ML20034C815
| ML20034C815 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/28/1990 |
| From: | Trout J ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#290-10311 OLA-4, NUDOCS 9005150093 | |
| Download: ML20034C815 (5) | |
Text
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nam 0 CORRESPONDENCE i
ropes & GRAY ONE INTERNATIONAL PLACE g
BOSTON, M ASSACH US ETTS O2110-2624 l
(617) 951 7000 i00s PENNsvLvaNiA Avt nut. N. W.
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April.28, 1990 1
Office of the Secretary U.S. Nuclear Regulatory Commission Washington,,D.C.
_20555 ATTENTION:
Docketing and Service Branch Re:
Vermont-Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station)
Docket No. 50-271-OLA-4 (Construction Period Recapture)
Dear Sir:
Enclosed please find Attachment.B to'" Interrogatories-Propounded by Vermont Yankee Nuclear Power Corporation to the State of Vermont-(Set No.
3)", which interrogatories were filed with you on-April 26, 1990.
Said Attachment B consists of pages' 12-15 of SALP' Report No. 50-271/88-89.
Please affix _this attachment to the interrogatories, as we hadLoriginally_ intended,
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but then inadvertently omitted,_to do.
Thank you for your assistance in this matter.
Very truly'yours,-
M J
f y P. Trout
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Service List
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ATTACH!ENT B l
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Maintenance /$urveillance(969 hours0.0112 days <br />0.269 hours <br />0.0016 weeks <br />3.687045e-4 months <br />,31%)
j III.C.1. Analysis 3
The crevious $Al.P report rated maintenance and surveillance performance as two distinct functional areas. Maintenance was rated as Category 2 with an improv-ing performance trend. The Maintenance program was considered a licensee l
strength as evidenced by high quality of craftsmanship and by overall plant reliability.
The Board recommended the. licensee review and. evaluate the root causes of balance of plant equipment induced reactor scrass and age-related l
equipment failures to identify possible underlying trends.
Surveillance was f
rated as Category 1.
The report concluded the in-service and nperational sur-L veillance programs remained an overall licensee strength. The Board recom-I mended the licensee expeditiously complete an independent surveiFisnee program i
verification audit.
Maintenance activities during routine powcr operations, short notice and un-I planned maintenance outages, as well as, refueling outages were reviewed during this assessment period. Additionally, an NRC Maintenance Team Inspection was l
conducted during the 1989 refueling outage.
The routine preventive and cor-rective mt.intenance programs continued to be effectively implemented, as evi-donced by high equipment availability, reliability and performance. Management maintained a low tolerance for degraded equipment and typically pursued conser-vative' resoluttor of maintenance deficiencies. The strength of the maintenance program is clearly derived from the individuals within the staff. The main-tenance organization is a highly stable, skilled and dedicat9d staff with ex '
tensive plant system knowledge. Maintenance personnel ensured work area clean-liness and restoration, thus perpetuating excellent plant housekeeping condi-tions. Transient equipment is typically obrerved to be propet;/ stowed and secured. Pride of owr.ership is obvious in the quality of wor a nship in daily activities.
l Plant management awareness of maintenance activities was evident during plant i
walk-downs and active involvement in the weekly coerations and daily outage meetings.
Similar corporate management involvement was noted periodically dur-ing routine operations and more frequently during outages and periods of sig-nificant activities. Recently, the licensee conducted two major self-initi-atives in the form of a Safety System Functional Inspection and an extensive maintenance program self-assessment. These initiatives have provided insight into potential programmatic and hardware improvements. Additionally, a com-puter based management data Avstem is being developed. Present projections estimate the system to be ful.ly functional by the end of 1991. These initi-atives are indicative of a continuing licensee commitment to improved main-tenanca program performance.
Engineering suppoi t to the maintenance process has been well integrated. The I&C and maintenance departments engineers typically effectively handled daily activities. Additional oft-site technical expertise is routinely provided by
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the engineering support department.
Further, engineering resources, as neces-sary, are provided by YNSD in Bolton, MA.
The licensee failure-mode analysis and root cause determination of inoperable equipment were deliberate and tech-nically sound.
The recent staffing of additional maintenance engineers has fur-l ther improved this function. The immediate benefit of increased resources has j
been realized in the identification and resolution of various HPCI and RCIC trip i
and throttle valve design deficiencies; investigation and analysis of the RHR service water valve stem failure; resolution of slow EDG starting times; as well as, a reduction in the backlog of root cause determinations.
These determina-i tions are typically accurate as indicated by a low incidence of repeat corrective maintenance activities. However, the licensee has been frustrated in attempts i
to increase the reliability and availability of the uninterruptible power supply i
sys+.em (UPS) and the toxic gas monitoring system (TGM). As a result of diverse random failures and poor design application, the Up$ system is scheduled to be i
replaced during the next refueling outage.
The recommendations of an !&C task l
force have been only partially successful in improving TGM performance. Addi-tionally, recurring reactor water cleanen (RCU) pump seal package failures have resulted in unanticipattd increased departmental man-rem exposures.
Extensive efforts tcward improved TGM system and RCU pump performance, as well as the I
commitment to replace the UPS system, were typical of a conservative licensee l
philosophy toward resolution of equipment reliability issues.
1 The staffing levels of the maintenance organization are sufficient to support activities during routine operations. Contractor and vendor experts are utt-lized for cutages and special projects.
Contractor and vendor training and CA programs were required to be consistent with those of VYNPC.
Departmental can-agement oversight of contractor and vendor activities was well maintained.
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Technical training programs have been properly implemented for maintenance an::
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!&C personnel.
Individual near and long term training objectives are clearly defined.
Recently, a mechanical and electrical laboratory within the training center conducted its initial training sessions.
A similar !&C laboratory is i
expected to be functional shortly.
These handeen facilities should enhance the quality of maintenance activities as well as provide potential reductions in man-rem exposures.
A previously identified deficiency was the lack of a program to ensure vender manuals were maintained accurate and current. This deficiency had been high-lighted in previous SALP reports and in the maintenance team inspection report.
l The licensee has since initiated an intensive program to establish vendor manual accuracy. The program ensures consistent control of the preparation, i-review, revision and approval of vendor provided technical information. At the conclusion of the assessment period, a dedicated contract engineering group had updated approximately two thirds of the vendor manuals.
The program is now well-defined and addresses this concern.
Maintenance activities were appropriately prioritized, scheduled, and performed in accordance with safety significance and-TS requirements.
Improved planning-l has greatly reduced the average preventive maintenance activity backlog.
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Throughout the assessment period, the licensee demonstrated the ability to accomplish a number of significant and, diverse maintenance activities during i
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short notice outages and power reductions to perform corrective maintenance.
Additionally, the maintenance department performed well during the five Unusual Events declared during this assessment period.
In each instance, failed equip-ment was expeditiously repaired and returned to service and the event was ter-minated prior to appreciable power reduction.
The maintenance organization continued to exhibit generally excellent perform-ance in outage activities, in addition to completing scheduled activities in a quality manner, the maintenance organization demonstrated the abiltty to effec-tively dispose of major emergent work issues.
The licensee appropriately re-vised critical path schedules and performed comprehensive engineering evalu-division plate inspection and repairs, feedwater check valve s cracking analysis, and various RHR service water valve repairs. Excalient external and interdepartmental communications were evident during complex acti-vities.
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I Notwithstanding excellent personnel and a good equipment and system reliability record, the maintenance program lacks a formal, conprehensive plan that clearly documents program policies, responsibilities, and objectives.
Absence of a plan hampers the licensee ability to provide a consinent approach to mainten-ance activities and to establish a baseline for determining prrgram effective-By the end of the assessment period, the licensee had osveloped and sub-ness.
stantially documented a formal program plan.
Surveillance activities inspected this assessment period included routine test-ing, calibration control programs, control of. measuring and test equipment, and containment integrated and local leak rate test programs.
The surveillance program continued to be well controlled and properly imple-mented.
Surveillance procedures were technically accurate and provided suffi-cient instruction to help assure proper performance.
The biennial procedure review program helped ensure adherence to TS requirements and the incorpora-tion of content and format upgrades.
accessible and complete.
Quality records were properly maintained, Surveillance prnedures were performed by highly experianced and knowledgeable personnel who demonstrated extensive understanding of component and instrument operations.
A consistently high level of attention to detail and procedural compliance was demonstrated with a noteworthy lack of personnel errors.
plant conditions and prerequisites were established. interdepartmental 4
Supervisory assistance was observed to be readily available to field technicians throughout surveil-lance activities.
Responsibilities for the IST program were reorganized during the assessment I
period.
Responsibilities for data acquisition and evaluation were more clearly j
defined.
The reorganizattom in conjunction with improved test instrumenta-tion, has resulted in consisunt data acquisition techniques with increased accuracy, as well as more meaningful data reduction and preventive maintenance l
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I 15 recommendations. Additionally, the valve inspection program was further re-fined. Particular improvements were obtained in the area of check valve in-spection.
The licensee aggressively pursued the previous $ ALP recommendation to complete a surveillance program review. During the assessment period, a comprehensive 100% audit of technical specification surveillances was conducted by an inde-pendent organization.
The licensee expeditiously addressed and corrected the the deficiencies identified by the audit. These deficiencies were primarily surveillance program administrative weaknesses rather than technical inade-quacies.
In conclusion, the maintenance and surveillance programs remained Itcensee strengths. The maintenance organization continues to be comprised of experi-enced and highly dedicated personnel. Management routinely demonstrated a con-servative approach to maintenance issues.
Increased staffing of maintenance engineers has improved design reviews, causal and failure analyses, and reduced work effort backlogs.
Superior performance during short netice and refueling activities continued to be a licensee strength. "he surveillance program con-tinued to be well implemented.
The minimal incidence of personnel errors re-flected an extremely knowledgeable, dedicated, and alart staff.
Incorporation of the surveillance audit corrective actions have further enhanced the admini-stration of the surveillance program.
Ill.C.2. performance Ratino: Category 1
!!!.C.3. Recommendations Licensee: None.
NRC:
- None, i
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