abnormal opera-tional conditions provided sufficient detail to communicate equipment status, correction, and restoration; and, (3) potential reportable

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occurrences'were filed-as'l'icensee event reports when required. No

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. inadequacies were identifie The licensee made a notification to the HQ Outy Officer via the ENS on 10/24/85 regarding a non-radiological : incident at~ the site involving asbestos.. The licensee reported that while rigging a turbine cover on_10/23/85,.some asbestos insulation became damaged, broke loose from

the casingi and became'_ airborne. Contractor personnel continued work

activities until 10/24/85 when' licensee nanagement became aware of the

' incident'and shut down work activities on the turbine deck and other-

places'in-the' turbine building potentially affected by asbestos con-

.taminationi The inspector did not review the licensee's response to-the event,-but did follow licensee actions to isolate, contain and.-

control. the' asbestos, decontaminate and~to regain' access to areas

'affected by.the incident. The inspector had no question regarding the

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licensee's' action .4 Plant housekeeping condition , including general cleanliness and storage of materials to prevent fire hazards were observed in all areas toured for conformance with AP 0042, Plant Fire Prevention, Jnd AP 6024, Plant-Housekeeping. No inadequacies were identifie .5 Radiation controls established by the licensee, including radiologi -

cal . surveys, condition of access control-barriers, and pesting within the radiation controlled area were observed ~for conformance with the

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requirements of 10 CFR 20 and AP 0503. No inadequacies were identifie . Recirculation' System Decontamination Activities The licensee completed a chemical decontamination of the RWCU'and recircu-

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11ation piping prior to removal. Due'to a partially successful chemical

, decontamination of the recirculation piping, the licensee decided to first vibrate,.and then hydrolaze the pipe to obtain acceptable decontamination

' factors (DF). .After hydrolazing the Recirculation system piping, an aver-age DF of.7 was obtained on contact with thel piping,'and.3.5 in the drywell general areas. A minimum drywell DF_of 2.5 was.needed to' complete

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- the recirculation pipe replacement project in less than 2000 man-Rems. An !

average contact DF of 11 was obtained on the reactor water cleanup system l

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following a chemical deco The inspector reviewed the licensee's administrative control of the chemi-ca' decontamination process under plant procedure OP 1123, Preparation / Control of Reactor Vessel Level and Ventilation for Decontam-ination and Recirculation Piping Replacement, and contractor procedure, DP.-2167-003, 0perating Procedure for the Spray Decontamination of:the:Re-circulation System. The inspector attended licensee daily status meetings on decontamination progress and inspected procedural compliance and radio-

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71ogical conditions et the' temporary decontamination building and in the 6 drywell . The inspector found the administrative control of decontamina- *

tion acceptabl b . Review of Outage Activities b~ 'The inspector attended daily outage meetings,' discussed' outage progress p

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with various plant personnel, and conducted frequent tours of the drywell'

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to; follow'the: licensee's activities. Significant milestones achieved by L- the licensee include completion of recirculation, RHR and RWCU decontami-nation, and initiation 'of recirculation pipe cutting and removal. Signif-icant events that warranted further review are discussed belo l

'61. Electrical problems with the. West refuel floor zone radiation monitor j

- (17-453A) caused ~ spurious high radiation signals and inadvertent iso- '

i lation of the Reactor Building ventilation system on 10/8, 10/19~and *

. 10/20/85; .The licensee verified that the actuations were not caused

by adverse radiological conditions on the refueling floor and reset.

i-the isolations. The' secondary containment isolation and standby gas treatment systems responded properly to the inadvertent actuation .

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-The inspector followed the licensee's actions to investigate and cor-

{ rect the channel problems, which were found to be caused by a faulty

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g, detector. - No inadequacies were identified regarding the licensee's *

actions to correct the cause of the spurious-safeguard actuation <

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!~ The licensee replaced the detector for radiation channel 17-453A and i used the normal surveillance procedure to complete a post repair cal- -

! ibration of the channel prior to returning-it to an operable statu '

During a review of OP 4511 '.' Source Calibration of Process Radiation

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Monitoring System" and associated-test sheets on 0ctober-28, 1985, ,

the inspector determined that Chemistry & Health Physics Technicians  :

l were not completing the' calibration per the proceant r

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l OP 4511 required .that the East and West refueling floor radiation  ;

! monitors-be calibrated by testing them with a source of known strength t

!- s over three of the four decades on the channel' operating range. The .

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i procedure further requires that the trip setpoint~be noted and verified ~

to be within the the range of 35 to 75 mR/hr. - Plant technical.'spect -

- fication~ require that the channel trip setpoint be set at less than -

or' equal .to 100 mR/hr. Cuntrary to the above procedural requirements, ,

on October 28,1985 the trip setpoint for.. the East and West Refueling l monitors was not ' achieved or logged during' calibration due. to a reduced i source strength that:allcwed calibration over only two of the four de- l

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. cades on:the_ operating range. The inspector noted that the same de- t h ficiency in completing the test occurred on.10/21/85 for _ testing fol-  ;

[ lowing replacement of the West monitor, and during the' previous '

quarterly calibration of both monitors on July,~26, 1985. The inspec--

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tor noted further that data sheet VYOPF-4511.08~for the. quarterly .i

calibration was inadequate.in that.it did not have a provision for re- i i cording the. trip 'setpoint or verifying the acceptance criteria were met, as specified by procedure steps (System 5)'A.6 and A.1 _

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The inspector reviewed the licensee's test program for the refueling

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zone monitors to determine whether the protection channel were veri-fled operable as required by the technical specifications. The in- ;

spector noted that channel operability was adequately demonstrated based on source calibration of the channels at three points over two decades, combined with monthly functional tests that were completed satisfactorily in accordance with OP 4326. The monthly functional tests verified the trip setpoints were adequate. Additionally, fol- t lowing di.scussion of this item with the inspector, the licensee took i actions to calibrate the monitors 'using a hand held source to verify the trip setpoint was adequately reached. The inspector had no fur-ther questions regarding channel operabilit .'

The licensee uses a " calibrator" which houses a calibrated source to generate the radiation fields needed to test the monitors. The

! licensee realized earlier this year that the source was decaying to unacceptable levels'and a new calibrator was ordered. The calibrator was received on site but returned to the supplier (General Electric), i

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lbecause the appropriate documents verifying calibration traceable to the National Bureau of Standards were not provided. The licensee continued to use the old source to perform the quarterly calibra-

, tions, but failed during the past two quarters to reach the trip ,

setpoints due to the decay in source strength to approximately 75 '

mR/hr. ~ This failure was disregarded by the technicians performing the calibration or by their supervisors who approved the calibration data sheets. The inspector met with the Plant Health Physicist and t the Chemistry & Health Physics Supervisor on October 30, 1985 to dis- l cuss his concerns regarding the failure of plant personnel to initiate the appropriate administrative actions when the channel calibration could not be performed in accordance with the procedure requirement .

The inspector reviewed the licensee's actions to verify that there l were no additional radiation channels that were improperly calibrat-ed. The licensee contacted a supplier of a new source to expedite its l

. shipmen Additionally, a Department Instruction was written and -

included with OP 4511 to correct the noted problem !

The failure to complete the last two quarterly calibrations in accor-dance with OP 4511 is contrary to Technical Specifications 6.5.A (VIO 50-271/85-36-02).

6.2 On November 12, 1985 the RHR Equipment Room Drain Sump (South Side)

overflowed during draining of the RHR Service Water system. The overflow was caused when plant workers placed herculite on the sump pumps float switch which prevented the pump actuation circuitry from sensing the increasing water level in the sump. The water rose to just above floor level and spread over an area of approximately 20 square feet. Upon noticing the overflow, a worker in the area re-moved the improperly positioned herculite and the pump actuated to empty the sum I

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Radiation levels in the area'following the event were negligible and contamination levels reached as high as 100K dpm. Subsequent cleanup activities were successful in decontaminating the floo None of the equipment in the area was affected by the event and no personnel contamination resulted from the overflow. Contractors working in the area were informed of the event to prevent its recur-rence. The inspector found no inadequacie .3 On November 15, 1985 the licersee started cutting and removal of the reactor recirculation pipe. The inspector observed the first cut activities and plasma-arc cut preparations. The inspector verified '

rigging and suspension of the pipes to be cut, inspected general !

.housekeepina conditions, verified good HP practices and coverage; reviewed the special fire protection controls established for plasma-arc cutting; and, verified compliance with fire protection

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requiremer.ts. No inadequacies were identifie .4 Reactor Mode Switch Replacement The licensee began actions to replace the reactor mode switch during the inspection period. The replacement was completed in accordance with MR 85-1635 and a special installation and test (I&T) procedure that was written for the GE SB-1 switch. The I&T procedure was pre-viously reviewed by the NRC staff and found acceptable, as documented ,

in the NRC Inspection Report 50-271/85-34. The first phase of the j I&T procedure was in progress during this inspection which consisted of verifying, for the new switch, each contact state for every end ;

point and intermediate position on the 4-stack, ganged switc t The contact states were verified using a volt-ohm meter to be as !

, specified by vendor drawings. All contacts tested satisfactorily except for 8 settings in procedure steps 67, 69, 83, 85, 99, 101, 115 and 11 In each of these steps, the contacts were found to be open :

in the intermediate position between RUN and STARTUP instead of closed as specified by the procedure and vendor drawing. The 8 con-tacts are all related to the APRM bypass function that removes the 120% hi-hi APRM trip as the reactor mode switch is moved from the RUN to the STARTUP-HOT STANDBY position. The plant technical specifica-tions. require that this trip be operable only when the reactor mode switch is in the RUN position, and the APRM reduced hi-hi flux trip at 15% is required to be operable with the mode switch in the REFUEL and STARTUP positions. The licensee denonstrated to the inspector, based on a review of vendor RPS drawings 5920-2119 and 5920-2120, that the new mode switch in the as found condition would meet the RPS functional requirements. There is no known reason why the 8 contacts should be closed (APRM 120% trip function operable) when the mode switch is in the intermediate position between RUN and STARTUP.

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, Licensee review of-this-item was still in progress at the conclusion

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of_the inspection period. The-licensee' planned to continue testing-

per the I&T procedure to! remove the old mode switch and to complete-the contact checks on itLfor comparison lwith the_ new switch. The

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vendor was also contacted for assistance. The licensee's actions and-dispositioning of this item will:be followed on a _ subsequent inspec-

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tion. This. item is open pending' completion of.the licensee's evalua- -

. tion of the acceptability of the replacement. mode switch and subsequent review by the NRC (IFI 85-36-03).

L6.5 _ During rigging activities to_ remove the ~A-2A section. of recirculation

, ' piping from the drywell at 9:10 pm on November 19,1985, herculite that was taped around the end of the pipe as an end cap was torn from the pipe, allowing internal dust-to spill onto the gating at the-252

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ft level and down to the 238 ft level. A cloud of dust created an- r

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airborne radiation area of 1.0X10-7 uCi/cc in the immediate vicinit of the' spill. Drywell work activities were shut down by duty health physics personnel at 9:20 pm following confirmation of the high air-1 borne levels. Four workers in the area were contaminated. Two of

the workers were.successfully decontaminated. The other two workers l were released from the site on November 20,.1985 following decon ac- ,

,- tivities with some residual skin contamination. Whole body counts 4 following showers showed 2.34% and 5.9% maximum permissible organ

burden for Co-60. Subs'equent whole body counts for the two workers

on November 22, 1985 showed no detectable activity above normal back-

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ground levels and thus, there was no uptake of radioactive material f

by either worker.

Drywell decontamination efforts were effective in returning dose and i

contamination levels to normal. No dose limits were reached which i required reporting or further investigation.

3-The inspector reviewed the actions taken by health physics personnel L

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in the drywell during and following the. incident. The response ac- t j tions were appropriate to identify the adverse radiological condi-tions 'and to protect workers in the drywell. As a result of this

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, incident the licensee modified the temporary end caps installed on . !

the piping prior to removal from the drywell. .The inspector discussed

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! the modification with plant personnel.and inspected pipe being pre-pared for removal from the drywell with end caps installed. The in-i spector has no further. question.s.

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Control Room Habitability Assessment s r

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The licensee's program to ensure that- the control room will remain habit--

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able during certain postulated accidents was reviewed against criteria j

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Vermont Yankee Final Safety Analysis Report

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Regulatory Guides 1.78 and 1.95

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NUREG-0737, " Post-TMI Requirements" Item III.D.3.44

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NRC Standard Review Plan The licenst a's performance relative to these criteria was determined by discussions with selected engineering personnel, a review of documents, inspection of the control room ventilation system, and NRC measurement of flows in portions of this syste Within the scope of this'raview, no violations were observe The licensee's strensth and weaknesses.were noted~as follows:

-Extensive steps have been taken to minimize inleakage of air into the con-trol room during the isolation mode of operation. These steps included taping and sealing holes in all duct work, use of soft rubber gaskets on the control' room doors, and effective dampers installed on the air in-

. takes. The inspector also noted that the operating procedures were par-ticularly clear and understandabl When a-radiological incident causes significant ground level releases of airborne radioactive material, the control room must be isolated using the manual isolation switch. However, manual operation does not automatically close the vents in the bathroom or kitchen attached to the control roo The licensee's safety evaluations appear to assume a complete isolation of the control room during radiological incidents. The licensee was request-ed to resolve the apparent inconsistency. (IFI 50-271/85-36-04).

The reactor operators were unaware that manual actuation causes only par-tial isolation of the control room and that the toxic gas monitor could be shifted to monitor the control room concentration rather than the air in-take during an accident. The licensee was requested to review the need for complete isolation using the manual switch and the need for this in-

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formation to be included in the appropriate plant procedures (IFI 50-271/85-36-05).

The inspector also noted that the chloride gas detector "setpoint" is giv-en as 1.5 ppm in the FSAR but is listed as 6 ppm or 7 ppm in the operating procedures. It is unclear if the "setpoint" causes an alarm or results in an automatic isolation signal in the control room makeup air gas monitor-ing system. The licensee was requested to clarify the setpoints for the chlorine gas detector and required action (s) when the setpoint is exceede (IFI 50-271/85-36-06).

These items will be reviewed in a future inspection.

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8. Shift Staffing The licensee reviewed the technical specifications and the shift staffing requirements for the present plant conditions trd concluded that, in the present operationa'. mode with the reactor completely defueled and no irra-diated fuel moves in progress, the minimum shift staffing by position ti-tle could be different than that specified by Technical Specification Table 6.1.1. The minimum shift-staffing by type of operator license would be maintained. Specifically, the minimum shift staff onsite could consist of one control room operator, one auxiliary . operator, and either the Shift '

Supervisor, or a Senior Reactor Operator designated as Shift Superviso The licensee's evaluation was summarized in a November 15, 1985 memorandum f.~om.the Operations Supervisor, along with instructions to administer the alternate staffing arrangements. The alternate staffing plan was imple-mented on November 18, 198 .

The inspector reviewed the licensee's evaluation and discussed the propos-al with the Operations Supervisor in advance of its implementation. The inspector reviewed the licensee's plans and identified no disagreement with the requirements in the technical specifications or 10 CFR 50.54(k),

54(1), 54(m)(1) and 54(m)(2). No inadequacies were identifie . Implementation of the Interim peer Inspection A special QC _ inspection group was set up for the I&C Department for outage related work. The inspector interviewed the I&C Supervisor and the as-signed QC inspectors to review the measures established to provide for interim implementation of the " peer" inspection program for outage activitie The I&C QC Group was established by hiring qualified contractor personnel with background in the related disciplines. Two inspectors were assigned to provide QC coverage for a minimum of 10% of all surveillances, mainte-nance requests,. installation and test procedure activities, and work under EQ files. More than 10% of the department activities were covered in practice and some special activities received full coverage (the actions to replace the reactor mode switch, for example). The inspectors received assignments and guidance from the I&C Engineer, who was also responsible for review and resolution of problems identified by the QC inspector This reporting line assured the QC inspectors would be independent from the personnel performing the work. The inspectors were also assigned re-

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sponsibility for the preimplementation rey;9w of special work procedures to assure they were technically accurate and in accord with vendor manuals '

and other applicable r9ference Resumes and training records were reviewed which showed snat each inspec-tor was certified to ANSI N45.2.6 for QC inspection. The QC inspectors also completed the VY indoctrination program for contractors to review the plant administrative procedures. The inspector noted that one contractor, who had most of his previous experience in the mechanical and NDE areas,

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-received additional training in the instrumentation and' control area. No L inadequacies were identified.regarding the qualifications and training of the QC inspectors.-lThe QC inspectors were interviewed during the perfor-

mance of routine dutiesand were found to-be knowledgeable of the QC pro-gram requirements, the technical aspects of.the activity in progress,.and

. the licensee's.' administrative controls. .

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!l The inspector reviewed work activities in progress and the QC inspection

for: - GE HFA relay- maintenance (5A-K288 per MR 85-2238 and QC Inspection Report I-0040); and,.the replacement of the S8-1 reactor mode switch (per MR 85.1634 and QC_ Inspection Report I-0028). Licensee actions regarding j' the' mode switch. replacement are discussed further in section 5.4 abov 'The inspector noted that the QC inspection reports contained detailed in-1 -

spection and acceptance criteria that were appropriate for assuring the *

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correct performance of_the activities in progress. Hold points were in-  ;

i corporated at appropriate points in the work process. No inadequacies '

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I ' Implementation of the interim QC-inspection program will be' reviewed fur-

} ther on subsequent' routine inspections.

i 10. Review of Licensee Event Reports (LERs)

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j I 'The licensee event reports. listed below were reviewed in the NRC Resident '

{ and Regional Offices. Each report was reviewed to verify: the event was i clearly described and its safety significance was identified; the event ,

cause was identified and corrective actions taken (or planned) were appro-

. priate; and, the report satisfied the requirements of 10 CFR 50.73. The l inspector had no further questions on.the reports, except as noted belo ,

I -- LER 85-12, Control Room Habitability System Actuation, 11/26/85 l

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LER 85-11, PCIS Group III. Isolation, 11/6/85

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10.1 LER 85-11 described the inad ertent PCIS Group III actuations that  !

occurred on 10/8, 10/19 and 10/20/85 due-to spurious signals from the

West Refuel Floor Zone radiation monitor. The'LER. reported that the  !

i possibility of. equipment problems was being evaluated as the cause of 'i

.the actuations. The inspector noted that the licensee subsequently  ;

j -determined that the channel detector caused the actuations and it was i

replaced. The' inspector stated that the licensee should: submit a  !

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supplement to LER 85-11 to list the cause of the events (equipment  ;

failure), the pertinent codes.for NRC Form 366 and, the corrective  !

!- actions taken to resolve the problem. This item is open pending sub- l

! mittal of the LER supplement and subsequent review by the NRC (IFI l 85-36-07).  !

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1 Emer'gency Operating Procedures (EOPs)

The-licensee's original plan to implement the new symptom oriented emer-

gency procedures (EOPs) in mid.1985.was delayed due to lack of full'sup-

, . port from the licensed operators. ~ The operators' concerns included questions on the adequacy of the E0Ps and ' anxiety about having sufficient i familiarity with the procedures to implement them. Additional simulator

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training was provided to all' operators, and the E0Ps were subsequently implemented on November 4, 1985.

. . The inspector reviewed operator attitudes on the E0Ps to' assess whether ,

the' operators were confident of-their ability to implement the procedure '

The inspector interviewed the Operations Supervisor concerning the process used to train the operators and assess their ability to implement the pro- .

cedures. The 1.nspector reviewed the critique sheets from the individual

operators following the additional: simulator training and found the opera- i tors.to be in agreement with the planned E0P implementation. Also, the i . inspector interviewed ten operators on threa shifts to verify that the i L operators supported the E0P implementation and found the operators to be very supportive of the change. The inspector found the implementation of j the E0Ps to be acceptabl !

! 12. Surveillance of Material Issued For Safety Related Maintenance [

The licensee-informed the inspector on November 8, 1985 of the results of i- a QA audit of materials issued for safety related maintenance. An appar- '!

' ent~ violation of materials control procedures was identified during in- I spection 50-271/85-22-and the licensee'.s responses and actions for that .

!_ violation are documented in letter FVY 85-77 dated 8/20/85. The 0QA audit ;

} was completed as a followup to an additional commitment made to the NRC t staff during inspection 50-271/85-2 ~

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' The 0QA audit reviewed the issuance of material for maintenance activities ;

during the period from July 1,1984 to December 31, 1984. The audit iden- -l 1 tified the material issue slips for all . safety related maintenance re-

quests completed during the. subject period. The material issue slips were ,

! -then traced to the corresponding purchase orders for the subject material !

. to establish traceability of.QC documentation for the mcterial. All main-

.tenance requests for which no purchase order was specified, or.for which

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! ' shop stock was the indicated source of the material, were deemed question-able and required further evaluation since traceability may have been L lost. The results of this review are summarized below.

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Of 1323 maintenance requests written during the subject period, 274 were

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! -designated as safety related for which work had been completed. Material was issued /used for 155 of the 274 maintenance requests. 0QA review'of> !

! the 155 MRs showed that 60 involved issuance of commercial grade or other- '

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wise non-traceable' material, and 27 involved material issued from shop ,

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stock (for a . total 'of 87). -l

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The licensee provided for inspector review a listing of the maintenance requests with non-traceable purchase specifications, along with a listing of MRs with a description of material issued from shop stock. The inspec-tor noted that the material issued from shop stock consisted of refur-bished material, gaskets, fuses and other consumable materials. The inspector noted further that one of the discrepancies concerned the use of commercial grade differential relays in the diesel generator protection circuits, which had previously been evaluated by licensee engineering as acceptable for use. The licensee stated that a noncomformance report would be written to disposition the finding This situation occurred in part because: commercial grade replacement parts were ordered for non-safety equipment that has since been reclassi-fied as safety related; and, because the original order or reorders for the materials lacked the safety application identification and reorders used the previous purchase order information. Plant procedures now require that material issue slips be labeled safety related for safety related work, which will assure that safety related material will be issued when appropriat Nonconformance report (NCR) 85-44 was drafted to disposition the items, which would include an evaluation of the material for continued use. The NCR will also include instructions on how to complete the evaluation, and would identify what additional actions would be required to prevent recur-rence of the problem. The inspector reviewed the licensee's proposed ac-tions to disposition the questionable items and identified no discrepancies. The inspector stated that the detailed plans to evaluate the discrepancies will be . reviewed by the NRC staff pending licensee ap-proval of NCR 85-44. The licensee stated that the full scope and schedule to complete the evaluations had yet to be established, but the material would be satisfactorily dispositioned prior to subsequent plant operatio This item is unresolved pending completion of the licensee actions de-scribed above, and subsequent review by the NRC staff (UNR 85-36-08).

13. Management Meetings Preliminary inspection findings were discussed with licensee management periodically during the inspection. A summary of findings for the report period was also discussed at the conclusion of the inspection and prior to report issuanc ,

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