IR 05000271/1999005
| ML20216D740 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/26/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20216D735 | List: |
| References | |
| 50-271-99-05, NUDOCS 9907300088 | |
| Download: ML20216D740 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
I Docket N Licensee N DPR-28 Report N Licensee: Vermont Yankee Nuclear Power Corporation
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Facility: Vermont Yankee Nuclear Power Station Location: Vemon, Vermont Dates: May 10,1999 - June 20,1999
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Inspectors: Brian J. McDermott, Senior Resident inspector i Edward C. Knutson, Resident inspector Robert J. Summers, Project Engineer Lonny L. Eckert, Radiation Specialist John E. Richmond, Resident inspector - Susquehanna Approved by: Clifford J. Anderson, Chief Projects Branch 5 Division of Reactor Projects i
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9907300008 990726 PDR ADOCK 05000271 G PDR l
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EXECUTIVE SUMMARY Vermont Yankee (W) Nuclear Power Station NRC Inspection Report 50-271/99-05 l
This integrated report covers a six week period of inspection and includes aspects of licensee operations, engineering, maintenance, and plaat support. In addition to the resident inspector activities, an announ::ed inspection of the Radiological Effluents Program was conducted by an j inspector from the NRC's Region I office.
l Operations l
Conirol room operators were conversant regarding the status of plant equipment and the conditions resulting in alarmed control room annunciators. Equipment deficiencies we re adec;uately addressed through use of the corrective action program or work order request l
process. (Section 01.1)
l Good preparation and personnel perfor< nance were observed during individual control rod scram time tests on May 25. The pre-job briefing placed appropriate emphasis on the need for good communications, verification of critical steps, and lessons leamed from operating experience.1 Good communication was observed during the second party verification for jumper l installation and individual rod scram switch selection. (Section 04.1)
Maintenance Routine maintenance activities this period involving the high pressure coolant injection (HPCI)
and service water system were adequately completed. A gasket for the HPCI exhaust line rupture disk was not Ivoperly installed, but was identified during the post maintenance test. This maintenance performance issue was entered in W's corrective action process. Equipment unavailability time was tracked in accordance with W's program for evaluating the effectiveness of maintenance. (Section M1.1)
Several examples of poor work practices and informal work controls were noted during a week ;
lon0 observation of instrument and Controls (l&C) maintenance. W relies strongly on the skill- j of-the-craft, verses detailed work plans or procedures. The level of knowledge, training, and experience of the l&C staff were good. The weaknesses noted during this inspection did not appear to reduce the overall effectiveness of the observed maintenance activities. (Section M1.3)
l Active management of the l&C corrective action and maintenance backlog was evident, in that !
l the number of safety-related and environmentally qualifiewf items in the backlog was low. The inspector concluded that, although the l&C backlog had increased over the last 12 months, backlog items had been appropriately prioritized. (Section M8.1)
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Executive Summary (cont'd)
Enoineerina The NRC identified that the operating procedure for the attemate cooling system (ACS)
contained insufficient guidance to ensure that all ACS design functions could be accomplishe The failure to provide an adequate procedure for operation of this system is a violation of Technical Specification 6.5, " Plant Operating Procedures." The safety impact of this problem was minimal since the spent fuel pool had been analyzed up to 200*F, and sufficient time would have been available for the emergency response organization to provide guidance during an
[ actual event requiring ACS operation. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. The issue was entered in VY's corrective action program as ER 99-0658. (Section E2.1)
VY failed to provide adequate quality assurance controls for purchased engineering design services associated with the scram discharge volume drain valves installed during the 1998 refueling outage. As a result, the inadequate vendor supplied design was not identified and the valves failed while in service. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent w'th Appendix C of the NRC Enforcement Policy. This violation was j ent d in VY's corregn action program as ER 98-2201. (Section E8.1)
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Plant Suooort
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The licensee maintained their Radiological Environmental Monitoring Program (REMP) in an effective manner with respect to sampling, analyzing, and reporting per their Offsite Dose Calculation Manual (ODCM) and in conducting safety reviews to properly bound unmonitored release pathways through 10 CFR 50.59 analysis. (Section R1.1)
The licensee maintained their REMP related eauipment in an effective manner with respect to l calibration of air samplers and the primary and secondary meteorological towers. (Section
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R2.1)
The licensee established, implemented, and maintained an effective quality assurance program for the REMP through QA audits of the contractor laboratory, intra-laboratory comparisons by j the contractor laboratory, and performance-based self-assessments. (Section R7)
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TABLE OF CONTENTS EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . il-TABLE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv
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Summary of Plant Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01 Conduct of 0perations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 01.1 Observation of Routine Plant Operations . . . . . . . . . . . . . . . . . . . . . . . 1 04 Operator Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 04.1 Individual Control Rod Scram Time Testing . . . . . . . . . . . . . . . . . . . . . 1 I I . M aintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 M1 - Conduct of Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 M1.1 Maintenance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 M1.2 Surveillance Observations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 M1.3 Observation of instrument and Control Maintenance Activities . . . . . . 4 M8 Miscellaneous Maintenance lasues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 M8.1 I&C Correciive Action anu Maintenance Backlog Review . . . . . . . . . . 5 4
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111. Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . 8 E2.1 Attemate Cooling System Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 E8 Miscellaneous Engineering lasues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
. E (Closed) eel 98-14-04: Scram Discharge Volume Drain Valve Failures
........................................................ 8 E8.2 Administrative Closure of Open items Related to Engineering. . . . . . . . g E8.3 Review of LERs Related to Engineering . . . . . . . . . . . . . . . . . . . . . . . 10 IV. Plant Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 R1 Radiological Protection and Chemistry (RP&C) Controls . . . . . . . . . . . . . . . . 10 R1.1 Radiological and Emuent Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 R2 Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 R2.1 Calibration of Emuent/ Process Radiation Monitoring Systems (RMS) . 11 R7 Quality Assurance (QA) in RP&C Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 R8 Miscellaneous RP&C lasues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 i R8.1 Review of Open items Related to RP&C . . . . . . . . . . . . . . . . . . . . . . . 12 I iv
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Table of Contents (cont'd)
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V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . 12 X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 X2 Year 2000 (Y2K) Readiness of Computer Systems . . . . . . . . . . . . . . . . . . . . 13
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X3 NRC Management Meeting with Vermont State Nuclear Advisory Panel . . . 13 l
t ATTACHMENTS
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Attachment 1 - List of Acronyms Used
Attachment 2 - Items Opened, Closed, or Discussed i
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Report Details I'
Summarv of Plant Status The Vennont Yankee (VY) plant was operated at 100% power throughout most of this report period. On May 10 and May 17, operators reduced power to 98% for several hours while repairs were made to computer inputs for the calculated core thermal power indication. On May 26 and June 8, reactor power reductions to 85% and 75% were made in support of control rod pattern adjustments. Minor power reductions were also made to support routine turbine valve testing and control rod surveillances.
l l. Operations
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01~ Conduct of Operations 01.1 Observation of Routine Plant Ooerations (71707)
The inspectors routinely toured the control room to assess the conduct of activities, verify safety system alignments, and verify compliance with Technical Specification (TS)
requirements. Equipment deficiencies identified in control room logs were reviewed, and discussed with shift supervision, to evaluate both the equipment condition and the licensee's initial response to the issue.
! Control room operators were conversant regarding the status of plant equipment and the conditions resulting in alarmed control room annunciators. Equipment deficiencies were adequately addressed through use of the corrective action program or work order request process.
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04.1- Individual Control Rod Scram Time Testina - I i Inspection Scope (71707) ,
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On May 25,1998, the inspector observed a briefing by Operations and Reactor Engineering in preparation for single control rod scram time testing. The inspector
. observed operator actions associated with single control rod scrams to evaluate the use of applicable procedures and the conduct of the activity.
, Observations and Findinas l
l The briefing of day shift personnel on the moming of May 25 provided a good overview of expectations for control of the activity and also reviewed related operational experience. A clear emphasis was placed on the necessity for careful and deliberate actions; several senior personnel reiterated that there were no schedule or other time
' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspecten report outline. Individual reports are not expected to address all outline topics.
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constraints. Second party verificatiori of jumper locations and individual control rod scram switches was used, with clear communication and acknowledgment prior to taking action. No problems were observed during this activit Conclusions Good preparation and personnel performance were observed during individual control rod scram time tests on May 25. The pre-job briefing placed appropriate emphasis on the need for good communications, verification of critical steps, and lessons teamed from operating experience. Good communication was observed during the second party verification for jumper installation and individual rod scram switch selectio l i
ll. Maintenance '
M1 Conduct of Maintenance i
M1.1 Maintenance Observations Inspection Scope (62707)
The inspector observed portions of planned maintenance activities to verify that the applicable procedures and Technical Specification requirements were satisfied, the correct parts were used, and that the post maintenance testing was adequate. The licensee's actions for monitoring the effectiveness of maintenance were also reviewed )
against the requirements of the " maintenance rule," 10 CFR 50.S Observations and Findinas The inspector observed all or portions of the following maintenance activities:
WO 99-04429-00. Replacement of Service Water (SW) oressure switch PS-104538 The inspector observed technicians replacing the failed pressure switch which provides an automatic start signal to the "B" SW pump on low SW header pressure. An identical replacement component was calibrated in the shop and functionally tested after installation. The switch's failure to reset during a surveillance test was not categorized as a maintenance rule functional failure, since the ability of the pump to start on low SW header pressure was not impacted. VY appropriately tracked the unavailability time for i the "B" SW pump during the actual replacement work when the SW pump auto start feature was disabled. The inspector determined this component failure and the replacement activity were appropriately addressed for the purposes of maintenance rule monitoring. No significant personnel performance issues were identified during the field observation.
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WO 99-01956-00. Hiah Pressure Coolant Iniection (HPCI) System. auxiliary oil oumo (P-85-1 A) motor inspection The inspector observed maintenance personnel performing a minor inspection of the auxiliary oil pump's motor using OP 5235. Through discussions and observation of the job, the inspector found the workers to be knowledgeable of the task. Appropriate blocking had been applied and the auxiliary oil pump functioned acceptably during the post maintenance test. The workers noted that a generic check included in OP 5235 was not applicable to this motor and identified this to their supervision. The inspector confirmed that maintenance supervision had captured this issue for a procedure
. enhancement. No problems were identifie WO 98-13023-00. HPCI turbine exhaust inboard rupture disc replacement Prior to commencing work, VY identified that the replacement rupture disc assembly was slightly wider than the installed assembly. This inconsistency was appropriately resolved by VY engineering prior to iastallation of the replacement unit. The inspector observed I no deficiencies during the maintenance; however, a minor problem occurred during reassembly, in that the inboard gasket was inadvertently folded while positioning the rupture disc. This problem was identified during post-maintenance testing, as discussed in M1.2 below. Event Report (ER) 99-0660 was generated to evaluate this maintenance problem. The inspector concluded that the gasket problem was not a significant concem, but represented an opportunity for improvement in maintenance practice Conclusions Routine maintenance activities this period involving the high pressure coolant injection (HPCI) and service water system w6re adequately completed. A gasket for the HPCI exhaust line rupture disk was not properly installed, but was identified during the post maintenance test. This maintenance performance issue was entered in Ws corrective ,
action process. Equipment unavailablity time was tracked in accordance with Ws ]
program for evaluating the effectiveness of maintenanc M1.2 Surveillance Observatiq03 (61726)
The inspector observed portions of a surveillance test to verify proper calibration of test instrumentation, use of approved procedures, performance of work by qualifed personnel, conformance to Limiting Conditions for Operations (LCOs), and correct post-test system restoratio i
. OP 4120, HPCI system surveillance, observed June 3 i
This surveillance was performed as the post maintenance test following a two day HPCI ;
system maintenance period. The inspector attended the pre-job brief and noted that it was thorough and that attendees actively participated.
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Post maintenance testing of the HPCI system identified a problem that occurred during maintenance on its turbine exhaust line. A small steam lesk at the turbine exhaust line rupture disk flange was readily identified by plant personnel. An open line of communication with operators in the plant allowed the control room operators to quickly secure from the test. Aside from the required rework, there were no consequences resulting from this test tailur M1.3 Observation of instrument and Control Maintenance Activities jnapection Scoce (62704, 62707, 37551)
The inspector observed a sample of instrument and control (l&C) maintenance activities l during the week of June 14 in order to evaluate the control of work, work practices, procedure quality, organizationalinterfaces, and quality assurance record. The l observed activities were compared with station procedures, industry standards, and l regulatory requirements.
! Observations and Findinos The inspector observed generally good l&C work practices, with a few notable
- exceptions. l&C technicians typically performed good test equipment setup and good i instrument line air removal. Setpoint checks were consistently well performe 'However, the inspector noted a few work practices that had the potential to cause problems during l&C activities. During several surveillances a degraded hand pump was used, which made accurate as-found setpoint checks difficult to obtain. The inspector
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also noted several instances when worker hardhats and test equipment were hung on instrument valve handles. Techniques for protecting unsupported instrument tubing (e.g., use of double wrenches when tightening fittings or use of counter torque when operating instrument valves) were not used.
- Communications were typically informal and did not appear consistent with the expectations expressed by VY's management. Three-part communication and the i phonetic alphabet were not consistently used. In one instance, the inspector identified that a control room annunciator received during the equipment restoration was unexpected and this had not been recognized by either operations or I&C.
l Post maintenance test (PMT) details were not always specified in work orders. In
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several instances, the details and scope of a PMT were determined by the technician I
following work completion. Operations appeared to rely on l&C to determine and perform the proper PMT. Nominal equipment operating parameters were not routinely checked following equipment maintenance and compared to pre-work readings. For i
example, following a fan replacement in a reactor building air monitor, the PMT verifmKI the fan operated property, but did not verify the sample flow was normal. The inspector noted that equipment alteration forms (e.g., lifted lead logs) were typically not required to be used, placing a greater reliance on the PMT to verify proper operation of equipment.
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e Work planner pre-job walkdowns were not always performe J Some work packages did not contain sufficient information to accomplish the task. lnis required the technicians to
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do further research, obtain additional drawings, or make temporary procedure changes.
l Required parts were not always pre-staged for scheduled work; in one instance, a scheduled transmitter calibration was canceled when o-rings could not be obtained.
l Use of controlled procedures and drawings was generally good. Calibration records and data sheets were appropriately completed, reviewed, and approved. The control of j measurement and test equipment (M&TE) was good. However, the inspector observed l that temporary procedure changes were performed by technicians during scheduled work, to resolve procedure problems which had been previously identified. The pending change list" for drawings and vendor manuals was not always checked by technicians when obtaining their own information. Drawings used for field work were not always ,
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l&C housekeeping practices were adequate. Broken equipment tags were appropriately I identified for replacement during routine activities. l&C radiological protection practices were good. Foreign material exclusion control, observed during a minor maintenance l
activity, was good. The I&C group had excellent training aids and equipment mock-ups for infrequently performed task Material condition of the plant was good; the emergency core cooling pump rooms were
- clean, the hydraulic control units (HCUs) and the torus room were exceptionally clean
- and had very few contaminated areas. The condition of the cor: trol room recorders was
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excellent.
l The inspector concluded that the generally good performance of the l&C group is largely due to the size, knowledge, and experience of the group. These factors appeared to compensate for informal work controls and work practice weaknesse Conclusions 1 Several examples of poor work practices and informal work controls were noted during a week long observation of instrument and Controls (l&C) maintenance. VY relies strongly on the skill-of-the-craft, verses detailed work plans or procedures. The level of knowledge, training, and experience of the l&C staff were good. The weaknesses noted during this inspection did not appear to reduce the overall effectiveness of the observed i
- maintenance activitie i l MS Miscellaneous Maintenance issues l
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M8.1 l&C Corrective Action and Maintenance Backfoo Review (40500)
The I&C backlog was reviewed, including corrective action items, corrective maintenance open items, and overdue preventative maintenance items. The corrective maintenance backlog had increased by about 50% over the last 12 months. l&C supervision was knowledgeable and able to provide details for selected items that the inspector inquired
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about. The backlog was readily accessible on plant computer systems, and VY management tracked and trended the backlog. As of June 1999, approximately 25% of the corrective action items and corrective maintenance open items were older than one year. Items in the backlog were appropriately prioritized based on maintenance rule ,
category (i.e., exceeded allowed functional failures), safety significance, and l environmental qualification categorie Active management of the l&C corrective action and maintenance backlog was evident, in that the number of safety-related and environmentally qualified items in the backlog was low. The inspector concluded that, although the l&C backlog had increased over the last 12 months, backlog items had been appropriately prioritize . Engineering E2 Engineering Support of Facilities and Equipment E Altemate Coolina System Review Inspection Scooe (37551,71707)
Operating procedures for the Altamate Cooling System (ACS) were reviewed to verify their adequacy for accomplishing the safety design basis described in the Final Safety Analysis Report (FSAR). In addition to the procedure review, the inspector performed a
.walkdown of accessible equipment and reviewed the applicable drawings. ACS was selected for review, in part, based its Probabilistic Risk Assessment classification of
" medium risk importance." Observations and Findinos The ACS is designed to provide the necessary heat removal for a normal plant shutdown in the unlikely event that all service water pumps become unavailable. Its safety design basis requires the capability to remove heat from the reactor coolant system (RCS) so that the reactor can be safely shut down, and from the spent fuel elements while 1
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maintaining safe shutdown conditions (reference FSAR Section 10.8.2). VY was required to develop this system during the initial plant licensin The system is a composite of equipment normally used by several plant systems that can be manually aligned to provide the ACS function. For ACS operation, the RHRSW j pumps are aligned to a safety class cooling tower cell and its deep basin, which then i become the plant's attemate heat sink. This alignment allows operators to use the RHR j system and its heat exchangers for torus cooling, shutdown cooling (SDC), and ;
augmented fuel pool cooling (AFPC). l l
The inspector reviewed OP 2181, " Service Water /Altemate Cooling Operating Procedure," Revision 48, and OP-2124, " Residual Heat Removal System," Revision 4 ;
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The RHR system's SDC and AFPC functions cannot be used simultaneously since both functions require the "A" loop of RHR. OP 2181 directs operators to consider using
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l AFPC after seven hours, based on fuel pool temperature considerations. However, the inspector noted that the RHR alignment change requires several time-consuming actions to be taken in the plant (e.g., reversing spectacle flanges). The inspector considered the OP 2181 guidance inadequate because it would not reasonably allow operators to maintain the plant in the cold shutdown condition and provide cooling to the spent fuel pool. This observation was discussed with W Operations and Engineering representative On June 3, W declared the ACS inoperable because the available ACS analysis was not sufficient to show the procedural guidance was adequate. On June 4, W made an NRC notification (EN# 35793) which stated that the procedures may not provide the specific information necessary to ensure the ACS would meet it design basis. At that time, W believed the ACS design bases required the capability to achieve and maintain cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, while keeping the spent fuel pool below 150* After further review, W determined their licensing basis for ACS requires the capability to achieve hot shutdown (rather than cold shutdown), and the capability to keep the o spent fuel pool temperature below 200*F. On June 9, the Plant Operations Review l Committee approved a safety evaluation to support changes to OP 2181 that will help j ensure the sequence of operator actions necessary to meet the all design bases.
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Revision 49 to OP 2181 added specific guidance and decision points for initiation of torus cooling, SDC, and AFPC. Based on the revised procedure and associated analysis, the plant can be placed in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, W does not consider this to be a requirement of their licensing basi The inspector considered Ws initial actions to address this issue appropriate. No technical issues were identified with Ws new approach which permits the spent fuel pool temperature to exceed its normal operating temperature limit. Representatives from the Office of Nuclear Reactor Regulation confirmed that this limit was not intended for emergency conditions and the inspector noted that the 200*F capability of the fuel pool was previousiv reviewed in an NRC Safety Evaluation Report dated October 14,198 Notwithstanding Ws initial response, further evaluation will be necessary since the procedure changes and safety evaluation are based on the current spent fuel pool loading. Pending Ws final ACS analysis, this issue will be tracked as an inspector !
follow-up item.- (IFl 99-05-01: ACS Design Basis and implementing Procedure) {
l After re-evaluation of the ACS design basis, W concluded that OP 2181, Revision 48, ;
had provided sufficient guidance to meet the ACS design basis with the support of the l emergency response organization. Although the procedure provided sufficient !
instructions on how to operate the system, the inspector concluded that the procedure l was inadequate because it did not address the expected sequencing of events i necessary to accomplish all of the ACS design function TS 6.5, Plant Operating Procedures, requires detailed written procedures covering the operation of systerns at the facility. OP 2181, " Service Water / Altemate Cooling Operating Procedure," provides ine instructions for operation of the ACS. Contrary to the above, prior to June 9,1999, W failed to provide an adequate procedure because I
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the procedure steps were insufficient to ensure that all ACS design functions could be accomplished. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. The issue was entered in j- W's corrective action program as ER 99-0658. (NCV 99-05-02: Inadequate Operating Procedure for the Alternate Cooling System) Conclusions The NRC identified that the operating procedure for the attemate cooling system (ACS)
contained insufficient guidance to ensure that all ACS design functions could be accomplished. The failure to provide m edequate procedure for operation of this system is a violation of Technical Specifich o " Plant Operating Procedures." The safety impact of this problem was minimal sinc J.a spent fuel pool had been analyzed up to 200*F, and sufficient time would have been available for the emerget._y response l organization to provide guidance during an actual event requiring ACS operation. This l Severity Level IV violation is being treated as a Non-Cited Violation, consistent with l Appendix C of the NRC Enforcement Policy. The issue was entered in VY's corrective action program as ER 99-065 E8 Miscellaneous Engineering issues
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l E (Closed) eel 98-14-04- Scram Discharoe Volume Drain Valve Failures Inspection Scope (37551,92700)
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l The inservice test failures of two scram discharge volume drain valves led to the l identification of problems with the new valve / actuator design installed during the 1998 refueling outage. This issue was initially reviewed in NRC Inspection Report 50-271/98-14 and was identified as an open item to allow the licensee a reasonable period of time to 8nvestigate the issue. W reported these failures in LER 50-271/98-025-00, and subsequently updated the report with supplemental LER 50-271/98-025-0 Observations and Findinas The inspector reviewed the LERs and concluded that W provided adequate information regarding the sequence of events and their root cause evaluation efforts, as is required by 10 CFR 50.73. The supplemental report also served as an NRC notification in accordance with 10 CFR part 21. However, the inspector considered this supplemental LER weak because it did not provide all of the details regarding the failed components j (or the engineering service vendor).
W attributed the failures to 1) an inadequate actuator sizing calculation by a vendor and 2) inadequate manufacturing quality assurance controls for the valves' configuistio !
. The inspector noted that the vendor in this case was working under its own quality assurance program and engineering procedures. The LER also acknowledges that a l contributing cause was the failure of W to identify conflicting information in the design packag ,
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The inspector concluded that W's measures used to evaluate the vendor supplied design were flawed because the actuator sizing calculations did not require W review or verification. Also, W failed to identify the problem during development of the safety evaluation when valve data provided verbally by the vendor (and used in the safety evaluation) was less conservative than the information provided by the vendor in the procurement documentatio CFR 50 Appendix B, Criterion Vil, " Control of Purchased Material, Equipment, and Services," requires that measures be established to assure that purchased equipment and services conform to the procurement documents. Criterion Vil also requires that documentary evidence that equipment conforms to the procurement requirements be available at the nuclear power plant prior to installation or use of such equipmen Contrary to the above, on April 20,1998, W completed the installation of new scram discharge volume drain valves that did not conform to their purchase specification in that they would not close under the design conditions described. This Severity Level IV i violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was entered in W's corrective action program as ER 98-2201. (NCV 99-05-03: Inadequate Control of Purchased Engineering j
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Services) Conclusions i W failed to provide adequate quality assurance controls for purchased engineering design services associated with the scram discharge volume drain valves installed during the 1998 refueling outage. As a result, the inadequate vendor supplied design was not identified and the valves failed while in service. This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was entered in W's corrective action program as ER 98-220 E8.2 Administrative Closure of Ooen items Related to Enaineerina (92903)
l The Severity Level IV violations listed below were issued in Notices of Violation prior to the March 11,1999, implementation of the NRC's new policy for treatment of Severity Level IV violations (Appendix C of the Enforcement Policy). Because these violation would have been treated as Non-Cited Violation in accordance with Appendix C, they are being closed out in this report based on the licensee entering the problems in their corrective action program for resolutio (Closed) VIO 98-80-04: Failure to Control Changes to Design Basis Document !
This violation is in the licensee's corrective action program as ER 98-130 (Closed) VIO 98-80-07: Failure to Obtain NRC Approval Prior to Revising QA Commitments. This violation is in the licensee's corrective action program as ER 98-1235.
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(Closed) VIO 97-531-050104: Incorrect Design inputs for RHR Pump Calculatio This violation is in the licensee's corrective action program as ER 97-66 (Closed) VIO 97-531-070104: incorrect References and inputs Used In Design Calculations. This violation is in the licensee's corrective action program as ER 97-66 E8.3 Review of LERs Related to Enaineerina (90712,92700)
An in-office review of Licensee Event Repods (LERs) was performed to assess whether further NRC actions were required. The adequacy of the overall event description, immediate actions taken, cause determination, and corrective actions were considered during this review. Subsequent in-plant inspections were used to obtain further information and evaluate the licensee's performanc (Closed) LER 98-025-00. 01: Scram Discharge Volume Valve Closing Time Excessive Due to Undersized Actuators The LER and its supplement were reviewed in NRC Inspection Report 50-271/98-14 and in Section E8.1 of this inspection report. Based on the in-plant inspections, these LERs are close IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls I R Radioloaical and Effluent Controls Inspection Scope (84750)
The following areas of the licensee's radiological environmental monitoring program (REMP) were inspected against the technical specification (TS) and offsite dose calculation manual (ODCM) requirements:
. verified selected locations of air, water, thermoluminescent dosimeter (TLD), and milk sampling stations, as specified in the ODCM;
. reviewed ODCM changes; e reviewed the 1997 and 1998 Environmental Reports; and
. reviewed a 10 CFR 50.59 evaluation pertaining to Generic Letter 80-1 Observations and Findinas j No sampling technique discrepancies were noted. Those sampling stations reviewed were located as defined by the ODCM. No special reports were issued by the licensee in 1998. The Annual Radiological Environmental Operating Reports for 1997 and 1998 j
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provided measurement results of the REMP samples around the VY site and met the TS/ODCM reporting requirement s
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The licensee's compliance with Appendix 1 to 10 CFR 50,10 CFR 20.1301 and 40 CFR 190 (dose limits to the public) was verified through the licensee's direct radiation measurement data (environmental TLD readings). Measured doses to the public were well below these regulatory requirement i No discrepa,1cies were noted in assumptions or conclusions made by the licensee in their 10 CFR 50.59 evaluation noted above.
' Conclusions l
The licensee maintained their REMP in an effective manner with respect to sampling, analyzing, and reporting per their ODCM and in conducting safety reviews to properly bound unmonitored release pathways through 10 CFR 50.59 evaluation R2 Status of RP&C Facilities and Equipment R2.1 Calibration of Effluent / Process Radiation Monitorina Systems (RMS) Insoection Scope (84750)
Recent calibration records of air samplers were reviewed. The most recent meteorological tower calibration results and operability were reviewed against the UFSAR and Regulatory Guide 1.23 commitment Observations and Findinos No discrepancies were noted pertaining to air sampler calibrations. Primary and secondary meteorological tower calibration results were found to be within the licensee's acceptance criteria. No calibration procedure inadequacies were note Conclusions The licensee maintained their REMP related equipment in an effective manner with respect to calibration of air samplers and the primary and secondary meteorological tower R7 Quality Assurance (QA)in RP&C Activities Inspection Scooe (84750)
The inspection consisted of (1) a review of the 1998 QA audit of the Duke Engineering and Service's Environmental Laboratory (DESEL); (2) a review of the July-December 1998 Semi-Annual QA Status Report; and (3) self-assessment j
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12 Observations and Findinos The 1998 DESEL audit covered most aspects of the radioactive effluents control program. Audit team members had a good mix of relevant experience. Responses to audit findings were reasonable. Licensee self-assessments helped provide a more
' performance-based review of REMP activities carried out by W staff. The self-assessments covered a wide range of REMP activities. No significant issues pertinent to the W license were identifie Results from the July-December 1998 Semi-Annual QA Status Report indicated that generally very good agreement was achieved by the licensee's blind sampling progra Discrepancies were investigated and resolve Conclusions
' The licensee established, implemented, and maintained an effective quality assurance program for the REMP through QA audits of the contractor laboratory, intralaboratory comparisons by the contractor laboratory, and performance-based self-assessment R8- Miscellaneous RP&C lasues R Review of Open items Related to RP&C (92904)
The following open item was closed based on the inspector's review of additional information from W and the licensee's corrective action plans. No violation of NRC requirements was identifie (Closed) IFl 98-13-04: Plant Air Balance Verification The licensee was nearing completion of a modification installing a housing around the turbine building ventilation system supply fans. The licensee has also conducted a number of air capacity tests and smoke tests throughout the station and has planned more testing in the upcoming refueling outage. As noted in Section R1.1, the licensee was also in the process of establishing in-line tritium sampling of main stack effluent These efforts will receive further review during the course of routine NRC inspections of the licensee's radioactive efnuent controls program and REM V. Management Meetings X1 Exit Meeting Summary The resident inspectors met with licensee representatives periodically throughout the inspection and following the conclusion of the inspection on July 20,1999. Inspectors from the NRC's Region I office met with licensee management at the conclusion of their respective on-site inspections. At these meetings, the purpose and scope of the inspections were reviewed, and the preliminary findings were presented. The licensee acknowledged the preliminary inspection findings. _
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13 l The inspector asked the licensee whether any material examined during toe inspection should be considered proprietary. No proprietary information was identifie X2 Year 2000 (Y2K) Readiness of Computer Systems The staff conducted an abbreviated review of Y2K activities and documentation using Temporary Instruction (TI) 2515/141, " Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants." The review addressed aspects of Y2K management planning, documentation, implementation planning, initial assessment, detailed assessment, remediation activities, Y2K testing and validation, notification activities, and contingency planning. The reviewers used NEl/NUSMG 97-07, " Nuclear Utility Year 2000 Readiness," and NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning," as the primary references for this revie The results of this review will be combined with the L :!s of other plant reviews in a summary report to be issued by July 31,199 X3 NRC Management Meeting with Vermont State . + 21 ear Advisory Panel On June 7,1999, Mr. William Kane, Associate Director of Inspections and Programs, from the Office of Nuclear Reactor Regulation, met with members of the Vermont State Nuclear Advisory Panel at the Green Street School, in Brattleboro, VT, to discuss the NRC's new reactor oversight proces i i
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Attachment 1 LIST OF ACRONYMS USED ACS Altemate Cooling System BMO Basis for Maintaining Operation CFR Code of Federal Regulation-CR control room CS core spray -
DESEL Duke Engineering and Services Environmental Laboratory EDG emergency diesel generator ER Event Report FME ' foreign material exclusion GE General Electric GL Generic Letter HEPA High Emciency Particulate Air HPCI high pressure coolant injection IFl _
inspector follow-up item IN " Information Notice LCO Limiting Condition for Operation LER Licensee Event Report NNS non-nuclear safety NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation ODCM. Offsite Dose Calculation Manual PORC Plant Operations Review Committee QA Quality Assurance QC Quality Control REMP Radiological Environmental Monitoring Program RETS Radiological Emuent Technical Speedications RHR residual heat removal RMS Radiation Monitoring System RP- radiation protection RP&C Radiological Protection and Chemistry SER Safety Evaluation Report i TS Technical Specifications
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UFSAR Updated Final Safety Analysis Report l URI unresolved item '
W Vermont Yankee ;
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Attachment 2 ITEMS OPENED, CLOSED, OR DISCUSSED OPENED
. IFl 99-05-01: ACS Design Basis and Implementing Procedure (page 7)
CLOSED VIO 98-80-0 Failure to Control Changes to Design Basis Documents (page 9)
VIO 97-531-050104: Incorrect Design inputs for RHR Pump Calculation (page 10)
VIO 97-531-070104: Incorrect References and inputs Used in Design Calculations (page 10)
LER 98-025-00, 01: Scram Discharge Volume Valve Closing Time Excessive Due to Undersized Actuators (page 10)
IFl 98-13-04: Plant Air Balance Verification (pkge 12)
NON-CITED VIOLATIONS NCV 99-05-02: Inadequate Operating Procedure for the Altemate Cco'ing System (page 8)
NCV 99-05-03: Inadequate Control of Purchased Engineering Services (page 9)
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