ML20117B475

Ack Receipt of Response to Raising Concerns Re Rupture of Steam Jet Air Ejector Rupture Disc & Subsequent Release of Radiation & Informs of Systematic Degradation of Safety Components at Plant

ML20117B475
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	12/16/1992
From:	Daley M NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:	Selin I, The Chairman NRC COMMISSION (OCM)
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ML20117B470	List: ML20117B472 ML20117B475
References
NUDOCS 9302110077
Download: ML20117B475 (12)

Text

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lNew England Coalition -on Nuclear.Pollutionilnc.

Box 545,~ BrattleborO, Vermont 05302

..Ph6ne (802M" t* @IC t0336

g. cat b

.: a op31 1:0F W

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December 15,'1992' ggg

=Ivan Selin, Chairman U.S. Nuclear Regulatory Coomission Washington, DC 20555

Dear Chairman Selin:

t We have received your response to our letter of: September 15, 1992 raising concerns about the rupture of the steam jet air ej ec t or rupture disc and subsequent release of radiation.

We appreciate your detailed reply to those concerns and are preparing our response.

The purpose of this letter, however, is to alert you to an alarming and potentially disastrous situation: systematic degradation of safety components at the Vermont Yankee-plant.

Because of an ongoing pattern of industry mismanagement'and regulatory neglect, Michael Mulligan resigned his position as a control room operator for the Vermont Yankee nuclear plant, and joined our organization.

In July, 1990, after many months of repeated efforts.to bring-important safety problems to the attention of plant management and NRC officials failed to produce substantive-change, Mr. Mulligan wrote the Coalition an anonymous letter regarjing f our major areas of. concern at the plant: gashed fuel

pins, spent fuel pool cooling, shift staffing, and-nocturnal burning of waste oil.

He sent similar letters to'the NRC and to the State of Vermont-Nuclear. Engineer, who eventually made.the

-letter public at the. request of then Governor Madeline Kunin.

Shortly thereafter, Mr. Mulligan contacted us by telephone

-- still. anonymously -- and made it clear that his primary concern.was much larger.

The plant, he told us, was headed;for-catastrophe, because the management.

shortsightedly focusing was on the bottom line,-and because theJNRC'has failed-to' recognize the consequences of that shortsightednesar The only hope, he.

told'us, was to open Vermont Yankee's operations to the light of' day.

Only-public demands for safer operation would force management to' allocate.more resources on safety concerns.

L The issues Mr. Mulligan has brought to our attention have-o t

I.

Gashed pins increase off gas levels and radiation doses to the public and especially to plant workers.

Mike and.other-Vermont Yankee workers were especially concerned about their in-creased exposure.

9302110077 930128 PDR ADOCK 05000271 i

F, PDR 1

'E d u' c a t i n g.

't h e Pu blic-in Clean A lt er n a tives to Xu c le a r Pax c r

i I

2) AC and-DC power systems.which' include:

~~

ICI the-emergency diesel generators,'2 1.

LER 90-009-00: " Inadvertent Reactor Scram Due to a

Short Circuit on the' Vital AC Bus as a Result of Personnel Error,"~

Event Date:

6/1/90.

'Also, LER 88-012-00:

" Overloaded' Power Supply in-Vital Fire Protection Control Panels,"

Event Date:

9/28/88; LER 90-008-00: " Failure to Meet-Separation Criteria for-Power Cables to Regulatory Guide 1.97 Instrumentation -Loops,"

Event Date:-5/29/90.

See also, LER-89-009-00: " Lack of Redundan -

cy in Residual Heat Removal Service Water Systems " Event Date:

b/28/89.

2.

LER 90-010-00: " Failure to-Meet ' Technical S p e'c if i c a t'i o n s for-Diesel Generator _ Operation Readiness Test,". Event Date:

S/16/90; LER 90-010-01 and LER 90-010-02: " Failure to Meet. Tech-nical Specifications for Diesel Testing Generator,"TEvent.Date:

8/15/90; and LER 91-012-00' and'LER-91~-01'2-01:

Reduced Cooling-Water Flow to Diesel Generator Heat-Exchangers and Station = Serv-6 ice Air Compressors.Due to High-Service Water System Backpressure Caused by Weak Design." Event Date:'4/23/91. Also, Harold--Eichen-

holz, Thomas G. Hiltz, and Richard S. Barkley: " Inspection? Report 50-271/91-19," Section 4.2.1:

"'A' Emergency Diesel Generator. Fuel Oil Transfer Pump Operability" and Section 4.222:

"'B' LEmergency Diesel Generator Failure to Start."

These' events took place: on' July 25 and July 25, _1991'respectively.Also, H. Eichenholz and P.

Harris,

" Inspection Report 50-271/92-06," Section 4.2.2:="'B' EDG Maintenance Associated with the ECCS' Tests:" "The April _5' test-was not successful because the "B" EDG failed-toistart, due to -incom-L plete resetting of the diesel governor _ shutdown plunger following--

the last operation of the diesel on April-

3....-

Vermont Yankee-preliminarily determined that the. root cause for the first failure was the advanced age of the "B" diesel generator _...'However based ~

on. satisfactory, performance ~during surveillance testing,- and. Ri n -

E

part, due to unavailability.of-parts, VY-was. reasonably assured ~

L that the "B" EDG governor would continue to;-performL its safety q

L function until its scheduled. replacement 11n May,.1992."

J L

On June-3,~1992, Vermont _ Yankee submittedLto'NRC a

"Requesti 4

(=

for_ Temporary' Waiver.of Compliance from Technical Specification LCO.

L Requirements rertaining to Emergency D1esel Generator,"

( B Y.92-058).

Technical: Specification 3.5.H.-1 requires-that "During_ any y

period when one of_the standby diesel generators is: inoperable,.

continued reactor--operation-is. permissible only _ during the succeed-ing seven days...." On_ June 4, 1992,' Charles W.

Hehl, Director of:

the Division of Reactor Projects at theLNRC granted a

" Temporary j.

Waiver of Compliance" allowing Vermont Yankee to run an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without a safety backup diesel generator.

3

,- ;~-

New England Coalition on Nuclear Pollution,Inc.

.,gt Box 545, Brattleboro; Vermont 05302--

.Jhorie (802)a5Y 0336 uoy ;;^ w un i

p pgnif 0 December 16, 1992 gg gy

.Ivan Selin, Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Chairman Selin:

We have received your response to our letter of September 15, 1992 raising concerns about the rupture of the steam j et air ej ec t o r rupture disc and subsequent release of radiation.

We:

appreciate your detailed reply to those concerns and are preparing our response.

The purpose of this letter, however, is to alert you to an alarming and potentially disastrous situation: systematic degradat1on of safety components at the Vermont Yankee plant.

Because of an ongoing pattern of industry mismanagement and regulatory neglect.. Michael Mulligan resigned his position as a control room operator for the Vermont Yankee nuclear plant, and-joined our organization.

In July, 1990, after many months of repeated efforts to bring important safety problems to the attention of plant management and NRC officials failed to produce substantive change, Mr. Mulligan w:ote the Coalition an anonymous letter.

regarging f our major areas of concern at the plant: gashed fuel

pins, spent fuel pool cooling, shift staffing, and nocturnal burning of waste oil.

H'e sent similar letter. to_the-NRC and to-the State of Vermont Nuclear Engineer, who eventually made the letter public at the request of then Governor-Madeline Kunin.

' Shortly thereafter, Mr.. Mulligan contacted us by-telephone

-- still-anonymously -- and made it clear that his-primary.

concern was much larger.

The plant, he told us, was headed for-4 catastrophe, because the management was shortsightedly focusing on the bottom line, and because the NRC has failed to recognize the consequences of that shortsightedness:-

The only hope, he.

told us, was to open Vermont Yankee's operations to'the light of day.

Only public demands forisafer-operation would. force management to allocate more resources on safetyEconcerns.

The issues Mr. Mulligan has brought to our attention have 1.

Gashed pins increase off gas levels and radiation doses to the public and especially to plant workers.

Mike and other Vermont Yankee workers were especially concerned about their in-creased exposure.

9302110077-930128 PDR ADOCK 05000271

_Fr PDR 1

E d u c a t in g'.I h e Pu blic in Clean

.A lt e r n a ti r es to NucIcar P o w e r;

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been profoundly shocking-to us.

We believe they'go stra'ight to

}

the core of the problems confronting _this' industry.

The H

Coalition'has always known Vermont Yankee'sidesign was vulnerable-to-severe accidents, and that.the plant participated-in.the

-broadly unacceptable risks inherent in the use of nuclear-technology, but we must admit-to having.taken a margin of comfort in theinotion that Vermont Yankee-was one of the better run-utilities.

.However, we.no longer e nj oy the comfort of that illusion.

By themselves, the circumstances surrounding Mr. Mulligan's resignation are an indication of an extraordinary situation at-the plant.

Combined with an investigation of the. issues he.has i

brought to our attention, the situation. proves to be nothing j

short of alarming.

We have checked and verified each of Mr. Mulligan's reports I

in NRC-documents, not because we doubted his story,_but because we knew others would.

There is simply no question-that a variety of major safety systems at Vermont Yankee have had substantial difficulties during the past four years.

We list them here, with accompanying footnotes documenting the equipment failures.

Each documenu is available in the NRC public document room;;most can also be found on the NbDOCS computerized document system.

(ECCS),1, which includes:

1) emergency core cooling system the system,'

HPCIgore spray ang the RCIC system; 1.

Licensee Event Report LER 89-015-00 (hereafter, simply LER): " Spurious Relay Actuation Caused ECCS Initiation Signal Due to Lack of Procedure for Reenergizing Local Instrument-Cabinet."

Event Date: 3/10/89.

2. LER 89-015--00 and LER 39-015-01: " Primary Containment Leak Rate Test Caused-Inadvertent Core Spray and RHR Pump Start Due to Inadequate Procedure." Event Date: 3/30/89.

3.

LER 91-007-00: "HPCI Declared Inoperable Due to Flow' Con-troller Set Point Drift," Event Date: 3/13/91.

See-also, LER 92-004-00: "High Pressure Coolant - Inj ection System InoperableiDue to ' Degradation.of Station Battery Bus Voltage Caused by Failed Battery-Charger Component." Event 1 Date: 2/20/92.

4.-

LER 89-014-00:

" Reactor Core Isolation.-Cooling System

. Inoperable Due to Motor Burn Out on.RCIC-21 Valve," Event Date:

7/18/89; and LER.92-015-00: " Reactor Core " Isolation -Cooling:

System Inoperable Due to Flow Controller Setpoint Drift," -Event

. Date: 4/24/92.

2-e w-,n>

+n-+

-.-----a

2) AC and DC power systems which include:

-- the emergency diesel generators,2 1.

LER 90-009-00: " Inadvertent Reactor Scram Due to a

Short Circuit on the Vital AC Bus as a kesult of Personnel Error,"

Event Date:

6/1/90.

Also, LER 88-012-00:

" Overloaded Power Supply in Vital Fire Protection Control Panels,"

Event Date:

9/28/88; LER 90-008-00: " Failure to Meet Separation Criteria for Power Cables to Regulatory Guide 1.97 Instrumentation Loopc,"

Event Date: 5/29/6J.

See also, LER 89-009-00: " Lack of Redundan-cy in Residual Heat Removal Service Water Systems " Event Date:

6/28/S9.

2.

LER 90-010-00: " Failure to Meet Technical Specifications for Diesel Generator Operation Readiness Test,"

Event Date:

S/16/90; LER 90-010-01 and LER 90-010-02: " Failure to Meet Tech-nical Specifications for Diesel Testing Generator," Event Date:

S/16/90; and LER 91-012-00 and LER 91-012-01:

Reduced Cooling Water Flow to Diesel Generator Heat Exchangers and Station Serv-ice Air Compressors Due to High Service Water System Backpressure Caused by Weak Design." Event Date: 4/22/91. Also, Harold Eichen-

holz, Thomas G.

Hiltz, and Richard S.

Barkley: " Inspection Report 50-271/91-19," Section 4.2.1:

"'A' Emergency Diesel Generator Fuel Oil Transfer Pump Operability" and Section 4.2.2:

"'B' Emergency Diesel Generator Failure to Start."

These events took place on July 25 and July 26, 1991 respectively.Also, H. Eichenholz and P.

Harris,

" Inspection Report 50-271/92-06 " Section 4.2.2:

"'B' EDG Maintenance Associated with the ECCS Tests:" "The April 5 test was not successful because the "B" EDG failed to start, due to incom-plete resetting of the diesel governor shutdown plunger following the last operation of the diestl on April 3....

Vermont Yankee preliminarily determined that the root cause for the first failure was the advanced age of the "B" diesel generator However, based on satisfactory-performance during surveillance testing, and in

part, due to unavailability of parts, VY was reasonably assured that the "B"

EDG governor would continue to perform its safety function until its scheduled replacement in May, 1992."

On June 3, 1992, Vermont Yankee submitted to NRC a

" Request for Temporary Waiver of Compliance from Technical Specification LCO Requirements Pertaining to Emergency Diesel Generator,"

(BV 92-068).

Technical Specification 3.5.H.1 requires that "During any period when one of the standby diesel generators is inoperable, continued reactor operation is permissible only during the succeed-ing seven days...." On June 4,

1992, Charles W.

Hehl, Director of the Division of Reactor Proj ects at the NRC granted a

" Temporary Waiver of Compliance" allowing Vermont Yankee to run an ai 'itional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without a safety backup diesel generator.

3

emergency bactery systems.I emergency batte5'

'h*'8' "7'***

-- switchyard bus and relays

-=

3) residual heat removal _ (RHR) systems, whichinegudes:

-- RHR service water systems and pumps 1.

LER 89-020-00: " Removal of a Technical Specification Sur-veillance Requirement from a Procedure Due to an ' Inadequate Technical Specification Review,"

Event-Date:

S/11/89:

"On 8/11/89, with the plant at 100% power, Vermont Yankee-discovered the procedure controlling battery maintenance and testing was not consistent with Technical Specification requirements."

2.

LER 92-004-00: "High Pressure Coolant Inj ec tion System Inoperable Due to Degradation of Station Battery Bus Voltage Caused by Failed Battery Charger Component." Event Date: 2/20/92.

3. LER 91 005-00: " Reactor Scram Due to Mechanical Failure of 345 kV Switchyard Bus Caused by Broken High Voltage Insulator Stack," Event Date: 3/13/91; LER 91-009-00: " Reactor Scram Due to Loss of Normal Off-Site Power (LNP) Caused by Inadequate Proce-dure Guideline," Event Date: 4/23/91; and LER 91-014-00: " Reactor Scram Due to Loss of 345 kV Switchyard Caused by Defective Off-site Carrier Equipment," Event Date: 6/15/91.

See

also, NRC Information Notice 91-81: " Switchyard Problems that Contribute to Loss of Offsite Power,"

December 16, 1991.

See also.

LER 87-008-00 and LER 87-008-01: " Loss of Normal Power During Shut-down Due to Routing All Off-site Power Sources Through One Break-er," Event Date: 8/17/S7.

J 4.

LER 92-012-00: " Degraded Grid Undervoltage Relays Found Below' Technical Specifications Limits,"

Event Date:

3/31/92.

Also, LER 91-010-00: " Failed Relay Coil Results in Primary Con-tainment Isolation Syster Actuation," Event Date: 4/12/91.

5.

LER 89-009-00: " Lack of Redundancy in Residual Heat Remov-al Service Water Systems," Event Date: 5/28/89; LER 91-005-00, LER 91-006-01, and LER 91-005-02: " Loss of [RHR]

'B' Loop Shut-down Cooling Due to Pressure Switch Activation,"

Event Date:

3/14/91: "On 3/14/91 at 0450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br />, with reactor vessel cooldown in-progress following a reactor scram on 3/13/91 and with the "B"

loop Residual Heat Removal (RHR) (BO*) System flushed and-lined up for Snutdown cooling, a Group 4

Primary Containment Isolation Signal (PCIS) (JM)* was received during two attempted starts of the "B" RHR pump and closure of' Shutdown Cooling Suc-tion Isolation valves. Also, LER 89-023-00: Failure to Perform-Daily Instrument. Checks on the Low Pressure Coolant Inj ec tion System Crosstie Monitor Due to Interpretation of Tech.

Spec..

Requirements",

Event Date: 9/11/89: " Vermont Yankee Technical Specification 4.2.A, Table 4.2.1, requires an instrument check of

d)1feedwater'systeml and-citeck val'ves2;j and'

~

~

-5) ser vic e water system check valves 3

... Continued...:

~ _

the indication for the res? dual heat removal.

(RHR) system a

crosstie - valve,-RHR-20 -be completed'once per day.-

Contrary to:

this requirement, it was discovered, on 9/11/S9, that the11ndica-tion to the valve had not been available from'3/20/S9, when the power supply breaker sto the indication was removed...."

Also, LER 91-015-00: " Containment Isolation Valve-FailureTto Close-Due to Erosion / Corrosion and Displacement of Screw-in-Seat,"

Event Date: 5/14/41: "On June 14, 1991 Residual _ Heat Removal Valve V10-34A Failed to Close."

1.

LER 88-007-00: Main Turbine Trip and Reactor.

Scram from Feedwater Flow Controller Malfunction Due to Failed Feedwater Flow Integrator," Event Date: 5/18/88.

2.

LER 92-010-00: "1992 Appendix J: Type B.and C Failure Due-

to Seat Leakage," Event Date: 3/8/92. "On 3/8/92, 3/12/92, and

- 3/17/92 Liquid Radwaste Valve LRW -83 (EIIS=WD),

Feedwater:

- Check Valve FDW-28B (EIIS=SJ) and Control Rod Valves CRD-413A and (EIIS=AA) weresfoundi o have seat-leakage above that= per-

' 413-3 t

mitted'by Technical Specification 3.7.A.'4."

LER 90-012-01: "1990 Appendix.J-Type B_and-C Failure'Due to.

Seat Leakage,"

Svent Date:- 9/3/90: "On_9/3/90 andL 9/5/90i Feedwater Check valve'FDW-95A-(EIIS=SJ) and_ Primary -Containment Atmospheric Control-valve PCAC-5B (EIIS=BB)-were found to-have seat leakage above that permitted-by Technical-Specification 3.7 A.4."

LER 89-007-00: "1989 Appendix.J~ Type B and C Failure Due to Seat Leakage," Event-Date: '2/15/89: "On.2/15/89, 2/17/89, 3/5/S9 and 3/7/89

... Liquid Radwaste Valves LRW-83~,.

LRW-94,.

LRW-95 (EIIS=WK),- Primary Contaii7ent: Atmospheric-' Control valve -PCAC-8,9,10,23 and PCAC-5,7,5A,7A 7B_(EIIS=BB), Containment Air -Com-

- pressor: Discharge-Check' Valve CA-89C_(EIIS = LD) and Feedwater-Check valve FDW-95A (EIIS=SJ)-were found;to"have seat ' leakage; above that permitted by Technical Specification 3.7.A.4'."

LER 84-011-01 and 84-011-02: "Updateion Leaking ' Containment Isolation Valves,"

Event Date: 5/15/84:

FDW-95A-and-1CA-

- 89C were-found to have. seat leakage above-that-permitted _ by Technical Specification 3.7.A.4."

IT SHOUL'D BE NOTED THAT THE SAME FEEDWATER CHECK VALVE

- FDW

'95A'--

WAS REPORTED LEAKING'FOR AT LEAST 5 YEARS,.FROM'1984 THROUGH 1990.

3.

LER 89-017-00:'" Service Water Check-Valves Inoperable-Due

~

to Corrosion of Internal Parts," Event Date: 3/30/89.

m 5

t '

--r m

..m p

,*L In addition.,there h' ave been' equipment problems in otherJke'y

~

areas _during the level 1 indicators,}astand the diesel fire pump,g=among-others.:

four-years as well: fo example, core _ water As though all of this weren't enough, maj or. questions - ha ve been raised during this same geriod-about p_ersonneletraining

-programs and plant procedures about the plant's emergency 1.

LER 92-014-00:

" Inadvertent Scram and ECCS I'nitiation While Shutdown When Restoring Four Level Transmitters.

to Service,"

Event Date:

4/12/92.

Also, letter from-Ernest:

C.

~

Hadley, attorney for We the People, Inc. to Ivan Selin, J 21 y: 21,

1992, concerning generic problems with water _ level instrumenta-tion at U.S.

nuclear reactors.

?.

LER 91-003-00: " Missed Diesel Fire Pump Fuel Oil Surveil-lance Due to Inadequate Procedure," Event Date: 2/27/91.

3.

Williams, J.H.; Conte, R.J.

& Bettehausen,-

L.

" Training-Program Inspection Report 50-271/91-S2 on 911021-25.

Deficien-cies noted...." Also LER 89-013-00 and LER 89-013-01:

" Reactor Vessel Inventory Decrease Due to Personnel Error," LEvent Date:

3/10/S9. PNO-I-89-021, a notice of' unusual event, covers the same event.

Another set of events due to incorrect procedurec is-de--

scribed in-LER 88-001-00 and LER 88-001-01: " Plant Service Water Effluent Stream Not Monitored Due to Procedure-Deficiency,"' Event Date:

2/11/88, Inspection Report 50-271/88-03 and Notice o f; Violation from [the same) Inspection' Report,".and LER 88-014-00:

" Missed Effluent Sample Due to Inadequate Corrective Action in LER 88-01, Rey, 1," Event Date: 10/19/88.

Other reports triggered by incorrect procedure include:

LER 89-24-00 and 89-24-01: " Missed Residual Heat Removal-Valve-Leak-age Surveillance Due to Incomplete-Proce' dure Review," Event'Date:

9/13/S9:

LER 90-018-00: " Primary Containment -Isolation Systes Spurious Actuation Due'to an Inadequate Procedure," Event' LDa t e-:

10/10/90; and LER 92-015-00: " Improper Insarvice Flow Testing.of the Control Room Chilled Water Pump Due.to ASME Code:Misinterpre-tation and Subsequent Missed. Quarterly TestiDue to Incorrectly Following the Surveillance Procedure," Event Date: 4/22/92.

See also, LER 89-015-00,.LER 89-015-00, LER 89-015-01, LER 39-020-00, LER 89-023-00, LER 91-003-00, and LER 92-014-00, all of which are cited-above.

5 t

~_

operating procedures (EOPs)l,_and-about plantisecurity 2, Problems with-training andl security were i d en ti fi e d.11n = pa rt,_

?vith a lack of adequate funding.

We do.not intend to detail-in this letter each of th'e.

~

_ problems we have.j ust_ enumerated :c they are already-well-

. documented.

Instead,.we_want to point to the extraordicary and d

pervasive pattern of these shortcomings.- It may be true that no one of these. shortcomings, by itself, constitutes an adequate reason to challenge the ongoing operation of this plant.

But when they are combined as_they havs been here, the-possibility is raised that disastrous results could ensue.

Each of these malfunctions and system degradctions has:

already been brought to the attention both of management and of the NRC.

The question then arises: why has-the systematic degeneration of this plant been allowed to continue?- Why has this not been corrected?

We can see no other explanation for this than that utility l

decision making is unduly driven by the bottom line-and that your staff is in some way acquiescing in this state of affairs.

In recent years, plant workers and mid-level management-alike have been keenly aware of subtle and not so-subtle messages from top management _that maintaining or-improving the plant's capacity factor -

acknowledged to be one of' thel

-highest in the industry

--_is far more important than resolving j

safety issues.-

In its day-to-day-scramble to produce more electricity and therefore higher profits, plant management has created an atmosphere that_causes employees to think-twice before raising safety concerns that might j eopardize corporate financial ~

goals.

For instance..the plant -j ust recently' shut down-because of

_ problems with.a recirculation pump controller.

This pump _

-controller has-experienced chronic problems and its-erratic

" behavior has~ been of considerable concern to on-duty operating

--p er s onn el. - Yet time after time the utility ^aas attempted a quick fix.

A look at the maintenance history of this piece of equipment would reveal a resistance to carrying'out a thorough troubleshooting that might lead to unwelcome down time.

1.

Bennett, F.P.; Conte, R-.J.

& Bettehausen, L.

" Inspection j

Report

1. 50-271/92-80: Emergency Operating _ Procedures-inspection 50-271/92-80, on 920224-28.

Weaknesses.

and

-deficiencies y

noted...."

2. Initial _ Systematic Assessment'of.Licenste Performance Report

'No.'50-271/91-99.

October 13,1992.

.j J

7t H

Cost cutting and cost containment activities lead to subtle-interactions that impact plant operations, such as tight-inventory ' control resulting: in the unavailability of-parts.

As noted above, this occurred with the fuel pool motor, and the governor on'the "B"

emergency diesel generator.

This, in-turn, leads to non conservative j udgments about running the plant with equipment in a degraded mode like,the tolerance, for over six years, of. leakage in feedwater check valve 96A I These activities are multiplying just as many'of the plant's key componerts are feeling the effects of age-related degradation.

Thus, rather than improving plant safety through increased vigilance, management is moving the plant in the opposite direction. For example, it has pushed hard to reducs the time spent for planned cutages.

This means that the plant can make more money (since even scheduled plant shutdowns are expensive), but it also reduces the amount of time and resources available for fixin s major safety systems.

In large measure, the de. gradation of the switchyard equipment appears to stem from ;

k of time and resources during the shortened outages to perform necessary testing and maintenance.

Increasing the fuel cycle from 12 months to 18 months generates more profits, but it also increases the strain on the system.

Plant components work harder and longer, with less frequently scheduled maintenance.

To maintain short outage times, the utility has began to shift various maintenance activities normally performed during an outage into periods when the plant is operating at full power.

This practice has had unsettling consequences, resulting in a reactor scram that.

seriously challenged safety eqgipment2, and a release of-radiation into the environment i

Proposed new NRC regulations would actually reduce the plant's accountability by extending reporting periods to match

1. LER S4-011-01 and S4-011-02: " Update on Leaking Containment Isolation Valves," Event-date: 5-15-S4:

...FDW 95A and S9C...were found to have seat leakage above that permitted by Technical Specification 3.7.A.4."

reports continuing into 1990.

'2.LER 91-009-00: " Reactor Scram Due to Loss of Normal Off-Site Power (LNP) Caused by Inadequate Procedure Guideline," event date 4/23/91.

3.LER 92-003: "A0G Rupture Disc Temporary Repair Not Within 1

System Design Basis" February 13, 1992 and NECNP letter'to l

Chairman Selin date September 15, 1992.

S

1 the longer cycles l, at a time when aging plants clearly require greater regulatory scrutiny.

l 1.2 formed of all of the system failures noted above, the NRC has imposed no fines and no shutdowns, and Staff regalatory f

practice seems focused on symptoms without any real understanding of the underlying pattern leading to the failures an such a wide scale.

On-site NRC inspectors, informed of ongoiag uncorrected conditions with potential safety implications respond to employees by calling for the utility to "self-correct" and for employees to submit more " maintenance r eq uestf' (MRs ).

Yet the utility's internal practice for handling MRs allows a screening of requests before they are actually logged onto the official computerized tracking system.

Given the atmosphere we have been describing, it is unreasonable for your Staff to assume that this c

screening is performed with safety considerations as the prime criterion.

Your staff's inability, or unwillingness, to identify the pattern described here is part of a structara) weakness in the oversight program.

Because of limited resources, NRC must focus on individual problems and their resolution, leaving inspectors too little time to explore underlying causes.

Officials from the NRC Region I inspection branch told members of the Vermont State Nuclear Advisory Panel as much at a December 2.

1992 meeting.

Regional Supervisor E.

Kelley spoke of the difficult " art" of allocating limited personnel and resources to the twenty nuclear plants in the region.

Senior Vermont Yankee Resident Inspector Harold Eichenholz and his partner, Paul Harris, mentioned a high reliance on the utility's ability to identify and correct its own problems because with only two inspectors on site, they must " choose and prioritize" the issues they follow.

The very nature of the problem we are describing would not be amenable to either self-identification or self-correction.

In addition, the recent.SALP Report identified deficiencies in Vermont Yankee's self assessment and engineering evaluations, concluding that " Performance declines [three deratings out of seven SALP categories] attributed to the failure of sel;~ assessme..c programs to effectively identify 1.

"Reduciag the Regulatory Borden on Nuclear Licensees,"

Proposed Rule RIN 3150-AE 30, Federal Register, June 13,

1992, pp.

27137-27191 and " Review of Reactor Licensee Reporting Re-auirements," Federal Register, June 19, 1992, pp. 27394-5.

5

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fundamental issues -in maj or program areas"l.

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In addition to having limited resources in'the field, your agency-hos no policy to' determine when the type of systematic -. _

failure va are-descr$b'ing sufficient 1 3. jeopardizes public safety to warrant-theEshut down of the plant This worries us.

-Experience has taught us that simply bringing'these-matters to the attention.of your-Staff.will not lead to action to counteract th'eoe trends at' Vermont Yankee.

Many NRC decisions have, in fact, served to reinforce Vermont Yankee's misguided activities' by relyi.ng too heavily on the utilities j udgments of what '

constitute.4 safe operation.

For example, for over 5 months the NRC has tolerated the operation of Vermont Yankee with the E and F Intermediate Range Monitors (IRMs) inoperable and two unshared Average Power Range Monitors (APXMs) in bypass.

This problem was discovered at the beginning of start up after the March refueling outage.

Yet the utility did not halt the start-up to repair the IRMs, even though plant technical specifications, the FSAR, and plant procedures require, as a minimum condition for operation, two-operable APRM downscale scram per channel.

NRC is allowing the utility to avoid a shutdown to correct

.this deficiency in the reactor protection system, although

-neither Vermont Yankee (after 20 years running this reactor!), or your staff, can determine the importance of'this function for protecting public safety.

Since there is no way to predict or determine when the reactor might enter a power level requiring this protective function, the NRC decision to allow operation in this degraded mode represents an unacceptable trade off of safety interests for the utility's interests.

l NRC allowed tha increase of intervals-between the inspection and overhaul of the emergency diesel generators when the utility shifted to 18 months between outages, despite: the fact thatJthese machines are over 20 years old and near or beyond the end of their usef ul lives.

The protracted and nearly intractable problems with the "A" EDG documented above, and the first ever failure of-the "B" EDG to start (twice!) during an integrated ECCS test, casts doubt on the wisdom of allowing such-reductions.

Compounding the generator failures themselves, NRC has made 1.

NRC presentation on the Vermont Yankee Inspection Program and-Recent SALP' Report, December 2, 1992, before the Vermont State Nuclear Advisory Panel.

See also SALP Report No.50-271/91-99.

'2.GAO report " NUCLEAR REGULATION ~~ Efforts to Ensure Nuclear Power Plant Safety Can be Strenthened"-GA0/RCED-S7-141.

l 10 i

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questionable j udgments about Vermont Yankee's reliance on the Vernon tic-line_when granting Limited Condition of Operation-requests.

This has led to situations where only one back up

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generator has been'available.for emergencies for as long as eight days-at a time with t'he plant running at full power.-

The burden-of owning and operating such a complex machine as a nuclear power plant demands an unwavering commitment to perfect-housekeeping.

Every safety system is needed, and its perfect operation must be assumed to be essential. This simply should not be a matter for negotiation between management and regulators.

NRC must therefore ensure that the maintenance of essential safety sy st ems is immune to budgetary pressures of any kind.

The evidence we have presented here suggests that the NRC's current oversight activities at Vermont Yankee are failing to achieve this goal.

We hope Vermont Yankee is only in the initial stages of degradation due to a neglect of preventive maintenance from the-combined factors of cost-cutting, cost containment, and over-emphasis on capacity factor.

But only a comprehensive analysis of Vermont Yankee's decisions in these areas can demonstrate this, and only immediate steps to halt these misguided decisions can curtail further deterioration.

Since the situa'.. ion we have described undermines public confidence in Vermont Yankee's dedication to a " safety first" philosophy, we call on you to conduct a public investigation of the issues we have raised, and allow the public opportunity-to participate in any corrective action plan you develop.

l-Sincerely, f

i Michael Dal with Joh Greenberg'and Michael Mulligan, for the~ Board of the New England l

Coalition on Nuclear Pollution 11

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