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U.S. NUCLEAR REGULATORY COMMISSIONREGION I

Report No. 91-03

Docket No. 50-271

Licensee No. DPR 28

Licensee: Vermont Yankee Nuclear Power CorporationRD 5, Box 169,

Ferry RoadBrattleboro, VT 05301

Facility: Vermont Yankee Nuclear Power StationVernon, Vermont

inspection Period: January 6 - February 11,1991

Inspectors: Harold Eichenholz, Senior Resident InspectorThomas G. Hiltz, Resident inspectorRichard S. Barkley, Project Engineer

' % Y/ <W J2//9Approved by:Jdfin F. Rogge, Chief, Readr Piojects Section 3A 'Dite

Inspection Summary: This inspection report dm 'ments the routine resident safetyinspections conducted between January 6 and F 2ary 11,1991. Station activities inspectedduring this period included: plant operations. iological controls; maintenance andsurveillance; security; engineering and technicai support; and safety assessment and qualityverification.

Results: Inspection results and conclusions are summarized in the attached ExecutiveSummary.

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9103040028 910220PDR ADOCK 05000271o PDR

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EXECUTIVE SU5151 ARYVermont Yankee Nuclear Power Station

Report No. 91-03

Plant Operations

Recurring plant operational conceris involving a house heating boiler steam leak and a *ll"Emergency I)iesel Generator room roof leak were reviewed. Appropriate programs andmaintenance activities were detern ined to be in place to address these issues. The conduct ofa Rod Pattern Exchange and repai s to inlet piping of the 4B Feedwater lleater exemplified ahigh level of planning and commtnications. Vermont Yankee continues to exhibit a goodsafety perspective in this functiomd area.

Rndiological Controls

Improper entry by a Radiation Protection Department technician into a High Radiation Area3 was identified by Vermont Yankee. Radiation Protection personnel were found to beg knowledgeable of plant radiological conditions, however, one area survey to be used by

personnel for assessing conditions was lacking contamination data. Vermont Yankee'sidenti6 cation of soil contamination beneath the Chemistry Laboratory due to a leak in a drainline was aggressively pursued for resolution of issues by establishing a corrective action plan.Additionally, conservative reporting techniques were noted. Efforts to reduce the volume ofradioactive material in the Spent Fuel Pool were adequately controlled and supervised.

Alaintenance and Surveillance

A proper safety perspective and timely correction of a separated Ocxible conduit on a PeltAccident Torus water temperature element was observed as a result of this NRC identifiedissue. Vermont Yankee addressed, in an appropnate and timely manner, a prior inspectionreport issue involving excessive grease on a liigh Pressure Coolant injection valve stem.Review of preventive maintenance activities on a Reactor Building heating and ventilationisolation valve found good conduct of work and conservative operational practices.

Security

A number of Vermont Yankee initiatives in the area of security are indicative of managementefforts to enhance security effectiveness. Notably were the Gatehouse 2 modifications,demonstrating the use of an explosive detection police dog in a power plant environment, andthe response to the Persian Gulf conflict.

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Engineering and Technleal Support

The current status of Vermont Yankee plans for installation of a hardened Wetwell Vent wasreviewed. Two Unresolved items involving review of an engineering investigation into theRHR Service Water design denciency and Gnal corrective actions associated with theRBCCW-ll7 power supply were closed.

Safety Assessment and Quality Verification

The NRC reviewed a licensee conducted Quality Assurance audit in the area of operatingexperience and assessment activities and the Corrective Action Program (CAP). Auditfindings and inspector review suggest additional licens0c attention is warranted in the CAParea. The status of the Safety Parameter Display System (SPDS) was reviewed. The need toprovide approprian orocedural guidance on the reportability of an out-of-service SpDS wasidentified.

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TABLE OF CONTENTS

EX ECUTIVE S U M M A R Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... il

TA B L E O F CO NTENTS . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . iv

1.0 SUMMARY OF FACILITY ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . 1

2.0 PLANT OPERATIONS (71707, 93702, 62703) . . . . . . . . I............

2,1 Inspection Activities . . . . . . . . . . . . . . . . . , , . . . . . . . . . . . . . . 1

2.2 Inspection Findings and Significant Plant Events 2...............

2.2.1 Rod Pattern Exchange and Repair of Feedwater Heater PipeLeak ...................................... 2

2.2.2 Review of Concerns Relating to Plant Operations 3..........

2.2.3 Main Generator Hydrogen Cooler Service Water Pipe Leak , . . . . 5

3.0 RADIOLOGICAL CONTROLS (71707, 93702) 5....................

3.1 Inspection Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.2 Inspection Findings and Review of Events . . . . . . . . . . . . , , . . . . . 63.2.1 Contamination Data Lacking on an Area Survey 6....,......

3.2.2 Chemistry Laboratory Drain Line Leak . . . . . . . . . . . . . . , . . 63.2.3 Reduction of Volume of Material Stored in Spent Fuel Pool 7....

3.2.4 Improper Entry Into a High Radiation Area, (LER 91-01) . . . . , , 8

4.0 MAINTENANCE AND SURVEILLANCE (62703,71707,92700,61726) . . . . 8

4.1 Maintenance inspection Activity . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4.2 Maintenance Observations 8.............................

4.2.1 Separated Flexible Conduit on Post Accident Torus WaterTemperature Element . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4.2.2 HPCI Valve Stem Maintenance . . . . . . . . . . . . . . . . . . . ,. 9

4.2.3 Preventive Maintenance on HVAC (SB) 11 9..............

4.3 Surveillance inspection Activity . . . . . . . . . . . . . . . . . . . . . . . . . . 9

5.0 SECURITY (71707, 92700) . . . . . . . . . . . . . , . . . . . . . . . . . . , , . . . . . 10

5.1 Observations of Physical Security . . . . . . . . . . . . . . . . . . . . . . . . . 105.2 Gatehouse 2 Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5.3 Explosive Detection Capability 10..........................

5.4 Response to the Persian Gulf Conflict 10.................. ,,.

6.0 ENGINEERING AND TECHNICAL SUPPORT (71707, 92701) . . . . . . . . . . 116.1 -Installation of a Hardened Wetwell Vent Generic Letter 89-16 11..... .

6.2 (Closed) Unresolved Item 50-271/89-09-03: Review of EngineeringInvestigation into the RHR Service Water Design Deficiency. . . . . . . . . I1

6.3 (Closed) Unresolved item 50 271/89 12-01: Final Corrective ActionsAssociated with the RBCCW-117 Power Supply. 12...............

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Table of Contents

7.0 SAFETY ASSESShiENT AND QUALITY VERIFICATION (90712,92700,90713, 71707) . . . . . . . . . . . . . . . . . . . , , . . . . , , . . . . . . . . . . . . . . 12

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7,1 Licensee Event Reports (LERs) 12........... .........,.. ,

7.2 LER Recapitulation 13.., ,............................

7.3 Periodic and Special Reports . . . . , . . . . , . . . . . . . . . . , , . . . . 13

7.4 Summary Assessment of Audit Report 90-17 . . . . . . . . . . . . . . . . . . 137.5 Safety Parameter Display System Operability . . . . . . . . . . . . . . . . . . 14

8.0 h1ANAGEhiENT h1EETINGS (30703,94600) 15.....................

l 8.1 Preliminary inspection Findings . . . . . . . . . . . . . . . . . . . . . . . . . . 15

8.2 Region Based inspection Findings . . . . . . . . . . . . . . . . . . . . . . . . . 158.3 Information hiecting with Local Officials . . . . . . . . . . . . . . . . . . . . 15

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DETAILS

! 1.0 SUMMARY OF FACILITY ACTIVITIES

Vermont Yankee Nuclear Power Station (VY) conducted routine full power operations formost of the inspection period. Weekly power reductions to 94 percent of rated power wereconducted to facilitate control rod exercises and main turbine surveillances. A powerreduction to 55 percent of rated power occurred on January 28 to conduct a scheduled rodpattern exchange and perform repairs due to a leak m the drain inlet piping on the 4Bfeedwater heater. Full power operations resumed on January 30. Offgas activity levelscontinued to remain in the 20,000 to 25,000 Uci/sec range and analysis indicated the activitylevel was primarily due to recoil effects.

During the inspection period, preventive maintenance was conducted on the Reactor BuildingVentilation System isolation valves (SB-9,11, and 12). The use of the Standby GasTreatment System and its associated lower air turnover rate caused the reactor building to bedeclared an Airborne Radioactivity Area a number of times.

Remodeling of Gatehouse 2 was initiated this inspection period. This long term project isintended, in part, to enhance personnel access and egress. VY used their Commitment toExcellence Program to further enhance improvements that this project can provide to thesecurity program and environment.

On January 16, the Massachusetts Institute of Technology initiated its site research as part ofa six month study associated with the International Program on Enhanced Nuclear PowerPlant Safety. The research project is expected to develop a set of performance indicatorsrelated to the management and organization of nuclear power plants.

As part of the consolidation of engineering and construction resources at VY to provide moreefficient and effective engineering services, the new position of Engineering Director was'illed by the present Reactor and Computer Engineering Supervisor. This organizationchange was effective February 4, and is the Erst phase of a planned restructuring of theseresources. This VY reorganization plan was reviewed in Inspection Report 50-271/90-18,section 8.1).

On February 1, VY provided certiGcation to the USNRC that the Simulator Facility meetsthe requirements of 10 CFR 55.45,

2.0 PLANT OPERATIONS (71707, 93702, 62703)

2.1 Inspection Activities

The inspector verified that the facility was operated safely and in conformance withregulatory requirements. Management control was evaluated by direct observation ofactivities, tours of the facility, interviews and discussions with personnel, and independentverification. The inspectors performed backshift inspections on January 24,29 andFebruary 5.

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2.2 Inspection Findings and Significant Plant Events

2.2.1 Rod Pattern Exchange and Repair of Feedwater lleater Pipe Leak

On January 28 at 1:35 a.m. VY initiated a power reduction from 100 percent teapproximately 63 percent of rated power to conduct a scheduled Rod Pattern Exchange(RPE), Power level changes were secured at 94 and 80 percent of rated power to facilitatethe conduct of weekly required surveillance testing. By 5:17 a.m., this date, the RPE was

Fullcompleted and reactor power was maintaining 53.5 percent of rated power output.closure Main Steam Isolation Valve testing was conducted satisfactorily.

At the reduced power condition, the VY operators were able to isolate the 4B feedwaterheater to repair a pin hole steam leak on a 20" inlet piping weld A welded patch repair wascompleted following a complete circumferential ultrasonic inspection (UT) of the inlet drainline nozzle / reducer area. The UT results indicated that the leak was due to a localizedcrosion/ corrosion condition. The area affected was 1/4" x 4" along the circumference of the

20" line where erosion / corrosion reduced the wall thickness below the 200 thousandthsminimum acceptable. Stress analysis requires a minimum wall of 100 thousandths. Typicalwall was greater than 400. VY believes that an external weld defect in the heat affected zonaof the nozzle to reducer (6" x 20") weld, in combination with the localized crosion/ corrosion,resulted in the leak after approximately eighteen years of in-service time. Erosion / corrosionstudies were performed on the 4A feedwater heater iniet line during the 1989 Outage.Because of the assumption that the respective heaters were mirror images of each other, the4B feedwater heater was not examined and therefore VY was not aware of the localizedcondition. This assumption appears to be invalid due to internal piping details not beingconsidered in the original crosion/ corrosion inspection program. The ConstructionDepartment has requested the services of Yankee Nuclear Service Division (YNSD) toprovide an erosion / corrosion inspection scope for the 1992 Outage. The scope is to includelessons learned from this heater drain line leak and other industry events. Another requestfor YNSD services was issued by the Construction Department to provide additional detailedinformation in feedwater heater repairs and/or replacements. The inspector reviewed as-found conditions of the equipment and VY repair plans. No unacceptable conditions were

identified.

Following the feedwater heater piping repairs at 12:16 p.m. on January 29, power ascensionwas initiated. Continuous video monitor coverage of the 4B feedwater heater was providedin the control room and numerous inspect ons into the heater bay were performed. At 11:30i

m. that evening, the plant achieved 100 percent of rated power output.

momprehensive planning and excellent communications were o served by the inspector in theb

conduct of these activities. A proper safety perspective by VY personnel was evident.

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2.2.2 Review of Concerns Relating to Plant Operations

During this inspection period, the NRC reviewed two concerns dealing with plant operationsthat were of a recurring nature. One concerned a House Heating System steam leak in thevicinity of the Condensate Demineralizer System control panel located in the TurbineBuilding, and the other a roof leak in the "B" Emergency Diesel Generator (EDG) Room.

Regarding the first item, the inspector toured the 232'-6" elevation of the Turbine-

Building in the vicinity of the condensate demineralizer control panel on January 28.A significant steam plume was noted to be emanating from the House Heating Boiler(HHB) System's condensate return tank vent located in the vicinity of the panel. Thisvent is located directly over a floor drain. Due to the steam plume, moisture wascondensing on a low overhead ceiling above the condensate return tank, piping, andpipe supports above the tank area. A nearby cable tray and cables appeared dry andthe control panel did not appear to be impacted by the steam.

The inspector held discussions with VY Operations Department personnel andreviewed maintenance records to ascertain the facts concerning the existence of thiscondition and resulting licensee actions planned or taken. This condition wasidentified by a plant operator early on January 25. Maintenance Request (hiR) 91-170was issued to document and correct the excessive blowing steam. Actions wereinitiated by the shift operating personnel to attempt to identify the cause of HHBsteam leaking into the condensate drain tank. Because this has been a recurringcondition over the years, the operators understood that they had to initiate aninvestigation to locate the steam trap (s) on associated space heaters that could allowthe bypass of steam into the condensate drain tank. This type of investigation isextensive, as the condensate collection system in question covers approximately 50steam coils / traps. To identify the faulty trap (s), one or more steam traps are isolateduntil the steam discharge is stopped. On January 28, the Operations PlanningCoordinator obtained support from Auxiliary Operators to conduct a systematic searchfor the faulty trap. Additional support was obtained from the evening and night crew,as directed by night orders, during the period of January 29-31. The results of theinvestigation determined that four traps were leaking. Following the generation ofMRs, the Maintenance Department completed repairs on three of the four traps byFebruary 8. The remaining leaking steam trap was scheduled for repair on February11.

The inspector reviewed VY's preventative maintenance practices and noted that theHHB System has annual work performed. The Maintenance Department inspectssteam traps during system start-up. The units selected for inspection are a function ofthe prior service history.

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Other than the effects that steam emanating from the condensate drain tank can haveon the equipment in the immediate vicinity, no significant plant or personnel safetyissues were identified by the inspector or VY However, the recurrence of steamleakage into this area has created housekeeping issues (e.g., minor rusting of pipesupports) that warrant further evaluation and correction by VY. As of the end of thisinspection period, the Operations Planning Cooidinator was addressing this follow-upitem with the Maintenance Department. The inspector considered this to beappropriate, given the expected recurrence of this condition as a normal function ofsystem operation.

-- The second issue involved a recurring roof leak in the vicinity of the "B" EDG room.Roof problems at VY have been an on-going licensee issue since February 1989. Theleak currently observed in the "B" EDG room is small in nature and appears to becoming from the penthouse area located near the generator end of the EDG. Thecurrent leakage is not resulting in rain water and/or melting snow falling uponequipment within the room. A visual survey of the room, however, provides evidencethat the leakage into the room in the past resulted in direct impact or splatter ontoequipment. To date, there is no evidence that this condition has adversely impactedthe ability of the equipment in this area to perform its intended safety function.Current equipment conditions suggest minor housekeeping issues exist.

VY records maintained by the Maintenance and Construction Departments provide achronology of activities relating to roofing problems in genrd, and the "B" EDGroom in particular. In the last two years, the Construction Department has madevarious attempts to correct the roof leak, This is in addition to a systematic programto replace major roofing surfaces at the plant. Although limited in success, continualimprovement in correcting the condition of the leak in the "B" EDG Room has beenobserved by both the licensee and inspector. According to VY, the cause of theremaining leakage is due to inadequate counterflashing around the supports of thediesel mufGers in the penthouse. Temporary repairs have reduced leakage to a minoramount. Long term repairs require lifting the mufflers off their supports to performcounterflashing. To assist in this project, a service request for YNSD was issued bythe Construction Department an February 1 to provide analytical services to VY byFebruary 22. The analysis is to address, amongst various engineering reviews, anyoperational constraints for lifting the mufner off its supports when the EDG isrequired to be operable. When leakage was signincant, such that water was sprayedor dripped onto EDG equipment, VY erected protective coverings to divert the leakaway from the electrical equipment. The licensee analysis of conditions associatedwith the roof in question indicated that a complete replacement of the entire roonngsystem above the EDGs is not warranted.

Although both of the above described issues represent recurrent conditions, the awareness andactions of VY operating and maintenance personnel and management indicate a proper levelof concern and good safety perspective. Programs and routine preventive and corrective

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maintenance actions are in place to properly address the safety aspects of these issues, Thelicensee continues to exhibit an acceptable approach in resolving recurrent equipment andfacility deficiencies. The inspector had no further questions or concerns regarding the issuesdescribed above.

2.2.3 Main Generator Ilydrogen Cooler Service Water Pipe Leak

A leak was identified by VY in the piping that provides service water to one of the four maingenerator hydrogen coolers (E10-1 Ai MR 91-0169 was issued to identify the equipmentdeficiency. On January 29, VY installed Temporary Modification 91-007, which placedpieces of soft rubber held over the pinhole leak by a hose clamp. The MaintenanceDepartment determined that the pinhole leak was due to weld porosity. The subject pipingwas changed from carbon steel to stainless steel material as part of a service water systemupgrade in 1989 to make the system more resistant to microbiological induced corrosion. VYhad a number of maintenance engineers lock at the piping leak to ensure that there were noconcerns for catastrophic pipe failure.

The purpose of the cooler is to remove heat absorbed in the generator by the ventilatinghydrogen gas. Plant operators informed the inspector that the cooler in question could not beremoved from service with the unit on the line due to concerns about differential limits

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between the coolers. The plant operators on shift, when questioned by the inspector as towhat differential temperature limits are used, indicated that according to the vendor technical

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manual a one degree celsius value is appropriate. Also, current higher than normal maingenerator bearing vibration indications (approximately 6.5 mils) could be adversely affecteddue to thermal sensitivity. Regarding the differential temperature limits between hydrogencoolers, the inspector noted that the January 29 hydrogen cooler outlet temperatures spanneda differential range of almost three degrees celsius. Following this condition being brought tothe attention of the Operations Department staff, the Night Orders for January 29, directedthe plant operators to balance the hydrogen coolers to within one degree celsius of each other.The inspector noted that no plant procedure or Licensed Operator Training Program lessonplan covered the aforementioned limit. The Senior Operations Department Engineer,indicated that during the next routine revision to OP 2181, " Service Water / Alternate CoolingOperating Procedure," the vendor technical manual guidance would be added.

The inspector determined that operators were familiar with the Hydrogen Cooler System;

operation and periodica!!y conducted system adjustments. The temporary repair to the'

cooling piping was timely and appropriate to the circumstances of plant operations. Theinspector had no further questions on this matter.

|3.0 RADIOLOGICAL CONTROLS (71707, 93702)

3.1 Inspection Activities

Compliance with the radiological protection program was verified on a periodic basis.

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3.2 Inspection Findings and Review of Events

3.2.1 Contamination Data Lacking on an Area Survey

Radiation Work permit (RWP) No. 90-1049, inspections, Routine Rounds, and Tagging Onlyis used by plant, security, and NRC personnel to perform required duties in the ReactorBuilding. For assessing the contamination data for areas of concern, the user of the RWP isdirected to the Radiological Situation Board (RSB). Because the inspec'or was entering theTorus Catwalk area on January 16, the subject RWP was utilized and the appropriate surveymap (Appendix A 4530.15) dated January 5, was assessed. No contamination data wasspeciRed for areas off of the catwalk itself. These areas are posted Contamination Area,Radioactive Materials Area, and RWP required. Discussion with VY personnel determinedthat the subject RWP could be used for entering the posted area. The RWP prescribedprotective clothing requirements.

The lack of contamination data for off of the catwalk area on the survey map was a concernto the inspector. This matter was discussed with the plant Health Physicist, whoacknowledged the inspector's comments and concerns. Subsequently, the survey map wasupgraded to indicate that smears taken from off the Torus Catwalk area indicatedcontamination levels in the range of less than 1,000 to 12,000 DPM per 100 centimeterssquared. Although the Radiation Protection (RP) Department technicians expect personnel tocommunicate with them when they go off the Torus Catwalk area, this does not replace theneed to provide appropriate radiological information on the area survey maps.

In general, the inspector found RP Department personnel knowledgeable of radiologicalconditions in the plant and that they provided good brienngs of area conditions. Theprotective clothing requirements specined on the RWP were appropriate for the contaminationlevels that existed off of the Torus Catwalk area. The inspector had no further questions onthis matter.

3.2.2 Chemistry 12boratory Drain Line Leak

During an attempt to repair a leak in a drain line from the sinks in the Chemistry Laboratoryon February 1, it was discovered that the drain line had failed below the concrete pad. Thesubject drain line is a three inch carbon steel pipe that transfers by gravity feed the chemicalwastes from the laboratory to the Chemical Waste Tank located in the Radwaste Building.An initial isotopic analysis of soil samples in contact with the drain line was performed onFebruary 1. Further evaluation was conducted by VY that was completed on February 4 thatindicated a second concrete pad did not exist below that of the fill and concrete floor of thelaboratory. Because of this condition, it was concluded that contar.tinated wastes from thelaboratory had been discharged to the soil below the pad. The concentration of long andshort lived activation and Ossion product radio-nuclides in the soil that is in immediatecontact with the drain line is approximately thirteen microcuries per cubic foot.

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In accordance with procedure AP 0010, " Occurrence Reports," a Potential ReportableOccurrence report was issued on February 4 av i1:50 a.m. By 3:35 p.m., this date, VYmade a four hour noti 0 cation to the NRC in accordance with 10 CFR 50.72 (b)(2)(vi).Although no news release or notincation to other government agencies was planned at thetime, VY made a conservative notification to the NRC because an inadvertent release ofradioactivity contaminated materials had occurred.

Immediate corrective actions implemented by VY on February 1, consisted of securing anyfurther releases into this drain line. The inspector verified that all identined pathways wereappropriately marked to either not be used or, if used, appropriate temporary collectionfacilities were provided. Considerable effort was made to open all drain traps to precludeunintentional discharge into the drain line. As a precautionary measure, nearbydecontamination facilities were de-activated from using their own drain line until furtherevaluation can be conducted to assure a proper level of integrity exists. VY has requestedanalysis and engineering assistance from YNSD to aid in the development of a plan of actionto appropriately address this event.

On February 6, the Technical Services Superintendent distributed a corrective action plan thatincluded actions to: (1) determine the extent of corrosion of the drain line; (2) determine theroot cause of failure; (3) determine the extent of ground contamination by soil samplecollection and generation of a depth proGle; (4) determine the applicability of the failuremechanism to other drain lines in the fill; and (5) determine a suitable repair / replacement torestore the Chemistry Laboratory to full services. At the end of the inspection period, VYwas in the precess of obtaining core soil samples and performing boroscopic evaluations ofthe drain line. The NRC will review the licenwe's actions and assessments in response tothis event during routine reviews of this functional area.

VY properly identified relevant issues associated with this event and aggressively purnedtheir resolution in the development and initial implementation of the corrective action plan.Good management involvement and oversight was noted. Conservative reporting achniqueswere employed to provide an early awareness to the NRC on an unfolding situal'an.

3.2.3 Reduction of Volume of Material Stored in Spent Fuel Pool

The inspector observed VY's ongoing efforts at reducing the volume of radioactive materialin the Spent Fuel Pool VY cfforts consisted of cutting off the stellite balls and velocitylimiters on used control rod blades, crushing the body of the blades, and cutting the LPRMstrings into smaller, more manageable pieces. The work was being conducted by contractorsunder VY supervision using MR 91-0006. The inspector observed ongoing work on thisproject, discussed various aspects of the work with the contractor employees, and closelyreviewed radiological controls on the ongoing work. The on-duty Radiation Protection (RP)technician was found to be very knowledgeable and diligently controlling ongoing work.

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Adequate surveys of the work area and the radiological hazards of the control rod blade andLPRh1 parts were noted. Hot particle controls were in-place and comprehensive, reDecting aconcerted effort to control a potentially difGeult contamination problem.

Overall, the inspector found the job to be adequately controlled and supervised. While theRP technician on-duty was kept quite challenged controlling a job with such potentiallyserious radiological consequences on his own, he was effective at accomplishing the task.

3.2.4 Improper Entry into a liigh Radiation Area, (LER 91-01)

On January 4 a Radiation Protection technician entered a posted High Radiation Area(radioactive waste cask room) to check the condition of the resin and to move a resin caskwithout a dose rate monitoring device as required by Technical Specification 6.5.B l. This

#event, and corrective action, was discussed in LER 91-01 issued by the licensee on January23. The inspector determined that this LER should remain open pending review of the eventand licensee corrective adions by an NRC Region I specialist inspector during a routinereview of the Vermont Yankee Radiological Controls Program.

4.0 MAINTENANCE AND SURVEILLANCE (62703,71707,92700,61726)

4.1 Maintennnee Inspection Activity

The inspector observed selected maintenance activities on safety related equipment toascertain that these activities were conducted in accordance with approved procedures,Technical Specifications, and appropriate industry codes and standards.

4.2 Maintenance Observations

4.2.1 Separated Flexible Conduit on Post Accident Torus Water Temperature Element

A separated flexible conduit for wiring associated with the post accident monitoringtemperature element, TE 16-19-33A, was noted by the inspector on January 31. The elementis located on torus penetration X-2068. Upon identi0 cation of this item to the I&CSupervisor, MR 91-218 was issued, an evaluation of impact on equipment operability wasmade, and a repair plan was developed.

This equipment was determined by the l&C Department to be both safety class andenvironmentally qualified. The I&C Supervisor informed the inspector that based upon theinstalled design features of the penetration, the separated conduit did not adversely impactability of the equipment to maintain its qualineation. However, the repair plan does includeinspections to verify that the separated flexible conduit did not result in any deterioration ofthe equipment.

The licensee's review of this item reflected a proper safety perspective, and was conducted ina timely matter. The inspector had no further questions in this matter.

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4.2.2 IIPCI Ynlve Stem hinintenance

In the prior inspection period (Inspection Report 50-271/90-18) the inspector notedinconsistent application of grease on some High Pressure Coolant Injection (HPCI) Systemvalve stems. Specifically, the HPCI 21 valve stem had what appeared to be an excessiveamount of grease on it. The licensee explained that the extra lubrication of this valve isattributable to the anti-rotation device which is not on the other valves. However, thehiaintenance Department indicated that the lubrication on the HPCI-21 valve stem isexcessive and will be reduced. The work was completed by the end of the inspection period.The licensee's actions were timely and appropriate. The inspector had no further questionson this matter.

4.2.3 Preventive hiaintenance on IIVAC (Sil) 11

In response to identified problems with the Reactor Building's ventilation supply valve SB-10,VY conducted inspections of the Reactor Building's ventilation supply and exhaust valves SB-9. -11, & -12 to maintain their reliability. These valves, large air-operated butterfly valveswhich serve as secondary containment isolation valves, are located just outside the ReactorBuilding above the roof of the main steam tunnel. As a result of their location, the valvesare exposed to the environment and subject to water intrusion and possible freezing.

The inspector reviewed the wor.k package for valve SB 11 which was controlled by h!R 90-0552. The inspector found the work to be controlled, necessary evaluations regardingscaffolding and material substitutions completed, and work outside the original scope of thework package (i.e. replace heat tracing) properly handled. VY found the valves to be inbetter material condition than valve SB-10, but elected to do material improvements to theoperators (i.e. replace the ' mess covers on the operators) while performing these inspections.In addition, VY elected to replace the heat tracing on several of the operators and to includean annual check of the heat trace during their cold weather inspections due to identifiedfailures of the heat trace on valve SB-10.

The inspector found the overall conduct of this work to be good. In addition, the inspectorviewed VY's decisien to test the !ccondary containment isolation capabilities of each of thesevalves prior to their remma' from service to reflect sound, conservative operational practice.

4.3 Surveillance Inspection Activity

Routine observations of daily surveillance was conducted. No unacceptable conditions wereidentified.

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5.0 ' SECURITY-(71707, 92700)

5.1 Observations of Physical Security

Compliance with the securit; pmgram.was verified on a periodic basis, including theadequacy of staffing, entry control, alarm stations, and physical boundaries. The inspectornoted that security personnel were alert and conscientious during the performance of their |duties. Daily security supervision involvement at Operations Planning meetings continues to jbe observed by the inspector. - 1

5.2- Gatehouse 2 Modifications

- On January 28, VY initiated construction activities for remodelling Gatehouse 2. This Jgatehouse is the principal plant access point into and out of the Protected Area. Theremodeling plans call for separating entrance and exit paths and providing for an additional 1

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process lane. The significant flow path design improvements, which are intended to provide'

enhanced security process and work environments, were aided by a Commitment toExcellence Program designated Task Team. This team employed a variety of backgrounds of :

personnel involved and helped VY optimize the-improved design of the gatehouse.

- VY's approach and commitment to improve existing security facilities is viewed as a licenseestrength. ,

5.3 ' Explosive Detection Capability

The inspector witnessed an on-site demonstration by a police dog specially trained andcertified to detect explosive material. The dog was handled by the Rutland, Vermont Police,

:with the Vermont State Police participating in the demonstration. VY initiated thedemonstration in an effort to assess the effectiveness of this type of capability in a power :plant environment. According to the Security Supervisor, preliminary indications are that|

effectiveness was demonstrated.L

VY's initiatives of this nature are indicative of security management effort to provideeffective security capabilities.

5;4 L Response to the Persinn Gulf Conflict

. Due to recent events in the Persian Gulf, the NRC has noted an appropriate heightened 1

security awareness with particular note for anything that may be out of the ordinary. Inaddition, a number of initiatives were taken by VY These include communications andaccess control improvements, but are not described in detail in this report because they are-considered Safeguards Information.

VY response has demonstrated a prudent and proper security perspective.

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6.0 ENGINEERING AND TECilNICAL SUPPORT (71707,92701)

6,1 Installntion of a IInrdened Wetwell Vent-Generle Ixtter 8916

In response to the NRC's issuance of Generic Letter 8916, " Installation of a HardenedWetwell Vent," the licensee specified in their October 30,1989, hiarch 26,1990 andDecember 31,1990 letters to the NRC their voluntary commitment to install a hardened vent.It is the licensee's intention to install the vent during the hlarch 1992 refueling outage. TheNRC, in its January 23,1991 letter, specified that tht staff has no objection to the licensee'sproposed design and Onds their commitment date acceptable. The modiGcation to the plant toinstall the hardened wetwell vent will be conducted under the provisions of 10 CFR 50.59.

6.2 (Closed) Unresolved item 50-271/89-09-03: Review of Engineering Investigntioninto the RllR Service Water Design Denciency.

During an engineering review of portions of the electrical distribut',on system, VY identified adesign error with the "B" train Residual Heat Removal (RHR) heat exchanger Service Water(SW) outlet valve RHRSW-89B. The error involved the wiring of the valve to a hiotorControl Center (hiCC) which, on the loss of off-site power, is supplied by the " A" trainEDG. During inspection 89-09, the inspector reviewed VY's immediate corrective actions inthis matter which included repowering this valve from another htCC on the "A" train; noproblems were identified. The issue was left open pending VY's long-term review andcorrective actions for this design denciency and the possible generic implications of thisevent.

The inspector reviewed VY's review of this incident in a YNSD report dated October 6,1989. VY engineering determined that no similar electrical situations to that identified withvalve RHRSW-89B existed at that time. However, they did Gnd one undesirable condition -a loss of power to h1CC 9D would result in tripping some loads powered from h1CC 8E. Inresponse to this condition, VY initiated Plant Design Change Request 90-10 to correct thissituation. This modification is scheduled to be completed during the 1992 refueling outage.

Based on the inspector's review of this matter, the actions taken by VY in this matter appearadequate. This item is closed.

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6.3 (Closed) Unresolved item 50 271/89-12-01: Final Corrective Actions Associatedwith the RBCCW-il7 Power Supply.

VY determined that the motor nocrated valve (MOV) RBCCW ll7, located on the return lineof the Reactor Building Closed Cooling Water (RBCCW) system from the drywell, should bepowered from an AC emergency power bus versus a non-emergency bus. The inspectorreviewed VY's immediate corrective actions in this matter and determined them to beadequate; however, final corrective actions were not yet implemented, in addition, VY wasrequested to review their response to TM1 Action Plan items (NUREG 0578 Item 2.1.4 andNUREG 0737 Item II.E.4.2)in light of the design of their RBCCW system,

in response to this matter, VY engineering reviewed the design basis for the RBCCW systemand determined the design to be in conformance with regulatory requirements provided thepower supply to the RBCCW-ll7 valve remains on an emergency power bus and that theenvironmental qualiGeations of the valve are upgraded. These actions are being accomplishedunder Engineering Design Change Request (EDCR) 90-408 which is scheduled to becompleted during the 1992 outage.

VY's review of the design logic for the RBCCW-ll7 valve automatic closure on acontainment isolation signal indicates that it meets the intent of NUREG 0'?37 and NUREG-0578 concerning auto-isolation due to the passive isolation provided by the closed RBCCWloop inside contaimnent. Although this line constitutes a non-essential containmentpenetration, the RBCCW serves a valuable post-accident function by providing the capabilityto remove heat inside containment. Thus, because of this function and the passive isolationdesign of this line, VY was exempted from the NUREG-0737 requirement to auto-isolate thisvalve. However, due to the above modifications, the valve will be capable of isolating theline in a post-accident environment if required. This item is considered closed.

7.0 SAFETY ASSESSMENT AND QUALITY VERIFICATION (90712,92700,90713,71707)

7.1 Licensee Event Reports (LERs)

The inspector reviewed the licensee event report listed below and determined that, withrespect to the general aspects of the event: (1) the report was submitted in a timely manner.(2) the descriptic,n of the event was accurate, (3) a root cause analysis was performed,(4) safety implications were considered, and (5) corrective actions implemented or plannedwere sufficient to preclude recurrence of a similar event.

-- LER 91-01: Entry Into a High Radiation Area by a Radiation Protection TechnicianWithout a Dose Rate Mcnitoring Device Due to Personnel Error. (See Section 3.2.4)

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7.2 LER Recapitulntion

The following LER was previously reviewed by the inspector and remained open pendingfurther NRC review.

-- LER 90-01: Inadvertent Primary Containment Isolation System Actuation andStandby Gas Treatment Start Due to Personnel Error.

This event was discussed in NRC Inspection Report 50-271/90-01, Section 7.2. Thelicensee's description in the LER accurately reflected the event. The inspector verified thatthe licensee's proposed corrective actions were both appropriate to the circumstances andimplemented as stated. This LER is closed.

7.3 P;riodic and Special Reports

The plant submitted the following periodic and special reports which were reviewed foraccuracy and the adequacy of the evaluation:

Monthly Statistical Report for December 1990--

Vermont Yankee Cycle 15 Start-Up Test Report dated January 23,1991.--

7.4 Summary Assessment of Audit Report 90-17

Quality Assurance Audit 90-17, conducted during the period of November 26-30,1990 at theplant, reviewed the adequacy of the operating experience and assessment activities and thecorrective action prognm for identined deficiencies. The audit indicated that there areweaknesses in the implementation of VY's corrective action programs, particularly procedureAP 0007, " Corrective Action." In particular, the audit noted that plant personnel apparentlyhave not been adequately trained on AP 0007 and all of the program elements are not beingfully utilized when required. The audit identi0ed four (4) deficiencies to plant managementwhich they are in the process of correcting. None of these deficiencies appear to besignificant nor are they repetitive occurrences of prior recent events, but they collectively

| indicate continuing weaknesses in the implementation of the existing corrective action; program. These are some of the same weaknesses in VY's corrective action programs which

were identified during the previous SALP period. Overall,-the audit found the correctiveaction program to be acceptable, but increased management oversight and support of theexisting program and additional training on procedure AP 0007 is needed.

The inspector reviewed AP 0007 issued on September 6,1990. The procedure was found tobe thorough and comprehensive and to demonstrate a clear commitment by management tostrive for an effective corrective action program. However, given the scope of the"significant" corrective action items which this procedure is to be applied to, many of whichare already handled by existing corrective action mechanisms, the completion of all of the

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actions required by the procedure for all significant items represents a substantial use of VY'sresources. Given this resource requirement, it appears that all of the elements of thisprocedure may not be used for all of the significant items noted in AP 0007. This conclusionappears to be supported by the findings of Audit 90-17 and the inspector discussions withpersonnel familiar with AP 0007. This concern was raised to plant management for theirreview.

Since the completion of Audit 90-17, training on AP 0007 has been provWed to selected VY =

personnel. Further, discussions with plant employees familiar with AP 0007 indicate that theprocedure is being used much more extensively since the completion of the audit. Review ofcompleted AP 0007 reports indicated that plant personnel are using the process in accordancewith the procedure. Overall, the inspector viewed i'rocedure AP 0007 to be a positivecorrective action programmatic improvement which required some assessment of its scope andadditional training by VY personnel to be fully effectively.

The inspector will continue to review the effectiveness of VY's corrective action programs,particularly ongoing improvements in the use of AP 0007, as part of the routine residentinspection program.

7.5 Safety Panuneter Display System Operability

in accordance with NUREG 0737. TAP ltem 1.D.2 and NUREG 0737, Supplement I, VYcommitted in their letter hVY 89 63 dated July 7,1989, to fully implement a SafetyParameter Display System (SPDS) prior to the completion of operating Cycle 14(approximately October,1990). This response provided certification of their plans asrequested in NRC Generic letter 89-06. At its Meeting No. 90-44 on August 13,1990, thePlant Operations Review Committee reviewed the history and system status of the SPDS andrecommended that it be consiriered operable. On August 15, 1990, VY in its letter BVY 90-085 informed the NRC that system testing and operator training had been successfullycompleted and the SPDS was declared operable on August 13, 1999.

The inspector determined from discussions with licensed operators that the availability of theSPDS was considered a beneficial emergency assessment capability. However, the loss ofoperability of this system was not considered to constitute a 10 CFR 50.72(b)(i)(v) reportableevent (i.e., any event that results in a major loss of craergency assessment capability, off-siteresponse capabbity, or communications capability). The inspector brought this matter to theattention of the Operations Supervisor (OS) and discussed the relevant NRC guidance laNUREG 1022, Supplement I, " Licensee Event Report System." Noting that plant procedureAP 0156, " Notification of Significant Events," provided no guidance on the subject of loss ofSPDS operability, the OS informed the inspector that the matter would be reviewed anddispositioned.

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; Plant procedure AP 0156, Revision 14 was issued on January 11 and specified that loss of theSPDS for greater than eight hours constituted a one hour rervrtable event. The inspectordetermined that this guidance to the plant operators was consistent with NRC guidance andhad no further questions on this subject.

8.0 h1 ANAGEhlENT SIEETINGS (30703, 94600) |

8.1 Preliminary inspection Findings

At t>eriodic intervals during this inspection, meetings were held with senior plant managementto discitss preliminary inspection findings. A summary of findings for the report period wasalso discussed at the conclusion of the inspection and prior to report issuance. No proprietaryinformation was identified as being included in the report.

8.2 Region liased Inspection Findings

One Region based inspection was conducted during this inspection period. Inspectionfindings were discussed with senior plant management at the conclusion of the inspection.

Date Subject Rpt, # Inspector

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1/28 - 2/1/91 Routine Physical Security 91 41 R. Alpert

8.3 Information Afecting with local Officials

An information meeting was held on January 31 between three of the five Selectman of theTown of Vernon, VT, the NRC Region 1 Chief of Reactor Projects Branch 3, and the seniorresident inspector. This meeting informed the local officials of the mission of the NRC,introduced key NRC personnel associated with the VY facility, discussed lines ofcommunication between the local officials and the NRC, and discussed the status of thefacility and related community issues with the local officials.

The meeting was viewed as being mutually beneficial, and was helpful in identifying a fewareas where the NRC could assist the local officials in fulfilling their responsib:i nes to thetown.

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