BVY-92-119, Forwards Revised Response to Weaknesses Noted in Insp Rept 50-271/92-80 on 920224-28.Corrective Actions:Plan to Update Procedure Generation Package,Revise OEs & Other Plant Operating Procedures & Incoporate Updates to EOPs

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Forwards Revised Response to Weaknesses Noted in Insp Rept 50-271/92-80 on 920224-28.Corrective Actions:Plan to Update Procedure Generation Package,Revise OEs & Other Plant Operating Procedures & Incoporate Updates to EOPs
ML20115C211
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 10/13/1992
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-92-119, NUDOCS 9210190217
Download: ML20115C211 (11)


Text

'

H VERMONT YANKBE NUCLEAR POWER CORPORATION

.- Ferry Road. Brattleboro, VT 05301-7002 t

ENGINE IN OFFICE N -

08? Mud S1fG E T BOLTON tM 01740 S 081770 4711 October 13,1992

BW 92119 l

!. U.G. Nuclear Regulatory Commission-

. Washington, D.C. 20555

! Attention: Document Control Desk l

References:

a) License No. DPR 28 (Docket No,50 271) b) Letter, USNRC to WNPC, inspection Report 92 80. NW 92 059, dated '

4/14/92 c) Letter. WNPC to USNRC, BW 91071, Response to inspection Report

. 92 30, dated 6/22/92 i d) Letter, USNRC to WNPC, Emergency Operating Procedures (EOP)

{ inspection Response Meeting . Inspection Report 50-271/92 80, NW t 92145, dated 7/30/92

Dear Sir:

Subject:

Revised Response to inspection Report 92 80 4

This letter is written to provide a revised response to the weaknesses id$ntified by an NRC Emergency Operating Procedure (EOP) Inspection Team during the special announced safety

,L inspection conducted from February 24 to February 28,'1992, and documented in Reference b).

Included in this submittal ls the additional information on specific actions Vermont Yankee plans to take on each of the issues identified during our meeting, held at the NRC Region 1 office on July 14,1992

[ and documented in Reference d),

information is submitted in tto accompanying attachments in response- to..?'le ' identified

. weaknesses in (1) the technical adequacy of the Vermont Yankee Plant Specific Technk:al Guidelines '

(PSTGs), EOPs, Reactor Pressure Vessel Control guideline and (2) the EOP programmatic controle es '

.. noted in Sections 3.1,3.2,3.3 and 4.2 and Sections 6.1 and 6.2, respectively, of Reference b).

g it is our intent to fully resolve allissues related to bot. .ne specific weaknasses identified by the i NRC inspection as well as those arising from our own root cause analysis, within an updated Procedu,3 Generation Package (PGP), revised OE's and other plant operating procedures, Further, we will pursue -

resolutions of any appropriate generic iterrs by continued participation in the cognizant industry groups such as the BWROG Emergency Procedures Committee and the NUMARC Severe Accident Working:

Group.

i 1GGOGU A b e 9210190217 921013 PDR. ADOCK 05000271 I Y'

G- PDR

= , - . ~ -. - . _ - . - .x . - .- ,

VERMONT VANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission October 13,1992 Page 2 We plan to incorporate the updates to the PGP and the EOPs, including correction of deficiencies concerning OE 3100, " Scram Procedure", and the "Torue Temperature Control

  • guideline, such that they mey be used for training beginning in February 1993, implementation will be completed and revised procodures issued, following completion of aperator training in 1993. Also, as agreed earlier, a sufficient quantity of borax required by OE 3107, Appendix J, has been obtained.

We believe that the actions proposed are responsive to your concerns; however, s,nould you have any further questions, please do not '1esitate to contact us.

Very truly yours, Vermont Yankee Nuclear Power Corporation jfja /' W Warren P. f rphy '

Senior Vic President, . . [lons cc: USNRC Region i Administrator USNRC Resident inspector - VYNPS IJSNRC Project Manager VYNPS

j

  • i .

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1 j ROOT CAUSE ANALYSIS i AND I

CORRECTIVE ACTION PLAN i- i i  !

l f

SUMMARY

OF NRC FINDINGS RELATIVE TO TECHNICAL ADEQUACY:

I j Discrepancies were identified in the VY PSTGs that detract from the' technical adequacy of the VY

> accident mitigation strategies. Additionally, t.ome problems were noted with the technical adequacy

!' of the EOPs and EOP support precedures, including some minor inconsistencies between the VY PSTGs

, and EOPs. The technical adequacy of the VY PSTGs, EOPs and EOP support procedures is considered j to be unresolved pending licensee review an:1 resolution (Sections 3.1,3.2, and 3.0).

VY RESPONSE: -

l Sections 3.1,3.2, and 3.3 of the inspection report contain a total'of 45 comments. Two of these l comments were resolved and. require no further licensee action an a result of our July 14,.1992 i l meeting and documented in Reference d). Vermont Yankee will resolve the remaining weaknesses, .

! criticisms, or acceptable alternatives to our current technical justifications by appropriate revision of  ;

I the PGP's, OE's and support procedures as identified in the attached matrix and supporting attachment  ;

- " Amplifying Information to NRC Comments", implementation will be completed and revised procedures issued, following completion of operator training in 1993.

f.

l ROOT CAUSFJ I

j We have conducted our review of the identified vreaknesses and have determined that there is no .

j single root cause for their occurrence. Some were' due to insufficient management oversight and l others were due to weaknesses in the qualit</ control process. The majority of the issues identified

! as weaknesses have as their root cause the lack of clearly defined standards regarding what constitutes sufficient justification for deviation from generic emergency procedurs guidelines.

We believe the standards have and will continue to evolve with practice and time as both the NRC and I

industry gain experience wits. .a issues. Fur example, as noted in the inspectica report, Vermont -

! Yankee's EOP program was much improved as a result of response to inspection findings (USNRC i inspection Report No. 50-271/01 02) as well as our own initiatives derived from the guidance provided

! in NUREG 1358, (" Lessons Learned From the Special inspection Program for Emergency Operating

[ Procsdures').

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SUMMARY

OR NRC FINDINGS RELATIVE Tr' PRQQBAMMATIC WEAKNESSES:

Weaknesses in the orogram have resulted in EOP appenC
es and support procedures that are not of .

l the same high quality (as the flowchart procedures).  ;

l The programmatic controls do not appear to be effective for ensuring that tools and materials will be

! available to support implementation of the EOP support procedures.

t

! These weaknesses in the EOP programmatic controls are considere'd to be unresolved pending licensee -

l review and resolution (Sections 6.1 and 6.2),

V -

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l VY RESPONSE:

An OE appendix writers guide will be developed in accordance with the criteria established in NUREG 0899, and incorporated into Vermont Yankee's PGP. In addition, the Verification and Validation programs will be revised to include the appropriate criteria when applied to OE appendices and support procedures, and will address the utilization of multhdisciplined teams during procedure development.

Appropriate surveillance checklists for tools and materials will De developed and controlled via administrative procedures. Scheduled surveillance intervals will be established basnd on past experience with similar tool and material control processes. Implementation will be completed and I revised procedures issued, following completion of operator training in 1993.

ROOT CAUSE:

The root cause for the programmatic weaknesses which resulted in EOP appendices and support pro.:edures not being of the same high quality as the flowchart procedures, has been determined to be due to a change in the m tod for preparation of OE appendices which did not require a review equivalent to the flowchart d6. atopment process._ A contributing cause was the erroneous assumption that, as with other procedures, there would be adequate exercise of the OE appendices and support procedures by operators during training and practice to provide additional verification and validation via the procedure change suggestion process. In addition, specific ouidance was not provided in the procedure writers guide for development of OE appendices in accordance with Vermont Yankee's PGP.

The root cause for failing to' ensura the availability of tools and materials needed for EOP implementation has been determined to be inadequate administrative controls. In the past, l uncontrolled checklists have been utilized for surveillance of materials and tools necessary for

. iraplementation of OE appendices, in addition, there was no provision for ensuring that review and

! timely revision of the checklists were performed when necessitated by EOP or support procedure

! changes.

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. I NRC SECTION #1- COf1PARISON OF BWROG EPGs & VY PSTGS -

[

,f COMMENT TYPE . . t

. t SECTION' TITLE REVISE REVISE REVISE REVISE OTHER f TFCH FORMAT PSTG DIFF-1 DIFF-2 OE(s)

A.1 Transitions from Other Gui.delines X X X X l  !

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A.2.a Injection Thru the RHR Heat Exchangers I X X X

[

t A.3.a Override to Repoen MSIVs X X- X X l A.3.b- ' Initiation of Shutdown Couling X X X X REV OP 0109 I A.4.a Initiation'of Alt Rod Insertion & Reset X X- X A.4.b -Increasing CRD Differenti11 Pressure X 'X X X N E'ei EOP APP f

5 B.1.a RPV Depressurization X X X X f B.2.a Def eat ing Isolatien Interlocks X X i D.3.a Termination of Injection at Vacuum Bkr Elev X -X X X D.3.b Termination of Inject for Primary Containment X X X X ,

Water Level Limit

-[

B.4.a Override Statement' X '

X t

B.4.b- Air Purge X X X X X C. l ' Entry Ccnditions X -X X REVISE ARPs I C.2 Secondary Containment Vent. Override X X X X C.3.a Operation of Available RB Ventilation '

. 'X X X I C.4.a Floor Drain Sump Water. Levels X X X X D.I'~ Emerpncy Depressurization X X f

.I E.1.a. Inhibit ADS' X X X X

[

E.1.b Spray Cooling X X X X ,

i E.lic Transition from Spray Cooling to Steam Cooling X X X  !

'E.2.a Termination & Prevention of Injection X '

ISSUE CLOSED E.2.b ' Defeating Interlocks X X 'X X NEW EOP APP E.3.a I i RPV Wtr Lvl Below Min Stm Cool Wtr Lvl X 'X j E.3.b Transition to Primary Containment Flooding- X X X X ,

E.4.a RPV Venting :X l X X X X N E'd EOP APP l

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- . = . - - , - . _ . - . . . - - _ . .-..__...-..._.n. - . . . - ~ _ . - . . - - . - . - . ~ . . . . - - . . . - . . _ _ . . _ - _ . . . - - _ - .

NRC SECTIO:! #2 CONPARISON OP VY PSTGS & VY EOPS ,

COMMENT TYPE .

i-

)- SECTION. TITLE REVISE REVISE REVISE REVISE j TECII FORMAT PSTC DIFF-1 DIFF-2 OE(S) OTHER A.1 ,

Shutdown conditions X X j B.1 Entry Conditions-RPV Water Level X X X j- Cannot be Determined i I

B.2.a Override-Transition to Level / Power X X X .j

.. control  ;

B.2.b Injection Through The RIIR fleat X X X X REVISE OP 2124 -l Exchangers l B.2.c Use of Alternate Injection Systems X X B.3.a fleat Capacity Temperature Limit & X X X REVISE OE 3100 SRV Tall Pipe Level Limit B.3.b RPV Depressuritation X REVISE OP OIO9  !

- B.4.a Defeating RPS Logic Trips X X i l

C.1.a Suppression Pool Temperature X. X X X j Control j- C.2.a Primary Containment Pressure X X X

D.1 Ifigh Reactor Building Differenti&1 X X X REVISE ON 3153, 3158 & j l . Pressure Entry Conditions CP 2116 i t

D.2.a 9. Floor' Drain Sump Water' Levels X X X X

} REVISE ARS(s)

{ E.1.a Transitions from Other Guidelines X ,

REVISE STUDY GUIDE E.2.a RPV Water Level Above the Minimum X ISSUE CLOSED  ;

Steam Cooling RPV Water Level  ;

t l- E.2.b Exit from Level Power Control X { X ,

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NRC SECTION #3 TECllNICAL. ADEQUACY OF EOPS & SUPPORT PROCEDURES .

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  • . COMMENT TYPE SECTION TITLE TEC11 FORMT," REVISE LEVISE REVISE REVISE PSTG DIFF-I DIFF-2 GE(s) OTI!ER A' Primary Containment Water X CHANGE DRYWELL IIIGH WATER Level Indication LEVEL ALARM SETPOINT B Isolation of Systems X REVISE ON 3153 & 3158 Discharging Into Secondary Containment c' Emergency RPV X X NEW EOP AP.'ENDICES Depressurization with Alternate Systems D' Control Rod Insertion X REVISE OP OID9 E Throttling Fire Water X X Injection _

NOTE: (I) ' PG D APPENDIX A: PLANT. SPECIFIC TECIhiICAL GUILDEIN (PSTG)

(2) 'PGP APPENDIX E: EPG TO PSTC DIFFERENCES (DIFF-1) 43). PGP APPENDIX F: PSTC TO JE DIFFERENCES (DIFF-2)

- - - - . -- - .. . . . . . - . ~ . .- -- --.-. .~.- . - . . _ - - . . . . - . - ~ .-= .-.- .- - .- - . . . .

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AMPLIFYING INFORMATION TO NRC COMMENTS NRC SECTION #1: COMPARISON OF BWROG EPGs & VY PSTGS i

SECTION TITLE BRIEF DESCRIPTION OF CORRECTIVE ACTION  ;

i

.A.1 Tranal" Lons f rom Other Guidelines Revise PSTG to specify transition to RP.' Control (OE 3101) '

Remove previous justification from Diff-l and justify OE tranention to OE 3100 (Scram Procedure) in Diff-2.

A.2.a Injection Thru the RitR Heat Exchangers Revise PSTC to agica with EPGs, remove previous justification from Diff-l and justify the use of the operating procedure in  ;

Diff-2. ,

A.3.a Override to Reopen MSIVs The bypassing of the high steam flow not in Run isolation i interlock will be removed f om the PSTG. Diff-1, OE 3101 and I, Appendix P will be modified to reflect change.

A.3.b Initiation of Shutdown Cooline, Revise PSTG to agree with EPGs; Diff-l will be changed to reflect change; the use of OP 0109 will be justified in Diff-2 and OP 0109 will be revised to provide direction as to when to shutdown to cold S/D.

N A.4.a Initiation of Alt rod Insertion & Rrsat The PSTGs and OEs will be revised to agree with EFGs.  !

A.4.b Increasing CRD Differential Pressure 3evise PSTG to agrae with EPGs; .the previous justification in i Diff-l will be deleted; the OEs will be changed to agree with the PSTGs and a new appendi- will be written with direction for increasisig cooling wate: -Jelta P.

B.l.a RPV Depressurization Rather than reliance on training, provide decision step which requires operator to determine if an ATWS condition exists prior to proceeding with depressurization in accordance with

, Tech. Specs. This will require revision of PSTG, Diff-l and EOPs.

8.2.a Defecting Isolation Interlocks Additional justification will be prcvided in Diff-3 utilizing existing design basis information.

B.3.a Termination of Injection at Vacuum Rkr Elev The PSTG will be revised to agree with the EPGs; Diff-l i

, , justification will be deleted and OEs changed to a;ree with I i

.STOs.

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, ., B.3.b Termination of Injection for Primary The PSTGs will be revised to agree with the EPGs; Diff-l

e containcent water Level Limit justification will be de leted and OEs changed to agree with 2

PSTGs. f B.e.a override Statement Revise Diff-l to streng: hen justification for not assuming unknown concentrations are above deflagration limits. t e

m , -

I B.6.b Air Purge The PSTG will be revised to agree with the E/Gs and Diff-l js.stification deleted. The OE will be changed to permit air  !

purge with TSC concurrence and revise Diff-2 &o justify )

difference between PSTG and OE. l C.1 Entry Conditions Move justification for differences to Diff-2 from Diff-l and revise alarm response procedures to include appropriate I accident mitigation strategy action steps.

C.2 Secondary Containment Vent. Override Revise PSTG to agree with EPGs, delete previous justification in Diff-l and change OEs to agree with PSTGs.

C.3,a Operation of'Available RB Ventilation Revise PfTG to agree with'EPGs and move justification from Diff-1 to Diff-2.

c.4.a Floor Drain Sump Water Levels Revise PSTG to agree with EPM and move justification from Diff-l to Diff-2 "D.1 En.ergency Depressurization Iaprove justificaticn in Diff-l E.1.a Inhibit ADS Revise PSTG to agree with EPGs; delete previous justification from Diff-l and revise OEs to agree with PSTG.

Spray cooling Revise PSTG to agree with EPG logic, delete previous E.1.b justification from Diff-l and change OE to agree with PSTGJ

' Transition from Spray Cooling to Steam Cooling Revise PSTGs and OEs to indicate transition to Primary E.1.c. Containment Flooding.

".ermination & Prevontion of Injection The comments relative to this issue were resolved at the July E.2.a 14, 1992 meating'with the NRC, no further action required.

Defeating Interlocks Revise PSTG and Ods tc, allow isolation interlocks to be E.2.b defeated and delete previous justification in Diff-1. A new appendix will be developad with direction on accomplishing the bypa*ssing.

Revise Diff-l to it.clude additional / complete and detailed E.3.a RPV Wtr Lvl Below Min Stm Cool Wtr 1.vl justification.

Transition to Primary Containment Flooding Revise PSTG to agree with EPG; delete previous justification E.3.b in Diff-l and revise OE to agree with PSTC.

HPV Venting Revise PSTG to agree with EPG; delete previous justification E.4.a from Diff-1;. revise Diff-2 to justify venting w/TSC conc.arrence; revise OEs to use MSIVs to vent and write new appendices for using systems to vent. l

( _

_ _ _ - - _ _ _ . = . = - . . .......:-. .- . - .

AMPLIFYING INFORMATION TO NRC iTKMENTS .

i NRC SECTION #2 COMPARISON OF VY PST* S & VY EOPS '

'SECTION TITLE BRIEF DESCRIPTION OF CORRECTIVE ACTION ,

4 .

A.1 Shutdown Conditions Ravise applicable steps in the OEs to stete that..."the reactor is and  ;

will remain shutdown as indicated by any of the following condit ions:" -

j B.1 Entry Conditions-RPV Water Level Revise Dif f-2 to expl ain philosophy of using scram procedure (OE 3100) and Cannot be Determined revise vE llOG and Appendix A to include "RPV water level cannot be determlaed" as a scram condition.

B.2.a override-Transition to Level / Power Revise Dif f-2 to explain philosophy of using scram procedure (OE 3100) and 1

i l Control- revice OE 3100 to include override. , i

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U.2.b Injection Through The RHR Heat Revise PSTG to agree W/TPG, then' justify in Diff-2 using the operating j

Exchangers procedure and revise operating procedure. ,

B.2.c Use of Alternate Injection Systems Revise OE to agree with PS*^

D.3.a Heat capacity Temperature Limit & The scram procedure (OE 33: will be revised to include override and SRV Tail Pipe Level Limit Diff-2 will be revised to celete previous justificaiten. -

B.3.b , RPV Depressurization Rcvise OP 0109 to permit RPV depressurization regardless of main condenser  !

availability, no other changes necessary. {

B.4.a Defeating RPS Logic Trips Revise OE 3101 and OL 3107 to agree with PSTG. f C.I.a Suppression Pool Temperature Rather than reliance on tr&ining, provide decision step which requires f Control operator to determine if an ATWS condillon e lets prior to proceeding with j depressurization in accordance with Tech. Specs. This will regteire '

revision of PSTG, Diff-l and EOFe.  ;

1 C.2.a p {.imary Containment Pressure Revise PSTG to ray Drywell and expla8n in Diff-1.

D. l' High Reactor Building Differential Revise OE to more closely agree with PSTG and change Diff-2. OP 2116, ON I Pressure Entry conditions 3153 and'3158 will be revised to contain direction from PSTC.

D.2.a Floor Drain Sump Water Levels Revise PSTG to agree with EPG; delete previous justification in Diff-1; Revise Dif f-2 to justify use of Alarm Response Procedures (ARPs) and  !

i- revise ARPs to provide direction per PSTG. l E.1.a Transitions from Other Guidelines Revise study guide to incorporate expectations on use of transitions.  !

E . 2 . a.. RPV Water Level Above the Minimum Comments resolved & require no licensee artic 7/14/92 mtg w/NRC i

Steam Cooling RPV Water Level
;

e E.2.b Exit from Level Power control. Revise Diff-2 to provide improved justification.

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AMPLIFYVNG INFORMATION TO NRC COMMENTS ,

NRC SECTION #3 TECliNICAL ADEQUACY Of EOPS & SUPPORT PROCEDURES

  • SECI,8jN TITLE BRIEF DESCRIPTION OF CORRECTIVE ACTION A Primary Containment Water The L'rywell high water level alarm setpoint will be changed to provide -

Level Indication indication consistent with OEs.

B Isolation of Systems Procedure ON 3153 and 3158 will be changed to agree with OEs. j-Discharging Into-Secondary Containment . _ l-C Emerger y RPV OEs will be revised to reference new appendices and new apyndices will be Depressurization with written to address alternate systems.

Alternate Systems D Control Rod Insertion OP 0109 will be revised to direct insertion of any rods that may be withdrawn even if already shutdown.

E Throttling Fire. Water Revise OE 3107 to indicate correct valve to be used for control.

' Injection I l

NOTE: (1) PGP APPENDIX As PLANT SPECIFIC TECffNICAL CUILPEIN (PSTG) l (2) 'PCP APPENDIX E EPG TO PSTG DIFFEREN2S (DIFF-1) l

'(3) PCP APPENDIX 7: PSTG TO OE DIFFERENCES (DIFF-2)

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