BVY-93-148, Presents Current Status of TS Surveillance Evaluation Initiated in Sept 1993 in Response to Concerns Identified by NRC & Util Re Implementing Procedures for TS Required Surveillances

Presents Current Status of TS Surveillance Evaluation Initiated in Sept 1993 in Response to Concerns Identified by NRC & Util Re Implementing Procedures for TS Required Surveillances

ML20059E438
Person / Time
Site:	Vermont Yankee
Issue date:	12/30/1993
From:	Reid D VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-93-148, NUDOCS 9401110166
Download: ML20059E438 (2)

Text

l

\ .

g

. . w.

VERMONT YANKEE NUCLEAR POWER CORPORATION

\

s Ferry Road, Brattleboro, VT 05301-7002 REPt.Y TO ENGINEERING OFFICE M' 580 MAIN STREET BOLTON, MA 01740 (508) 779 6711 December 30,1993 BW 93-148 U.S. Nuclear Reguiatory Commission ATTN: Document Control Desk Washington, D.C. 20555

References:

(a) License No. DPR-28 (Docket No. 50-271)

(b) Letter, WNPC to USNRC, BW 93-102, dated 8/19/93 (c) Letter, WNPC to USNRC, BW 93-87, dated 7/16/93 (d) Letter, WNPC to USNRC, BW 93-069, dated 7/2/93 (e) Letter, USNRC to WNPC, NW 93-198, dated 11/18/93

Subject:

Technical Specification Surveillance Self Evaluation Status The purpose of this letter is to present the current status of our Technical Specification surveillance evaluation. This self-assessment was initiated in September in response to concerns identified by both the NRC and us regarding implementing procedures for Technical Specification required surveillances. Its focus is to ensure that our procedures adequately implement the Technical Specification surveillance requirements.

The scope includes a comprehensive and thorough review of each Technical Specification surveillance section and the associated implementing procedures.

The evaluation process employed structured data sheets prepared for each Technical Specification implementing procedure to assure a comprehensive and focused review. These data sheets required a team cf knowledgeable engineers who served as independent evaluators to consider the following parameters for each implementing procedure:

is the T.S. Identified?

is the test frequency correct?

Is ownership clearly established?

- Are administrative limits provided?

Is the acceptance criteria appropriate?

Is direction provided when acceptance criteria is not met?

Are test results documented and retrievable?

!s the intent of the T.S. met?

- is the correct instrument number specified?

Are measuring and test equipment requirements appropriate?

Are plant instruments identified and appropriate?

Has instrument accuracy been addressed?

- Are assumptions correct?

Is the test consistent with T.S. interpretations?

O70..;

9401110166 931230 PDR P

ADOCK 05000271 ppg i

g; POI II '

s ,,

VUWONT YANKu NUCI LAR POMR CORPORATION U.S. Nuclear Regulatory Commission Decem,ber 3U,1993 Page 2 Where appropriate, comments were developed which address potentiallmprovement opportunities for procedure, Technical Specifications, surveillance schedules, and supporting documents. Each potential improvement opportunity identified by the evaluators was cataloged in a data base file along with the surveillance number, procedure number, test description and component (s) tested.

Our evaluation of T.S. Section 4.2 has been completed and has concluded that every requirement is currently being adequately addressed by our surveillance test schedule and implementing procedures.

Although many procedure and Technical Specification improvement opportunities were found to exist, no instances of Technical Specification non-compliance were identified.

Section 4.2 of the Vermont Yankee Technical Specifications was selected as the first section for this evaluation because Section 4.2 was considered to be the most challenging and represented approximately '

twenty percent of all Technical Specification (T.S.) surveillances. Our review of Section 4.2 has enveloped a total of 227 surveillance tests and 71 implementing procedures. In excess of 500 man-hours have been dedicated to this evaluation to date.

Our evaluation process assigned a unique ID number for each T.S. surveillance requirement and cataloged the ID number in a data base file. After all procedure review data were entered, the file identifying the surveillance tests being implemented by plant procedures was compared with the file containing the assigned T.S. ID numbers. In this manner, any T.S. requirement not being addressed by a procedure would be easily identified. This valuable matrix of T.S. ID number vs. plant procedure number confirmed with one relatively minor exception, that each Section 4.2 surveillance requirement was being addressed by Vermont Yankee implementing procedures. The one exception that was identified, was being scheduled, performed and documented but no formalimplementing procedure was provided. A formalimplementing procedure for this particular surveillance has since been developed.

Data base " sorts" of implementing procedure enhancement and Technical Specification improvement opportunities have also been developed. These enhancement and improvement opportunities typically include recommendations to improve clarity and documentation, as well as unresolved items which require further evaluation by the surveillance owner. The improvement opportunities have been forwarded to the Plant Manager for dispositioit.

Our comprehensive review of the remaining surveillance sections of the Technical Specifications is continuing and is expected to be completed in the first quarter of 1994. In response to our meeting scheduled by Reference (e), we have also completed a review of all other sections of our Technical Specifications. This review confirmed that the inspection and testing currently being performed adequately demonstrates the design basis operability condition. The improvement opportunities resulting from that review have also been forwarded to our Engineering staff or to the Plant Manager for disposition.

I trust that this information is helpful; however, should you have any questions or require additional information, please do not hesitate to call.

Sincerely, VERMONTYANKEE NUCLEAR POWERCORP.

k[

Donald A. Reid f

Vice President, Operations cc: USNRC Region 1 Administrator USNRC Resident inspector - VYNPS USNRC Project Manager - VYNPS

-