IR 05000029/1985015

Insp Rept 50-029/85-15 on 850730-0919.No Violation Noted. Major Areas Inspected:Operational Safety Verification Reviews,Radiological Controls,Plant Events,Maint, Surveillance & Emergency Preparedness Activities

ML20198B966
Person / Time
Site:	Yankee Rowe
Issue date:	10/31/1985
From:	Eichenholz H, Elsasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20198B958	List: IR 05000029/1985015 ML20198B952
References
50-029-85-15, 50-29-85-15, NUDOCS 8511070384
Download: ML20198B966 (18)

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U.S. NUCLEAR REGULATORY COMMISSION Region I Report No'. 50-29/85-15 Docket N Licensee N OPR-3 Licensee: Yankee Atomic Electric Company 1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Yankee Nuclear Power Station Inspection at: Rowe, Massachusetts Inspection Conducted: July 30 - September 19, 1985 Inspector: [^

- @W N/k/g 5 g .H. Eichenholz, Synior ljesident Inspector

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1. 1. /o/h 3 T. Elsasser, ectisti Chief

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Reactor Proj ection 3C Inspection Summary: Inspection on July 30, 1985 - September 19, 1985 (Report No. 50-29/85-15)

Areas Inspected: Routine onsite regular and backshift inspection by the resident inspector (137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br />). Areas inspected included: Review of licensee action on previous findings, operational safety verification reviews, review of radiological controls, review of plant events, maintenance observations, surveillance observations, review of emergency preparedness activities, Plant Information Report reviews, onsite review committee, and licensee action on NUREG-066 Results: In this inspection period, no violations were identified. Licensee

performance in the areas of Emergency Preparedness and onsite safety committee i- safety evaluation review were considered notable licensee strengths (Sections 9 and 11). Areas needing increased licensee attention involve fire protection

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and prevention activities (Section 4), and communications between Maintenance and Operations Departments during plant maintenance (Section 7).

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PDR ADOCK 05000029 G PDR

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. 2 Details 1. Persons Contacted

,P,lant Operations B. Drawbridge, Assistant Plant Superintendent T. Hendersoa, Technical Director N. St. Laurent, Plant Superintendent The inspector also interviewed other licensee employees during the inspection, including members of the Operations, Radiation Protection, Chemistry, Instrument and Control, Maintenance, Reactor Engineering, Security, Training, Technical Services, and General Office Staff . Summary of Facility Activities At the start of the inspection period on July 30, 1985 the plant was operating at full power, and continued to do so until entering Cycle XVII end of cycle coast down operations on August 3,1985. Plant operations continued to be stable until August 17, 1985 when a load reduction to 70%

power was initiated to facilitate scheduled turbine throttle valve and main steam line non-return valve testing. During the testing of the turbine throttle valves, a problem with the No. 3 control valve occurred and resulted in exceeding the average cold leg temperature Technical Specification (TS) limit. This event is discussed in Section 6 of the report. A load increase was initiated on August 17, 1985 and maximum power was achieved on August 18, 198 For the remainder of the inspection period, the plant continued normal coastdown operations, with the reactor power limited to 77% at the end of the inspection period. Throughout the inspection period, the licensee continued to maintain the core in a rodded condition (i.e., control rod Group C inserted below 83 inches withdrawn) to maintain licensee compli-ance with 10 CFR 50.4 During this inspection period two new milestones involving plant operation were achieved by the licensee. The first occurred on August 19, 1985 and marked the 25th anniversary of initial criticality. The second milestone occurred on September 1, 1985 when the previous operating record of 289 continuous days of operation was exceede At the completion of this inspection period, the plant has been in continuous operation for 307 day . Licensee Action on Previous Inspection Findings (Closed) Inspector Follow Item (83-15-01) Licensee to facilitate inspection be General Electric Field Service Personnel on two AK-25 breakers with EC-1 trip devices. The breakers involved are the 480 VAC supply breakers for Emergency Motor Control Center (EMCC) Nos. 3 and .

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This item was last reviewed in Inspection Report 50-29/84-07. Closure of this item was pending the licensee sending the EMCC-3 breaker to the factory for optimizing its performance in light of excessive movement of the trip arm on the EC-1 trip devic The inspector reviewed the documentation associated with Job Order Package No.84-300 and Safety Related MR 84-991, both issued on July 13, 1983. On August 7, 8, and 9, 1984, an inspection and repair of the EMCC-3 breaker was performed at the G.E. Farmington, Conn. facility. A licensee QA representative witnessed vendor activity. Following the return of the breaker to the plant, post maintenance testing was implemented in accordance with procedure OP-4506, Rev. 7, Inspection of ECCS Circuit Breaker. The breaker was installed and returned to service on August 11, 198 Since the licensee's efforts have resolved the concern for excessive trip arm movement on the breaker's installed EC-1 trip devices this item is considered close (Closed) Inspector Follow Item (50-29/84-20-02). Develop a procedure for use of large radiation sources. Procedure DP-8108, Rev. O, Control of Calibration Sources was issued by the licensee in August, 1985, and establishes guidelines for handling and using calibration sources that are greater than 5 mr/hr at 18 inches. These guidelines provide for the proper defining, posting, barricading and controlling of access to radiation fields generated by the handling and use of those sources. Use of this procedure should result in reduced exposure to handlers and other personnel in the immediate area where the source is being use (0 pen) Inspector Follow Item (50-29/84-20-09) Foilow Dose Equivalent Iodine (DEI) levels due to apparent fuel claddirg failure in core XVI During the inspection period fluctuations in DEI were noted to vary between 5.2% to 9.1% of the allowable TS limit. The licensee continues to maintain maximum bleed, purification, and charging flow rates (50 GPM) to maintain the steady state DEI levels at a minimu The inspector attended a September 5, 1985 presentation by a representative of Brown Boveri Reaktor GMBH (BBR) on it's capabilities for locating failed fuel rods in fuel assemblies. It is the licensee's intention to issue a contract to BBR for their services during the upcoming refueling outage to locate failed fuel rods. BBR utilizes an ultrasonic testing process in lieu of the traditional sipping and eddy current testing methods that locate questionable fuel bundles and the individual failed fuel rod BBR services of the kind to be used at the Yankee Nuclear Power Station were used successfully at a number of U.S. and foreign facilities to locate failed fuel rods.

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(Closed) Inspector Follow Item (50-29/84-23-01) Review and strengthen procedural controls relating to the use of high pressure compressed gas cylinders._In a memorandum from the plant's Health and Safety Supervisor to the inspector, dated August 1, 1985, the results of the licensee's review and actions related to use and storage of high pressure gas cyl'aders was documented. The licensee has determined that 1) current practices are in conformance with the appropriate NFPA, OSHA, and Compressed Gas Association Codes, 2) upgrading of storage facilities is warranted, and 3) appropriate practices will be covered at a future plant safety meeting with plant personne During the inspection period, the inspector observed the completion of upgrading work in the storage area outside the clean maintenance shop for oxygen and acetylene cylinders. Rcutine surveillances of the licensee's practices for high pressure gas cylinders are being performed by the Health and Safety Supervisor. Additional actions to resolve inspector concerns in this area have included the Maintenance Department's efforts to remove from various areas of the facility all high pressure gas cylinders that were being temporarily stored in place without an apparent need for their us (Closed) Inspector Follow Item (50-29/85-07-01) Resolve NRC concerns related to the Public Notification System (PNS). This item documented inspector concerns for the apparent lack of an adequate description of the PNS for plant operators and inadequacies in the procedures to notify governmental agencies when certain PNS equipment malfunctions occur. The licensee has issued OP-Memo 20-5, Rev. I which provides a description of the system, its operation, and the surveillance features associated with the system. In addition, the OP-Memo provides information on the nature of notifications to governmental agencies that are to take place should equipment malfunctions occu The inspector reviewed the licensee's corrective actions, determined that they were responsive to the NRC concerns, and considers this item close . Operational Safety Verification Reviews Daily Inspection During routine facility tours, the following were checked: manning, access control, adherence to procedures and LCO's, instrumentation, recorder' traces, protective systems, control rod positions, Containment temperature and pressure, control room annunciator, radiation monitors, radiation monitoring, emergency power source operability, control room and shift supervisor logs, tagout logs, and operating order l

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. 5 The inspector noted two annunciators on the T.A. panel in the control room with "Not Operating" stickers attached. According to the control room operator these annunciators were out of service as a result of Lif ted Lead Requests (LLR) No.85-108 and 113. The LLR numbers were referenced on '.he stickers. These lifted leads help maintain a " black-board". annunciator concept while modifications over an extended period of time occur. The practices of attempting to maintain a black-board condition for control room annunciators and referencing the "Not Operating" stickers to the appropriate Lifted Lead Request are noted as commendable licensee practice No deficiencies were identifie b. System Alignment Inspection Operating confirmation was made of selected piping system train Accessible valve positions and status were examined. Power supply and breaker alignment were checked. Visual inspections of major components were performed. Operability of instruments essential to system performance was assessed. The following systems were checked:

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Low Pressure and High Pressure Injection System Motor driven Emergency Feedwater Pump standby status verified during tour of the Primary Auxiliary Buildin Charging System verified during control room board status revie Emergency Diesel Generator (EDG) unit standby verified during tours of the EDG rooms and control room board status revie c. Biweekly and other Inspections During Plant tours, the inspector observed shift turnovers; compared boric acid tank samples and tank levels to the Technical Specification; and reviewed the use of radiation work permits and Health Physics procedures. Area radiation and air monitor use and operational status were reviewed. Verification of tagouts indicated the action was properly conducte s' _ , , ___

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. 6 The following inspector identified deficiencies were noted:

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On a tour of the Switchgear room on August 2, 1985, the inspector observed two 1cose reinforcing bar protruding from hardened cement at the top of the battery room wall This reinforcing bar was installed as part of EDCR 84-317, Masonry Wall Modifications Inside .the Turbine Building. The inspector brought the condition to the attention of the Maintenance Support Department cognizant enginee Following the licensee's investigation the inspector was informed that four additional reinforcing bar were identified as being loose. The inspector verified that corrective measures were implemented by the licensee prior

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to their proceeding with additional construction associated with the subject reinforcing ba As a result of a tour of the lower Primary Auxiliary Building (PAB) area on September 4, 1985, the inspector noted that all wall and door louvers installed in the lower north wall were propped open. The inspector brought the condition to the attention of control room personnel and questioned the appropriateness of the licensees actio Although Operations Department personnel could not readily provide an explanation as to the design basis of the

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louvers, immediate action was taken to place them in the closed position. The inspector requested the Operations Department to ascertain the intended function of the louvers and the appropriateness of blocking them open. The inspector further noted that neither plant procedures, operator training material nor the recently issued Final Safety Analysis Report acknowledge the existence or function of the louver Following the Operations Department review of.the item, the licensee issued Special Order 85-69, dated September 5, 1985 which informed plant operators that the louvers were installed to prevent PAB flooding of Motor Control Center 4 in the event of ruptured piping. Additionally, there was a stipulated concern about steam entering the PAB if a mainsteam or main feedwater line ruptures. The Special Order directed plant operators to not prop open or

o'therwise make inoperable the free opening and closing of the louver ________ _ - _ _ _ .

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. 7 The inspector concluded that the licensee's immediate corrective actions to close the louvers and disseminate functional requirements to the operators were appropriate and performed in a timely manner. However, the licensee should consider including the purpose (s) of the louvers in more appropriate. operational documents, including the FSA The inspector noted that the installation of the louvers was a licensee commitment to the NRC in its WYR 75-19 letter of February 14, 1975. Licensee letter FYR 85-71 dated June 28, 1985 to the NRC:NRR has committed to incorporate the safety evaluations of all design changes in the next revision to the FSAR scheduled for July 12, 198 The inspector had no further questions on this ite . Observations of Physical Security Checks were made to determine whether security conditions met regulatory requirements, the physical security plan, and approved procedures. Those checks included security staffing, protect 2d and vital area barriers, vehicle searches, and personnel identification, access control, badging, and compensatory measures when require With the exception of the following item, no discrepancies were noted in this area:

On July 30, 1985, the inspector observed one of the plant gates to be open with required compensatory measures being performe The inspector saw no activity in the vicinity of the gate and questioned the Security Officer on duty as to the necessity to maintain the gate in an open condition. The inspector learned that this was a standard practice for this gate when individuals are in a building outside the Protected Area and it involves

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personnel safety concern Inspector concerns pertaining to this item were discussed with the Security Supervisor and Assistant Plant Superintendent. They indicated that the practices would be reviewed with the contracted security organizatio . Fire Protection and Housekeeping The licensee continues to maintain a strong commitment to good housekeeping conditions in all areas of the plant. Significant construction activity in the Turbine Building associated with seismic upgrading has not significantly degraded overall building cleanliness condition e_ n

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During this inspection period the inspector observed the following deficiencies: .x ~

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The inspector reviewed licensee activities associated with the installation of Engineering Design Change Request (EDCR)84-317, Masonry Wall Modifications Inside the Turbine Building and Switchgear Room Jet Impingement Plat Following extensive modifications to the wall between the

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switchgear room and turbine building, fire damper G1 was .- ,

reinstalled. This damper, which is normally open for ventil-ation of the switchgear room, will automatically close either due to a fire external to the Switchgear room that melts the damper's thermal link or due to fire detection

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equipment within the switchgear room that activates the ^1 '

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switchgear room halon system and closes the damper. The control room log indicates that the fire barriers for the ,

switchgear room were restored to operable status cn August 23, 1985. At this time the licensee removed the posted continuous fire watsh from duty. This fire watch was imple- ,

mented due to the requirements of ?S 3c7.4.11, Penetration Fire Barriers.' , .g

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s Although portions of the wall and the fire damper were the modification, the licensee analyzed the removed switchgearduring'm roo halon system to be operable with the instal-lation of a steam / dust barrier enclosing this work are This is documented in the EDCR and negated the need for a one-hour fire watch patrol per TS 3.7.10.5. At the same .

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time, the battery room Nos. I and 2 were inoperable and had a'une-hour fire watch patrol in effect per TS 3.7.1 .~

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On August 27, 1985 theinspectorobservedthatfiredamser G1 was open and the dust barrier was removed. The. inspector questioned control room personnel on the status of the damper and was informed that it was operable. Following a detailed field inspection of the damper, the inspector determin d that the damper was not re-connectel'to the wiring associated"with the switchgear room halon system _

actuation circcit.' The inspector confirmed his finlings with the Plant's Fire Protection Coordinator (FPC).

Immediate corrective action by the Shift' Supervisor consisted of placing the damper in the closed positio This resulted in the switchgear room halon system being operabl ,

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. 9 For the period of August 23-27, 1985, the switchgear room halon system would not have been fully functional. With the licensee maintaining a one hour fire watch patrol for the battery room Nos. I and 2 halon system inopefability, they were in technical compliance with the applicable action statement for the switchgear room halon syste However, the inspector's concerns centered on the fact that operational personnel were not aware of the degraded system and compensatory measures were not specifically identified to mitigate the situation. The licensee's procedural controls, which utilized special one-time installation procedures were not effective in controlling the required compensatory measures for removing and restoring fire protection equipmen The_ inspector held a discussion with the plant's FPC who acknowledged the inspector's comments and concerns. On August 28, 1985 the FPC requested the Maintenance Support Department (MSD) Supervisor to consider the inclusion of specific criteria to be included in the one-time installation procedures prior te reducing or removing established compensatory measures for fire protection concerns. The MSD Supervisor issued a memorandum on September 10, 1985 to MSD Personnel delineating the procedural requirements to be contained in all one-time installation procedures ~ that require removing and restoring any portion of the fire detection and protection system from service in support of design change. The inspector concluded, that, the licensee's corrective actions were timely and fully responsive to the inspector's concerns, and had no further questions on this ite On September 5, 1985, the inspector reviewed licensee fire protection practices associated with hot work needed to install the jet impingement plate for the switchgear room wall per EDCR 84-317. A permit for the hotwork was issued to control the welding being performed. At 11:25 a.m. the inspector reviewed hotwork activity associated with the EDCR, with the inspector noting that a fire watch with portable extinguishing equipment was stationed in the work area. The inspector returned to the area at approximately 9 11:50 a.m., found that work had stopped due to a lunch break, and did not find the fire watch in the area. The licensee stipulates a requirement in procedure AP-5005, that, the fire watch will remain on the work site while work is performed and remain in the area for at least 30 minutes after the work is completed to check for smoldering fire <

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The inspector located and interviewed the assigned fire watch, who was a supervisor of the contractor performing the welding operations. The fire watch was not completely familiar with the requirement and initially indicated he was not informed of the requirement by the licensee. The Fire Watch Certification Form, APF 5005.4, is signed by the fire watch as part of their training that they are aware and understand the requirement The inspector relayed his findings and concerns to the cognizant Maintenance Support Department enginee Li-censee corrective actions included (1) removing the con-tractor fire watch from duty, and (2) retraining and recertification of the individual to perform fire watch dutie Inspector concerns relative to the licensee's performance involving fire protection and prevention have been documented in the most recent SALP Report, 50-29/85-9 Many of these concerns have been directly related to contractor work activities. A continued high level of licensee oversight of contractor activities that involve control of ignition sources is warrante . Radiological Controls Radiological Controls were observed on a routine basis during the reporting period. Standard industry radiological work practices, conformance to radiological control procedures and 10 CFR Part 20 requirements, were observed. Independent surveys of radiological boundaries and random surveys of non-radiological areas throughout the facility were taken by the inspecto During a tour of the facility on August 27, 1985, the inspector noted that three check sources were left unattended in a non-radiologically controlled area. These unlicensed check sources were sitting beside equipment being brought to the facility for calibration fro.n the offsite Emergency Operating Facility. This item was brought to the attention of a licensee Radiation Protection Engineer for corrective action. The inspector had no further comments in this are . Inspector Review Of Plant Events On August 17, 1985, the licensee implemented a load reduction from 168 MWe to facilitate Throttle Valve exercise per OP-4225, and Main Steam Non Return Valve operability test per OP-4261. Additionally, preventive maintenance (oil change) was performed on Boiler Feedwater Pumps Nos. 1 and At 3:35 a.m. on August 17, 1985, while closing Control Valve No. 1 locally and opening Control Valve No. 3 from the Main Control Board, Control Valve

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. 11 No. 3 became stuck at approximately the quarter open position. Plant Operators closed Control Valve No. I and then Control Valve No. 3 was closed and locked in place to prevent unnecessary pressure oscillation Plant load dropped from 120 to 90 MWe during this plant transient, with the average Main Coolant System (MCS) inlet temperature (Tc) obtaining a maximum valve of 523.5 degree fahrenheit. Prior to the transient, Tc was less than 515 degrees fahrenhei Technical Specification 3.2.4 requires the MCS inlet temperature to be less than 515 degrees fahrenheit and, if this value is exceeded, the plant operators have 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to restore the parameter within limits. Following stabilizing the positions of the control valves, the operators inserted control rods which reduced the main coolant system inlet temperature to less than 515 degree fahrenheit within 35 minutes. By 4:30 a.m. the throttle valve exercise was completed and a load increase from 90 MWe was initiated. Maintenance Request 85-905 was initiated to have the operation of Control Valve No. 3 investigated. This event was reviewed by the Plant Operation Review Committee at its Meeting No. 85-40 on August 21, 198 The inspector had no further questions on this item at this tim . Monthly Maintenance The inspector observed and reviewed maintenance and problem investigation activities to verify compliance with regulations, administrative and maintenance procedures, codes and standards, proper QA/QC involvement, safety tag use, equipment alignment, jumper use, personnel qualification, radiological controls for worker protection, fire protection, retest requirements, and reportability per Technical Specification. The following activities were include Maintenance Request (MR)85-393 Shutdown Cooling System Safety Valves (SV-234 & SV-205) Inspection

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MR 85-864 No. 2 NRV Packing Leak

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Mr 85-904 NRV Main Steam Line Pressure Switch (MS-PS-31) failed Surveillance

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MR 85-879 and 881 No. 3 Charging Pump Excessive Leakage

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MR 85-927 Diesel Fire Pump Fuel Pressure Gause Regarding MR 85-904, the inspector noted that this was the second recent failure of an ASCO Tripoint Model TL10A22 pressure switch. The prior occurrence was on July 18, 1985 and resulted in the issuance of MR 85-817 for Main Steam Line Pressure Switch MS-PS-11 that had failed the OP-4656 surveillance test. Both failures involved setpoint drift outside TS limit The licensee plans to issue Plant Information Reports on these events. The disassembly and inspection of the MS-PS-31 switch that failed it's sur-veillance test on August 16, 1985 resulted in the licensee initiating

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action to ascertain whether the failure is reportable under 10 CFR 21. The inspector has verified that the licensee is in communication with the Automatic Switch Co relative to the MS-PS-31 failur On September 12, 1985, the licensee performed procedure OP-4656 for the monthly surveillance of the Main Steam line pressure switches and noted that switch MS-PS-33 was out of the established administrative limits, but within the TS-limits. MR 85-1029 was issued, and resulted in a spare unit being installed to facilitate the inspection of another ASCO pressure switch. The inspector reviewed this maintenance activity and noted that the surveillance procedure OP-4656 was being used to remove power from the TS required trip circuit. Plant operators and the I&C Department explained to the inspector that they were still performing surveillance activitie The inspector took issue with this position and concluded that maintenance was being performed and that TS 3.3.1 action statement was applicabl This action statement required the licensee to complete the change out of the pressure switch within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or be in hot standby within this time frame. It was clear to the inspector that inadequate communications between maintenance and operations personnel had occurre The inspector held a discussion with the Assistant Plant Superintendent

.(APS) and representatives of the Maintenance and Operations Department relative to the observed activities. The APS acknowledged the inspectors comments and concerns, and indicated that communicating the TS implications of proposed maintenance between the departments will receive added atten-tion. Subsequently, the Shift Supervisor issued Lifted Lead Request N to document and control the removal of power from the trip channel associated with the MS-PS-33 pressure switch. The inspector confirmed that the maintenance activity was accomplished well within the time frame in the TS action statemen The inspector will review in a subsequent inspection the licensee's corrective action associated with the failures of the ASCO Tripoint Model TL10A22 pressure switches (50-29/85-15-01). Monthly Surveillance Observation The inspector observed tests and parts of tests to assess performance in accordance with approved procedures and LCOs, test results (if completed),

removal and restoration of equipment, and deficiency review and resolution. The following tests were reviewed:

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OP-4220, Water Balance

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OP-4271, Leakage Check of the Neutron Shield Tank

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OP-4211, Emergency Feedwater Pump Operability Testing

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OP-4202, Control Rod Operability Check

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OP-4216, Testing of the Post-Accident Hydrogen Vent System No inadequacies were discovere . Emergency Preparedness Activities Medical Emergency Drill On September 17, 1985, the inspector reviewed portions of a Medical Emergency Drill which was conducted by the licensee to test the Emergency Medical Team Response to on-site medical emergencie Additional objectives included (1) to test the Radiation Protection

' Department response to a medical emergency in a Radiation Controlled area, (2) to test plant personnel 'nterfacing with off-site support services (i.e., ambulance and hospital), and (3) to evaluate the North Adams Regional Hospital response to a radiation medical emergenc The inspector's review of site related drill activities did not result in the identification of any deficiencies in licensee performance. In fact, the inspector observed a well planned, con-ducted, and audited drill that should help to further improve an already strong licensee capability in the emergency medical response are Implementation Of An Upgraded Emergency Operations Facility (EOF)

On August 23, 1984, the NRC issued an Order confirming further licensee commitments on emergency response capability that involved complete implementation of an upgraded E0F by September 1,1985. To comply with this requirement, the licensee has relocated the existing EOF from the Furlon House located near the plant to the New England Power Company Hydro Division office on Conway St. in Buckland, Mas The upgraded EOF is seventeen miles from the plan The following actions were taken by the licensee as part of Emergency Preparedness Training as a prerequisites to declaring the new EOF operational on August 28, 1985:

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Tours were conducted on August 2 and 6 to familiarize all EOF staff members with the general layout and work areas of the buildin An E0F Training Drill on August 14, 1985 includes activation of the Engineering Support Center (ESC) and facsimile transmissions between plant, ESC, and EO The Emergency Preparedness Drill on August 28, 1985 used and i evaluated the upgraded EOF, the Forward Control Point (Furlon House) and communications between emergency facilities and ]

off-site teams. The Media Center was activated for the dril Thirty-nine and twenty-six licensee employees, respectively, ;

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. 14 responded to the EOF and Forward Control Points during the drill. The inspector observed licensee drill activities at the E0 Emergency drills were conducted in accordance with procedu es that were revised to reflect the existence of the upgraded 20 Due to coordination problems beyond their control, the licensee was unable to incorporate an ENS equipment package in the-upgraded E0F. In cooperation with an NRC request, the licensee has installed a commercial phone line at the EOF with two extensions for dedicated ENS use until special ENS equipment is installed at the EOF. The inspector provided the HQ Duty Officer with the dedicated phone number for ENS use at the E0 No deficiencies were identified during the inspectors review of this ite Public Notification System (PNS) Testing On August 29, 1985, the licensee activated its Emergency Notification System in order to test the effectiveness of the PNS. This test was conducted by the Federal Energy Management Agency (FEMA), who coordinated the activities of the civil defense officials in Massachusetts and Vermont, The Nation Weather Service and the local radio stations designated part of the Emergency Broadcast Syste Alarm-equipped weather alert radios and sirens in the town of Charlemont, Clarksburg, Colrain and North Adams were activated for this test. A telephone survey was conducted by FEMA to determine if people within the 10 mile Emergency Planning Zone heard the test and are familiar with the emergency plan booklet mailed to them in January, 198 FEMA survey results will be reviewed at a later date when availabl The test was performed with no equipment malfunctions occurrin . Plant Information Reports (PIRs)

PIRs prepared by the licensee per AP-0004 were reviewed. The inspector determined whether the conditions were reportable as defined in the TS and whether the licensee's system of problem identification and corrective action is being effectively utilized. The following PIRs were reviewed:

PIR N Occurrence Date Report Date Subject 85-01 1/18/85 2/8/85 Waste Gas Loop Seal Oscillation (potential unplanned release)

85-02 4/5/85 5/23/85 Fire Main Break Between Waste Disposal Building and PAB-Fan Roo E o

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85-03 4/26/85 6/10/85 Overflow of Primary Auxiliary Building (PAB)

Sum /27/85 6/10/85 Leak in 1st Point Extraction Steam Line 85-06 7/16/85 8/21/85 Failure of SI Accumulator Time Delay Relay Except for the following comments the inspector had no further questions:

PIR 85-06: This internal licensee information report describes the failure to maintain an 11.85 + 0.23 second time delay setpaint on an SI >

accumulator time delay relay (TDC4). The condition resulted from setpoint drift. The licensee's actions associated with this event were described in Section 11.c of Inspection Report 50-29/85-14. Upon review of this PIR the inspector noted that since 1979 there have been five (5) events associated with the Agastat Model SSC12PCA relay. The four (4) installed relays at the plant are tested on a once every 31 day basis in accordance with TS 4.5.1.c. The previous and current setpoint drift values for the TDC4 relay were out of specification by .04 and .05 seconds, respectively. The licensee's corrective action for this event included replacement of the relay due to observed erratic operation in maintaining the required setpoin In the past, the events associated with failures of the SI accumulator time delay relays have been reported as LERs per the Plant's TSs. In accordance with the requirements of 10 CFR 50.73 the event described by the PIR is not reportable to the NRC. However, the licensee is effectively utilizing the PIR as a corrective action system to promptly and consistently recognize and address non-reportable concerns. The licensee is encouraged to continue this positive attribut The inspector identified no violations regarding the licensee's actions associated with these events, and noted that a determination of cause of occurrence was made with appropriate short and long-term corrective actions specifie . Onsite Review Committee On September 3 and 17, 1985 the inspector observed the meetings of the Yankee NPS onsite review committee (PORC) to ascertain that the provisions of TS 6.5.1. were me Except for the following item, the inspector had no further comments as a result of reviewing the licensee's activities associated with the onsite review committee:

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During the meeting on September 3, 1985, the inspector observed the committee review of Engineering Design Change Review (EDCR)84-307,

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.- 16 Reactor Protection System Upgrade. The inspector noted that this review was performed in a very detailed manner by the committee, and reflected licensee management's attention to improve design control and safety evaluation reviews in response to NRC identified concerns and weaknesses noted in the recent SALP Report (50-29/85-99).

In an attempt to improve the quality of PORC reviews, station management had scheduled and implemented a training session for all PORC members and Alternates on July 24, 1985. This training consisted of a review of Committee responsibilities, including 10 CFR 50.59 review requirements. The inspector informed station management representatives that the licensee's corrective actions in this area have resulted in a positive trend in Committee performance and have been responsive to the SALP Board recommendatio . Licensee Action on NUREG-0660, NRC Action Plan Developed as a Result of the TMI-2 Accident The NRC's Region I office has inspection responsibility for selected action plan items. These items have been broken down into numbered descriptions (enclosure 1 to NUREG-0737, Clarification of TMI Action Plan Items). Licensee letters containing commitments to the NRC were used as the basis for acceptability, along with NRC clarification letters and inspector judgment. The following item was reviewed:

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NUREG-0737, II.B.I, Reactor Coolant System (RCS) Vents This item was discussed previously in Inspection Reports 50-29/83-15 and 84-07. The latter inspection results noted the submission by the licensee to the NRC of proposed TSs (Proposed Change No.183, licensee letter FYR 84-48, April 17,1984 for the RCS Vents). The inspector noted in this inspection period that the licensee had reviewed and approved EDCR 84-312, Relocation of Power Supplies for Motor Operated Valves. This EDCR, in part, provides for supplying emergency power to the Pressurizer Vent Valve PR-MOV-55 When the NRC issued its Safety Evaluation Report (SER) on September 14, 1983 for the RCS vents, they stipulated that the licensee will propose TSs that will provide for operability testing of the PR-MOV-558 valve from both the off-site and emergency power sources (via backfeed). This testing was to include testing the related capability of transferring from the non-emergency to the emergency bus within 30 minutes of the loss of off-site source. The licensee's

. Proposed Change No. 183 requesting issuance of RCS vent TSs neither specified the SER surveillance features, nor documented the

- licensee's intent to transfer the power for PR-M0V-558 to an emergency bus to negate the SER stipulations. This information was l discussed with the NRC

NRR Licensing Project Manager (LPM) on September 13, 1985. This action was taken for the purpose of ensuring the soon-to-be issued TSs for this item would correctly reflect the

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licensee's modification to the facility, and not leave the SER concern unaddresse Additionally, EDCR 84-312 indicates that other power supply changes will be implemented that will result in all four RCS vent valves being de-energized but capable of being re-energized from the Switchgear Room in the event of an accident that requires their us This action is the result of the licensee's Appendix R analysis and written commitment to remove power from valves PR-MOV-558, VD-MOV-559, PR-MOV-560, and VD-MOV-561 in its letter FYR 85-49 to NRC:NRR on April 30, 1985. The EDCR appropriately indicates that a revision to the TSs requested in Proposed Change 183 will be required to reflect operability with the valves in the de-energized condition, as well as appropriate surveillance to ensure the de-energized condition is maintaine 'The inspector will continue to follow the licensee's implementation of this item during routine inspection of the facilit NUREG-0737, II.B.2.3., Plant Shielding - Equipment Qualification

.This item required the licensee to review safety-related equipment which may be unduly degraded by radiation during post-accident operation of this equipment and provide fully qualified equipment and/or appropriate corrective action The equipment qualification considerations due to radiation effects are incorporated into the requirements of the Commission Memorandum and Order on equipment qualification (CLI-80-21). A post implementation review of equipment qualification requirements associated with the aforementioned Order will be conducted at a later date and will encompass this item. This item is considered close NUREG-0737, II.K.3.25.B.2, Effects of Loss of Power on Pump Seals On June 12, 1980, the licensee in its letter.WYR 80-66 to NRC-NRR specified that as a result of discussions with the NRC staff ( prior to issue of NRUGE-0737) indicated this item was not applicable to PWRs and, therefore, not applicable to the Yankee Plant. Subsequently, the licensee reiterated this position in response to NUREG-0737 in its letter to NRC:NRR on December 15, 198 The inspector's review of the NUREG-0737 requirements of this item, noted that (1) the consequences of a loss of cooling water to the reactor recirculation pump seals was to be analyzed based upon a complete loss of alternating current (AC) power for at least two hours, and (2) Westinghouse operating reactors were to submit the evaluation by January 1, 1982. The inspector requested the Technical Services Supervisor to provide the analysis to the inspector in a ccordance with NUREG-0737 so that the appropriateness of the licensee position can be reviewed and the item closed if warrante I,

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This item remains ope . Management Meetings During the inspection. period, the following management meetings were conducted or attended by the inspector as noted below:

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The inspector attended an exit meeting held on August 16, 1985 by region based specialists at the conclusion of Inspection 50-29/85-16, Review of the licensee's Health Physics, Radwaste and Transportation Programs, ensite inspectio The inspector attended an exit meeting held on September 12, 1985 by a region based specialist at the conclusion of Inspection 50-29/85-17, Review of the licensee's Security Program, onsite inspectio At. Periodic intervals during the course of-the inspection period, meetings were held with senior facility management to discuss the inspection scope and preliminary findings of the resident inspector.