IR 05000271/1993031

Insp Rept 50-271/93-31 on 931115-19.No Violations Noted. Major Areas Inspected:Personnel Interviews,Surveillance Test Observations & Independent Exam of Selected Procedures, Records & Documents

ML20058Q163
Person / Time
Site:	Vermont Yankee
Issue date:	12/20/1993
From:	Conte R, Hansell S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058Q151	List: IR 05000271/1993031 ML20058Q150
References
50-271-93-31, NUDOCS 9312280107
Download: ML20058Q163 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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DOCKET NO: 50-271

REPORT NO: 50-271/93-31 LICENSE NO: DPR-28

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FACILITY NAME: Vermont Yankee Nuclear Power Station RD 5, Box 169 -

Ferry Road Brattleboro, Vermont 05301

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INSPECTION AT: Vernon, Vermont INSPECTION CONDUCTED: November 15-19, 1993 INSPECTOR: Sam Hansell, Operations Engineer 70 f'bl9,7 .

INSPECTOR: . #71 t S. L. Hansell, Operations Engineer Date BWR Section, Operations Branch .

Division of Reactor Safety

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l APPROVED BY: c < f ,

MN M /NWh I Richard J. Conte, Chief Date BWR Section, Operations Branch  ;

Division of Reactor Safety

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9312280107 931221 gDR ADDCK OSOOO271 PDR,, .

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. Insoection Summary: Insoection from November 15-19. 1993 menort No. 50-271/93-31)

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Areas Inspected: The inspection objectives were to determine the safe opemtion of the plant by conducting personnel interviews, surveillance test observations, and independent [

examination of selected procedures, records and documents. The review was focused on the surveillance activities scheduled the week of the inspection and selected review of safety- !

related surveillance test procedures and dat l The purposes of the inspection were threefold. The first was to determine whether the ;

surveillance testing of safety-related equipment is conducted in accordance with approved l plant procedures as required by technical specifications (TS) and the inservice test (IST) .;

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program. The second was to review the facility's corrective actions from the OSTI's noted IST program weaknesses. And the third was to review open items related to the reactor recirculation jet pump technical specification surveillance, removal of high pressure j feedwater heaters from service, and chemistry technician training qualificatio Rentlis: The observed surveillance testing of safety-related systems and components observed this inspection was conducted in accordance with approved plant procedures and ;

technical specifications. The personnel followed the surveillance test procedures, accurately collected and analyzed the test data, and completed the closcout documentatio In general, the inservice test (IST) program for pumps and valves was implemented in !

accordance with approved plant procedures. The revised IST program procedure guidance :

provides clear responsibility and direction for the plant personnel who perform, schedule, ,

and track the surveillance tests. Each department surveillance test _ coordinator demonstrated ;

a detailed knowledge of the IST program and a positive ownership for their surveillance i responsibilities. The revised surveillance test program procedures contain improved and detailed information for program implementation. However, a weakness was noted for the tracking of safety-related pumps that required an increased frequency surveillance test. Plant ,

personnel ensured the proper surveillance frequency was performed instead of using an approved procedure change form to update the computer automatic tracking syste The recent program upgrades adequately addressed all of the OSTI's noted program i weaknesses. The changes included the following: (1) the surveillance program {

implementation was strengthened to provide better overall program control; (2) the shift '

supervisor was included in the review and acceptance of surveillance test data; and (3) the I

engineering department was provided more input to the IST program changes. The IST unresolved item was closed based on the facility's satisfactory corrective actions (271/93-80-01).

Three open items were closed related to the reactor recirculation jet pump technical specification surveillance (271/93-12-01), removal of high pressure feedwater heaters from l service (271/93-23-02), and chemistry technician training qualification (271/93-23-01). All l three open items referenced above were closed based on the facility's satisfactory corrective t

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actions (sections 4.2,4.3, and 4.4 respectively).

The licensee's TS review program (discussed in letter BVY 93 069) warrants further review ;

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(271/93-31-01).

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DETAILS INTRODUCTION AND OVERVIEW The inspection was conducted in accordance with NRC Inspection Procedure 61700,

" Surveillance Procedures and Records." The standards applied for this inspection were the American National Standard (ANSI N18.7-1976/ANS-3.2) and American Society of Mechanical Engineers (ASME),Section XI,1987. The review was focused on the surveillance activities scheduled the week of the inspection and selected review of safety-related surveillance test procedures and data. This inspection was a followup to the Operational Safety 'leam Inspection (OSTI) conducted between June 7 and July 2,199 The plant recently implemented its third ten-year cycle of the inservice test (IST) progra l The inspector reviewed the implementation of the IST program. The engineering department ,

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provides the program oversight of the IST program. The operations department and

maintenance department share in the implementation responsibilities of the IST progra l The purposes of the inspection were threefold. The first was to determine whether the surveillance testing of safety-related equipment is conducted in accordance with approved plant procedures as required by technical specifications (TS) and the inservice testing program. The second was to review the facility's corrective actions from previously noted IST program weaknesses. The third was to review open items related to the reactor recirculation jet pump technical specification surveillance, removal of high pressure feedwater heaters from service, and chemistry technician training qualificatio .0 011SERVATION OF SURVEILLANCE TESTING Scope The inspector observed the performance of surveillance testing by operations, instrumentation and control (I&C) and mechanical maintenance personnel. The observations included the l following: content of the surveillance procedure, surveillance test data collection, plant

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equipment response, and the surveillance test documentation closcout. The r:: view was to determine if personnel followed procedures, adequately coordinated the surveillance test activity, equipment operated as designed and surveillance test data was properly evaluated for the acceptance criteria. Attachment I contains the list of surveillance tests observed by the inspector.

I Findings The surveillance tests were coordinated between the plant surveillance test coordinator and individual department surveillance coordinators. The Maintenance Planning and Control (MPAC) computer provides each departments' required surveillance tests each week. The department surveillance coordinator assigns and tracks the completion of their responsible surveillance _______-________ _ _ __

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The inspector observed the scheduled performance of surveillance procedure OP-4126,

" Diesel Generators Surveillance," to determine if the procedure adequately demonstrated ,

system operability as required by TS 4.10.A.l. The operators coordinated and controlled the

"B" emergency diesel test from the main control room. The diesel was started and operated as designed and the test demonstrated satisfactory system operabilit The operators followed the approved surveillance test procedure as written. The procedure '

contained sufficient detail and was easy to follow. The performance data was properly documented by the operators and accurately reviewed by the shift engineer (SE) and shift supervisor (SS).

The inspector performed a local observation of the diesel fuel oil transfer pump surveillance test. The operators adjusted the diesel fuel oil transfer pump flow and pressure locally as .

required by the surveillance test procedure. After the pump reached steady state [

performance values, the mechanical maintenance personnel obtained and recorded the pump and motor vibration readings. The pump and motor were marked properly to ensure ,

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consistent collection of the vibration data for each test. The vibration instrument was calibrated and used correctl .

The dicsci fuel oil pump test was stopped due to a broken stopwatch. The stopwatch was being used to collect total pump run time. The test was properly stopped when the operators recognized and reported the faulty stopwatc The inspector observed two I&C technician surveillance tests in the control room. The two !

tests were OP-4352, "RHR Pump Discharge Pressure Functional / Calibration," and OP-4326,

" Reactor Building Ventilation and Refueling Floor Radiation Monitors Functional." The I&C department had dedicated personnel performing surveillances for the wee The I&C technicians received operations approval prior to starting and upon completion of each surveillance test. The I&C tests were well coordinated between the control room and field personnel. Direct communications were maintained at all times to ensure the control room and field personnel were on the same procedure ste The I&C surveillance test (ST) procedures were descriptive and provided written guidance for each specific switch or test component manipulation. The I&C technicians followed the ;

ST step by step with the procedure in hand. The ST performance steps were followed by the corresponding data collection steps. The surveillance documentation was completed on a separate data collection shee In one instance, the I&C technicians recognized a discrepancy between the surveillance I

procedure expected response and the data sheet requirement. Surveillance test OP-4326, step 67, listed alarm 9-3-R-9 as the correct annunciator. The OP-4326 data sheet incorrectly I

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5 i listed the expected alarm as 9-3-R-7. The problem was immediately identified by the I&C i technician who was verifying expected overhead annunciator alarms. The I&C personnel documented the problem and provided a procedure change request to correct the problem for the next procedure revisio The 1&C test equipment was calibrated and controlled in accordance with the approved plant procedure. The I&C department also controlled and maintained the test equipment for most ,

of the operations surveillance tests. This system appeared to work well as noted by the up to date calibration of equipment used for all observed test .3 Conclusions The surveillance testing of safety-related systems and components was conducted in accordance with approved plant procedures and technical specifications applicable to this inspection. The personnel followed the surveillance test procedures, accurately collected and analyzed the test data, and completed the closcout documentation. The surveillance test procedures contained sufficient detail and were easy to follow. The surveillance test equipment was calibrated and controlled in accordance with the approved plant procedur Appropriate corrective action was taken for the OP-4326 data sheet erro .0 PROGRAMMATIC REVIEW OF SURVEILLANCE TESTING Scope The inspector reviewed selected aspects of the Vermont Yankee surveillance program. The review of surveillance areas included the in-service test (IST) program, implementation of the ,

program activities, adequacy of program procedures, and the computerized surveillance j

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tracking system. The review focused on the OSTI team's noted weaknesses related to the surveillance progra In summary, the OSTI previously noted the following program weaknesses: the surveillance ;

program appeared fragmented, procedural guidance was not clear, justifications to establish j

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new pump baseline data were weak, and the single reviewer for IST data acceptability (shift engineer) has resulted in past problems. The licensee's OSTI corrective action results are I noted belo ! Fmdings 3.2.I Surveillance Program Procedure Review The inspector reviewed the three recently rev; sed plant procedures that provide the !

surveillance program written guidance. Procedure AP-4000, " Surveillance Testing Control,"

provides the overall implementation and program direction. Procedure AP-164, " Operations l

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1 Department Inservice Testing," provides the operations department program responsibilitie And procedure AP-0211, " Predictive Maintenance Progmm," provides the maintenance program responsibilitie The following changes were made to the surveillance program to address the program fragmentation and procedure clarity issues. Procedure AP-4000 was revised to designate the Technical Programs Surveillance Test Coordinator (STC) as the responsible authority for r- overall program management. The STC is an engineering position and maintains the surveillance program database, generation of surveillance test work orders, tracking tests to completion and updating plant management of program status as required. The STC was very knowledgeable of the surveillance program procedure requirements and t'e significance

of proper program implementatio Each department has a designated surveillance test coordinator who reports directly to the STC. Overall, the department test coordinators (DTCs) were knowledgeable about the ,

overall IST and department IST program procedure requirements. They provided years of surveillance testing experience and program ownership for their respective department .2.2 Detailed Procedure Guidance for Required Actions

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The OSTI noted that previous surveillance program procedures lacked detailed guidance for pump and valve tests that resulted in an " alert" or " required action" condition. The Appendices for procedures AP-0164 and AP-0211 were revised to provide written requirements for components or system test data that do not meet the " acceptable" criteri The revised alert and required action procedure information was detailed and identical to the ;

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written requirements of the ASME code for OMa-6, " Inservice Testing of Pumps,"

and OMa-10. " Inservice Testing of Valves."

The new procedures also incorporate the use of the facility's corrective action report (CAR) ;

and work order request (WOR) systems to document and track noted surveillance deviation The requirements to use the CAR and WOR systems were provided directly in the body of the IST procedure corrective actions sectio .

The inspector identified a new program weakness when licensee personnel track pumps that require an increased frequency surveillance test. Plant personnel used an informal chart to- ,

ensure the surveillance test frequency. The operation's DTC did not use an existing approved procedure change form to update the computer automatic tracking syste Procedure AP-4000 contains form VYAPF 4000.01 that should be completed and forwarded to the Surveillance Test Coordinator for any pump performance tests that fall in the " alert" -

range of operation. The STC can change the computer database to print automatically any surveillance test frequency that is doubled due to a pump performance proble Upcm further review, the inspector noted a related discrepancy in that procedure AP-0164 did

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not directly reference procedure AP-4000. AP-0164, Appendix A, step 1.0, states that the

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Surveillance Test Coordinator shall be notified to change the frequency of testing as require The AP-0164 procedure did not reference the computer change form VYAPF 4000.01. The STC and operations DTC interviewed did not recall using the AP-4000 change form for pumps requiring an increased surveillance frequenc The inspector reviewed the surveillance frequency of the safety-related pumps in the " Alert" range. In all cases, the pump surveillances were performed at the proper increased frequency. Even though tests were performed on time, the procedure information was not used to update the computer program. This raises the prospect that a test could be performed late or missed. The inspector identified this concern as a program weaknes .2.3 Review of Surveillance Test Data Procedure AP-164 was revised to include an independent senior reactor operator (SRO)

review of IST results after the shift engineer (SE) review to evaluate the acceptance criteri The independent review by a licensed SRO provides a " defense in-depth" approach to correct and identify problems before a degraded component or system is declared operable. The inspector's review of surveillance test data noted that the performance data was evaluated correctl .2.4 Plant Engineering Involvement in the Inservice Test Program The plant recently implemented its third ten-year cycle of the inservice testing (IST)

program. The inspector reviewed the implementation of the IST program. The engineering department provides the program oversight of the IST prcgram. The maintenance department and operations department share in the implementation responsibilities of the IST progra The IST program was appropriately implemented. The inspector reviewed various IST results to ensure that the actions taken were appropriate, the equipment specified in the IST program vras tested, and appropriate alert and required action bands were established. The inspector also evaluated the procedure implementation for the use of temporary pump baseline dat The inspector reviewed the documentation of the maintenance engineering group to establish new baseline criteria for a Core Spray pump in the Alert range (CAR 93034MECl). The .

engineering depanment personnel disapproved the proposed pump baseline data change because it was not allowed by the ASME code, OMa Part 6 2rior to the recent ST program revision, the plant engineering group would not have been included in the pump baseline data change. This was one example that the engineering department input was beneficial to the implementation of the IST progra .

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3.2.5 - Computerized Surveillance Test Tracking System The plant staff recently implemented a computerized surveillance test tracking system as part -

of the Maintenance Planning and Control (MPAC) system computer to replace a manual . .

tracking system.- The plant personnel knew how the MPAC system worked and were able to determine if the existing surveillance test problems had been entered and documented in the computer as required by the program procedure '

The new system scheduled surveillances based upon the required surveillance interval. For example, a test that was required to be performed weekly would be routinely scheduled for .

every Monday, while a monthly requirement may be routinely scheduled for the third :

Monday of each month. The " drop dead date" was calculated and scheduled based on the 1.25 times interval allowed by TS. If a surveillance approached the test drop dead date, a

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separate computer printout was sent to the applicable department manager and STC. The STC would follow up each surveillance to ensure that the required surveillance would be

performed on tim The inspector concluded that the new computerized surveillance test tracking system was an ;

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improvement over the manual system. Its features increase the probability that surveillance tests will not be missed. However, the tracking of pumps requiring an increased surveillance - -

frequency was an example that did not take advantage of the computer tracking system capabilitie t Summary of Conclusions i

The inspector concluded that the recent surveillance program revisions were effective and ;

adequately addressed the OSTI's noted weaknesses. The surveillance test program

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appropriately ensures safety-related equipment operability. Vermont Yankee personnel were knowledgeable about the recent ST program change <

The revised IST program procedure guidance provides clear responsibility and direction for I the plant personnel who perform, schedule and track the surveillance tests. Each department j surveillance test coordinator demonstrated a detailed knowledge of the ST program and a positive ownership for their surveillance responsibilitie The procedure change to have the SRO review IST data after the SE review appears to be 'a positive improvement and removes the burden of a single personnel error resulting in a '

degraded safety-related component or system being declared operabl Calibrated test equipment used for surveillance testing was adequately controlle A new program weakness was noted for the tracking of safety-related pumps that required an ,

increased frequency surveillance tes ,

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1 LICENSEE ACTIONS ON PREVIOUS INSPECTION FINDINGS

! (Closed) Unresolved Item (271/93-80-01): Weaknesses in IST Program

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In summary, the OSTI previously noted the following surveillance test program weaknesses: ;

the surveillance program appeared fragmented, procedural guidance was not clear, justifications to establish new pump baseline data were weak, and the single reviewer for IST ;

data acceptability (shift engineer) have resulted in past problem The inspector reviewed the licensee's response to the surveillance test program weaknesses as discussed in section 3.2 of this repor The inspector concluded that the recent surveillance program revisions were effective and !

adequately addressed the OSTI's noted weaknesses. The surveillance test program

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appropriately ensures safety-related equipment operCity. Vermont Yankee personnel were knowledgeable about the recent ST program changes. Based on the above information this ,

item is closed (271/93-80-01).

, LCJosed) Violation (271/93-12-01): Violation of 10 CFR 50. Apoendix B. Criterion V. for the Reactor Recirculation System Surveillanc The violation was the failure to record and monitor recirculation jet pump operability during single reactor recirculation pump operatio ;

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The inspector reviewed the licensce's response to the Notice of Violation. The plant revised f

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the two procedures affected, OP-4110, " Reactor Recire System Surveillance," and OP-2428,

" Single Loop Operation." The review compared the two operating procedures to the associated technical specification (TS).

Operating Procedure OP-4110 surveillance data form VYOPF 4110.04, sections B, C, and '

D, were revised to list the TS surveillance and acceptance criteria requirements for single recirculation loop operation. The procedure also includes the applicable TS number 4.6. and reference to OP-242 As noted above, the specific TS issue from the NOV was resolved satisfactorily. Based on the above information this item is closed (271/93-12-01).

However, to determine if this problem is an indication of other TS surveillance discrepancies, the licensee has undertaken their own TS review (discussed in letter BVY 93-069). The licensee is in the process of reviewing all technical specifications to ensure there is a surveillance procedure to match every TS surveillance requirement. 'The TS .

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review is in its initial phase and was approximately 20 percent complete the week of the inspectio i

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Licensee completion of this project and subsequent NRC staff review is warranted in light of past findings in the surveillance test area (50-271/93-31-01), (Closed) Unresolved item (271/93-23-02): Removal of feedwater heaters at the end of cycl l The unresolved item was associated with the feedwater operating procedure guidance that -

would allow bypassing all feedwater heaters at power with the potential for exceeding the ;

minimum critical power ratio (MCPR) thermal limit or have an adverse impact on reactor ;

core power oscillation '

The inspector reviewed the licensee's documentation related to the removal of the high pressure (HP) feedwater heaters from service contained in Operating Procedure OP-2172,

"Feedwater System."

The review included the licensee's response to the Boiling Water Reactor Owners Group (BWROG) letter 92030, dated March 18, 1992. The letter discussed Interim Corrective Action (ICA) implementation guidelines for reactor thermal hydraulic stability. A section o the BWROG letter discussed possible performance improvements related to the feedwater '

system operation. The owners' group letter stated that " operation with reduced feedwate temperatures (without all feedwater heaters inservice) near the power instability exclusion area will increase the likelihood of a thermal-hydraulic oscillatio The Vermont Yankee (VY) response to the BWROG's letter was contained in a Yankee .

Atomic, Bolton, memorandum VY92-11. TAG, dated July 7,1992. VY's response noted that their feedwater system was very reliable and that no action was required related to the i

possible loss of feedwater heating and its impact on thermal hydraulic instabilitie The operations management recognized the possible consequences of removing the HP i feedwater heaters from service as described in their feedwater operating procedure. The

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current plant operating philosophy was not to remove HP feedwater heaters from servic The removal of HP feedwater heaters from service was discussed approximately four years ago, but not performed due to the potential unfavorable impact on the MCPR thermal limi :

The licensee opened a commitment action tracking item (UND 93060) to delete OP 2172,

section J " Bypassing HP Feedwater Heaters at End of Cycle." The procedure guidance is scheduled to be removed during the next biennial procedure review scheduled for February 1994. Based on the above information this item is closed (271/93-23-02). ,

(Clo<.ed Insnestor Followup Item (271/93-23-01): Verification of Chemistry ,

Technicians' Ounlifications  ;

The inspector followup item was related to misplaced chemistry technician qualification records that were found to have missing qualification signature !

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The inspector reviewed the licensee's response to a previous inspector followup item related - '

to the chemistry technician qualification. The facility personnel discovered chemistry technician qualification records at the plant. The qualification cards contained a few training _

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items that were not signed for completion. The facility performed a comprehensive internal audit of all chemistry technician qualification records to determine the impact and appropriate corrective actions for the incomplete qual card The chemistry training supervisor forwarded the technicians audit information to the ,

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chemistry manager for review and recommended course of action. The chemistry manageri provided his assessment and recommended actions to the training department on 7 November 15, 1993. The chemistry manager assigned one chemistry technician to complete four on-the-job (OJT) training guides; two chemistry technicians were recommended to receive some additional initial training modules; and, where appropriate, training waivers -

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were submitted for equivalent work experience or job equivalent training. The manager also identified and recommended an update to an OJT item related to the new circulating and

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service water treatment system The inspector considered the facility's response with respect to chemistry technician performance was appropriate. Based on the above information this item is closed  ;

(271/93-23-01).

! EXIT MEETING  ;

The inspectors met with licensee representatives at the conclusion of the inspection on November 19, 1993. The inspector summarized and discussed the findings and observations made during the inspectio ,

An inspectoc follow-up item is an area that requires further review and evaluation by the :

NRC staff. An unresolved item is an area in which more information is needed to determine if the item is acceptable, a deviation, or violation. Unresolved items are discussed in sections 4.1 and 4.3. Inspector followup items are discussed in sections 4.2 and <

Key Personnel contacted during the inspection were:

P Vermont Yankee Nuclear Power Corocration f

• R. Wanczyk Manager, Vermont Yankee Station

• B. Buteau Engineering Director

• R. Clark Director, Quality Assurance

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• R. Pagodin Operations Superintendent

• L. Doane Operations Manager

• M. Watson 1&C Manager

• W. Peterson QA Manager

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• W. Anson Technical Programs Coordinator

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Vermont Yankee Nuclear Power Corocration (Cont'd.)

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• R. Grippardi QA Supervisor l F. Burger Technical Services Administrator J. Devincentis Technical Programs Supervisor i United States Nuclear Regulatory Commission  ;

• S. Chaudhary Senior Reactor Engineer  ;

• S. Hansell Operations Engineer  ;

H. Eichenholz Senior Resident Inspector

• Denotes those present at the exit meeting on November 19, 1993. The inspector also held i discussions with other licensee management, operations, maintenance, and chemistry ;

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Attachment: Documents Reviewed

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ATTACIIMENT 1 DOCUMENTS REVIEWED  ;

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PROCEDURE NUMBER TIT Revision i

Administrative Procedures (APs)

AP4)164 " Operations Dept. Inservice Testing" Rev. 3 AP-0211 " Predictive Maintenance Program" Re ,

AP-4000 " Surveillance Testing Control" Rev.15

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Operating Procedures (Oos)

OP-2124 " Residual Heat Removal System" Rev. 34 OP-4123 " Core Spray Surveillance" Rev. 24 OP-4124 "RHR and RHRSW System Surveillance" Rev. 33

• OP-4126 " Diesel Generator Surveillance" Rev. 32

• OP-4326 " Reactor Building Ventilation and Refueling Floor Radiation Monitors" Rev.14

• OP-4352 "RHR Pump Discharge Pressure Functional /

Calibration" Rev.15 OP-2172 "Feedwater System" Rev.17 OP-2428 " Single Imop Operation" Rev. 8 OP-4110 " Reactor Recire. System Surveillance' Rev. 21 Reports and Audils Revision BWROG Letter-92030 response, VY92-11. TAG

• Denotes the surveillance procedures directly observe ,

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