ML20045A565
| ML20045A565 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/04/1993 |
| From: | Conte R, Walker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20045A555 | List: |
| References | |
| 50-271-93-12, NUDOCS 9306110068 | |
| Download: ML20045A565 (22) | |
See also: IR 05000271/1993012
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
VERMONT YANKEE NUCLEAR POWER STATION
EMERGENCY OPERATING PROCEDURE INSPECTION
REPORT NO:
93-12
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FACILITY DOCKET NO: 50-271
FACILITY LICENSE NO: DPR-28
LICENSEE:
Vermont Yankee Nuclear Power Corporation
Ferry Road
Brattleboro, VT 05301-7002
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FACILITY:
Vermont Yankee Nuclear Power Station
INSPECTION AT:
Vernon, Vermont
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INSPECTION DATES:
May 11 - 12,1993
INSPECTORS:
S. Hansell, Operations Engineer
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LEAD INSPECTOR:
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/f. Walk 8r, Senior Operations Engineer
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APPROVED BY:
Richard J. Conte, dtief, BWR Section
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Operations Branch, DRS
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9306110068 930604-
ADDCK 05000271
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EXECUTIVE SUMMARY
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This was a special announced inspection of the Vermont Yankee Emergency Operating
Procedures (EOPs). The objectives of the inspection were to address the open items
associated with the EOPs identified in Inspection Report No. 50-271/92-80 and to review the
licensee's actions in response to discrepancies related to jet pump operability testing
identified in Examination Report No. 50-271/93-03.
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In general, the Vermont Yankee EOPs and Plant Specific Technical Guidelines (PSTGs) were
found to be technically adequate. The licensee corrected the majority of the previous
concerns related to the technical adequacy of the PSTGs, EOPs, and EOP support
procedures. Most of the outstanding concerns were not significant, and licensee
representatives committed to correct the identified problems. The licensee corrected the
human factors weakness and some of the technical adequacy concerns related to the
implementation of the RPV Control guideline. However, concerns still exist related to
implementation of the RPV Pressure Control mitigation strategy for conditions that require
entry into RPV Control. Two of the three unresolved items associated with the technical
adequacy of the VY PSTGs and EOPs were closed based on the progress made by the
licensee. The unresolved item associated with the implementation of the RPV Control
guideline remains open due to the concerns related to the implementation of the RPV
Pressure Control accident mitigation strategy.
The licensee revised the Procedure Geaeration Package (PGP) to formalize some of the items
that were noted as weaknesses during the previous EOP inspection. The Writers' Guide and
verification and validation (V&V) program were revised to address EOP support procedures.
The V&V that was performed for the latest revision to the EOPs and support procedures
appears to have been effective. The QA involvement in the EOP program, the qualifications
of the personnel involved in the V&V process, and the comprehensiveness of the latest
revision to the EOPs and support procedures displayed the importance that the licensee places
on providing quality procedures for implementation of their accident mitigation strategies.
The unresolved item related to the informality of the V&V program and the weaknesses
associated with control of the EOP support procedures was closed.
The licensee has taken effective corrective actions to improve the administrative controls for
ensuring that tools and materials are available for implementation of the EOPs. All required
tools and materials were available at the time of the inspection and positive controls have
been established to ensure that they will be available if needed. The unresolved item
associated with the control of EOP tools and materials was closed.
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The licensee failed to fully complete a jet pump technical specification (TS) surveillance
requirement during single loop operations in November 1992. The surveillance procedure
did not contain appropriate acceptance criteria and instructions to ensure that the TS
requirements were met. This was determined to be a violation of NRC requirements (section
5). There was no threat to public health and safety due to the failure to complete the
surveillance; however, the inadequate surveillance procedure was significant, especially in
light of previous weaknesses in that area. The short term corrective actions taken by the
licensee to revise the procedure appear to be appropriate.
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DETAILS
1.0
INTRODUCTION
In February 1992, an NRC inspection team evaluated the Vermont Yankee Emergency
Operating Procedures (EOPs) to determine if the EOPs were technically adequate and could
be carried out in the plant by the plant staff. The team also evaluated the programmatic
controls for maintaining the EOPs. In general, the VY Plant Specific Technical Guidelines
(PSTGs) and EOPs were found to be technically adequate; however, discrepancies were
identified in the PSTGs and EOPs that detracted from the technical adequacy of the VY
accident mitigation strategies. Weaknesses in the programmatic controls for development and
maintenance of the EOPs resulted in EOP appendices and support procedures that were not
of the same high quality as the flowchart EOPs. Additionally, programmatic controls were
not effective for ensuring that tools and materials would be available to support
implementation of the EOP support procedures. The results of the team inspection are
documented in Inspection Report No. 50-271/92-80.
The NRC team identified three unresolved items associated with the technical adequacy of
the Vermont Yankee EOPs and two unresolved items associated with the EOP programmatic
controls. The licensee responded to these items in a letter dated June 22,1992. A meeting
was held in the NRC Region I office on July 14,1992, at the request of the licensee, to .
discuss the issues and concerns identified during the team inspection. As a result of the
meeting, the licensee provided a revised response, dated October 13, 1992, which provided
additional information on the specific actions to be taken on the issues.
During initial operator licensing examinations in February 1993, the NRC raised several
questions related to the Technical Specifications (TS) and surveillance procedures for jet
pump operability testing. Licensee representatives acknowledged that there were
inconsistencies between the TS surveillance requirements, the TS Bases, and the surveillance
procedures and committed to correct the identified discrepancies. While researching the
responses to the NRC questions, the licensee identified that a required surveillance for jet
pumps in the idle loop during single loop operation was not performed in accordance with
Technical Specifications. The missed surveillance is documented in Licensee Event Report
(LER) 93-04. The discrepancies related tojet pump operability testing were considered an
unresolved item and are documented in Examination Report 50-271/93-03.
The purpose of this inspection, conducted May 11 - 12,1993, was to address the unresolved
items identified in the February 1992 EOP inspection and to review the licensee's actions in
response to discrepancies related to jet pump operability testing.
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2.0
PERSONS CONTACTED
Vermont Yankee Nuclear Power Corocration
R. J. Wanczyk, Plant Manager
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J. T. Herron, Technical Services Superintendent
R. E. Sotus, Operations Support Manager
R. Gippardi, Quality Assurance Supervisor
M. Benoit, Reactor and Computer Engineering Manager
M. E. Palionis, Senior Operations Engineer
C. Cameron, Senior Reactor Engineer
J. Brooks, Shift Engineer
R. McCullough, Operations Experience Coordinator
A. Wonderlick, YNSD Quality Support Group
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S. Jefferson, Assistant to Plant Manager
The inspectors also held discussions with licensed operators during the inspection.
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Nuclear Regulatory Commission
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P. Harris, Resident Inspector
- Denotes those present for the exit meeting on May 12, 1993.
3.0
TECIINICAL ADEQUACY OF THE EOPS
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Scope
The inspectors reviewed the licensee's responses to the unresolved items related to the
technical adequacy of the PSTGs, EOPs, and support procedures identified in Inspection
Report 50-271/92-80. This review included a review of selected portions of the VY PSTG,
differences documentation, flowchart EOPs, EOP appendices (OE appendices), and other
support procedures. The documents reviewed are listed in Attachment 1. The licensee's
specific response to the NRC comments related to technical adequacy of the EOPs is
included as Attachment 2.
The inspectors walked down the OE appendices indicated in Attachment 1 to ensure that the
procedures are technically adequate to accomplish the intended tasks. The walkdowns were
conducted with a licensed Senior Reactor Operator (SRO) recently trained on the revised
procedures. Licensed operators were also interviewed to assess some of the concerns
identified during the desk top review of the PSTG and EOPs.
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Findings
3.1
Technical Adequacy of PSTGs
(Closed) Unresolved item (271/92-80-01): Technical adequacy of the VY PSTGs, including
the adequacy of the justification for deviations from the BWR Owners' Group (BWROG)
Emergency Procedure Guidelines (EPGs). The majority of the previously identified concerns
have been corrected. Licensee representatives committed to revise several inconsistencies
and typographical errors that the NRC identified in the PSTGs and differences
documentation. The most significant of these items were inconsistencies associated with the
strategy for purging the primary containment for hydrogen control. This unresolved item is
closed based on the progress made by the licensee and the commitment to correct the
outstanding discrepancies (271/92-80-01).
3.2
Technical Adequacy of EOPs and Support Procedures
(Closed) Unresolved item (271/92-80-03): Technical adequacy of the VY EOPs and EOP
support procedures, including the inconsistencies between the VY PSTGs and the EOPs.
The majority of the previously identified concerns have been corrected. Licensee
representatives agreed to correct inconsistencies between the PSTGs and the EOPs in the
primary containment pressure control leg. This unresolved item is closed based on the
progress made by the licensee (271/92-80-03).
The licensee plans to change the drywell high water level alarm setpoint to provide indication
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that will allow the operator to maintain adequate core cooling by core submergence utilizing
the Primary Containment Flooding procedure without challenging primary containment
structural integrity. A new transmitter is required before the setpoint change can be
performed. At the time of the inspection, a Setpoint Change Request had been initiated and
a new transmitter was in receipt inspection.
During review of the previously identified NRC concerns, the licensee's response to one of
the items did not appear to be adequate. During the previous NRC inspection, the NRC staff
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was concerned that OP 2124, " Residual Heat Removal System," did not provide direction to
inject LPCI through the heat exchangers as soon as conditions permit as indicated in the
differences documentation. The licensee did not take any specific action to address this
concern. The step in OP 2124 that licensee representatives indicated provides the direction
does not direct action. The step describes when the heat exchanger bypass valve can be
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throttled, but does not direct action to direct flow through the heat exchanger as soon as
conditions permit as intended by the PSTG. The inspector was also concerned that operators
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would not normally refer to the system operating procedure to inject with LPCI in an
emergency situation. To address this concern, licensed operators were questioned on how
they would operate the RHR System if directed to inject with LPCI. An SRO indicated that
he would not expect an RO to refer to the system operating procedure or ask for direction on
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how to operate RHR when directed to inject with LPCI in an emergency. He indicated that,
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if asked for guidance, he would not direct actions to throttle the heat exchanger bypass until
initiating a cooldown and that he would not expect an RO to throttle the bypass unless
directed. An RO indicated that he would not throttle the heat exchanger bypass valve unless
specifically directed by the SRO. These responses indicated that the intent of the PSTG, to
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inject through the heat exchangers as soon as possible when injecting with LPCI, would not
be met.
3.3
RPV Control Guideline Implementation
(Open) Unresolved Item (271/92-804)2): Problems with the implementation of the RPV
Control guideline. The licensee removed the note from OE 3100, " Scram Procedure," which
allowed unlimited deviations in procedure adherence. This corrected the previously
identified human factors weakness and allowed the logic of the PSTG to be preserved in OE
3100. The licensee also corrected some of the previously identified technical adequacy
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concerns by adding overrides to OE 3100 End specifying RPV level not determined as a
scram condition. However, the licensee did not correct some of the problems associated
with implementation of the RPV pressure control strategy. This item remains unresolved due
to the problems discussed below (271/92-80-02).
The flowchart EOPs, OE 3100, " Scram Procedure," and OE 3101, "RPV Control
Procedure," implement the RPV Control guideline. OE 3101 implements the RPV Control
guideline when RPV water level cannot be determined or cannot be maintained above 127"
or when a scram condition occurs and reactor power remains above 2% or cannot be
determined. All other conditions and all transitions from other guidelines that require entry
into the RPV Control guideline are implemented by entry into OE 3100.
VY PSTG step RC/P-3 directs RPV depressurization when it can be determined that the
reactor will remain shutdown when implementing the RPV Control guideline. OE 3100 does
not contain direction to depressurize the RPV. Instead OE 3100 directs entry into OP 0109,
" Plant Restoration," which provides direction for RPV depressurization. OP 0109 cannot be
entered until RPV water level has been restored between 127" and 177" (the normal control
band). This conflicts with the logic of the PSTG, which does not require that RPV water
level be restored to normal prior to RPV depressurization. The justification for
implementation of the RPV Control guideline in OE 3100 does not indicate that OP 0109
provides the direction to depressurize the RPV, and there is no specific justification for
deviations in the implementation of PSTG step RC/P-3.
The VY PSTGs specify that the RPV Water Level Control (RC/L), RPV Pressure Control
(RC/P), and RPV Power Control (RC/Q) steps are to be executed concurrently, irrespective
of the entry conditions, whenever the RPV Control guideline is entered. OE 3100 is a series
flowpath, which does not allow concurrent execution of the RC/L, RC/P, and RC/Q steps.
The licensee's justification for the differences between the PSTGs and the EOPs in the
implementation of the RPV Control guideline state that the accident mitigation strategy is
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preserved because conditions that warrant parallel parameter control cause entry into OE
3101 either concurrently with the scram procedure or very rapidly after entry of the scram
procedure. The differences documentation does not indicate that any technical analysis was
performed to justify this statement. It is not clear which conditions warrant parallel
parameter control and how the licensee determined that the accident mitigation strategy is
preserved for all conditions which require entry into RPV Control.
Appendix B of the BWROG EPGs indicates that the symptomatic approach to emergency
response, upon which the EPGs are based, precludes being able to establish in advance a
priority for executing any of the parallel action paths of the RPV Control guideline. The
implementation of the RPV Control guideline in the VY EOPs does not allow the operator to
prioritize the action paths for all conditions that require entry into the RPV Control
guideline.
In the case of RPV Pressure Control, the implementation in OE 3100 and OP 0109 does not
lead the operator to the direction to depressurize as expeditiously as the accident mitigation
strategy described in the VY PSTGs. The direction to depressurize the RPV is the tenth step .
in OP 0109, following actions to secure the turbine, reset the scram and PCIS isolatieis, and
maintain condenser vacuum, etc.. The operator must work through the entire OE 3100
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flowchart (a minimum of 18 steps and decision blocks), obtain a copy of OP 0109, and work
through the precautions; prerequisites; and first nine steps of OP 0109 before being directed
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to depressurize the RPV. There is no justification in the differences documentation that
describes why this method of implementation of the RPV pressure control strategy is
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preferable (or at least equivalent) to the mitigation strategy of the PSTG.
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Licensee representatives committed to remove the requirement for RPV water level to be
restored below 177" as an entry condition into OP 0109. This would remove the specific
concern related to preservation of the PSTG logic for step RC/P-3; however, the concerns
related to concurrent parameter control and prioritization of RPV Pressure Control would
still remain. The justification for the differences between the VY PSTGs and the EOPs in
the implementation of the RPV Control guideline, specifically with respect to RPV Pressure
Control, is not adequate.
Conclusion
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The licensee corrected the majority of the previous concerns related to the technical adequacy
of the PSTGs, EOPs, and EOP support procedures. Most of the outstanding concerns were
not significant and licensee representatives committed to correct the identified problems. The
licensee corrected the human factors weakness and some of the technical adequacy concerns
related to the implementation of the RPV Control guideline. However, concerns still exist
related to implementation of the RPV Pressure Control mitigation strategy for conditions that
require entry into RPV Control.
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4.0
EOP PROGRAMMATIC CONTROLS
Scope
The inspectors reviewed the licensee's responses to the unresolved items related to the EOP
programmatic controls identified in Inspection Report 50-271/92-80. This review included a
review of selected portions of the VY Procedure Generation Package (PGP), which includes
the PSTGs; differences documentation; OE Flowchart and Text Procedures Writer's Guide;
and descriptions of the Verification and Validation (V&V) programs. In order to evaluate
the licensee's V&V process, the inspectors reviewed the results of the verification and
validation of the latest revision to the EOPs and support procedures. The documents
reviewed are listed in Attachment 1. The inspectors also discussed the V&V process with
licensee personnel that are responsible for the program.
The walkdown of the OE appendices (indicated in Attachment 1) was also used to assess the
effectiveness of the V&V process and to verify that the tools required to perform the tasks
were identified and available. The inspector and operator inventoried all four of the EOP
tool boxes to ensure the equipment was available to perform each EOP task.
Findings
4.1
Verification and Validation Program
(Closed) Unresolved Item (271/92-80-04): Informality of the V&V program and weaknesses
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associated with control of the EOP support procedures. The EOP team inspection identified
that the documented V&V process did not formally address some of the important
components of an effective V&V program and that the programmatic controls for the EOP
support procedures were inadequate.
The NRC staff noted that there was no requirement for a multi-disciplined approach and no
mention of human factors involvement in the V&V process. The VY PGP was revised to
indicate that the Operations Manager will assign the tasks of verification and validation to
individuals representing various disciplines to ensure the correct level of expertise is applied.
The specific disciplines assigned to the validation are specified on the procedure revision
checklists. Licensee representatives indicated that the specific disciplines did not need to be
specified for verification because various disciplines were involved in the development of the
Writers' Guide. Personnel from operations, engineering, I&C, training, and Quality
Assurance (QA) were involved in the V&V of the latest revision to the EOPs and support
procedures. Additionally, human factors and technical contractors were used in the
verification process.
During the previous inspection, the NRC staff was also concerned that the PGP did not
require that the V&V evaluators be independent from the OE writer. The licensee did not
specifically address this concern; however, the review of the V&V results indicated that a
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more thorough review of the comment disposition was done than had been performed for
previous revisions.
During the team inspection, the NRC staff noted that the VY PGP did not provide specific
instructions for V&V of the OE Appendices and that it was silent on V&V to be conducted
on procedures referenced by the OEs and OE Appendices. Additionally, the OE Writers'
Guide did not address text procedures; and, therefore, did not apply to the OE Appendices
and other EOP support procedures. The VY PGP was revised to include guidance for
performing verification and validation of the OE Appendices and other support procedures.
The Writers' Guide was revised to include Fuldance for text procedures. The licensee also
developed a " Support Procedure Revision Checklist" to ensure that the programmatic controls
are addressed and dispositioned during the revision process. These revisions appeared to
address adequately the NRC staff's concerns except that the " Support Procedure Revision
Checklist" is not referenced in the body of the PGP. There was no clear defmition of which
procedures would require use of this checklist. Licensee representatives indicated that
because all procedure revisions must go through the Operations Department, Operations
Department supervision would ensure that the checklist was used for all EOP support
procedures.
Verification and validation of the revised OE appendices and support procedures was
accomplished by a Quality Assurance (QA) surveillance. The QA surve:llance report
followed the V&V criteria contained in the Vermont Yankee PGP. The QA surveillance was
performed by a site QA engineer with operations experience and a human factors contractor.
The QA personnel performed a comprehensive detailui review of the revised EOPs. The
QA verification and validation found approximately 255 items for review and resolution to
improve the EOP procedures. The majority of the items were minor changes to improve
human factors aspects of the OEs. The NRC staff review and walkdown of the OE
Appendices did not reveal any new discrepancies when compared to the QA surveillance
findings. The QA department is in the process of resolving the EOP V&V fmdings with the
operations personnel responsible for maintaining the EOPs. The QA department has a
" Surveillance item Status Report" program to track the resolution of the EOP V&V findings.
During the team inspection, the team members discerned a view among licensee personnel
that, because the EOPs, especially the appendices and other support procedures, address
situations that go beyond the design basis of the plant and have a low probability of
occurrence, they did not need to be controlled at the same level as other procedures. A
contributor to this view was the concern that the Accident Management Guidelines, which
include guidelines for containment venting to support the EOPs, had not been revised for
seveml years and that no verification and validation had been done on the guidelines. The
liceae recently revised the Accident Management Guidelines and performed the applicable
aspects of V&V on the revised guidelines. An SRO reviewed the vent lineups, and a
Probabilistic Risk Assessment (PRA) expert was involved in the revision process. Revision
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of these guidelines indicated that the licensee recognized the value of developing and
maintaining high quality procedures to implement their accident mitigation strategies,
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including those that address situations beyond the design basis of the plant.
The review of the technical adequacy issues from the previous inspection identified that the
majority of the concerns, with the exception of the concerns related to implementation of the
RPV Pressure Control strategy, were effectively resolved. Additionally, a number of
discrepancies identified by the NRC staff in-office review of the PSTGs and procedures were
identified by the licensee's V&V process and corrected before the on-site inspection. During
the walkdown of the OE Appendices, the operator was able to perform or simulate all
procedure steps needed to complete each task successfully. The directions were written in a
logical and easy to use format. These findings indicated that the revisions that were made to
the V&V program were effective. The unresolved item related to the informality of the
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V&V program and weaknesses associated with the control of the EOP support procedures is
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closed based on these findings.
4.2
Tools and Materials
(Closed) Unresolved Item (271/92-80-05): Weaknesses in the licensee's programmatic
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controls for ensoring that tools and materials are available for implementation of the EOPs.
The previous EOP inspection noted that some EOP equipment and material was not stored in
the required location. For example, the required amounts of boric acid and borax for
alternate boron injection were not available on site. The toolbox in the Reactor Building,
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which contains tools and materials needed to accomplish EOP support procedures, was not
inventoried on a periodic basis. Additionally, there were no positive controls (e.g., lock or
cable-tie) on any of the EOP toolboxes.
The required quantities of boric acid and boric are now stored in a locked cage in +e
Reactor Building. All OE Appendices were reviewed and revised as necessary for tools and
equipment required for performance. During the walkdowns, all required tools and
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equipment were in the correct location, as described in the procedures. The tool boxes were
controlled with locks and tamper detection devices and included a list of contents. The EOP
tool boxes located in the Reactor Building were added to the operations surveillance report
schedule. All of the EOP equipment storage areas are now scheduled to be inventoried twice
a year. Based on the corrective actions taken by the licensee and the observations during this
inspection, this item is closed.
4.3
EOP Labelling
During the walkdowns of the OE appendices, the inspector assessed the labelling used for
EOP components. The EOP valve labels in the plant were easy to read and were
appropriately human factored. For example, all labels contain the valve information on the -
front and back of the label plate. The equipment descriptions in the procedures matched the
existing plant and control room labelling word for word except for one minor discrepancy.
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Appendix CC, "RPV Venting Via MSIVs," step 11, references use of " main turbine inlet
pressure" on control room panel (CRP) 9-7 to equalize and open the main steam isolation
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valves (MSIVs). The operators stated they would use pressure indicator PI-101-2, " main
steam pressure," on CRP 9-7 to satisfy the procedure condition. The facility's validation of
OE Appendix CC noted the same discrepancy.
Equipment in the control room electrical panels used for EOP evolutions was not labelled as
well as the plant equipment. The operator had no problem finding the correct terminal
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boards to install bypass jumpers in the control room. However, the licensee has recognized
that specific EOP labelling in the electrical panels may reduce the time required and
possibility for an error when performing emergency tasks. The licensee has submitted a
work order to upgrade the EOP labelling by installing banana plugs in the electrical panels.
Conclusion
The licensee revised the PGP to formalize some of the items that were noted as weaknesses
during the previous EOP inspection. The Writers' Guide and V&V program were revised to
address EOP support procedures. The V&V that was performed for the latest revision to the
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EOPs, PSTOs, and differences documentation appears to have been effective. The QA
personnel performed a comprehensive and detailed V&V of the revised OE appendices and
other support procedures. The QA involvement in the EOP program, the qualifications of
the personnel involved in the V&V process, and the comprehensiveness of the latest revision
to the EOPs and support procedures displayed the importance that the licensee places on
providing quality procedures for implementation of their accident mitigation strategies.
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The inspectors concluded that the licensee has taken effective corrective actions to improve
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the administrative controls for ensuring that tools and materials are available for
implementation of the EOPs. All required tools and materials were available at the time of -
the inspection and positive controls have been established to ensure that they will be available
if needed.
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5.0
JET PUMP OPERAllILITY
Scope
The inspectors reviewed the licensee's corrective actions taken in response to a jet pump
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surveillance that was not performed during single loop operations (SLO). This review-
included a review of procedure revisions and previous LERs. The inspector also held
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discussions with personnel responsible forjet pump operability testing. The documents
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reviewed are listed in Attachment 1.
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Findings
(Closed) Unresolved item (271/93-03-01): Discrepancies related to jet pump operability
testing. In November 1992, the plant was in single recirculation loop operation for several
days. Technical Specification (TS) 4.6.F.2 requires diffuser to lower plenum differential
pressure to be checked daily when operating with one recirculation pump and that the
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differential pressure of any jet pump in the idle loop shall not vary by more than 10% from
established patterns. The data was collected; however, baseline curves (established patterns)
were not established. The licensee reported that the surveillance was not performed in
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accordance with Technical Specifications in LER 93-04. They indicated that the root cause
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of the event was that TS 4.6.F.2 was ambiguous in that it does not define what is meant by
" established patterns." They cited an inadequate procedure as a contributing cause because
the surveillance procedure also did not define " established patterns."
OP 4110, " Reactor Recirc System Surveillance," Rev.17, did not contain appropriate
acceptance criteria for determining that the surveillance requirements of TS 4.6.F.2 were
met. The acceptance criteria in OP 4110 stated that "the idle loop jet pumps do not differ by
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more than 10% from established (i.e., average) patterns." Section C of form VYOPF
4110.04, " Jet Pump Operability Checks," contained a place to record average differential
pressure for the idle loop, but no instructions for use of the data were provided. The
procedure section of OP 4110 did not clearly defm' e which portions of VYOPF 4110.0A were
required to be performed. VYOPF 4110.04 had a signoff for performance by the operator
and review by the Shift Supervisor; however, there was no place to indicate that the relevant
acceptance criteria had been met. During SLO in November 1992, the differential pressures
for all of the jet pumps, including those in the idle loop, were recorded as part of the daily
operability check, but the average differential pressure of tl e jet pumps in the idle loop was
not recorded in some cases.
TS 4.6.F.3 requires that the baseline data required to evaluate the conditions in TS 4.6.F.1
and TS 4.6.F.2 be acquired each operating cycle. OP 4110 contained a note which stated
that, "should Vermont Yankee operate with a single recirculation pump in service, the data
recorded at that time will determine the corresponding values for that condition." However,
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this instruction was not adequate to ensure that the baseline data for determining jet pump
operability during single loop operation was acquired. No basehne pattern was established
during SLO in November 1992.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be
prescribed by documented instructions, procedures, or drawings, of a type appropriate to the
circumstances and that the instructions, procedures, or drawings shall include appropriate
quantitative or qualitative acceptance criteria for determining that important activities have
been satisfactorily accomplished. The licensee is responsible for ensuring that written
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instructions are provided for completing Technical Specification surveillance requirements.
Failure to provide adequate written instructions for the completion of TS surveillance
requirements 4.6.F.2 and 4.6.F.3 was determined to be a violation of 10 CFR 50, Appendix
B, Criterion V (271/93-12-01).
Review of previous LERs identified two instances in which TS surveillance requirements
were not met due to inadequate procedures (LER 91-03 and LER 91-04). In one of these
cases, the inadequate procedures were identified as a result of corrective actions to address a
weakness in establishing surveillances to fully meet Technical Specification surveillance .
requirements. Changes were made to the VY Procedure Writer's Guide applicable to
surveillance procedures including: (1) delineating the specific sections of the procedure that
satisfy TS requirements; (2) department supervisor review of results to ensure the TS
requirements are met; and (3) review of the procedure relative to the specific Technical
Specification requirement being satisfied to ensure compliance. These enhancements to the
Writers' Guide should have prevented the failure to complete the jet pump surveillance
during SLO when OP 4110 was revised in July 1991 during the periodic procede c review
process.
In their analysis of the event in LER 93-04, the licensee indicated that there was no threat to
the health and safety of the public due to the failure to perform thejet pump surveillance
during single loop operation. This determination was based on the fact that jet pump
integrity was confirmed for the jet pumps in the active loop during SLO and for all jet pumps
prior to entry into SLO and following restart of the idle recirc pump. GE SIL-517 indicates
that the surveillances on jet pumps in an idle loop are not required due to low stress on the
jet pump beam when the pumps are not operating. The licensee intends to request a TS
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revision to delete TS 4.6.F.2. Regardless of this, the failure to provide adequate procedures
to complete Technical Specification surveillance requirements is significant, especially in
light of the previous weaknesses in this area. Additionally, the licensee's identification of an
ambiguous Technical Specification as the root cause of the event indicates a lack of
understanding of the significance of the event.
The licensee revised OP 4110 to address the missed jet pump operability surveillance and to
clarify the relationship between the steps in the procedure section and the steps in the form
that is used to perform the jet pump operability surveillances. The body of OP 4110 was
revised to specify the specific sections of form VYOPF 4110.04 that should be performed for.
,
each jet pump surveillance. Form VYOPF 4110.04 was reformatted to include specific
instructions for TS surveillance compliance, data analysis, and acceptance criteria.
Additionally, form VYOPF 4110.04 was revised to require an entry by the operator for each
relevant acceptance criteria. OP 2428, " Single Loop Operation," was also revised to provide
instructions for Reactor Engineering to determine the established patterns of differential
pressure in the jet pumps in the idle recirc loop. These corrective actions appeared to be
appropriate to ensure that jet pump operability testing will be completed in accordance with
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Technical Specifications with the exception that the revised OP 4110 did not reference OP
2428 as required by the VY Procedure Writer's Guide. The unresolved item related to
discrepancies in jet pump operability testing is closed, based on the actions of the licensee.
Conclusion
The licensee failed to fully complete a jet pump surveillance requirement during single loop
operations in November 1992. The surveillance procedure did not contain appropriate
acceptance criteria and instructions to ensure that the TS requirements were met. This was
determined to be a violation of NRC requirements. There was no threat to public health and
safety due to the failure to complete the surveillance; however, the inadequate surveillance
procedure was significant, especially in light of previous weaknesses in that area. The short
term corrective actions taken by the licensee to revise the procedure appear to be
appropriate.
6.0
EXIT MEFTING
Management was informed of the purpose and scope of the inspection at the entrance
interview on May 11, 1993. The findings of the inspection were summarized at the exit
meeting on May 12, 1993. Licensee representatives were informed that four of the five
unresolved items related to the EOPs would be closed. The unresolved item related to the
implementation of the RPV Control guideline would remain open pending further review.
The failure to complete the jet pump surveillance during SLO was an apparent violation due
to inadequate procedures.
Attendees at the exit meeting are listed in section 2.0 of this report.
Attachments:
1. Documents Reviewed
2. Licensee Specific Response to NRC Comments
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A'ITACIIMENT 1
Documents Reviewed
Flowchart EOPs
OE 3100, " Scram Procedure," Rev. 8
OE 3101, "RPV Control Procedure, " Rev. 8
OE 3102, " Alternate Level Control," Rev. 9
OE 3103, "Drywell Pressure, Temperature and Hydrogen Control
Procedure," Rev. 9
OE 3104, " Torus Temperature and Level Control Procedure," Rev. 8
OE 3105, " Secondary Containment Control Procedure," Rev.10
OE 3106, " Radioactivity Release Control Procedure," Rev.1
EOP Support Procedures
OE 3107, "OE Appendices," Rev. 2
Appendix A, " Scram Conditions"
Appendix D, " Manual Isolation and Venting of the Scram Air Header"
Appendix F, " Initiation of a Manual Scram
Appendix I, " local Firing of Squib Valve"
Appendix BB, " Insertion of Control Rods Using Cooling Water Differential Pressure"
Appendix CC, "RPV Venting via MSIVs"
Appendix DD, "RPV Venting via MSL Drains"
Appendix EE, "RPV Venting via HPCI"
Appendix DD, "RPV Venting via RCIC"
OP 0109, " Plant Restoration," Rev. 7
OP 2116, " Secondary Containment Integrity Control," Rev.15
OP 2124, " Residual Heat Removal System," Rev. 29
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OP 2136, " Reactor Building and Containment Airborne Radiation
Monitoring System," Rev.14
ON 3153, " Excessive Radiation Levels," Rev. 8
ON 3158, " Reactor Building High Area Temperature / Water Level," Rev. 7
Alarm Response Sheets:
3-E-1, "RX BLDG RAD HI-HI"
3-E-3, "RX BLDG RAD HI"
3-E-4, ." REFUEL FLOOR RAD HI"
3-E-5, "NW FUEL STOR RAD HIGH"
4-L-6, "RX BLDG FLOOR DRN SUMP SOUTH LVL HI"
4-M-6, "RX BLDG FLOOR DRN SUMP NORTH LVL HI"
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VY Accident Management Guideline
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Attachment 1
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Other Procedures
OP 4110 " Reactor Recirc System Surveillance," Rev.17 and Rev.19
OP 2428, " Single Loop Operation," Rev. 8
Other
Vermont Yankee Procedure Generation Package, Rev. 8
Appendix A, " Plant Specific Emergency Procedure Technical Guidelines"
Appendix B, " Operational Emergency Flowchart and Text Formatted Procedures
Writer's Guide"
Appendix C, "OE and Supporting Procedure Verification Methods"
Appendix D, "OE and Support Procedure Validation Methods"
Appendix E, "EPG to PSTG Differences (Diff-1)"
Appendix F, "PSTG to OE Differences (Diff-2)
Vermont Yankee Procedure Writer's Guide, Rev 5
Vermont Yankee Procedure Generation Package Review, Ciel Consultants,
January 1993
Vermont Yankee OE Table Top Validation (3 Scenarios)
Quality Assurance Surveillance Report No. 93-11, " Emergency Operating Procedures
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Appendices and Support Procedure Verification and Validation"
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Memo JCB/MEP/TWJ to PORC, dated 2/25/93, " Vermont Yankee Procedure'
Generation Package (PGP)," Rev. 8
Memo J. C. Brooks /M. E. Palionis to PORC, dated 2/27/93, OE 3107, "OE
Appendices," Rev. 2
Memo J. Brooks to L. Doane, dated 4/17/93, "Use of Jumpers in the EOP
Appendices"
Memo M. M. Houle to J. M. Devincentis, dated 2/16/93, "VY Procedure Writer's Guide,"
Rev. 5
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Attachment 1
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Memo CB Cameron to R. J. Wanczyk, dated 3/9/93, " Responses to NRC Questions on Jet
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Pump Operability"
Memo M. E. Palionis to PORC, dated 4/21/93, OP 4110, " Reactor Recire System
Surveillance," Rev.19
LER 93-04, dated 3/25/93, Jet Pump Surveillance not Performed during Single Loop
Operations as Required by Technical Specifications Due to an Ambiguous Technical
Specification Requirement
LER 91-03, dated 3/26/91, " Missed Diesel Fire Pump Fuel Oil Surveillance due to an
Inadequate Procedure"
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LER 91-04, dated 3/29/91, " Incomplete Surveillance Testing of Reactor Protective System -
Logic Instrument Channels due to Inadequate Procedures"
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SPECIFIC RESPONSE TO NRC COMMENTS
REVISED 2/16/93
NRC SECTION #1: COMPARISON OF BWROG EPGs & VY PSTGS
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SECTION
TITLE
BRIEF DESCRIPTION OF CORRECTIVE ACTION
A.1
Transitions from Other Guidelines
Revised PSTG Steps; T/T-2, T/L-2.1, T/L-3.1, DW/H-2,
SC/T-4.1, SC/R-2.1, SC/L-2.1, and R/R-2, located on pages;
23, 26, 28, 37, 43, 45, 46 and 48, respectively, to specify
transition to the procedure developed from the RPV Control
Guideline. Removed previous justification from Diff-1 (71,
78, 84, 111, 128, 133, 138 and 143) and justified OE
transition to OE 3100 (Scram Procedure) in Diff-2 (15, 16,
17, 19, 21, 29, 30, 32 and 33)
A.2.a
Injection Thru the RHR Heat Exchangers
Revised PSTG Step RC/L-1 page 14, C5-3 page 68 and C5-3.2
page 69 to agree with EPGs. Removed previous justification
from Diff-1-42, 183 and 185, and justified the use of the
operating procedure in Diff-2-10, 34 and 35. OP 2124
" Residual Heat Removal System" states "...with injection
through the heat exchanger as soon as possible".
A.3.a
Override to Reopen MSIVs
The bypassing of the high steam flow not in Run isolation
interlock was removed from the PSTG Steps RC-OR page 17 and
C5-2 page 66.
Diff-1-48 and Diff-1-181 were changed to
reflect the deletion, and OE 3101 Step RC/P-OR and OE 3102
Steps ALC/Q-7 & 8 were modified to reflect change, as well as
and Appendix P,
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A.3.b
Initiation of Shutdown Cooling
Revised PSTG Step RC/P-4 page 19 to agree with EPGs; Diff-1-
55 was deleted to reflect change; the use of OP 0109 was
justified in Diff-2-12. Operating procedure OP 0109 was
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revised to provide direction as to when to shutdown to cold
S/D.
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A.4.a
Initiation of Alt Rod Insertion & Reset
The PSTG Step RC/Q-3 page 21 and OE-3101 Step RC/R-1 were
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revised to agree with the EPGs.
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A.4.b
Increasing CRD Differential Pressure
Revised PSTG Step RC/Q-3.4 to agree with EPGs; the previous
justification in Diff-1-65 was deleted and OE-3101 Step RC/R-
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5 was changed to agree with the PSTGs. A new appendix
(Appendix BB) was written to give direction for increasing
cooling water delta P.
B.I.a
RPV Depressurization
Deleted direction,to depressurize based on Torus temperature
above 120 F and isolated from the condenser from the PSTG,
page 23 and OE-3104 Temperature Control leg. deleted Diff-1-
72.
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B.2.a
Defeating Isolation Interlocks
Provided additional justification in Diff-1-97 utilizing
existing design basis information.
B.3.a
Termination of Injection at Vacuum Bkr Elev
The PSTG Step T/L-3.2; page 30, was revised to agree with the
EPGs; Diff-1-87 justification was deleted and OE-3104 Step
T/L-21 changed to agree with PSTGs.
B.3.b
Termination of Injection for Primary
The PSTG Step T/L-3.3; page 29, was revised to agree with the
Containment Water Level Limit
EPGs. Revised Diff-1-88 and revsied OE-3104 Step T/L-25 agree
with PSTGs.
B.4.a
Override Statement
Revised Diff-1-106 to strengthen justification for not
assuraing unknown concentrations are above deflagration
limits.
B.4.b
Air Purge
PSTG Step DW/H-2.2; page 38, was revised to agree with the
EPGs and Diff-1-110 justification revised. The OE was
changed to permit air purge with TSC concurrence and revised
Diff-2-20 to justify difference between PSTG and OE.
C.1
Entry. Conditions
Revised PSTG Secondary Containment Control Entry Conditions;
Page 40, to agree with EPGS. Deleted Diff-1-120, 121 and 122
justifications. Justified differences in Diff-2-23 through
26. Revised alarm response procedures to include appropriate
accident mitigation strategy action steps.
C.2
Secondary Containment Vent. Override
Revised PSTG Step SC-OR; page 43, to agree with EPGs, deleted
previous justification in Diff-1-124 and changed OE-3105 Step
SC-OR to agree with PSTGs.
C.3.a
Operation of Available RB Ventilation
Revised PSTG Step SC/T-2; page 43 to agree with EPGs and
moved justification from Diff-1-125 to Diff-2-28.
C.4.a
Floor Drain Sump Water Levels
Revised PSTG Step SC/L-1; page 46, to agree with EPGs and
moved justification from Diff-1-136 to Diff-2-31.
D.1
Emergency Depressurization
Improved justification in Diff-1-143.
E.1.a
Inhibit ADS
Revised PSTG Step Cl-OR; page 50,to agree with EPGs; deleted
previous justification from Diff-1-146 and revised OE-3102,
1/3; Step ALC/L-OR, to agree with PSTG.
E.1.b!
Spray Cooling
Revised PSTG Step;Cl-2; page 51, to agree with EPG logic,
revsied previous justifications in Diff-1-149 and 150.
Changed OE-3102, 1/3; Step ALC/L-5 to agree with PSTG.
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Transition from Spray Cooling to Steam Cooling
Revised PSTG Step C7-4, page 74, and OE-3102, 1/3; Step
ALC/L-10 to indicate transition to Primary Containment
Flooding if RPV water level cannot be restored and maintained
above TAF.
E.2.a
Termination & Prevention of Injection
The comments relative to this issue were resolved at theIJuly
14, 1992 meeting with the NRC, no further action required.
E.2.b
Defeating Interlocks'
Revised PSTU Step C2-4.1; page 53 and OE-3102,.1/3; Step
ALC/D-12 to allow isolation interlocks to be defeated and
revised previous justification in Diff-1-157. New appendices
(Appendix CC, DD, EE, and FF) were be developed with
direction on accomplishing the bypassing.
E.3.a
RPV Wtr Lvl Below Min Stm Cool Wtr Lvl
Revised Diff-1-185 to include additional / complete and
detailed justification.
E.3.b
Transition to Primary Containment Flooding
Revised PSTG Step C5-OR, page 70 to agree with EPG, deleted
previous justification in Diff-1-187 and added OE-3102, 3/3,
Step ALC/Q-30 to agree with PSTG.
E.4.a
RPV Venting
Revised PSTG Step C6-2, page 73, to agree with EPG, deleted
previous justification from Diff-1-190. Revised Diff-2-37 to
justify venting w/TSC concurrence, revised OE-3102, 2/3, Step
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ALC/CF-4 to use MSIVs to vent and wrote new appendices
(Appendix CC, DD, EE and FF) for using systems to vent.
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SPECIFIC RESPONSE TO NRC COMMENTS
Revised 2/16/93
NRC SECTION #2 COMPARISON OF VY PSTGS & VY EOPS
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SECTION
TITLE
BRIEF DESCRIPTION OF CORRECTIVE ACTION
A.1
Shutdown Conditions
Revised the following OE steps: OE-3100 (S -OR) , OE-3101 (RC/Q-OR, RC/L-OR
and RC/P-8), OE-3102 1/3(ALC/D-1 and ALC/D-14), OE-3102 2/3 (ALC/F-OR) and
OE-3102 3 /3 (ALC/Q-OR) to state that..."the reactor is and will remain
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shutdown as indicated by any of the following conditions:" or that the
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" reactor will not remain shutdown.
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B.1
Entry Conditions-RPV Water Level
Revised OE 3100 and Appendix A to include "RPV wat.er level cannot be
Cannot be Determine
determined" as a scram condition.
B.2.a
Override-Transition to Level / Power
Revised OE-3100 to include override.
Control
B.2.b
Injection Through The RHR Heat
Same as A.2.a of Section 1.
Exchangers
B.2.c
Use of Alternate Injection Systems
Revised OE-3101 Steps RC/L-5 and 6 to agree with PSTG.
B.3.a
Heat Capacity Temperature Limit &
The scram procedure (OE 3100) was revised to include override and Diff-2-9
SRV Tail Pipe Level Limit
was revised.
B.3.b
RPV Depressurization
Revised OP 0109 to permit RPV depressurization regardless of main
condenser availability.
B.4.a
Defeating RPS Logic Trips
Revised OE-3101 Step RC/R-5 and OE-3107, Appendix F to include ".
defeating RPS logic trips if necessary".
C.1.a
Suppression Pool Temperature
Same as B.1.a of Section 1.
Control
C.2.a
Primary Containment Pressure
R vised PSTG Step DW/P; page 36, to say Drywell and explain in Diff-1-97.
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D.1
High Reactor Building Differential
Revised OP 2116, ON 3153 and 3158 to contain direction from PS*IG.
Pressure Entry Conditions
D.2.a
Floor Drain Sump Water Levels
Revised PSTG Step SC/L-1; page 46, to agree with EPG, deleted previous
justification in Diff-1-136 and revise Diff-2-31 to justify use of Alarm
Response Procedures (ARPs). Revised ARPs to provide direction per PSTG.
E.1.a
Transitions from Other Guidelines
Transitions in OE-3103 Step DW/T-16, OE-3104 Step T/T-9, OE-3105 Steps
SC/T-9, Sc/R-8 and SC/L-10, and OE-3106 Step R/R-6 were revised to ensure
the operator did not exit the leg when directed to RPV-ED..
E.2.a
RPV Water Level Above the Minimum
Ccements resolved & require no licensee action 7/14/92 mtg w/NRC
Steam Cooling RPV Water Level
E.2.b
Exit from Level Power Control
Revised OE-3102 3/3 to more closely agree with the PSTGs. Revised Diff-2-
36 to provide improved justification.
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SPECIFIC REPONSE TO NRC CObH4ENTS
Revised 2/16/93'
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NRC SECTION #3 TECHNICAL ADEQUACY OF EOPS & SUPPORT PROCEDURES
SECTION
TITLE
BRIEF DESCRIPTION OF CORRECTIVE ACTION
A
Primary Containment Water
'The Drywell high water level alarm setpoint will be changed to provide
Level Indication
indication consistent with OEs.
B
Isolation of Systems
Procedures ON 3153 and 3158 have been changed to agree with OEs.
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Discharging Into Secondary
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Containment
C
Emergency RPV
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OE-3102 Step ALC/D-12, was revised to reference new appendices. New appendices
Depressurization with
(Appendix
CC, DD, EE and FF) were written to address alternate systems. Same an
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Alternate Systems
E.4.a of Section 1.
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D
Control' Rod Insertion
OP 0109 was revised to direct insertion of any rods that may be withdrawn even
if already shutdown.
T
E
Throttlingt Fire Water
OS 3107 Appendix,M is being changed to direct throttling RHR-27A for pressure
Injection-
control..
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