ML20153C221
| ML20153C221 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/17/1998 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Maret G VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| 50-271-97-10, NUDOCS 9809240027 | |
| Download: ML20153C221 (3) | |
See also: IR 05000271/1997010
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September 17,1998
Mr. Gregor/ A. Maret
Director of Operations
Vermont Yenkee Nuclear Power Corporation
185 Old Ferry Road
Brattleboro, Vermont 05301
SUBJECT:
NRC INSPECTION REPORT 50 271/97-10, NOTICE OF VIOLATION, AND
EXERCISE OF DISCRETION
Dear Mr. Reld:
This refers to your March 6,1998 correspondence, in response to our letter dated February
5,1998, regarding Vermont Yankee. This correspondence dealt with Notice of Violation
50-271/97-10which identified three (3) Severity Level IV violations.
Thank you for informing us of your corrective actions. We have reviewed this matter in
accordance with NRC Inspection Manual Procedure 92903," Follow-up - Engineering."
Based upon our preliminary in-office review of your staff's determination of the causes for
these violations, it appears that the stated corrective actions are appropriate. These
corrective actions will be examined during a future inspection to assess their overall
effectiveness.
Your cooperation with us is appreciated.
Sincerely,
Original Signed by: R. Summers
Curtis J. Cowgill, Chief
Reactor Projects, Branch 5
Division of Reactor Projects
Docket No. 50-271
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9809240027 980917
ADOCK 05000271
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Mr. Gregory A. Maret
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Vermont Yankee
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cc w/o cv of Licensee's Resoonse Letter:
R. McCullough, Operating Experience Coordinator Vermont Yankee
G. Sen, Licensing Manager, Vermont Yankee Nuclear Power Corporation
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cc w/cv of Licensee's Resoonse Letter:
D. Rapaport, Director, Vermont Public interest Research Group, Inc.
D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire
Chief, Safety Unit, Office of the Attorney General, Commonwealth of Massachusetts
D. Lewis, Esquire
G. Bisbee, Esquire
J. Block, Esquire
T. Rapons, Massachusetts Executive Office of Public Safety
D. Katz, Citizens Awareness Network (CAN)
M. Datey, New England Coalition on Nuclear Pollution, Inc. (NECNP)
State of New Hampshire, SLO Designee
State of Vermont, SLO Designee
Commonwealth of Massachusetts, SLO Designee
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Mr. Gregory A. Maret
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Vermont Yankee
Distribution w/ encl:
Region 1 Docket Room (with concurrences)
PUBLIC
Nuclear Safety Information Center (NSIC)
NRC Resident inspector
H. Miller, RA/W. Axelson, DRA -
C. Cowgill, DRP
B. Summers, DRP
C. O'Daniell, DRP
B. McCabe, OEDO
R. Croteau, NRR
C. Thomas, NRR (COT)
R. Correia, NRR
F. Talbot, NRR
Inspection Program Branch, NRR (IPAS)
DOCDESK
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DOCUMENT NAME: G:\\ BRANCH 5\\RPLY-LTR\\VY9710.RES
Ta receive a copy of this document, indicate In the box:
"C' = Copy without attachment / enclosure
'E' = Copy with attachment / enclosure
"N"=
' No copy
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OFFICE
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NAME
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DATE
09/10/98
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OFFICIAL RECORD COPY
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VERMONT YANKEE
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NUCLEAR POWER CORPORATION
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185 Old Ferry Road, Brattleboro, VT 05301-7002
(802) 257 5271
March 6,1998
U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
References:
(a)
Letter, USNRC to VYNPC, NRC Inspection Report 50-271/97-10, Notice of Violation
and Exercise of Discretion, NVY 98-14, dated 2/5/98
(b)
Letter, USNRC to VYNPC, Vermont Yankee Design Inspection, NRC Inspection Report
No. 50-271/97-201, NVY 97-130, dated 8/27/97
SUBJECT:
Vermont Yankee Nuclear Power Station
License No. DPR-28 (Docket No. 50-271)
Repiv to a Notice of Violation - NRC Inspection ReDort 50-271/97-10
This letter is written in response to Reference (a), which documents the findings of a special inspection conducted
from September 29 to November 20,1997. The special inspection identified three (3) Severity Level IV violations.
Our responses to the violations are provided below.
VIOLATION A
10 CFR 50, Appendix B, Criterion XI, Test Control, requires that all testing required to demonstrate that
structures, systems, ard components will perform satisfactorily in service is performed in accordance with
written test procedures which incorporate the requirements and acceptance limits contained in applicable
design documents. Test procedures shallinclude provisions for assuring that adequate test instrumentation
is available and used. Test results shall be documented and evaluated to assure that test requirements have
been satisfied.
Contrary to the above, prior to April 20,1995, the licensee failed to assure that the test instruments used in
RHR heat exchanger performance testing were adequate to assure the test requirements were satisfied.
Specifically, (1) the flow instruments used during the testing were calibrated at the wrong flow condition; and
(2) temperature instrument accuracy was such that small changes in temperature across the heat exchanger
led to large uncertainties in the test results.
RESPONSE
Reason for the Violation
Vertnont Yankee does not contest this violation. The test methodology attempted to utilize existing installed
instrumentation without adequately addressing calibration, accuracy and uncertainty effects caused by the differences
in test conditions from normal operating conditions. The detailed calculations used to develop and generate the test
acceptance curves included conservative assumptions for random error uncertainty, but did not sufficiently address
bias error effects on uncertainty. The test methodology was developed with detailed graphical acceptance curves,
which essentially became a pass / fail acceptance criteria for the test. This, coupled with the lack of an objective test
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ownership and oversight responsibility, led to a failure to identify and address a substantial test bias caused by the
transient nature of the test and instrumentation response,
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VERMONT YANKEE NUCLEAR POWER CORPORATION
Docket No. 50 271
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Page 2 of 5
Corrective Steos That Have Been Taken and the Results Achieved
Vermont Yankee developei a Basis for Maintaining Operation (BMO) which assessed and documented the
operability of the RHR heat exchanger. In addition to the corrective actions identified in the BMO, we conducted
an extensive study to identify and quantify the extent of the flow and temperature biases in the test methodology.
This was completed and documented on August 14, 1997. This study concluded that the quantification of the test
biases did not substantially affect the overall test results and that the RHR heat exchanger satisfied its design basis
heat transfer requirements.
Vermont Yankee also assigned the Service Water (SW) System Engineer to be responsible for future acceptance
testing of SW heat exchangers, which includes the RHR heat exchangers, incumbent with this ownership is a clear
understanding of the importance of proper development, conduct and critical evaluation of test results to continued
operability evaluations of the subject heat exchanger. Ownership was a critical missing aspect in the conduct of the
previous testing program. Management expectations identifying responsibilities for developing, conducting and
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evaluating heat exchanger test results have been generated and will be used in future testing.
Corrective Stet s That Will Be Taken to Avoid Further Violations
Vermont Yankee has internally committed to performing new baseline tests on the RHR and Spent Fuel Pool
Cooling (SFPC) heat exchangers with an independent, industry expert utilizing supplemental, high accuracy
instrumentation. Performance of baseline testing with indepenaent consulting expertise will result in a program that
-will ensure initial and ongoing testing compliance. Additional testing of the RHR heat exchanger (s) is currently
planned for our refueling outage beginning in March 1998 and the SFPC heat exchanger shonly following the
outage. A revised differential temperature testing methodology will be implemented for the corner room coolers,
RRU 7 and 8, currently scheduled for March 1998. This test method will also utilize supplemental high accuracy
test instrumentation.
Date When Full Compliance Will Be Achieved
Compliance was achieved on August 14,1997 when a study concluded that the quantification of test biases did not
substantially affect the overall test results and that the RHR heat exchanger satisfied its design basis heat transfer
requirements.
VIOLATION B
10 CFR 50.59(b)(1) requires that the licensee shall maintain records of changes in the facility to the extent
that these changes constitute changes in the facility as described in the safety analysis report and these records
must include a written safety evaluation which provides the basis for the determination that the change does
not involve an unreviewed safety question.
Contrary to the above, on December 30,1994, the licensee changed the facility as described in the FSAR and
failed to perform a written safety evaluation to determine that the change did not involve an unreviewed
safety question (USQ). Specifically, FSAR Section 10.7.6, Safety Evaluation, states that the RHR Service
Water Pump spaces are provided with space coolers (RRU 5,6,7 and 8) to prevent overheating of the safety-
related pump motors during long periods of operation. The licensee changed the classification of space coolers
RRU 5 and 6 from safety-related to nonsafety-related without a written safety evaluation to determine that
no unreviewed safety question existed.
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VERMONT YANKEE NUCLEAR POWER CORPOR ATION
Docket No. 50-271
Page 3 of 5
RESPONSL
Reason for the Violation
Vermont Yankee does not contest this violation. Comer room coolers RRU-5,6,7 and 8 are located in the ECCS
corner rooms which contain the RHRSW pumps, the ECCS pumps and associated instrumentation. To mitigate
postulated accidents, it must be determined that the pumps and associated equipment can withstand the post-accident
environment while performing their intended functions. To evaluate the ECCS corner room heat load, a post
accident (LOCA) heat removal analysis was performed. It was concluded that the long term cooling requirements
could be satisfied without taking credit for the heat removal capability of the RRU 5 and 6 coolers. Since the heat
removal capability of the RRU 5 and 6 coolers was not required, the heat removal safety function was downgraded
from Safety Class to Non-Nuclear Safety (NNS) class. Even though the heat removal function was revised to NNS,
the cooling units remained Safety Class 3 because of the service water pressure boundary interface. There was a
lack of recognition that a 10CFR50.59 Safety Evaluation was necessary as pan of this partial downgrade.
Additionally, no formal process ensured this activity was correctly and completely documented.
Corrective Steos That Have Been Taken and the Results Achieved
1)
A Safety Evaluation was completed in support of this safety function downgrade on July 2,1997.
2)
The non-safety related cooling function for RRU 5 and 6 has been documented in the SW Design Basis
Document (DBD).
3)
This event and others of a similar nature were collectively assessed and are being addressed by the
Configuration Management Improvement Project (CMIP) discussed below.
Corrective Steos That Will Be Taken to Avoid Further Violations
The FSAR will be revised to incorporate this revised heat removal function safety classification for RRUs 5 & 6.
This will be included in the next scheduled FSAR revision.
Based upon the evaluation of several related events prior to the Reference (b) inspection, Vermont Yankee initiated
a Configuration Management Improvement Program (CMIP) to improve the station's design control and
configuration management processes. A Project Plan has been established to enhance and streamline the
configuration management processes at Vermont Yankee and facilitate the use and maintenance of design basis
documentation. The CMIP basically consists of:
Design Basis Document (DBD) development
Validation of DBDs versus Plant
Process Improvements, including integration of procedures, DBDs, Improved Technical
Specification (ITS) program, accessibility of engineering and licensing information.
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FSAR Verification
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Open item resolution from all the above
This project is the responsibility of a project manager who reports directly to the Design Engineering - Nuclear
Services Manager. This project is a long term improvement process that will remain a "living" program through
the remaining plant lifetime.
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VERMONT Y ANKEE NUCLEAR POWER CORPORATION
Decket No. 50-271
Page 4 of 5
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One of the Process Improvements is the generation of a process that will address design basis changes to the facility
that do not result in physical modifications. This procedure will be utilized for the same type of issue raised in the
violation and prevent recurrence of similar violations in the future.
Date When Full Comoliance Will Be Achieved
Full compliance was achieved when a 10CFR50.59 Safety Evaluation was approved on July 2,1997 downgrading
the heat removal function of RRUs 5 & 6 to a non-safety related function.
VIOLATION C
10 CFR 50, Appendix B, Criterion XVII, Quality Assurance Records, requires that sufficien' records shall
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be maintained to furnish evidence of activities affecting quality. The records shall include records of
inspections and tests.
Contrary to the above, prior to June 10, 1997, the licensee failed to maintain su * at records, in that
technical specification surveillance test records for the main station battery servhee test performed on
September 14, 1996, in accordance with Procedure OP-412.5, " Main Battery Performance / Service Test,"
Rev.6, did not contain the printout of test data showing individual cell voltage (ICV) and battery terminal
voltage readings.
RESPONSE
Reason For The Violation
Vermont Yankee does not contest this violation. The records were appropriately generated during the test and
reviewed to insure the successful completion of the battery service test. The records were subsequently lost between
the engineer's review of the completed work package and transfer of the records to the document control center for
long term retention, in addition, the test equipment would have generated a test stoppage had the parameters fallen
outside of allowable values. Our initial assessment of this event determined the apparent cause to be failure to
follow procedure by personnel who are tasked with handling Maintenance QA records.
Corrective Steos That Have Been Taken and the Results Achieved
Personnel involved with this event were made aware of he importance of the computer printouts as part of the
procedure QA records.
Searches of Maintenance Engineering (including computer disks), document control and work control temporary
QA file areas were conducted in an effort to locate or re-create the data. This effort was unsuccessful. It should
be noted that the computer disks are not maintained as QA records. The procedure requires a paper copy be
attached to the procedure data sheets for retention as a QA record.
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Since this violation was received, a new higher level Event Report (ER) was initiated to investigate, assess for
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similar conditions and determine if any additional corrective actions are warranted.
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VERMONT YANKEE NtJCLEAR POWER CORPORATION
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Docket' No. 50 27.1
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Corrective Steos That Will be Taken to Avoid Further Violations
' In addition, the following actions are planned to insure proper control of all Maintenance QA records:
(1)
A self assessment will be performed of the training of administrative staff for the control, handling and
transmittal of Maintenance QA records. This is expected to be complete by May 31,1998.
(2)
Maintenance will evaluate the handling practices of in-process work packages to insure all necessary
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controls are in place to prevent a similar loss of documentation. This will include an evaluation of other
data types (computer printouts, field notes, etc.) that are potentially vulnerable to this type of occurrence.
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This is expected to be complete by July 31,1998.
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(3)
The control of computer disks containing backup data for test results will be evaluated. This is expected
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to be complete by July 31,1998.
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Date When Full Comoliance Will be Achieved
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Compliance has been achieved by review of the test data and signoff'by the cognizant engineer, subsequent review
of the computer file with your inspector and completion of the short term corrective actions.
The technical and administrative staff responsible for work package use and closcout are aware of the importance
of these ret.ords as part of the QA files. We believe this to be an isolated instance. Therefore, Vermont Yankee's
controls for retention of QA records are in compliance with 10CFR50, Appendix B and no further occurrences are
expected. The additional actions planned will help to insure that Vermont Yankee is not vulnerable in other areas
and that all personnel who work with the records are aware of their importance and procedure requirements for their
, control.
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We trust that the enclosed information is responsive to your concerns, however, should you have any questions or '
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require additional information, please contact us.
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Sincerely,
VERMONT YANKEE NUCLEAR POWER CORPORATION
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Donald A
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Senior Vice President, Operations
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cc:
USNRC Region 1 Administrator ,
USNRC Resident Inspector - VYNPS
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Vermont Department of Public Service
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