ML20198B078
| ML20198B078 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 12/09/1998 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Maret G VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| NUDOCS 9812180051 | |
| Download: ML20198B078 (27) | |
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I December 9,1998 l
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Mr. Gregory A. Maret Director of Operations Vermont Yankee Nuclear Power Corporation 185 Old Ferry Road Brattleboro, Vermont 05301
SUBJECT:
MID YEAR INSPECTION RESOURCE PLANNING MEETING - VERMONT YANKEE
Dear Mr. Maret:
On November 10,1998, the NRC staff held an inspection resource planning meeting (IRPM). The IRPM provided a coordinated mechanism for Region I to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in May 1999.
This letter advises you of our planned inspection effor' r%uiting from the Vermont Yankee IRPM review. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival j
onsite. Enclosure 1 details our inspection plan for the next 6 months. Resident inspections are not listed due to their ongoing and continuous nature. contains a historical listing of plant issues, referred to as the Plant issues Matrix (PIM), that were' considered during this IRPM process to arrive at an integrated view of licensee performance trends. The PIM includes only items from inspection reports or other docketed correspondence between the NRC and Vermont Yankee. The IRPM may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since
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the last NRC inspection report was issued, but had not yet received full review and
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consideration. This material will be placed in the PDR as part of the normal issuance of
' NRC inspection reports and other correspondence.
We willinform you of any changes to the inspection plan. If you have any questions, please contact me at 610-337-5233.
Sincerely,
/t
/
Original Signed By:
1 Curtis J. Cowgill, lil, Chief j
s PDR ADOCK 05000271 Reactor Projects Branch 5 G
PDR Division of Reactor Projects
. Docket No. 50-271
Enclosures:
- 1) Inspection Plan
- 2) Plant issues Matrix e._,.
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Mr. G. Maret:
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cc w/ encl:
i R. McCullough, Operating Experience Coordinator - Vermont Yankee G. Sen, Licensing Manager, Vermont Yankee Nuclear Power Corporation D. Rapaport, Director, Vermont Public Interest Research Group, Inc.
D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire
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Chief, Safety Unit, Office of the Attorney General, Commonwealth of Massachusetts b
~ D. Lewis, Esquire G. Bisbee, Esquire l
J. Block, Esquire T. Rapone, Massachusetts E>.ecutive Office of Public Safety D. Katz, Citizens Awareness Network (CAN)
M. Daley, New England Coalition on Nuclear Pollution, Inc. (NECNP)
State of New Hampshire, SLO Designee
. State of Vermont, SLO Designee Commonwealth of Massachusetts, SLO Designee 1
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Mr. G. Maret:
3 Distributio_D w/ encl:
Region I Docket Room (with concurrences)
PUBLIC Nuclear Safety information Center (NSIC)
NRC Resident inspector H. Miller, RA/W. Axelson, DRA -
DRP Director, Region i DRP Deputy Director, Region i DRS Director, Region I DRS Deputy Director, Region i DRS Branch Chiefs, Region I C. Cowgill, DRP R. Summers, DRP D. Callison, DRP C. O'Daniell, DRP R. Nimitz, DRS L. Scholl,DRS Distribution w/enci (VIA E-MAIL):
B. McCabe, OEDO
. C. Thomas, NRR (COT)
R. Croteau, NRR R. Correia, NRR inspection Program Branch, NRR (IPAS)
DOCDESK DOCUMENT NAME: G:\\ BRANCH 5\\1-VY\\PPR\\VYlRPM.RJS Ta receive a copy of this document,Indcate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N"=
No copy Rl/DRP 3. S^
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l RSummerdbo ~l OFFICE l
NAME CCowgill l'
DATE 12/7/98 12/4 /98 12/ /98 12/ /98 12/ /98 OFFICIAL RECORD COPY 0
ENCLOSURE 1 VERMONT YANKEE INSPECTION PLAN FOR DECEMBER 1998 THROUGH MAY 1999 Inspection Program Area / Title Planned Dates Type Inspection UO1277 Initial Exam Onsite Prep 01/11/99 OA 81700 Physical Security Program 01/25/99 Core UO1277 Initial Exam Administration 01/25/99 OA Occupational Radiation Exposure 83750 01/25/99 Core (Non-outage) aintenance Rule BaseHne 62706 03/22/99 OA Follow-up Environmental Monitoring 84750 04/05/99 Core Program 86750 Solid Radwaste Program 04/05/99 Core 82301 EP Exercise Evaluation 04/26/09 Core Legend:
IP Inspection Procedure Number Ti Temporary Instruction Program / Sequence Number Core -
Minimum NRC Inspection Program (mandatory at all plants)
OA Other inspection Activity Pi Additional Inspection Effort Planned by Region i SI Safety initiative Inspection l
E1-1
ENCLOSURE 2 PLANT ISSUES MATRIX l
E 2-1
VERMONT YANKEE PLANTISSUE3 MATRIX Date Type Source ID SFA Code item Description 8/14/98 Negative IR 98-10 N
1-OPS 4C A review of 1997 and 1998 LERs found that W has been slow in completing some root cause 699 evaluations and correcbve actions. A large number of these LERs related to old design issues which W is actively identifying and, overall, the completed corrective actions have been good.
No impact on plant safety has been observed as the result of the delays. W management has acknowledged this trend and is assessing the need for process improvements.
8/14/98 NCV IR 98-10 S
1-OPS 4C A required 1-hour notification to the NRC for the open torus vent system drain valves was 698 NCV 98-10-02 delayed by 30 days. The failure to make the report as required by 10 CFR 50.72 is considered a Non-cited Violation.
8/14/98 NCV IR 98-10 L
1-OPS 1C W identified two drain valves in the torus vent system were not in their required position during 697 NCV 98-10-01 the June 1998 reactor startup. Immediate corrective actions were appropriate and provided assurance that no other va!ve position discrepancies existed. The fact that the valves were open when primary containment was required is a violation, however this event did not have a significant impact on plant safety. This licensee identified and corrected violation is being treated as a Non-cited Violation.
8/14/98 Positive IR 98-10 L
1-OPS SA Operators identified an inconsistency in the TS requirements for automatic deactivation of the 696 turbine stop and control valve fast closure scram signals. Immediate corrective actions to reduce power and activate the scram inputs according to the most limiting TS were appropriate.
7/10/98 NCV IR 98-09 L
1-OPS SA The failure to continuously monitor and record torus temperature readings every five minutes as 695 NCV 98-09-02 SC required by Technical Specifications 4.7.A.1. was identified and corrected immediately by the licensee and is being treated as a non-cited violation.
7/10/98 VIO IR 98-09 S
1-OPS 1C Procedure inadequacies were identified that complicated the scram recovery actions: 1) 694 VIO 98-09-01 abnormal or emergency procedures not ensuring the RFPs in PTL; 2) procedure for reenergizing bus 6 did not identify automatic restart of turbine auxiliary oil pump. These two examples are considered a violation of Technical Specifications, Section 6.5.
7/10/98 Positive IR 98-09 N
1-OPS 1B Overall the on-shift operations crew performance was acceptable with some exceptions. A 693 problem relating to the on shift operating crew concemed the failure to conouct a full shift briefing to discuss re-energizing bus 6 prior to conducting the evolution and the failure to place the standby reactor feedwater pumps (RFPs) in pull-to-lock (PTL).
7/10/98 Positive IR 98-09 S
1-OPS 1B The NRC team determined that this transient had relatively low risk significance. All safety 692 2A equipment operated as expected.
7/10/98 Positive IR 98-09 N
1-OPS SB The Vermont Yankee (W) review of this event was timely and effective with some exceptions 691 noted. During their review, W did not question the calibration of the electrical bus overcurrent relays.
FROM: 10/1/97 TO: 8/14/98 Page 1 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Description ammmmmmmmmum -
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7/2/98 Negative IR 98-08 L
1-OPS 3A On two occasions, operations personnel were not rigorous in implement procedures with the 656 potential to affect Technical Specification related equipment. On a third occasion, operations personnel proceeded with main turbine activities after procedure acceptance criteria were not mot and no procedure change was initiated. None of these issues presented a significant technical or operational concem. No violations occurred and these incidents were viewed as personnel perfarmance weaknesses.
7/2/98 Negative IR 98-08 L
1-OPS 3A Operatore fared to identify the "A" core spray (CS) loop recirculation valve closed during the 655 electrical grCJnd investigation, causing the CS loop to be out of its normal alignment for over an hour before the condition was identified by an operations department supervisor.
7/2/98 VIO 1R 98-08 S
1-OPS 1C Inadequacies in an electrical ground isolation procedure rasulted in an unanticipated closure of 654 VIO 98-08-01 the "A" CS pump minimum flow valve. The lack of appropriate guidance in procedure OP-2145, conceming which systems and components would be affected and how they should be restored, was a violation of 10 CFR 50, Appendix B, Criterion V, Instructions Procedures, and Drawings.
7/2/98 Positive IR 98-08 S
1-OPS 1B Operators responded promptly and in accordance with applicable procedures to an unexpected 653 2A loss of the "A" reactor recirculation pump on June 5,1998. The shift supervisor conducted f equent briefings of the control room operators, and operator communications was a strength.
Operator actions were successful in causing the reactor to promptly exit the exclusion region of the power / flow operating curve.
5/2/98 Negative IR 98-04 N
1-OPS 3C On two occasions, known equipment problems were not discussed in the procedure or during 638 1C the pre 'olution brief, and presented minor challenges to the operators when they occurred.
5/2/98 Positive IR 98-04 N
1-OPS 1A The shutc.Jwn for the refueling outage was well controlled and the operators demonstrated good 637 3C teamwork and communications.
2/10/98 Positive IR 98-02 N
1-OPS 3B A simulator retake examination (Part C, only) was administered to one senior reactor operator 628 applicant on February 10,1998, at the Vermont Yankee Nuclear Power Training Center. The test met NRC expectations for a quality examination The applicant passed the retake examination.
3/14/98 Positive IR 98-01 L
1-OPS 4A VY appropriately reported the results of a corapleted analysis which verified the design 620 SB vulnerability of the standby gas treatment system to over-pressurization as a result of a design basis accident, during routine containment vent and purge operations. Interim corrective actions were determined to be appropriate and timely.
FROM: 10/1/97 TO: 8/14/98 Page 2 of 22 21 October 1998
VERMONT YANKEE PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 3/14/98 Positive IR 98-01 L
1-OPS 4A VY reported a potential unanalyzed condition involving the susceptiblity of the reactor building 619 SA closed cooling water (RBCCW) system to HELB. Specifically, VY postulated that the consequentia! failure of the RBCCW system following a HELB could compromise primary containment integrity. VY's identification of this RBCCW design vulnerability reflects well on the depth of review of their Design Basis Documentation Program.
3/14/98 NCV IR 98-01 L
1-OPS 1C Failure to perform four-hour estimates of offgas flow rate fo!!owing the loss of AOG instrument 618 NCV 98-01-01 SA power supply ES-OG-C at 9:35 a.m. on March 1, until 7:50 a.m. on March 2, was a violation of TS Table 3.9.2. However, this condition was of minimal safety significance, in that the plant operated at steady state conditions during this period and that AOG operation is routinely monitored during operator rounds. Accordingly, this licensee identified and corrected violation was treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy.
12/6/97 Positive IR 97-11 N
1-OPS 5B During a regularly scheduled NSAR committee meeting, the inspector observed that the 567 IR 96-200 presentations were informative and that many of the NSAR committee members actively engaged the presenters in additional discussion. The inspector determined that the agenda had been revised to focus routinely on the known problem areas of corrective action effectiveness and human performance.
12/6/97 Positive IR 97-11 N
1-OPS SA Station management and PORC response to the 11/25/97 reactor scram and the resolution of 565 5B plant technical and human performance concems prior to unit start-up were appropriate. The temporary modification (TM) and associated actions to address the generator runback circuit problem were adequately implemented, but operator training on the TM was weak and administrative overight not comprehensive.
12/6/97 Positive IR 97-11 N
1-OPS 1B Control room operator response to the 11/25/97 reactor scram was good and in accordance 564.5 3B with off-normal and emergency operating procedures.
12/6/97 VIO IR 97-11 S
1-OPS 1B A significant contributing cause of the automatic reactor scram was a failure to provide an 564 VIO 97-11-01 1A appropriate level of review and approval of the 345 KV switching orders which was contrary to LER 97-023 TS 6.5 and a cited violation.
10/31/97 Positive IR 97-08 L
1-OPS SA October 10,1997 ENS call, involving the ACS cable separation issue, identified an appropriate 551 LER 97-021 SB immediate response to the ACS operability concem and appropriate follow-up corrective actions.
9/4/97 Negative IR 97-09 N
1-OPS 3B Weak areas of understanding were identified during the written exam. SRO candidates directing 547 shift operations related to execution and use of emergency procedures was a significant item of Negative noted in the operating examination. Two of four applicants passed the exam.1 - SRO upgrade applicant failed written and operating portion and 1 - SRO upgrade applicant failed operating portion of exam.
FROM: 10/1/97 TO: 8/14/98 Page 3 of 22 21 October 1998
VERMONT YANKEE Pl. ANT ISSUES MATRIX Date Type Source ID SFA Code item Descr!ption 7/16/98 Negative IR 98-80 N
2-2B The licensee's informal handling of the cable vendor's failure analysis of the failed cable from 729 MAINT startup transformer T-3-B to Bus 2 did not property control the vendor-supplied service.
8/14/98 NCV IR 98-10 S
2-2B The VY staff took appropriate corrective actions in response to a failure of the "B" core spray 702 NCV 98-10-03 MAINT pump supply breaker on Ma-218,1998. The subsequent root cause investigation was thorough and the associated long term corrective actions were appropriate. VY's reporting of this event was consistent with the requirements of 10 CFR 50.72 and 10 CFR 50.73. The failure to provide adequate procedures for maintenance of 4160 volt safety-related circuit breakers was characterized as a Non-cited Violation.
8/14/98 Positive IR 98-10 L
2-2B The licensee appropriately identified an adverse trend in SW system reliability and established 701 MAINT the performance monitoring required by 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Although long term corrective actions have not yet been implemented, monthly evaluations are in progress and the established monitoring goals should ensure implementation of these improvements remains a priority.
8/14/98 Negative IR 98-10 N
2-2A A number of material condition deficiencies exist in the service water pump room and this area is 700 MAINT a notable exception to the overall good material condition of the plant. The deficiencies are actively tracked and evaluated by System Engineering as part of the Service Water System Health Report. VY has planned corrective actions and the inspector identified no operability concems.
7/10/98 Positive IR 98-09 S
2-5B The cause of the 'B' RP-M/G set trip was unknown but licensee troubleshooting and testing 697 MAINT efforts were sufficient to assure the equipment was operating properly just before plant startup.
7/10/98 Negative IR 98-09 S
2-SA During their investigation of the 'A' feedwater regulating valve (FRV) failure, the 'B' Recirculation 696 IFl 98-09-03 MAINT SC Pump M/G (RP-M/G) bearing failure, and the 'C' reactor feedwater pump (RFP) minimum flow valve, VY identified human performance problems in the maintenance process conceming foreign material control, analysis of failed parts, and of preventive maintenance inspections of the feedwater pump minimum flow valve pneumatic positioner.
7/2/98 Positive IR 98-08 N
2-2B A failure of the "B" standby gas treatment system to start on demand was identified as a 670 MAINT potential maintenance rule functional failure and is scheduled for evaluation. Appropriate goals for system monitoring have been established and there were no previous maintenance rule functional failures in the rolling three year period.
7/2/98 Negative IR 98-08 N
2-SA A 4-hour NRC event notification for a discovery that could have prevented fulfillment of a safety 659 MAINT 3C function was delayed by 14 days due to inadequate reviews and delays 4n Event Report 4C processing. Other recent examples indicate weaknesses exist in VY's process for evaluating potentia!!y reportable events. The failure to make a required NRC notification within the time frame specified by 10 CFR 50.72(b) is being cited as a violation.
FROM: 10/1/97 TO: 8/14/98 Page 4 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Description 7/2/98 Negative IR 98-08 N
2-2B The "B" standby gas treatment system fan failed to start on demand due to an incorrect over-658 MAINT current trip setting on its supply breaker. Installation procedures for a 1992 modification failed to implement required design settings and this error is being cited as a violation of 10 CFR 50, Appendix B, Criterion 111, Design Control.
7/2/98 Positive IR 98-08 N
2-2A A closecut inspection of the torus found the overall cleanliness was very good, particularly 657 MAINT considering the scope of work performed during the refueling outage (grit-blasting and recoating of all underwater surfaces, and installation of new strainers on the residual heat removal and core spray system suctions). The housekeeping conditions in the drywe!! were also examined during final closeout, and were determined to be adequate to support reactor operations at power.
5/2/98 Positive IR 98-04 N
2-1A The NRC concluded that the licensee followed the plant technical specifications for the 642 MAINT degraded primary containment penetration associated with the recirculating water sample line.
Also, the licensee provided an appropriate basis for the retraction of the event notification.
5/2/98 VIO IR 98-04 S
2-2B The short circuiting of the "A" main station battery that occurred on April 1 was the result of 641 VIO 98-04-02 MAINT 3C inadequate supervisory oversight of preparations to perform the battery charge. VY's immediate corrective actions were appropriate, and the initial root cause evaluation was adequate. Failure to perform steps of the goveming procedure in series was a violation of TS 6.5.
5/2/98 Positive IR 98-04 S
2-SB VY was successful in identifying a single leaking fuel bundle through in-core sipping.
640 MAINT SC Continuation of in-core sipping after the leaking fuel Ibundle had been identified was conservative. VY was taking appropriate steps to identify the cause of the fuel leak.
5/2/98 NCV IR 98-04 L
2-2B Incorrect orientation of a peripheral fuel bundle was identified by an alert operator during an 639 NCV 98-04-01 MAINT 3A unrelated activity, and was the result of 1) an error in the fuel loading schedule, and 2) an error in performance of the fuel movement procedure. These errors were mitigated by the fact that they were identified and corrected during the ongoing fuel movement operation, and that an oppoitunity for disovery of the condition still existed during the full core verification phase of refueling. Licensee corrective actions were prompt and appropriate, which resulted in a non-cited violation consistent with section Vll.B.1 of the NRC Enforcement Policy.
3/14/98 NCV 1R 98-01 L
2-SA As a result of a question posed during training, VY determined that two out of six channels of the 623 NCV 98-01-04 MAINT SB APRM downscale trip function were not being tested in accordance with TS Table 4.1.1. The 3B failure to test APRM channels "B" and *E' downscale trip functions represented a violation of TS surveillance requirements. Once identified, the affected channels were declared inoperable and the surveillance procedure was promptly revised to test their function weekly. This licensee identified and corrected violation was not cited.
FROM: 10/1/97 TO: 8/14/98 Page 5 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Description 3/14/98 Negative IR 98-01 N
2-3A The inspector observed a few instances where the VY staff's performance during the S/U 622 MAINT 3B transformer work did not meet management's expectations, in that test data, which were 4B consistent with an intermittent low ground was not initially recognized; one operations shift crew was not fully cognizant of the extent of maintenance restoration; and post-maintenance ground monitoring, as specified in the maintenance plan, was initially overlooked.
3/14/98 Positive IR 98-01 N
2-3A The decision to continue troubleshooting the T-3A startup transformer intermittent ground while 621 MAINT 1C at p0wer was appropriate and consistent with Technical Specifications. The transformer outage plan included appropriate administrative controls on the duration of the activity; prerequisites and operational limitations were well thought out, and contingency actions were adequately addressed. Workers were methodicalin the performance of tasks, and industrial safety and real-time housekeeping were noted to be strengths.
1/24/98 Positive IR 97-12 L
2-1A During routine rounds, an auxiliary operator heard a noise in the feedwater heater bay which 609 MAINT 2A was subsequently determined to be an instrument air leak between the regulator and the valve controller for a feedwater heater high level dump valve. A repair plan and operational contingencies were promptly developed, and the repair was completed without incident. The inspector concluded that the air leak repair activity was an appropriately prompt response to a problem that had been identified as a result of good watchstanding practice.
1/24/98 Positive IR 97-12 N
2-3A Special tests were conducted to co!!ect information on operation of the RHR and CS pumps in 608 MAINT the current minimum flow configurations, in response to concems raised by the NRC in inspecton report 97-201. The inspector observed that the tests were well planned and performed in a controlled manner.This non-intrusive data collection / ultrasonic instrument troubleshooting activity was appropriately controlled via a station work order.
12/19/97 VIO IR 97-81 N
2-SA A violation was identified for inadequate determination of the effectiveness of risk significant 600 VIO 97-81-01 MAINT SC SSC maintenance during a refueling outage because unavailability was not monitored. Prompt corrective actions resulted in closure of this violation during the inspection.
12/19/97 Positive IR 97-81 N
2-1C Performance criteria for systems included with the scope of the Rule appeared to be acceptable.
599 MAINT However, the VY methodology for establishing reliability performance criteria differed from other prior accepted programs.
12/19/97 Positive IR 97-81 N
2-1C The level of detail in the PRA, truncation limits and quality of the PRA were appropriate to 598 MAINT perform risk categorixation in accordance with the Maint Rule. Risk ranking methodology was consistent with industry guidance and basis for expert panel risk ranking decisions were thoroughly documented. The risk ranking by the expert panel for the sample of SSCs reviewed was appropriate.
FROM: 10/1/97 TO: 8/14/98 Page 6 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Descr/ption 12/19/97 Positive IR 97-81 N
2-1C VY had done a good job on identifying those systems, structures, and components (SSCs) to be 597 MAINT included in th<. ;, cope of the maintenance ru!e.
12/6/97 Positive IR 97-11 N
2-28 The "A" service water subsystem limiting condition for operation maintenance period included 569 MAINT preventive maintenance on the "C" SW pump and motor. No problems were noted, and activities were completed weII within the 15-day allowed outage time.
10/31/97 NCV IR 97-08 L
2-SA The low pressure coolant injection surveillance testing discrepancy discussed in LER 96-27 was 555 Positive NCV 97-08-05 MAINT not cited. This licensee identified and corrected old design issue was appropriately resolved by LER 96-27 the VY staff.
10/31/97 NCV IR 97-08 L
2-SA Procedural non-compliance contributed to this fuel oil samp!ing and analysis problem. However, 554 Negative NCV 97-08-04 MAINT 3A this procedural error was not cited. Licensee corrective actions were appropriate.
LER 96-29 3C 10/31/97 NCV IR 97-08 L
2-SA Licensee identified and corrected reactor building ventilation radiation monitor testing 553 Positive NCV 97-08-03 MAINT discrepancy was not cited. VY staff actions to resolve this discrepancy were prompt and LER 96-23 appropriate.
10/31/97 Positive IR 97-08 N
2-3A Based upon observation of a variety of maintenance and surve!!!ance testing activities, 552 MAINT appropriate control and execution of these activities was noted.
10/31/97 NCV IR 97-08 L
2-SA The low pressure coolant injection surveillance testing ciscrepancy discussed in LER 96-27 was 520.2 LER 96-27 MAINT SC not cited.
10/31/97 NCV IR 97-08 L
2-3A The procedural non-compliance which contributed to the fuel oil sampling and analysis events 520.1 LER 96-29 MAINT 1C discussed in LER 96-29 was not cited.
10/31/97 NCV IR 97-08 L
2-3A Licensee staff identified through-wall cracks in the radwasted building ventilation ductwork (LER 520 LER 96-23 MAINT 2A 96-23) which provided a potential unmonitored release pathway. Prompt and appropriate SC corrective action was initiated to remedy the problem, which was not cited.
7/16/98 NCV IR 98-80 L
3-ENG 4A The licensee's safety evaluation for the 1974 HPCl/RCIC Vacuum Breaker Modification (EDCR 728 NCV 98-80-09 73-32) incorrectly stated that the modification did not create an unreviewed safety question.
This old design issue was a violation of 10 CFR 50.59 but was not cited in accordance with Enforcement Policy Vll.B.3.
7/16/98 VIO IR 98-80 N
3-ENG 4A The licensee's safety evaluation for the control room HVAC temporary modification and 727 VIO 98-80-01 procedure change failed to address the impact of required operator actions and was a violation of 10 CFR 50.59.
FROM: 10/1/97 TO: 8/14/98 Page 7 of 22 21 October 1998
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VERMONT YANKEE PLANTISSUES MATRIX Date Type Source
/D SFA Code item Description 7/16/98 Positive IR 98-80 N
3-ENG 38 Personnel responsible for the commercial grade dedication program were knowledgeable of the 726 program and appeared to be implementing the program properly.
7/16/98 Positive IR 98-80 N
3-ENG 4A Modification EDCR 97-414, AOG Modifications, was acceptable with sufficient documentation i
725 and justifications, adequate installation instructions, and adequate post modification testing to ensure operability. The team also concluded that the program for designing and installing configuration changes to plant systems was adequate and the 50.59 program was properly applied in this case.
7/16/98 Positive IR 98-80 L
3-ENG SC Modification EDCR 98-402, HPCl/RCIC Vacuum Breakers, resolved the technical issue 724 associated with water hammer problems and installed a design that is consistent with other utilities and with General Electric recommendations.
7/16/98 Positive IR 98-80 N
3-ENG 4C The Minor Modification procedure was appropriately being used to make minor design changes.
722 The Equiva!ency Evaluation procedure provides for a detailed assessment of attemate replacement items and this process was property implemented for the items sampled.
7/16/98 Positive IR 98-80 N
3-ENG SC The licensee was working off their TM backlog and had a procedure in place to minimize future 721 TM's. PORC review of the overdue TMs was also evidenced and the team concluded sufficient management attention was being given to TMs.
7/16/98 VIO IR 98-80 N
3-ENG SB Corrective actions for the control room ventilation system temporary modification, if the 720 VIO 98-80-02 nonsafety-related instrument air supply was lost, were inadequate in that no operability determination was performed in accordance with administrative procedures and the root cause determination failed to identify that the components were previously overlooked during engineering reviews performed in response to NRC Generic Letter 88-14, a violation of Appendix B, Criterion XVI.
7/16/98 VIO IR 98-80 N
3-ENG SA The licensee failed to report the control room HVAC design deficiency as required by 10 CFR 719 VIO 98-80-03 4C 50.73 and a violation was issued.
3C 7/16/98 Positive IR 98-80 N
3-ENG 4A The DBD program was concentrating on the most risk significant systems and this program was 718 4C an essential part of the transition of design engineering responsibility to VY.
7/16/98 VIO IR 98-80 N
3-ENG 4C The licensee's failure to maintain control of the new design basis documents resulted in a 717 VIO 98-80-04 violation agairst Appendix B, Criterion Ill, Design Control.
7/16/98 Positive IR 98-80 N
3-ENG 5A The Event Report (ER) process provided sufficient information to support the early identification 716 of emerging problems to licensee management. ER screening meetings contributed the perspectives of all departments to ER disposition plans.
FROM: 10/1/97 TO: 8/14/98 Page 8 of 22 21 October 1998
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VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Description 7/16/98 Negative IR 98-80 N
3-ENG SB Trend report frequency (annual) and corrective action for recurring problems areas were being 715 evaluated by the licensee. Previous inspections and SALP assessments identified ER trending as a weakness and no significant progress has been made in th;s area.
7/16/98 Negative IR 98-80 N
3-ENG SB The documentation of initial operability determinations was not a! ways consistent with 714 procedural guidance.
7/16/98 NCV IR 98-80 N
3-ENG SA The licensee issued a late LER for the HPCl/RCIC vacuum breaker, a violation of 50.73. This 713 NCV 98-80-05 4C item was similar to the violation recently issued with inspection Report 50-271/97-10. This 3C reportability issue was not cited in accordance with Enforcement Policy Vll.B.1 7/16/98 Negative IR 98-80 N
3-ENG 28 The licensee's control of vendor supplied services for the steam relief valve setpoints was weak.
712 7/16/98 Positive IR 98-80 N
3-ENG SA The licensee's conservative approach for containment pressure, using an analysis from a similar 711 5B plant with key W values incorporated, provided reasonable assurance that the plant could startup and operate safely. An inspector fo!!ow-up item was opened pending review by the NRC of the W specific analysis.
7/16/98 Positive IR 98-80 N
3-ENG 4C The W Systems Engineering organization continued to show progress in implementing its 709 mission consistent with the industry expectations for systera engineers. The system engineers' notebooks and system health reports reviewed by the team were consistent with those goals.
7/16/98 VIO IR 98-80 N
3-ENG 4C A change to the Quality Assurance Program that reduced previous commitments was 708 VIO 98-80-07 implemented prior to NRC approval and was a violation of 10 CFR 50.54.
7/16/98 Negative IR 98-80 N
3-ENG SC The licensee did not address the potential impact on plant equipment and a continued 707 implementation of the unapproved standard. This indicated a weakness in implementat!on of the corrective action process. An unresolved item was opened pending the completion of t!te NRC's review of a related licensee submittal.
7/16/98 Positive IR 98-80 N
3-ENG 5A The QA program instituted at W to provide oversight of the functional area assessments was 706 acceptable and use of the self assessment program was effective.
7/16/98 Positive IR 98-80 N
3-ENG 2A The station service transformer, bus 9 rating and bus 9 feeder breaker overcurrent relay setting 705 had sufficient margin available to permit the testing of the fire pump under all operating conditions.
FROM: 10/1/97 TO: 8/14/98 Page 9 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Descript/on 8/14/98 Positive IR 98-10 N
3-ENG 4C The Inservice Inspection (ISI) program was property controlled and had been satisfactorily 703 implemented. It included acceptab!e ASME program coverage, qualified personnel, approved procedures, proper implementation, appropriate examination documentation, and VY oversight.
The ISI personnel were knowledgeable of ISI and ASME Code requirements. The documentation supporting the program and ISI examinations was appropriate and readily available. Observations and indications had been clearly documented and resolved satisfactorily.
7/10/98 Negative IR 98-09 N
3-ENG 4A The licensee's failure to identify the deficiency in the VY design basis document EDG-1 703 regarding frequency control, was a deficiency of the licensee's Design Control and would be addressed in inspection report 50-271/98-80.
7/10/98 Negative IR 98-09 N
3-ENG 2B The licensee's failure to verify the EDG required frequency setting by a documented 702 independent review was a shortcoming in their EDG surveillance procedure.
7/10/98 Negative IR 98-09 S
3-ENG 2B The licensee's procedure control process exhibited a problem in that the operations and 701 surveillance procedures for a loss of normal power (LNP) were not well coordinated.
Specifically, prior to the June 9,1998 event, there was no documented evidence that either Reactor Protection System (RPS) motor generator (M/G) set or vital instrument M/G set would perform satisfactorily in service during the starting of a residual heat removal (RHR) pump on an emergency diesel generator (EDG) supplied bus.
7/10/98 VIO IR 98-09 N
3-ENG 5A The licensee's failure to enter their event reportinr; (ER) process and initiate appropriate 700 VIO 98-09-04 corrective action as a result of their repeated out-of-toleranc@iings (including the November 1997 'D' RHR O/C trip delay calibration finding) was a vioWn oN OFR 50, Appendix B, Criterion XVI, Corrective Action.
7/10/98 Negative IR 98-09 S
3-ENG 4A The discrepancy between the bus 1 O/C relay setting, w1ich was based on starting a single RFP 699 and the control circuit diagram which permitted a two p mp automatic start, reflected an oversight in the licensee's Design Control process.
7/10/98 Negative IR 98-09 N
3-ENG SB The licensee's failure to consider the calibration of the bus 1 overcurrent (O/C) relay a potential 698 contributing cause is a shortcoming in their root cause analyses.
7/2/98 Positive IR 98-06 N
3-ENG 4B The inspectors concluded that the licensee's actions to resolve the BMOs identified in the 690 SB licensee's May 1,1998 letter, as they pertain to restart of the plant, have been appropriate.
SC Adequate controls are in place to ensure the mitigating factors are implemented prior to restart.
7/2/98 Positive IR 98-06 N
3-ENG 4C The inspectors concluded that the licensee had taken prompt and comprehensive corrective 689 58 action where appropriate or the items were already discussed in other inspection reports.
SC FROM: 10/1/97 TO: 8/14/98 Page 10 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Description 7/2/98 VIO IR 98-06 N
3-ENG 5A The irapectors concluded that the licensee failed to recognize that the failure to notify the NRC 688 VIO 98-06-01 4C when they (VY) identified that the ECPs would not safeguard the integrity of the containment 3C barrier was a violation of the reportability requirements of 10 CFR 50.73.
7/2/98 Positive IR 98-06 N
3-ENG 58 The inspectors concluded that the licensee had implemented their operability assessment 687 SC program in accordance with their procedures and BMO guideline. The inspectors review of a sample of the BMOs related to the outage work and restart revealed no problem areas.
7/2/98 Positive IR 98-06 N
3-ENG SB The inspectors concluded, based on a limited review of the LOCA analysis at the Duke 686 Engineering and Services offices, that the calculation adequately supported the initial torus temperature of 90 F. A more thorough review of the analysis will be performed by NRR in conjunction with the licensee's proposed change number 204 to the Technical Specifications.
7/2/98 Negative IR 98-08 N
3-ENG 4B Two weakness were identified during NRC review of VYs corrective action for steam tunnel 673 SA blowout panels. The operability determination failed to address the impact of a lower relief pressure on the secondary containment design basis and VTs walkdown of the steam tunnel failed to identify a missing pipe penetration seal. The penetration seal was replaced prior to plant start up. Pending VYs evaluation of the BMO weaknesses, secondary containment operability during previous operation, and review of reporting requirements, this issue will be tracked as an unresolved item.
7/2/98 Negative IR 98-08 N
3-ENG SA A modification that upgraded the safety classification of release mechanisms for two steam 672 tunnel blowout panels adequately resolved an NRC-identified design inadequacy.
7/2/98 Negative IR 98-08 L
3-ENG 4C The licensee identified that the chamfers on the intemal edges of five high energy line break 671 containment isolation valves were inconsistent with those recorded in applicable work documents and procedure requirements. The correct chamfers were installed in the valves in May 1998, reducing the potential for valve damage under blowdown conditions.
5/2/98 NCV IR 98-04 L
3-ENG SA Thorough licensee review of an in-service test procedure identified that two thermal relief check 646 NCV 98-04-03 4C valves had not been adequately tested in the forward direction during the 1996 refueling outage.
Immediate operability determinations were prompt and adequately founded.
5/2/98 Negative IR 98-04 N
3-ENG SA VY's initialinvestigation of the effect of the fault on the "A" main station battery was not of 643 sufficient depth to prove operability. VY subsequent analysis, based on additional information obtained from the battery manufacturer, concluded that the battery had not been damaged as a result of the event. The NRC determined that this conclusion was adequately founded.
3/11/98 Licensing Meeting N
3-ENG 4C Licensing issues needed for restart were not submitted in a timely manner. The NRC indicated 636 Summary that better planning is needed by the licensee to avoid late submittal of documents which require NRC review.
FROM: 10/1/97 TO: 8/14/98 Page 11 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Description 2/23/98 Licensing Letter N
3-ENG 4C Numerous licensing actions required expedited NRC reviews to meet licensee schedules.
635 Licensee timeliness of submittats could be improved.
4/15/98 Licensing Letter, Relief N
3-ENG 4B The licensee's planned testing on the torus patch did not appear to meet ASME Code 634 Request requirements. When the NRC pointed this out, the licensee submitted a Code relief request.
This was viewed as a licensee engineering staff weakness involving a lack of timeliness and inadequate specification of retest requirements.
3/14/98 Negative IR 98-01 L
3-ENG 5A The VY staff's discovery and initial dispositioning of the hign pressure coolant injection and 624 4A reactor core isolation cooling systems' vacuum breaker design vulnerability was appropriate.
4B The retraction of the January 15,199810 CFR 50.72 notification appears to have been poorly founded, based upon the subsequent review of the November 30,1971 letter to the NRC staff defining the vacuum breaker instaliation and updating the licensing and design basis. (The inspector notes that the retraction was subsequently withdrawn on March 23,1998.)
1/24/98 NCV IR 97-12 L
3-ENG SA VY's identification and corrective actions to address electrical cable separation *old design 616 Positive NCV 97-12-04 4A issues" were appropriate and were executed, or planned to be accomplished, in a time period commensurate with their safety significance. These actions are consistent with Generic Letter 91-18 and 10 CFR 50, Appendix B, Criterion XVI," Corrective Actions." The extended period without appropriate electrical cabling separation was a violation of 10 CFR 50, Appendix B, Criterion lit, Design Control, as well as the VY UFSAR. However, this violation was not cited in accordance with Section Vll.B.1 of the NRC Enforcement Policy.
1/24/98 Positive IR 97-12 N
3-ENG 2A Seismic and safety grade classification issues associated with the HPCI gland exhauster 615 URI 97-05-04 SC discharge line to the SBGT system, the torus /drywell pumpback system, and interfacting connections, were being appropriately addressed. The licensee provided a reasonable basis for the classifications and the URI was closed.
1/24/98 Positive IR 97-12 N
3-ENG 2A in reviewing seismic design considerations for the +/- 24 volt DC power system, the inspector 614 URI 97-05-03 SC determined that there is no regulatory requirement for this system to be a safety class electrical system, and therefore, that the batteries need not be seismically mounted. Imprecise wording and inconsistencies in formatting in the FSAR which lead to this issue being raised are being addressed by the licensee. Accordingly, URI 97-05-03 is closed.
1/24/98 Negative IR 97-12 N
3-ENG SC Based upon the inspector's review of active Basis for Maintaining Operations (BMOs) and the 613 4C VY staff's current projections for closure of BMOs following the Spring 1998 refuel outage, the NRC was concemed with resolution of the issues.
FROM: 10/1/97 TO: 8/14/98 Page 12 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Description 1/24/98 Positive IR 97-12 L
3-ENG SA As a result of the design basis documentation effort, W identified that the vent side of the 612 4A vacuum breakers on the high pressure coolant injection (HPCI) and reactor core isolation cooling (RCIC) steam exhaust lines to the torus should more appropriately coummunicate from inside the torus vice outside primary containment.
1/24/98 Positive IR 97-12 L
3-ENG SA During an independent review of the containment re-analysis and the torus temperature analysis 611 5B of record, the licensee identified several potential sources of energy input to the torus that had either not been accounted for or were non-conservative.
12/19/97 Positive IR 97-81 N
3-ENG 3B The maintenance rule coordinator and his assistant in the maintenance organization 606 demonstrated an excellent knowledge of the maintenance rule program and were key to the successfulimplementation. System engineers had good overall knowledge of the maintenance rule and the specific applicable requirments to their duties.
12/19/97 Positive IR 97-81 N
3-ENG SC W had developed appropriate guidelines for conducting and documenting periodic 605 assessments. The guideline covered the topics required by the rule. The periodic assessment that was dated November 1997 was not completed in a timely manner. However, it adequately covered the areas required in paragraph (a)(3) of the rule and was determined to be thorough.
12/19/97 Positive IR 97-81 N
3-ENG 1C The approved procedures for the planning and control of equipment removed from service,at 604 power, to perform preventive maintenance were determined to be appropriately detailed and consistent with the intent of 10 CFR 50.65, paragraph (a)(3). The implementation of these procedures and the specific LCO Plan executed for the "A" RHRSW pump replacement during the week of December 15,1997, were well planned and executed.
12/19/97 Positive IR 97-81 N
3-ENG 1C The system engineers and expert panel reviewed and revised system basis documents, 603 performance evaluations, and performance improvement plans as required. It was noted, in some cases during the initialimplementation of the maintenance rule and development of the system engineering department assignments, that event report investigations were not completed in a timely manner.
12/19/97 Positive IR 97-81 N
3-ENG 1C The criteria established and trending for the systems within the scope of the maintenance rule 602 were appropriate. Industry wide experience was appropriately used to assist in determining root cause and corrective actions. Additionally, W administrative procedures established the proper guidelines for initiating goals, trending, and monitoring.
12/19/97 Positive IR 97-81 N
3-ENG 1C The goal setting and monitoring of selected (a)(1) systems were appropriate. Corrective actions 601 plans were found to be generally well implemented and for the most part timely. Use of industry operating experience to assess in-scope SSCs was evident. System engineers interviewed were generally knowledgeable of their assigned systems and familiar with the maintenance rule and its implementation.
FROM: 10/1/97 TO: 8/14/98 Page 13 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code item Description 11/20/97 NCV IR 97-10 L
3-ENG SA Non-cited violation issued for numerous "old design" issues identified by the VY staff as a result 595 Positive NCV 97 SC of several design review efforts in progress. Licensee efforts include Design Basis 11a thru 11g Documentation, improved Tech Specs project, improved Setpoint Program.
11/20/97 Negative IR 97-10 N
3-ENG 2B Licensee departed from coinmitments made in response to GL 89-13, with respect to RRU and 594 RHR heat exchanger thermal performance testing (reference VY letter BVY 90-007, dated 1/22/90.)
11/20/97 VIO IR 97-10 N
3-ENG 4C Licensee failed to maintain adequate control of the main battery survei!!ance test quality records 593 VIO 97-10-08 28 as required by Appendix B, Criterion XVil. Negative in the engineering design interface for control of surveillance testing and data collection.
11/20/97 VIO IR 97-10 N
3-ENG 4C Limnsee failed to adequately evaluate changes to the safety classification of safety related 592 VIO 97-10-07 ECCS comer room cooling room units RRU S and RRU 6. Violation of 10 CFR 50.59 requirements which occurred in December 1994.
11/20/97 VIO IR 97-10 N
3-ENG 4C Ucensee failed to assure test instruments adequate for intended function (Appendix B, Criterion 591 VIO 97-10-06 XI, Test Control). Poor design control and design testing oversight by the engineering staff.
3-ENG SC An aggregate SL 111 violation was issued for (A) inadequate design control relative to torus 590.9 01013 5A temperature limits [10 CFR 50 Appendix B Criterion 111], (B) inadequate corrective action for a 01023 discrepancy between the design and TS [10 CFR 50 Appendix B Criterion XVl], and C) failure to 01033 report past operation in a condition outside the plants design basis (10 CFR 50.73).
IR 97-10 4/14/98 VIO EA 97-531 N
3-ENG 4A 10 CFR 50 Appendix B Criterion ill Design Control violation for failure to translate design limits 590.8 02014 for consecutive RHR pump starts into operating procedures.
3-ENG 4A 10 CFR 50 Appendix B Criterion l11 Design Control violation for failure correctly select equipment 590.7 03014 is a subsystem essential to the safety-related function of the emergency diesel generators.
Specifically, air to the solenoid valves that operated the EDG service water cooling flow control valves was supplied by a nonsafety-related pressure regulator whose failure could have prevented the flow control valves from opening.
3-ENG 4A 10 CFR 50 Appendix B Criterion ll! Design Control violation for failure to correctly translate RHR 590.6 04014 minimum flow specifications into procedures.
3-ENG 4A 10 CFR 50 Appendix B Criterion I!! Design Control violation for failure to use the correct design 590.5 05014 inputs in calculation of net positive suction head margin for the RHR pumps.
FROM: 10/1/97 TO: 8/14/98 Page 14 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code Itern Description 4/14/98 VIO EA 97-531 N
3-ENG 4A 10 CFR 50 Appendix B Criterion ill Design Control violation for failure to update the heat 590.4 06014 exchanger fouling assumption used in RHR service water room cooler thermal performance calculations after an inspection of the cooler unit coils indicated the assumption was incorrect.
3-ENG 4A 10 CFR 50 Appendix B Criterion lil Design Control violation for failure to assure correct 590.3 07014 references and inputs were used in two design calculations.
3-ENG SB 10 CFR 50 Appendix B Criterion XVI Corrective Action violation for failure to properly evaluate 590.2 08014 SC and correct the nonconformance between vendor recommended RHR pump minimum flow and the plant configuration despite prior opportunities.
3-ENG SB 10 CFR 50 Appendix B Criterion XVI Corrective Action violation for failure to property eva!uate 590.1 09014 SC and correct a degraded condition relative to commitments in the Preliminary Design Assessment Report for protection against the effects of tomadoes.
3-ENG SA The licensee failed to report a condition that alone could have prevented the fulfillment of the 590.05 10014 4C safety function of the RHR system as required by 10 CFR 50.73.
3C 11/20/97 Positive IR 97-10 N
3-ENG 4B Licensee had improved its validation process as a result of lessons leamed from the A/E 589 4C inspection. Licensee adjusted the depth and breath of its validation process using SSFI type techniques.
12/6/97 NCV IR 97-11 N
3-ENG 4B The adequacy of controls for the conduct of system manipulations for performance monitoring, 574 Negative NCV 97-11-02 4C was reviewed. This issue was the result of an inspector observation of system performance monitoring, during which a procedural limit was found to have been exceeded. Inspector fo!!ow-up and day-to-day monitoring of plant activities indicated that the type of intrusive system performance monitoring conducted during inspection period 95-19 was isolated. The failure to have property operated the RBCCW system per OP-2181 was a violation of minor safety significance and not cited.
12/6/97 NCV IR 97-11 L
3-ENG 4C The VY staff identified the applicability of the generic issue involving the omission of 570 Positive NCV 97-11-03 4B overpressure relief protection for piping sections that are isolated by the primary containment LER 96-15 isolation system. Having implemented comprehensive and time!y corrective actions to resolve this "old design issue," it was not cited.
10/31/97 NCV IR 97-08 L
3-ENG SA Failure to have included and tested a number of keep fill system check valves in the VY 557 Positive NCV 97-08-06 Inservice Testing Program was not cited. These program oversights were identified via licensee LER LER 96-11 corrective actions for a previous violation.
FROM: 10/1/97 TO: 8/14/98 Page 15 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA s'ade item Description 10/31/97 Strength IR 97-08 L
3-ENG 4C W established a program that met commitments to GL 89-10, " Safety-Related Motor-Operated 556 Valve Testing and Surveillance." Final validation of switch settings scheduled to be completed by 1/30/98. Use of Electric Power Research Institute (EPRI) motor-operated valve (MOV) performance prediction program to validate switch settings for all MOVs was a program strength.
10/9/97 Negative L
3-ENG 5A Division Si powered and Sil powered cables located in the same manho!e, contrary to FSAR 548 LER LER 97-021 5B statement and W separation criteria due to inadequate original design specifications. Due to LER 97-006 use of inadequate design specification and installations during initial plant construction.
10/16/97 Positive IR 97-80 N
3-ENG SC W continues to review and correct cable separation issues. Inspectors found some minar cable 542 tray installation problems that did not affect equipment operability.
7/2/98 Negative IR 98-08 L
4-PS 2B The failure to maintain fire barrier penetration seal 40-T10465 in a configuration corresponding 685 to the tested configuration is a violation of NRC requirements, which is not being cited since the condition was identified, and corrected, by W.
7/2/98 Positive IR 98-08 N
4-PS 1C The 1997 annual audit of the EP program met all the requirements of Part 50.54(t) of NRC 683 regulations. The licensee did not provide copies of the audit to the local offsite agencies, although they were available for review by these agencies. The contractor organization that performed the quality assurance audits was sufficiently independent from the contractor support provided to the licensee's EP staff. The licensee's pursuit of corrective actions for identified problems was aggressive but not always wellaiocumented 7/2/98 Positive IR 98-08 N
4-PS 1C The EP training function has ensured that assigned responders were kept adequately trained as 682 required by the emergency plan. However, the NRC concluded that the licensee's evaluation of training was generally informal in that the licensee did not have good tracking mechanisms to monitor completion of drill requirements and relied on oral feedback about course material.
7/2/98 Positive IR 98-08 N
4-PS 1C The licensee's EP organization was adequately staffed to oversee the EP function at the site.
681 There were indications of some communications issues that had the potential to reduce overall effectiveness. The senior managers with responsibilities for oversight of EP maintenance were adeuately informed of their duties. The licensee was adequately maintaining the emergency response roster as well as the respirator qualifications of members of the emergency response organization.
7/2/98 Positive IR 98-08 N
4-PS 1C The recent changes to the emergency plan and implementing procedures were made in 680 accordance with NRC requirements.
7/2/98 Positive IR 98-08 N
4-PS 2A The licensee maintained the major onsite and offsite emergency facilities in an adequate state of 679 readiness. Equipment readiness surveillances were routinely performed.
FROM: 10/1/97 TO: 8/14/98 Page 16 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source iD SFA Code item Description 7/2/98 Positive IR 98-08 N
4-PS SA W implemented genera!!y effective self-assessments, surveillance, and audits of radiation 678 SB protection program activities.
SC 7/219 8 Positive IR 98-08 4-PS 1C W established and implemented a sampling and analysis program in response to NRC Bulletin 677 80-10. The licensee is effectively investigating a condition involving trace tritium contamination identified in storm drains. Notwithstanding, the low-level material is being effectively monitored and controlled in accordance with regulatory requirements.
7/2/98 Positive IR 98-08 N
4-PS 1C W implemented its radioactive material and contamination control program in an effective 676 2A manner. Station areas were generally clean with no significantly contaminated areas or abandoned areas identified. While the licensee *s criteria for evaluation of removable alpha contamination for material was not consistent with NRC guidance, the licensee took immediate and effective action to correct procedures and communicate the change.
7/2/98 Positive IR 98-08 N
4-PS 1B Radiation protection requirements were effectively implemented for the June 9,1998, reactor 675 scram. High radiation area access controls were implemented in accordance with procedures.
General radiation protection program practices and procedures (e.g., posting barricading and access controls) were appropriately implemented.
7/2/98 Positive IR 98-08 N
4-PS 1C W established and implemented good extemal and intemal exposure controls, and 674 3A implemented effective radioactive material and contamination controls during the cycle 20 refueling outage. W met outage occupational exposure goals, notwithstanding some early identifled deficiencies involving torus work activities.
5/2/98 VIO IR 98-04 N
4-PS 4A The inspector identified a pathway which provided unmonitored access from the turbine building 652 VIO 98-04-06 SA into the reactor building vital area. Appropriate compensatory measures were established, and long term corrective action is under development. The pathway for unmonitored vital area access was a violation of the W Physical Security Plan.
5/2/98 Positive IR 98-04 N
4-PS 1C W maintained an effective program for the training and qualifications of contractor radiation 651 protection personnel. The licensee implemented an effective audit of ongoing radiological controls activities.
5/2/98 Positive IR 98-04 N
4-PS 1C W implemented an effective radioactive material and contamination control program during the 650 outage.
5/2/98 NCV IR 98-04 L
4-PS 1C Applied radiological controls for ongoing work activities were generally well implemented. The 649 NCV 98-04-05 licensee implemented generally effective extemal and intemal exposure control programs. A licensee-identified condition involving high radiation areas with inadequate barricades and postings was appropriately addresssed.
FROM: 10/1/97 TO: 8/14/98 Page 17 of 22 21 October 1998
VERMONT YANKEE PLANT ISSUES MATRIX um Date Type Source ID SFA Code item Description ui 5/2/98 Positive IR 98-04 N
4-PS 1C Overall, the licensee implemented an ALARA program that met the requirements of the 648 regulations. Notwithstanding, ALARA planning and preparation activities were limited in scope and areas for improvement were identified.
5/2/98 Negative IR 98-04 N
4-PS 1C VY radiological control coverage of significant work involving torus modifications was weak.
647 Additionally, industrial safety issues involved in the work were not immediately recognized and addressed by the licensee until brought to management's attention by the inspector. Upon notification, the licensee suspended work activities pending improvements in radiological control coverage, and took action to address the industrial safety concems.
3/19/98 Positive IR 98-05 N
4-PS 1A As an enhancement to the inspection, Section 6.1 of the Plan, titled "lliumination," was reviewed.
632 2B The inspectors determined, by observing the performance of a lighting survey by secunty personnel using a calibrated light meter, that the licensee was implementing its lighting program as required in the Plan.
3/19/98 VIO IR 98-05 N
4-PS 3A During performance testing of the personnel and package search equipment, a second violation 631 VIO 98-05-01 3B of NRC requirements associated with access controls of personnel and packeges was identified.
Specifically, a test device was introduced into the search train by the regional assist team with the licensees knowledge, and w0s not detected by the security force.
2/10/98 VlO IR 98-05 N
4-PS 1C Performance testing of the IDS, by the regional assist team, resulted in the assist team 630 VIO 98-05-02 4C successfully gaining undetected access into the protected area (PA) by climbing over the protected area barrier (PAB) without generating an alarm in six of ten zones. This resulted in a violation of NRC requirements associated with the protected area intrusion detection system.
3/19/98 Positive IR 98-05 N
4-PS 1A In general, the licensee maintained a satisfactory program. Management support is ongoing as 629 1C evidenced by adequate manning levels to permit effective program implementation and some recent security equipment enhancements. Audits were thorough and in-depth, event logs are being trended and ana!yzed quarterly, and security equipment, with the exception of the intrusion detection system (IDS), was being tested and maintained in accordance with the NRC-approved physical security plan (the Plan).
3/14/98 Positive IR 98-01 N
4-PS 1C The Quality Assurance audits and surveillance reports were thorough, programmatic, and well 627 5A documented. However, self-assessment activity was minimal.
3/14/98 Strength IR 98-01 N
4-PS 1C Overall, the program for the transportation of radioactive materials and its related activities and 626 3B the training program for these activities were being implemented effectively.
3/14/98 Positive IR 98-01 N
4-PS 1C The implementation of the solid radioactive waste program was managed effectively.
625 2B FROM: 10/1/97 TO: 8/14/98 Page 18 of 22 21 October 1998
VERMONT YANKEE PLANTISSUES MATRIX Date Type Source ID SFA Code
! tem Description 1/24/98 VIO IR 97-12 N
4-PS 1C The HPCI room automatic self-closing fire door was inoperable for an indeterminate period 617 VIO 97-12-05 2A between October 2,1997 and January 13,1998. W took prompt action to restom operability SC and to correct the suspected cause. The inoperable fire barrier was a violation of 10 CFR 50, Appendix R requirements.
11/20/97 NCV IR 97-10 L
4-PS SA Non-cited violation issued for licensee identified concems resulting from corrective actions from 596 Positive IR 97-80 a previous violation issued against 10 CFR 50, Appendix R.
LER 96-26 12/6/97 Positive IR 97-11 L
4-PS 2A Licensee actions to identify a leaking fuel rod and supprese flux to minimize further aggravation 568 3C of the condition were appropriate and timely. The W staff proceeded carefully and deliberately in addressing this issue.
10/31/97 NCV IR 97-08 L
4-PS SA Failure to have appropriately controlled the movement of reactor vessel shield blocks during the 562 Positive NCV 97-08-07 1990 and 1992 refueling outages was not cited. This event was appropriately identified and LER 96-03 resolved by the W staff.
10/31/97 Positive IR 97-08 L
4-PS 1C R7 -Technical depths of audits was good and met TS rquirements. Chemistry lab QC 561 program was very good.
10/31/97 Positive IR 97-08 L
4-PS 3A The licensee maintained plant air cleaning systems in accordance with established design 560 specification. The licensee performed exce!!ent iodine collection efficiency test methodologies for SBGT system.
10/31/97 Positive IR 97-08 L
4-PS 1C The licensee maintained and implemented a good calibration program and good trending 559 analyses for effluent radiation monitonng systems.
10/31/97 Positive IR 97-08 L
4-PS 1C The licensee maintained and implemented effective radioactive liquid and gaseous effluent 558 control programs.
10/16/97 Positive IR 97-80 N
4-PS SC The NRC staff considered Ws initiatives to identify long-standing App. R and fire program 541 design issues a Positive. Corrective actions taken and planned to prevent recurrence of similar design deficiencies were comprehensive. Due to the comprehensive response, the NRC decided to exercise discretion and not cite the additional violations of NRC requirements identified during Ws detailed review of Appendix R and fire protection programs.
10/16/97 Positive IR 97-80 N
4-PS 3B The W staffs current understanding of fire protection and Appendix R requirements was found 540 to be good.
10/16/97 Positive IR 97-80 N
4-PS 5B Overall, the licensee had made good progress in resolving fire protection and Appendix R 539 program related issues. The team determined that appropriate interim corrective actions were in place to compensate for identified Appendix R program deficiences.
FROM: 10/1/97 TO: 8/14/98 Page 19 of 22 21 October 1998
ABBREVIATIONS USED IN PIRE TABLE NSAR' Nuclear Safety and Audit Review PORC Plant Operations Review Committee TM Temporary Modificabon TS Technical S +:;'-A:+1 ENS Emergency Nobficabon System ACS Attemate Coohng System SRO Senior Reactor Operator NCV Non-Cited Violation SCRO Senior Control Room Operator RHR Residual Heat Removal CS Core Spray PRA Prababilistic Risk Analysis SW Service Water BMO Basis for Maintaining Operation LSFT Logic System FuncbonalTesting PCIV Primary Containment isolation Valve RPT/ARI Recire Pump Trip /Altemate Rod inserbon LCO Limiting Condition for Operabon FSAR Final Safey Analysis Report HPCI High Pmssure Coolantinjuechon RCIC Reactor Core ise;duen Cooling RHRSW RHR Service Water ECCS Emergency Core Cooling System FROM: 10/1/97 TO: 8/14/98 Page 200f 22 21 October 1998 u
=
RRU Room Recrculation Unit EDG Emergency DieselGenerator LOCA Loss of Coolant Accdent -
RBCCW Reactor Building Closed Cooling System LER Licensee Event Report MOV Motor-Operated Valve QC Quality Control EOP Emergency Operating Procedure GL Generic Letter FROM: 10/1/97 TO: 8/14/98 Page 21of 22 21 October 1998 f
GENERAL DESCRIPTION OF PIM TABLE COLUMNS The actual date of an event or segruficant issue for those items that have a clear date of occurrence (mainly LERs), the date the source of the informabon was issued (such as for EALs), or the last date of the inspection period (for irs).
7)pe The categorization of the item or finding - see the Type / Findings Type Code table, below.
Source The document that describes the findings: LER for Licensee Event Reports EAL for Enforcement Action Letters, or IR for NRC Inspedon Reports.
AD Identrlication of who discovered issue: N for NRC; L for Licensee; or S for Self Identifying (events).
SFA SALP Fundional Area Codes: OPS for Opersbons; IAAINT for Maintenance; ENG for Engineenng; and PS for Plant Support.
Code Template Code-see table below.
Nem Descripson Details of NRC findings on LERs that have safety significance (as stated in irs), findings described in IR Executive Summaries, and amphfying ;..fv.ne:;06 contained in EALs.
TYPE / FINDINGS CODES TEMPLATE CODES ED Enforcement Discretion - No Civil Pena ty 1
Operational Performance: A - Normal Operations; B - Operatons During Transients; and C -
Strength Overall Strong Licensee Performance Weakness Overau Weak Licensee Performance 2
Material Condition: A - Equipment Condition or B - Programs and Processes EER
- Escalated Enforcement item - Waiting Final NRC Action 3
Human Nfv.aeace: A -Work Performance; B - Knowledge, Skills, and Abilities I Training; C -
VIO Violation Level 1,ll,Ill, or IV 4
Engineenng/ Design: A - Design; B - Engineenng Support; C - Programs and Processes NCY Mited Vm' DEV Deviaton from Licensee Commitment to NRC S
Problem idenbficaten and Resoluten: A - Identification; B - Analysis; and C - Resoluten Positive Individual Good Inspechon Finding NOTES-Negative Individual Poor inspection Finding Eels are apparent violatons of NRC requirements that are being considered for escalated enfh.ea; action in accordance with the " General Statement of Policy and Procedure for NRC LER Licensee Event Reportto the NRC Enforcement Action" (Enforcement Policy). NUREG-1600. However, the NRC has not readied its final enforcement decision on the issues idenbfied by the Eels and the PIM entnes may be URI" Unresolved item from inspection Report modified when the final decrsions are made. Before the NRC makes its enforcement decison, the Licensing Licensing issue from NRR ficensee win be pmvided with an opportunity to either (1) respond to the apparent violation or (2) request a predecisional entwient conference.
RulSC Miscenaneous - Emergency Preparedness Finding (EP), Declared Emergency, Nonconformance issue, etc. The type of an MISC URis are unresolved items about which more information is required to determine whether the findings are to be put in the item Descnptm column.
issue in question is an acceptable item, a deviation, a nonconformance, or a violation. However, the NRC has not reached its final conclusions on the issues, and the P!M entries may be modified when the final conclusens are made, 1
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