IR 05000271/1993080
| ML20057A538 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 09/07/1993 |
| From: | Haverkamp D, Schmidt W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20057A536 | List: |
| References | |
| 50-271-93-80, NUDOCS 9309140369 | |
| Download: ML20057A538 (46) | |
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U.S. NUCLEAR REGULATORY COMMISSION i l REGION I' !
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! Report N Docket N ,
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Licensee N DPR-28 l l
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, Licensee: Vermont Yankee Nuclear Power Corporation l j RD 5, Box 169 l Ferry Road l Brattleboro, VT 05301 j
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Facility: Vermont Yankee Nuclear Power Station Vernon, Vermont l Inspection Period: June 7 - July 2,1993 Team Leader: Wayne Schmidt, Sr. Resident Inspector-Nine Mile Point ,
Division of Reactor Projects (DRP) .
Assistant Team leader: David lxw, Project Engineer, DRP j Maintenance / Surveillance: Ken Kolaczyk, Resident Inspector-Millstone Station,DRP !
- Engineering / Technical Support
- Suresh Chaudhary, Sr. Reactor Engineer, Division of l
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Reactor Safety (DRS) _ l Monte Conner, Project Engineer, DRP -!
Management / Corrective Actions: Scott Barber, Sr. Resident Inspector-Susquehanna, DRP - l Dan Dorman, Project Manager, Office of Nuclear l Reactor Regulation (NRR) l Plant Operations: Mike Buckley, Reactor Engineer, DRS !
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Approved by: 'd #** 3 f/7 /4 7 Wayne L. Schmidt, Team Igder, DRP ' Date j b d/2 //- l b
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thin Donald R. Haverkamp, (Team hjinager), Chief Date-Technical Support Staff, DRP i
9309140369 930907 PDR ADOCK 05000271 %@)
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l EXECUTIVE SUMMARY l
l Operations !
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The operations staff performed well and provided leadership for other site departments. This staff operated the plant safely and demonstrated good knowledge of plant status and conditions. Initial actions taken in response to abnormal conditions were good. Operator aids were of good quality and well tracked. Operations department management appropriately controlled overtim Areas for improvement were noted in attention to detail for activities involving administrative procedures, specifically in the content of operator logs, the clearing of control room deficiency stickers, and the controls over long-term temporary modi 5 cations. Some conditions identified by the team suggested an acceptance of readily correctable deficient conditions, which had minor safety signiGeance.
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Maintenance and Surveillance l The maintenance and instrument and control departments effectively supported safe plant l operations. The material condition of the plant was very good. Vermont Yankee personnel appropriately identified, assessed, and resolved equipment deficiencies. The maintenance backlog was maintained within a manageable size, with no outstanding significant work orders, which would impact the safe operation of the plant. Implementation of the surveillance testing and preventive maintenance programs appeared eppropriate. The quality and quantity of spare parts was adequately controlled. Vendor manual information was appropriately assessed and incorporated into the maintenance and surveillance programs.
- Some maintenance and surveillance processes relied heavily on the capabilities of personnel.
l Although Vermont Yankee personnel were very capable and performed their functions well, j the minimal procedural guidance ai,6 additional levels of review were not consistent with a defense-in-depth philosophy. An unresolved item (50-271/93-80-01) was identified concerning problems in the in-service testing program and in the control of maintenance
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l The team concluded that the implementation ofindustry information was generally good, and that the quality and depth of reviews had improved. However, an unresolved item (50-271/93-80-01) was identified concerning engineering analysis of main steam isolation valve closure capability following a loss of coolant acciden Overall, the team observed no indication that safety-related equipment degradation was occurring in a systematic fashion. While there were specific equipment failures, the team did not identify any fundamental weaknesses that would have allowed equipment to degrade to a point where it would not perform its safety functio ii .
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- l Vermont Yankee self-assessments and audits effectively identified numerous program weaknesses. Consequently, Vermont Yankee management has made, and continues to make, improvements to correct the weaknesses. Aspects of the predictive maintenance program were being consolidated and detailed guidance provided. Effective actions were taken to increase the consistency of work order documentation and accuracy of the failure codes. A )
pilot program was being implemented to enhance equipment trending. A reliability-centered l maintenance program was being developed, which was effectively using industry and plant-specific informatio Engineering and Technical Support
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The Vermont Yankee on-site and corporate staffs and Yankee Atomic engineering staffs l l provided good quality support to the plant. Prioritization and tracking of engineering efforts 1 were appropriate and focused on plant safety. Staffing levels were appropriate and overtime was not excessive. Plant design changes were well prepared and documented and efforts to improve the quality of safety evaluations have been effectiv Management Processes and Corrective Actions Vermont Yankee ma.ngement had taken actions to address past problems through self- ,
assessment and observation programs. Further, the identification and use of industry I experience information had improved over the past year. The separation of the licensee's l corrective action guidelines into two tiers inherently established the level of followup for events classified as " routine" at a minimal level. As a result, these problems were typically addressed by corrective maintenance, with very little self-assessment of the human or procedural factors that led to a given problem or issue. The licensee had identified some of l these weaknesses and was taking action to correct them.
j The team reviewed the activities of PORC and NSARC and found them to be of high quality.
L Both committees probed the issues presented in detail and fulfilled their safety review ;
responsibilities wel The team noted that many recent QA audits were exceptionally good. These audits probed many areas and their findings and conclusion were concise and comprehensive. Various departments responded differently to these audits. The team noted that the departments that took prompt and extensive actions in response to these audits had a healthy attitude toward self-assessment. Some responses were conciliatory in nature. The licensee has noted the variability in responses and was taking action to improve the self-assessment ethic of the entire statio l iii
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TABLE OF CONTENTS ,
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EXECUTIVE SUMMARY ....... ..............................ii INSPECTION SCOPE AND OBJECTIVE ........................ I r
l OPERATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Control Room Observation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I Control of Overtime . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 i Corrective Action Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 l Log Keeping and Performance of Rounds .................... 2 l Abnormal Plant Indications ............................. 3 2.5.1 Drywell Temperatures . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.5.2 O ffgas Alarms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
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2.5.3 Turbine Load Bay Fire Protection System . . . . . . . . . . . . . . . . 5 Temporary Modification Process . . . . . . . . . . . . . . . . . . . . . . . . . . 5 j Operations Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 MAINTENANCE AND SURVEILLANCE . . . . . . . . . . . . . . . . . . . . . . . . 6 l Corrective Maintenance Review .......................... 7 l 3.1.1 Generation of Work Orders . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.1.2 Work Order Coordination and Oversight . . . . . . . . . . . . . . . . . 9 Maintenance Planning and Control System . . . . . . . . . . . . . . . . . . . 10 Equipment Trending and Predictive Maintenance . . . . . . . . . . . . . . . I1 3.3.1 Equipment Failure Trending . . . . . . . . . . . . . . . . . . . . . . . 12 3.3.2 In-service Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 3.3.3 Predictive Maintenance .......................... 15 3.3.4 Reliability Centered Maintenance and Repetitive Failures . . . . . . 15 3.3.5 Limiting Condition for Operations Maintenance ........... 16 S urveillance Program . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 3.4.1 High Pressure Coolant Injection Surveillance . . . . . . . . . . . . . 17 3.4.2 Entry into LCOs .............................. 17 3.4.3 Computerized Surveillance Test Tracking System .......... 18 3.4.4 Standby Gas Treatment Review ..................... 18 Spare Parts Qualification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 iv
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- Preventive Maintenance .............................. 20 I 3.6.1 480 Volt Preventive Maintenance Review ............... 20 j 3.6.2 4160 Breaker Preventive Maintenance Program ........... 20 3.6.3 Instrumentation and Controls Department Power Supply
! Operation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 3.6.4 Service Water Pump Performance and Maintenance . . . . . . . . . 22
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l Industry Experience Information . . . . . . . . . . . . . . . . . . . . . . . . 23 j Maintenance and Surveillance Conclusions . . . . . . . . . . . . . . . . . . . 25 j
! i l ENGINEERING AND TECHNICAL SUPPORT ................... 26 )
l Engineering Organization and Staffing . . . . . . . . . . . . . . . . . . . . . . 26 l j Design Changes and Modifications . . . . . . . . . . . . . . . . . . . . . . . . 26 i i 4.2.1 Design Change Process and Prioritization . . . . . . . . . . . . . . . 27 1 4.2.2 Review of Design Changes . . . . . . . . . . . . . . . . . . . . . . . . 27 ,
l Management Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 j Engineering Support to the Plant . . . . . . . . . . . . . . . . . . . . . . . . . 29 Yankee Nuclear Services Division Support to Vermont Yankee ...... 29 j Design Basis Program ............................... 30 l 3 .59 Safety Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 l l
- One for One Evaluation .............................. 31 j Motor Operated Valves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 4.10 Engineering and Technical Support Conclusions . . . . . . . . . . . . . . . .
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1 MANAGEMENT PROCESSES AND CORRECTIVE ACTIONS ......... 32 2 Self-Assessment Initiative ............................. 32
5.1.1 Observation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 j 5.1.2 Self-Assessment Policy .............. ........... 33 Corrective Action Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 i 5.2.1 Corrective Action Processes ........................ 34 j 5.2.2 Review of Potential Reportable Occurrence Reports . . . . . . . . . 35 i 5.2.3 Root Cause Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
{ 5.2.4 Corrective Action System Conclusions . . . . . . . . . . . . . . . . . 37 i Quality Assurance Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
- 5.3.1 Quality Services Group / Independent Inspection ........... 38
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5.3.2 Off Site Audits ............................... 39 Plant Operations Review Committee and Nuclear Safety Audit and 1 Review Committee ................................. 40
] Management Processes and Corrective Action Conclusion . . . . . . . . . . 40 j
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! INSPECTION SCOPE AND OBJECTIVE From June 14 through July 2,1993, a team of eight NRC inspectors performed an Operational Safety Team Inspection (OSTI) at the Vermont Yankee Nuclear Power Station (Vermont Yankee). The purpose of the inspection was to assess Vermont Yankee Nuclear :
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Power Corporation's effectiveness in identifying, examining, and resolving program weaknesses, which affect the control and support of safe plant operations. The areas reviewed included the conduct of plant operations, maintenance, surveillance testing, and engineering and technical support activities. In these areas, management processes and corrective actions were reviewed to assess the resolution of technical issues and self-assessment capabilities. The team findings and conclusions were discussed with licensee !
management at a public exit meeting on July 16,199 l l
' OPERATIONS Control Room Observation The team observed the activities of operations department personnel in support of safe plant operation Operators performed well during routine control room activities and were very ,
knowledgeable of plant and equipment status. Control room access control was noteworthy j and resulted in a quiet and non-distractive atmosphere. The team verined adequate on-shift l
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staffing through observation The team reviewed the system in place for tracking control room equipment deficiencies and l
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found it adequate. Operators attached yellow stickers to the deficient component, identifying l the component, the work order (WO) number, date, and remarks. The operations i
department conducted a review of the yellow stickers while the inspection was proceeding and found that four of the sixteen stickers on equipment in the control room inappropriately remained on the equipment, in that the deficient condition had been correcte Administrative Procedure 0021, Work Orders, required a note on the WO to alert the shift supervisor (SS) to remove the stickers following return of the equipment to service. Of the remaining twelve stickers, the team observed that WOs had been written: however, only one WO had the required note to alert the SS to clear the yellow sticker after completion of work. While not safety significant, this was a weakness in the administrative controls over control room deficiencies.
i Selected operator aids that the team reviewed, in the control room and the reactor building, I provided appropriate information to the operators. Operator aids were of good qual. v, !
l properly tracked, and updated with procedure changes as needed. The aids provided operators with information that the operations department believed would be helpful in safe operation of the plant.
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The team noted that the controls over defeated control room annunciators were appropriat i
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The operators were aware of the reasons for defeated annunciators and the tracking of these
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issues was adequate. The team conducted an in-depth review of thejustification for defeating the high reactor average power range monitor (APRM) and rod block annunciator The defeated annunciators did not defeat the rod block function of the APRMs. The APRM instrumentation was observed fluctuating to the rod block setpoint causing the rod block to be generated. This would have caused numerous annunciator alarms if the annunciators were not defeated. The team also verified, based on review of reactor thermal power computer determinations and an independent hand calculation of reactor thermal power, that the unit l was being operated within its licensed thermal power limi ;
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l Control of Overtime The team reviewed the overtime hours worked by operations department personnel for the "
i three months prior to the inspection. This review included 57 personnel and a specific l review of records for four individuals with above average overtime hours. In addition, the schedules for the weeks ending on April 10,17, and 24 and June 19 were reviewed. The process for determining the necessity of overtime and assigning overtime hours was discussed with the operations manager. The control ofindividual overtime hours was the responsibility of the operations manager and implemented by the operations secretary using AP 0894, Shift .
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Staffing / Overtime Limits. The controls over overtime were satisfactory and well documented and met the NRC guidelines and station procedure requirement .3 Corrective Action Process The team interviewed and observed operators and found that they use work order requests (WORs) to identify problems to the SS that may need correction. (See Section 3.1 for a discussion of the corrective maintenance process.) Operators used the potential reportable i occurrence (PRO) report properly when issues involving reportability concerns came u l The operators interviewed and observed by the team believed that they were expected to find i and report problems and to enter the problems on WORs in the Maintenance Planning and l Control (MPAC) system computer (see Section 3.2), to bring attention to the condition and get corrective action. The operators observed knew how the MPAC system worked and made queries to determine if plant problems had been reported and were able to obtain the status of the work order requests. Overall, the team concluded that the operators understood the corrective action process wel .4 Log Keeping and Performance of Rounds The team inspected operator logs and found that entries generally reflected significant conditions and operator actions taken, and that logs could be used to reconstruct the details of significant events. Well organized and legible operator's logs and rounds sheets caused appropriate information to be taken during rounds. Often during the inspection, the team observed that operators kept the Technical Specification System / Component Inoperable log i
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, i j (i.e., limiting condition for operation (LCO) log) up to date. The log entries mad (, j ( following the failure of residual heat removal service water system valve MOV-89A, showed ;
j that the valve was considered inoperable and that the proper technical specification (TS) !
l LCOs were entered and also reflected the corrective actions taken. However, some operator
{ logging discrepancies were observed: ,
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- During review on June 11, 1993, the team noted that the logs did not reflect an jI
- unexpected alarm on the "B" recirculation pump seal differential pressure, or the j i operations and instrument and control (I&C) staffs' judgement on the cause and the - j i resolution of the problem. The team found that the WO for this item adequately i i documented the initial actions taken.
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! * During a tour, the team noted that the required fire watch log for fire permit 93-157 i j was not documented as completed within the one-hour time period. This was !
j discussed with the SS who stated that the person had completed the fire watch tour !
j but forgot to log the results. A late entry was made on the fire watch log to show !
- compliance with requirements of TS 3.13.f.2, Turbine lead Bay out of service. The . l SS made no entry in his log. The licensee wrote a memorandum addressing the !
l expectations for fire watches and log keeping to prevent recurrence.
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i Abnormal Plant Indications i i i 1 e
! During the inspection the team identified several instances where the operating staff was j j living with long-standing deficient conditions or problems. The team found each of these - :
i issues, by themselves, to be non-safety significant, but determined that management support ;
to correct these conditions was wea i i -t
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j 2.5.1 Drywell Temperatures ,
i j During a review of the control room operators' logs, the team found that the readings for j drywell temperature had been outside the designated normal value for most of the current j operating cycle. The note in the log indicated that these reading were under evaluation.
- Operations or engineering staffs had conducted no specific assessment for these elevated
{ temperature readings. Operations personnel believed that a procedure change request had been submitted, but it had not. It was submitted during the inspection on June 17, 1993.
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I j The team questioned the licensee as to the effects of high temperature on environmentally j
[ qualified (EQ) equipment and drywell structural concrete. Because of the high temperatures the team reviewed the environmental qualification information for several motor-operated j valves located in the drywell to determine if the grease in the operators could be affected by j_ the high temperatures. The team noted that the environmental profile for the drywell
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Through a review of drywell area schematics, the team determined that no drywell motor l
operated valves were located in the high temperature areas. The licensee informed the team l that the grease used in the motor-operated valves, Exxon Nebula, was certified capable of operating in the 190 F drywell environment. Therefore, the team concluded that the temperatures in the upper areas of the drywell did not appear to have an adverse impact on l the motor-operated valves.
l The team calculated the average bulk drywell temperature using the licensee's hand calculation method and found the temperature within the administrative limits. However, the team identified that the computer calculation of the average drywell temperature on the safety l
parameter display system, used as an entry condition to the emergency operating procedures, was inconsistent with the manual method. Specifically, the volumetric weighing factors for
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the 246-foot and 250-foot elevations had been transposed during computer data entry. This l computer error had been in place since the last outage. This mistake caused the average l drywell temperature to be slightly (< 1*F) less conservative. The integrated leak rate test
! (ILRT) performed on April 17, 1992, used these incorrect factors during containment testin The licensee initiated a detailed review of the results of the ILRT, which may require an l
update to their ILRT report to the NRC. A preliminary reevaluation of the results showed '
l that the ILRT would still be within the leak criteria. The licensee wrote a potential reportable occurrence to track corrective action and determine reportability. The error was not detected during the ILRT verification of the testing software. The licensee stated that the computer code was changed on June 24,1993, to the correct value .5.2 Offgas Alarms
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During control room tours, the team noted that the offgas system, " INLET GUARD BED B"
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and " INLET ABSORBER A", Alert and High radiation alarms, were locked-in, and these i alarms had been locked-in the entire cycle. The team verified that offgas release rates were well within the TS requirements. The team was concerned that with the constant alarms the instruments would not give the operators an indication of an increasing offgas radiation level.
l There was no program to evaluate the operation of the plant with continuous alarm conditions. Also, there was no program to perform a 50.59 evaluation for continuous alarms. When asked about the required setting for this parameter, the licensee evaluated and j implemented a change to the alarm setpoints to increased values, which cleared the alarms '
and allowed the operators indication of increases in the future. The Technical Specifications, Final Safety Analysis Report (FSAR), and the Offsite Dose Calculation Manual were independently checked by the team to verify that there were no requirements or calculation changes required because of this setpoint change.
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2.5.3 Turbine Load Ilay Fire Protection System j l The team found that, because of a poor fire suppression system design, operators repeatedly
- bypassed the detection system and entered the TS LCO for an inoperable fire detection l system in the turbine load bay. This LCO had been entered 13 times in June 1993, and 93 .
l times from the 2nd quarter of 1991 through the 4th quarter of 1992. The licensee stated that !
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this system was bypassed because an over-sensitive detection system caused five inadvertent [
actuations in the last eight years. The team was concerned with the acceptance of this :
condition and frequent LCO entries without progress toward resolution in the past eight !
years. The licensee stated that the system design was being reviewe j Temporary Modification Process l
The team found that Vermont Yankee personnel generally did not use temporary ,
modifications (TMs) on safety-related equipment, preferring to use the more formal plant (
l design change request. The 38 TMs open at the time were generally on non-safety-related I equipment. Control room tracking and logging of TMs appeared appropriate. The team did note that the administrative review process for TMs older than six months was not strictly followed as discussed below and that TMs that had been superseded by actual plant changes ;
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AP 0020, Control of Temporary Modification, stated that " Modifications made under this procedure should be temporary in nature, normally not to exceed six months, and the total I number of Temporary Modifications should be kept to an absolute minimum." Further, the procedure stated "To ensure that Temporary Modifications are removed at the earliest f opportunity, quarterly reviews are performed for all open requests, and any Temporary 1 Modifications installed for greater than six months will require additional review by PORC."
The team noted that, of the 38 active TMs,28 were older than six months, dating back to j July 199 l The team reviewed the PORC meeting minutes, in which all TMs over six-months old were discussed. The PORC decisions seemed appropriate, however, in three cases (TMs91-008, l
'91-025 and 91-053), the PORC's completion dates for the TMs were exceeded, but no new PORC review, as required by AP 0020, Section E.3, was performed. PORC meeting 92-54 scheduled TM 91-025 to be made permanent during 1992, and TMs91-008 and 91-053 made l permanent during 1993. The April 13,1993, audit of outstanding TMs showed that one year
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had been added to each of these completion date Five of the outstanding TMs concerned motor-operated valve (MOV) modifications involving either increased motor size or torque switch bypass travel. The latest operation department's review stated that these modifications were to be made permanent by EDCR 92-40 However, the EDCR, approved in January 1993, had not cleared the related TMs.
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The team selected several TMs to determine how the control room drawings and procedures i reflected changes made by each TM, as " deemed necessary" by AP 0020, Section B.4.b. No l drawing notations of TM changes could be found; and, only TM 91-053, Resin Dewatering l System Mechanical Installation, resulted in a procedure change to OP 0023, Installation and l Testing of Cable and Conduit. No safety issues were identified in this drawing revie l However, there was no procedure requirement to ensure that controlled plant drawings which I were affected by a TM were updated or had a reference to the applicable T l l
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In summary, the team concluded that the TM process was adequate, however plant l management inconsistently applied the process for reviewing TMs older than six month Five TMs were not promptly converted to permanent modification following the approval of ,
EDCR 92-402. However, the team identified no direct safety concerns resulting from the ]
TM .7 Operations Conclusions Overall, the licensee operated in a way which was consistent with plant safety. The control i room operators demonstrated good knowledge of the current plant status. Initial actions !
taken in response to abnormal conditions were good. The control room access was noteworthy and resulted in a quiet and non-distractive atmosphere. Operator aids were of !
good quality and well tracked. Operator overtime was appropriately controlle The licensee's attention to detail for activities involving administrative procedures was weak i based on the performance observed for TMs and control room deficiencies. Some conditions I
- identified by the team indicated an acceptance of deficient conditions, which had minor safety j significance, yet were readily correctable. These deficient conditions included high drywell i temperature readings, locked-in offgas alarms and an over-sensitive turbine load bay fire l detection system. Additionally, logging deficiencies were observed in that a fire watch log
was not properly maintained, and a reactor coolant pomp seal differential pressure alarm was not logged.
l MAINTENANCE AND SURVEILLANCE The team reviewed selected aspects of Vermont Yankee maintenance and surveillance programs. The maintenance areas reviewed included the maintenance work order process and procedures, and preventive and predictive maintenance programs. The surveillance areas
, reviewed included the in-service test program, performance of testing activities, adequacy of l test procedures and the surveillance tracking program.
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j-7 Corrective Maintenance Review The Vermont Yankee management considers the work order process as the lowest level of i
their corrective actions system. The team reviewed this process, including the identification of deficient equipment, the approval of work order requests OVORs), and the prioritization, documentation, and oversight of work orders OVOs). Administrative Procedure (AP) 0021, Revision 22, " Work Orders", specifies the requirements and guidelines of the WO proces The team focused on this process to gain insight into its effectiveness in identifying and ,
resolving equipment deficiencies that impact safe operation of the plan t 3.1.1 Generation of Work Orders
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When a member of the plant staff identified a problem that needed correction, the employee entered a WOR in the MPAC computer describing the action requested and the reason it was l needed. The SS evaluated the WOR condition; if the SS believed that the condition needed correction, it was passed on to the operations planning coordinator for review. The i operations planning coordinator then reviewed the WOR; if he thought that the condition ,
needed correction, a WO would be generated. If a WO was generated, it could be tracked ;
through MPAC. If the SS or the operations planning coordinator rejected a WOR, however, I it was removed from the active files. It received no further supervisory review and was not included in any tracking. If a WOR identified a condition that needed immediate corrective actions, the SS could change the WOR to a WO and work could commenc The team reviewed all rejected WORs documented in the MPAC system since April 1,1993, noting that the documented basis for rejection, in MPAC, was weak. The MPAC system provided the only documented feedback to the originator for rejection of a WOR. To
, determine the reason for rejection, the team inten'iewed the operations planning coordinator.
l In general, he provided a sound basis for the rejected WORs. In many cases, the SS or l operations planning coordinator rejected WORs because an approved WO or a duplicate
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WOR was already entered into the MPAC system. In other cases, WORs were rejected l because the equipment condition was acceptable. For example, several WORs identified l packing leaks from hydraulic control unit (HCU) valves. Discussions with the operations j planning coordinator indicated that the leakage was extremely small and considered
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acceptable. During plant walkdowns, the team noted that the HCU valves were in very good material condition and, with respect to the valves identified in the WORs, observed no significant leakage. Other reasons why WORs were rejected included equipment deficiencies that were already corrected by a related maintenance activity or calibration, or that would be addressed through an established program. For example, slightly low equipment oil levels, which were not considered urgent, would be corrected through the weekly oil round program.
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The team noted an exception to the otherwise sound basis for rejecting WORs. This exception pertained to the lower shear pin on the control rod drive (CRD) repair room doo ,
The team noted that WORs were submitted on April 16, 1993, and May 5,1993. On both - l occasions, the WORs were rejected. The shear pin was required to maintain the room i
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locked because it was a locked high radiation area, yet simultaneously, allow the door to open in event of a pipe break in the steam tunnel to relieve the pressure to the reactor ,
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building. Discussions with the operations planning coordinator showed that he rejected the WORs, because the shear pin was no longer required after the CRD repair room was no longer required to be a locked high radiation area. Although the lack of a shear pin would j satisfy the ability to relieve pressure to the reactor building, the shear pin was required to ;
meet the documented design criteria for the door. Another WOR was submitted on l May 28,1993, and was approve l i
Subsequent to the observation of the rejected shear pin WORs, the team noted that the j licensee had written a potential reportable occurrence (PRO) on the issue on June 4,1993, !
before the team's inspection commenced. The PRO indicated that the WORs for replacing- l the shear pin had been rejected for over one year. The team's review of PROS, includmg ,
this PRO, is documented in Section 5.2.2 of this repor !r
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The team also reviewed the non-rejected Type 2 WORs (i.e., WORs related to plant or !
security equipment) generated from April 1 to June 16,1993. - During this period, the l Vermont Yankee staff generated approximately 1,000 WORs, which encompassed both j safety-related and non-safety-rated components. The WORs identified work required by '
plant modifications, preventive maintenance activities, equipment calibration and inspections,
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and equipment deficiencies. In conjunction with the review of non-rejected WORs, the team ;
conducted plant walkdowns to identify potential equipment deficiencies. In general, the .
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material condition of the plant was very good. Based on the number of WORs generated, '
the team concluded that the Vermont Yankee staff appropriately identified equipment deficiencies to allow correctio In summary, operations department management approved most of the WORs generated by the staff. With one exception, WORs were well screened and a sound basis provided for rejected WORs. However, in the one instance where an equipment deficiency was rejected at least twice before finally being approved, Vermont Yankee personnel failed to recognize the documented design requirements of the equipment. The team concluded that, while there were no safety concerns raised during its review, the WO process did not have sufficient management oversight or follow-up of rejected WORs to be considered a rigorous corrective ac ion process for routine failures. Little defense-in-depth was provided in the oversight of the work order proces i . - _ - .
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3.1.2 Work Order Coordination and Oversight Beyond the review of WORs generated since April 1,1993, the team reviewed outstanding ;
corrective maintenance WOs. The purpose of the review was to assess Vermont Yankee ;
management oversight and prioritization of outstanding WOs, and coordination with other ;
departments. Additionally, the team reviewed WOs to ensure that potential safety concerns beyond simply repairing an equipment deficiency were appropriately addresse The team found that the maintenance efforts were focused on maintaining safe plant operation, through the prioritization and scheduling efforts of the operations planning coordinator. However, there was little management oversight of these efforts. Based on this, the team reviewed several hundred WOs and found that the prioritization was generally appropriate. The team did not identify any significant equipment deficiency that should have been categorized as a priority 1 WO. The team found that this was due to the knowledge of the operations planning coordinator, not due to management oversigh :
The team, however, noted that two WOs, which were priority 1, were documented in the MPAC system as still being open, although the deficiencies were about 20 months ol Discussions with the operations planning coordinator suggested that the WOs should not bc priority 1. The deficiencies related to the operation of a valve and a clogged line in the
! radwaste system. The team did not identify a reason to assign the WOs as priority 1.
l During the discussion of the old priority 1 WOs with the operations planning coordinator, the team noted that the operations planning coordinator immediately changed the WOs to a lower ,
priority. AP 0021 states that the operations planing coordinator will discuss with the repair i department supervisor what priority to assign a WO. AP 0021, however, does not specify any guidelines or requirements for changing or reassessing the priority of a WO. The team concluded that the change in the WO priority before discussing the priority with the repair department supervisor was inconsistent with the process for the initial assignment of prioritie J Vermont Yankee management was provided monthly reports to ascertain the backlog of WOs. Discussions with management suggested that their primary focus was the number of :
- outstanding WOs and trends. The May report indicated 451 open corrective maintenance I WOs,281 of which were greater than three months ol The team selected WOs for review which appeared to require additional evaluation. After
- review, two of these WOs appeared to specify a non-identical component replacement. The l team verified that the required evaluations were completed for these WOs and the evaluations appropriately addressed potential concerns.
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The team found that WOs were issued for other than hardware issues, i.e., requests for engineering services. The team noted one WO requesting that the engineering department '
determine if a hanger was missing on a 24" service water (SW) piping. After discussions '
with the appropriate engineering department supervisor, the team noted that the supervisor was unaware of the WO to resolve this L ager issue. The request was about three manths old. The supervisor further s'.ated that this type of issue would best be resolved in the PRO system rather than the WO process. The supervisor's position was in conflict with the operations planning coordinator who said that these types of issues should be entered into the WO process. Apparently, engineering had previously evaluated hanger requirements according to their seismic analysis, and authorized the removal of some hangers. The ,
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operations planning coordinator stated that this type of question was frequently raised and, l most of the time, was not a problem. Subsequent review by the engineering department j showed that the SW hanger was not required by their seismic analysis. However, this event indicated an inconsistent understanding of the use of the WO and PRO processes to identify l
potential dencient condition In summary, Vermont Yankee management oversight of outstanding WOs nas appropriat ,
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The backlog was appropriately tracked and maintained within a manageable siz Appropriate technical evaluations for work orders were performed when required. However, there was an over-reliance on the skills of the operations planning coordinator to ensure that i work was properly prioritized, with little day-to-day management involvement. Some other j weaknesses were noted, including a lack of guidanc: in reassessing and changing WO ;
priorities, and an example of an inconsistent understanding among Vermont Yankee personnel of die process for identifying and correcting deficiencies that could affect systems ,
qualificatio I 1 1 Maintenance Planning and Control System l
The team found that the MPAC system provided a good tool for prioritizing, tracking, and l documenting work and surveillance activities. The MPAC system maintained the surveillance schedule and the official maintenance records and had extensive capabilities and l
maintenance functions including tracking plant equipment down to component part lists, j purchasing and stock records, preventive maintenance records, ar.d work order generation,
- status and history. The MPAC system was also capable of inventory control and individual l components and systems failure and performance data trendin However, the team noted that personnel were not using the MPAC system to its fullest l l capabilities. Although MPAC contains system data for all plant systems and component (parts) data for most safety systems, component data for other support systems were being entered only as maintenance work was performed on that system. Therefore, all plant data records were not yet complete.
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The training on the MPAC system for all site personnel was performed just before the last refueling outage so MPAC could be used for outage control. Team interviews suggested a
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disparity in the plant staff's ability to use the capability of MPAC for maintenance and engineering functions. The team's discussions with personnel indicated the belief that the MPAC was not user friendly and the system guidelines were overly complex and not specific for the users' needs.
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The team ncied that the documentation of work in the MPAC system was weak. Several WOs contained minimal description of the work performed. Failure codes documented for !
l the WOs were inconsistent and inaccurate. For example, several WOs addressing corrective maintenance listed the failure code for routine maintenance. Further, in the work i description, in some instances the apparent cause of the failure was cited as normal wear or ;
l end-of-life, yet the failure code for end-of-life was not selected. These inaccuracies would l impact the effectiveness of trending through the MPAC syste j
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The WO process included a requirement for the individual doing the work to attempt to
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identify the cause of the failure. The cause was identified in the MPAC system by a l two-digit cause code. The team noted that the use of cne of the cause codes was excessive, and, in some cases incorrect. The Vermont Yankee staff previously identified problems in the area of documentation and failure codes in MPAC and recently implemented an extra
- level of review to ensure consistent detail and failure codes accuracy. The team reviewed several recently completed WOs. These WOs were detailed and contained accurate failure l
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t In summary, the MPAC system has extensive capabilities and can become a very useful tool to the plant staff. Some weaknesses, however, were noted that impact the full use of the ,
l system. These includal the completeness of the data base, and the documentation and i
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accuracy of the WOs. The licensee had identified some of these weakness, and was taking steps to address them. Recent WOs reflected the effectiveness of some of these action ;
i' Equipment Trending and Predictive Maintenance i
The team reviewed Vermont Yankee's trending programs to determine their effectiveness in identifying and taking appropriate response to degrading equipment performance. The Maintenance Department Trending Program was specified by Procedure No. AP 0200, ;
Conduct of Maintenance Activities. The stated purpose of the program was to identify and j evaluate equipment and system trends so that maintenance can take place prior to equipment i or system failure. The gradual degradation of equipment from time ofinstallation to failure was to be systematically monitored to allow a determination to be made as to when measures should be taken to prevent failur i l
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h 12 r 3.3.1 Equipment Failure Trending
Plant personnel trended equipment failures for selected systems and components in their ,
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equipment failure trending reports. A maintenance technician compiled the data and trend information in quarterly and annual reports. Based on interviews, the maintenance technician discussed adverse trends in equipment failures with the maintenance engineers and the i
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The equipment failure trending was effective in identifying significant equipment ,
deficiencies. Based on the trend information in the reports, some systems experienced increased failure rates; others decreased rates. Equipment failure trending, however, identified the increased failure rates, and the staff appropriately initiated recommendations or actions. Most notable were actions taken for the service water system, electrical distribution system and the "A" emergency diesel generato The team, however, noted that the guidance in AP 0200 was very general, and as a result,
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- the effectiveness of the trending program relied heavily on personnel. For example, the l systems required to be trended were not specified in AP 0200, but documented through an l internal memorandum and based on personal judgement. The method by which the failures l were trended, the definition of a failure, the establishment of upper control limits were all documented in an uncontrolled document in the failure trending file. The significance of upper control limits and any required actions, if one were exceeded, was not specified. The program provided no guidelines for assessing the trend slope developed for each syste I
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! The Vermont Yankee staff initiated a three-month pilot program, prior to the team's [
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inspection, which will use the MPAC system and will look at more comprehensive information, including current trending data and industry data for identified plant trend This information also will include failure codes, reconciliation codes, and peer inspection Discussions with the maintenance technician showed that trending based on corrective ;
maintenance was also being considered. Vermont Yankee management stated that, after l l completion of the pilot program, its effectiveness would be evaluated, and the incorporation l
01 the program into AP 0200 would be considere In summary, the trending program has been effective in identifying significant trends in j system reliability. Efforts to enhance the program effectiveness and use the MPAC system !
were evident. The efforts were considered positive, however, since these efforts were still in the early stages of development, their effectiveness was not evaluated during this inspectio ,
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3.3.2 In-service Testing The plant was in its second ten-year cycle of the in-service testing (IST) program and the third ten-year cycle was under review. The team reviewed the implementation of the IST program. The engineering department provides the program oversight of the IST progra The maintenance department and operations department share in the implementation responsibilities of the IST progra Overall, the IST program was appropriately implemented. The team reviewed various IST results to ensure that the actions taken were appropriate, that the equipment specified in the j IST program was tested, and that appropriate alert and required action bands were j established. The team also reviewed the establishment of the initial baseline hydraulic values for the spent fuel pumps. The acceptable operation of the pumps was thoroughly established using a five point pump curve and comparison with the manufacturer's pump curv However, the team noted some weaknesses in the IST program implementation. During the team inspection, operations personnel performed the quarterly IST test for the reactor building vent valve HVAC-9. The test indicated that the closure time for HVAC-9 reached the alert range. Subsequent review by the plant staffidentified that the closure time during the previous quarterly test results, in March 1993, was in the alert range. In March, the plant staff did not recognize that the valve had entered the alert range, and consequently, failed to increase the surveillance frequency to monthly. The operations department issued a PRO on this issu The team reviewed the surveillance procedure for HVAC-9 and others, and noted that the sun'eillance procedures did not include the specific IST acceptance values or the specific data reduction calculations within the body of the procedures. Instead, the acceptance criteria for IST and the alert values were located in a separate document maintained by the shift engineer. According to AP 164, Operations Department In-service Testing, the shift engineer verifies the acceptability of the IST results. No additional renew of IST acceptability is performed. As a result, an error by the shift engineer was not identified until the subsequent performance of the surveillance. The team also noted that the human factors, when comparing the surveillance test results to the IST acceptability criteria, were wea The order that the valves were listed in the IST document was different than that in the surveillance procedure. Consequently, it was more difficult to check that the values were within the acceptable rang Another weakness was the justification for a new pump hydraulic data reference baselin Specifically, following a mechanical pump seal replacement in April 1993, the residual heat removal service water (RHRSW) pump C baseline for pump differential pressure was incorrectly adjusted significantly higher. The justification was that the baseline was altered because of a pump seal replacement. On the subscquent testing of RHRSW pump C, the results returned to the levels consistent with the previous baseline. Based on the new baseline, however, the pump was in the alert range. Vermont Yankee engineering then
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invalidated the new baseline based on the evaluation that the new baseline was incorrectly determined and that the replacement of the seal should not affect the pump hydraulic characteristics and, therefore, the baseline. A PRO was issued to address this instanc The corrective actions and root causes were still under development at the time of the inspectio The team identified that the RHRSW pump A baseline for pump differential pressure was ,
adjusted lower bazd on a seal replacement in April 1993. This adjustment was inconsistent with the justification for pump C that disregarded a required action range value, because the seal replacement should not affect the baseline. If the baseline had not been changed in April, the subsequent three IST tests would have placed pump A in the alert, required action and alert ranges, respectively, when compared with the original baselin .
Discussions with plant personnel showed that the hydraulic portions of the IST baseline were reestablished because the vibration portion of the IST baseline changed from the seal
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replacement. The operations department personnel believed that this was the normal l practice promulgated by the engineering department. Additionally, both engineering
! department and operations department staffs, which have the responsibility for this portion l of the IST program, were unable to provide a basis for why the pump hydraulics would be i affected by the seal replacement. Subsequently, the maintenance department personnel stated that the lift clearances were adjusted by the seal replacement, which, in turn, may affect the pump hydraulics. VY issued a PRO to address the RHRSW Pump A IST baselin The team noted that AP 164 did not provide clear guidelines on justil , n of IST baselin This coupled with inconsistent implementation of this aspect of the IST program is a weakness. The plant staff had identified the pump C problem and was taking corrective actions. A new procedure was being developed, however, several aspects of this problem were still under consideratio Overall, the IST program was properly implemented. The degradation of equipment was appropriately monitored, and the establishment of the initial pump curve for the spent fuel pumps was thorough. Some weaknesses were identified with the program. The single reviewer for IST acceptability and human factors in verifying IST data may have contributed to the failure to identify that valve HVAC-9 was in the alert range. The fragmentation of the program, lack of clear procedural guidance, and weak justifications to establish a new baseline may have attributed to the inappropriate establishment of the baseline of the RHRSW pump C. These issues will be unresolved pending completion of the Vermont Yankee staff review and subsequent corrective actions. (Unresolved Item 50-271/93-80-01)
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3.3.3 Predictive Maintenance The team reviewed the Vermont Yankee predictive maintenance program. The predictive I
maintenance program included vibration monitoring of non-IST ccmponents, thermography, transformer component oil sampling and analysis, weekly yard readingt, battery individual !
voltage readings, and weekly oil round The predictive maintenance program was effective in ideatifying many equipment degrading conditions prior to failure. For example, several temperature rises were noted in electrical equipment such as transformers and breakers. Oil samples identified cloudiness (indication
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of water) in the recirculation motor generator set. Increases in vibration were noted in l
feedwater pumps and a reactor recirculation unit. The main transformer increasing gas
! concentrations were identified. These deficiencies were addressed appropriately through WO's, increased monitoring, and additional analysi The maintenance department has taken steps to enhance this program. A new procedure, AP 0211, Predictive Maintenance Program, was under review which consolidated vibration test and analysis with thermography. The procedure provided detailed guidance on performance of the tests, qualifications of personnel, frequency of tests, test acceptance criteria, and corrective actions. The components, tested under this program, were clearly delineated in matrix tables. Additionally, the plant staff was enhancing component oil sampling j capabilitie Overall, the team concluded that the predictive maintenance program was effectiv i Enhancements to the predictive maintenance program capabilities and program guidance were
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positive initiatives.
l 3.3.4 Reliability Centered Maintenance and Repetitive Failures l
The team noted that the Vermont Yankee maintenance organizaticn was developing a l reliability centered maintenance (RCM) program for various plant systems. At the time of the inspection, the instrument and controls (I&C) department had substantially completed development of the RCM program for their components and systems. The development of I l the RCM program by the maintenance department had just started.
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The team reviewed several RCM documents and noted them to be thorough. Personnel who developed the maintenance recommendations were required to use inputs from a variety of j sources. Examples included preven'ive maintenance guidance from vendor technical manuals, site component maintenance history cards, and licensee event reports. Industry-
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wide experience for a particular component was utilized through a review of NRC generic letters, information notices, and the nuclear plant reliability data system (NPRDS).
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The team noted that Vermont Yankee determined through a review of industry data and the plant performance history that the majority of power supply failures were most likely attributed to capacitor failures. Accordingly, the licensee was implementing a predictive maintenance program focused on determining capacitor performance by measuring the ripple voltage on the output of the power supply. Degradations in output ripple voltage will indicate that the capacitors may have degraded. The team reviewed a compilation of Lamda power supply failures that have been recorded in the NPRDS. The team verified that the majority of power supply failures were attributed to degraded capacitors. Therefore, the team concluded that the licensee's decision to monitor the performance of the power supply capacitors was pruden The team reviewed corrective maintenance, whose apparent root cause was end oflife or normal wear, and how the specific failures were factored into the service life for the components. Discussions with maintenance department personnel indicated that these failures were not factored into the service life of the equipment. The failures, which the team selected, were in systems for which the RCM documentation had not yet been develope .
Consequently, the basis for the service life was not yet fully documented. Maintenance <
department personnel indicated that a systematic approach would not be effective until the RCM program had been completed.
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Based upon a review of the draft RCM documents, the team concluded that Vermont Yankee l
l was using an adequate data base for the development of the RCM program. Additionally, ,
! the team concluded that the licensee was using the information obtained to increase component reliability. Adjustment of service life based on component failures, however, will rely on the completion of the RCM program.
3.3.5 Limiting Conditions for Operation Maintenance !
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The team found that the Vermont Yankee staff adequately planned and controlled the performance of maintenance on safety-related equipment during TS LCOs. The plant l operations review committee (PORC) approved guidelines were of good quality and specific criteria for planning were included to prevent the abuse of LCO maintenance and minimize equipment out-of-service times. Normally, LCO maintenance was performed just before the l
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[ surveillance was due, to limit the cycles and stress, and out-of-service time on equipment.
l This policy v.-as demonstrated during the LCO maintenance on the standby gas treatment system train B, when post-maintenance testing and monthly survei!!ance were done simultaneously.
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17 Surveillance Program 3.4.1 liigh Pressure Coolant Injection Surveillance i The team observed the performance of surveillance procedure OP 4120, High Pressure l Coolant Injection (HPCI) System Surveillance, to determine if the procedure adequately demonstrated system eperability as required by TS 4.5.E. Operators controlled this test very well, based on control room and local observations. The system operated smoothly and the test demonstrated adequate system operation according to the T !
During the review, the team noted that OP 4120 did not ensure that the HPCI pump minimum flow valve MOV-25 opened to ensure at least 400 gallons per minute flow when the pump was in operation. Valve MOV-25 sensed HPCI discharge flow through use of a flow meter on the pump discharge. Insteed, OP 4120 specified that valve MOV-25 was to ;
be cycled to verify operability. Through discussions with Vermont Yankee, the team was informed that the ability of MOV-25 to respond to changes in system flow was assured through the performance of an I&C department surveillance. The I&C department i surveillance performs this task by verifying that the flow sensing element adequately responds to changes in system inputs. Based upon the discussions with Vermont Yankee personnel, the team concluded that the testing which was performed on MOV-25 adequately assured that the valve would respond appropriately to changes in system flow. Therefore, the team concluded that the Vermont Yankee surveillance program adequately tested the HPCI system to ensure the operability require-ments of TS 4.5.E were me .4.2 Entry into LCOs While reviewing surveillance activities, the team noted that Vermont Yankee did not !
routinely enter TS LCOs when the performance of a test rendered the equipment inoperabl i The team noted that NRC Generic Letter 91-18, entitled "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degrading and Nonconforming Conditions and Operability", stated that, unless specifically prohibited otherwise, the TS !
LCO stttement shall be entered when equipment is removed from service and rendered incapable of performing its safety function. The team discussed this guidance with the plant manager who observed that this position was contrary to normal practices at Vermont Yanke The team was concerned that the Vermont Yankee operating philosophy could be a safety concern for the following reasons. TS equipment may be left inoperable for greater than the TS allowed outage time if a TS LCO were not entered. Operators may unknowingly allow redundant TS required equipment to be rendered inoperable by allowing maintenance to be performed on one train and surveillance on the other. However, when the team reviewed the work scope for the previous three-month period, equipment had been returned to service during surveillance testing before the TS allowed outage time was exceeded and work had not been performed on redundant trains of equipment. Therefore, the failure of Vermont
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rendered inoperable during the performance of surveillance tests was not an immediate safety . l issue. Nevertheless, this was another example of weak administrative processe l l
i 3.4.3 Computerized Surveillance Test Tracking System j
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During the development of the new surveillance tracking system, the plant staff continued to report to the NRC about two missed TS surveillances per yea ;
The new system scheduled surveillances based upon the required surveillance interval. For )
! example, a test that was required to be performed weekly may be routinely scheduled for every Monday, while a monthly requirement may be routinely scheduled for the third
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1.25 times interval allow ed by TS. If the surveillance test was accomplished before its l scheduled due date, the computer would note that it was early, and cue management to . i compare the next scheduled date with the drop dead date to ensure that the required i surveillance would not be missed. The system also provided cues if the surveillance was !
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performed later than the scheduled due date, and immediately identified an apparent missed 1 surveillance if the last entered accomplishment date was after the drop dead dat :
l The team concluded that the new computerized surveillance test tracking system was an j improvement over the manual system. Its features provided additional assurance that !
surveillances would not be misse l
I 3.4.4 Standby Gas Treatment Review TS 4.7.B, Standby Gas Treatment System (SGTS), requires that a sample of the charcoal filters be taken and analyzed every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. The team found that the radiation protection (RP) office was responsible for tracking the filter operating hours. The .
RP office performed this task by recording the hours of operation weekly. The remaining hours to filter inspection were then logged and posted at the RP control point. The team l determined that the Vermont Yankee surveillance tracking system was adequate to ensure the filters were inspected as required by plant T .5 Spare Parts Qualification During discussions with Vermont Yankee personnel, the team idenMed an employee perception that spare parts were being disposed of and, therefore, would not be available when needed for repair of old equipmen L L_________ _ . - - - _. .- .-
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l One of the findings by the licensee's Self-Assessment in Materials Management was that a l formal "Insentory Reduction Plan," to eliminate obsolete and surplus inventory, should be
! initiated. A survey of the warehouse had indicated no usage of approximately 10,000 items i in the last eight years. The licensee made a significant purchase of critical spare parts in ;
j 1987, and believed that adequate spare parts were available. One justification for not using l old and possibly obsolete parts for system design changes was that adequate spare parts l would then not be available. The team reviewed the inventory reduction plan and concluded l that this plan was a well thought out initiative. However, failure to communicate the plan and its justification to engineers and maintenance personnel was an example of weak management-to-worker communicatio ,
In discussions with plant engineering, the team became aware of some conflict between the procurement and engineering staffs, in that procurement personnel were making technical l l decisions without plant engineering staff input or knowledge it was stated that engineers l would rather obtain needed parts for plant changes through Mercury (a construction contractor) than through the Vermont Yankee procurement system. Some managers felt that procurement should be a part of engineering instead of being under finance. To resolve these problems, plant management formed a task force to address the employee concer The team concluded that this action was appropriat During this review, the team noted the purchase of updated instrumentation for the main steam line radiation monitors, vessel level recorders, and various transmitters. In addition, a t modification was under consideration to install digital feedwater instrumentation. The team I i considers the upgrading of these instrument systems a positive initiative.
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During the review of the store room inventory, the team noted that a large number of "P" l (parts) tags had conditional acceptance notes. For example, the size and *hread dimensions j l
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of a bolt might be accepted, but the "P" tag states that the material acceptance is the ;
responsibility of the end user. This conditional acceptance caused considerable extra work for the end user, usually I&C, electrical, or mechanical maintenance. The licensee stated l that the procurement staff of three plant employees and two contracted engineers could not l perform detailed one-for-one replacement evaluations. The team received mixed response from the different maintenance departments. The mechanical maintenance engineers stated that they did not have adequate staff to perform the required additional qualifications left as
"P" tag conditional acceptance issues. I&C, however, stated that final equipment qualification should always be the responsibility of the using department. The team ,
identified no cases where "P" tag conditional acceptance issues were not addressed by plant I design change requests (PDCR), engineering design change requests (EDCR), or WO ,
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documentation. Therefore, the current use of the "P" tags was determined to be acceptabl I I
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The team reviewed the relatively new qualification laboratory for independent commercial grade veri 6 cation. This laboratory contained both Rockwell (metal) and Durometer (organic
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materials) hardness instruments, and a X-Met 880 metal content organizer with a considerable number of calibration sources. The Swedish-built, portable X-Met 880 used a l'
radiation source to determine metallic content. It was able to distinguish between the different types of stainless steels. The team considered this new equipment and its related program a good licensee initiativ The engineering staff reduced the number of NCRs during receipt inspection by implementing use of a material disposition request (MDR) grading for incoming part Engineers used the MDR format to accept parts pending the disposition of minor administrative deficiencies. The MDR format required less of an administrative review for processing and thereby reduced the administrative workload of plant personnel. The team reviewed the MDR/NCR process, including a sample of both, for the last two years to determine if MDRs and resultant NCRs were handled properly. During 1992, thirteen shipment MDRs resulted m three NCRs. The engineering staff stated that there has been no significant increase in receipt inspection rejection rate in the last few years. The team
! considered the use of a MDR process, in order to reduce the more extensive NCR process, a
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good initiative.
l Preventive Maintenance l
l 3.6.1 480-Volt Motor Control Center Preventive Maintenance Review The team reviewed the preventive maintenance program for the 480-volt motor control {
l centers. The team verified that the licensee's preventive maintenance program has incorporated the vendor recommended preventive maintenance requirement .6.2 4160-Volt Breaker Preventive Maintenance Program
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The team reviewed the preventive maintenance program and the performance history of the 4 Kv breakers. The 4 Kv breakers were supplied by General Electric and consist of a variety of sizes and types. The maintenance staff performed preventive maintenance on these breakers, including clear.ing, inspecting and lubricating, every three refueling cycles. The governing procedure for the preventive maintenance program was contained in OP 5222, 4 Kv Ac Circuit Breaker Inspection, Calibration and Testing. The team reviewed the
! procedure and noted that it contained the recommended preventive maintenance actions that l were outlined in the vendor supplied technical manua j
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The team noted that the breakers were infrequently cycled. Most of areakers had j between 500-1500 cycles of operation, which was well within the breaker design life. Since j the vendor technical manual did not recommend that preventive maintenance be performed on
! the breakers until 2000 cycles of operation, the team considered the Vermont Yankee 4 Kv breaker preventive maintenance program to be well within the manufacturer's recommendations. The team noted that the licensee was tracking breaker cycles of opemtion and was using the information to equalize wear among the various breakers by swapping breakers from high to low use application The team noted that the licensee was aware of two breaker design weaknesses: prop spring failure and premature wear of the teflon-coated sleeve bearings in the M-13 operating mechanism. To correct both design weaknesses the licensee replaced the defective teflon-coated bearings with improved, vendor-supplied replacement components and commenced a program of prop spring replacement when routine preventive maintenance was performed on the breaker The team reviewed the maintenance history of several breakers and noted that the reliability of the breakers was good. According to plant personnel, no 4 Ky breaker had failed to close when required during the previous two years of plant operation. Based upon a review of the l breaker preventive maintenance program, and the operational history of the breakers, the
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team concluded that the 4 Kv breaker preventive maintenance program was adequate to ensure reliable breaker operatio .6.3 Instrumentation and Controls Department Power Supply Operation l The team reviev/ed the performance history of five power supplies that were installed in the reactor protection, residual heat removal, low pressure coolant injection and the reactor core ,
isolation cooling systems. The purpose of the review was to ascertain the performance of the power supplies, the incorporation of vendor maintenance recommendations and the monitoring of power supply performance. Vermont Yankee used power supplies from four ,
different manufacturers: General Electric, Lamda, Techtronics and Elm The team noted that the performance history of the power supplies, manufactured by General Electric, Lamda and Techtronics, was good. The power supplies manufactured by ELMA had a history of failures and were in the process of being replace The team verified that the preventive maintenance which the licensee performed on the power supplies was in accordance with the vendor recommended guidance. Based upon a review of l power supply operation and preventive maintenance history, the team concluded that the I&C
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department appropriately maintained the power supplies.
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3.6.4 Service Water Pump Performance and Maintenance l ,
l During a tour of the service water (SW) pump room the team noted that the pump motor l casings were hot. The pump motor temperatures are monitored by the plant process computer. An examination of winding temperatures by the team revealed tnat the windings of one pump had reached 240 F. The winding temperature alann limit contained in the process computer was set at 266 F. The team was concerned that the high winding temperatures may decrease the operational life of the motors. Additionally, following a design basis event, the high winding te:nperatures may cause the SW pump motors to fail quickly when the non-safety-related ventilation system stops on the loss of power. Further,
! the high winding temperatures may not be detected by the plant process computer since it is also supplied by a non-safety related power system.
l Through discussions with Vermont Yankee, the team was informed that the high service I
water pump motor temperatures had been reviewed in a 1983 evaluation. The evaluation ;
concluded that, although the pump motors were running hot, the decrease in operational life was acceptable based upon the frequency of motor overhauls. Further, although the winding temperature alarm was above the vendor recommended design limit of 244 F, it was below the 266 F design limit commonly applied for motors of similar configuratio i Vermont Yankee engineering also stated that degradation of the SW pump motors would be detected following a design basis event since the plant process computer was supplied by a station battery that could power the computer for three hours. Once the three hours elapsed, ;
l additional power could be supplied to the computer from a highly reliable diesel generator power supply. Operators could take actions to secure a running SW pump, if they suspected moter degradation. Additionally, temporary ventilation could be supplied to the structur The team reviewed the evaluation concerning the high winding temperatures and determined that it was acceptable. The team also concluded that the present SW pump motor monitoring system would provide operators with adequate warning of potential motor failur The team reviewed the SW pump operational and maintenance history to determine if the licensee's preventive maintenance program was adequate to ensure the SW pump reliabilit However, through comparison the team noted that all of the recommended vendor manual pteventive maintenance recommendations were not incorporated in the Vermont Yankee program. Two of the recommended actions, which were not incorporated, included greasing the motor bearings approximately every three months of operation, and checking the i condition of the lower bearing housing once per year. Although the vendor manuals for the SW pumps and motors did not specifically recommend when the service water pumps or motors were to be rebuilt, the maintenance staff rebuilt the pumps, and inspected and meggered the motors approximately every four year r
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Vermont Yankee was not abic to provide a documented basis for why the vendor
! recommended preventive maintenance guidance was not incorporated into the SW pump motor preventive maintenance, however, Vermont Yankee personnel stated that vendor recommended maintenance actions will be reviewed under a reliability centered maintenance program that was currently under development. The program would require all vendor recommended maintenance actions for a component be compared to the present Vermont Yankee preventive maintenance program. Vendor recommendations that were not currently utilized would then be incorporated into the Vermont Yankee maintenance program. If a recommendation was not used, adequate justification would be provide A review of the SW pump and motor performance history revealed that their performance j
was good. All four motors had been rebuilt only once since the start of commercial l operation. Therefore, the team concluded that the deletion of the vendor recommended l motor preventive maintenance did not appear to have significantly impacted motor service l life.
l Industry Experience Information l
The plant staff and management tracks the review and closure of operating experience information using procedure AP 0028, Operating Experience Review and l Assessment / Commitment Tracking. Incoming information was assigned a tracking number and forwarded to the Shift Engineer for initial review and recommendations. Recommended actions were assigned tracking numbers and due dates. Appropriate reviews of the proposed resolution, usually through the cognizant department head, were performed prior to closur Overdue commitments were reviewed regularly at department head meetings.
l The team reviewed the licensee's response to selected General Electric (GE) Service Information Letters (SILs), Rapid Information Communication SILs (RICSILs), Part 21 reports, NRC Information Notices (ins) and Bulletins. The team concluded that the reviews were generally good and noted improvement in the tracking of follow-up actions and in the documentation of reviews.
! Specifically, the team reviewed responses to several SILs including:
SIL 477, dated December 13, 1988, Main Steam Isolation Valve Closure SIL 475, Revision 2, dated November 28,1988, RCIC and HPCI High Steam Flow Analytic j Limit SIL 452, supplement 1, dated November 18, 1988, Feedwater Element Transmitter Calibration SIL 351, Revision 2, dated April 4,1990, HPCI/RCIC Turbine Control Calibrations.
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l The team found that the plant staff generally provided good documentation in support of their responses to these issues. Howeser, for SIL 477 a calculation had not been completed to ;
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review. (Unresolved item 50-271/93-80-02)
1 l The team also reviewed the plant personnel's response to a 10 CFR 21 report dealing with the emergency diesel generators (EDGs). This report was generated following determination l
l at Arkansas Nuclear 1 that the Fairbanks Morse diesel engine air intake cooling system was not functioning properly. The plant staff took effective action using thermography to i
determine that the reverse flow through the cooling system was not occurring on either of i
! their EDG l The plant staff's responses to 24 NRC Information Notices from 1989 to the present were reviewed. In each case the team found the responses appropriate. It was evident that the quality and depth of the responses had improved over the period of the NRC revie The team identified ard discussed the following process concerns with the licensee: l
- Several reviews of industry experience relied heavily on the MPAC system to confirm i
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that the licensee did not use a particular referenced component. The licensee l indicated that all components used in the plant were not in MPAC. The team l concluded that reviews by using MPAC alone could result in missing referenced equipment. Interviews with cognizant personnel or investigations of maintenance or procurement records were not routinely conducted as a pan of the licensee's operating experience revie * Several reviews of industry experience concluded that existing procedures addressed industry concerns. However, the licensee did not indicate which portion of a given
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did not take any precautions to identify those portions of plant procedures used to address operating experience, nor were there any additional controls to assure that these procedures were not modified in the futur Overall, the team concluded that the plant staff was currently receiving and performing adequate review on industry information. Further, based on reviews of older and newer issues it was apparent that the quality and depth of review had improved.
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25 Maintenance and Surveillance Conclusions Overall, the team concluded that the selected aspects of the maintenance and surveillance program were effective. The material condition of the plant was very good. Vermont Yankee personnel were appropriately identifying, assessing and resolving equipment deficiencies. The maintenance backlog was maintained within a manageable size, with no outstanding significant WO that would impact the safe operation of the plant. The quality and quantity of spare parts were adequately controlled. The preventive maintenance and surveillance testing programs appropriately ensured component operability. Industry information was appropriately assessed and incorporated into the maintenance and surveillance programs.
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Some maintenance and surveillance processes, however, relied heavily on the capabilities of persoanel. Although plant personnel were very capable and performed their functions well, the minimal procedural guidance and additional levels of review were not consistent with a defense-in-depth philosophy. The work order process relied primarily on one person to disposition WORs. Inconsistent level of detail and inaccurate cause codes were entered in the MPAC system. The equipment failure trending was not formal and depended heavily on the effectiveness of personnel and communications. A single individual verified acceptance of IST test results. The IST guidelines for establishing a new baseline were minimal and t
development of justifications was inconsistent.
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Other weaknesses were noted including operations staff control of out-of-service equipment during testing. Additionally, documentation of deviations from the vendor preventive
! maintenance recommendations, and feedback of component failure for adjusting service life
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were lacking; however, these areas were contingent on the development of a RCM progra Overall, the team observed no indication that safety-related equipment degradation was occurring in a systematic fashion. While there were specific equipment failures, the team did not identify any fundamental weaknesses that would have allowed equipment to degrade i to a point where it would not perform its safety functio The plar.t staff and management effectively identified numerous program weaknesses, including many of those described above, through self assessments and audit Consequently, management has made, and continues to make, improvements. Aspects of the predictive maintenance program were being consolidated and detailed guidance provide Effective actions were taken to increase the consistency of WO documentation and accuracy of the failure codes. Improvements were made to the control of spare parts. A pilot program was being implemented to enhance equipment trending. A reliability-centered maintenance program was being developed, which was effectively using industry and plant specific informatio .-
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, Although some initiatives were too early to assess, plant management's efforts in self-identifying weakness and areas for improvement were noteworthy. The progress made toward addressing weaknesses was appropriat .0 ENGINEERING AND TECIINICAL SUPPORT The team addressed this area by observations and by interviewing site, corporate, and contractor engineers, management, supervision, and working personnel and assessed the engineering support by interviewing operations and maintenance personnel at all levels of responsibilit .1 Engint cring Organization and Staffing The engineering organization at Vermont Yankee was set up on the basis of classical engineering discipline, i.e., mecuanical/ structural and civil, and electrical and instrument and control. The site engineering organization was headed by an engineering director who reported directly to the Vice President of Engineering in the corporate office. The engineering director was assisted by three engineering supervisors in providing management direction, control, and scheduling of day-to-day and long-term assignments to the engineering staff. The site engineering staff was responsible for providing day-to-day engineering ;
support to the plant operation, designing simple modifications, temporary modifications, and implementing construction and erection of major modifications and design change The team determined that the site engineering was adequately staffed by competent engineers
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and administrative support personnel. There were six contract engineers working in the engineering department, three each in the electrical and mechanical sections, but their work was controlled in the same manner and by the same procedures as the work of staff engineers. The licensee provided upgraced training to the staff to improve the quality of !
safety reviews performed at the sit The review of time tracking records and graphs indicated that no excessive overtime work was being performed by the engineering staff during normal operation of the plant. This time tracking of the engineering department included contract engineer's time. In addition, overtime was appropriately used and controlled for engineers, during the outages and other -
unusual operating circumstance .2 Design Changes and Modifications l Design changes to the plant were made using two processes. More complicated and :
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i specialized modifications and design changes were performed by the Yankee Nuclear Services Division (YNSD), located off-site at Bolton, Massachusetts. These changes were documented using engineering design change requests (EDCRs). less complex changes were prepared by the on-site engineering group in plant design change requests (PDCRs).
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4.2.1 Design Change Process and Prioritization The team reviewed the process for making design change improvements to the plan Licensee personnel stated they have always had more ideas to improve the plant than the resources to implement such ideas. As a Commitment to Excellence Program (CEP)
initiative, as described in a May 27,1992 memorandum, the licensee started a pilot program to identify and prioritize the items that were on the work list. This program required the ,
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initiating department to provide an expanded description of the problem or idea, suggested fix (including expectations / requirements), some justification to help prioritize the job (reactor or personnel safety, improved perfonnance, ALARA, etc.), and a sponsor for the idea. After management approval, the idea was put on the "wishlist", sent to engineering to l provide a gross cost estimate, and then prioritized by plant management. Ideas that made the i major project list were budgeted and only then fully scope ,
The team reviewed the latest department heads "wishlist" status report, dated June 1,199 This listing showed 13 high priority requests,17 medium priority requests and 22 low priority requests now included on the Project List, and 14 requests that were recommended to be dropped from the wishlist. Team review indicated that Vermont Yankee management l
effectively controlled this process.
4.2.2 Review of Design Changes i
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The team reviewed a selected sample of design changes performed by the licensee's on-site and off-site engineering and technical support organizations. The intent of this review was to determine the technical adequacy of the design change and modification, and the quality of !
the engineering and technical staff efforts for the modificatio The team selected the following EDCRs for detailed review. The sample included design changes from electrical, mechanical and structural areas, and included safety evaluations performed pursuant to 10 CFR 50.59 requirement !
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EDCRs:
89-402: Upgrade of Seismic Instrumentation
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90-406: Torus Hardened Vent System Modification
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90-408: RBCCW Isolation / Return System Valve (70-117) Power Supply Modification 92-404: RHRSW Valve 89 A & B Replacement 92-405: DG Relay Replacement 92-408: GL 89-10 MOV Improvement l
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l To determine the adequacy of efforts in minor and/or simple design changes that were performed by on-site engineers, the team selected the following plant design change requests.
l The PDCRs were reviewed to assess the technical adequacy of the design change effort, the l safety evaluation if required, and the validity and depth of the safety evaluation included with l the design change packag PDCRs:
91-002: Containment Spray System Valve Improvement i 91-0(M: Instrument Air Dryer Skid Replacement 91-005: ECCS Test Switch /Undervoltage Input
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- Refueling Bridge Modification
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92-014: HPCI Loop Seal TM-91-025 - Conversion ,
93-001: Turbine Exhaust Fan l A/B, Reactor Exhaust Fan 1 A/B Discharge Dampers Replacement Based on the above review and discussions with responsible engineers, the team determined that the EDCRs were of high technical quality, and included good engineering analysis and satisfactory safety evaluations. The modification / design change packages were adequately documented and controlled, and overall effort in this area was of high quality. The PDCRs contained adequate technical detail and included acceptable safety analysis if they affected safety-related systems. Also, they included satisfactory engineering analysis as the basis of these design change .3 51anagement Oversight The team reviewed the " Engineering Department Status Reports" for January and
! April 1993. The reports provided a comprehensive tabulation and analysis of the j department's work load, staffing, work in progress and project status, and administrative and j budget information, and were approved by the engineering directo The team found, through review of these reports and individual interviews and discussions with engineers, that on-site engineering staff was working on more reactive jobs vice long-
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term project work. Because the licensee does not have a " system engineering" group, the i i day-to-day operational support to the plant systems was provided by assigned engineers for l the particular discipline needing engineering attention. However, by review of the safety i
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evaluations, on-site design change efforts, and temporary modifications, the team determined -
that the engineers were providing adequate technical support and design change and l modification services to the plant.
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The team reviewed how the licensee tracks the status of YNSD work by an engineering status report (site program) and a weekly project status report (YNSD at Bolton program) I which is sent to site engineering weekly. Additionally, there was suf6cient engineering interface between site engineering and YNSD engineering management and staff to ;
communicate any sudden change of schedule from the published schedule. The team determined that site engineering adequately tracked the engineering work being performed by YNSD at Bolto .4 Engineering Support to the Plant The engineering staff representative to the morning meeting rotated monthly and provided input for plant conditions and maintenance work. For example, on June 16, the decision to :
not reduce power on the weekend and shutdown the reactor building ventilation system
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affected other engineering work related to general access to the reactor building. This was effectively communicated to the affected engineer During the team review of MPAC (see Section 3.1), an engineering initiative to make the i MPAC more usable was noted. A new Screen 10 was created to contain, in a summary form, a number of Delds related to a particular component-based engineering progra Fields included Safety Class, EQ Program Issues, Appendix J, MOV Program, IST Program, Vital Fire, and NPRDS, and will be entered by the engineering staff by the end of 199 These data will then be maintained current by assigned engineers. The team considers this MPAC enhancement to be a positive initiative by engineerin l l Yankee Nuclear Services Division Support to Vermont Yankee During the course of the above review and evaluation of the design change and modification f process, the team noted that the licensee's off-site engineering organization (YNSD) not only i provided engineering services to the plant on request, but also was actively engaged in reviewing plant systems and processes to recommend upgrading and/or betterment in safety and reliability. Examples included upgrading the existing Vernon Tie Line; replacement of -
generator step up transformer; and development of a new drawing series A19160 to provide :
enhanced controls on MOV limit switche {
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On the basis of the above observations, the team concluded that YNSD was actively engaged )
in improving plant safety and reliability, and was not a passive organization to just fulfill the l Vermont Yankee request l l
In the area of plant support and " minor" modifications (PDCRs), the team noted that the on-site engineers were knowledgeable of plant systems and procedures, and able to recognize the limitation of technical resources on-site. When this occurred, YNSD helped in resolving technical issues. The team found that YNSD demonstrated adequate expertise in the development and implementation of modifications in the field. YNSD was also involved in the development of the EOPs and the Net Positive Suction Head (NPSH) envelope curve for l
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safety-related pumps. The team did not identify any major design or installation problems, J inadequate safety evaluation, and/or inadequate technical response to plant events by either
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off-site or on-site engineering organization .6 Design Basis Program The team reviewed the design basis program administrated by the Vermont Yankee corporate engineering office. As with many pre-1970 designed plants, the final safety analysis report (FSAR) was considered the primary design basis document. The plant design bases are provided in Chapter 15 and at the beginning of each system chapter of the FSAR.
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Supporting design information was available in the " Vermont Yankee Engineering Program",
a computenzed listing of 23 types of documents.
l The licensee demonstrated how this system functioned to make design basis information l available to their staff. The TS and FSAR sub-systems presently contain only the indexes of these documents, but information on any plant system (i.e., HPCI) or subject (i.e., testing)
can be easily searched to locate the appropriate document information. It is planned that these directories will someday contain the entire text of the TS and the FSAR. The team request for a list of HPCI drawings produced a multiple-page listing of all drawings with
"HPCI" in the title. The licensee indicated this system saves considerable time in locating plant information. While not all menu items are fully functional, data entry continues as ;
time is available. The team found that the Engineering Program was a good licensee !
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l The licensee presented the status of the design basis reconstitution effort. Some of the l
engineering projects recently completed or working include the FSAR rewrite program, LOCA reanalysis (scheduled to be completed by the end of the upcoming refueling outage),
piping redesign, service water upgrade, electrical design review, fire area improvements, and reactor vessel reanalysis. The licensee stated they are committed to respond to system issues as they arise. This was demonstrated by team review of licensee response to system issues that arose during the inspection. The team concluded that appropriate design basis programs exist at Vermont Yanke .7 50.59 Safety Evaluations The last SALP identified problems with the quality of 10 CFR 50.59 safety evaluations (SEs); however, the team noticed that current safety evaluations were comprehensive and of high quality. The team reviewed a selected sample of SEs performed by the licensee's engineering and technical support on-site and off-site organizations. The sample included six l such SEs performed by YNSD at Bolton, MA, and at the plant site by licensee engineer l These SEs were for design changes or for day-to-day operational support for the plant staf This review was done in conjunction with design changes and modification program reviews j and is discussed in Section 4.2.2 in detai l l
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The team determined that the safety evaluations performed by the licensee's engineering support organizations were of high technical quality and adequately analyzed and evaluated safety of the affected systems under changing circumstance .8 One-for-One Evaluation The team reviewed the licensee's "one-for-one" replacement evaluation for the control room air-conditioning system chiller. The function of the chiller is to provide chilled water for the control room air-conditioning system and reject the heat to the condensers located on the roof. The existing chiller (model 30HS060-A160) was supplied by Carrier Corporation at the time of the original construction of the plant. The proposed chiller being evaluated for .
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replacing the original chiller is also a Carrier Corporation equipment (model # 30HLO60-631), and is designated by Carrier as the replacement equipment for the original chiller. The j
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manufacturer has certined that the replacement eqmpment is " equal to or better than" the original chiller in electrical, mechanical, and environmental performance. The licensee .
evaluation found the replacement chiller was acceptabl !
I By review of the data sheets for both of the chillers, the team veriGed that the replacement chiller was equal in performance to the original chiller. In electrical performance, it was more ef5cient as the new chiller required less power input for the same heat removal. The team determined that the "one-for-one" replacement evaluation for the chiller was acceptable.
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The team reviewed the licensee's projected work in the area of MOV initiatives, prepared by YNSD, as documented in design package EDCR 92-408. This EDCR was scheduled to be ,
implemented during the next outage and would make a number of TM changes permanen l The design change modined selected valve actuators in order to meet GL 89-10 l requirements, and was one of a series of MOV improvements. The licensee's MOV l improvement program included modiGcation of the original design of actuator circuitry l
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(EDCRs86-406 and 87-408), adding SB actuators and removing motor brakes, providing l
four train limit switches, and incorporating torque switch by-passing circuitry (EDCRs 88- l 402,89-406, and 89-408). Overall, the team concluded that the licensee's efforts in this area !
l were adequat I l The team identined a potential operability concern with the reactor water cleanup (RWCU) '
l inboard (V12-15) and outboard (V12-18) containment isolation valves. The valve operators (0.36 HP Limitorque SMB-000) have a nominal thrust rating of 8000 lbf. The licensee used I a maximum differential pressure (DP) of 1,089 psid across these valves for development of the calculated thrust needed per their MOVATS data base. Per the licensee, closure of these i valves under this DP requires 9,949 lbf, which was in excess of the nominal rating of the actuator. The team found that an initial safety assessment of this condition, provided by the engineering staff, was subjective and did not fully address valve operability.
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The team identified this operability concern to the licensee on June 29 and discussed it in a conference call with the MOV coordinator and YNSD. Subsequently, the engineering staff j provided a revised operability assessment on June 30. The licensee recalculated available motor thrust for each valve at its design undervoltage condition and determined new thrust l values of 9,677 lbf for V12-15 and 12,517 lbf for V12-18. In addition, the licensee noted j
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that Limitorque technical update 92-01, allowed up to 2000 operations of their valve actuators at 140% of rated thrust (11,200 lbf). This thrust was in excess of that needed for closing of either valve and provided the basis for their operability assessmen The team also questioned the " weak link analysis" for these William Powell valves to ensure l l
that drive train failure was avoided. Since the closing torque switches for these valves were bypassed for 99% of full stroke, the full torque of the motor was transmitted through the valve drive train to stroke either valve fully closed. The licensee reviewed the " weak link analysis" received from the William Powell valve company and concluded that the valve ,
I structural capabilities were in excess of the calculated output ;hrusts. The team concluded that the licensee's assessment provided reasonable assurance of RWCU valve isolation capabilit .10 Engineering and Technical Support Conclusions ,
l The team found that the on-site, corporate, and YNSD staffs adequately supported safe plant !
operations. Engineering and technical support, work prioritization and tracking of engineering efforts were appropriate. Plant design changes prepared on-site and off-site were well documented including adequate safety evaluations. Actions taken to improve the safety evaluations provided from YNSD engineering have been effectiv .0 MANAGEMENT PROCESSES AND CORRECTIVE ACTIONS 1 Self-Assessment Initiative Early in 1993, licensee management began a review of the effectiveness of their self-l assessment programs. Following this review, Vermont Yankee senior management issued the Observation Program and the Self-Assessment Policy in May and June 1993, respectively. The team found that these new initiatives were well developed, but the overall effectiveness could not be assessed until they became fully implemented and had time to become effective.
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5.1.1 Observation Program The Observation Program, beginning in May 1993, provided objective methods "to identify strengths and weaknesses" and specified acceptable standards "in the areas of industrial safety, radiation protection, material condition, housekeeping, fire protection and the general ;
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j conduct of doing work." It specified responsibilities for frequent supervisory obsenation of plant activities, and required management review, trending and corrective actions. The program included observation within the supervisor's department and in other depanment work area :
The team reviewed approximately sixty recent observation reports for adequacy of the issues addressed, thoroughness of the review and corrective actions, and frequency of observations i relative to the requirements of the program. The team concluded that most of the designated personnel were conducting observations in accordance with the expected frequencies, and that [
most observations provided useful findings and immediate corrective actions. The team j noted that the observation report form cued immediate corrective actions including the initiation of process documents as necessary, and observed umt many completed reports documented immediate corrective actions and/or initiation of work order requests. The team noted the following weaknesses in a few of the observation reports: (1) Although ;
deficiencies were observed, no actions were taken or recommended for those deficiencie '
(2) There was no clear definition of areas observed, making it difficult to hssess the effectiveness of the observatio The team concluded that the Observation Program has the potential to assist the licensee in lowering the threshold for entering corrective action processes. The program requires cognizant department head reviews of observations to identify trends and to ensure that adequate observations are being conducted. The team concluded that the ability of this program to fulfill its potential value relies on the department heads' review, trending, and communication of their expectations.
l 5.1.2 Self-Assessment Policy The new Vermont Yankee Self-Assessment Policy was issued in June 1993. Although each department had conducted informal self-assessment in the past, no formal self-assessment policy or guidance existed. The team reviewed several older internal self-assessment reports
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accomplishments and their effectiveness, many self-assessment reports were merely lists of accomplishments with little or no assessment.
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The Self-Assessment Policy was issued the week before the inspection and plant staff actions were not available for the team's evaluation. The Self-Assessment Policy provides guidance and requires supervisors to develop departmental self-assessment plans. It also requires incorporation of self-assessment activities as an element to be evaluated by the licensee's quality assurance (QA) audit program. The team reviewed the guidance provided in the policy statement and the initial specific department assessment plans. The team found that this effort was well developed and, based on the initial plans, should lead to a good, in-depth self-assessment effor .2 Corrective Action Systems The licensee's .mid-1992 audit of corrective actions identified concerns that the threshold for entering corrective action processes was too high. In response to this concern, the licensee revised its Corrective Action Guideline to include an augmented list of events which should be considered for significant corrective action review. During a late-1992 audit of Operating Experience Assessment and Corrective Action, the audit team re-audited the threshold issue and identified several events in the operator logs that it felt should have been considered for review but were not. The licensee concurred that the threshold was still too high, but rejected funher action on the events cited in the audit, noting that " Vermont Yankee l considers its work order process as a corrective action process for processing routine l equipment failures." The team reviewed the licensee's corrective action processes to determine if the licensee's resolution of identified problems was effectiv .2.1 Corrective Action Processes The Vermont Yankee Corrective Action Guideline (CAG) document describes the interaction of various corrective action processes implemented in plant procedures. The Vermont Yankee staff uses a two-tierd method to classify conditions adverse to quality. The lower, entry-level tier involves routine processes which identify potential issues for reportability evaluation (potential reportable occurrence (PRO)) or the need for work assignment of a WOR. Generally, these processes do not require any rigorous root cause analysis, identification of similar conditions in other systems or components, or corrective action processes. During management review of PROS, the cognizant department head or superintendent makes recommendations regarding the need for significant corrective actio The higher tier includes licensee event reports (LER), significant corrective action reports (CAR) and significant nonconformance reports (NCR). These processes require root cause analysis, evaluation of similar conditions and corrective actions. A nine-element evaluation is required for significant events. This evaluation is required for every LER, significant NCR or significant CAR. These detailed evaluations are normally not generated for PROS, corrective WOs, radiation protection incident reports, quality control findings, or material deficiency reports. By establishing this hierarchy, the licensee has established the threshold for evaluation between the two tier l
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i The team reviewed the listing of about 100 PROS and 40 CARS initiated within a year of the inspection. Based on that screening, the team selected approximately 40 PROS and 20 CARS for in-depth review. The team found that the implementation of these two processes l generally allowed proper assessment and corrective actions to be taken. However, there were weakness identified, as outlined belo .
5.2.2 Review of Potential Reportable Occurrence Reports The team highlighted the following examples of PROS, which indicted weaknesses in the corrective actions and evaluations of problems :
PRO 92-55 documented a failure of the 1A uninterruptable power supply (UPS) with an inoperable diesel generator (DG-1-1 A). DG-1-1 A was made inoperable to repair defective cylinder liners and other camponents under a temporary waiver of compliance of Technical Specification (TS) 3.5.H.l. As a result of this, the licensee declared an unusual event at 7:50 p.m., June 27,1992, and notified the states of New Hampshire and Vermont and the Commonwealth of Massachusetts which required an immediate notification per 10 CFR 50.72(a)(i). The PRO 92-55 reportability evaluation initially concluded that this event was not reportable as a shutdown required by TS. This was based on the issuance of a waiver for TS 3.5.H.1 for DG-1-1 A inoperability. TS 3.5.A.6, which was not addressed by this waiver, requires the initiation of a plant shutdown if TS 3.5.A.4 is not met. The licensee used the temporary waiver for the DG as a basis for their original reportability determination. This appeared inappropriate since the waiver was for a different TS. This decision was later remanded and CAR 92-27 was initiated. The licensee cancelled CAR 92-27 and submitted LER 92-18. During review, the team noted that the licensee did not l specify the basis for their revised reportability decision or their use of a waiver to justify the l original reportability determinatio PRO 93-09 addressed a licensee concern regarding compliance with Technical Specification (TS) 4.7.A.3. TS 4.7.A.3 requires that the adequacy of the containment boundary be demonstrated prior to conduct of maintenance that violates the integrity of certain systems (i.e., those systems that are connected to valves listed in Table 4.7.2b). In this case, the system was the containment hydrogen / oxygen (H/O,) monitoring system. The licensee's evaluation concluded that TS 4.7.A.3 does not apply to H/0 2monitoring system maintenance
"because primary system integrity is maintained" by closing manual isolation valves VG-29A(B) and VG-30A(B). The licensee further concluded that the " isolation is provided by a valve which meets or exceeds the original requirements." The team concluded that TS 4.7.A.3 applies to the H/0 monitoring 2 system which was connected to valves listed in Table l 4.7.2b. The team concluded that the TS requires demonstration of the adequacy of the valves used for isolation (VG-29A(B) and VG-30A(B)), but that TS 4.7.A.3 assumes that the valves in the H/0 monitoring 2 system are not leak tested by the licensee's Appendix J program. In fact, the licensee's Appendix J integrated leak rate test exposes manual isolation valves VG-29A(B) and VG-30A(B) to Appendix J peak containment pressure, P.. Therefore, the team concluded that the licensee had satisfied the intent of TS 4.7.A.3. However, the l
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team disagreed with the licensee's conclusion that TS 4.7.A.3 does not apply to the H/02
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monitoring system, but rather concluded that the assumptions of TS 4.7.A.3 regarding the licensee's Appendix J testing of the H/0 2monitoring system were inaccurate. The licensee is evaluating this issue for corrective actions as significant CAR 93-0 PRO 93-10 identified the inability to re611 the security systems DG fuel oil (FO) day tank following a surveillance run. After completion of the surveillance, the FO transfer pump was started and both the motor and pump rotated. However, there was no observed FO flow into the day tank. The licensee noted one possible cause as freezing. A WO was written to !
investigate the cause of the inadequate flow. The pump was disassembled and no cause was l identified (i.e., blockage, freezing, valve lineup, etc.). After reassembly, the pump was started, and the day tank was refilled. No additional follow-up actions were taken to prevent recurrence even though freezing was considered as a likely caus PRO 93-42 addressed broken shear pins on the control rod drive (CRD) rebuild room door which had not been replaced for more than one year. Disapproval of work order requests for this task was attributed to lack of documentation of the "true purpose and intent of the shear pins and why they are required (i.e., for EQ [ environmental qualification] or for high radiation protection)." Attached to the PRO were a series of management questions regarding various potential procedural and documentation failures which may have contributed to the occurrence. Although a commitment tracking item was issued to engineering to address the management questions, the block for "None" was checked under
" Additional Corrective Action Process Required." Licensee resolution of the management questions was still in progress at the time of the inspectio ;
The team noted that the last two PROS identified problems that should have required additional corrective action. The first two PROS did receive additional follow up. However, there was no critical evaluation of the decision making process used to reach the licensee's conclusion. The focus of the PROS on reportability directs licensee resources away from an expanded evaluation of any given event. The PRO does allow for additional corrective actions during management review. However, the assignment is strongly biased by the short event description provided on the PRO. Thus, the follow up varies widely from PRO to !
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l 5.2.3 Root Cause Analysis '
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Vermont Yankee's procedure AP-0007, " Corrective Action Reports", contains a " User's l ;
Guide for Root Cause Analysis". Several significant corrective action processes require root cause analysis and reference the user's guide, which provides a flow chart of possible causal factors. The team reviewed the user's guide and selected licensee event reports (LERs) and significant corrective action reports (CARS) to evaluate the effectiveness of the root cause analysis performed. In addition, several routine CARS which contained root cause analyses were reviewed.
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The team found that the user's guide provided specific direction and that it highlighted common errors in root cause analysis such as excessive reliance on " personnel error" masking potential problems with processes or equipment. Although the user's guide did not explicitly comment on the pitfall of preconceived notions, the team concluded that i systematically following the guide should prevent root cause determinations swayed by preconceptions. The team concluded that the user's guide was a useful tool. The licensee indicated that all engineers were required to receive approximately four hours of training in use of root cause analysi l All significant CARS reviewed contained some root cause analysis. Not all root cause analyses were documented using the forms provided in AP-0007, however all did provide some documentation of the process used to arrive at the root cause. Significant CAR 92-31 evaluated a spill from the condensate demineralizer backwash receiving tank which was a ,
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complex event with many contributing causes. Although the root cause analysis was not well I
documented, the team concluded that thorough management review had developed a comprehensive set of corrective actions which addressed all of the deficiencies that led to the !
spil For other significant events reviewed, only two root cause flow charts and one detailed event chronology were found. In addition, no cause-and-effect charts were foun Notwithstanding this, these evaluations were found to be generally complete and to address most of the root causes and causal factors that led to a given even The team also evaluated cause determinations in other corrective action process documents (PRO, routine CAR, etc.). The team noted that the statement of root cause for PRO 92-44 (Ground in DC-2A for RHR-57) was, "The root cause of the ground was traced to a bare l power wire in the DC-2A breaker cubicle." The team's concern was that a bare electrical l wire was the deficient condition, not the root cause. This statement was an example of not l making good root cause determinations.
l The team concluded that the licensee had adequate root cause analysis procedures and i
training, but that the documentation of root cause analysis should more clearly demonstrate the process followed to arrive at the stated cause .2.4 Corrective Action System Conclusions The licensee's two-tierd CAG documed significantly minimizes the allocation of resources for routine events. For many recent P. Os, this results in very little additional evaluation I
beyond that required for reportability. i ne team noted that the Vermont Yankee staff's implementation of this two-tierd CAG resulted in a very thorough review of significant issues and, in most cases, very little further evaluation of routine items. The team reviewed CARS, PROS, audits, NCRs and other station programs to determine if the threshold established was appropriate to permanently resolve issues and to prevent their recurrence. The team concluded that the licensee's corrective actions systems were adequate for addressing I
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significant issues when raised, however, the team concurred with the licensee's findings that the threshold for entering the more rigorous application of root cause determinations needs to i be lower to provide better opportunities to identify recurring problems and to trend failure .3 Quality Assurance Activities {
The quality assurance (QA) department of Yankee Atomic Electric Company (YAEC)
cc acts the QA program at Vermont Yankee, which includes the periodic audits required by tectuueal specifications and the vendor qualification program. This QA group, located in Bolton, Massachusetts, also conducts audits for Yankee Rowe and, as requested, provides auditors for other nuclear power plants in New England. For Vermont Yankee audits, the group routinely calls in technical specialists from Maine Yankee, Millstone, Pilgrim, ,
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Seabrook or Yankee Rowe. Audit plans for the upcoming quarter and audit results from the past quarter are reviewed each quarter with the licensee's Nuclear Safety and Audit Review Committee (NSARC).
l The on-site QA function is provided by the quality services group (QSG) which consists of approximately six YAEC employees. QSG augments or supplements many of the activities i
administered by the YAEC QA group. QSG conducts surveillances on elements of the two- ,
year audit plan prior to scheduled QA audits. One QSG member routinely participates in
- each QA audit. In addition, QSG membe- participate in audits at other plants. The QSG <
l also provides independent assessment as requested by the plant staff.
5.3.1 Quality Services Group /!r.0.cpendent Inspection The team reviewed recent Q5G surveillance reports and concluded that the surveillances were thorough and comprehensive and that the findings were well focused. The QSG surveillances evaluated a good balance of plant response to developing problems, plant execution of i routine evolutions, and evaluation of programmatic issues. The team noted an increase in l QSG surveillances, in response to department supervisor requests, as a licene stiengt !
l This demonstrated increased licensee awareness of the value of QA findings in the self-assessment process.
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- The team evaluated the licensee's procedure, AP 6025, Rev. 3, " Quality Control / Independent j Inspection". The procedure implements independent inspection quality control requirements l
through peer inspection, and defines the qualifications for a peer inspector. Selection criteria j for identifying activities for independent inspection are stipulated, however, no management
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expectation is provided regarding the amount of independent inspection expected. This weakness was identified by the licensee in the 1993 QA audit of maintenance / instrument and control l r
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5.3.2 Off-Site Audits The team reviewed YAEC procedure OQA-XVI-2, Rev. 2, " Audit Evaluation and Corrective Action". This procedure defines the categories of audit findings and describes the corrective action processes. It designates responsibility for development of the plant response, to include time frame for resolution of audit findings, and responsibility for implementation of resolutions. It provides for evaluation of the plant management response by the audit team leader and avenues for appropriate level of management involvement in resolution of disagreements between the audit team leader and the plant staff. Open items are to be reaudited by the QSG on a bimonthly basi '
I The team reviewed recent Technical Specification (TS) audits. The licensee's February 1991
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l TS audit which followed up on a previous surveillance finding found that the licensee's
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method of surveillance tracking was vulnemble to missed surveillances. Specifically, manual tracking allowed for errors such as surveillance completion dates not being properly !
recorded. This could result in tracking from the scheduled date of the last surveillance rather than the actual date of completion that may have been earlier. Furthermore, the audit found that the licensee routinely scheduled surveillances for 1.25 times the surveillance interval (the maximum interval allowed by TS). This combination, the audit team found, could result in missed surveillance The licensee's February 1991 audit evaluated the findings of corrective action report (CAR)
91-25 that stated that "the 1S (1.25 times interval) margin is not to be used as a routine ,
practice." In March 1991, in response to CAR 91-25 the licensee conducted a review of the Master Surveillance List and the TS/ Implementing Procedure List "to ensure that the information contained in these lists is accurate and complete." The licensee concluded that its manual tracking procedure was adequate, but tiat it "is not efficient and errors will be ;
cxperienced if the procedure is not fchwed correctly." Therefore, the licensee's corrective i actions included implementatien of an upgrade to its computerized MPAC system for surveillance tracimg. 'tne program upgrade, which was under development at that time, was expected to use the date of performance of the last test to calculate the " scheduled due date" and the "last permissible ... date" for a next test. Since March 1991, the licensee has undergone several iterations in the de ; 'nt and evaluation of the sun'eillance tracking program. The system was implemento a e g the Spring of 1993. The team reviewed the tracking system and the surveillance accomplishment interval for more than one hundred recent surveillances. The team concluded that tha licensee does not, as a routine practice, use the TS-allowed 25% increase in the specified surveillance interva!. The team also concluded that the tracking system addressed the concerns raised in the 1991 audit and that the system should prevent future missed survehnces. (See Section 3.4.3.)
The team concluded that the licensee's quality assurance program was robust and effectively )
implemented. The team noted an improving trend in management involvement in audit and surveillance planning, evaluation of findings, and implementation of effective corrective action .
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l Plant Operations Review Committee and Nuclear Safety Audit and Review Committee The team observed the conduct of the plant operations review ccmmittee (PORC). The PORC meeting was overseen by the vice-chairman and included four members for a quorum.
l An agenda was pnblished before the meeting and primarily included the review of plant l procedures. Some procedures reviewed were not included in the agenda. During the
- meeting, various PORC members discussed the procedure changes from a summary memo for the reviewed procedures. Thc members questioned the procedure reviewers on the changes. The PORC also required the reviewers to certify that the change had no affect on the TS, Final Safety Analysis Report (FSAR), and the Yankee Operational Quality Assurance Plan (YOQAP). The members actively questioned the reviewers on the material presented.
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The team found the licensee's PORC conformed to the requirements of TS. The chairman
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questioned the safety impact of a procedure deletion for ontite painting. Other changes were l approved with minimal discussion. Recent PROS were reviewed for informational purpose The PORC did not provide any recommendations for followup of these issues nor question the status of any commitments generated from these PROS. The team considered this lack of followup a minor weakness. Upon questioning the PORC members about this matter, the team determined that the members expected that their questions would be answered on
- followup of certain procedures or PROS. However, these questions were not provided in i
their "up-front" review of the issue / problem. In later discussion, the PORC chairman noted that these could be tracked with the procedure or under a separnte AP0028 commitmen The licensee was considering including this approach in future PORC meeting The team attended the quarterly Nuclear Safety Audit and Review Committee (NSARC)
meeting for the review of audits. The team found that the review of the audits conducted during the previous quarter was thorough and comprehensive. The audit team leaders presented the teams' fmdings and the committee exhibited good concern for safety implications and a strong desire to understand the programmatic implications of the audit findings. The audit group supervisor presented the plans for audits for the upcoming quarter including elements requested by the plant staff. Input to the plans was provided by the committee. The team concluded that the committee was an effective tool for review of audit plans and fmdings and that a good q'.:estioning attitude was pervasive on the committe .5 Management Processes and Corrective Action Conclusion l
The team noted that the licensee had initiated two new programs /;)olicies (Observation l Program and Self-Assessment Policy) since the last SALP in an attempt to reverse a
! performance decline m the safety assessment / quality verification functional area. In addition, licensee management had taken a more active role in the resolution of plant problems and other performance issues. The team noted a general improvement in the resolution of these issues over the past year. However, some weaknesses were noted in the degree of followup on certain routine items. PROS deemed not reportable received very little additional I
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followup. The separation provided by the licensee's corrective action guidelines (CAG) into two tiers inherently established the level of followup for events classified as " routine" at a minimal level. As a result, these problems were typically fixed by corrective maintenance, '
with very little self-assessment of the hurnan c.r procedural factors that led to a given problem or issue. The licensee had identified some of these weaknesses and was taking action to correct the The team noted that many of the recent QA audits were exceptional. These audits probed many areas and their findings and conclusions were concise and comprehensive. Various departments responded differently to these audits. The team noted that the departments that took prompt and extensive actions in response to these audits had a healthy attitude toward self-assessment. (See Section 5.3.2) Some responses were conciliatory in nature. The licensee had noted the variability in responses and was taking action to improve the self-assessment ethic of the entire statio >
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The team reviewed the activities of PORC and NSARC and found them to be of high qualit i
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Both committees probed the issues presented in detail and fulfilled their safety review responsibilities well. One minor deficiency was noted with the PORC's followup of plant events and problem :
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