ML20115H870
| ML20115H870 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/19/1996 |
| From: | Thayer J VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-96-91, NUDOCS 9607230359 | |
| Download: ML20115H870 (7) | |
Text
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VERMONT YANKEE I NUCLEAR POWER CORPORATION Ferry Road, Brattleboro. VT 05301-7002 ENGINEERING OFFICE 580 MAIN STREET i
OOLTON, MA 01740 l
(508)779-6711 July 19,1996 BVY 96-91 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
References:
(a)
License No. DPR-28 (Docket No. 50-271)
(b)
Letter, USNRC to VYNPC, inspection Report No. 50-271/96-05, NVY 96-108, dated June 19,1996
Subject:
Reply to a Notice of Violation - Inspection Report No. 50-271/96-05 This letter is written in response to Reference (b), which documents that our activities were not in full compliance with NRC requirements. The violations, all classified as Severity Level IV, were identified during an inspection conducted from March 25, to May 11,1996. Our response to the violations is provided below.
l VIOLATION A:
10 CFR 50, Appendix B, Criterion XIV, inspection, Test, and Operating Status, states, in part, that measures shall be established for indicating the operating staetus of systems and components, such as tagging valves or switches, to prevent inadvertent operstions.
j Vermont Yankee Administrative Procedure (AP)-0140, Vermont Yankee Local Control Switching Rules, Revision 19, provides the procedural guidance to ensure the safet, of personnel and equipment to maintain systemlntegrity. AP-6001, Installation, Test and SpecialTest Procedures, Revision 19, provides controls and guidance in the development and implementation of 1
installation and Test (l&T) Procedures and references AP-0140. AP-6001, steps 2 and 3 specify that the operations staff will review the impact on the equipment that must be removed from service or degraded and the impact the 1&T procedure may have on other plant equipment.
Contrary to the above, the development and review by the cognizant engineering and operations staffs of step 7.6 of I&T Procedure for EDCR 95-408, HPCI Turbine Push-Button, dated 11/30/95, l
failed to recognize that the removal of fuses 23A-F1 and 23A-F2 on December 7,1995 would: 1) result in the automatic opening of torus to HPCI suction valves; and 2) cause the Technical i
Specifications (TS) 3.7.D.2 primary containment isolation system Limiting Condition for Operating entry conditions to be satisfied because of inoperable logic circuits for HPClisolation.
l This is a Severity Level IV violation.
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U.S. Nucle r R:gulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION July 19,1996 l
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RESPONSE
- 1) Reason for the violation i
Vermont Yankee does not contest this violation. The cause of the occurrence was personnel error in that personnel involved in the preparation, review and approval of the Design Change, l&T and Tagging Order did not identify the impact of fuse removal.
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- 2) Corrective steos that have been taken and the results achieved A detailed followup investi0ation identified the root cause and has been documented in an Event Report. The lessons learned from the event have been incorporated into Engineering, Operations and l
Contractor training programs.
The lessons learned from the event have also been and continue to be integrated into the preparation I
of other similar on-line maintenance and design installation activities. This has resulted in an increased sensitivity to the level of advance preparation and additional review and approval requirements for on-line evolutions. Members from appropriate departments are now required to participate in advance preparation and review for future similar on-line maintenance and design installation actMties.
- 3) Corrective steos that will be taken to avoid further violations Additional review and assessment of the event determined that a contributing cause was that the j
expectations for Operations Department review of I&T procedures was not well understood (e.g.
j expectation that a thorough review of proposed tagouts be performed consistent with the level of review
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performed under the switching and tagging process). The expectations have been reviewed with i
Operations Department personnel and will formally be incorporated in procedure AP-6001, " Installation, Test and Special Test Procedure", by August 1996.
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- 4) Date when full comollance will be achieved Full compliance was achieved upon restoration of the fuses on December 7,1995.
VIOLATION B:
10 CFR 50, Appendix B, Criterion XI, Test Control, states in part, that a test program shall be established to assure that all testing required to demonstrate that systems and components will perform satisfactorily in service.
10 CFR 50.55 a(g)(1) specifies that the Inservice inspection requirements for boiling water reactors must satisfy the requirements of Section XI of the effective edition of the ASME Boiler and Pressure Vessel Code and Addenda.
The 1980 edition of ASME Code,Section XI, sub-section IWC 5000, specifies that a demonstration of an open flow path for open-ended piping shall be conducted.
Contrary to the above, during the second interval of the Vermont Yankee Inservice inspection Program (May 1,1983 to September 1,1993) the containment spray header in the torus. a i
subsystem of the residual heat removal system, was not tested to demonstrate a flow path i
through the open ended spray header nozzles.
This is a Severity Level IV violation.
U.S. Nuclear Regulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION July 19,1996 Page 3
RESPONSE
- 1) Reason for the Violation Vermont Yankee does not contest this violation. The cause of the occurrence was attributable to personnel errors by utility and contractor personnel. When the ASME code changed, neither the personnel revising the program nor the reviewers of the program realized that the testing requirements had changed.
These errors were cognitive errors in that personnel revising and reviewing the program failed to identify the changes in the ASME code.
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- 2) Corrective steos that have been taken and the results achieved A detailed follow-up investigation assessed the impact on operability, determined the scope of the problem, identified the root cause and scheduled a formal test of the Torus Spray piping.
- 3) Corrective steos that will bc taken to avoid further violations An open flow path test for the Containment Spray header in the Torus will be performed during the 1996 refueling outage, currently scheduled for September 1996.
Additionally, a third party independent audit of the ISI program has been initiated. Included in the audit scope is an assessment of the adequacy of code revision vs. program update. The audit team includes personnel from other utilities or companies expert or experienced in ISI program requirements and implementation. This independent review will be completed by August 1996.
1 This event has been factored into the 1996 Engineering Support Personnel Continuing Training program. This training will be completed by December 31,1996.
A copy of the Event Report, which documents this issue, including the corrective action investigation, will be provided to the Authorized Nuclear in-Service inspector to allow him to benefit from the investigation. This will be completed prior to the 1996 Refueling Outage.
All applicable systems with open ended discharge lines will be included in the ISI Program prior to the 1996 Refueling Outage.
- 4) Date when full comoliance will be achieved All action items, except for engineering personnel training, will be completed prior to, or during the 1996 refueling outage which is scheduled to begin September 7,1996.
VIOLATION C:
10 CFR Part 50, Appendix B, Criterion VI, states, in part, that measures shall be established to t
control the issuance of documents, such as procedures and instructions, which prescribe all activities affecting quality.
Vermont Yankee AP-6805, Revision No.19, states that the control document system ensures that critical documents in use throughout the plant are always current.
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U.S. Ntcle r R:gulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION July 19,199F PaDe 4 i
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' Contrary to above, prior to March 29,1996, the Vermont Yankee Motor-Operated Valve Program I
manual [a critical document] was not a controlled document maintained in accordance with AP-l 6805.
i This is a Severity Level IV violation
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RESPONSE
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- 1) Reason for the violation i
i Vermont Yankee does not contest this violation. The cause of the occurrence was personnel error in that management expectations to update the MOV Program Plan were not fully implemented.
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- 2) Corrective steos that have been taken and the results achieved i
l As described in the inspection Report [ Reference (b)], the Vermont Yankee MOV Program Plan is now
" controlled" in accordance with plant procedure AP-6805, Document Control.
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- 3) Corrective stens that will be taken to avoid further violations i
We are currently finalizing a generic Programs Procedure, which will provide guidance on the structure j.
and content of all similar Vermont Yankee documents, including the MOV Program Plan. The Programs Procedure will also prescribe standard requirements, such as *he need to identify re view and j
approval authority, as well as requirements for periodic program document reviews and upo1stes.
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The Vermont Yankee MOV Program Plan will continue to be maintained in accordance with AP-6805.
i The introduction of the VY Program Frocedure will further assure proper management oversight and j
appropriate updating of the Vermont Y6.nkee MOV Program Plan.
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- 4) Qpte when full comollance will be achieved Full compliance was achieved on March 29, 1996 when the MOV Program Plan was made a
" controlled" document in accordance with plant procedure AP-6805.
l The Programs Procedure is expected to be approved by December 1996.
i VIOLATION D:
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10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that measures shall be
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established to assure conditions adverse to quality such as non-conformances are promptly i'
identified and corrected.
Vermont Yankee AP-0009, Event Reports, Revision 1, provides guidance for the preparing and j
i processing of Event (including non-conformance related events involving safety-class structures j
determined not to be in conformance with required codes, standards, or regulatory
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l requirements) Reports requiring immediate department head and/or operations shift supervisor review to address issues potentially reportable or impacting systems or component operability.
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Contrary t0 the above, the identification of the station battery room block wall seismic qualification non-conformance with NRC approved acceptance criteria on March 6,1996 was not 2
formally entered into the VY corrective action process of AP-0009 until March 12,1996 (six days f
U.S. Nuclear Regulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION i
July 19,1996 Page 5 later) for the shift supervisor to initiate a station battery operability assessment. In addition, as documented in LER 96-08, dated April 4,1996, action to correct this non-conforming condition was not planned to be completed for approximately one year.
This is a Severity LevelIV violation
RESPONSE
- 1) Reason for the violation Vermont Yankee does not contest this violation. The cause of the occurrence was personnel error in that engineering management waited for the results of an engineering analysis prior to reporting the lasue to plant management. This delayed the performance of an operability determination.
- 2) Corrective steos that have been taken and the results achieved Timeliness for entering the corrective action process has been discussed with the appropriate engineering staff and emphasis placed on the need for prompt notification of plant management.
Recent experience with other issues (e.g. RHR minimum flow valves, tornado design issues) have been used to provide case studies in appropriately handling engineering design discrepancies.
A design change was prepared, the block wall was repaired and the station battery support structure modified in April of 1996.
- 3) Corrective steps that will be taken to avoid further violations The timeliness of issue revelation and operability determinations will receive further emphasis through our Engineering Support Personnel (ESP) training program.
- 4) Date when full comoliance will be achieved Full compliance was achieved on April 26,1996 when the station battery block wall modification was completed. We also continue to stress timely entry into the corrective action process and associated operability evaluations in all of our activities.
ADDITIONAL INFORMATION:
1 Reference (b) also requested that a discussion of any current or planned engineering initiatives be included in this letter and our assessment is provided below:
On October 25,1995, Vermont Yankee announced the appointment of a new engineering management team committed to improving the quality of our engineering products and the culture of our engineering organization. By the end of 1995, the new management team had completed reassignment of engineering and licensing responsibilities, allocation of staff resources and the integration of Yankee Atomic engineering staff into the Vermont Yankee engineering organization.
Throughout the transitional period, the new engineering organization has continued to meet operational and emerging challenges, demonstrate a strong safety culture, critically self-assess existing engineering programs, and to lower the threshold of discovery. The notable increase in the number of Licensee Event Reports (associated almost exclusively with the discovery of latent technical issues)
U.S. Nucle r Regulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION July 19,1996 l
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and the expansion of budget and outage workscope to resolve these issues, are clear indicators of our
- commitment to identifying and resolving conditions potentially adverse to safety and quality. We believe these trends highlight the success of our broad based initiatives, most notably in the Appendix R, Appendix J, inservice Testing and Motor Operated Valve areas.
Our commitment to aggressive and timely resolution of emergent issues has never been greater, as evidenced by our responses to problems associated with the RHR minimum flow valves, recirculation pump discharge bypass valves, scram solenoid pilot valves, IST program, Appendix R program, Appendix J program and Torus-Drywell vacuum breakers.
Other broad based initiatives that we are currently planning include FSAR improvements, Design Basis Document development, conversion to improved Standard Technical Specifications, electronic data files for design and licensing basis information, improvements in our 10CFR 50.59 process, increased participation in industry initiatives, self assessments in our Inservice inspection and Erosion / Corrosion programs, and refinement of our critical programs and guidelines.
To facilitate the increased workload brought on by the engineering re-organization (particularly the new Performance Engineering function), the increased emphasis on questioning the status quo and the commensurate increase in emergent work, we have increased our permanent Engineering staff. In addition, we have significantly increased our use of contract engineering support to assist us in expeditiously completing our program self assessments (App.R, App.J. IST) and resolving identified problems.
I Given the changes and improvements noted above, y e firmly believe that our engineering performance j,
has improved and continues to improve.
k We trust that the information provided is fully responsive to your concerns; however, shoulo, 'u have additional questions or require any additional information, please contact this office.
Sincerely, i
VERMONT YANKEE NUCLEAR POWER CORPORATION V
Jay K. Thayer Vice President, Engineering CC:
USNRC Region i Administrator l
USNRC Resident inspector - WNPS l
USNRC Project Manager - WNPS i
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