Text

Various CRS 10/10/2001 to 09/20/2005
	ML070670306
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	09/20/2005
From:	; Entergy Nuclear Operations
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML070670306 (206)
	v • d • e

Entergy

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I CONDITION REPORT CR-VTY -2003-02321 Originator: McNutt,Brian K Originator Phone: 8022585369 Originator Group: Operations Mgr\ Mgmt Operability Required: Y Reportability Required: N Supervisor Name:

Discovered Date: 10/23/2003 09:40 Initiated Date: 10/23/2003 0O:OO Condition

Description:

No Indicated Cooling Flow Upon Pump Start Upon pump start for scheduled quarterly surveillance there was no indicated cooling water flow. Spec is 5-6 gpm.

Immediate Action

Description:

INITIATED W O R N 0 : Complete : WR #03-59256 NOTIFIED SHIFT SUPERVISOR : Complete : Shift Supervisor notified Suggested Action

Description:

EQUIPMENT:

Tap Name Tap Suffix Name Component Code Process System Code P 1C RHRS TRENDING (For Reference Purposes Only):

Trend TYDe Trend Code MR ISSUE POTENTIAL MR ISSUE - YES MRFF (Y/N) ACTUAL MRFF - NO PERSONNEL INJURY PI-NON-INJURY HOW IDENTIFIED HI-SELF-REVEALING Attachments:

Closure Description ERFIS DATA ON MOTOR TEM

E**- I ADMIN CR-VTY-2003-02321 Initiated Date: 10/23/2003 0:OO Owner Group :Eng SYS System Eng Mgmt Current

Contact:

Current Significance: B - ACE Closed by: Pallang,Alexander P 1/19/2004 6:33

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Summary

Description:

No Indicated Cooling Flow Upon Pump Start Remarks

Description:

The ER 2003232 1 was migrated from the VY Niagara application on 10/30/2003 to generate this CR.

Closure

Description:

Condition Report Closure Review IAW LI-102 Section 5.8.1 Completed

Attachment Header Document Name:

PR-VTY-2003-02321 Document Location kfosure Description Attach

Title:

VTY CTP PLANTMODE TREND-1 10/23/2003 PSS 100.0% RUN One Single-Variable Trend 11:49:58 StartTime: 1: 1. 1 . Archive Sample Rate:

EndTime: I Real-Time Sample Rate:

110.000 100.000 90.000 I 80.000 I t 1012312003 6:30:03 1012312003 11:00:10 Pt. Namel: 0 . RHR SERV WATER MTR C UPPER BRG 93.677 DEQ F 0

EnfC??g)f I OPERABILITY I CR-VTY-2003-02321 OperabilityVersion: 1 Operability Code: NIAGARA CONVERSION Immediate Report Code: NIAGARA CONVERSION Performed By: Von der Esch,Gary R 10/23/2003 1 1 : 12 Approved By: Von der Esch,Gary R 10/23/2003 1 1 : I2 Operability

Description:

Niagara indicators set during Shift Supervisor Review.

Event Reportable Per Ap 0 156 :: No Per AP 0167 Degraded or Non conforming SSC's will remain operable :: No Operability Determination Attached (See Admin Tab for attachment) :: N/A Pre-screening Comments / Operability Justification:

"C" RHRSW Pump is considered inoperable at this time. "C" RHRSW Pump is considered available for ORAM. Cooling can be provided through the cooling bypass line. Flow was verified through the bypass line by FIN Team.

DH Review Performed By: VONDERESCH,GARY on 10/23/2003 Approval Comments:

Entergy--I- A SSIGNMEN TS 1 CR-VTY-2003-02321 Version: I Significance Code: B - ACE Classification Code: B Owner Group: Eng SYS System Eng Mgmt Performed By: Pallang,Alexander P 10/24/200309: 14 Assignment

Description:

Pre-screening Comments / Operability Justification:

"C" RHRSW Pump is considered inoperable at this time. "C" RHRSW Pump is considered available for ORAM. Cooling can be provided through the cooling bypass line. Flow was verified through the bypass line by LlN Team.

DH Review Performed By: VONDERESCH,GARY on 10/23/2003 Screening Comments:

Presented on I0/24/03 by LED (APP)

Niagara indicators set at screening.

How Identified :: Self-Revealing Potential 10CRF50.65 Maintenance Rule Issue :: Yes

Entergy CORRECTIVE ACTION CR-VTY-2003-02321 CA Number: I Assigned By: CRG/CARB/OSRC Pallang,AlexanderP Assigned To: Eng SYS System Eng Mgmt Subassigned To : Eng SYS System Eng Staff Jonasch,Stephen F Originated By: Pallang,AlexanderP 10/24/200309: 14:OC Performed By: Boivin,Joseph J I I / I 9/2003 16:06:4$

Subperformed By: Jonasch,Stephen F I I / I 9/2003 16:02: 14 Approved By:

Closed By: Boivin,Joseph J I I / I 9/2003 16:06:45 Current Due Date: 11/22/2003 Initial Due Date: I 1/22/2003 CA Type: CR DISPOSITION Plant Constraint: NONE CA

Description:

This CA for Disposition was generated during Niagara to PCRS Conversion Screening Comments:

Presented on 10/24/03 by LED (APP)

Investigate Type :: Apparent Cause

Response

CA for Disposition Subresponse :

ACE Evaluation Report provided and is attached to this CR as an attachment. Addtional attachments are provided which are referenced in the Evaluation Report.

Closure Comments:

This CA for Disposition was generated from ER Investigation information from the VY Niagara application on 10/30/2003.

Attachments:

Subresp Description ASCO SOV Instructions SMRC 2003-0 16 Equipment Failure Eva1 Check List ACE Failure Evaluation Report Score Card

Attachment Header Document Name:

Document Location Attach

Title:

~ S C sov O Instructions

SERIES Installation 81Maintenance Instructions

%-WAY INTERNAL PILOTED-OPERATED SOLENOID VALVES 8210 NORMALLY OPEN OPERATION - GENERAL SERVICE 8211

.3/4" NPT Form No.V5826R:

Positioning NOTICE: See separate solenoid installation and maintenance This valve is designed to perform properly when mounted in a instructions for hfomwtion on: W h g , Solenoid Temperahue; position. However, for optimum lifeand performance, the solenc Came of Improper Operation, or Cod Replacement. should be mountedvertically and upright to reduce the possibility foreignmatteraccumulatinginthe solenoidbasesub-assemblyarc DESCRIPTION Mounting Series 8210 valves are 2-way normally open internal For mounting bracket (optional feature) dimensions, refer to Figure pilot-operated solenoid valves designed for general service.

Valves are made of rugged forged brass. Series 8210 valves are provided with a genera1purpose solenoid enclosure.

Series EF8210 and 8211are the same as Series 8210except they are provided with an explosionproof or explosionproofhatertight solenoid enclosure.

OPERATION Normally Open: Valve is open when solenoid is de-energized; I-INCHES4 closed when energized. .343dia. (2 holes)

IMPORTANT: Minimum operating pressuredifferentialrequired is 5 psi. Figure 1. Mounting bracket dimensions Manual Operator (optional feature) Piping Manual operator allows manual operation when Connect piping tovalve accordingto markingsonvaIve body. Apl desired or during an electrical power outage. To pipe compound sparingly to male pipe threads only. If applied engage manual operator (close the valve) insert screwdriver and turn stem clockwise until it stops. @

Valve will now be in the same position as when the solenoid is valve threads, the compound may enter the valve and c a operationaldifficulty.Avoid pipe strain by properly supportinga aligning piping. When tightening the pipe, do not use valve energized. Todisengagemanualoperator (open thevalve),turnstern solenoidas a lever. Locate wrenches applied to valve body or pipi countercloclcwise until it stops. as close as possible to connection point.

A CAUTION: To protectthe solenoidvalve, installa strain A CAUTION: For valve to operate electrlcally, manual or filter suitable for the service involved in the inlet side operator stem must be fully rotated counterclockwise. closeto the valve as possible. Clean periodicallydependii onserviceconditions.See ASCO Serles 8600,8601 and 86 INSTALLATION Check nameplate for correct catalog number, pressure, voltage, for strainers.

frequency, and service. Never apply incompatible fluids or exceed MAINTENANCE pressureratingofthevalve.Instal1ationandvalvemaintenance tobe performed by qualified personnel. A WARNING: To prevent the possibility of person Future Service Considerations injury or property dsmage, turn off electrical pow1 Provision should be made for performing seat leakage, external depressurize valve, and vent fluid to a safe area b@o leakage, and operational tests on the valve with a nonhazardous, servicing the valve.

noncombustible fluid after disassemblyand reassembly. NOTE:It is not necessary to remove the valve from the pipeline Temperature Limitations repairs.

For maximum valve ambient and fluid temperatures, refer to chart below. Check catalog number prefix and watt rating on nameplate. Cleaning

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Allsolenoidvalvesshouldbe cleaned periodically. The time betwe cleaningswillvaqdependingon the medium and serviceconditio Watt Maximum Maxlmum Ingenera1,ifthevoltage to thecoiliscorrect, sluggishvalveoperatit Rating Solenoid Ambient Fluid excessive noise or leakage will indicate that cleaning is required.

Number Prefix Class Temp. the extreme case, faulty valve operation wi11occur and the valve n AC/DC fail to open or close. Clean strainer or filter when cleaning the val None, W, 125°F Preventive Maintenance Keep the medium flowingthrough the valve as free from dirt a 180°F foreign material as possible.

(60°C) (82°C) While in service, the valve should be operated at least ono 180°F month to insure proper opening and closing.

(25°C) (82°C) Depending on the medium and service conditions, perio inspection of internal valve parts for damage or excessive wea Printed in U.S.A. Page 1 of 3 ASCO Valves es*h a* 50-60 Han~verRoad. Rorham Park, New Jeney 07932

recommended. Thoroughly clean all parts. If parts are worn or 3. Install body passage gasket, body passage eyelet, diaphragm damaged, install a complete ASCO Rebuild Kit. assembly, diaphragm spring, valve bonnet and bonnet screws.

Causes of Improper Operation Hand thread screws as far as possible. Then torque bonnet Incorrect Pressure: Checkvalvepressure. Pressure to valve must screws in a crisscross manner to 144 & 15 in-lbs [16,3 -t 1,7 be within range specified on nameplate. Nm].

ExcessiveLeakage: Disassemblevalveand clean allparts. Ifparts 4. Install bonnet gasket, disc holder spring, disc holder qsembly are worn or damaged, install a complete ASCO Rebuild Kit. and adapter in valve bonnet. Torque adapter to 175 2 25 in-lbs [19,8 +. 2,8 Nm].

Valve Disassembly

5. Replace solenoid b

1. Disassemblevalveinanorderlyfashionusingexplodedviewfor identification and placement of parts.

2. Remove solenoid enclosure. See separate instructions. 6. Optional Manual Operator - If removed, install stem with

3. Unscrew solenoid base sub-assembly using special wrench stem gasket clockwise into valve bonnet asing a'suitable adapter supplied in rebuild kit. For special .yrench adapter screwdriver. Reinstall flat washer and retainer. Then turn only, order ASCO Wrench Kit No. K218950. manual operator stem counterclockwise until it stops. This is

4. Remove solenoid base sub-assembly, core, plugnut assembly the position for electrical operation.

and solenoid base gasket. 7. Install solenoid, see separate instructions.

5. Unscrew adapter from valve body, then remove disc holder assembly, disc holder spring and bonnet gasket. A WARNING: To prevent the possibility of personal

6. Optional Manual Operator - It is not necessary to injury or property damage, check valve for proper disassemble the manual operator unless external leakage is operation before returning to service. Also perform evident. If disassembly is required, remove retainer using and internal seat and external leakage tests with a asuitable pairof retainingringpliers. Then remove flatwasher nonhazardous, noncombustible fluid.

and backout manualoperatorstemcounterclockwisewithstem gasket attached.

7. Remove bonnet screws, valve bonnet, diaphragm spring, diaphragm assembly, body gasket, body passage eyelet (not present on all valve constructions) and body passage gasket.

8. All parts are now accessible for cleaning or replacement. If parts are worn or damaged, install a complete ASCO Rebuild Kit.

- Service Notice -

When installing a new ASCO Rebuild Kit, the parts supplied are shown in Figure 1. The parts supplied are new, improved and a direct replacement for the present parts providing all new parts are installed.

A CAUTION:TO ensure proper valve operation, install alt parts supplied in ASCO Rebuild Kit. Do not mix old and new parts.

Valve Reassembly Part Name Torque Value Inch-Pounds Torque Value Newton- Meters

1. Lubricate body gasket,bodypassagegasket,bonnet gasket and Solenoid base solenoid base gasket with DOW CORNING@200 Fluid lubricant or an equivalent high-grade silicone fluid. 175 & 25 19,8 f 2,8

2. Optional Manual Operator - Lubricate stem gasket with Adapter DOWCORNINW 111Compoundlubricantor anequivalent ~~

high-grade silicone grease. Bonnet screws 144 f 15 16,3 +-1,7 Page 2 of 3 Form No. V5826R2

Special wrench adapter for solenoid base IMPORTANT See torque plugnut assembly

solenoid base gasket *

disc holder assembly bonnet screw (4)

disc holder spring mounting bracket (optional feature) manual operator stem

diaphragm assembly MANUAL OPERATOR (OPTIONAL) body passage eyelet

body passage gasket

Figure 1. Series 8210 - valve without solenoid.

Form No.V5826R2 Page 3 of 3 ASCO Valves hiomauc SWEh ca. 50-80 HWCNW Road. florham park. NW ~eneyo m

Attachment Header Document Name:

Document Location Fubresp Description Attach

Title:

SMRC #dB1)3 0 I&, ORIGINATOR Stephen Jonasch Page 1 of -

TITLE Simplification of RHRSW Motor Cooling Lines to Improve Reliability DESCRIPTION Priority: 0 A1 A B C (Identify Reason for Choice)

Proposed Cycle: Current Cycle 17Future Cycle See attached.

System RHRSW Component P-8-1A - D ER # See attached JUSTIFICATION (Include cost benefit if priority A, B or C and the results of the RIDM Process)

, lo, See attached.

Originator Stephen Jonasch Signature:/Date e - f l U

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3 ManagernDE rb Signaturemate Dept. SuperintendentApprova*l* %&!-&

Dide 4-23-0? IJpp.. Epc( @q+

&&#m?/*~cr ccplt;esaiem#

DE Superintendent Approv JE-4 1 4 4 %

SE SuperintendentAppro (Equipment Issues)

Implementing Dept. Supt.

Work Managemendoutage Supt. Approva Reason(s) for disapproval:

SMRCDISPOSITION Priority: H A 1 O A

. oc I$ 3 APPROVE CANCEL 1

=- @

/

Current Cycle 0Future CycIe fd /W-/

CYt(mits/Requirements (see at&ehnmt>At: 0 Reschedule Request B e i U /

APPROVED:

SMRC Chairman VYAPF 0051.01 AP 0051 Rev. 2 Page 1 of 1

SMRC PRESENTATION

SUMMARY

Title:

Simplification of RHRSW Motor Cooling Lines to ImDrove Reliabilitv SMRC Request No.:

Problem Statement & Assessment RHRSW pump motor oil cooling lines have numerous Components (relief valves, pressure control valve, solenoid valve, strainer, sight glass) that are not appropriate for the intended application and have resulted in significant decrease in system reliability, caused numerous ERs to be generated, resulted in entering TS actions that could result in shutting the unit down, caused significant NRC oversight and initiation of a BMO. See attached for additional information.

Solution Musts Avoid Plant Shutdown Avoid MIC Oversight Improve reliability of the system.

Replace improperly designed components.

Simplify the cooling process.

Solution Wants Ease of maintenance Minimize impact to Operations in normal and off-normal plant conditions (ACSLOCA)

Eliminate IST components Option Summary (See the attached sheet)

(Identify the Option Recommended)

1. Replace improper components; simplify system.

2. Do nothing; risk plant shutdowns, NRC Oversight, poor system reliability.

L 4

Option #1 is the recommended option to pursue.

ShortList Reduces future maintenance Improvement to reliability Eliminate IST components 0 Final Recommendation Develop a MM to simplify the inlet lines to the motor oil cooling to RHRSW pumps VYAPF 005 1.02 AP 0051 Rev. 2 Page 1 of 2

Must:

Solution costs must be less than benefits b-0 Avoid plant shut down b- Avoid NRC Oversight o

Replace Improperly Designed Components I

Improve reliability 03

~~

W Simplify Minimize Impact to OPS during W

normal and off normal times Eliminate IST components 4

Ease of Maintenance

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, ' I DECISION-MAKING FLOWCHART Ideal Condition No f 1

Do Nothing k /

- : Consult with 5 managementand 3 f consider SMRC :

presentation. :

s

. s rn m m m rn am solution cost to r.....9......~...9rn....+

I Identify Mustsand i

Wants and evaluate :

rn 8

solutions.

(Employ Decision-8 makingMode1) 5, Implement Selected Solution w/ Management Review

DECISION-MAKING FLOWCHART W

Condition:

RHRSW pump motor oil cooling components (relief valves, PCV, SOV, strainer and sight glass) are not appropriate for intended purpose and resulted in significant decrease in system reliability, generated numerous ERs, invoked NRC oversight and initiation of a BMO.

The condition is REQUIRED to be addressed if any of the following questions can be answered YES.

Would the condition, if not addressed, result in

1. a Non-Compliance with NRC RegulationsNY Plant License? X* Yes

___I x* No

2. any other regulatory non-compliance? -Yes _c X No

3. imminent personnel injury or accident? -Yes - X No

4. actual increased VY Production Cost greater than $75,000? -Yes 2X No If Yes, explain your answer below and then proceed to the Solution Selection Process.

Past conditions HAVE resulted in operation of the system in a degraded condition and subsequently declaring the system INOP, invoked increased NRC oversight, threatened a plant shutdown and required a BMO to address the issue. The system has been repaired to a marginal status and many of the inherent defects are not fully resolved.

RIDM 06/18/03

DECISION-MAKING FLOWCHART 0

Condition: RHRSW pump motor oil cooling- components (relief valves, PCV, SOV, strainer and sight glass) are not appropriate - for intended purpose and resulted in significant decrease in system reliability, generated numerous ERs, invoked NRC oversight and initiation of a BMO.

The Condition may be addressed if it adds value consistent with the VY Vital Few and its benefit to VY can be quantified...

Does addressing the Condition, benefit VY in any of the following a.reaS? (Include lost opportunity considerations as well)

1. Reduced Production Cost or Increased Plant Output? -Yes X No If Yes, Quantify in dollars. $ 12,600 For every Megawatt-hour gained, assume a marginal benefit of $33.00. Projection of the benefit should consider all future operating hours for which the benefit would appIy.

Explain: Reduction in maintenance efforts (220 mhrs to date); elimination of IST componentdtests (4mhrs)

(220 mhrs x $50 + 4 mhrslvr x $50 x 8 yead201 1) =

2. Reduced or Averted NRC Inspection hours. -X Yes -No If Yes, Quantify in dollars. $ 18,400 Consider averted NRC inspections from avoided events, NRC PI Color Changes or findings that would resuIt in added inspections. Assume an inspection cost of $230kiipector-hour for these cost estimates.

(Includes inspector plus VY personnel cost.) 2 man-weeks estimated: 80 hrs x $230 = $18,400

3. Increased public confidence. -Yes X No If Yes, Quantify in dollars. $

Consider such attributes as protection of the environment, increased public safety, etc. When no firm value can be accurately assessed, a nominal cost range should be applied for conditions, which would measurably improve Public Opinion as follows:

Some benefit $5,000 Significant Benefit: $25,000

4. Other Benefits (ALARA dose savings, averted plant shutdown or de-rate, etc.) _xI_ Yes -No If Yes, Quantify in dollars. $ 10,080,000 For Dose savings assume $15,OOo/Rem. For averted plant shutdown, assume $30,000 per hour.

Explain: Degradation of the motor cooling line resulted in a declaration of the system being Inoperable and a BMO was required to avert a plant shutdown. Should this occur again, a shut down may occur. Modification of all 4 trains wilI take approximately 2 weeks. $30,000 x 14 days x 24 hrs/day = $10,080,000 Total Benefit expected from Solution: $ 10,111,000.

RIDM 06/18/03

DECISION-MAKING FLOWCHART A SHOULD DO Decision is limited in its implementation cost to a fraction of the quantified benefit. The limitation will be defined by the evaluation of two parameters:

1) The Probability of attaining the perceived benefit and

2) The significance of the WORST CASE adverse Consequence that would be realized if the Solution were not undertaken.

NOTE: This cost constraint process is not intended to provide absolute caps on project implementation.

Instead, the evaluator should impose reasonable Probability Multide I Examples Consequence Multiple Temporary and minor loss of Insignificant/ Mmimal adverse impact; generation; opportunity cost with > 5 0.05 year payback Plant outage recoverable in days, Some Impact opportunity cost with payback >2 and 0.5 c 5 years. .-

Threatens long term shutdown (> 60 Moderate to Highly Significant 1.0 days) or continued plant operation.

Probability Multiple X Consequence Multiple = Cost Benefit Factor (CBF).

Shutdown costs: 0.1 (low probability) x 0.5 (outage consequence) x $10,111,000= $505,550 IUDM 06/18/03

Attachment 1 SMRC REQUEST Simplification of RHRSW Motor Cooling Lines to Improve Reliability Problem

Description:

RHRSW pump motor oil cooling lines have numerous components* that are not appropriate for the intended application and have resulted in significant decrease in system reliability, caused numerous ERs to be generated, resulted in entering TS actions that could result in shutting the unit down, caused significant NRC oversight and initiation of a BMO. See attached for additional information.

"relief valves - SR-70-13A-D and SR-70-14A-D

solenoid valves - SE-70-4A-D

strainers - S-70-9A-D

pressure control valves - PCV-104-75A-D

sight glasses - FI-70-104A - D Recommendation:

Simplify the RHRSW motor oil cooling lines by eliminating as many of the components as possible.

Justification:

Elimination of these components is desirable to improve system reliability and enhance the simplicity of the system. Past operational problem have resulted in excessive maintenance efforts, engineering evaluations, NRC involvement and a risk to plant generation. A detailed synopsis is provided in attachment 2 documenting the stated impacts.

PROPOSED OPTIONS:

There are two proposed options presented below. The difference between Option 1 and 2 is who performs the evaluation of increased pressure on the motor cooling coil. If Option 1 is selected, the evaluation of the motor cooling coil is performed by the motor manufacturer, Westinghouse. Option 2 is to perform the evaluation in-house. If performed in house (which Structural Engineering considers inappropriate), there is a large cost penalty. Therefore, Option 1, motor cooling coil evaluation to be performed by Westinghouse, is the preferred method.

BUDGET ESTIMATES:

The costs below are for all 4 pump motor cooling lines, Also, the cost figures are estimates based upon experience with past projects. The final design has not been determined and some of the data above is conditional to the current understanding of the

project, costs Option 1 Option 2 Engineering:

FSD: calcs 100/200 hours x $ 5 0 h = $ 5,000 $ 10,000 Mods 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months x $50/hr = $ 5,000 $ 5,000 Interface 80/100 hours x $5Okr= $ 4,000 $ 5,000 Westinghouse $ 10,000 $ 0 Structural: 100/400 hours x $50/hr = $ 5,000 $20,000 Electrical 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months x $ 5 0 h = $ 4,000 $ 4,000 Materials: pipe, fittings, supports $10,000 $10,000 Installation: 4f men; supplies, consumabIes $140,000 $140,000 Total $ 183,000 $194,000

Attachment 2 SMFX REQUEST Simplification of RHRSW Motor Cooling Lines to Improve Reliability Justification:

A detailed justification supporting the SMRC recommendation to simplify the RHRSW motor cooling lines is provided below. Of significant importance is issues regarding reliability, or lack thereof, of the components as documented in the numerous ERs or other documents such as the BMO and work orders. A brief synopsis of those documents is provided with a final overview of the cause of the problems at the end of this attachment.

System

Description:

The RHRSW system consists of 4 pumps driven by x horse power; 4kv motors.

Motor bearings are located at the top and bottom of the motor and set in an oil reservoir. The top bearing is a thrust bearing which has a cooling coil setting in the oil bath to prevent the bearing from overheating and shorten its life. Each of the motor oil cooling systems consists of piping and the following components:

Solenoid Operated valve: SE-70-4A-D; 1 ASCO SOV. The Solenoid valve controls the water flow; energized to closelde-energized to open; and is logic tied to the pump start.

Pressure Control Valve: PCV-70-75A - D; 36 Fisher regulator. The Pressure Control Valve functions to reduced flow to the 3 -

6 gpm flow rate as observed by the Brooks Sight Glass.

Strainer: S-70-4A - D; 3/8 Kentrol Y strainer. The Strainer functions to strain the RHRSW water to prevent debris from clogging the downstream components.

Safety relief valves: SR-70-13A-D & SR-70-14A-D; 1 Crosby. The safety relief valves function to protect the cooling coil from over pressurization.

Sight Glass: FT-70-70A-D; Brooks 0- 10 gpm flow indicator. The flow indicator is observed by the operator to assure that at Ieast 3 gpm of water is flowing through the cooling coil.

The following is a listing of Event Reports documenting probIems encountered since 2000 on the motor cooling portion of the RHRSW pump motors. It is grouped by the major components noted above.

ER # Descriptioddate Pressure Control Valve Issues 2000- 1670 During surveillance testing, the motor cooling flow was noted by the NRC to be out of spec; low. As found flow was 2.4 gpm. (10/31/02) 200 1-0666 During surveillance testing, the IST as found motor cooling flow was found to be out of spec; high. (4/6/01) 2002-0583 The RB A 0 reported that the motor cooling flow for the B RHRSW pump had decreased to 3.2 gpm; original flow was 3.6 gpm.Approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months later, the flow had decreased to 3.1 gpm. The Control Room instructed the A 0 to adjust PCV-104-75B to increase flow. (3/25/02) 2002-0760 The Control Room was informed from the A 0 that the motor cooling flow for the D RHRSW pump had dropped below the required spec of 3 - 6 gpm. The flow was found to be 2.7 gpm. The A 0 was instructed to adjust the PCV-104-793 to raise the flow to 3.2 gpm. On the second set of rounds, the A 0 reported that the flow had again dropped below the L required setting and was readjusted to 3.5 gpm. The flow was them monitored every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . (4/15/02) 2002-0797 On 4/14/02, at 0650 hrs, RHRSW pump was removed from service to trouble shoot conditions noted on prior ER 2002-760. Trouble shooting efforts were performed per WO 02-1617 to inspect the entire motor cooling line. One condition noted was a stiff diaphragm gasket that could contribute to the erratic behavior. (4/19/02) 2002-0803 During the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months maintenance run for P-8-1D, motor cooling water flow decreased from 4.5 gpm to 3.2 gpm over a 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months period. Pressure downstream of the PCV also decreased from 12 psi to 10 psi. P-8-1D was declared inoperable. (4/21/02)

2002-0806 PCV-104-75D has a spring with a range of 25 - 75 psig. The system is set to approximately 12 psig when running the RHRSW pump. Verified that the spring was 25 - 75 during rebuild of valve on WO 02-1617-4.

(4/21/02) 2002-1945 Unexpected results observed during the Pm of P-8-1D. The cooling water pressure fluctuated when pump was started after cooling water pressure regulator was rebuilt. Cooling water flow was constant, I&C manually stroked the PCV and the pump was retested with no fluctuation noted. (9/7/02)

Relief Valve Issues 2002-2415 During A 0 rounds, water was observed coming out of the drain pipe that SR-70-13A AND SR-70-14A tap into. (10/14/02) 2002-2449 During the operability pump run of the 'A' RHRSW Pump, the motor cooling water line relief valve, SR-70-13A, had a steady stream of water leaking thru it. Impact to refuel startup - valve replaced (10/16/02) 2002-2683 During RHRSW surveillance testing it was noticed that the motor cooling line reliefs on "A"and "C" RHRSW pumps were leaking. "A"- 5 dpm and "C" - 10 dpm. Work orders were initiated. (10/30/02) 2003-0160 SR-70-13D was removed during the recent "B" RHR LCO for setpoint testing in accordance with the IST Program. Expansion testing is required to be performed on at least two of the other valves in this group. The other valves in this group include SR-70-13A, 13B, and 13C. (1/23/03)

L 2003-0813 Inlet union threads to relief valve was found to be damaged and was extremely difficult to loosen. The assembly was removed and a new union welded onto the inlet. (10/4/02) 2003-1019 SR-70-13A was replaced as corrective maintenance activity and was reported as leaking approximately 5 dpm during RHRSW pump operation.

During testing of the removed valve it was found to be leaking pass the seat at 10 psig. (5/1/03) 2003-1027 Relief valve SR-70-13B failed the as-found setpoint test. This valve is the last of four valves in the functional group to be tested; therefore no expansion testing of other valves is required due to this failure. (5/7/03) 3

2003-1216 Relief valve SR-70-13D was replaced and a tested spare installed. The new installed relief valve may not be properly set to its setpoint. The pressure gauge used to pre-test it was found to be out of calibration by 32 psig. (6/5/03)

Solenoid Operated Valve Issues 2001- 1250 Solenoid operated valve in the motor cooling line failed to close/stuck open when the pump was stopped and allowed continued flow. This is an ACS inventory concern. (5/14/01) 2002-0765 RHRSW pump D was running for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the maintenance run.

While D pump was running the service water pressure dropped to 90 psig.

During trouble shooting efforts, it was discovered that the motor cooling flow was still flowing for the RHRSW pump D with the pump off. The manual valve was shut and the header pressure equalized. (4/15/02) 2002-0802 Following the RHRSW pump D 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months maintenance run, after the pump was secured, the motor cooling solenoid valve failed to reposition (close).

The manual isolation valve was closed and then reopened 1 minute later, and the solenoid valve remained open. The manual isolation valve was closed again and the operator heard/felt the solenoid valve close. This is a repeat occurrence. (4/21/02)

Sight Glass Issues 2002-1192 Following inspections involving disassembly of the sight glass for cleaning, it was observed that the flow meter was not installed properly, it was upside down.

2003-0992 Following cleaning, the sight glass indicator was stuck and had to be disassembled to free it up.

BMO 2002-006 As a result of m&y of the above issues, the Operability of the RHRSW motor cooling lines, and hence the entire RHRSW system, was cast into doubt. Accordingly, BMO 2002-006 was generated to address these issues. The BMO concluded it was acceptable to continue to operate until the MCO scheduled for mid May.

The BMO required a number of short and long term commitments. One long term commitment was to review the motor cooling line system and determine where reliability enhancements and simplifications could be obtained.

This SMRC request is therefore an outcome of the numerous design and reliability issues identified during the investigations conducted by System Engineering.

WORK ORDERS As part of the activities noted above, there was a resultant impact to maintenance and planning personnel. A review of work orders completed during the year 2000 to present, which most of the issued noted above occurred, resulted in finding 40 work orders on 18 components and over 220 man hours of labor expended on these issues. All of this work was not planned.

EVALUATION OF CAUSES Motor Cooling Flow Rate Drifting: The PCV was designed to control pressure using a spring rated for 25 - 75 psig. While the inlet pressure to the PCV is essentially Service Water header pressure of 100 psig, the outlet pressure was observed to be only 10 - 19 psig. The design of the PCV is that the spring is above the diaphragm and past the valve seats. Pressure is monitored, via a weep hole, to above the gasket (and hence the spring) after the valve seat. Since the seat is only open minimally to obtain the 3 - 6 gpm flow, the pressure sensed by the spring is in the range of the 10 - 19 psig outlet pressure. The spring is overrated for this application and therefore the PCV does not control the flow very well and drifts. To resolve this issue, a different spring was installed that was closer to the design requirements. The correct spring was NOT installed as this wouId have required installation of a different model pressure control valve.

L SOV Sticking Open Problems: The SOV is in the same category of being overrated for its purpose. The SOV is a pilot operated SOV which operates on the dP across the pilot.

In the low flow application applied here, where flow has been restricted by the PCV to only 3 - 6 gpm, insufficient dP is generated to properly actuate the SOV to close. There is sufficient dP initially to OPEN the SOV, as it is a normally energized and closed valve.

In the closed position, the dP across the pilot is 100 psig Service Water on the inlet side and (essentially) zero on the outlet side since there is no flow. After opening, (not energized), the dP is very low and the pilot valve has difficulty in generating the dP to close the SOV. Discussions with the vendor confirmed that the current application for this style of valve is inappropriate.

5

Relief Valves: Relief valves have been a constant problem with leaks and setpoint drift.

Leakage results in a concern for ACS inventory and requires Engineering evaluation or Maintenance repair. Setpoint drift requires expansion of the test group and results in additional, unnecessary workload. As an added note; the relief valves on each pump are welded together at the discharge line so that individual relief valves cannot be removedtested. This added maintenance has impacted the condition of the union threads and resulted in replacement of one damaged union.

Additional Aspects: Other positive items to consider is the impact to the IST program.

Elimination of the relief valves and the solenoid valve also removes these components from the IST program. A total of 12 components would be removed from the program and resuIt in a reduction of quarterly testing or solenoids and testing of relief valves on a 5 year interval; provided failures do not drive increased testing; which has shown to be an issue. Elimination of the strainer would resolve an concern of strainer plugging if it occurred during a LOCA. By simplifying the motor cooling line to eliminate the other components, the need of a strainer is eliminated. Installation of a simpler style of flow meter, an inline styIe with adjustable flow valve, will reduce excessive maintenance efforts to clean the current style flow meter. All of the above improvements would result in a m r e reliable system that is simpler to operate and reduce the need for maintenance.

Contributinp Causes: While the above problems of the PCV and SOV are related to pressure and flow considerations; the initial cause of the issue was a prior modification to the motor cooling line location. TM 93-065 was generated to move the motor cooling line suction from the outlet of the RHRSW pumps to a lower pressure connection in the 8 service water header. This was performed due to the high pressure that the SOV was experiencing at outlet of the pumps. The SOV was experiencing approximately 300 psig pressure (loo+ psig from the service water pumps and an additional 190+ psig from the RHRSW pump) which was causing the SOV cover gasket to be blown out. The design change moved the motor cooling line to the lower pressure source (service water pressure

- 100 psig) and impacted the response of the SOV and the PCV to the lower pressures.

Page 1 of 4 Rev 2 Attachment 1 SMRC REQUEST Simplification of RHRSW Motor Cooling Lines to Improve Reliability Problem

Description:

RHRSW pump motor oil cooling lines have numerous components* that are not appropriate for the intended application and have resulted in significant decrease in system reliability, caused numerous ERs to be generated, resulted in entering TS actions that could result in shutting the unit down, caused significant NRC oversight and initiation of a BMO. See attached for additional information.

"relief valves - SR-70-13A-D and SR-70-14A-D

solenoid valves - SE-70-4A-D

strainers - S-70-9A-D "pressure control valves - PCV-104-75A-D "sight glasses - FI-70-104A - D Recommendation:

The goal is to simplify and improve reliability of the RKRSW motor oil cooling lines by eliminating as many of the components as possible.

The preferred conceptual design (Option 1) envisions the elimination of the relief valves, solenoid valves, strainer, and pressure control valves. A smaller, in line flow rotameter on the outlet side ( N N S ) would replace the current sight gauge (inledSC3). How would be controlled by the use of a flow orifice designed to provide approximately 6 gpm constant flow. (EPU modifies the outlet to return all water back to the service water systeddeep basin in ACS mode.) Manual isolation and bypass lines/valves would be provided to allow on-line maintenance to the orifice.

Justification:

Elimination of these components is desirable to improve system reliability and enhance the simplicity of the system. Past operational problem have resulted in excessive maintenance efforts, engineering evaluations, NRC involvement and a risk to plant generation. A detailed synopsis is provided in attachment 2 documenting the stated impacts.

Page 2 of 4 Rev 2 PROPOSED OPTIONS:

There are two proposed options presented below. The difference between Option 1 and 2 is the elimination of the Solenoid valve entirely (Option 1) vs. replacing the Solenoid valve with a qualified SOV to meet EQ temperature limits for Power Uprate (Option 2).

Option 1 (eliminate the SOV) is the preferred solution as it is less expensive, eliminates a component prone to failure and complies with the stated goal to simplify the system and make it more reliable. Option 1 also provides the cost assuming that the job would be performed concurrenth with the EPU modification associated with the discharge side of the motor oil cooling lines. Option 2 assumes indeDendent projects performed at different timeframes.

Option 1:

Eliminate relief valves, PCV valves, strainers, and SOVs. Replace the present inlet flow indicator (SC-3) with a smaller in-line rotameter on the OUTLET side ( N N S ) of the motor cooling line. Install a flow orifice on the inlet side with isolation and bypass valves to allow work on line. Note: Instrument tubing may be an alternate method of limiting flow and pressure. Paperwork would be a MM that also incorporates the EPU mod on the outlet line to install a 3-way valve and route the water back to service water piping to maintain deep basin inventory in ACS mode. The Westinghouse evaluation for constant flow to the motor is required. NPS support has been estimated to reflect doing both this mod and the EPU outlet piping mod at the same time to minimize setup/prep costs. EQElect work would be limited to updating drawings to eliminate the SOV wiring. Stress/Seismic would be limited to a sanity check review that says we have less weight and therefore no new analysis is required.

Option 2:

This option was requested per a SMRC comment in an initial presentation. The major change by this request specifies that the SOV does NOT get eliminated. Rather, a new, EQ qualified Solenoid will be installed to address the PUP new heat loads in the corner rooms. Additionally, expect the SOV to be heavier to take into account the added closing forces needed to address the original sticking issue. The added weight will potentially impact stress/seismic and require new supports. Additional engineering time (electrical) will be required to review wiring/amp loading calc if the new SOV draws more current.

Also, EQ should have a contingency cost to completely qualify a SOV for our EQ conditions if a suitable qualified replacement cannot be obtained. The Westinghouse evaluation for constant flow through the motor would NOT be required as the SOV will shut off the water and is the only positive savings for about $1Ok in this option. This modification proceeds separately from the EPU mod on the outlet line and may be

Page 3 of 4 Rev 2 performed at a different datehefuel sometime in the future. Therefore, we would not get the synergy of performing the work on one MM and have to expect N P S to charge for preps, manpower, tooling etc. We will still attempt to eliminate the relief valves. An additional impact to the change in SOV will be to asswe that the current PCV is properly sized due to different flow conditions. A replacement PCV will be needed to address the reliability of flow control. In this mod we will NOT replace the flow indicator and strainer.

BUDGET ESTIMATES:

The costs below are for all 4 pump motor cooling lines. Also, the cost figures are estimates based upon experience with past projects. The final design has not been determined and some of the data below is conditional to the current understanding of the project.

OPTION 1 Dept Description of Activity Time cost Source (lhr = $50)

FSD Calculations to S U D D O ~mod

~ 100 hrs $5.000 base budget FSD Write MM package

40 hrs $2,000 f base budget FSD Interface with construction

20 hrs $1.000 I base budget FSD Westinghouse motor evaluation $10,000 Contractor structural Evaluate stress/seismic 100 hrs $5,000 base budget Electrical Update electrical dwgs to eliminate 80 hrs $4,000 base budget _-

NPS Materials: piping, fittings, supports $10,000 Capital Cost NPS Installation: men. sumlies. consumables* $69.300"

Contractors these line items reflect the synergies of performing the work in conjunction with modifications already planned on the outlet line as required by EPU to address deep basin inventory conservation.

- includes a 10%contingency for problems requiring additional manpower.

Page 4 of 4 Rev 2 OPTION 2 Dept Description of Activity Time cost Source (1 hr = $50)

FSD Calculations to support 140 hrs $7,000 base budget mod/PCV/SOV/Strainer eval*

FSD Write MM package for inlet 100 hrs $5,000 base budget line/SOv/pCv FSD Interface with construction 80 hrs $4,000 base budget Structural Evaluate stress/seismic pipingheavier 150 hrs $7,500 EPU sov Structural Design new pipe supports 80 hrs $4,000 EPU structural Seismic Qual report for new SOV $2,000 EPU Electrical Evaluate/revise electrical dwgs for new 100 hrs $5,000 EPU sov Electrical Initiate Spec to buy new SOV 40 hrs $2,000 EPU Electrical Buy 4 new EQ qualified SOVs** $40,000 EPU Electrical EQ Program documentation updates for 80 hrs $4,000 new SOVs Project Eng Materials: piping, fittings, supports $10,000 Capital Cost NPS Installation: men, supplies, consumables $140,700 Contractors TOTAL $231,200

Does not include potential need of a remote flush capability for the strainer.

- Assumes ability to find previously EQ qualified SOVs which meet the VY EQ limits and will resolve the mechanical problems addressed in this SMRC. If not; a contingency to qualify Solenoids to VY EQ requirements will be required.

w 99 2.56 %

6' Must:

99 Solution costs must be less than benefits

~~

c 0 m 0 Avoid plant shut down 00

+ Avoid NRC Oversight 0 0 Replace Improperly 0 v1 W Designed Components Improve reliability 0 00 0 P m Simplify Wants Minimize Impact to OPS 0 m 00 during normal and off normal times

~~

EIiminate IST components 0 P 4 Ease of Maintenance 0 4 W FINAL SCORES rc, W

Attachment Header Document Name:

Document Location fSubresp Description Attach

Title:

IEquipment Failure Eva1 Check List

ENVYEQUIPMEN" FAILURE EVALUATION C m W S T EqutpmentlComponent Being Evaluated:

&$-IC/ S - 778 -4 c Response info Included in Item # Question for Revlew Disposition YES NO WA Report (inittal)

F l 3 Was the equipment failure expected? t/

Are there deficiencles in the performance of past maintenance? I this component?

7 8

Does any associated component OE relate to this type of component failure? I 9

~ ~~~ ~~~ ~

10 Are there deficiencies in current I-maintenance practiceslbehaviors or in associatedtraining?

11 Does there appear to be any deficiency in design?

12 Is there any concern with quality of parts, shipping, or handling?

13 Does this appear to be a Maintenance Rule FunctionalFailure?

VYOPF O009.06 AP OOO9 Rev. 15 Page 1 of 1

Attachment Header Document Name:

Document Location pubresp Description Attach

Title:

F C E Failure Evaluation Report

APPARENT CAUSE/EQUIPMENT FAILURE EVALUATION REPORT CR Number: CR-VTY-2003-02321 Assigned Department: System Enaneering Investigator: Steohen Jonasch Ext: x3056 Date Report CompIeted: 11/18/03 X The CR was caused by or identified an equipmentkomponent faiIure.

( I f YES, complete VYAPF 0009.06 (Equipment Failure Evaluation Checklist) in accordance with Appendix M.)

0 The CR involved one or more HU inappropriate acts.

( I f YES, complete VYAPF 0009.05 (ENVY Human Performance Evaluation Form) in accordance with Appendix H.)

No HU conditions were observed or identified in this investigation.

Problem Statement: * (copied from CR):

No Indicated Cooling Flow Upon Pump Start Upon pump start for scheduled quarterly surveillance there was no indicated cooling water flow. Spec is 5 - 6 gpm.

Report Narrative:

On 10/23/2003, Operations was in the process of performing surveillance testing on the A and C RHRSW pumps per OP 4124 in preparation for the barrel replacement project per MM 2003-037 and 036. Upon start of the C RHRSW pump, no motor oil cooling flow was observed in the sight glass flow indicator. The normal motor oil cooling flow requirement is 5 - 6 gpm. Upon this discovery, the AOs informed the Control Room of the discrepancy and the pump was shut down.

Why was there no flow:

Trouble shooting was conducted to determine which of two possible causes for the lack of indicated flow; either a stuck indicator in the sight glass or the solenoid valve (SE 4C)failed to open. Both issues have occurred in the past; ERs 2003-0992 and 2003-1509 provide insights to past equipment failures. Operations determined that the flow indicator within the sight glass was not stuck by opening up the bypass valve (bypasses the solenoid valve) and flow was established and noted in the sight glass. Based upon this, the solenoid valve was determined to be the cause of the lack of flow.

Appendix J

- AP 0009 Rev. 15

Whv did the solenoid valve not open:

A Work Order (WO 03-5149) was generated to disassemble the solenoid valve to determine the Cause of the SOV failure. The solenoid was disassembled by experienced I&C techs using the vendor installation & Maintenance Instructions/drawing (copy attached) with the System Engineer present. Each piece was inspected as it was removed.

When the solenoid base sub-assembly (see drawing in attached Maintenance Instructions) of the valve was removed, water poured out of the tube. This tube allows the core to travel internally up and down the tube and allows the spring actuated disc holder to shuttle to vent pressure to the top of the diaphragm. This equalizes pressure across the daphragm and the internal valve seats of the valve are allowed to open; thereby providing the cooling flow. With water present in the base tube, the core became hydraulically locked, preventing the valve from opening.

Why was there water in the base tube:

Further investigation during disassembly of the solenoid valve revealed that the body passage O-ring gasket had debris built up on the O-ring surfaces and there appeared to be a nick in the O-ring itself. Additionally, the body passage eyelet, a small metal tube which fits internal to the O-ring was missing. This eyelet probably did not affect sealing or alignment of the O-ring. Discussion with the I&C tech could not determine why the eyelet was missing. This area may not have been overhauled during the last work order activity and could be from the manufacturer or an overhaul many years ago. In either case, it would not have contributed to this failure as it had been operating satisfactorily till then.

Cause(s) of Condition:

Apparent Cause(s):

AC-1 (P.2.h) Degraded subcomponent contributed to failure The solenoid valve failed to open because the core was hydraulically locked by water within the base tube.

Contributing Cause(s):

cc-1 (M.2.0)

Contributing to the failure where water was present in the base tube was a failure of the O-ring to seal due to encrusted debris and damage.

Appendix J AP0009Rev. 15

Extent of Condition:

The extent of condition is limited to the RHRSW pumps. Each of the four pumps has a motor oil cooling line where flow is controlled by the opening of the solenoid valve.

This specific type of failure has been observed only on the C RHRSW pump and is attributable to the leaking O-ring. Based upon the above, there are no generic or common mode considerations that will affect the safety related function to provide cooling water.

The level of risk from this failure is low. During surveillance testing, flow to the motor oil cooler is verified upon start of the motor. Verification of motor flow is also performed during ACS mode of operation, where RNRSW pumps are most critically needed. Each of the four pumps is a 100%capacity pump capable of performing its safety related functions. The pumps are protected during other evolutions with a temperature alarm in the Control Room to warn of a lack of cooling. At that point, either a different pump can be started or an A 0 can be sent to the location to bypass the solenoid valve.

However, these specific solenoid valves have been the subject of other similar failures where the solenoid valve failed to close. This allows cooling water to continue to flow through the valve; thereby presenting an issue of deep basin inventory margin during ACS mode of operation. This has been documented on numerous ERs, along with numerous other problems associated with the motor oil cooling lines. A total of 21 ERs plus 1 BMO have been generated documenting the numerous deficiencies of the motor oil cooling line system. These deficiencies were summarized in SMRC 2003-016; copy attached. This SMRC recommended a design change to the motor oil cooling lines where the solenoid valve; along with other problem components; were removed from the system. The SMRC was given a B implementation category indicating the need for available funding to be approved before proceeding further.

Common Cause Analysis:

N/A L RELATED OPERATING EXPERIENCE:

Previous Related Conditions (ENVY):

The same failure was documented in ER 2003-1509 and the valve overhauled per WO 03-3722 in July 03. This therefore is a repeat MRFF. (See CA -02).

Related industry OE:

None found Appendix J AP 0009 Rev. 15

Corrective Actions:

Immediatdlnterim Actions Completed Item # Action Taken cc-1 Observed disassembly of SOV to determine cause of failure (WO 03-5149) and repair.

Other Provided functional design deficiency corrective actions to management (SMRC (extent of 2003-07 6) 1 condition) i Item #

Proposed/Assigned Corrective Actions Action Assigned Due Date Department AC-1 System F i g 12/19/03 Functional Failure via Appendix J

.- AP 0009 Rev. 15

Attachment Header Document Name:

Document Location pubresp Description Attach

Title:

FIGURE 8 APPARENT CAUSE ANALYSIS SCORECARD CA for Disposition No.

G~-vfy-deu3--0~3a/

card Performer:

Item Poss. Score Aspect Evaluated Score

Award

1. Does the Problem Statement clearly describe one Condition? 4 4

2. Is the Equipment Failure Evaluation result adequately described in the Report 6 Narrative? G

3. Is the Human Performance Evaluation result adequately described in the 6 Report Narrative?

4. Are the Human Performance and/or Equipment Failure Evaluation attached? 4

5. Has the Extent of Condition Evaluation been performed for the Extent of 8 23 Problem and for the Extent of Cause?

6. Does the Extent of Condition Evaluation include appropriate assessment of risk? 4 4

7. Are the results of the Common Cause Analysis clearly presented? 6 L I

8. Is the Apparent Cause(s) clearly presented and do they make sense based on 8 the data presented? 2 3

9. Are all other (immediate, interim, etc.) Corrective Actions clearly presented? 5 5

10. Are all corrective Actions correctly classified, i.e., CA, LTCA, EN? 5 5

11. Are the results of the internal Related ConditiondOE Search clearly 5 c 2s uresented?

1 12. Are the results of the external Related Conditions/OE Search clearly 5 s

presented?

13.

sense? -

Do all causes have a CorrectiveAction linked to thqm and do the CASmake

\Ih\L 8 c _

14. Is the Effectiveness Review action clearly presented? 3 c

15. Is there a CA to present the results of the Effectiveness Review to the CARB 2 assigned?

16. Is a completed scorecard, signed by the Department Head, attached to the gA&

CRCA? w - L 73 57 TOTAL Score = 53 TOTAL%= \mfa INSTRUCTIONS: Award scores only on information provided in the Report. If a type of action is not applicable,do not count these points. In this case, the base number (denominator) will be 432 (maximum possible). Divide the Award Points by the Possible Points and multiply by 100 to achieve TOTAL %.

Figure 8 AP 0009 Rev. 15 Page 1 of 1

Entergy CORRECTIVE ACTION CR-VTY-2003-02321 CA Number: 2 Assigned By: Eng SYS System Eng Staff Jonasch,Stephen F Assigned To: Eng SYS System Eng Mgmt Boivin,Joseph J Subassigned To : Eng SYS System Eng Staff Jonasch,Stephen F Originated By: Jonasch,Stephen F 11/19/2003 15:49:41 Performed By: Boivin,Joseph J 12/17/2003 14:52:44 I Subperformed By: Jonasch,Stephen F 1 21 1712003 14:43:46 Approved By:

Closed By: Boivin,Joseph J I2/l7/2003 14:52:44 Current Due Date: 1211912003 Initial Due Date: 1 21 1912003 CA Type: CORRECTIVE ACTION Plant Constraint: 0 NONE CA

Description:

Evaluate Maintenance Rule Functional Failure via MR Performance Evaluation

Response

Sat - see below Subresponse :

A Maintenance Rule Performance Evaluation has been prepared, copy attached, evaluating the performance of the RHRSW system. The evaluation concludes that the system is not acceptable and recommends it be revised to MR (a)( I ) status.

Additional commitments are specified to return the system to acceptable MR (a)(2) condition. These commitments recommend specific activities involving SMRC 2003-0 16, copy attached, to implement a design change.

Closure Comments:

Attachments:

Subresp Description SMRC 2003-0 16

Attachment Header Document Name:

FR-VTY-2003-02321 CA-00002 Document Location ISubresp Description Attach

Title:

kMRC I

2003-016

SMRC#gl?fl3 c016 ORIGINATOR StePhen Jonasch Page 1of -

TITLE Simplification of RHRSW Motor Cooling Lines to Improve Reliability DESCRIPTION Priority: A1 (XI A 0B 0 C (Identify Reason for Choice)

Proposed Cycle: (XI Current Cycle Future Cycle See attached.

System RHRSW Component P-8-1A - D ER # See attached JUSTIFICATION (Include cost benefit if priority A, B or C and the results of the RIDM Process)

See attached.

DE Superintendent Approv SE Superintendent Approv (Equipment Issues)

Implementing Dept. Supt. Approv Work Managemendoutage Supt. Approva Reason(s) for disapproval:

SMRCDISPOSITION Priority: CIA1 n A

.f l, oc dMPROVE CANCEL Current Cycle 0 Future Cycle =>- . i . . . /

&ts/Requirements (see at&&mmtk BUUW a RescheduleRequest ProjectLeadDepartment 6 - c7sk hdG.

APPROVED:

SMRC Chairman

' SignatureDate VYAPF OO51.01 AP 0051 Rev. 2 Page 1 of 1

SMRC PRESENTATION

SUMMARY

Title:

Simplification of RHRSW Motor Cooling Lines to ImDrove Reliability SMRC Request No.:

Problem Statement & Assessment RHRSW pump motor oil cooling lines have numerous components (relief valves, pressure control valve, solenoid valve, strainer, sight glass) that are not appropriate for the intended application and have resulted in significant decrease in system reliability, caused numerous ERs to be generated, resulted in entering TS actions that could result in shutting the unit down, caused significant NRC oversight and initiation of a BMO. See attached for additional information.

SoIution Musts Avoid Plant Shutdown Avoid NRC Oversight Improve reliability of the system.

Replace improperly designed components.

Simplify the cooling process.

Solution Wants Ease of maintenance Minimize impact to Operations in normal and off-normal plant conditions (ACSLOCA)

Eliminate IST components Option Summary (See the attached sheet)

(Identify the Option Recommended)

1. Replace improper components; simplify system.

2. Do nothing; risk plant shutdowns, NRC Oversight, poor system reliability.

L

-i Option #1 is the recommended option to pursue.

ShortList Reduces future maintenance Improvement to reliability Eliminate IST components Final Recommendation Develop a MM to simplify the inlet lines to the motor oil cooling to RHRSW pumps VYAPF 005 1.02 AP 0051 Rev. 2 Page 1 of 2

33 P Z) q..

Must:

Solution costs must be less than benefits 0 5; Avoid plant shut down 0 Avoid NRC Oversight 6

L Replace Improperly Designed 0 Components Improve reliability 0

0 m SimpIify Wants Minimize Impact to OPS during 0 m normal and off normal times

~~ ~~

Eliminate IST components 0 4 Ease of Maintenance 0

FINAL SCORES

.' I . ' I DECISION-MAKING FLOWCHART Ideal Condition

=---T Do Nothing

+ : Consult with :

$ managementand :

consider SMRC :

presentation. :

mD m m m m ID.

solution cost to

+

...,............ r.....+

f Identify Mustsand 5 9

Wants and evaluate solutions. ..

1 9

9 8

3 (Employ Decision-f making Model) 8 9

Implement Selected Solution wl Management Review

DECISION-MAKING FLOWCHART Condition:

RHRSW pump motor oil cooling;components (relief valves, PCV, SOV, strainer and sight glass) are not appropriate for intended purpose and resulted in significant decrease in system reliability, generated numerous ERs, invoked NRC oversight - and initiation of a BMO.

The condition is REQUIRED to be addressed if any of the following questions can be answered YES.

Would the condition, if not addressed, result in

1. a Non-Comdiance with NRC Rep;uIations/VY Plant License? X* Yes X* No

2. any other regulatory non-compliance? -Yes __c X No

3. imminent personnel injury or accident? -Yes - X No

4. actual increased VY Production Cost greater than $75,000? -Yes -X No If Yes, explain your answer below and then proceed to the Solution Selection Process.

Past conditions HAVE resulted in operation of the system in a degraded condition and subsequently declaring the system INOP, invoked increased MRC oversight, threatened a plant shutdown and required a BMO to address the issue. The system has been repaired to a marginal status and many of the inherent defects are not fully resolved.

DECISION-MAKING FLOWCHART 0

Condition: RHRSW pump motor oil cooling components (relief valves, PCV, SOV, strainer and sight- glass) are not appropriate for intended purpose and resulted in significant decrease in system reliability, generated numerous ERs, invoked NRC oversight and initiation of a BMO.

The Condition may be addressed if it adds value consistent with the VY Vital Few and its benefit to VY can be quantified...

Does addressing;the Condition, benefit VY in any of the following areas? (Include lost opportunity considerations as well)

1. Reduced Production Cost or Increased Plant Output? -Yes X No If Yes, Quantify in dollars. $ 12,600 For every Megawatt-hour gained, assume a marginal benefit of $33.00. Projection of the benefit should consider all future operating hours for which the benefit would apply.

Exdain: Reduction in maintenance efforts (220 mhrs to date); elimination of IST componentsltests (4 mhrs)

(220 mhrs x $50 + 4 mhrs/yr x $50 x 8 years/2021) =

2. Reduced or Averted NRC Inspection hours. - X Yes -No If Yes, Quantify in dollars. $ 18.400 Consider averted NRC inspections from avoided events, NRC PI Color Changes or findings that would result in added inspections. Assume an inspection cost of $230hspector-hour for these cost estimates.

(Includes inspector plus VY personnel cost.) 2 man-weeks estimated: 80 hrs x $230 = $18,400

3. Increased public confidence. --Yes - X No If Yes, Quantify in dollars. $

Consider such attributes as protection of the environment, increased public safety, etc. When no firm value can be accurately assessed, a nominal cost range should be applied for conditions, which would measurably improve Public Opinion as follows:

I some benefit - $5,000 SignificantBenefit: $25,000

4. Other Benefits (ALARA dose savings, averted plant shutdown or de-rate, etc.) -X Yes -N O If Yes, Quantify in dollars. $ 10,080,000 For Dose savings assume $15,000/Rem. For averted plant shutdown, assume $30,000 per hour.

Emlain: Degradation of the motor cooling line resulted in a declaration of the system being Inoperable and a BMO was required to avert a plant shutdown. Should this occur again, a shut down may occur. Modification of all 4 trains will take approximately 2 weeks. $30,000 x 14 days x 24 hrdday = $10,080,000 Total Benefit expected from Solution: $ 10,111,000.

RIDM 06/18/03

. .. DECISION-MAKING FLOWCHART A SHOULD DO Decision is limited in its implementation cost to a fraction of the quantified benefit. The limitation will be defined by the evaluation of two parameters:

1) The Probability of attaining the perceived benefit and

2) The significance of the WORST CASE adverse Consequence that would be realized if the Solution were not undertaken.

NOTE: This cost constraint process is not intended to provide absolute caps on project implementation.

Instead, the evaluator should impose reasonable Probability that Benefit will be Probability Realized Multide LOW 0.1 Medium (50/50) 0.25 High (almost certain) 0.5 Worst Case Consequence if Solution Examples Consequence not Pursued Multiple Temporary and minor loss of Insignificant/ Minimal adverse impact; generation; opportunity cost with > 5 0.05 year payback Plant outage recoverable in days, Some Impact opportunity cost with payback >2 and 0.5 c 5 years . L Threatens long term shutdown (> 60 Moderate to Highly Significant 1.o days) or continued plant operation.

Probability Multiple X Consequence Multiple = Cost Benefit Factor (CBF).

Shutdown costs: 0.1 (low probability) x 0.5 (outage consequence) x $10,111,000= $505,550 RIDM 06/18/03

Attachment 1 SMRC REQUEST Simplification of RHRSW Motor Cooling Lines to Improve Reliability Problem

Description:

RHRSW pump motor oil cooling lines have numerous components* that are not appropriate for the intended application and have resulted in significant decrease in system reliability, caused numerous ERs to be generated, resulted in entering TS actions that could result in shutting the unit down, caused significant NRC oversight and initiation of a BMO. See attached for additional information.

relief valves - SR-70-13A-D and SR-70-14A-D "solenoid valves - SE-70-4A-D

strainers - S-70-9A-D

pressure control valves - PCV-104-75A-D

sight glasses - FI-70-104A - D Recommendation:

Simplify the RHRSW motor oil cooling lines by eliminating as many of the Components as possible.

Justification:

Elimination of these components is desirable to improve system reliability and enhance the simplicity of the system. Past operational problem have resulted in excessive maintenance efforts, engineering evaluations, NRC involvement and a risk to plant generation. A detailed synopsis is provided in attachment 2 documenting the stated impacts.

PROPOSED OPTIONS:

There are two proposed options presented below. The difference between Option 1 and 2 is who performs the evaluation of increased pressure on the motor cooling coil. If Option 1 is selected, the evaluation of the motor cooling coil is performed by the motor manufacturer, Westinghouse. Option 2 is to perfom the evaluation in-house. If performed in house (which Structural Engineering considers inappropriate), there is a large cost penalty. Therefore, Option 1, motor cooling coil evaluation to be performed by Westinghouse, is the preferred method.

BUDGET ESTIMATES:

The costs below are for all 4 pump motor cooling lines. Also, the cost figures are estimates based upon experience with past projects. The find design has not been determined and some of the data above is conditional to the current understanding of the project.

costs Option 1 Option 2 6s Engineering: J FSD: calcs 100/200 hours x $50/hr = $ 5,000 $ 10,000 Mods 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months x $50/hr = $ 5,000 $! 5,000 Interface 80/100 hours x $ 5 0 b $ 4,000 $ 5,000 Westinghouse $ 10,000 $ 0 Structural: 100/400 hours x $50/hr = $ 5,000 $20,000 Electrical 80 hours9.259259e-4 days 0.0222 hours 1.322751e-4 weeks 3.044e-5 months x $50/hr = $ 4,000 $ 4,000 Materials: pipe, fittings, supports $10,000 $ 10,000 Installation: x men; supplies, consumables $140,000 $140,000 Total $ 183,000 $194,000

Attachment 2 SMRC REQUEST Simplification of RHRSW Motor Cooling Lines to Zmprove Reliability Justification:

A detailed justification supporting the SMRC recommendation to simplify the RHRSW motor cooling lines is provided below. Of significant importance is issues regardhg reliability, or lack thereof, of the components as documented in the numerous ERs or other documents such as the BMO and work orders. A brief synopsis of those documents is provided with a final overview of the cause of the problems at the end of this attachment.

System

Description:

The RHRSW system consists of 4 pumps driven by x horse power; 4kv motors.

Motor bearings are located at the top and bottom of the motor and set in an oil reservoir. The top bearing is a thrust bearing which has a cooling coil setting in the oil bath to prevent the bearing from overheating and shorten its life. Each of the motor oil cooling systems consists of piping and the following components:

Solenoid Operated valve: SE-70-4A-D; 1 ASCO SOV. The Solenoid valve controls the water flow; energized to closelde-energized to open; and is logic tied to the pump start.

Pressure Control Valve: PCV-70-75A - D; WYFisher regulator. The Pressure Control Valve functions to reduced flow to the 3 -

6 gpm flow rate as observed by the Brooks Sight Glass.

Strainer: S-70-4A - D; 3/8 Kentrol Y strainer. The Strainer functions to strain the RHRSW water to prevent debris from clogging the downstream components.

Safety relief valves: SR-70-13A-D & SR-70-14A-D; 1 Crosby. The safety relief valves function to protect the cooling coil from over pressurization.

Sight Glass: FI-70-70A-D; Brooks 0- 10 gpm flow indicator. The flow indicator is observed by the operator to assure that at least 3 gpm of water is flowing through the cooling coil.

The following is a listing of Event Reports documenting probIems encountered since 2000 on the motor cooling portion of the RHRSW pump motors. It is grouped by the major components noted above.

ER # Descriptioddate Pressure Control Valve Issues 2000- 1670 During surveillance testing, the motor cooling flow was noted by the NRC to be out of spec; low. As found flow was 2.4 gpm. (10/31/02) 2001-0666 During surveillance testing, the IST as found motor cooling flow was found to be out of spec; high. (4/6/01) 2002-0583 The REI A 0 reported that the motor cooIing flow for the B RHRSW pump had decreased to 3.2 gpm; original flow was 3.6 gpm. Approximately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months later, the flow had decreased to 3.1 gpm. The Control Room instructed the A 0 to adjust PCV-104-793 to increase flow. (3/25/02) 2002-0760 The Control Room was informed from the A 0 that the motor cooling flow for the D RHRSW pump had dropped below the required spec of 3 - 6 gpm. The flow was found to be 2.7 gpm. The A 0 was instructed to adjust the PCV-104-75D to raise the flow to 3.2 gpm. On the second set of rounds, the A 0 reported that the flow had again dropped below the -

required setting and was readjusted to 3.5 gpm. The flow was them monitored every 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . (4/15/02) 2002-0797 On 4/14/02, at 0650 hrs, RHRSW pump was removed from service to trouble shoot conditions noted on prior ER 2002-760. Trouble shooting efforts were performed per WO 02-1617 to inspect the entire motor cooling line. One condition noted was a stiff diaphragm gasket that could contribute to the erratic behavior. (4/19/02) 2002-0803 During the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months maintenance run for P-8-1D7motor cooling water flow decreased from 4.5 gpm to 3.2 gpm over a 30 hour3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months period. Pressure downstream of the PCV also decreased from 12 psi to 10 psi. P-8-1D was declared inoperable. (4/21/02)

2002-0806 PCV-104-75D has a spring with a range of 25 - 75 psig. The system is set to approximately 12 psig when running the RHRSW pump. Verified that the spring was 25 - 75 during rebuild of valve on WO 02-1617-4.

(4/21/02) 2002-1945 Unexpected results observed during the P m of P-8-1D. The cooling water pressure fluctuated when pump was started after cooling water pressure regulator was rebuilt. Cooling water flow was constant. I&C manually stroked the PCV and the pump was retested with no fluctuation noted, (9/7/02)

Relief Valve Issues 2002-24 15 During A 0 rounds, water was observed corning out of the drain pipe that SR-70-13A AND SR-70-14A tap into. (10/14/02) 2002-2449 During the operability pump run of the 'A' RHRSW Pump, the motor cooling water line relief valve, SR-70-13A, had a steady stream of water leaking thru it. Impact to refuel startup - valve replaced (10/16/02) 2002-2683 During RHRSW surveillance testing it was noticed that the motor cooling line reliefs on "A" and "C" RHRSW pumps were leaking. "A" - 5 dpm and "C"- 10 dpm. Work orders were initiated. (10/30/02) 2003-0160 SR-70-13D was removed during the recent "B" RHR LCO for setpoint testing in accordance with the IST Program. Expansion testing is required to be performed on at least two of the other valves in this group. The other valves in this group include SR-70-13A, 13B, and 13C. (1/23/03) 2003-0813 Inlet union threads to relief valve was found to be damaged and was extremely difficult to loosen. The assembly was removed and a new union welded onto the inlet. (10/4/02) 2003- 1019 SR-70-13A was replaced as corrective maintenance activity and was reported as leaking approximately 5 dpm during RHRSW pump operation.

During testing of the removed valve it was found to be leaking pass the seat at 10 psig. (5/1/03) 2003-1027 Relief valve SR-70-13B failed the as-found setpoint test. This valve is the last of four valves in the functional group to be tested; therefore no expansion testing of other valves is required due to this failure. (5/7/03)

2003- 1216 Relief valve SR-70-13D was replaced and a tested spare installed. The new installed relief valve may not be properly set to its setpoint. The pressure gauge used to pre-test it was found to be out of calibration by 32 psig. (6/5/03)

Solenoid Operated Valve Issues 2001- 1250 Solenoid operated valve in the motor cooling line failed to close/stuck open when the pump was stopped and allowed continued flow. This is an ACS inventory concern. (5/14/01) 2002-0765 RNRSW pump D was running for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for the maintenance run.

While D pump was running the service water pressure dropped to 90 psig.

During trouble shooting efforts, it was discovered that the motor cooling flow was still flowing for the RHRSW pump D with the pump off. The manual valve was shut and the header pressure equalized. (4/15/02) 2002-0802 Following the RHRSW pump D 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months maintenance run, after the pump was secured, the motor cooling solenoid valve failed to reposition (close).

The manual isolation valve was closed and then reopened 1 minute later, and the solenoid valve remained open. The manual isolation valve was closed again and the operator heardfelt the solenoid valve close. This is a repeat occurrence. (4/21/02)

Sipht Glass Issues 2002-1 192 Following inspections involving disassembly of the sight glass for cleaning, it was observed that the flow meter was not installed properly, it was upside down. -

2003-0992 FolIowing cleaning, the sight glass indicator was stuck and had to be disassembled to free it up.

BMO 2002-006 As a result of m&y of the above issues, the Operability of the RHRSW motor cooling lines, and hence the entire RHRSW system, was cast into doubt. Accordingly, BMO 2002-006 was generated to address these issues. The BMO concluded it was acceptable to continue to operate until the MCO scheduled for mid May.

The BMO required a number of short and long term commitments. One long term commitment was to review the motor cooling line system and determine where reliability enhancements and simplifications could be obtained.

This SMRC request is therefore an outcome of the numerous design and reliability issues identified during the investigations conducted by System Engineering.

WORK ORDERS As part of the activities noted above, there was a resultant impact to maintenance and planning personnel. A review of work orders completed during the year 2000 to present, which most of the issued noted above occurred, resulted in finding 40 work orders on 18 components and over 220 man hours of labor expended on these issues. All of this work was not planned.

EVALUATION OF CAUSES Motor Cooling Flow Rate Drifting: The PCV was designed to control pressure using a spring rated for 25 - 75 p i g . While the inlet pressure to the PCV is essentially Service Water header pressure of 100 psig, the outlet pressure was observed to be only 10 - 19 psig. The design of the PCV is that the spring is above the diaphragm and past the valve seats. Pressure is monitored, via a weep hole, to above the gasket (and hence the spring) after the valve seat. Since the seat is only open minimally to obtain the 3 - 6 gpm flow, the pressure sensed by the spring is in the range of the 10 - 19 psig outlet pressure. The spring is overrated for this application and therefore the PCV does not control the flow very well and drifts. To resolve this issue, a different spring was installed that was closer to the design requirements. The correct spring was NOT installed as this would have required installation of a different model pressure control valve.

L SOV Sticking: Open Problems: The SOV is in the same category of being overrated for its purpose. The SOV is a pilot operated SOV which operates on the dP across the pilot.

In the low flow application applied here, where flow has been restricted by the PCV to only 3 - 6 gpm, insufficient dP is generated to properly actuate the SOV to close. There is sufficient dP initially to OPEN the SOV, as it is a normally energized and closed valve.

In the closed position, the dP across the pilot is 100 psig Service Water on the inlet side and (essentially) zero on the outlet side since there is no flow. After opening, (not energized), the dF' is very low and the pilot valve has difficulty in generating the dp to close the SOV. Discussions with the vendor confirmed that the current application for this style of valve is inappropriate.

I .

Relief Valves: Relief valves have been a constant problem with leaks and setpoint drift.

Leakage results in a concern for ACS inventory and requires Engineering evaluation or Maintenance repair. Setpoint drift requires expansion of the test group and results in additional, unnecessary workload. As an added note; the relief valves on each pump are welded together at the discharge line so that individual relief valves cannot be removedtested. This added maintenance has impacted the condition of the union threads and resulted in replacement of one damaged union.

Additional AsDects: Other positive items to consider is the impact to the IST program.

Elimination of the relief valves and the solenoid valve also removes these components from the IST program. A total of 12 components would be removed from the program and result in a reduction of quarterly testing or solenoids and testing of relief valves on a 5 year interval; provided failures do not drive increased testing; which has shown to be an issue. Elimination of the strainer would resolve an concern of strainer plugging if it occurred during a LOCA. By simplifying the motor cooling line to eliminate the other components, the need of a strainer is eliminated. Installation of a simpler style of flow meter, an inline style with adjustable flow valve, will reduce excessive maintenance efforts to clean the current style flow meter. A11 of the above improvements would result in a m r e reliable system that is simpler to operate and reduce the need for maintenance.

Contributing Causes: While the above problems of the PCV and SOV are related to pressure and flow considerations; the initial cause of the issue was a prior modification to the motor cooling line location. TM 93-065 was generated to move the motor cooling line suction from the outlet of the RHRSW pumps to a lower pressure connection in the 8 service water header. This was performed due to the high pressure that the SOV was experiencing at outlet of the pumps. The SOV was experiencing approximately 300 psig pressure (loo+ psig from the service water pumps and an additional 190-t psig from the RHRSW pump) which was causing the SOV cover gasket to be blown out. The design change moved the motor cooling line to the lower pressure source (service water pressure .I

- 100 psig) and impacted the response of the SOV and the PCV to the lower pressures.

6

Page 1 of 4 Rev 2 Attachment 1 SMRC REQUEST Simplification of RHRSW Motor Cooling Lines to Improve Reliability Problem

Description:

RHRSW pump motor oil cooling lines have numerous components* that are not appropriate for the intended application and have resulted in significant decrease in system reliability, caused numerous ERs to be generated, resulted in entering TS actions that could result in shutting the unit down, caused sigmficant NRC oversight and initiation of a BMO. See attached for additional information.

relief valves - SR-70-13A-D and SR-70-14A-D

solenoid valves - SE-70-4A-D "strainers - S-70-9A-D

pressure control valves - PCV-104-75A-D

sight glasses - FI-70-104A - D Recommendation:

The goal is to simplify and improve reliability of the RHRSW motor oil cooling lines by eliminating as many of the components as possible.

The preferred conceptual design (Option 1) envisions the elimination of the relief valves, solenoid valves, strainer, and pressure control valves. A smaller, in line flow rotameter on the outlet side ( N N S ) would replace the current sight gauge (inledSC3). Flow would be controlled by the use of a flow orifice designed to provide approximately 6 gpm constant flow. (EPU modifies the outlet to return all water back to the service water systeddeep basin in ACS mode.) Manual isolation and bypass lines/valves would be provided to allow on-line maintenance to the orifice.

Justification:

Elimination of these components is desirable to improve system reliability and enhance the simplicity of the system. Past operational problem have resulted in excessive maintenance efforts, engineering evaluations, NRC involvement and a risk to plant generation. A detailed synopsis is provided in attachment 2 documenting the stated impacts.

Page 2 of 4 Rev 2 PROPOSED OPTIONS:

There are two proposed options presented below. The difference between Option 1 and 2 is the elimination of the Solenoid valve entirely (Option 1) vs. replacing the Solenoid valve with a qualified SOV to meet EQ temperature limits for Power Uprate (Option 2).

Option 1 (eliminate the SOV) is the preferred solution as it is less expensive, eliminates a component prone to failure and complies with the stated goal to simplify the system and make it more reliable. Option 1 also provides the cost assuming that the job would be performed concurrently with the EPU modification associated with the discharge side of the motor oil cooling lines. Option 2 assumes independent projects performed at different timeframes.

Option 1:

Eliminate relief valves, PCV valves, strainers, and SOVs. Replace the present inlet flow indicator (SC-3) with a smaller in-line rotameter on the OUTLET side (NNS) of the motor cooling line. Install a flow orifice on the inlet side with isolation and bypass valves to allow work on line. Note: Instrument tubing may be an alternate method of limiting flow and pressure. Paperwork would be a MM that also incorporates the EPU mod on the outlet line to install a 3-way valve and route the water back to service water piping to maintain deep basin inventory in ACS mode. The Westinghouse evaluation for constant flow to the motor is required. NPS support has been estimated to reflect doing both t h ~ smod and the EPU outlet piping mod at the same time to minimize setup/prep costs. EQElect work would be limited to updating drawings to eliminate the SOV wiring. Stress/Seismic would be limited to a sanity check review that says we have less weight and therefore no new analysis is required.

Option 2:

This option was requested per a SMRC comment in an initial presentation. The major change by this request specifies that the SOV does NOT get eliminated. Rather, a new, EQ qualified Solenoid will be installed to address the PUP new heat loads in the comer rooms. Additionally, expect the SOV to be heavier to take into account the added closing forces needed to address the original sticking issue. The added weight will potentially impact stress/seismic and require new supports. Additional engineering time (electrical) will be required to review wiringlamp loading calc if the new SOV draws more current.

Also, EQ should have a contingency cost to completely qualify a SOV for our EQ conditions if a suitable qualified replacement cannot be obtained. The Westinghouse evaluation for constant flow through the motor would NOT be required as the SOV will shut off the water and is the only positive savings for about $lOk in this option. This modification proceeds separately from the EPU mod on the outlet line and may be

Page 3 of 4 Rev 2 performed at a different datehefuel sometime in the future. Therefore, we would not get the synergy of performing the work on one MM and have to expect N P S to charge for preps, manpower, tooling etc. We will still attempt to eliminate the relief valves. An additional impact to the change in SOV will be to assure that the current PCV is properly sized due to different flow conditions. A replacement PCV will be needed to address the reliability of flow control. In this mod we will NOT replace the flow indicator and strainer.

BUDGET ESTIMATES:

The costs below are for all 4 pump motor cooling lines. Also, the cost figures are estimates based upon experience with past projects. The final design has not been determined and some of the data below is conditional to the current understanding of the project.

OPTION 1 TOTAL $106,300 these line items reflect the synergies of performing the work in conjunction with modifications already planned on the outlet line as required by EPU to address deep basin inventory conservation.

- includes a 10%contingency for problems requiring additional manpower.

Page 4 of 4 Rev 2 OPTION 2 Dept Description of Activity Time cost Source (1 hr = $50)

FSD Calculations to support 140 hrs $7,000 base budget mod/PCV/SOV/Strainer eval*

FSD Write MM package for inlet 100hrs $5,000 base budget

~ine/Sov/pcv FSD Interface with construction 80 hrs $4,000 base budget Structural Evaluate stress/seismic pipingheavier 150 hrs $7,500 EPU sov structural Design new pipe supports 80 hrs $4,000 EPU structural Seismic Qual report for new SOV $2,000 EPU Electrical Evaluatehevise electrical dwgs for new 100 hrs $5,000 EPU sov Electrical Initiate Spec to buy new SOV 40 hrs $2,000 EPU Electrical Buy 4 new EQ qualified SOVs** $40,000 EPU Electrical EQ Program documentation updates for 80 hrs $4,000 new SOVs Project Eng Materials: piping, fittings, supports $10,000 Capital Cost NPS Installation: men, supplies, consumables $140,700 Contractors TOTAL $23 1.200

Does not include potential need of a remote flush capability for the strainer.

- Assumes ability to find previously EQ qualified SOVs which meet the VY EQ limits and will resolve the mechanical problems addressed in this SMRC. If not; a contingency to qualify Solenoids to VY EQ requirements will be required.

Must:

Solution costs must be less than benefits 0 bo Avoid plant shut down c Avoid NRC Oversight 0 bo 0 Replace Improperly 0 rD Designed Components Improve reliability 0 VI 00 0 P 00 Simplify Wants Minimize Impact to OPS 0 m 00 during normal and off normal times Eliminate IST componenB 0 P Ease of Maintenance 0

P z

Attachment Header Document Name:

PR-VTY-2003-02321CA-00002 Document Location Attach

Title:

Entergy Vermont Yankee 10CFR50.65 Maintenance Rule Program Performance Evaluation for RHRSW Residual Heat Removal Service Water (Check One)

This pe f l o m n c e evaluation has determined that this SSC requires a Perjormance Improvement Plan with Goals and Goal Monitoring.

This pe flonnance evaluation has determined that this SSC does not require a Perjormance Improvement Plan and will continue to be monitored under category (a)(2)of the Maintenance Rule Program.

Revision: Original Date: 01/08/04 Evaluation Number: ER 2003-02321 Page 1 of 9

1 List of Revisions Revision Date Description Original 01/08/04 Original (ER 2003-02321)

Page 2 of 9

Performance Evaluation 1.0 Problem Statement Residua1 Heat RemovaI Service Water (RHRSW) - C RHRSW train has exceeded its Maintenance Rule Performance criteria with a Repetitive Maintenance Rule Functional Failure. The repetitive failure involved the failure of the RHRSW motor oil cooling line solenoid operated valve, SE-70-4C from opening to provide cooling flow. The first failure occurred 7/10/03; documented via ER 2003-1509. The second failure occurred 10/23/03; documented via ER 2003-2123. This is a goal requirement of the Maintenance Rule Program; VY Implementation Guideline 6, paragraph A-2-c.

2.0 Background

The RHRSW system consists of 4 - 100% pump trains which act as booster pumps to the service water system to provide cooling water to the RHR Heat Exchanger. This heat exchanger provides a heat transfer medium to remove heat from the reactor and torus under various conditions, both normal and accident. Two pumps each per train are physically located in the NE (A Train) and SE (B Train) corner rooms at the 232 level.

The pumps are tested quarterly via surveillance tests conducted with the RHR pumps per OP 4124. The pumps also are run to support torus cooling andor when the RHR system is used to lower the torus level due to normal in-leakage.

The pumps are run by a 4 KV, 350 Hp motor. The top bearing of the motor is contained within an oil bath to provide lubrication and increase the life of the bearing. This oil bath is cooled via service water flow through a coil in the bath. The flow of cooling water is approximately 5 gpm, monitored by a sight glass, controlled on/off with a solenoid operated valve and at reduced pressure (approx 15 psi) using a pressure regulating valve.

On 10/23/2003, Operations was in the process of performing surveillance testing on the A and C RHRSW pumps. Upon start of the C RHRSW pump, the A 0 stationed at the pump to monitor its performance observed that no flow was indicated on the motor oil cooling line -

sight glass flow indxator. Upon this discovery, the A 0 informed the Control Room of the lack of cooling water flow and the pump was shut down by the Control Room.

Trouble shooting determined that the lack of flow through the motor cooling lines was due to Solenoid Operated Valve SE-70-4C failure to open. CR-VTY-2003-02321 was initiated and was determined to be a repeat failure of solenoid valve SE-70-4C reported on ER 2003-1509.

The Maintenance Rule Program requires that systems that have repeat failures and more than one risk significant PRA functional failures (PRAFF) be evaluated for (a)(l) status. As of 12/03, the following is the current MR status of the RHRSW system:

Subsystem TrainA TrainB TrainC TrainD TrainA TrainB Unavailability Criteria 1.79% 1.79% 1.79% 1.79% 1.24% 1.24%

Unavailability Actual 0.45% 0.76% 0.50% 0.92% 0.61% 0.83%

MRFF Criteria 2 2 2 2 2 2 MRFF Actual 0 0 2 0 0 0 Page 3 of 9

3.0 Event Evaluations 3.1 Event #1: ER 2003-1509 7/10/2003 Event

Description:

ER 2003-1509 reported that during a routine start of the C RHRSW pump, motor cooling flow was observed to be NOT flowing as normally indicated on the flow sight glass.

Observing motor cooling flow is a routine surveillance activity to validate motor cooling flow has started whenever a RMISW pump is started. This is a confirmation that the solenoid valve has opened. Upon observing no motor cooling flow, the bypass valve was utilized to establish flow.

Event Details:

The solenoid valve is a normally energized, normally closed valve. Upon RHRSW pump start, the solenoid de-energizes and the valve opens. The solenoid valve has failed to close in the past. This results in constant flow of cooling water which is not a significant impact to the system, except in ACS mode of operation. However, in this event, the de-energized solenoid valve failed to open, preventing cooling water to the motor bearing oil cooler. This is the first time this type of event has been reported.

Event Analysis:

The Event Report as written states that the solenoid had failed. As a clarification, the electrica1 portion of the valve; the solenoid; did NOT fail. Additional comments in the ER specified that the valve became unstuck after flow was lverted using the bypass valve. However, the solenoid valve failed to open possibly due to the pilot actuator portion of the valve (used to assist opening the valve) becoming stuck or clogged. Work Order 03-3722 was issued the same day and the FIN team overhauled the valve using a replacement gasket kit. The same solenoid (electrical portion) was reused and the valve (and solenoid) tested satisfactorily after repair. Discussion with the FIN team indicated that there was nothing obviously damaged in the valve or the replaced gaskets or spring.

RESPONSE TO SCREENING COMMITTEE ADDITIONAT, CONSIDERATIONS AND TAB 4 ITEMS Tab 4 specifies to evaluate for extent of condition. As noted above, there have been numerous failures of the solenoid operated valve to CLOSE. Evaluation of the solenoid valve and discussions with the vendor has indicated that this valve is not properly suited for this application. However, this is the first failure reported where the valve failed to OPEN. The fact that the valve eventually opened after the bypass valve was opened, points to the pilot portion of the valve. The design of this valve is to utilize a pilot operated assist to utilize the dp to help open the valve. In past failures, failure to close, is due to the pilot dp not being able to be overcome by the (energized to close) solenoid forces and the valve has remained open. In this first failure, if the pilot orifice portion of the valve had become stuck or clogged, this would account for the failure of the valve to see the dp and thereby use the dp to assist the valve in opening. Unfortunately, the replaced gaskets are no longer available for inspection, and probably were disturbed when the valve was opened for repair making the inspection meaningless anyway.

Page 4 of 9

3.2 Event #2: ER 2003-02321 10l23l2003 Event

Description:

No Indicated Cooling Flow Upon Pump Start. Upon pump start for scheduled quarterly surveillance there was no indicated cooling water flow. Spec is 5 - 6 gpm.

Event Details:

On 10/23/2003, Operations was in the process of performing surveillance testing on the A and C RHRSW pumps per OP 4124 in preparation for the barrel replacement project per MM 2003-037 and 036. Upon start of the C RHRSW pump, no motor oil cooling flow was observed in the sight glass flow indicator. The normal motor oil cooling flow requirement is 5 - 6 gpm. Upon this discovery, the AOs informed the Control Room of the discrepancy and the pump was shut down.

Event Analysis:

Trouble shooting was conducted to determine which of two possible causes for the lack of indicated flow; either a stuck indxator in the sight glass or the solenoid valve (SE 4C) failed to open. Both issues have occurred in the past; ERs 2003-0992 and 2003-1509 provide insights to past equipment failures; Operations determined that the flow indicator within the sight glass was not stuck by opening up the bypass valve (bypasses the solenoid valve) and flow was established and noted in the sight glass. Based upon this, the solenoid valve was determined to be the cause of the lack of flow.

A Work Order (WO 03-5149) was generated to disassemble the solenoid valve to determine the Cause of the SOV failure. The solenoid was disassembled by experienced I&C techs using the vendor installation & Maintenance Instructions/drawing with the System Engmeer present. Each piece was inspected as it was removed. When the L solenoid base sub-assembly of the valve was removed, water poured out of the tube.

This tube allows the core to travel internally up and down the tube and allows the spring actuated disc holder to shuttle to vent pressure to the top of the diaphragm. This equalizes pressure across the diaphragm and the internal valve seats of the valve are allowed to open; thereby providing the cooling flow, With water present in the base tube, the core became hydraulically locked, preventing the valve from opening.

Further investigation during disassembly of the solenoid valve revealed that the body passage O-ring gasket had debris built up on the O-ring surfaces and there appeared to be a nick in the O-ring itself. This appeared to be the cause of the leakage. Additionally, the body passage eyelet, a small metal tube which fits internal to the O-ring was missing. This eyelet probably did not affect sealing or alignment of the O-ring. Discussion with the I&C tech could not determine why the eyelet was missing. This area may not have been overhauled during the last work order activity and could be from the manufacturer or an overhaul many years ago. In either case, it would not have contributed to this failure as it had been operating satisfactorily till then.

Page 5 of 9

These specific solenoid valves have been the subject of other similar failures where the solenoid valve failed to close. This allows cooling water to continue to flow through the valve; thereby presenting a concern of deep basin inventory margin during ACS mode of operation. This has been documented on numerous ERs, along with numerous other problems associated with the motor oil cooling lines. A total of 21 ERs plus 1 BMO have been generated documenting the numerous deficiencies of the motor oil cooIing line system. These deficiencies were summarized in SMRC 2003-016; copy attached. This SMRC recommended a design change to the motor oil cooling lines where the solenoid valve; along with other problem components; were removed from the system. The SMRC was given a B implementation category indicating the need for available funding to be approved before proceeding further.

4.0 Cause Determination Summary In evaluating the cause determination, 10CFR50.65 Program Manual also specifies that the overall system performance should be considered as opposed to a focus on an individual event( s ).

As noted above, similar solenoid valve failures have occurred muItiple times where the valve has failed to close. In this mode, water to the cooling coil in the motor continues to flow.

While these failures are not considered to be MRm;s (the safety function of the pump is not impacted) there is an impact to the deep basin inventory in the ACS mode of operation.

Evaluations were conducted on the solenoid valve and it was concluded that the current solenoid valve is not the appropriate model for this application.

In addition to the failures of the solenoid valve, numerous other failures have occurred to other components comprising this subsystem. The PCV valve used to flow was found to have a drifting problem where flow would gradually decline below the minimum required flow rate. Relief valves in the system have historically failed setpoint testing and leak testing. The resulting failures were impacts to the IST program and required significant amount of work to repair the valves. Procurement has been unable to obtain replacement relief valves meeting the setpoint tolerance requirements of the relief valves.

The problems noted above, plus others associated with the motor cooling lines was documented in a presentation to Management via the SMRC process. SMRC 2003-016 addressed the numerous problems associated with the components in those lines and recommended a modification which eliminated all the problem components. (A copy of SMRC 2003-016 is attached). At the current time, this SMRC is approved with a B rating, meaning that implementation cannot proceed until funding has been authorized. At the present time, funding has not been authorized and the change is not included on the 5 year plan.

Page 6 of 9

5.0 Industry Operating Experience (IOE) Review A number of searches within the Industry, INPO and NRC were conducted. The WRDS data base was searched using search criteria of motor and cooling and solenoid in order to cast a wide net of experiences. A total of 171 events were recorded via this search. There were numerous failures involving solenoid valves in various systems and applications which did not directly apply to this evaluation. Their failures were typically attributed to normal wear out; contacts burned; aging; cycle fatigue; fuses blown and burned coil. None of these causes were applicable to this condition. The closest events reported were from Braidwood, where in 95 a Target Rock Solenoid valve in the W A C system clogged due to scaling and a 94 event at Susquehanna where a diesel air start solenoid was clogged from piping debris. Neither of these events provides any useful information other than a similarity in foreign material causing the events.

Using more specific search criteria, includng vendor (ASCO) a search of LERs did not obtain any records of RHRSW motor cooling line solenoid valve failures.

A search of Operation Events revealed that one OE event was applicable. OE 271-931021-1, reported that on 10/21/93, a utility was required to shutdown due to motor cooling line design criteria being misinterpreted and causing a failure due to pressure exceeding the design criteria on the solenoid valve. The misapplication of the design criteria required a new design to be temporarily installed until a permanent design is implemented. The design change consisted of moving the motor cooling line from the pump discharge to the pump suction to reduce overall pressure to the SOV. That utility was Vermont Yankee.

6.0 PRA Functional Failure Review The PRA Group conducted a review of these MRFFs per VYlOCFR50.65 Implementation Guide No 9, SSC Performance Monitoring Appendix A, Memo SAVY 98-041, Guidelines for B s k Review of MRFFs. The review determined that both of these failures were risk significant PRAFFs.

7.0 Conclusion There have been two failures of the CyRHRSW motor oil cooling line solenoid valve to open and provide cooling water. It is uncertain why the failures occurred on the Cytrain. Review of run times indicate A RHRSW pump is the most run pump with C pump running about half the time as A pump. However, the number of start demands are much closer; 16 vs. 11 over the last 3 months. Still, there appears to be no clear trend that this is a time related condition as the other motor cooling lines have not experienced this failure. Additionally, there have been additional failures of these valves to close to shut off the cooling water. SMRC 2003-016 documented a number of additional issues involving other components within the motor cooling line subsystem and recommended a design change. At the present time, the requested change has not been authorized on the plant 5 year plan. The PRA Risk Achievement Worth (RAW) ranks system importance for the RHRSW system as HIGH with an importance value of 130; or as the 10th out of 43 systems. Based upon the evaluation above and the importance of the system to safety, System Engineering considers that the overall performance of the RHRSW motor oil cooling line is unacceptable.

Page 7 of 9

8.0 PIP Determination Based on this evaluation, it has been determined that performance of the RHRSW System with respect to the motor oil cooling line subsystem is unacceptable and recommends its Maintenance Rule status be changed from (a)(2) to (a)(l). Since a repeat MRFF has occurred, this SSC will be subject to a Performance Improvement Plan.

9.0 Performance Improvement Plan 9.1 Corrective Actions:

9.1.1. Action

Repair solenoid valve SE-70-4C and conduct an inspection of the valve as it is disassembled to determine cause of failure.

Responsibility: I&C-FINISystem Engineering Due Date: Complete (WO03-5 149)

9.1.2. Action

Re-evaluate the present SMRC to strengthen its rating based upon new information (2 MRFFs) to increase its priority. Re-submit to SMRC committee.

Responsibility: System Engineering Due Date: 2/6/04

9.1.3. Action

Review financial costs presented in the SMRC to determine any cost savings, reductions. Consider efficiencies, schedules, reductions of efforts, changes of implementation depts., coordination with other LCOs; simplification of the proposed design, etc.

Responsibility: System Engineering Due Date: 2/6/04

9.1.4. Action

Provide support to System Engineering as needed for items above.

Responsibilitv: Design Engineering (J. Rogers accepts)

Due Date: 2/6/04 9.2 Goals and Goal Monitoring performance is acceptable with no failures related to the RNRSW motor oil cooling line associated with the design change for 3 successive (quarterly) surveillance intervals.

Anticipated start date is 12/30/04.

9.3 Reassessment for Acceptable Performance (a)(2)

FoIlowing completion of CAS and Goal Monitoring; reassess to (a)(2). Anticipated to be 9/30/05.

10.0 Additional Actions None Page 8 of 9

Performance Evaluation / PIP Review and Approval Revision (OriginaI) Dated 01/08/04 Prior to Expert Panel review and approval all departments responsible for additional or corrective actions SHALL have reviewed and provided preliminary approval of any assigned responsibilities for the actions (if applicable).

Prepared By: f LA/f?/@J S p m Engneer I Evaluator Date Approved By:

Approved By: f System Engineering Manager Date Approved By: /

Expert Panel Chairman Date Plant Manager review and approval is required for initial disposition of SSCs to the (a)( 1) category only. If the performance evaluation concludes that the SSC will remain in the (a)(2) category, approval up through the Expert Pane1 is all that is required.

Reviewed By: I Plant Manager Date Forward a copy of all approved Performance Evaluations and PIES to the Maintenance Rule Coordinator (MRC) for update of the Maintenance Rule Programs tracking and trending database.

Entered By: I MRC Date Disposition of SSCs from (a)( 1) back to the (a)(2) category requires Expert Panel review and approval.

Approved By: f Expert Panel Chairman Date Page 9 of 9

I I CA Number: 3 Assigned By: CRG/CARB/OSRC Pallang,Alexander P Assigned To: Eng SYS System Eng Mgmt Subassigned To : Eng SYS System Eng Staff Jonasch,Stephen F Originated By: Pallang,Alexander P 12/18/2003 07:12:46 Performed By: Boivin,Joseph J 1/15/2004 13:07: 19 hbperformed By: Jonasch,Stephen F 1/14/2004 16:17:28 Approved By:

Closed By: Boivin,Joseph J 1/15/2004 13:07:19 Current Due Date: 01/19/2004 Initial Due Date: 0 I / 1 9/2004 CA Type: CR CLOSURE REVIEW CA Plant Constraint: 0 NONE CA

Description:

CR CLOSURE REVIEW Perform a Condition Report Closure Review IAW LI- 102 Section 5.8.1 The Responsible Management, or designee, reviews the CR to make a recommendation for closure using the following criteria as applicable:

The root cause, probable root cause, or apparent cause is valid.

The specific condition is corrected or resolved.

Overall plant safety is not inadvertently degraded.

Generic implications of the identified condition are considered, if significant.

Actions were taken to lessen the likelihood of recurrence, if significant.

Any potential operability or reportability issue(s) identified during the resolution of the condition has been appropriately addressed.

All corrective action items are completed.

Effectiveness Reviews, have been initiated via a Learning Organization CR when applicable.

Response

Sat Subresponse :

A closure review has been conducted in accordance with ENN-LI- 102, para. 5.8.1. The CR response provided 5 attachments which explained the condition, provided an investigation report with supporting vendor maintenance instructions. The cause of the problem was properly identified and is valid. A commitment was generated to further evaluate the condition as a MRFF and write a Performance Evaluation as required by the Maintenance Rule Program. The PE was written and attached to the commitment. As a result of the PE, the Maintenacne Rule Committee met and concurred with the PE. All actions required by this CR have been completed. Other actions have been initiated as a result of the Maint Rule PE and are tracked separately via the MR program.

Closure Comments:

Entergy I CONDITION REPORT CR-VTY-2005-00048 Originator: Shoufler,John C Originator Phone: 5 I 2 1 Originator Group: Operations Staff Operability Required: Y Reportability Required: Y Supervisor Name: Keith,Ronald M Discovered Date: 01/06/2005 16:38 Initiated Date: 01/06/2005 1655 Condition

Description:

Water spill on floor in RCIC 232' elevation.

A hose was ordered removed from the drain on FP DV-76-30 1 (Cable Penetration Area Deluge Valve) for house keeping purposes. The hose was replaced by a bucket under the drain to catch the drips. When the fire pump was started for surveillance, water came out of drain filled and overflowed bucket and made a mess on the floor, hence the hose to the drain.

Immediate Action

Description:

Informed control room, and dumped bucket.

Suggested Action

Description:

Re-install drain hose, and ensure that research as to why drain hoses are installed before authorizing their removal.

EQUIPMENT:

Tan Name Tag Suffix Name Comuonent Code Process Svstem Code DV-76-301 VALVE MR=Y FP TRENDING (For Reference Purposes Only):

Trend Type Trend Code HOW IDENTIFIED HI-SELF-REVEALING WORK PROCESS WP-CB KEY ACTIVITY KA-HK KEYWORDS KW -HOUSEKEEPING

~~~

. I Entergy 1- ADMIN CR-VTY -2005-00048 Initiated Date: 1/6/2005 I6:55 Owner Group :Operations Mgr\ Mgmt Current

Contact:

MMD Current Significance: D - ADMIN CLOSURE Closed by: Dudley,Mona M 1/11/2005 12:42 Summary

Description:

Water spill on floor in RCTC 232' elevation.

A hose was ordered removed from the drain on Fp DV-76-301 (Cable Penetration Area Deluge Valve) for house keeping purposes. The hose was replaced by a bucket under the drain to catch the drips. When the fire pump was started for surveillance, water came out of drain filled and overflowed bucket and made a mess on the floor, hence the hose to the drain.

Remarks

Description:

Closure

Description:

Tygon tubing installed to prevent re-occurrence.

OPERABILITY I CR-VTY-2005-00048 OperabilityVersion: I Operability Code: EQUIPhENT OPERABLE Immediate Report Code: NOT APPLICABLE Performed By: Keith,Ronald M 0 1/06/2005 17:05 Approved By: Keith,RonaId M 0 1/06/2005 1 7:05 Operability

Description:

water on floor is worse then unsightly hose and causes a safety hazard.

Approval Comments:

. . I CR-VTY-2005-00048 Entergy I ASSIGNMENTS Version: 1 Significance Code: D - ADMIN CLOSURE Classification Code: D Owner Group: Operations Mgr\ Mgmt Performed By: Dudley,Mona M 01/11/2005 12:39 Assignment

Description:

Screening Data Significance D - ADMIN CLOSURE Owner : loperations Mgr\ Mgmt Comments:

A Human Performance Evaluation VYAPF 0009.05 is required for all HU identified CRs Trending Items HOUSEKEEPING SELF-REVEALING No security issue.

No HU issue.

Operations installed tygon tubing to drain line to prevent recurrence and informed area owner. Ops confirmed WO and / or CR on degraded valve.

- i REPORTABILITY I CR-VTY-2005-00048 Reportability Version: 1 Report Number:

Report Code: NOT REPORTABLE Boilerplate Code: NOT REPORTABLE Performed By : Hamer,Michael J 01/10/2005 0957 Reportability

Description:

Not reportable - This event does not meet the screening criteria.

Entwgy

~~

I CONDITION REPORT CR-VTY-2005-00261 I

Originator: McAvoyStephen C OriginatorPhone: 2585504 Originator Group: Tech Chemistry Mgmt Operability Required: Y Reportability Required: N Supervisor Name: Wender IV,Samuel A Discovered Date: 0 1/25/2005 08:47 Initiated Date: 01/25/2005 09: I6 Condition

Description:

Chemical treatment of the Service Water System suspended due to lack of service water supply (frozen pipe)

Daily treatment of the service water system with a biodispersant (BULAB 8006) is suspended pending restoration of service water flow to the chemical treatment building. Treatment required per DP 0640 (Chemistry Department Scheduling) and PP760 I (Service Water Chemical Treatment and Monitoring Program)

Immediate Action

Description:

CR 2005-0255 and WOR 05-63679 written 1/24/05 on lack of water to this building (possible frozen supply line)

Suggested Action

Description:

REFERENCE ITEMS:

Type Code DescriDtion CR 2005-00255 PROCEDURE DP 0640 PROCEDURE PP 760 1 WR 05-63679 TRENDING (For Reference Purposes Only):

Trend Type Trend Code HOW IDENTIFIED HI-SELF-REVEALING KEY ACTIVITY KA-CP CAUSAL FACTOR CODES CFC-M2G4 CAUSAL FACTOR CODES CFC-M2D4 WORK PROCESS WP-CE KEYWORDS KW-ADVERSE TREND KEYWORDS KW-COLD WEATHER KEYWORDS KW-NPDES

Entergy ADMIN CR-VTY-2005-00261 Initiated Date: I /25/2005 9: 16 Owner Group :Tech Chemistry Mgmt Current

Contact:

JMT Current Significance: C - MPC & CORRECT Closed by: Taylor,James M 2/11/2005 15:37 Summary

Description:

Chemical treatment of the Service Water System suspended due to lack of service water supply (frozen pipe)

Daily treatment of the service water system with a biodispersant (BULAB 8006) is suspended pending restoration of service water flow to the chemical treatment building. Treatment required per DP 0640 (Chemistry Department Scheduling) and PP760 I (Service Water Chemical Treatment and Monitoring Program)

Remarks

Description:

Closure

Description:

trend data entered. closure review documented in disposition response.

Entergy I OPERABILITY I CR-VTY-2005-00261 OperabilityVersion: 1 Operability Code: NOT REQUIRED Immediate Report Code: NOT APPLICABLE Performed By: Harris,Michael D 01/25/2005 10:45 Approved By: Harris,Michael D 0 1/25/2005 I0:46 Operability

Description:

The affected system is NNS and there are no operability concerns.--MDH Approval Comments:

ASSIGNMENTS CR-VTY-2005-00261 Version: 2 Significance Code: C - MPC & CORRECT Classification Code: C Owner Group: Tech Chemistry Mgmt Performed By: Taylor,James M 01/26/2005 I 1 :08 Assignment

Description:

Screening Data I Significance' C - MPC & CORRECT Owner : Tech Chemistry Mgmt t Comments:, Evaluate alternative methods

! A Human Performance Evaluation VYAPF 0009.05 is required for all HU identified CRs Trending Items ADVERSE WEATHER COLD WEATHER SELF-REVEALING TRACK AND TREND

<<End>>

DH screen refers to CR 2005-255.

Entefgy I

~

A SSI GNMENTS I CR-VTY-200500261 Version: 1 Significance Code: D - ADMIN CLOSURE Classification Code: D Owner Group: Tech Chemistry Mgmt Performed By: Wender IV,Sarnuel A 0 1/25/2005 I3:07 Assignment

Description:

Track & Trend - Result of Frozen Pipes (See CR 2005-255) for details and resolution

I I Entergy CORRECTIVE ACTION CR-VTY-2005-00261 CA Number: 1 Assigned By: CRG/CARB/OSRC Assigned To: Tech Chemistry Mgmt Wender IV,Samuel A Subassigned To : Tech Chemistry Staff McAvoy,Stephen C Originated By: Taylor,James M 1/26/2005 1 1 :09:25 Performed By: Wender IV,Samuel A 2/1 1/2005 13:29:38 Subperformed By: McAvoyStephen C 2/10/2005 14:42:57 Approved By:

Closed By: Taylor,James M 2/1 ]/ZOO5 15:35:37

-~~~ ~

Current Due Date: 02/24/2005 Initial Due Date: 02/24/2005 CA Type: CR DISPOSITION Plant Constraint: 0 NONE CA

Description:

CR Disposition Chemical treatment of the Service Water System suspended due to lack of service water supply (frozen pipe)

(Review CR for Full Details)

Review Screening Comments on the Assignment Tab ii The CRG has initially classified this CR as Classification Code - "C" Significance Code - " MPC & CORRECT"

'J Follow the process provided in AP 0009 Appendix K. If during your investigations into this event it is determined that the classification should be changed, contact the CA&A representative for re-consideration by the CRG.

li Perform Most Probable Cause Evaluation. Issue the appropriate CAS. (per LI 102)

CR Disposition Guidelines: This is only a guide. It is not a substitute for the applicable procedures.

LJ All Attachments are to be in PDF format oAttach Most Probable Cause Investigation Report or Document in the Response or Sub response field oEnsure all Screening Comments have been addressed in the investigation - (CR assignment tab) oDevelop adequate corrective actions and issue CAS. (Due Dates per LI 102 Attachment 9.5) o LT CAS Require Approval from Manager/ GMPO or Director prior to initiating

' oAttach completed VYAPF 0009.02 (CR Trend Input Data Sheet) in accordance with Appendix E.

oAttach completed VYAPF 0009.05 (Human Performance Evaluation) if required. Include Cause Dept ooAttach completed EN-LI- 1 18 Attachment 9. I7 (Equipment Failure Evaluation Checklist) .if assigned.

1 oSpecify any references needed and enter into Ref. Items.

Response

?Condition Report Closure Review IAW LI-102 Section 5.9.1 Completed, Recommend CR Closure?

Subresponse :

See attached CA report and CR trending data sheet.

Closure Comments:

Attachments:

Subresp Description CR T r e w e e t

Entergy CORRECTIVE ACTION CR-VTY-2005-00261 Attachment Header Document Name:

kntitled Document Location Attach

Title:

CR TRENDING INPUT DATA SHEEX CR No: Dispositioning Dept:

J fly- 2 OOS'd 0 zbt NOTE I

See Appendix E (CR Trending) for instructions on how to obtain lidormation with which to complete this form I 1 CAUSE CODES 1 WORK PROCESS Cf KEY A C T l W cf VYAPF 0009.02 AP OOO9 Rev. 17 Page 1of 1

Attachment Header Document Name:

Document Location Attach

Title:

Condition Report Corrective Action CWCA Number: CR-VTY-2005-0261 Initiated Date: 1/25/05 Significance Code: C-MPC and Correct Owner Group: Chemistry Assignee: Steve McAvoy Problem Statement:

Chemical treatment of the Service Water System suspended due to lack of service water supply (frozen pipe). CR screening assignment requested an evaluation of alternative methods of chemical treatment.

Event Descrirition:

Daily treatment of the service water system with a biodispersant (BULAB 8006) was suspended for 3 days due to a frozen section of service water supply pipe to the chemical treatment building. Chemical treatments of the service water system are required by DPO64.0 (Chemistry Department Scheduling) and PW601 (Service Water Chemical Treatment and Monitoring Program). This auxiliary treatment system is comprised of treatment chemicals supplied in (nominal) 55-gallon drums,2 identical positive displacement chemical metering pumps and a common discharge header to a diffuser discharge located in the Service Water Intake Bay just upstream of the Service Water Traveling Screens. Service water that carries the metered chemical through the system is supplied by a single pipe that originates in the Service Water Pump Room located at the intake structure.

This exposed line is insulated and heat traced. [See CR 2005-0255 and WOR 05-63679 written 1/24/05 regarding the lack of Service water supply to the treatment building (ultimately caused by a recent period of sub-zero weather, a failed heat trace, an isolated supply valve and resultant frozen pipe section).]

Chemical Treatment is performed per OP4630,Sampling and Treatment of the Service Water System, and regulated by the site NPDES permit No. 3-1199 issued by the State of Vermont. Chemicals concentrations allowed by this permit are calculated from the known metering pump output into a known service water system flow (calculated from the number of operating SW pumps). Metering pumps are calibrated quarterly per OP4630.

Most Probable Causets):

[M.2.g.4.} - System / component configuration problem. While the treatment system has redundant chemical supply pumps, there are non-redundant individual components that cannot be bypassed if failed.

[M.2.d4.} - Inadequate failure modes and effects evaluation. Active components with a history of failure (i.e. pumps) are redundant. Static system components (i.e.

supply and discharge piping) are not redundant.

Evaluation of Alternative Treatment Methods:

There are several restrictions to any reasonable and practical alternative -

treatments methods: All treatment chemicals are supplied in 55-gallon drums and are susceptible to freezing which restricts winter use / storage outside of a heated structure. Additionally, the consistency of the products vary with temperature (thicker in winter, thinner in summer - hence the positive displacement pumps).

Merely siphoning the product from a drum would in all likelihood violate our NPDES pennit (a permit currently in review for revision, public comment and renewal). Development of a portable self-contained treatment skid would also cause issues with Security due to the proximity to the Protected Area fence.

Short of making the present system totally redundant, no reasonable and practical alternative treatment methods are recommended.

Corrective Actionh):

No further corrective action recommended.

File:CR-05-26 1

CONDITION REPORT 1C R - V T Y - ~ O O ~ - O ~ ~ ~ O Originator: DeForge,Dolord J Originator Phone: 8022585512 Originator Group: Operations Staff Operability Required: N Reportability Required: N Supervisor Name: Twarog,John R Discovered Date: 09/20/2005 08: 12 Initiated Date: 09/20/2005 0820 Condition

Description:

Water flowing from overhead in Operations area of Admin Building second floor.

While working on the morning of 09/17/05 water was observed flowing from the overhead in the Operations area of the admin building second floor.

Immediate Action

Description:

The control room was contacted and requested to check the third floor "I&C Restroom" for an overflow condition. Soon thereafter the water flow stopped.

Suggested Action

Description:

Fix leaks in the "I&C Restroom" or secure the rest room or install more reliabIe flushing mechanisms.

TRENDING (For Reference Purposes Only):

Trend Tvpe Trend Code WK MAMS EU MAMS REPORT WEIGHT 4

ADMIN 1 CR-VTY-2005-02710 Initiated Date: 9/20/2005 8:20 Owner Group :Maint Support Mgmt Current

Contact:

RMF Current Significance: C - CORRECT ONLY Closed by: Felumb,Rhonda 9/22/2005 15 :38 Summary

Description:

Water flowing from overhead in Operations area of Admin Building second ffoor.

While working on the morning of 09/17/05 water was observed flowing from the overhead in the Operations area of the admin building second floor.

Remarks

Description:

Closure

Description:

CR CLOSURE REVIEW COMPLETED - CONDITION CORRECTED

Entefgy ASSIGNMENTS CR-VTY-2005-0271O Version: 2 Significance Code: C - CORRECT ONLY Classification Code: C Owner Group: Maint Support Mgmt Performed By: Felumb,Rhonda 0912 112005 1053 Assignment

Description:

Screening Data Significance: C - CORRECT ONLY Owner :' Maint Support Mgmt Comments:

Description:

Report Weight Self- Revealing (4)

" Problem Codes WK, EU

" Work Group Codes

" Keywords Repeat event - Over flow has ocurred on several occasions. This result in wqater dripping on to electrical euipment including lighting panels.

Entergy CORRECTIVE ACTION CR-VTY-2005-02710 CA Number: 1 Assigned By: CRG/CARB/OSRC Assigned To: Maint Support Mgmt Subassigned To : Maint Support Staff Tietze,Brian J Originated By: Felumb,Rhonda 912 112005 1 O m 2 1 Performed By: Todd,Jon T 9/22/2005 13:40:43 Subperformed By: Tietze,Brian J 9/22/2005 13:33:55 Approved By:

Closed By: Felumb,Rhonda 9/22/2005 15:36:25 Current Due Date: 10/20/2005 Initial Due Date: 10/20/2005 CA Type: ACTION Plant Constraint: 0 NONE CA

Description:

C - CORRECT ONLY (Review CR for full details)

The CRG has initially classified this CR as Classification Code - "C"

Significance Code - CORRECT ONLY Per the CRG, Correct the condition identified in the CR. CNCR closure statements are expected to confirm this action has been completed.

I Review CRG Comments on the Assignment Tab I All Attachments are to be in PDF format

Response

Item is closed.

CR and CA has been reviewed per EN-LI- 102 Section 5.9 [ I ] and it is appropriate to close the CR.

Subresponse :

The flush valves were replaced with Auto-matic valves and this type has proven more reliable than the manual flush valves as proven in the 2nd Floor Admin Bldg. men's bathroom for similar problems.

Closure Comments:

Closure review complete

Entergy 1 CONDITION REPORT CR-VTY-2002-01913 Originator: Lawrence,Bruce E OriginatorPhone: 8022585354 Originator Group: Operations Mgr\ Mgmt Operability Required: Y Reportability Required: N Supervisor Name:

Discovered Date: 09/03/2002 09:OO Initiated Date: 09/03/2002 0O:OO Condition

Description:

Flow indicator stopped operating during rod surveillance During weekly Operable Control Rod Check OP 4 1 1 1, flow on FI 3-305 (CRD DRIVE WATER FLOW) stopped indicating.

A check of the local indications showed that the local indicator FI 3-214 also was not responding. Stabilizing valve flow is responding correctly, and rod motion is correct.

Surveillance was stopped until this problem was resolved.

Immediate Action

Description:

INITIATED W O W 0 : Complete : 02-54872 NOTIFIED SHIFT SUPERVISOR : Complete : Shift Supervisor notified Suggested Action

Description:

EQUIPMENT:

Tap Name Tap: Suffix Name Comaonent Code Process System Code FI-3-305 CRD TRENDING (For Reference Purposes Only):

Trend Tyae Trend Code HOW IDENTIFIED HI-SELF-IDENTIFIED KEY ACTIVITY KA-UN PERSONNEL INJURY PI-NON-INJURY WORK PROCESS WP-PO CAUSAL FACTOR CODES CFC-R I C4 Attachments:

Closure Description FLOW INDICATOR STOPPED OPERATING DURING ROD SURVEILLANCE

Entergy ADMIN CR-VTY-2002-01913 Initiated Date: 9/3/2002 0:OO Owner Group :Maint Support Mgmt Current

Contact:

Current Significance: C Closed by: Caron,Mikey 9/5/2002 X:22

~~~ ~

Summary

Description:

Flow indicator stopped operating during rod surveillance Remarks

Description:

The ER 2002 I9 13 was migrated from the VY Niagara application on 10/30/2003 to generate this CR.

Closure

Description:

Attachment Header Document Name:

Document Location Attach

Title:

VERMONT YANKEE Event Level (Circle One) ER NO.ER- 20021913 (complete at screening meeting)

EVENT REPORT

~~

1 2 3 PART 1: IDENTIFICATION OF EVENT (Originator) Will in all known data)

~ ~~ ~

A) Initiated By (Pnnt) BRUCE LAWREWE Date 09/03/2002 Phone # 8022585354 Department OPERATIOW B) EvenVDiscovery (Date) 09/03/2002 Occurred (Time) 9:OO AM Equip No(s). Fl-3-305 System(s) affected CRD c ) Event

Title:

Flow indicator stopped operating during rod surveillance D) Reference Document (WO, Procedure, Calculation, Drawing, AuditlSurveillance No., etc.

E ) Event Descrintion (Describe the event and susoected cause. if known) How Identified: - Self-Revealing During weekly Operable Control Rod Check OP 41 11, flow on FI 3-305 (CRD DRIVE WATER FLOW) stopped indicating. A check of the -

x Self-Identified local indications showed that the local indicator FI 3-214 also w a s not responding. Stabilizing valve flow is responding correctly, and rod motion is correct.

- By Others

- QAD

- External Surveillance w a s stopped until this problem was resolved.

F) Immediate Action Taken - Recommendations. if any. W W O No. Nonconformance Tags Installed? L N O -YES (if segregation required)

INITIATED\VORA\O 02-54872 SOTlFlED SHIFT SUPERVISOR Shift Supervisor notified PART 2: REVIEW OF EVENT (Department Head)

A) Deuartment Head Review

1. SS Review Required (operability conceddegraded equipment AP 0156, K O , TS)?-NO L Y E S (deliver to SS)

2. Security-Related Event? -

xNO - YES (immediately notify S S S i S S )

3. Personnel Injury/Accident? -

XNO - YES (FAX ER to Treasury/Risk Mgr. for Accident Type (Discuss with Safety Coord.) W Personnel)

4. Recommended Event Level 3

5. Nuclear Network entry required? -

XNO -Y E S

6. Recommended Responsible Department? MART- I & C B) If depraded or nonconformine. SSCs will remain ooerable then record and attach Ooerabilitv Basis/ Justification. Refer to AP 0167.

F l y 4 troubleshooting identified a blown fuse In the indication circuit. The fuse nas replaced by FIN4 andindication was restored.

C) Additional Comments/Actions Taken:

Department Head Signature/Date JBXWE CANTRELL 09/03/2002 PART 3: REPORTABILITY AND OPERABILITY (SS/SE)

A) Event reportable per AP 0156? L N o t Reportable -Reportable Attach copy of VYAPF 0156.01 if reportable or if additional notifications required.

B) Per AP 0167 degraded or nonconforming SSCs will remain operable? X Y / A -NO -YES C) Documentation for Operability Determination attached? -x N/A -YES If YES: -Formattached (VYAPF 0167.01) and/or

- Evaluation attached or included in ER Shift SupervisorDatemime LONNIE CANTRELL 1 09/03/2002 i 2:06 PM VYAPF-0009.01 (Satilplc)

A P 0009 Rcr. I3 Pagc 1012

PART 4: EVENT SCREENING MEETING ER NO.ER- 20021913 A) Additional Initial Notifications and Reviews Required? X N O -YES B) BMO Required? E N 0 -YES (Processing Time -Resp. Dept. BMO # 1 C) Reportable? X N O -YES - Further Evaluation Required (Assigned To 1 D) Potential 10CFR50.65 Maintenance Rule Functional Failure? -

X N O -YES E) Potenfial Reactivity Management Event? -XNO -YES F) NRC Significance Determination Process? -x N O -YES G ) NRC Performance Indicator? -X N O -YES H) StartupNode Restraint?XNO -YES Spccific Action Rcquircd: Rcsp. Dcpt.: Modc Affcctcd:

I) Human Perfonnance Related? -X NO -YES If YES -Consequential -Nan-consequential J) Event Level Determined 3 K) Responsibility for ER Investigation and Recommending Corrective Action Assigned to (Dept.): M A I W - SUPPORT L) Additional Considerations Additional Reviewers: -Training See .Attdched Page

-Maint. Rule Coordinator

-Reactor Engineer

-Fire Protection Engineer

-Radiation Protection

-Safety Coordinator M) Completed by/Date JIM TAYLOR 1 09/04/2002 -Other: Specify PART 5: EVENT INVESTIGATION (Assigned Department)

~ ~ ~~~~~~~ ~ ~ ~~~ ~ ~ ~ ~~

A) Investigation Type: (RCA rcquired for Lcvcl I ; Optional for Lcvcl2) B) Investigation Results:

- RCA -ACE xMPC (DH check one) 1. Attach report for Level 1 and 2 ERs (see PP 7017 for details.)

C) MRFF: -

XNO -YES 2. Note Most Probable Cause Codes (Lcvcl3 ERs) See Attached Page D) Event Reportable: L N O -YES (LER No. ) 3. Startuphlode Restraint: - Resolved Approved:

E) Estimated hours to perform investigation 4. Adverse Trend -X NO -YES F) Actions Taken (Level 3 ER Disposition): 5. NRC PI color change xN0 -YES See .Attached Page Investigator (if other than Dept. Head) DAVID PHILLIPS / 09/04/2002 DH Review DAVID PHILLIPS I 09/04/2002 PART 6: REVIEWS A) Additional Reviews:

B) I I QAD (Level I ) Design Eng. (Design Deficiency, "Use-As-Is" dispositions)

Comments:

PART 7: APPROVALS (Forward to the TSM after final aooroval)

A) DAVID PHILLIPS I 09/04/2002 I I Department Head (Level I,2,3 ERs) Supt/Dir designee (Level I & 2 ERs) PORC (Level 1 ERs)

B) I I Plant Mgr (Level 1 E&, Some Level 2s) Dir. Of Operations (Level 1 ERs)

PART 8: CANCELLATlON/CLOSEOUT A) Repair/rework complete I Nonconformance Tags removed 1 B) ER Cancelled By (SuptiDirldesignnee: I Basis/Cancellation Comments:

C) Technical Support (ER Database Updated, Copies Distributed, Coinmitrnents Initiated)

ERCiDate Mikeg Caran I 09/05/2002 VYAPF-0009 01 AP 0009 RC\, 13 r a p 2 or2

Attached Page for Event Report ER-20021913 PART 1 Affected Eauiament Affected Svstems Reference Documents Event Descriation Immediate Action Taken PART 2 Additional Comments / Owrabilitv Justification DH Actions Taken PART 4 Swcific Action Required Additional Reviewers SDecified Additional Considerations Presented on 9/4/02 by Bill Pittman.

PART 5 Causal Factors Rlc4 Unknown could not determine cause due to spurious Corrective Actions Action Description Status Department DueDate CTS CTS Number Tracked INITIATED W O W 0 Repair performed under Done MAINT - I & C N WO 02-03863-00 PART 6 Additional Reviews Reviewer Comments PART 7 Amrover Comments PART 8 Basis I Cancellation Comments ReponPmledon 0905RO02a18251\M

OPERABILITY 1 CR-VTY-2002-01913 OperabilityVersion: I Operability Code: NIAGARA CONVERSION Immediate Report Code: NIAGARA CONVERSION Performed By: Cantrel1,Lonnie J 09/03/2002 I4:06 Approved By: Cantrel1,Lonnie J 09/03/2002 14:06 Operability

Description:

Niagara indicators set during Shift Supervisor Review.

Event Reportable Per AP 0 I56 :: No Per AP 0 I67 Degraded or Non conforming SSC's will remain operable :: N/A Operability Determination Attached (See Admin Tab for attachment) :: N/A Pre-screening Comments / Operability Justification:

FIN-I troubleshooting identified a blown fuse in the indication circuit. The fuse was replaced by FIN-I and indication was restored.

DH Review Performed By: CANTFELL,LONNIE on 09/03/2002 Approval Comments:

I .

Entefgy ASSIGNMENTS CR-VTY-2002-01913 Version: 1 Significance Code: C Classification Code: C Owner Group: Maint Support Mgmt Performed By: Taylor,James M 09/04/2002 09:34 Assignment

Description:

Pre-screening Comments / Operability Justification:

FIN-I troubleshooting identified a blown fuse in the indication circuit. The fuse was replaced by FIN-I and indication was restored.

DH Review Performed By: CANTFELL,LONNE on 09/03/2002 Screening Comments:

Presented on 9/4/02 by Bill Pittman.

Niagara indicators set at screening.

How Identified :: Self-Identified

Entffgy CORRECTIVE ACTION CR-VTY-2002-01913 CA Number: 1 Assigned By: CRG/CARB/OSRC Taylor,James M Assigned To: Maint Support Mgmt Subassigned To : Maint Support Staff Originated By: Taylor,James M 9/4/2002 09:34:00 Performed By: Phillips,David L 9/4/2002 15:59:00 Subperformed By: Phillips,David L 9/4/2002 15:59:00 Approved By:

Closed By: Phillips,David L 9/4/2002 16:OO:OO Current Due Date: 1 1/02/2002 Initial Due Date: I 1/02/2002 CA Type: CR DISPOSITION Plant Constraint: NONE CA

Description:

This CA for Disposition was generated during Niagara to PCRS Conversion Screening Comments:

Presented on 9/4/02 by Bill Pittman.

Investigate Type :: Most Probable Cause

Response

CA for Disposition Reviews:

Maint - Support Sup't : PHILLIPS,DAVID : 09/04/2002 3 5 9 5 6 PM :

Approvals:

Maint - Support Sup't : PHILLIPS,DAVID : 09/04/2002 4:OO: 16 PM :

Subresponse :

Niagara indicators set during investigation.

Cause Codes ::

Rlc4 - Unknown could not determine cause due to spurious Corrective Actions identified during Investigation:

Action : Description : Done : Department : Due Date : CTS Number : CTS Tracked INITIATED W O W 0 : Repair performed under WO 02-03863-00 : Done : MAINT - I & C : : : N Closure Comments:

This CA for Disposition was generated from ER Investigation information from the VY Niagara application on 10/30/2003

CONDITION REPORT CR-VTY-2002-02518 Originator: Jonasch,Stephen F Originator Phone: 80245 13056 Originator Group: Eng SYS System Eng Mgmt Operability Required: Y Reportability Required: N Supervisor Name:

Discovered Date: 10/19/2002 00:3O Initiated Date: 1 O/ 1 8/2002 0O:OO Condition

Description:

Water in RHR Pump Mechanical Seal Flow Indicators Water has been observed in FIS- 10-124A and HS- I 0- 124C, RHR Pump Mechanical Seal Leak-off Line Flow Rate Indicators. This may be indicative of a weeping mechanical seal. The flow rate indicators will alarm at the control room (Alarms 3-J-5 and 3-N-5) when they reach the setpoint of 0.5 gpm. These alarms have not annunciated. While water was observed to be present, i.e. the sight glass was full, there appeared to be no water flowing into the sump, where the leak off is piped to.

Immediate Action

Description:

Suggested Action

Description:

NOTIFIED SHIFT SUPERVISOR : Complete EQUIPMENT:

Tag Name Tag Suffix Name Component Code Process System Code RHR REFERENCE ITEMS:

Tvpe Code Description WR 02-055549 & 055550 TRENDING (For Reference Purposes Only):

Trend Tvpe Trend Code PERSONNEL INJURY PI-NON-INJURY WORK PROCESS WP-su HOW IDENTIFIED HI-EXTERNAL CAUSE DEPT CD-SYSTEM ENGINEERING CAUSAL FACTOR CODES CFC-P2D4 CAUSAL FACTOR CODES CFC-P2E4 KEYWORDS KW-PIPE LEAK (E.G., SW)

Attachments:

Closure Description OD WATER IN RHR PUMP MECHANICAL SEAL FLOW INDICATORS

-I

I I I Entergy I ADMIN CR-VTY-2002-02518 1

Initiated Date: I O/ I8/2002 0:OO Owner Group :Eng SYS System Eng Mgmt Current

Contact:

Current Significance: C Closed by: Taylor,James M 11/21/2002 11:36 Summary

Description:

Water in RHR Pump Mechanical Seal Flow Indicators Remarks

Description:

The ER 200225 18 was migrated from the VY Niagara application on 10/30/2003 to generate this CR.

Closure

Description:

Attachment Header Document Name:

Document Location plosure Description Attach

Title:

OPERABILITY DETERMINATION SYSTEM: -

RHR

. COMPONENT: P-lO-IA&1C DATE: 10/19/2002 E VENT REPORT ER 2002-2518 NUMBER: 43

-TITLE: Water in RHR Pump Mechanical Seal Flow Indicators ~

COMPONENT/SYSTEMIS OPERABLE Yes DESCRIPTION OF NON-CONFORMING OR DEGRADED CONDITION(S)

Water has been observed in FIS-I0-124A and FIS-IO-l24C, RHR Pump Mechanical Seal Leak-off Line Flow Rate Indicators. This may be indicative of a weeping mechanical seal. The flow rate indicators will alarm at the control room (Alarms 3-J-5 and 3-N-5)when they reach the setpoint of 0.5 gpm. These alarms have not annunciated. While water a observed to be present, i.e. the sight glass was full, there appeared to be no water flowing into the sump, where the

. I q. k off is piped to.

DfSCUSSiON Water has been observed in FIS-10-124A and FIS-lO-l24C, RHR Pump Mechanical Seal Leak-off Line Flow Rate Inaicators while the RHR pumps were running. This may be indicative of a weeping mechanical seal. The flow meters art3 Fischer-Porter instruments consisting of a threaded cast bronze body piped into the mechanical seal leak off line.

Attached is a glass sight glass with a relay alarm transmitter on top.

1-The flow rate indicators will alarm at the control room (Alarms 3-J-5 and 3-N-5) when they reach the setpoint of 0.5 gpm. These alarms have not annunciated. This indicates that the mechanical seal weepage is minor. Currently the C RHR pump is running. While water was observed in the sight glass, there appeared to be no water dripping into the RHR Corner room sump where the drain piping is directed. An observation of the sump through a small hatch could cl6arly observe the end of the drain pipe. This could indicate that either the weepage is so minor that it does not fill enough of the piping to drain into the sump (estimated to be 20' or the pipe may have some blockages or dams in it that impeeds the water, or a combination of the both. At the time of t h e observance, the pump had been running for approximately 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . It has been noted that in the past, the water from the sight glass does eventually drain.

8 1-System Engineering considers that the mechanical seal is weeping and has not failed. This is based upon the fact that nowater has been observed in the shaft areas of the pump. Had the mechanical seals failed, the dp of the pump; 200 pSd; would have upset the orings and rotating seal faces in the mechanical seal and forced water up the shaft since the flow indicator drainage piping is being restricted.

Based UPOR the above discussion, System Engineering considers that the mechanical seal weepage is minor, that the line to the sump is damming the water and there is insufficient leakage to flow into the sump. Both conditions will be Fnvestigatedvia the ER process. Work Order requests have been generated to inspect the flow indicators and rod out t h 3 piping. System Engineering considers that the RHR pumps are OPERABLE.

POTENTIAL ADVERSE EFFECTS

~ -,

The potential of the leak off piping to the sump being clogged wou[d result in a backup of water into the flow indicator as is'currently being experienced. This would have no impact to the safety related functions of the RHR pumps. They would still continue to provide their safety related function, to operate in the LPCl mode, in the event of an accident.

AtNtionally, they would still operate in the shut down cooling mode, as evidenced by the currently operating C RHR pump-

.>,+

Page 1 of 2

~ _ _ . ..........

,T@emechanical seal may be weeping as evidenced by the water in the sight glasses. The weep wouId have no impact to.the abittiy of the RHR pump to perform its safety related functions.

S A F FUNG~ONS

~ Losr No safety functions have been lost. The RHR pumps continue to be OPERABLE and will perform all the required safety functions.

supPoin sscs FOR SAFETY FUNCT~ONSiosr There would be no loss of support SSC for Safety Functions as no support SSCs are involved in this issue.

MiTIGATiNG FACTORS None COMPENSATORY ACTIONS None R~FERENCE

. I P@D G-191172 Fischer-Porter Specification Manual for Variable Area Flowmeters Series 1OA2235 GWD 1299 Alarm Response Sheets 3-J-5and 3-N-5

.)

c, .

I

, I,

.~

Page 2 of 2

Attachment Header Document Name:

Document Location Attach

Title:

VERMONT YANKEE Event Level (Circle One) ER NO.ER- 20022518 (complete at screening meeting)

EVENT REPORT 1 2 3 PART 1: IDENTIFICATION OF EVENT (Originator) (Fill in all known data)

A) Initiated By (Print) Stephen Junarch Date 10/18/2002 Phone # 8024513056 Department SYSTEM ENGINEERING B) EvenUDiscovery [Date) IO/I~/~OOZ Occurred (Time) 1 2 9 0 AM Equip No(s). System[s) affected RHR c ) Event

Title:

Water in RHR Pump Mechanical Seal Flua Indicators D) Reference Document (WO, Procedure, Calculation, Drawing, AudiUSurveillance No., etc. See Attached Page E) Event Descriotion (Describe the event and suspected cause. if known) How Identified: - Self-Revealing Water has been observed in FIS-10-124A and FIS-10-124C, R H R Pump Mechanical Seal Leak-off Line Flow Rate Indicaton. This may be - Self-Identified indicative of a weeping mechanical seal. The flow rate indicaton will alarm a t the control room (Alarms 3-.I-5 and 3-N-5) when they reach the setpoint of 0.5 gpm. These alarms have not annunciated. While water was observed to be present, i.e. the sight glass was full, there

- By Others appeared to be no water flowing into the sump, where the leak oNis piped to.

- QAD X External F) Immediate Action Taken - Recommendations. if any. W W O No. Nonconformance Tags Installed? I N 0 -YES (if segregation required)

P A R T 2: R E V I E W OF E V E N T (Department Head)

A) Department Head Review I. SS Review Required (operability conceddegraded equipment AP 0156, K O , TS)?-NO A Y E S (deliver to SS)

2. Security-Related Event? -XNO - YES (immediately notify SSS/SS)

3. Personnel Injury/Accident? -XNO - YES (FAX ER to TreasuryiRisk Mgr. for Accident Type [Discuss with Safety Coord.) W Personnel)

4. Recommended Event Level 3

5. Nuclear Network entry required? -XNO -YES

6. Recommended Responsible Department? SYSTEM ENGINEERING B) If demaded or nonconforming SSC's will remain operable then record and attach Ouerabilitv Basis/ Justification. Refer to AP 0167.

See attached OD.

C) Additional Comments/Actions Taken:

NOTIFIED SHIFT SUPERVISOR Department Head SignatureDate RICHARD RUSlN / 10/19/2002 P A R T 3: R E P O R T A B I L I T Y AND O P E R A B I L I T Y (SS/SE)

~~~~~ ~~

A) Event reportable per AP 0156? L N o t Reportable -Reportable Attach copy of W A P F 0156.01 if reportable or if additional notifications required.

B) Per AP 0167 degraded or nonconforming SSCs will remain operable? -N/A -NO XYES C) Documentation for Operability Determination attached? -N/A xYES If YES: -Form attached (VYAPF 0167.01) and/or

-X Evaluation attached or included in ER Shift Supervisor/Date/Time ROBERT FAUPEL I 10/19/2002 I 1:41 PM VYAPF-0009.0 I (Samplc)

AP0009 Rcv.13 Pagc I o f ?

PART 4: EVENT SCREENING MEETING ER NO.ER- 20022518 A) Additional Initial Notifications and Reviews Required? L N O -YES B) BMO Required?XNO -YES (Processing Time -Resp. Dept. BMO # )

C) Reportable? XNO -YES - Further Evaluation Required (Assigned To j D) Potential 10CFR50.65 Maintenance Rule Functional Failure? -

X N O -YES E) Potential Reactivity Management Event? - X N O -YES F) NRC Significance Determination Process? X N O -YES G) NRC Performance Indicator? -X N O -YES H) Startup/Mode Restraint?LNO -YES Spccific Action Requimd Rcsp. Dcpt.: Modc Affcctcd:

1) Huinan Perfonnance Related? - x NO -YES If YES -Consequential -Nan-consequential J) Event Level Determined 3 Kj Responsibility for ER Investigation and Recommending Corrective Action Assigned to (Dept.): SYSTEM ENCINEERINC L) Additional Considerations Additional Reviewers: -Training Presented on 10/19/02 by JRD & CJW

-Maint. Rule Coordinator

-Reactor Engineer

-Fire Protection Engineer

-Radiation Protection

-Safety Coordinator M) Completed by/Date PAT LQCW I 10/1912002 -Other: Specify PART 5: EVENT INVESTIGATION (Assigned Department)

~~ ~ ~~~ ~ ~ ~ ~~~ ~ ~ ~~ ~

A) Investigation Type: (RCA requimd for Lcvcl I ; Optional for k v c l 2 ) B) Investiption Results:

-RCA -ACE Z M P C (DH check one) I. Attach report for Level I and 2 ERs (see PP 701 7 for details.)

C) MRFF: - XNO -YES 2. Note Most Probable Cause Codes ( k v c l 3 ERs) See Attached Page D) Event Reportable: L N O -YES (LER No. ) 3. StartupMode Restraint: - Resolved Approved:

E) Estimated hours to perform investigation 2 4. Adverse Trend -X NO -YES F) Actions Taken (Level 3 ER Disposition): 5 . NRC PI color change L N O -YES See Attached Page Investigator (if other than Dept. Head) Stephen Jonasch / 11/18/2002 DH Review JOE BOIVIN I 11/18/2002 PART 6: REVlEWS A) Additional Reviews:

B) I i QAD (Level 1) Design Eng. (Design Deficiency, "Use-As-Is" dispositions)

Comments:

PART 7: APPROVALS (Forward to the TSM after final approval)

A) JOE BOlVlV I 11/18/2002 I I Department Head ( k v e l 1,2,3 ERs) Supt/Dir designee (Level I & 2 ERs) PORC (Level I ERs)

Bj I I Plant Mgr (Level 1 ERs, Some Level 2s) Dir. O f Operations (Level 1 ERs)

PART 8: CAXCELLATIONKLOSEOUT A) Repair/rework complete i Nonconformance Tags removed 1 B) ER Cancelled By (Supt/Dir/desipee: t BasisKancellation Comments:

C) Technical Support (ER Database Updated, Copies Distributed, Commitments Initiated)

ERCiDate JIM TAYLOR I 11/21/2002 VYAPF-0009.01 AP 0009 Rcb I 3 rabCz RsponPnnled on llnlR002 a1 11.40AM

Attached Page for Event Report ER-20022518 PART 1 Affected EauiRment Affected Svstems Reference Documents 02-055549 a 055550 Work Requests Event Description Immediate Action Taken PART 2 DH Actions Taken PART 4 Specific Action Reauired Additional Reviewers Seecfied Additional Considerations PART 5 Causal Factors P2d4 lnacurate indication.

P2e4 Insufficient monitoring of component.

Corrective Actions Action Description Status Department DueDate CTS CTS Number Tracked INITIATED wowo wos 02-4747; 4748; Done SYSTEM ENGINEERING N 5014and 5015 to cleanlinvestigate PART 6 Additional Reviews Reviewer Comments PART 7 Amrover Comments PART 8 Basis I Cancellation Comments

Entergy 1 OPERABILITY I CR-VTY-2002-02518 OperabilityVersion: I Operability Code: NIAGARA CONVERSION Immediate Report Code: NIAGARA CONVERSION Performed By: Faupe1,Robert F I O/ 1912002 13:4 1 Approved By: FaupeLRobert F 10/19/2002 1 3:4 I Operability

Description:

Niagara indicators set during Shift Supervisor Review.

Event Reportable Per AF'Ol56 :: No Per AP 0 167 Degraded or Non conforming SSC's will remain operable :: Yes Operability Determination Attached (See Admin Tab for attachment) :: Engineering Evaluation Pre-screening Comments / Operability Justification:

See attached OD.

DH Review Performed By: RUSINJUCHARD on I0/19/2002 Approval Comments:

Entergy I ASSIGNMENTS 1 CR-VTY-2002-02518 Version: 1 Significance Code: C Classification Code: C Owner Group: Eng SYS System Eng Mgmt Performed By: Logue,Patricia L 10/19/2002 17:04 Assignment

Description:

Pre-screening Comments / Operability Justification:

See attached OD.

DH Review Performed By: RUSIN,FUCHARD on 10/19/2002 Screening Comments:

Presented on 10/ 19/02 by JRD & CJW Niagara indicators set at screening.

How Identified :: External

I I I Entergy CORRECTIVE ACTION CR-VTY-2002-02518 CA Number: 1 Assigned By: CRGICARBIOSRC Logue,Patricia L Assigned To: Eng SYS System Eng Mgmt Subassigned To : Eng SYS System Eng Staff Originated By: Logue,Patricia L 10/19/2002 17:04:0C Performed By: Boivin,Joseph J 1 1/ I 8/2002 16:44:0C Subperformed By: JonaschStephen F 11/18/2002 15:30:0C Approved By:

Closed By: Boivin,Joseph J 11/18/2002 16:44:OC Current Due Date: 12/18/2002 Initial Due Date: 12/ 18/2002 CA Type: CR DISPOSITION Plant Constraint: NONE CA

Description:

This CA for Disposition was generated during Niagara to PCRS Conversion Screening Comments:

Presented on 10/19/02 by JRD & CJW Investigate Type :: Most Probable Cause

Response

CA for Disposition Reviews:

System Engineering : BOIVIN,JOE : 11/18/20024:44:07 PM :

Approvals:

System Engineering : BONIN,JOE : 1 1/18/20024:44:24 PM :

Subresponse :

Niagara indicators set during investigation.

Cause Codes ::

P2d4 - Inacurate indication.

P2e4 - Insufficient monitoring of component.

Corrective Actions identified during Investigation:

Action : Description : Done : Department : Due Date : CTS Number : CTS Tracked INITIATED W O W 0 : WOs 02-4747; 4748; 5014 and 5015 to deadinvestigate : Done : SYSTEM ENGINEERING : : :

N Closure Comments:

This CA for Disposition was generated from ER Investigation information from the VY Niagara application on 10/30/2003.

Attachments:

Subresp Description INVESTIGATION REPORT

Attachment Header Document Name:

Document Location Attach

Title:

INVESTIGATION REPORT

Page 3 of4 ER 2002-25 I8 EVENT REPORT ER #2002-2518 LEVEL 3 EVENT DESCRIPTION (copied fiom ER)

Water has been observed in FIS-10-124A and FIS-10-124C7 RHR Pump Mechanical Seal Leak-off Line Flow Rate Indicators. This may be indicative of a weeping mechanical seal. The flow rate indicators will alarm at the control room (Alarms 3-5-5 and 3-N-5) when they reach the setpoint of 0.5 gpm. These alarms have not annunciated. While water was observed to be present, i.e. the sight glass was fill, there appeared to be no water flowing into the sump, where the leak off is piped to.

EVENT EVALUATION The purpose of the flow indicators is to determine mechanical seal failure fiom the RHR pump. A flow rate of 0.5 gpm will activate the alarm setpoint and indicate this failure.

This setpoint has not been achieved. Additionally, no water was observed going to the sump from the drain line. It is not unusual for mechanical seals to weep and this would not constitute mechanical seal failure. The exact amount of weepage is unknown at this time and it is complicated by the fact that the sight glass on the flow indicator is very dirty. Work orders were initiated (see Corrective Actions for list) and are scheduled for the corresponding RHR LCOs for each pump, to clean the sight glass and to rod out the piping. Retest of the RHR pumps will assist in determining the extent of the weepage.

MOST PROBABLE CAUSE The most probable cause of the water in the flow indicator is that there is a minor weep past the mechanical seals. The amount of weepage is not certain however it appears to be a minor weep as no water flow was observed out of the drain line. The amount of weepage will be better determined after the sight glass and piping is cleaned per the work orders initiated to hither investigate this issue. Retest of the RHR pumps will determine the extent of the weepage.

FOLLOWUP VERIFICATION Not required

Page 4 of 4 ER 2002-25 18 MAINTENANCE RULE FUNCTIONAL FAILURE (MRFF) DETERMINATION The above condition was evaluated to not be a Maintenance Rule Functional Failure. No functions were lost. The RHR system would have operated if required and performed its safety functions.

CORRECTIVE ACTIONS System Engineering has initiated work orders (listed below) and scheduled them for their appropriate RHR LCO date. Any hrther actions will be determined at that time. There are no fbrther actions to be taken at this point in time.

A RHR pump - WO 02-004747 scheduled 4/28/03 B RHR pump - WO 02-005015 scheduled 1/20/03 C RHR pump - WO 02-004748 scheduled 4/28/03 D RHR pump - WO 02-005014 scheduled 1/20/03

Entergy I CONDITION REPORT CR-VTY-2003-00992

~~~

Originator: Wisniewski,Andrew T Originator Phone: 8022585427 Originator Group: Operations Mgr\ Mgmt Operability Required: Y Reportability Required: N Supervisor Name:

Discovered Date: 0 9 0 112003 23:2 1 Initiated Date: 05/02/2003 0O:OO Condition

Description:

RHRSW Pump A Cooling Water Flow Indicator Reading Downscale Operators started to perform the post LCO Maintenance surveillance on RHRSW Pump A per OP 4124 when they noticed that the cooling water flow indicator did not move. The AOs ascertained that there was flow to the pump. The A 0 was directed by the Control Room to attempt to increase flow to move the slug off its seat. This was unsuccesful and the pump was shut down. An Emergency Work Order was generated and I&C cleaned the indicator. The surveillance was then performed successfully although cooling flow had to be adjusted due to the previous adjustment of the valve.

Immediate Action

Description:

INITIATED WOIUWO : Complete : WO # 03-2675 NOTIFIED SHDFT SUPERVISOR : Complete : Shift Supervisor notified Suggested Action

Description:

EQUIPMENT:

Tag Name Tag Suffix Name Component Code Process System Code FI- 104-70A RHRS TRENDING (For Reference Purposes Only):

Trend Tvoe Trend Code KEY ACTIVITY KA-TM HOW IDENTIFIED HI-SELF-REVEALING PERSONNEL INJURY PI-NON-INJURY WORK PROCESS WP-PO KEYWORDS KW-TRACK AND TREND Attachments:

Closure Description RHRSW PUMP A COOLING WATER FLOW INDICATOR READING DOWNSC

Entergy 1 ADMIN CR-VTY-2003-00992 I

Initiated Date: 5/2/2003 0:OO Owner Group :Tech CA&A HU Mgmt Current

Contact:

Current Significance: C Closed by: Houle,Mona M 5/29/2003 I6:20 Summary

Description:

RHRSW Pump A Cooling Water Flow Indicator Reading Downscale Remarks

Description:

The ER 20030992 was migrated from the VY Niagara application on 10/30/2003to generate this CR.

Closure

Description:

Attachment Header Document Name:

Document Location fclosure Description Attach

Title:

VERMONT YANKEE Event Level (Circle One) ER NO.ER- 20030992 (complete at screening meeting) 1 EVENT REPORT 1 2 3 PART I : IDENTIFICATION OF EVENT (Originator)(Fill in all known data)

A) Initiated By (Print) ANDREW WISNIEWSKI Date 05/oz/z003 Phone # 802258~427 Department OPERATIONS B) EvenUDiscovery (Date) 05/01/2003 Occurred (Time) 11:zl PM Equip No(s). FI-104-70.4 System(s) affected RHRSW c ) Event

Title:

RHRSW Pump A Cooling Water Flow Indicator Reading Downscale D) Reference Document (WO, Procedure, Calculation, Drawing, AudiUSurveillance No., etc.

E) Event Descnation (Describe the event and susoected cause. if known) How Identified: X Self-Revealing Operators started to perform the post LCO Maintenance surveillance on RHRSW Pump A per OP 4124 when they noticed that the cooling - Self-Identified water flow indicator did not move. The AO's ascertained that there was flow to the pump. The A 0 was directed by the Control Room to

- By Others attempt to increase now to move the slug off its seat. This was unsuccesful and the pump was shut down. An Emergency Work Order was generated and I&C cleaned the indicator. The surveillance was then performed successfully although cooling flow had to be adjusted due

- QAD to the previous adjustment of the valve. - External F) Immediate Action Taken - Recommendations. if anv. WWWO No. Nonconformance Tags Installed? L N O -YES (if segregation required)

INITIATEDWORAVO WO # 03-2675 YOTIFIED SHIIT SUPERVISOR Shift Supervisor notified PART 2: REVIEW OF EVENT (Department Head)

A) Department Head Review I. SS Review Required (operability conceddegraded equipment AP 0156, LCO, TS)?-NO L Y E S (deliver to SS)

2. Security-Related Event? -XNO - YES (immediately notify SSSWS)

3. Personnel Injury/Accident? -XNO - YES (FAX ER to TreasuryiRisk Mgr. for Accident Type (Discuss with Safety Coord.) VY Personnel) j/ 4.

5.

Recommended Event Level Nuclear Network entry required?

3

-XNO -YES I 6. Recommended Responsible Department? MAlNT - SUPPORT B) If deeraded or nonconforming SSC's will remain oaerable then record and attach Oaerabilitv Basis/ Justification. Refer to AP 0167.

C) Additional ConirnentslActions Taken:

Department Head Signatureoate WILLIAM PITTMAN JR J 05/05/2003 PART 3: REPORTABILITY AND OPERABILITY (SSISE)

A) Event reportable per AP 0156? X N o t Reportable -Reportable Attach copy of VYAPF 0156.01 if reportable or if additional notifications required.

B) Per AP 0167 degraded or nonconforming SSCs will remain operable? XN/A -NO -YES C) Documentation for Operability Determination attached? -x N/A -YES IfYES: -Form attached (VYAPF 0167.01) and/or

- Evaluation attached or included in ER Shifi Supervisor/Date/Time MICHAEL HARRIS / 05/05/2003 / 7:09AM VYAPF-0009.01 (Sarnplc)

AP 0009 Rci I?

Pagc I 012 Repon P n n M on 0512912003 al4.26 PM

PART 4: EVENT SCREENING MEETING ER NO. ER- 20030992 A) Additional [nitial Notifications and Reviews Required? LNO -YES B) BMO Required?LNO -YES (Processing Time -Resp. Dept. BMO # )

C) Reportable? XNO -YES -Further Evaluation Required (Assigned To 1 D) Potential 1 OCFR50.65 Maintenance Rule Functional Failure? -x N O -YES E) Potential Reactivity Management Event? -x N O -YES F) NRC Significance Determination Process? XNO -YES G) NRC Performance Indicator? -xNO -YES H) Startup/Mode Restraint?xNO -YES Spccific Action Rcquircd: Rcsp. Dcpt.: Modc Affcctcd:

I) Human Performance Related? -x NO -YES If YES -Consequential -Nan-consequential I) Event Level Determined 3 K) Responsibility for ER Investigation and Recommending Correcfive Action Assigned to (Dept.): TECHNICAL SUPPORT L) Additional Considerations Additional Reviewers: -Training See Attached Page

-Maint. Rule Coordinator

-Reactor Engineer

-Fire Protection Engineer

-Radiation Protection

-Safety Coordinator M) Completed byiDate JIM TAYLOR I 05/05/2003 -Other: Specify PART 5: EVENT INVESTIGATION (Assigned Department)

A) Investigation Type: (RCA rcquircd for Lcvcl 1; Optional for Lcvcl 2) B) Investigation Results:

- RCA -ACE rMPC (DH check one) 1 , Attach report for Level 1 and 2 ERs (see PP 7017 for details.)

C) MRFF: -

xNO -YES 2. Note Most Probable Cause Codes (Lcvcl3 ERs)

D) Event Reportable: &NO -YES (LER No. 1 3. StartupMode Restraint: - Resolved Approved:

E) Estimated hours to perform investigation 0.2 4. Adverse Trend -X NO -YES F) Actions Taken (Level 3 ER Disposition): 5. NRC PI color change L N O -YES See Attached Page Investigator (if other than Dept. Head) ROY RAMSDELL 1 05/29/2003 DH Review ROY RAMSDELL I 05/29/2003 PART 6: REVIEWS A) Additional Reviews:

B) I I QAD (Level I ) Design Eng. (Design Deficiency. "Use-As-1s" dispositions)

Comments:

See Attached Page PART 7: APPROVALS (Forward to the TSM after final approval)

A) ROY RAMSDELL I 05/29/2003 I I Department Head (Level I ,2,3 ERs) Supt/Dir designee (Level 1 & 2 ERs) PORC (Level 1 ERs)

B) I I See Attached Page lor Comments Plant M g (Level I ERs, Some Level 2s) Dir. Of Operations (Level 1 ERs)

PART 8 CANCELLATIONICLOSEOUT A) Repairkwork complete I Nonconformance Tags removed I B) ER Cancelled By (SupUDiddesignee: I BasisiCancellation Comments:

C) Technical Support (ER Database Updated, Copies Distributed, Commitments Initiated)

ERCiDate MONA HOULE / 05/29/2003 VYAPF-0009.0 I AP 0009 Rcv.14 P ~ 2 0~ r 2C Rewrl Pnnled on 0512912003a14 26 PM

Attached Page for Event Report ER-20030992 PART 1 Affected EauiDment Affected Svstems Reference Documents Event Description Immediate Action Taken PART 2 Additional Comments I Oaerabilitv Justification DH Actions Taken PART 4 Specific Action Reauired Additional Reviewers Specified Additional Considerations Presented on 5/5/03 by WMP. JMT Repairs completed FYI Jonasch PART 5 Causal Factors Corrective Actions Action Description Status Department DueDate CTS CTS Number Tracked NONE Track 8 Trend ER. Done OPERATIONS N PART 6 Additional Reviews Reviewer Comments ROY RAMSDELL (Technical Support Track h Trend ER.

SUP't)

PART 7 Amrover Comments ROY RAMSDELL (Technical Support Track & Trend ER.

Sup't)

PART 8 Basis I Cancellation Comments Uoporl Pnnted on 0512912003a14 26 PM

OPERABILITY I CR-VTY-2003-00992 OperabilityVersion: I Operability Code: NIAGARA CONVERSION Immediate Report Code: NIAGARA CONVERSION Performed By: Harris,Michael D 05/05/2003 07:09 Approved By: Harris,Michael D 05/05/2003 07:09 OperabiIity

Description:

Niagara indicators set during Shift Supervisor Review.

Event Reportable Per AP 01 56 :: No Per AP 0 I67 Degraded or Non conforming SSC's will remain operable :: N/A Operability Determination Attached (See Admin Tab for attachment) :: N/A Approval Comments:

Entergy ASSIGNMENTS CR-VTY-2003-00992 Significance Code: C ClassificationCode: C Owner Group: Tech CA&A HU Mgmt Performed By: Taylor,James M 05/05/2003 08:19 Assignment

Description:

DH Review Performed By: PITTMAN JR.,WILLIAM on 05/05/2003 Screening Comments:

Presented on 5/5/03 by WMP. JMT Repairs completed FYI Jonasch Niagara indicators set at screening.

How Identified :: Self-Revealing

CORRECTIVE ACTION I CR-VTY-2003-00992 CA Number: 1 Assigned By: CRG/CAREVOSRC Taylor,James M Assigned To: Tech CA&A HU Mgmt Subassigned To : Tech CA&A HU Staff Originated By: Taylor,James M 5/5/2003 08: 19:OO Performed By: Ramsdel1,Roy A 5/29/2003 15:20:00 Subperformed By: Ramsdel1,Roy A 5/29/2003 15: 19:OO Approved By:

Closed By: Ramsdel1,Roy A 5/29/2003 15:20:00 Current Due Date: 05/3 1/2003 Initial Due Date: 05/3 1/2003 CA Type: CR DISPOSITION Plant Constraint: NONE CA

Description:

This CA for Disposition was generated during Niagara to PCRS Conversion Screening Comments:

Presented on 5/5/03 by WMP. JMT Repairs completed FYI Jonasch Investigate Type :: Most Probable Cause

Response

CA for Disposition Reviews:

Technical Support Sup't : RAMSDELL,ROY : 05/29/2003 3:20: 3 PM : Track & Trend ER.

Approvals:

Technical Support Sup't : RAMSDELL,ROY : 05/29/2003 3:20:52 PM : Track & Trend ER.

Subresponse :

Corrective Actions identified during Investigation:

Action : Description : Done : Department : Due Date : CTS Number : CTS Tracked NONE : Track & Trend ER. : Done : OPERATIONS : : : N Closure Comments:

This CA for Disposition was generated from ER Investigation information from the VY Niagara application on 10/30/2003.

Enf- CORRECTIVE ACTION CR-VTY-2001-02066 CA Number: 3 Assigned By: CRG/CARB/OSRC Goodwin,Scott D Assigned To: Eng DE Mech Civil Struct Mgmt Subassigned To : Eng DE Mech Civil Struct Staff Originated By: Goodwin,Scott D IO/ I0/200 1 oo:oO:oc Performed By: Goodwin,Scott D I 1/29/2001 0O:OO:OC Subperformed By: Goodwin,Scott D 1 I /29/200 1 0O:OO:OC Approved By:

Closed By: Goodwin,Scott D 11/29/2001 O0:OO:OC Current Due Date: I2/04/200 I Initial Due Date: 12/04/2001 CA Type: CR DISPOSITION Plant Constraint: NONE CA

Description:

This CA for Disposition was generated during Niagara to PCRS Conversion Investigate Type :: Most Probable Cause

Response

CA for Disposition Reviews:

Mechanical - Civil/Str Eng Supervisor : GOODWIN,SCOTT : I 1/29/2001 12:OO:OO AM :

Approvals:

Mechanical - Civil/Str Eng Supervisor : GOODWIN,SCOTT : 1 1/29/2001 12:OO:OO AM :

Subresponse :

Niagara indicators set during investigation.

Cause Codes ::

P2j4 - Component aging.

Corrective Actions identified during Investigation:

Action : Description : Done : Department : Due Date : CTS Number : CTS Tracked Initiate 0028 Commitment : Complete a CCN (or Revision) to the VYC- 1005 RI Crack Growth calculation to include the effect of the new t4emperature transients and develop revised operating cyclic limits that include these transients. (Refer to this ER) : Open : MECHANICAL - CIVIL/STRUCTURAL ENG. : 04/01/2002 : 2783 1 : Y Initiate 0028 Commitment : Following the above-listed 0028 to MecWStructural, issue 0028 to Operations to revise these procedures. Discussed with Mitch McCluskie. (Refer to this ER) : Open : OPERATIONS : 07/01/2002 : 27832 : Y Closure Comments:

This CA for Disposition was generated from ER Investigation information from the VY Niagara application on 10/30/2003.

Entwgy I CONDITION REPORT CR-VTY-2001-02066 1

~~~~~ ~ ~ ~

Originator: Betti,Enrico J Originator Phone: 508865 1679 Originator Group: Eng DE Mech Civil Struct Mgmt Operability Required: Y Reportability Required: N Supervisor Name:

Discovered Date: 10/05/200I 0 1 :29 Initiated Date: 10/05/2001 0O:OO Condition

Description:

Degrading Trend in RPV Feedwater Thermal Sleeve Bypass Leakage on the N4C Nozzle In my review of the Feedwater Leak Detection thermocouple data (OP-4172), I have noted over the last 18 months additional temperature changes on the lower thermocouples on the N4C feedwater nozzles. Prior to this time temperature changes on this nozzle have followed startup conditions when cold feedwater flow causes the thermal seal to relax. Over the last 18 months we have seen additional changes at fulI power that are not related to SU/SD cycling.

These changes were not associated with power reductions or startup/shutdown transients and represent additional thermal cycling not considered in the current revision of crack growth calculation. There were 3 of these additional temperature transient last cycle and 2 so far this cycle. While these temperature changes are less severe than the ordoff flow events, these additional cycles are not considered in the current feedwater nozzle crack growth assessment (VYC-1005 Rev I). Therefore these changes need to be tracked and the crack growth calculation needs to updated to provide operating limits.

The current VYC- 1005 calculation demonstrated that Crack Growth would be maintained within acceptable limits if there are no UT indications and the next UT exam is conducted within 25 SU/SD cycles plus 50 on/off flow cycles (the current AP-0 145 limit).

If it is conservatively assumed that we have 3 of these new temperature changes each SU/SD cycle, my calculations (draft CCN- I to VYC- 1 105 R1) indicate the AP-0145 cyclic limits would change to 22 SU/SD cycles plus 44 on/off flow cycles plus 66 leakage pattern flow changes (not associated with a SU/SD events). Therefore while not a substantial impact on our current limits, the impact is not negligible and a process for recording these temperature transients needs to be put in place.

For Preliminary Recommendation and Oberability Assessment see attached Attached Electronic Document.

Immediate Action

Description:

Suggested Action

Description:

EQUIPMENT:

Tap Name Tag Suffix Name Component Code Process System Code N4C NB REFERENCE ITEMS:

Type Code Description PROCEDURE OP-4 172.02 TRENDING (For Reference arposes Only):

Trend Type Trend Code HOW IDENTIFIED HI-SELF-IDENTIFIED KEY ACTIVITY KA-MO PERSONNEL INJURY PI-NON-INJURY WORK PROCESS WP-PM CAUSAL FACTOR CODES CFC-P254

Entwgy CONDITION REPORT CR-VTY-2001-02066 I Closure Description ER F W TEMP ELECT DOC.DOC DEGRADING TREND IN RPV FEEDWATER THERMAL SLEEVE BYPASS LE)

ALL

Erztergy I ADMIN CR-VTY-2001-02066 Initiated Date: 10/5/2001 0:OO Owner Group :Eng DE Mech Civil Struct Mgmt Current

Contact:

Current Significance: C Closed by: Caron,Mikey 12/4/2001 0:OO Summary

Description:

Degrading Trend in RPV Feedwater Thermal Sleeve Bypass Leakage on the N4C Nozzle Remarks

Description:

The ER 20012066 was migrated from the VY Niagara application on 10/30/2003 to generate this CR.

Closure

Description:

Attachment Header Document Name:

Document Location Attach

Title:

Degrading Trend in RPV Feedwater Thermal Sleeve Bypass Leakage on the N4C Nozzle Description In my review of the Feedwater Leak Detection thermocouple data (AP-4172), I have noted over the last 18 months additional temperature changes on the lower thermocouples on the N4C feedwater nozzles. Prior to this time temperature changes on this nozzle have followed startup conditions when cold feedwater flow causes the thermal seal to relax. Over the last 18 months we have seen additional changes at full power that are not related to SUED cycling.

These changes were not associated with power reductions or startuplshutdowntransients and represent additional thermal cycling not considered in the current revision of crack growth calculation. There were 3 of these additional temperature transient last cycle and 2 so far this cycle, While these temperature changes are less severe than the onloff flow events, these additional cycles are not considered in the current feedwater nozzle crack growth assessment (WC-1005 Rev 1). Therefore these changes need to be tracked and the crack growth calculation needs to updated to provide operating limits.

The current VYC-1005 calculation demonstratedthat Crack Growth would be maintainedwithin acceptable limits if there are no UT indications and the next UT exam is conducted within 25 SUED cycles plus 50 onloff flow cycles (the current AP-0145 limit).

If it is conservatively assumed that we have 3 of these new temperature changes each SUED cycle, my calculations (draft CCN-1 to VYC-1105 RI) indicate the AP-0145 cyclic limits would change to 22 SUlSD cycles plus 44 onloff flow cycles plus 66 leakage pattern flow changes (not associated with a SUlSD events). Therefore while not a substantial impact on our current limits, the impact is not negligible and a process for recording these temperature transients needs to be put in place.

Preliminary Recommendation

1. Complete a CCN (or Revision) to the WC-1005 R1 Crack Growth calculation to include the effect of the new temperature transients and develop revised operating cyclic limits that include these transients.

2. Revise the cycle tracking procedure (AP-0145) limits to include temperature transients not associatedwith SU/SD or ON/OF flow changes.

3. Revise OP-4172.02 feedwater procedure to specify that temperature transient events are to be identified based on review of thermocouple data and provided to Operationsfor recording in the AP-0145 procedure.

4. It is recommendedthat to facilitate tracking, that we consider adding TC signals to ERFIS.

(This was recently done for the other RPV skin temperature TC on TR-3-89.) This would provide better assurance that we capture pertinent fatigue data.

Operabilitv Assessment UT inspections during the 2001 outage found no recordable indications. Given the low number of transient cycles since the last outage, the impact of the observed variations on projected N4C would have been negligible, and there is significant margin to ASME XI allowable crack growth limits. Therefore there is no immediate operability or safety issue.

No of Observed & Estimated Cycles Draft Limit sukd cycle 1 22 onloff flow events 2(estimated) 44

temperature change events 2 66 There is no requirement for reporting this issue to he NRC under our current licensing commitment (BVY 01-02).

What we need to do over the next few months is complete the calculation update and institute the procedure changes. This will assure that the next UT exams is performed well before potential crack growth would reach ASME XI limits.

Attachment Header Document Name:

Document Location plosure Description Attach

Title:

1) VERMONT YANKEE Event Level (Circle One) ER NO.ER- 20012066 I (complete at screening meeting) 1 EVENT REPORT I 2 i'3j PART 1: IDENTIFICATION OF EVENT (Originator) (Fill in all known data)

A) Initiated By (Print) ENRICO BETTI Date 10/05/2001 Phone ?4 5088651679 Department MECHANICAL-CIVIUSTRUCTURAL ENC.

B) EventiDiscovery (Date) io/o5/2001 Occurred (Time) 129 A M Equip No(s). N4C System(s) affected NB c) Event

Title:

Degrading Trend in RPV Feedwater Thermal Sleeve Bypass Ledkage un the N4C Nozzle D) Reference Document (WO, Procedure, Calculation, Drawing, AudiUSurveillance No., etc. see Attached page E) Event DescriDtion (Describe the event and suspected cause. if known) How Identified - Self-Revealing In my rcvicw of the Fccdwatcr Leak Detection thermocouple data (OP-4172), I h a w notcd over the last 18 months additional tcmpcraturc -

X Self-Identified changcs on thc lower thcrmocouplcs on the N4C feedwater nozzles. Prior to this time tcmpcraturc changcs on this nozzle havc followed startup conditions when cold fccdwatcr flow causes the thermal seal to rclax. Over the last 18 months we havc seen additional changcs at

- By Others full power that arc not rclated to SU/SD cycling. - QAD

- External These

- - Continued on Attachcd Page F) Immediate Action Taken - Recommendations. if any. W W O No. Nonconfonnance Tags Installed? L N O -YES (if segregation required)

P A R T 2: R E V I E W OF E V E N T (DepartmentHead)

A) Deoartment Head Review

1. SS Review Required (operability concem/degraded equipment AP 0156, LCO, TS)?-NO X Y E S (deliver to SS)

2. Security-Related Event? - XNO - YES (immediately notify SSS/SS)

3. Personnel Injury/Accident? . -X N O - YES (FAX ER to Treasury/Risk Mgr. for Accident Type (Discuss with Safety Coord.) VY Personnel)

4. Recommended Event Level 3

5. Nuclear Network entry required? - XNO -YES

6. Recommended Responsible Department? WECHANIC.AL.CrVluSTRucTuRAL E X B) If degraded or nonconfonnine SSC's will remain ooerable then record and attach ODerability Basis/ Justification. Refer to AP 0167.

Bnsed un the assessment enclused, there are nu operability issues associated with this event. Initial evaluation. includingconsideratiun u fthe cited low temp.

cyclisg, indicated significant margins to defined limits accounting ***Continued un Attached Page C) Additional Comments/Actions Taken:

Department Head SignatureiDate SCOTT GOODWIN I 10/09/2001 P A R T 3: R E P O R T A B I L I T Y AND OPERABILITY (SS/SE)

A) Event reportable per AP 0156? Z N o t Reportable -Reportable Attach copy of VYAPF 0156.01 if reportable or if additional notifications required.

B) Per AP 0167 degraded or nonconfonning SSCs will remain operable? LN/A -NO -YES C) Documentation for Operability Determination attached? -NIA LYES IfYES: XFom attached (VYAPF 0167,01)and/or

-X Evaluation attached or included in ER Shift SupervisoriDateiTiine WAYNE KING / 10/09/2001 I l2:OOAM VYAPF-OOD9.Ol (Snnrplc)

AP0009 Rcv.12 Pagc I 0 1 2 Repon Pnnled on 1210412001 a1 l l : 3 2 A M

~~~~ ~

I PART 4: EVENT SCREENING MEETING ER NO.ER- 20012066 A) Additional Initial Notifications and Reviews Required? X N O -YES B) BMO Required?XNO -YES (Processing Time -Resp. Dept. BMO # 1 C) Reportable? LNO -YES -Further Evaluation Required (Assigned TO 1 D) Potential I OCFR50.65 Maintenance Rule Functional Failure? -

XNO -YES E) Potential Reactivity Management Event? -X N O -YES F) NRC Significance Determination Process? -XNO -YES G ) NRC Perfonnance Indicator? -XNO -YES H) StartupA4ode Restraint?XNO -YES Spccific Action Rcquircd: Resp. Dcpt.: Modc Affcctcd:

I) Human Performance Related? -x NO -YES If YES -Consequential -Nan-consequential J) Event Level Detennined 3 K) Responsibility for ER Investigation and Recommending Corrective Action Assigned to (Dept.):MECHANICAL- CIVIUSTRUCTUR~L EXG L) Additional Considerations Additional Reviewers: -Training

-Maint. Rule Coordinator

-Reactor Engineer

-Fire Protection Engineer

-Radiation Protection

-Safety Coordinator M) Completed by/Date SCOTT GOODWIN I 10/10/2001 -Other: Specify PART 5: EVENT INVESTIGATION (Assigned Department)

A) Investigation Type: (RCA rcquircd for Lcvcl 1; Optional for Lcvcl 2) B) Investigation Results:

-RCA -ACE xMPC (DH check one) I . Attach report for Level 1 and 2 ERs (see PP 7017 for details.)

C) MRFF -xNO -YES 2. Note Most Probable Cause Codes (Lcvcl3 ERs) See Attached P w e D) Event Reportable: X N O -YES (LER No. ) 3. Startup/Mode Restraint: - Resolved Approved:

E) Estimated hours to perform investigation 3 4. Adverse Trend -X NO -YES F) Actions Taken (Level 3 ER Disposition): 5. NRC PI color change X N O -YES See Attached Page Investigator (if other than Dept. Head) SCOP GOODWIN 1 11129/zoo1 DH Review SCOTTGOODWN i 11/29/2001 PART 6: REVIEWS A) Additional Reviews:

B) i SCOTT GOODWIN I 11/29/2001 QAD (Level 1) Design Eng. (Design Deficiency, "Use-As-Is dispositions)

Comments:

PART 7: APPROVALS (Forward to the TSM after final approval)

A) SCOlT GOODWIN 1 11/29/2001 I I Department Head (Level 1,2,3 ERs) Supt/Dir designee (Level I & 2 ERs) PORC (Level I ERs)

B) i I Plant Mgr (Level I ERs, Some Level 2s) Dir. Of Operations (Level I ERs)

PART 8: CANCELLATION/CLOSEOUT A) Repaidrework complete I Nonconformance Tags removed /

B) ER Cancelled By (Supt/Dir/designee) I Basis/Cancellation Comments:

C) Technical Support (ER Database Updated, Copies Distributed, Commitments Initiated)

ERCiDate llikey Caron 1 12/04/2001 VYAPF-0009.0 I AP 0009 R e \ . 12 Page 2 o r 2 Re~onPnnledon 1210412001 at 11 32AM

Attached Page for Event Report ER-20012066 PART 1 Affected Eauiement Affected Svstems Reference Documents OP-4172.02 Procedure (W)

Event Descrietion

- - Continued From Page 1 changes were not associated with power reductions or startuphhutdown transients and represent additional thermal cycling not considered in the current revision of crack growth calculation. There were 3 of these additional temperature transient last cycle and 2 so far this cycle. While these temperature changes are less severe than the onloff flow events, these additional cycles are not considered in the current feedwater nozzle crack growth assessment (VYC-1005 Rev I). Therefore these changes need to be tracked and the crack growth calculation needs to updated to provide operating limits.

The current VYC-I005 calculation demonstrated that Crack Growth would be maintained within acceptable limits if there are no UT indications and the next UT exam is conducted within 25 SUED cycles plus 50 onloff flow cycles (the current AP-0145 limit).

If it is conservatively assumed that we have 3 of these new temperature changes each SUlSD cycle, my calculations (draft CCN.

1to VYC-1105 R I )

indicate the AP-0145 cyclic limits would change to 22 SUlSD cycles plus 44 onloff flow cycles plus 66 leakage pattern flow changes (not associated with a SUED events). Therefore while not a substantial impact on our current limits, the impact is not negligible and a process for recording these temperature transients needs to be put in place.

For Preliminary Recommendation and Oberability Assessment see attached Attached Electronic Document.

Immediate Action Taken PART 2 Additional Comments I Operabilitv Justification

- - Continued From Page I for conservative number of low temp cycles assumed.

DH Actions Taken PART 4 Seecific Action R e w i r e d Additional Reviewers Specified Additional Considerations PART 5 Causal Factors P2j4 Component aging.

Corrective Actions Action Description Status Department DueDate CTS CTS Number Tracked

Attached Page for Event Report ER-20012066 Initiate 0028 Complete a CCN (or MECHANICAL - 04/01/02 27831 Y Commitment Revision) to the W C - CIVIUSTRUCTURAL 1005 R I Crack Growth ENG.

calculation to include the effect of the new t4emperature transients and develop revised operating cyclic limits that include these transients. (Refer to this ER)

Initiate 0028 Following the above- OPERATIONS 07/01/02 27832 Y Commitment listed 0028 to MechlStructural, issue 0028 to Operations to revise these procedures. Discussed with Mitch McCluskie.

(Refer to this ER)

PART 6 Additional Reviews Reviewer Comments PART 7 Approver Comments PART 8 Basis / Cancellation Comments Rewrl Pnnled an 1210412001a1 11:32 AM

. - -~

~

VERMONT YANKEE Event Level (Circle One) ER NO.ER- 20012066 (complete at screening mEting)

EVENT REPORT PART 1: IDENTIFICATION OF EVENT (Originator) (Fill in all known data)

A) Initiated By (Print) ENIUCO ~ x T n Date io/s/01 Phone # M188651679 -

Deparlment MECllAXlC.4L WIUSTRUCTUR4LENG.

3) EventlDiscovery (Date) io/5/01 Occurred (Time) I:ZVAM Equip No@). NJC System(+ aEfected NR c) Event

Title:

Dqndinc Trend in KPV ~~rInrter'FbcmelSIccvc B y p ~ s ~ L c n k a gurn c tlwN4CNoek D) Reference Document (WO, Procedure, Calculation, Drawing, AuditISurveillance No., etc.): o ~ 4 m . o ~

E) Event Description (Describe the event and s u s m t e d cause. if J? own How Identified: - Self-Revealing Io my review of the Fccdwnhr Leak Detectioo thermocouple dam &'4172), I llave noted over the last 18 months additional temperature chnnges on U a lorvcr therruocouples on iheN4C feedwater ncmles. Prior lo this h'nie tempcrature c b m g m on this n o d e have followed startup X

. Self-Identified By Others conditions w l ~ e ncold feedwater flow ~ilusest l ~ etherind seal Lo relax. Over the 1st I 8 months we have sten additional chop s t h l l power

- Qm that are not related Co SUDD cycling.Ti1ese changes were not associated with power reductions or smrtuphhuldown trmsicnt?. and represent additional thermal cycliug not comldered in the current revision of crack growth calculation. Tliere were 3 of tlicrr additionat temperatme

-- External traasicnt last cycle and 2 so far thia cycle. While these temperature ch3'nges we less sewre than the on/offflow events, these additional cycla are notconsMered In tbc current feedwater n d e crackgrowth assessrncrit(WC-I005 Rev 1).Therefore tlicw changes need to be tracked and the crack growth calculation

- - - - Event Dcscriptian Continucd on Attachment *****

F) Immediate Action Taken - Recomrnendatioms~an& WWWO No. Nonconformance Tags Installed? SNO -YES (if segregation required)

~~ ~

PART 2: REVIEW OF EVENT (Department Head)

A) Department Head Review

1. SS Review Required (operability conceddegraded equipment AP 0156, LCO,TS)? -NO &ES (deliver to SS)

2. Security-Related Event? -

A* -

YES (immediately notify SSS/SS)

3. Personnel Injury/Accident? -//NO YES (FAX ER to TreasuryRisk Mgr. for Accident Type (Discuss with Safety Coord.) W Personnel)

4. Recommended Event Level 3

5. Nuclear Network entry required? d o -YES 6 . Recommended Responsible Depamnent? &,E wq t

8) ~ ili Ba i /Ju ifi '0 . eferto 01 7.

See Allrchnimll A) Event reportable per AP 0156? &ot Reportable -Reportable Attach copy of WAPF 0156.01 if reportable or if additional notifications required.

B) Per AP 0167 degraded or nonconforming SSCs will remain operable? &N/A -NO -YES '

C) Documentation for Operability Determination attached? -N/A P E S 1fYES: Form attached (VYAPFOI67.01)andor valuation attached or included in ER Shift Supervisor/Date/Tim I &U/??{ /

opo VYAPF-0009 01 (Sample)

,' 6 I.< '

.4P 0009 Rev. 12 Page 1 of 2 RspmRMdcn lag101 . I1227 PM

PART 4: EVENT SCREENING MEETJNG ER NO.ER- 2W12OG6 A) Additional Initial No *ficationsand Reviews Required? - -YES B) BMO Required? L O -YES (Processing Time Resp. Dept. BMO # 1 C) Reportable? LNO - YES - Further Evaluation Required (Assigned To 1 D) Potential 10CFR50.65 Maintenance Rule Functional Failure? d N O -YES E) Potential Reactivity Management Event? -JNO -YES F) NRC Significance Determination Process? A 0 -YES G) NRC Performance Indicator? P O H) Startup/Mode Restraint? JNO -YES Specific Action Required: Resp. Lkpt: Mode Affected:

I) Human Performance Related? I/NO -YES If YES -Consequential -Nan-consequential J) Event Level Determined 3 K) Responsibility for ER Investigation andRecommending Corrective Action Assigned to (Dept.): AK M/s L) Additional Considerations Additional Reviewers: -Training

-Maint. Rule Coordinator

-Reactor Engineer

-Fire Protection Engineer I Radiation Protection

-Safety Coordinator M) Completed bymate -Other:Specify PART 5: EVENTINVESTIGATION (Assigned Department)

A) InvestigationType: (RCA quired for Level I; OptionaI for Level 2) B) Investigation Results:

A RCA - ACE LM PC @Hcheckone) 1. Attach report for Level 1 and 2 ERs (see PP 7017 for details.)

C) MRFF: 4 I

0 -YES 2. Note Most Probable Cause Codes (Level 3 E&)

D) Event Reportable: JNO -YES (LER No. 1 3. StartupMode Restraint: Resolved Approved:

E) Estimated hours to perform investigation 3 4. Adverse Trend -dN0 -YES E) Actions Taken (Level 3 ER Disposition): 5. NRC PI color change L N O -YES H &ab 477 Investigator (ifother than Dept. Head)

PART6: REVIEWS s

- m f /I 1 DH Review: J //. m o&

A) Additional Reviews: 7B-- MXC d ! = h B) I I

. QAD (Level 1) Design Eng. (Design Deficiency, Use-As-Jsdispositions)

Comments:

PART 7: APPROVALS (Forward to the TSM after f i a l approval)

A) .- I Department Head (Level 1,2,3 ERs) j\*ZPc5/ nll cz /

Supt/Dir designee (Level 1 & 2 ERs) fd j f i PORC (Leva 1 E-)

I w Plant ~ g (Level r

hljfl I 1 kk,Some Level 2s)

MI8 Dir. Of Operatfons (Level 1 ERs) f Basjs/CanceIlahon Comments:

,Copies Distributed, Commitments Initiated)

Attachment Header Document Name:

Document Location 1Closure Description Attach

Title:

DegradingTrend in RPV Feedwater Thermal Sleeve Bypass Leakage on the N4C Nozzle Determine What Happened:

MPC: Increasedthermal Cycling at the N4C feedwater RPV nozzle. This is most likely due to loosening of the thermal sleeve interferencefii due to minor corrosion in the carbon steel safe end at the inconel thermal sleeve interface.

MPC Cause Code: Component Aging P.2.j Corrective Actions:

To date the additional thermal cycle events have been relatively infrequent, 3 events last cycle and 2 events to date this cycle. The impact of the observed cycles on projected crack growth is very small and there is significant margin to ASME XI allowable crack growth limits. Therefore there is no immediate operability or safety issue. Physical modifications to the thermal sleeves would be a very major undertaking. Therefore physical modifications are not recommendedat this time. Engineering will continue to monitor the leak detection data for new transients.

While these temperature changes are less severe than the odoff flow events, these additional cycles are not considered in the current feedwater nozzle crack growth assessment (VYC-1005 Rev 1).Therefore these changes need to be tracked and the crack growth calculation needs to updated to provide operating limits.

The corrective actions inciuded in the ER include

1. Complete a CCN (or Revision) to the VYC-1005 R i Crack Growth calculation to include the effect of the new temperature transients and develop revised operating cyclic limits that include these transients. fpJ"[-20 66- @

2. Revise the cycle tracking procedure (AP-0145) limits to include temperature transients not associated with SU/SD or OWOF flow changes.

3. Revise OP-4172.02feedwater procedure to specify that temperature transient events are to be identified based on review of thermocouple data and provided to Operations for wording in the AP-0145 procedure.

This following 0028 has been issued to perform this work. -

To facilitate tracking the last item recommendedin this ER was to consider adding TC signals to ERFIS. (This was recently done for the other RPV skin temperature TC on TR-3-89.) This would provide better assurance that we capture pertinent fatigue data. The system engineer, Joe Boivin indicates he is all for this idea. Unfortunately a preliminary evaluation of the cost benefit for this change indicates little financial benefit.

It is estimating that obtaining a SMlRC request, design change, and implementationthis change would require approximately $75,000to fund design and implement this change. This change would eliminate manual collection and processing of the data. This collection and processing requires about 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months per year. Assuming $60 per hour for the staff-hour cost of VY operations and Engineering, 1Oyears to the end of license, this would translate to about $120,000 in savings for VY. A $45,000projected benefit. This is a relatively small projected benefit over 10 years. Given the lack of available engineering resources, it is recommendedwe not pursue this last recommendationat this time. n

Attachment ER-20012066, Part 5 9 Degrading Trend in RPV Feedwater Thermal Sleeve Bypass Leakage on the N4C Nozzle Determine What Happened:

MPC: Increasedthermal Cycling at the N4C feedwater RPV nozzle. This is most likely due to loosening of the thermal sleeve interference fit due to minor corrosion in the carbon steel safe end at the inconel thermal sleeve interface.

MPC Cause Code: Component Aging P.2.j Corrective Actions:

To date the additional thermal cycle events have been relativeiy infrequent, 3 events last cycle and 2 events to date this cycle. The impact of the observed cycles on projected crack growth is very small and there is signifkant margin to ASME XI aItowable crack growth limits. Therefore there is no immediate operability or safety issue. Physical modifications to the thermal sleeves would be a very major undertaking. Therefore physical modifications are not recommended at this time. Engineering will continue to monitor the leak detection data for new transients.

While these temperature changes are less severe than the onloff flow events, these additional cycles are not considered in the current feedwater nozzle crack growth assessment (VYC-1005 Rev 1). Therefore these changes need to be tracked and the crack growth calculation needs to updated to provide operating limits.

The corrective actions included in the ER include

1. Complete a CCN (or Revision} to the WC-1005 R1 Crack Growth calculation to include the effect of the new temperature transients and develop revised operating cyclic limits that include these transients.

2. Revise the cycle tracking procedure {AP-0145) limits to include temperature transients not associated with SU/SD or ON/OF flow changes.

3. Revise OP-4172.02 feedwater procedure to specify that temperature transient events are to be identified based on review of thermocouple data and provided to Operations for recording in the AP-0145 procedure.

&C.*el This following 0028 has been issued to perform this work.

To facilitate tracking the last item recommended in this ER was to consider adding TC signals to ERFIS. (This was recently done for the other RPV skin temperature TC on TR-3-89.) This would provide better assurance that we capture pertinent fatigue data. The system engineer, Joe Boivin indicates he is all for this idea. Unfortunatelya preliminary evaluation of the cost benefit for this change indicates little financial benefit.

It is estimating that obtaining a SMIRC request, design change, and implementation this change would require approximately $75,000 to fund design and implement this change. This change would eliminate manual collection and processing of the data. This cokction and processing requires about 200 hours0.00231 days 0.0556 hours 3.306878e-4 weeks 7.61e-5 months per year. Assuming $60 per hour for the staff-hour cost of VY operations and Engineering, 1Oyears to the end of license, this would translate to about $1 20,000 in savings for W. A $45,000 projected benefit. This is a relatively small projected benefit over 10 years. Given the tack of available engineering resources, it is recommended we not pursue this last recommendationat this time.

n

~. ~__.

M/S Desion Item E.J.Betti Due 4-1-02

Degrading Trend in RPV Feedwater Thermal Sleeve Bypass Leakage on the N4C Nozzle Description In my review of the Feedwater Leak Detection thermocouple data (OP-4172), I have noted over the last 18 months additional temperature changes on the lower thermocoupfeson the N4C feedwater nozzles. Prior to this time temperature changes on this nozzle have followed startup conditions when cold feedwater flow causes the thermal seal to relax. Over the last 7 8 months we have seen additional changes at full power that are not related to SU/SD cycling.

.These changes were not associated with power reductions or startup/shutdown transients and represent additional thermal cycling not considered in the current revision of crack growth calculation. There were 3 of these additional temperature transient last cycle and 2 so far this cycle. While these temperature changes are less severe than the onloff Row events, these additional cycles are not considered in the current feedwater nozzle crack growth assessment (VYC-I 005 Rev 1). Therefore these changes need to be tracked and the crack growth calculation needs to updated to provide operating limits.

The current VYC-1005 calculation demonstrated that Crack Growth would be maintained within acceptable limits, if there are no UT indications and the next UT exam is conducted within 25 SUED cycles plus 50 onloff flow cycles (the current AP-0145limit).

If it is conservatively assumed that we have 3 of these new temperature changes each SUlSD cycle, my calculations (draft CCN-1 to VYC-1105 R1) indicate the AP-0145 cyclic limits would change to 22 SUED cycles plus 44 onloff flow cycles plus 66 leakage pattern flow changes (not associated with a SUlSD events}. Therefore while not a substantial impact on our current limits, the impact is not negligibfe and a process for recording these temperature transients needs to be put in place.

Preliminary Recommendation

1. Complete a CCN (or Revision) to the WC-1005 R1 Crack Growth calculation to include the effect of the new temperature transients and develop revised operating cyclic limits that include these transients.

2. Revise the cycle tracking procedure (AP-0145) limits to indude temperature transients not associated with SU/SD or ON/OF flow changes.

3. Revise OP-4172.02 feedwater procedure to specify that temperature transient events are to be identified based on review of thermocouple data and provided to Operations for recording in the AP-0145procedure.

4. It is recommendedthat to facilitate tracking, that we consider adding TC signals to ERFIS.

(This was recently done for the other RPV skin temperature TC on TR-3-89.) This would provide better assurance that we capture pertinent fatigue data.

Operabilitv Assessment UT inspections during the 2001 outage found no recordable indications. Given the low number of transient cycles since the last outage a small amount of the available margin has been used to date (See the table below). The impact of these observed cycles on projected N4C is very small and there is significant margin to ASME XI allowable crack growth limits. Therefore there is no immediate operability or safety issue. Given the frequency of these transients to date it is possible that our current 4 cycle UT schedule can be maintained.

No of Observed & Estimated Cycles Draft Limit sulsd cycle 1 22 onloff flow events 2(estimated) 44 temperature change events 2 66 There is no requirement for reporting this issue to the NRC under our current licensing commitment (BVY 01-02).

Performing the calculation update and instituting procedure changes, will assure that the next UT exams is performed well before potential crack growth would reach ASME XI limits.

Entergy 1 OPERABILITY 1 CR-VTY-2001-02066 OperabilityVersion: I Operability Code: NIAGARA CONVERSION Immediate Report Code: NIAGARA CONVERSION Performed By: King,Wayne I0/09/200 1 0O:OO Approved By: King,Wayne 10/09/2001 0O:OO Operability

Description:

Niagara indicators set during Shift Supervisor Review.

Event Reportable Per AP 0 I56 :: No Per AP 0 167 Degraded or Non conforming SSC's will remain operable :: N/A Operability Determination Attached (See Admin Tab for attachment) :: Engineering Evaluation Pre-screening Comments / Operability Justification:

Based on the assessment enclosed, there are no operability issues associated with this event. Initial evaluation, including consideration of the cited low temp. cycling, indicated significant margins to defined limits accounting for conservative number of low temp cycles assumed.

DH Review Performed By: GOODWIN,SCOTT on 10/09/2001 Approval Comments:

Emtergy I ASSIGNMENTS I CR-VTY-2001-02066 Version: 1 Significance Code: C Classification Code: C Owner Group: Eng DE Mech Civil Struct Mgmt Performed By: Goodwin,Scott D 1 o/ I0/200 1 0o:oo Assignment

Description:

Re-screening Comments / Operability Justification:

Based on the assessment enclosed, there are no operability issues associated with this event. Initial evaluation, including consideration of the cited low temp. cycling, indicated significant margins to defined limits accounting for conservative number of low temp cycles assumed.

DH Review Performed By: GOODWIN,SCOTT on 10/09/2001 Niagara indicators set at screening.

How Identified :: Self-Identified

Enterw CORRECTIVE ACTION CR-VTY-2001-02066 I CANumber: 1 Assigned By: Tech CA&A HU Staff Burger,Frederick J 1 Assigned To: Eng DE Mech Civil Struct Mgmt Subassigned To : Eng DE Mech Civil Struct Staff Originated By: Burger,Frederick J 12/4/2001 15:20:00 Performed By: Goodwin,Scott D 1 1/20/2002 1456:OC Subperformed By: Betti,Enrico J 11/20/2002 14:41:oc Approved By:

Closed By: Logue,Patricia L I1/20/2002 15:35:0C I ~~~~~~~

Current Due Date: 1 1/11/2002 Initial Due Date: 04/01/2002 CAType: ERCA Plant Constraint: NONE CA

Description:

ER-200 1-2066-0 I Complete a CCN (or Revision) to the VYC- 1005 RI Crack Growth calculation Complete a CCN (or Revision) to the VYC-I005 R1 Crack Growth calculation to include the effect of the new temperature transients and develop revised operating cyclic limits that include these transients. (Refer to this ER)

Provide revised calculation summary [ and its 50.59) to Operations to facilitate procedure changes.

EXTENSIONS:

Due date revised IAW AP 0028 Section G. 1 .c per SDG Due date revised to 9/16/02 IAW AP 0028 Section G. 1.c per SDG Due date revised to 10/1/02 IAW AP 0028 Section G. 1.c per SDG Due date revised to 11/11/02 IAW AP 0028 Section G.1 .c per SDG Niagara indicators set at Initiation and DH Review:

Commitment Type :: B Source Type :: Corrective Action Source Detail :: Event Report Summary of Niagara Due Date Extensions:

On 04/03/2002 revision 1 changed the due date from 04/0 1/2002 to 07/ 15/2002.

On 07/18/2002 revision 2 changed the due date from 07/15/2002 to 09/16/2002.

On 09/ 1 8/2002 revision 3 changed the due date from 09/ I 6/2002 to IOIO 1/2002.

On 10/09/2002 revision 4 changed the due date from 10/0 I /2002 to 1 1/ I I /2002.

Response

Commitment ER-2001-2066-01 Niagara indicators set at DH Approval:

Item Complete :: Yes Subresponse :

VYC- 1005 R2 is complete. A PDF version of the Calc cover page, 50.59 Applicabilty Determination and Screen, and suggested Procedure Markup has been mailed to Karen Mego of Ops.

Response Attachments indicated in Niagara ::

VYC- I005 Rev 2 : Calculations

CORRECTIVE ACTION 1 CR-VTY-2001-02066 Closure Comments:

The Commitment ER-200 1-2066-0 1 was migrated from the VY Niagara application on 10/30/2003 to generate this CA.

Attachments:

Closure Description COMPLETE A CCN (OR REVISION) TO THE VYC- 1005 R1 CRACK GROWTH COPY OF CALC COVER SHEET

Attachment Header Document Name:

Document Location klosurel Description Attach

Title:

Action Item I Regulatory Commitment I Responsible Department: MECHANICAL - CIVIL/STRUCTURAL E Number: ER-2001-2066-01 Source Type: Corrective Action Regulatory Commitment Source Detail: Event Report NRC Violation Violation Level Initiated Date: 12/04/2001 Non-Cited Violation Resulted in a Fine

Title:

Complete a CCN (or Revision) to the VYC-1005 R1 Crack Growth calculation Instructions:

Complete a C C N (or Revision) to the VYC-I 005 RI Crack Growth calculation to include the effect of the new temperature transients and develop revised operating cyclic limits that include these transients. (Refer to this ER)

Provide revised calculation summary ( and its 50.59) to Operations to facilitate procedure changes.

EXTENSIONS:

Due date revised I A W

- - Continued on Attached Page DueDate:

Rev #:

r l I[

Affected Systems:

Affected Programs:

Affects the W Emergency Plan Impacts Plant Safety Item to be completed during outage:

NRC Presentation Required PORC Presentation Required Presented on:

Presented on: E Inspection Re port at PORC meeting # E3

RESPONSE

Assign to: ENRICO BETTI Response Comments:

VYC-1005 R2 is complete. A PDF version of the Calc cover page, 50.59 Applicabilty Determination and Screen, and suggested Procedure M a r k u p has been inailed to Karen M e g o o f Ops.

Response Attachments: S e e Attached Page Reviewed by: ENRICO BETTI Reviewed date: 11/20/2002 WAPF 0028.01 AP0028 Rev. 20

Page 2 DHAPPROVAL Number: ER-2001-2066-01 Additional Notifications:

i Copy Training Department Copy Vendor Quality Assurance Group (item involved vendor partslservices compliance)

Copy System Engineering item is applicable to W System Copy Maintenance Rule Coordinator (item applicable to W Maintenance Rule Program)

Add itionaI Copies:

~ ~~ ~

IX Item is complete, well documented, no further tracking required.

Additional commitment tracking Additional actions tracked by another process:

Approval Comments:

1 Approved by: SCOTT GOODWIN Reviewed date: 11/20/2002 SUPT APPROVAL Approval Comments:

I Approved by: Reviewed date:

OEC CLOSEOUT Trending Information Keywords:

UGenerated from Operating Experience CALCULATION I

Applicable to VY CRACK Corrective Action resolved the issue Training related 0 Maintenance Rule related Performance Evaluation related Performance Improvement Plan related Close out Comments:

Closed by: PAT LOGUE Date: 11/20/2002 VYAPF 0028.01 A P 0028 Rev. 20

Attached Page for Commitment Report ER-2001-2066-01 Instructions

- - Continued From Page 1 AP 0028 Section G. I .c per SDG Due date revised to 9/16/02 IAW AP 0028 Section G. I .c per SDG Due date revised to 1011102 IAW AP 0028 Section G. I .c per SDG Due date revised to 1 1/11/02 IAW AP 0028 Section G. I .c per SDG Affected Proarams Affected Svstems Response Comments Response Attachments VYC VY C- I005 Rev 2 Kevwords DH Approval Comments SUPT ApDroval Comments Closeout Comments Reoorl Printed on 11/20/2002 at 3:39 PM Attached Page 1

Attachment Header Document Name:

PR-VTY-2001-02066 CA-00001 Document Location Attach

Title:

This document contains Vermont Ya&x proprietaryinformatim. This infbrmation may not ba lransmittedin whole a in part, to final Turnova to Dcc (Section;?):

1) All open items, ifany, have been closed.

2) I m p I e ~ t i o nC o M m (Section 23.4)

@ ~ c ~ ~ . I ~a tci co dn y r e f l existing

~ plant configuration, fconsrmation method indicafadbelow)

Walkdown &-Built input miew Discussion with (hint Name)

OR MA, calculationdos not nflectexisting plant c o n f i ~ o n

3) Resolution of doaunents ident&ed in the Design Output Documents Section of VYAPF 0017.07has been initiated as required (Man 23.6,23.7) u?ulL3 sxe f4-;

printed Name DatC page I of 58pages*

For dculations p e r f o d using AP 00x7 this is the number of pages inthebody of the calculation. VYAPlF 0017.01 For vendor catculations, tbis is the number of pages ofAP 0017 form added AP 0017 Rcv. 8

('Tide page, review forms, data sheet& 50.59, etc.) Page 1 of 1 LPCm

Entergy CORRECTIVE ACTION CR-VTY-2001-02066 Assigned By: Tech CA&A HU Staff Burger,Frederick J Assigned To: Operations Mgr\ Mgmt Subassigned To : Operations Mgr\ Mgmt Originated By: Burger,Frederick J 12/4/200I 15:23:00 Performed By: McCluskie,Mitchell C 11/27/2002 12:34:OC hbperformed By: Mego,Karen L 1 1/27/2002 12: I8:OC Approved By:

Closed By: Logue,Patricia L 12/2/2002 08:03:00 Current Due Date: I2/06/2002 Initial Due Date: 07/01/2002 CAType: ERCA Plant Constraint: NONE CA

Description:

ER-200 1-2066-02 Revise OP 0 145 and OP 4 172 Revise OP 0145 and OP 4172 to reflect the revised calculation VYC-I005 (Refer to this ER) Changed commitment to Revise AP 0145, and Instrustions to "Revise AP 0145 to reflect the revised calculation VYC 1005.

CHANGE:

The Calc revision was approved 1 1/20/2002 and did not necitate changes to OP 4172. See attached approved Commitment Change Form 0028.04. Copy of LPC approved change sheet attached.

EXTENSIONS:

Please extend to 9/05/2002. This change will not be needed until post outage plus 3 to 6 months when cyclic data is again collected and reviewed for the previous cycle. Meets the criteria of G. I .c. Please extend to 12/06/2002 Niagara indicators set at Initiation and DH Review:

Commitment Type :: B Source Type :: Corrective Action Source Detail :: Event Report Summary of Niagara Due Date Extensions:

On 07/03/2002 revision 1 changed the due date from 07/01/2002 to 09/05/2002.

On 09/05/2002 revision 2 changed the due date from 09/05/2002 to 12/06/2002.

Response

Commitment ER-200 1-2066-02 Niagara indicators set at DH Approval:

Item Complete :: Yes Subresponse :

Change made by AF' 0145 Rev. 8 LPC 1, copy of RPO signed form attached.

Closure Comments:

The Commitment ER-2001-2066-02 was migrated from the VY Niagara application on 10/30/2003 to generate this CA.

Attachments:

Closure Description ER 200 1-2066-02 COMMITMENT CHANGE FORM

Entergy CORRECTIVE ACTION CR-VTY-2001-02066 Attachment Header Document Name:

FR-VTY-2001-02066 CA-00002 Document Location plosurel Description Attach

Title:

3

COMMITMENT CHANGE FORM Change Details:

Change title: to Revise AP 0145. Change the Instructions: to Revise AP 0145 to reflect revised calculation VYC-1005. (Refer to this ER.)

Justification:

Correct procedure is AP 0145, not OP 0145. No change needed to OP 4272, Feedwater System Surveillance. Form WOPF 4172.02 is completed every Friday morning with the data made availiable to Engineering f o r Analysis. There are no short term actions to be taken. AP 0145 has LPC to add reference to OP 4172 as the source of the Feedwater Leak Pattern'Changes and is supplied by Engineering. This is performed once per cycle, approximately 3 months after startup for the preceeding cycle. E. Betti concurrs with this change that no change to OP 4172 is needed. The cormnitment was initiated a year prior to WC-1005 rev 2 being approved and did not reflect changes made to

~

the draft procedure change to AP 0145.

Review/Approval:

Department Manager Superintendent PORC Plant Manager Sr. Management Repxesentative W A P F 0028.04 AP 0028 R e v . 2 0 Page 1 of 1

Attachment Header Document Name:

Document Location Attach

Title:

1 Action Item 1 Regulatory Commitment Responsible Department: OPERATIONS Number: ER-200 1-2066-02 Source Type: Corrective Action Regulatory Commitment Source Detail: Event Report Violation Level Initiated Date: 12/04/2001 Non-Cited Violation UResulted in a Fine

Title:

Revise OP 0145 and OP 4172 Instructions:

Revise OP 0145 and OP 4172 to reflect the revised calculation WC-1005 (Refer to this ER) Changed cointnitment to Revise AP 0145, and Instrustions to "Revise AP 0145 to reflect the revised calculation VYC 1005.

CHANGE:

The Calc revision was approved 1112012002 and did not necitate changes to OP 4172. See attached approved Commitment Change Form 0028.04.

- - Continued on Attached Page Affected Systems:

Affected Programs:

R Affects the VY Emergency Pian Impacts Plant Safety Item t o be completed during outage:

NRC Presentation Required PORC Presentation Required Presented on:

Presented on: E Inspection Report at PORC meeting #

RESPONSE

Assign to: KAREN MEGO Change made by AP 0 145 Rev. 8 LPC 1, copy of RPO signed form attached.

Response Attachments:

Reviewed bv: KAREN MEGO Reviewed date: 11/27/2002 VYAPF 0028.01 AP0028 Rev. 20

Page 2 DHAPPROVAL Number: ER-2001-2066-02 Additional Notifications:

Copy Training Department Copy Vendor Quality Assurance Group (item involved vendor partskewices compliance)

Copy System Engineering item is applicable to W System Copy Maintenance Rule Coordinator (item applicable to W Maintenance Rule Program)

Additional Copies:

~~~ ~

I X Item is complete, well documented, no further tracking required.

Additional commitment tracking Additional actions tracked by another process:

Approval Comments:

Approved by: Mitchell McCIuskie Reviewed date: 11/27/2002 SUPT APPROVAL Approval Comments:

Approved by: Reviewed date:

OEC CLOSEOUT Trending Information UGenerated from Operating Experience I

Applicable to VY Corrective Action resolved the issue Training related UMaintenance Rule related E Performance Evaluation related Performance Improvement Plan related Close out Comments:

Closed bv: PAT LOGUE Date: 12/02/2002 VYAPF 0028.01 AP 0028 Rev. 20

Attached Page for Commitment Report ER-2001-2066-02 Instructions

- - Continued From Page I Copy of LPC approved change sheet attached.

EXTENSIONS:

Please extend to 9/05/2002, This change will not be needed until post outage plus 3 to 6 months when cyclic data is again collected and reviewed for the previous cycle, Meets the criteria of G.1 .c. Please extend to 12/06/2002 Affected Proarams Affected Svstems Response Comments Response Attachments Keywords DH ApDroval Comments SUPT Approval Comments Closeout Comments Report Printed on 12/02/2002 at 8:07 AM Attached Page 1

Attachment Header Document Name:

Document Location klosurel Description Attach

Title:

PREAPPROVED LPC FORM A. Procedure No.: A p 0145 Current Revision #: 8

Title:

Equipment Cycle Record Keeping D. Duration: [XI Permanent 0 One Time Only I. Originator (PrintBigdDate)

E. SurveilIanceDatabase Change? 0 Yes, change submitted No (Use AP 0096, App. A as a reference)

(Complete & atlach AP 0096 App. C, F. Procedure Type: Technical 0 Admin. ( N P p ) unless editorial)

G. AP 0091, Risk Assessment c]Yes IXI No H. Page(s) affected: 3. ADD.A. 'DE.1, WAPFO145.01 DE. 1 g q w A. Technical Verification Review (print/Sign/Date) (Use ce)

+z& z c]N/A B. Cross-Discipline Review(s) (Print/Sign/Date)

@ N/A (May p om fied Review) (N/A if editorial change)

C. Qualified Review (pnht/Sign/Date) (Use AP 0096, D. 50.59 review completed type:

0NfA Evaluation N/A (N/A if editorial change)

[7 50.54(q) (EPP only) -

E. RPO Approval (PrintlSign/Date) F.IF 50.59 Evaluation: aN/A G. Plant Manage;(Print/Sign/Date) (SPs only)

H. Training: (Required for Admin Procedures, unless editorial) Ix] NfA I. Effective Date:

CDS Initials VYAPF 0097.01 AP 0097 Rev. 3 Page 1 of 1

r 1C R - V T Y - ~ O O ~ - O O ~ ~

I I I CONDITION REPORT Originator: Hopta,Dennis W Originator Phone: 8022585462 Originator Group: Maint I&C Mgmt Operability Required: Y Reportability Required: N Supervisor Name:

Discovered Date: 02/26/2002 1O:OO Initiated Date: 02/27/2002 0O:OO Condition

Description:

Inoperative Flow Switch Flow switch contacts failed to reset when normal cooling water flow established during HPCI run. Adjusting switch through full range of available position did not succeed in providing reset function of this device.

Immediate Action

Description:

NOTIFIED SHIFT SUPERVISOR : Complete : Shift Supervisor notified Suggested Action

Description:

EQUIPMENT:

Tag Name Tag Suffix Name ComDonent Code Process System Code FSL 107 HPCI REFERENCE ITEMS:

Type Code Description wo wo 01-5852 TRENDING (For Reference Purposes Only):

Trend TyDe Trend Code HOW IDENTIFIED HI-SELF-REVEALING KEY ACTIVITY KA-sv PERSONNEL INJURY PI-NON-INJURY WORK PROCESS WP-PO CAUSAL FACTOR CODES CFC-R 1F4 Attachments:

Closure Description INVESTIGATION INOPERATIVE FLOW SWITCH OPERABILITY STATEMENT

f I I i Entergy ADMIN CR-VTY-2002-00353

~~~~ ~ ~ ~ ~

Initiated Date: 2/27/2002 0:OO Owner Group :Maint Support Mgmt Current

Contact:

Current Significance: C Closed by: Caron,Mikey 4/16/2002 15:54 Summary

Description:

Inoperative Flow Switch Remarks

Description:

The ER 20020353 was migrated from the VY Niagara application on 10/30/2003to generate this CR.

Closure

Description:

Attachment Header Document Name:

Document Location Attach

Title:

INVESTIGATION

E & C Department Levei 3 Event Report J Event Report #: 2002-0353 Investigator: ROY GREGOR Most ProbableCause Codeis): R. 1.f.4 Action(s) Taken:

Flow switch FSL 107 contacts failed to reset when normal cooling water flow established during I

HPCI run. This switch actuates annuciator CRP9-3-S-7 GLAND SEAL CONB COOLING WATER LOW FLOW and provides no trip functions. Technician attempted to adjust reset function of this switch with no success. Work Order 01-005852-001 was generated to replace the flow switch.

The replacement is scheduled for 5/28/02 and will be tracked under the work order process.

Other considerations/Notes/Rernarks:

A review of EMPAC records indicate that this switch was replaced under work order 0 1-002124-0 1 and this present failure maybe due to infant mortality. No failures noted under EMPAC prior to 01-002 i 24-0 1.

Time Required to Complete Investigation: 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months

Attachment Header Document Name:

Document Location klosure Description Attach

Title:

VERMONT YANKEE Event Level (Circle One) ER NO.ER- 20020353 (complete at screening meeting)

EVENT REPORT 1 2 3 PART 1: IDENTIFICATION OF EVENT (Originator) (Fill in all known data)

Initiated By (Print) DENNISHOPTA Date 02/27/2002 Phone # 8 0 ~ 2 ~ 8 5 4 6 2Department MAINT I & C

~

B) EvenUDiscovery (Date) 02/26/2002 Occurred (Time) 1o:OO AM Equip No(s). FSL-23-107 System(s) affected HPCI C) Event

Title:

lnoperative Flow Switch D) Reference Document (WO, Procedure, Calculation, Drawing, Audit/Surveillance No., etc. See Attached Page E) Event Description (Describe the event and suspected cause. if known) How Identified: E Self-Revealing Flow switch contacts failed to reset when normal cooling water flow established during HPCi run. Adjusting - Self-Identified switch through full range of available position did not succeed in providing reset function of this device.

- By Others

- QAD

- External F) Immediate Action Taken - Recommendations. if any. WR/WO No. Nonconformance Tags Installed? E N 0 -YES (if segregation required)

NOTIFIED SHIFT SUPERVISOR Shift Supervisor notified PART 2: REVIEW OF EVENT (Department Head)

A) Department Head Review

1. SS Review Required (operability concertidegraded equipment AP 0156, LCO, TS)?-NO E Y E S (deliver to SS)

2. Security-Related Event? -XNO -YES (immediately notify SSS/SS)

3. Personnel Injury/Accident? -XNO -YES (FAX ER to Treasury/Risk Mg.for Accident Type (Discuss with Safety Coord.) W Personnel)

4. Recommended Event Level 3

5. Nuclear Network entry required? -XNO -YES

6. Recommended Responsible Department? MAlYT .SUPPORT B) If demaded or nonconforming SSC's Will remain ooerable then record and attach Ouerabilitv Basis/ Justification Refer to AP 01 67.

Note operability statement written 5 days after event discovery. Ron Keith C) Additional CommentsiActions Taken:

Department Head Signature/Date FRANK LIPINSKI 1 03/04/2002 PART 3: REPORTABILITY AND OPERABILITY (SSISE)

A) Event reportable per AP 0156? L N o t Reportable -Reportable Attach copy of W A P F 0156.01 if reportable or if additional notifications required.

B) Per AP 0167 degraded or nonconforming SSCs will remain operable? -N/A -NO EYES C) Documentation for Operability Determination attached? -NIA &YES If YES: X F o n n attached (VYAPF 0167.01) and/or X Evaluation attached or included in ER Shift SupervisoriDateRime RONALD KEITH / 03/04/2002 1 1290 .AM VYAPF-0009.01 (Saniplc)

AP 0009 Rci. I3 Page I or2

PART 4: EVENT SCREENING MEETING ER NO. ER- 20020353

~~ ~~

A) Additional Initial Notifications and Reviews Required? L N O -YES B) BMO R e q u i r e d ? x N O -YES (Processing Time Resp. Dept. BMO # )

C) Reportable? &NO -YES -Further Evaluation Required (Assigned TO 1 D) Potential I OCFR50.65 Maintenance Rule Functional Failure? -XNO -YES E) Potential Reactivity Management Event? -X N O -YES F) NRC Significance Determination Process? -XNO -YES G) NRC Performance Indicator? -XNO -YES H) Startup/Mode Restraint?xNO -YES Spccific Action Rcquircd: Rcsp. Dcpt.: Modc Affcctcd:

1) Human Performance Related? -x NO -YES If YES -Consequential -Nan-consequential J) Event Level Determined 3 K) Responsibility for ER Investigation and Recommending Corrective Action Assigned to (Dept.): MAlNT - SUPPORT L) Additional Considerations Additional Reviewers: -Training

-Maint. Rule Coordinator

-Reactor Engineer

-Fire Protection Engineer

-Radiation Protection

-Safety Coordinator M) Completed by/Date FRkVK LIPINSKI I 03/05/2002 -Other: Specify PART 5: EVENT INVESTIGATION (Assigned Department)

A) Investigation Type: (RCA rcquircd for Lcvcl I ; Optional for Lcvcl 1) B) Investigation Results:

- RCA -ACE XMPC (DH check one) I . Attach report for Level 1 and 2 ERs (see PP 7017 for details.)

C) MRFF: -

XNO -YES 1

2. Note Most Probable Cause Codes (Lcvcl 3 ERs)

- Resolved See Attached Page D) Event Reportable: E N 0 -YES (LER No. 3. StartupMode Restraint: Approved:

E) Estimated hours to perform investigation 3 4. Adverse Trend -X NO -YES F) Actions Taken (Level 3 ER Disposition): 5 . NRC PI color change E N 0 -YES See Anached Page Investigator (if other than Dept. Head) DAVID PHILLIPS / 04/15/2002 DH Review DAVID PHILLIPS I O4/15/2002 PART 6: REVIEWS

~~~ ~ ~

A) Additional Reviews:

B) I I QAD (Level 1 ) Design Eng. (Design Deficiency, "Use-As-Is" dispositions)

Comments:

PART 7: APPROVALS (Forward to the TSM after final approval)

A) DAVID PHILLIPS I 04/15/2002 I I Department Head (Level 1,2,3 ERs) Supt/Dir designee (Level 1 & 2 ERs) PORC (Level I ERs)

B) I I Plant Mgr (Level I ERs, Some Level 2s) Dir. O f Operations (Level I ERs)

PART 8: CANCELLATION/CLOSEOUT A] Repair/rework complete I Nonconformance Tags removed I B) ER Cancelled By (SupVDiddesignee: I Basis/Cancellation Comments:

C) Technical Support (ER Database Updated, Copies Distributed, Commitments Initiated)

ERC/Date Mikey Caron I 04/16/2002

\'YAPF-0009.01 AP 0009 Rcv. I3 Rgc 2 01'2 Reoorl Pnnledon 04116ROO2 at 3 55 PM

Attached Page for Event Report ER-20020353 PART 1 Affected Eaubment Affected Svstems Reference Documents wo 01-5852 Work Orders Event Description Immediate Action Taken PART 2 Additional Comments I Oaerabilitv Justification DH Actions Taken PART 4 Saecific Action Required Additional Reviewers Suecified Additional Considerations PART 5 Causal Factors Rlf4 Investigation deferred to a later time.

Corrective Actions Action Description Status Department DueDate CTS CTS Number Tracked INITIATEDW O W 0 WO 01-005852-001 was Done MAIN1 -SUPPORT N generated to replace the flow switch.

PART 6 Additional Reviews Reviewer Comments PART 7 Auarover Comments PART 8 Basis I Cancellation Comments Repon Ptinled m 04116R002 d l 3.55 PM

c 1 VERMONT YANKEE Event Level (Circle One) ~ ER NO.ER- 20020353 IEVENT REPORT (complete at screening m PART 1: IDENTlFlCATION OF EVENT {Onghator) will in all known data) 1 2 fl ;;

A) Initiated By (Print) DENNIS H ~ P T A Date O M ~ O ZPhone# 8022.~2 Department mMNr-Y&C

3) EvenrlDiscovety (Date) oy26~a-z Occumd (Time) 10:WAM Equip No@). FSLZWI~ SysteMs) affected npa C) Event

Title:

~ u p c r . ~ UIvWe $witen D) (WO,PmceduR, Calculation. Drawing, AuditlSweillance No., etc.): AwUckdpap

.E) 9

.. How Identified: 5 Self-Revealing Flow switch mntacts CaiIed to reset when nornu1 coolingwater now establbhed during HPCI mu.AdJusting - Self-ldentifted swilch through full range of svaifable position dM w t 5 d in providing tesct lumdon of thls device.

By Others PAD

- External 0 . . 0 WWWONo. Nonconformance Tags Installed? E N 0 -YES (if segregation required)

NOTIFWD SHIFTSUPERVISOR ShiRSupcpervlroraotiW wgrc P I - 5 & 9 JL A) -

PART 2: REVIEW OF EVENT (Department Head) 1.

2.

3.

SS Review Required (operability concemldegraded equipment AP 0156, LCO,TS)?

Security-Related Event?

Femonnel Injury/Accident?

-A0

/

YES (deliver to SS)

(immediately noti& ss/ss)

YES ( F A X ER to Treasury/RiskMgr. for Accident Type (Discuss with Saf Coord.) W Personnel) 3 d-4.

5.

6.

Recommended Event Level Nuclear Network entry required?

Recommended Responsible Deparhnent? & 7 s,, ..

YES

)

I B

-lc DeparhneN Head SignaturelDale

&, I Y

PART 3: REPORTABILITY AND OPERABILITY (SSISE)

A) Event reportable perm0156? p o t ReportabIe -Reportable Attach copy ofWAPF0156.01 B) Per AP 0167 degraded or nonconforming SSCs will remain operable? - N/A -NO &YES!

C) Documentation for Operability Determination attached? -NIA - A S IfYES:

Shift Supervisor/Datemime //%AM r/l WAPF-OW9.OI (synpk) xp (NO9 Rcv.13 pdge i 012

PART 4: EVENT SCREENING MEETING #

i ER NO.ER- 20020353

6) BMO Required? -NO Y .-YES A) Additional Initial No ications and Reviews Requid?

(ProcessingTime -

/-NO -YES Resp. Dept BMO #f 1

- Further Evaluation R w n d (Assigned To 1 C) Reportable? 4 0 -YES D) Potential IOCFR50.65 Maintenance Rule Functional Failure? 40- YES E) Potential Reactivity Management Event?

F) NRC SignificanceDetermination hocess?

G) NRC Performance Indicaror?

H) StamphlodeRestraint? L N O -YES Specific Action Required: Resp. Dcpt: Mode Affect4 I) Human Performance Related? - 1fm -ansequentid -Non-consequential J) EventLmelDetermined 3 K) Responsibility for ER Investigationand RecommendingC o d v e Action Assigned to (Dept.):

L) Additional Considemtiom

-Maint Rule Coordinator

-Reactor Engineer

-Fire Rotection Engineer

- Radiation Protection

-Safety Coordinator M) Completed bymate (

f

-Other. SpeciQ PART 5: EVENT INVESTIGATION (Assigned Department)

A) Investigation Type: (RCA requiredfor Level 1; Optional for b e l 2) B) InvestigationResults:

- RCA -ACE L M p C (DHcheckone) I. Attach report for Level 1 and 2 ERs (see PP 7017 for details.)

C) MRFF: @O - YES 2. Note Most Probable Cause Codes

- Resolved (Level 3 ERs)

D) Event Reportable: d N 0 -YES (LER No. 1 3. StrrtuplMode Restraint; Approved:

L E) Estimated hours to perform investigation 7 4. AdverseTrend d N 0 - W F) Actions Taken (Level 3 ER Disposition): 5. NRC PImior change ,(NO -YES Investigator (if other than Dept. Head) & I I ~ / / ~ / o ~ D H R e v , i e w&: ~ I9diSAL v U Y PART& REVIEWS A) Additional Reviews: /fl/v4 B) d/* UIA I QAD (Level 1) I Design Eng. (Design Defickncy, "Use-As-Is" dispositions)

Comments:

A

PART 7: APPROVALS (Forward to the TSM after final approval)

B)

Depa-nt kz i#YkS

&ad (Level 1,ZS ERs)

Nlllt I Nld t-l i 4

/

SupuDir dcsignke (Level 1 & 2 ERs)

I N/fi PORC (Level 1 ERs)

I Plant Mgr (Level I ERs[Some Level 2s) Dir. Of Operadons (Level I ERs)

PART 8: CANCELLATIONKLOSEOUT A) Repair/rework complete tdlfi f Nonconformance Tags removed I I B) ER Cancelled By (Supt/Dir/designee) Nh I BasislCancelIationComments:

Attachment Header Document Name:

Document Location blosure Description Attach

Title:

3/4/02 5.

FAILURE OF FSL-23-107AND OPERABILITY CONCERNS RELATED TO THE F k W .

Xnstrument function.

Thisi@mment monitors the flow of cooling water to the Gland Seal condenser (E-18-1A) and the Lube Oil cooler (E-19-1A). The instrument is set to alarm at 50 gpm decreasing flow and provides only an annunciation fbnction on CRP 9-3.

Operability of the HPCI system.

A review of Technical Specifications section 3.5 and UFSAR section 6.4.1 was performed to evaluate the loss of FSL-23-107 alarm function on system operation. FSL-23-107 does not impact upon the requirements of either T.S3.5 or UFSAR 6.4.1. Based on the rqu2ements of Tech Specs and the UFSAR the HPCX. system is considered operational. HPCI will still perform its intended function without the alarm input o f FSL-23-107.

FSL23-107can still give Operation a local indication of flow along with other indicators such as FI-23-47.

Roy Gregor ENGINEERING ANALYSIS I&C DEPARTMENT

OPERABILITY [ CR-VTY-2002-00353 OperabilityVersion: 1 Operability Code: NIAGARA CONVERSION Immediate Report Code: NIAGARA CONVERSION Performed By: Keith,Ronald M 03/04/2002 0O:OO Approved By: Keith,Ronald M 03/04/2002 0O:OO Operability

Description:

Niagara indicators set during Shift Supervisor Review.

Event Reportable Per AP 0156 :: No Per AP 0 I67 Degraded or Non conforming SSC's will remain operable :: Yes Operability Determination Attached (See Admin Tab for attachment) :: Engineering Evaluation Pre-screening Comments / Operability Justification:

Note operability statement written 5 days after event discovery. Ron Keith DH Review Performed By: LIPINSKI,FRANK on 03/04/2002 Approval Comments:

I I A SSIGNMEN TS 1 CR-VTY-2002-00353 I

Version: I Significance Code: C Classification Code: C Owner Group: Maint Support Mgmt Performed By: Lipinski,Frank P 03/05/2002 0O:OO Assignment

Description:

Pre-screening Comments / Operability Justification:

Note operability statement written 5 days after event discovery. Ron Keith DH Review Performed By: LIPINSKIFRANK on 03/04/2002 Niagara indicators set at screening.

How Identified :: Self-Revealing

Entergy CORRECTIVE ACTION CR-VTY-2002-00353 CA Number: 1 Assigned By: CRG/CARB/OSRC Lipinski,Frank P Assigned To: Maint Support Mgmt Subassigned To : Maint Support Staff Originated By: Lipinski,Frank P 3/5/2002 0O:OO:OO Performed By: Phillips,David L 4/15/2002 0O:OO:OO Subperformed By: Phillips,David L 4/15/2002 0O:OO:OO Approved By:

Closed By: Phillips,David L 4/15/2002 0O:OO:OO

~~

Current Due Date: 04/27/2002 Initial Due Date: 04/27/2002 CA Type: CR DISPOSITION Plant Constraint: NONE CA

Description:

This CA for Disposition was generated during Niagara to PCRS Conversion Investigate Type :: Most Probable Cause

Response

CA for Disposition Reviews:

Maint - Support Sup't : PHILLIPS,DAVID : 04/15/2002 2:oo:oo AM :

Approvals:

Maint - Support Sup't : PHLLIPS,DAVID : 04/15/2002 2:oo:oo AM :

Subresponse :

Niagara indicators set during investigation.

Cause Codes ::

RI f4 - Investigation deferred to a later time.

Corrective Actions identified during Investigation:

Action : Description : Done : Department : Due Date : CTS Number : CTS Tracked INITIATED W O W 0 : WO 01-005852-001 was generated to replace the flow switch. : Done : MAINT - SUPPORT : : :

N Closure Comments:

This CA for Disposition was generated from ER Investigation information from the VY Niagara application on 10/30/2003.

Entergy 1 CONDITION REPORT CR-VTY-2002-00698 Originator: Amirault,Laurence P Originator Phone: 8022585270 Originator Group: Operations Mgr\ Mgmt Operability Required: Y Reportability Required: Y Supervisor Name:

Discovered Date: 04/05/2002 03:OO Initiated Date: 04/05/2002 0O:OO Condition

Description:

RRU-7 Service Water Flow As-Found data outside of Acceptance Criteria The Crew was performing Flow Rate Testing of RRUs 7 & 5 to verify data taken on RRU 7 during the last Quarterly Flow Rate test of RRUs 7 & 5 per OP 4 I8 1, using VYOPF 41 8 1.06. The As-Found Data for RRU-7 was found to be outside of the acceptance criteria of 100-200gpm. The As-Found flow rate was 232 gpm. The procedure was continued and the flow rate was adjusted to 163 gprn, within the As-Left acceptance criteria of 161-168 gprn.

Immediate Action

Description:

NOTIFIED SHIFT SUPERVISOR : Complete : Shift Supervisor notified OTHER : Complete : Adjusted Flow per procedure Suggested Action

Description:

EQUIPMENT:

Tag Name Tag Suffix Name Component Code Process System Code RRU-7 WAC REFERENCE ITEMS:

Type Code Description PROCEDURE OP4181 TRENDING (For Reference Purposes Only):

Trend TyDe Trend Code WORK PROCESS WP-CA CAUSE DEPT CD-OPERATIONS HU TYPE HU-NC (NON-CONSEQUENTIAL)

KEY ACTIVITY KA-AN HOW IDENTIFIED HI-SELF-IDENTIFIED PERSONNEL INJURY PI-NON-INJURY CAUSAL FACTOR CODES CFC-03G4 KEYWORDS KW-REWORK Attachments:

Closure Description PRO MEMO ALL GRAPH RRU-7 SERVICE WATER FLOW AS-FOUND DATA OUTSIDE OF ACCEPTAN1 OPERABILITY ASSESSMENT

Entergy I ADMIN CR-VTY-2002-00698 Initiated Date: 4/5/2002 0:OO Owner Group :Operations Mgr\ Mgmt Current

Contact:

Current Significance: C Closed by: Houle,Mona M 6/6/2002 13:I5 Summary

Description:

RRU-7 Service Water Flow As-Found data outside of Acceptance Criteria Remarks

Description:

The ER 20020698 was migrated from the VY Niagara application on 10/30/2003 to generate this CR.

Closure

Description:

Attachment Header Document Name:

fCR-VTY-2002-00698 Document Location Attach

Title:

INTEROFFICE MEMORANDUM - REGULATORY COMPLIANCE TO: MIKE DESILETS, TECHNICAL SERVICES SUPERINTENDENT FROM: MIKE HAMER, REGULATORY COMPLIANCE ANALYST

SUBJECT:

ER 2002-0698: RRU-7 SERVICE WATER FLOW AS-FOUND DATA OUTSIDE OF ACCEPTANCE CRITERIA DATE:

APRtL 08,2002 EVENT DESCRIPTiON:

On 04/05/02with the reactor at full power, the Operations crew was performing flow rate testing of RRUs 7 and 5 to verify data taken on RRU-7 during the last Quarterly Flow Rate Test per OP 4181.

The As-Found data for RRU07 was discovered to be 232gpm, 32gpm greater than the acceptance criteria of 100-200gpm. Flow rate was adjusted to 163gprn as allowed by procedure, with in the As-Left acceptance criteria of 161-168gpm.

The following regulations were considered when determining reportability of this event.

Degraded or Unanalyzed Condition

§50.73(a)(2)(ii) fThe licensee shall report.] Any event or condition that resulted in:

(B) The nuclear power plant being in an unanalyzed condition that significantly degraded plant safety.

Event or Condition That Could Have Prevented the Fulfillment of a Safety Function

§50.73(a)(2)(v) [The licensee shall report:] Any event or condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to:

(3) Remove residual heat; (D) Mitigate the consequences of an accident.

DlSCUSSION/BASES:

RRU-7 remained fully operable as described in the operability assessment completed by Design Engineering on 04/05/02in response to ER 2002-0698. Additionally, there are no Technical Specifications related to the flow rate of Service Water through the RRUs. Both trains of RHR remained fully functional during this condition.

CONCLUSION: This event is not reportable as an LER.

RECOMMENDED: / Y---l Michael J. Hamer Date Regulatory Compliance Analyst n

APPROVED: / 4//l/bt Michael Desilets- Dati Technical Services Superjntendent 2

Attachment Header Document Name:

Document Location Attach

Title:

Attachment to Event Report 2002-0698 Event

Description:

RRU-7 Service Water Flow As-Found data outside of Acceptance Criteria.

Background:

The Crew was performing Flow Rate Testing of RRUs 7 & 5 to verify data taken on RRU 7 during the last Quarterly Flow Rate test of RRUs 7 & 5 per OP 4181, using VYOPF 4181.06. The As-Found Data for RRU-7 was found to be outside of the acceptance criteria of 100-200 gpm. The Aseound flow rate was 232 gpm. The procedure was continued and the flow rate was adjusted to 163 gpm,within the As-Left acceptance criteria of 161-168 gpm.

From ER 2002-0663; RRUs 5,6,7& 8 were flow tested per OP4181 on March 13,2002.The same ultrasonic flow meter (VY-6117) was used for all four tests. The results for RRus 5,6 & 8 were as expected and consistent with previous resuIts. The as found flow for RRU-7 was found to be 113 gpm.

This value is 66 gpm lower than the previous as found flow recorded on 12/12/01.

Discussion:

The 113 gpm as found flow is within the acceptable range of 100 to 200 gpm. A review was conducted of flow test results dating back to 11/14/99 when the cooling coil was replaced. All as found flow measurements were found to be above 153 gpm (see attached trend graph). The average of the readings for this period is 164 gpm. Per procedure the flow was adjusted and the as left flow was recorded at 161 gpm. Based on past test results there is no negative trend or other record of a rapid and dramatic loss of flow as recorded.

On April 4,2002 the Operations Department was requested to check the flow to RRU-7. On ApriI 5th the flow was found to be 232 gprn which is 32 gpm above the acceptance criteria. The flow was subsequently readjusted to 168 gpm. Event Report 2002-0698 was generated to document this condition.

The flow measurement is obtained by using a portable ultrasonic flow meter, The position of the ultrasonic transmitterheceiverheads, condition of the pipe surface, location of the test area, and contact condition are critical to the proper operation of the unit. A problem with any one of these parameters could.result in inaccurate readings. Based on the fact that previous tests were successfully conducted using the same location on the pipe it is most likely that the transducers were not firmly connected to the pipe.

Summary:

The most probable cause for the low reading is a failure of the transducers to make firm contact with the pipe wall.

Actions:

No further actions required for this Event Report.

Part 5: Event Report Investigation Discussion:

This event report documented the results for the ER 2002-0663 investigation. ER 2002-063 documents the cause of the low reading. When the 113 gpm reading was readjusted to be in band (set to 161 gpm) with an error caused by placement of the ultrasonic detector, it essentially adjusted the flow to approximately 223 gpm. With the usual small increase in flow, 232 gpm was an exfled as-found flow.

Discussion previously on the Iow reading documented in ER 2002-0663 with the investigator lead to one of three conclusions;

1. If the as-found reading was significantly higher, then bad placement of the detector in the reading, which would result in a higher that normal readings.

2. If the reading was at or below the as left reading, then it would be expected there was some blockage.

3. If at or only slightly above the as-left reading, then the previous reading was a valid reading with no other problems noted other than the previous as-left being in actuality left low in the band or the valve was mechanically agitated in some manner to cause flow to be low.

Looking at a cause of bad positioning, the position of the ultrasonic transmitter/receiver heads, condition of the pipe surface, location of the test area, and contact condition are critical to the proper operation of the unit. A problem with any one of these parameters could result in inaccurate readings. Based on the fact that previous tests were successfully conducted using the same location on the pipe it is most likely that the transducers were not firmly connected to the pipe.

Summary:

The most probable cause for the low reading is a failure of the transducers to make firm contact with the pipe wall. This could not be reproduced. Based on previous readings, and data over the last several years, this is considered to be an isolated occurrence. This was the first occurrence of a bad placement reading for this surveilIance.

Actions Based on this being an isolated occurrence, no further actions required for this Event Report. The system engineer will continue to monitor data from the quarterly tests and analyze the results to anticipate any plugging of the RRUs. Any future readings will be reviewed and analyzed and actions taken as appropriate.

i

Attachment Header Document Name:

Document Location plosure Description Attach

Title:

Attachment Header Document Name:

PR-VTY-2002-00698 Document Location plosure Description Attach

Title:

VERMONT YANKEE Event Level (Circle One) ER NO.ER- 20020698 (complete at screening meeting)

EVENT REPORT I 2 3 PART 1: IDENTIFICATION OF EVENT (Originator) (Fill in all known data)

A) Initiated By (Print) LAUREYCEAMIRAULT Date 04/05/2002 Phone # 8022585270 Department OPERATIOYS B) Event/Discovery (Date) 04/0512002 Occurred (Time) 3:OO AM Equip No(s). RRU-7 System(s) affected HVAC c ) Event

Title:

RRU-7 Service Water Flon As-Found data outside of Acceptance Criteria D) Reference Document (WO, Procedure, Calculation, Drawing, Audit'Surveillance No., etc. see Attached Page E) Event Descriotion (Describe the event and suspected cause. if known) How Identified: - Self-Revealing T h e Crew was performing Flow Rate Testing of RRUs 7 & 5 to verify data taken on RRU 7 during the last Quarterly Flow Rate test of -

X Self-Identified RRUs 7 & 5 per OP 4181, using VYOPF 4181.06. The As-Found Data for RRU-7 was found to he outside of the acceptance criteria of 100-

- By Others 200 gpm. The As-Found flow rate was 232 gpm. The procedure was continued and the flow rate was adjusted to 163 gpm. within the As-Left acceptance criteria of 161-168 gpm.

- QAD

- External F) Immediate Action Taken - Recommendations. if any. WWWO No. Nonconformance Tags Installed? L N O -YES (if segregation required)

NOTIFIED SHIFT SUPERVISOR Shift Supervisor notified OTHER Adjusted Floa per procedure PART 2: REVIEW OF EVENT (Department Head)

A) Deuartment Head Review 1, SS Review Required (operability concernldegraded equipment AP 0156, LCO, TS)?-NO -X YES (deliver to SS)

2. Security-Related Event? -XNO -YES (immediately notify SSSiSS)

3. Personnel InjurylAccident? -XNO -YES (FAX ER to TreasuryBisk Mgr. for Accident Type (Discuss with Safety Coord.) VY Personnel)

4. Recommended Event Level 3

5. Nuclear Network entry required? -xNO -YES

6. Recoinmended Responsible Department? OPER4TIONS B) If degraded or nonconforming SSC's will remain ooerable then record and attach Ouerabilitv Basis/ Justification. Refer to AP 0167.

C) Additional CommentslActions Taken:

Department Head SignaturelDate WILLIAM PITIiVAN JR J 041051zooz PART 3: REPORTABILITY AND OPERABILITY (SS/SE)

A) Event reportable per AP 0156? X N o t Reportable -Reportable Attach copy of VYAPF 0156.01 if reportable or if additional notifications required.

B) Per AP 0167 degraded or nonconforming SSCs will remain operable? KN/A -NO -YES C) Documentation for Operability Determination attached? -X N/A -YES IfYES: -Form attached (VYAPF 0167.01) and/or

- Evaluation attached or included in ER Shift Supervisor/Date/Time MICHAEL HARRIS t 04/05/2002 I 12:OOAb.l VYAPF-0009.01 (Samplc)

AP 0009 R C ~ I. 3 Pagc I o r 2 Re0oi1Piinledan 0610612002 a1 1.16 PM

PART 4: EVENT SCREENING MEETING ER NO.ER- 20020698 A) Additional Initial Notifications and Reviews Required? E N 0 -YES B) BMO R e q u i r e d ? x N O -YES (Processing Time - Resp. Dept. BMO # 1 C) Reportable? -NO -YES -

X Further Evaluation Required (Assigned To TECHXICAL SUPPORT )

D) Potential IOCFR50.65 Maintenance Rule Functional Failure? -xNO -YES E) Potential Reactivity Management Event? -

X N O -YES F) NRC Significance Determination Process? -

xNO -YES G) NRC Performance Indicator? -

xNO -YES H) Startup/Mode Restraint?xNO -YES Spccific Action Rcquircd: Rcsp. Dcpt.: Modc Affcctcd:

I) Human Perfonnance Related? -NO EYES If YES -Consequential ENon-consequential J) Event Level Determined 3 K) Responsibility for ER Investigation and Recommending Corrective Action Assigned to (Dept.): OPERATIONS L) Additional Considerations Additional Reviewers: -Training REWORK

- Maint. Rule Coordinator

-Reactor Engineer

-Fire Protection Engineer

-Radiation Protection

-Safety Coordinator M) Completed by/Date WILLIAM PllTiMAN JR I 04/05/2002 X Other: Specify

- See Attached Page PART 5: EVENT INVESTIGATION (Assigned Department)

A) Investigation Type: (RCA rcquircd for Lcvcl I; Optional for Lcvcl 2) B) Investigation Results:

-RCA -ACE EMPC (DH check one) I . Attach report for Level 1 and 2 ERs (see PP 7017 for details.)

C) MRFF: -XNO -YES 2. Note Most Probable Cause Codes (Lcvcl3 ERs) See Attached Page D) Event Reportable: Z N O -YES (LER No. 1 3. Startup/Mode Restraint: - Resolved Approved:

E) Estimated hours to perform investigation 2 4. Adverse Trend -

X NO.-YES F) Actions Taken (Level 3 ER Disposition): 5. NRC PI color change X N O -YES See Attached Page lnvestigator (if other than Dept. Head) KAREN MECO / 05/03/2002 DH Review EDWARD HARhlS I 05/15/2002 PART 6: REVIEWS A) Additional Reviews: JOE BOIVIN 06/04/2002 (System Engineering DH)

B) I I QAD (Level 1) Design Eng. (Design Deficiency, "Use-As-Is" dispositions)

Comments:

See Attached Page PART 7: APPROVALS (Forward to the TSM after final approval)

A) EDWARD HARMS 1 06/04/2002 I I Department Head (Level 1,2,3 ERs) Supt/Dir designee (Level I & 2 ERs) PORC (Level 1 ERs)

B) I I Plant Mgr (Level 1 ERs, Some Level 2s) Dir. Of Operations (Level 1 ERs)

PART 8: CANCELLATIONlCLOSEOUT A) Repaidrework complete I Nonconformance Tags removed I B) ER Cancelled By (Supt/Dir/designee: I Basis/Cancellation Comments:

C ) Technical Support (ER Database Updated, Copies Distributed, Commitments Initiated)

ERC/Date MOXAHOULE I 06/06/2002 Repart Pnnlsd on 06!0612002 ai 1 16 PM

Attached Page for Event Report ER-20020698 PART I Affected Eauipment Affected Svstems Reference Documents OP 4181 Procedure (VY)

Event Description Immediate Action Taken PART 2 Additional Comments I Operabilitv Justification DH Actions Taken PART 4 Specific Action Reauired Additional Reviewers Specified System Engineering DH Additional Considerations PART 5 Causal Factors 0394 Improper test equipment.

Corrective Actions Action Description Status Department DueDate CTS CTS Number Tracked INVESTIGATED THE investigate cause of Done OPERATIONS N PROBLEM high as found reading, see the attachment.

PART 6 Additional Reviews Reviewer Comments JOE BOlVlN (System Engineering reviewed by S. Vekasy DH)

PART 7 ApDrover Comments PART 8 Basis I Cancellation Comments Repon Printedon 0610612002 a1 1.16 PM

&> . .. . :-e "I

VERMCYNT YANKEE * - - . Event L&eI (Circle One) .-

1 ---' ER No.ER- . -266$69tj-& *'

(complete at screening meeting)

EVENT REPORT 1 2 0 PART 1: LDENTIFICATION OF EVENT (Originator) (Fill in all known data)

A) Initiated By (hint) LAURENCEMIRAULT Date 04~z002 Phone# s 0 ~ ~ 7Department 0 OPERATIONS B) EventrDiscovery (Date) 04/0sm Occurred (Time) ~NAM Equip No(s). RRU-1 System(s) affected HVAC C ) Event

Title:

RRU-7 s w i wa(a

~ F1.w As-Found dnrn O ~ MofCAccrptnmCriterin D) Reference Document (WO, Procedure, Calculation, Drawing, Audit/Sweillance No., etc.): scc~ t t ~ Phn e~ d E) Event Description (Describe the event and suspected cause, ifknown) How Identified: I Self-Revealing

?he Crew was performing Flow Rate Testing of RRU3 7 k 5 to verify dnm taken on RRU 7 during the last Quarterly Flow Rate test of RRUs 7 &

5 per OP 4181, using VYOPF 4181.06. The As-Found Data for RRU-7 was found to be outside of the acceptancecriteria of 100-300 pm. The As-x Se]f-&ntified By Others Found flow rate was 232 gpm. The praccdure was continued and the flow rn&cwas adjusted to 163 gpm, within the As-Left aweptance criteria of

~

161-168 gpm. QAD I

External

--- .....i F) .Immediate Action Taken - Recommendations. if any WWWO No -d[A Nonconformance Tags Installed? X N O .,YES (if segregation required)

NOTLFfED SHIFTSUPERVISOR S h i i Supavlsarnrtifid OTHER Adjusted Flow per prnccdurc PART 2: REVIEW OF EVENT (Department Head)

A} Deoartment Head Review

1. SS Review Required (operability concem/degraded equipment AP 0156, LCO, TS)? -NO -A S (deIiver to SS)

2. Security-Related Event? -/NO -YES (immediately notify SSS/SS)

3. Personnel InjurylAccident? flo I YES (FAX ER to Treasurykisk Mgr.for Accident Type (Discuss with Safety Coord.) W Personnel)

4. Recommended Event Level -3

5. Nuclear Network entry required?

/NO YES

&-A, I

6. Recommended Responsible Department? 8/25 B) If degraded or nonconforming SSC's will remain oowable then record and attach Operabilitv Basis/ Justification. Refer to AP 0167.

C) Additional CommentdActions Taken:

=ea+=.-, .; . -. -- . . ....I., .-_ -

Department Head SignatureDate ., t PART 3: REPORTABILITY AND OPERABILITY (SS/SE)

A) Event reportable per AP 01561 X N o t Reportable -Reportable Attach copy ofVYAPF 0156.01 if reportable or if additional notifications required.

B) Per AP 0167 degaded or nonconforming SSCs will remain operable? kN/A -NO -YES C) Documentation for OperabiIity Determination attached? &N/A -YES If YES: -Form attached (VYAPF 0167.01) and/or

-Evaluation attached or included in ER Shift SupervisorDateiTime &&I& f 4!/dz f 0479 WAPF-OOW.OI (Sample)

APW09R~v.13 R w l t W t d on C-%m2lQZN4%uI h!JC 1 of 2

PART Q: EVENT SCREENING MEETING ER NO.ER- 20020698 A) Additional Initial Notifications and Reviews Required? 6 0 -YES B) BMO Required? /NO -YES (Processing Time R a p . Dept.

C) Reportable? Y 0 d F w t h e r Evaluation Re D) Potential 10CFR50.65 *YES Ma tenancc? Rule Functional Failure? &O -YES E) Potential Reactivity Management Event? -

/NO -YES F) NRC Significance Determination Process? LNO YES G) NRC Performance Indicator? -/No I YlES H) StartuplMode Restxaint? ,/FjO -YES Specific Action Required: Rep. Dept.: Mode Affected:

9 Human Performance Related? -NO &[s If YES -ansequential eon-consequentiat J) Event Level Determined .q ..._.. i-.

K) R&pons%liS<r ER investigation and Recommending Corrective Action Assigned to (Dept)

L) Additionat Considerations Additional &ieWes: -Training

-Maint. Rule Coordinator k&a7/-& -Reactor Engineer

-Fire Protection Engineer

-Radiation Protection

-Safety coordinator M) Completed bymate &er:SpeciQ a 452y t

~

Y PART 5: EVENT INVESTIGATION (Assigned Department)

B) Investigation Results:

MPC (DHcheck one) I . Attach report for Level 1 and 2 ERs (see PP 7017 fordetails.)

2. Note Most Probable Cause Codes ( L W C ~3 E&)

3. Startup/Mode Restraint: - Resolved Approved:

4. Adverse Trend -NO -YES

5. NRC PI color change -NO -YES Investigator (if other than Dept. Head) I DH Review: I Additional Reviews:

B) I QAD (Level 1)

Comments:

PART 7: APPROVALS (Forward to the TSM after final approval)

A) I I Department Head (Level 1,2,3 ERs) Supt/Dirdesignee (Level I & 2 ERs) PORC (Lever 1 E%)

B) I I Plant Mgr (Level 1 E%, Some Level 2s) Dir. Of Opetations (Level I ERS)

PART S: CANCELLATIONICLOSEOUT A) Repairkework complete ujd I

1 Nonconformance Tags removed &/# I B) ER Cancelled By (Supt/Dir/desjgnee) blk4 1 Basis/Cancellation Comments:

Copies Distributed, Commitments Initiated)

J (+h--

A

-,>=&* ..... < . . . . . . . . . . . . . wAPF-G09:01 . ....-Ili .,-.._4:..: ....i......

AP 0009 Rev. I3

%e 2 of2

Attachment Header Document Name:

Document Location plosure Description Attach

Title:

ER 2002-0698 RRU-7 Operability Assessment RRU-7 and other required components remained operable when the SW flow to the RRU was set at 232 gpm which is 32 gpm above the acceptance criteria.

This flow rate would have provided more than adequate RRU-7 heat removal capability without adversely affecting the RRU or other required components. The flow rate was not high enough to have caused long term erosion or vibration problems even if it had to operate long term after an accident.

Providing an extra 32 gpm to the RRU wouId not have diverted enough SW from any other required component to adversely affect required heat removal. 32 gpm is roughly 1/2 percent of total SWS flow after an accident. The SW pumps would have operated a little farther out on their operating curve and made up most of the difference. Even if pump flow remained constant all components would have received adequate flow, Additionally the Aver temperature is lower than the analysis value for this mode of SWS operation providing additional heat removal capability.

IN conclusion, all required components were operable during the period of high flow and would have remained operable if an accident or transient had occurred.

Enfeqgy 1 OPERABILITY 1 CR-VTY-2002-00698 OperabilityVersion: 1 Operability Code: NIAGARA CONVERSION Immediate Report Code: NIAGARA CONVERSION Performed By: Harris,Michael D 04/05/2002 0O:OO Approved By: Harris,Michael D 04/05/2002 0O:OO Operability

Description:

Niagara indicators set during Shift Supervisor Review.

Event Reportable Per AP 0 156 :: No Per AP 0167 Degraded or Non conforming SSC's will remain operable :: N/A Operability Determination Attached (See Admin Tab for attachment) :: N/A Approval Comments:

Entergy I ASSIGNMENTS 1 CR-VTY-2002-00698 Version: 1 Significance Code: C Classification Code: C Owner Group: Operations Mgr\ Mgmt Performed By: Pittman,William M 04/05/2002 0O:OO Assignment

Description:

DH Review Performed By: PITTMAN JR.,WILLIAM on 04/05/2002 Screening Comments:

REWORK Niagara indicators set at screening.

How Identified :: Self-Identified Reportability Selection :: Further Investigation Required Reportability Responsible Dept. :: Tech CA&A HU Mgmt Human Performance Indicator :: Yes - Non-Consequential

Entergy I REPORTABILITY 1 CR-VTY-2002-00698 Reportability Version: I Report Number:

Report Code: NIAGARA FURTHER INV Boilerplate Code: NIAGARA COWER2 Performed By : Pittrnan,William M 04/05/2002 0O:OO Reportability

Description:

Reportability information imported from Niagara Screening information:

Reportable Selection - Further Investigation Required Responsible Department - Tech CA&A HU Mgrnt Investigation information:

Event Reportable - NO LER Number -

I I EntWgy CORRECTIVE ACTION CR-VTY-2002-00698 Originated By: Pittman,William M 4/5/2002 0O:OO:OO Performed By: Harms,Edward L 5 / 1 5/2002 16:08:00 Subperformed By: Mego,Karen L 5/3/2002 08:43:00 Approved By:

Closed By: Harms,Edward L 6/4/2002 I2:54:00 Current Due Date: 06/04/2002 Initial Due Date: 06/04/2002 CA Type: CR DISPOSITION Plant Constraint: NONE CA

Description:

This CA for Disposition was generated during Niagara to PCRS Conversion Screening Comments:

REWORK Investigate Type :: Most Probable Cause

Response

CA for Disposition Investigation information:

Event Reportable - NO LER Number -

Reviews:

System Engineering : BOIVIN,JOE : 06/04/2002 1 1 : 12:28 AM : reviewed by S. Vekasy Operations : HARMS,EDWARD : 05/15/2002 4:08:27 PM :

Approvals:

Operations : HARMS,EDWARD : 06/04/2002 12:54:22 PM Subresponse :

Niagara indicators set during investigation.

Cause Codes ::

03g4 - Improper test equipment.

Corrective Actions identified during Investigation:

Action : Description : Done : Department : Due Date : CTS Number : CTS Tracked INVESTIGATED THE PROBLEM : Investigate cause of high as found reading, see the attachment. : Done : OPERATIONS

: :N Closure Comments:

This CA for Disposition was generated from ER Investigation information from the VY Niagara application on 10/30/2003.

ML070670306

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