ML023470147

G20020602 - Raymond Shadis Ltr. 2.206 - Vermont Yankee Personnel Unfamiliar with Plant Design

ML023470147
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	10/15/2002
From:	Shadis R New England Coalition on Nuclear Pollution
To:	Collins S Office of Nuclear Reactor Regulation
References
2.206, G20020602
Download: ML023470147 (6)

Text

EDO Principal Correspondence Control DUE: 11/26/02 Raymond Shadis New England Coalition on Nuclear Pollution TO:

Collins, NRR DOC DT: 10/15/02 FINAL REPLY :

FOR SIGNATURE OF :

DESC:

GRN CRC NO:

Collins, NRR ROUTING:

2.206 - Vermont Yankee Personnel Unfamiliar with Plant Design DATE: 10/22/02 ASSIGNED TO:

NRR CONTACT:

Collins Travers Paperiello Kane Norry Craig Burns Miller, RI

Cyr, OGC Skay, NRR

Goldberg, OGC SPECIAL INSTRUCTIONS OR REMARKS:

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I POST OFFICE B*OX 545. BRATTLEPRORO. V\\l-I-MONT 05302 October 15, 2002 ByFAX and U.S.Mail U.S. Nuclear Regulatory Commission Samuel J. Collins, Director Office of Nuclear Reactor Rcgulation Mail Stop 05E-7 11555 Rockville Pike Rockvillc. Maryland 20852 Re: Vermont Yankee Personnel Unfamiliar with Plant Design Dear Mr. Collins.

On October 6, 2002 Entcrgy Nuclear Vermont Yankee (ENVY) declared an accident mitigation system. the Reactor Core Isolation Cooling System (RCIC) inoperable. The Event Notification (39250) stated, "Following reactor core isolation cooling svstem injcction check valve surveillance, the check valve apparently did not fully close..Tlb.iLrequlted in high pump.suction prcssure trip which would have prevented frrther system operation." (emphasis added).

On October 11. 2002. ENVY retracted the notification stating, "The RCIC -pump doe, not have this aforementioned trip device." (emphasis added)

Therc is simply no excuse for a licensee assuming that a nuclear power plant has in place safety or accident mitigation component feature.s that it does not have.

Elhctive accident mitigation requires that operators, supervisors and other responsible plant personnel be fam.iiar in detail with the engineered safety and accident mitigation features of their plant. This was a lesson driven home in 1hc 1979 Three Mile Island Nuclear Power Plant Accident when operators trying to recover safe reactor cooling parameters inadvertently worked to frustrate enginecred safety systems.

Therefore, on behalfofrthe New England Coalition on Nuclcar Pollution, I now request under the provision, o 1"0 CFR 2.206 that the NRC undertake enforcement action at Vermont Yankee Nuclear Power Plant requiring a complete review of training and qualification or nuclear operations and maintenance personnel. I further request under provisions of 10 CFR 2.206 that the NRC undertake an evaluation of the Vermont Yankee Final Safety Analysis Report to determine if the document accurately reflects the configuration of the facility in detail sufficient for operations personnel to be able to lbxmilitrize them.elves with pump/protection features such as the phantom trip device referred to above.

In the arena of regulatory policy, I ask NRC to undertake an evaluation of the safiety implications inherent in relying on economics of synergies (shared personnel, engineering analysis, etc) between ever larger numbers of nuclear pover plants as arc being acquired by operating EDO -- G20020 6 02

-- 7-082-8013 Ratimond Shadis

Rajmond Shadis 207-882-8013 p.2 2

NECNP/NRC 10/15/2002 comparnes, such as Entergy. Following the 1996 Independent Safety Assessment ofMaine Yankee, company officers, including Fntergy management, explained to the NRC Commissioners that many of Maine Yankee's problems (poor maintenance, inadequate engineering design and analysis, poor quality control, etc) sternr'ed from poor communications and responsibilities transfer at the interface of Mainc Yankce and Yankee Atomic, which supplied cnginccring support. If the failurc to capture cmcrging issues and achicve comprehensive knowledge of design and function occurs because ofdiflficulties at the simple interface of two related companies, then how many more gross misapprehensions can be expected when an operating company expects to save money by shifting supervision and upper echelon technical support from plant to plant to plant?

Within its review of Vermont Yankee, 1 request that NRC undertake to determinc how much of' pump trip device faux pas is attributable to the integration of ENVY personnel from other facilities.

Finally, as Mr. David Lochbaum, nuclear safety engincer with the Union of Concerned Scientists, points out in the attached communication, there is insufficient information in the Event Notice and in the Retraction to determine the significance of the referenced RCIC valve leak. I request that NRC publicly review its Event Notification standards with the licensee to ensure that at least preliminary risk determination can proceed from Event Notification.

Thank you for your attention and consideration, Raymond Shadis StaffAdvisor Attachmcntz:

1. Event Notification

2.

Retraction of Event Notification

3. E-mail R.Shadis to David Lochbaum. UCS

4.

Mr. I ochbaurn%' Commcntr on Event Notificjtion 39250 and Retraction Cc:

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207-882-8013 P. 3 Ra3mond Shadis 3

NECNIP/NRC 10/15/2002 ATTACHMENTS

1. Event Notification*

IPower Reactor IEvent Number: 39250 FACILITY: VERMONT YANKEE REGION: 1 NOTIFICATION DATE: 10/06/20021 UNIT: I

[I STATE: VT INOTIFICATION TIME: 18:00[EDT]

RXTYPE: [1) GE-4 EVENT DATE: 10/06/20021 EVENT TIME: 11:30F.DT]I NRC NOTIFIED BY: MITCH McCLUSK.IE LAST UPDATE DNAIT: 10/1 1/2002 HQ OPS OFFICER: FANGlE JONES EMERGENCY CLASS:

NON EMERGENCY IPETE ESELGROTH RI 10 CFR SECTION:

AIND 50.72(b)(3)(v)(D)

ACCIDENT MITIGATION I

UNIT ISCPAI.M CODFIRX CRITITNIT PWRI INIT RX MODE ICURR PWRI CURR RX MODE 1 N

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Relueling J0 Refueling EVENT TEXT RCIC SYSTEM DECLARED rNOPERABT.E Following reactor core isolation cooling system injection check valve surveillance, the check valve apparently did not fully close. This resulted in high pump suction presbure trip which would have prevented further system operation. The licensee conservatively declared the RCIC system inoperable and entered Tcch Spec LCO 3.5.G.2, a 14-day action statement. Shortly alterwards the plant pressure was dropped to less than 150 pig as part ofnorn'ml plant,shutdown "to refueling, this takes the plant out of the Tech Spec action statement as it no longer applies.

The licensee ib conducting an in,,estigation of the problem with RCIC injection check valve.

Repair-, will be completed prior to plant restart.

The licensee notified the NRC Resident Inspector and the State of Vermont.

2. Retraction of Event Notification*

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Ratmond Shadis 207-882-8013 p.4 4

NECNP/NRC 10/15/2002 RETRACTION FROM Andy Wisniewski on 10/11/02 at 1428 EDT to GcrryWaig "BASIS FOR RETRACTION:

NRC Event Notilication 39250 was made with the concern that this condition may have rendered the Reactor Coie Isolation Cooling (RCIC) system inoperable due to a 'high pump suction pressure trip'. The RCIC pump does not have this aforementioned trip device. Therefore, the predicament that Operations has been confronted with for declaring the RCIC system inoperable may be more aptly stated as; 'Could the leakage that occurred past the discharge check valve, after the RCIC system run, have over-pressurized the RCIC system suction piping and caused the system to be unavailable for service if called upon for a 'Loss of AJ AC Event'. A team of engineers was assembled to detcrmine the extent of this condition that resulted in the completion of an Operability Determination on 10/08/02 by the RCIC System Engineer, concluding that the RCIC system remained operable based upon the following two fact,:

1. The RCIC suction line relief valve lifts at 150 psi.

2. The outer pump discharge valve, combined with a pressure switch, provides I an additional barrier ol'defense. The pressure switch actuates at 74psi and causes the RCTC PUMP SUCT PRESS HI alarm in the control room. The alarm response procedure directs operators to close the isolation valve that is downstream of the discharge check valve.

"Additionally, the leakage has been determined to be 'slight' and well within the capacity of the relief valve, based upon system performance and observation of the event as it occurred. The RCIC system would have performed it's specified safety function during this condition if required.

"Therefore, ENS Event Number 39250, made on 10/06/02, is being retracted."

The licensee notified the NRC Resident Inspector of this retraction.

The Rl DO (John Whitc) was notified by the NRC Headquarters Operations Officer.

• EVENVT NOTIFICATION 392.50 and RETRACTIN ofEVJLIVT NAOTIFICATION 39250 ( 10/06/02 11/I1/02) (Content Re-Forrnatted rcor Reprint)

3. E-mail R.Shadis to David Lochbaum, UCS

+.............----------------------------------- --------------------------. >>> shadis.rcxr corn 10/15/02 10:32AM >>>

Dave, Would you please give me your take on this Event Report and Retraction?

Thanks. Ray

4. Mr. Lochbaum's Comments on Event Notification 39250 and Retraction Hello Ray:

It's fishy for the following reasons:

1) The leakage past the check valve was subjectively labeled as being "slight." The event report

207-882-8013 P.

5 NECNP/NRC 10115/2002 does not specif' the reactor pressure at which this "slight" leakage was observed. if it was at reduced pressure as the plant was being shut down, even a big ol' hole would have produced "slight" leakage. "Slight" leakage is only relevant if it,vas observed with reactor pressure at or near rated pressure of around 1.020 psig.

NECNP/NRC 10115/2002

2) The retraction indicates that Vermont Yankec does not have a pump suction trip device, which was the basis for the initial call. Who made that initial caU'? Someone on the street or someone who has had an iota or two of training? Did the former owner take the owner's manual with him so the present owner had no knowledge of whether the plant had or didn't have a pump suction trip device? Not rcally comforting to see operability calls being made by people with no clue whatsoc,,cr about how the plant i6 designed.

3) The alleged conccm was leakage overpressuring the RCIC pump suction piping and impairing system function during events such as station blackout. But are the "outer pump discharge valve, combined with a pressure switch" powered from DC sources? If not. they will not work during a station blackout event and thus cannot close. NOTE: This may be a diflicult question for the present owner of Vermont Yankee to answer. After all, it's more complex than knowing whether the plant has a pump suction trip device or not, and they got that one wrong.

Thanks.

Dave Ra~jmond Shadis