ML20202D343
| ML20202D343 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 02/05/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20202D315 | List: |
| References | |
| 50-271-97-10, NUDOCS 9802170051 | |
| Download: ML20202D343 (30) | |
See also: IR 05000271/1997010
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Docket No: 50 271
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License No: DPR 28
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Report No: 50 271/97 10
Licensee: Vermont Yankee Nuclear Power Corporation
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Facility: Vermont Yankee Nuclear Power Station
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Location: Vernon, Vermont
Dates: September 29 November 20,1997
Inspectors: George W. Morris, Reactnr Engineer
William A. Cook, Senior Resident Inspector
Edward C. Knutson, Resident inspector
Robert J. Summers, Project Engineer
Approved by: William H. Rutand, Chie' :
Electrical Engineering Banch '
Division of Reactor Safety
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9902170051 990205
PDR ADOCK 05000271
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EXECUTIVE SUMMARY
Vermont Yankee Nuclear Power Station
NRC Inspection Report Nn. 50 271/97 10
This inspection included aspects of licensee engineering and technical support operations.
As a result of the NRC's Architect / Engineer (A/E) team inspection documented in
inspection report 50 271/97 201, dated August 21,1997, and follow up by the regional
and resident inspectors, multiple apparent escalated enforcement items and three violations
were Identified.
Enalneerina
- The licensco f ailed to maintain control of the design process by f alkng to assure
suitebility of equipment to support safety related functions and failing to verify the
inputs of safety related calculations. (Section E1.1)
- The licensee f ailed to provido prompt or adequate corrective action for conditions
adverse to quality on f"se occasions. (Section E2.1)
- The licensee failed to provide licensee event reports required by 10 CFR 50.73
when equipment was found outside the design basis. (Section E4.1)
- The RRU 5 & 6 room coolers were reclassified as nonsafety-related without a safety
evaluation. (Section E3.1)
- The RHR heat exchanger performance test f ailed to adequately identify and control
the required test instrument acceptance criteria. (Section E2.3)
- The quality assurance records associated with the 1996 main station banery
surveillance tests could not be recovered and were presumed lost. (Section E3.2)
- Six design issues and one fire protection issue were treated as non cited violstions
in accordance with Sections Vll.B.3 and Vll.B.4 of the NRC's Enforcement Policy.
(Sections E8.3 ano F3.1)
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TABLE OF CONTENTS
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E X E C U T I V E S U M M A R Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
111. E n g i n e e r i n g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
El Conduct of Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
E1.1 D e sig n Cont r ol . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
E1.2 Design Basis Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
E2 Engineering Support of Facilities and Equipment .......................5
E2.1 Cor r ective Ac tion s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 i
E2.2 (Update) Unresolved item 50 271/97 201 12: Room Cooler Test
Measurement inaccuracles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
E2.3 (Closed) Unresolved item 50 271/97 201 18: Measuring and Test
Equipment /RHR Heat Exchange Thermal Performance Test . . . . . . . . . . . 9
E3 Engineering Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . 9
E3.1 Safety Evaluations . .....................................9
E3.2 (Closed) URI 50 271/97 201 22: Loss of Surveillance Recorda . . . . . . . 11
E4 Eng ieering Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . 11
E4.1 Reportability Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
E8.1 Licensing Commitments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
E8.2 Station Blackout and Alternate Power Supply . . . . . . . . . . . . . . . . . . . 13
E8.3 Licensee Identified Design issues Review . . . . . . . . . . . . . . . . . . . . . , .14
E8.4 (Closed) FSAR Update ........ ..........................17
F8 Miscellaneous Fire Protection Issues ..............................18
F8.1 Inoperable Fire Barrier Penetration Seals identified in LER 96 26 . . . . . . 18
V. M a n a g em e nt M eeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
X1 Exit Meeting Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
lTEMS OPENED, CLOSED AND DISCUSSED . . . . . . . . . ...................20
LIST OF ACRONYMS USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2
A/E INSPECTION TEAM OPEN ITEMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
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Reoort Details
lil. Eneineering
E1 Conduct of Engineering
E1.1 Deslan Control
a. insoection Scone (92903)
Inspection report 50 271/97 201 documented multiple examples of design control
problems. -The inspectors reviewed the following unresolved items to assess the -
Vermont Yankee (VY) design control process,
b, Observations and Findinas
(Closed) Unresolved item 50 271/97 201-Qj Suppression Pool Cooling The
licensee identified that Technical Specification Amendment No. 88, which permitted
operation with the suppression pool above 90*F, was not consistent with the FSAR
safety analysis. The licensee documented this deficiency in Event Report (ER) 96-
0644, dated November 2,1995. The licensee had also established an
administrative limit of 90'F (except during surveillance testing) in response to Basis
for Maintaining Operability (BMO) 96 05. The licensee's review of the historical
record determined that during two separate periods, one in August 1988 and
another in August 1993, the suppression pool temperature had exceeded 90*F.
The licensee documented this finding in ER 97 0635, dated May 29,1997. The
NRC architect / engineer (A/E) inspection team document 61 that the licenses had
failed to maintain maximum suppression pool temperature consistently within the
value used in the FSAR Chapter 14.6.3 accident analysis. This is an apparent
violation of 10 CFR Appendix B, Criterion Ill, Design Control in that the licensee
f ailed to control the design interfaces (completely determine all the effects of
operating with the suppression pool temperature above 90*F). (eel 50 271/9710-
01a)
Ifdgnd) IFl 50 271/97 201 04: RHR Pump NPSH Calculated Margin - The A/E
team identified that the licensee had used non conservative curvo fit data instead of
actual vendor data to demonstrate net positive suction head (NPSH) margin for RHR
pumps. In response to the A/E finding, the licensee issued ER 97 0664, dated
May 29,1997, and memorandum VYS 60/97, dated June 6,1997, which justified
operability based on conservatism in other supporting calculations. This is an
apparent violation of 10 CFR 50, Appendix B, Criterion lil, in that the licensee failed
to correctly establish the suitability of application of the RHR pump NPSH under all
design conditions. (eel 50 271/9710 01b)
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{Q1qsed) LER 50 271/9712:NCV 50 271/9710-02and Unresolved item
50 271/97 201 05: RHR/LPCI Flow Rates The licensee identified that calculation
VYC 0937, Rev.1, had failed to verify the low pressure coolant injection (LPCI)
flow inputs to the loss of coolant accident (LOCA) analysis VYC 937, were
correctly interpreted in Tech Spec 4.5.A.1.c. The licensee issued ER 97 0502,
dated May 0,1997, to document this deficiency and immediately evaluated the
effect on peak clad temperature to be less than 50'F.10 CFR 50.40 (a)(3)(l)
defines a significant change or error is a difference in peak fuel cladding temperature
of more than 58'F.
The f ailure to verify the I F7 flow inputs to the LOCA analysis is a violation of
10 CFR Appendix B, Crefatu % Design Control. This violation was identified by
, the licensee and corrects gims were prompt and comprehensive. As a result,
this violation of NRC requirembo;s will not be cited in accordance with Section
, Vll.B.1 of the NRC Enforcement Policy. (NCV 50 271/97 10 02)
l IClosed) Unresolved item 50 271/97 201 00: RHR Pump Minimum Flow Protection
The A/E team identified that the licensee had f ailed to rectify the discrepancy
between the RHR pump minimum flow and the pump vendor's documented
minimum flow protection requirements. At VY, the minimum flow lines of both RHR
pumps have orifices restricting flow to 350 gpm. The pump manuf acturer
recommended a continuous minimum flow of 2700 gpm with a one time only
allowance of 350 gpm for 30 minutes based on a pump in good condition. This is
an apparent violation of 10 CFR 50, Appendix B, Criterion lil, in that the licensee
f ailed to establish the suitability of application of the RHR pump minimum flow
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protection, that is essential to the safety related function of the RHR system, by not
rectifying the discrepancy between the manuf acturer's recommendation and the as-
installed design. (eel 50-271/9710 01c)
(Closed) Unresolved item 50 271/97 201 08: RHR Pump Motor Starting Limitations
The RHR motor starting limits were provided based on a motor design ambient
temperature of 80'F. The A/E team identified that the licensee had f ailed to
correctly translate the RHR corner room accident design temperature and RHR pump
motor manufacturer's starting limits into operating procedure OP 2124, RHR
System, Rev. 42, dated April 24,1997. The licensee initiated ER 97 0714, dated
Juno 10,1997, to address this concern because the RHR pump motors may be
required to start in ambient temperatures as high as 148'F. Failure to correctly
translate the expected motor ambient temperature and the manuf acturer's
recommendations into operating instructions is an apparent violation of 10 CFR 50,
Appendix B, Criterion Ill. (eel 50 271/9710 01d)
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(Closed) Unresolved item 50 271/97 201 13: Room Cooler Thermal Performance - l
The licensee had based its acceptance criteria for room cooler thermal performance I
on fouling caused by silting. The A/E team identified that the licensee had failed to
revise the fouling assumptions used in calculation VYC 1329 as a result of its
inspection of the safety related unit coolers RRU 7 and 8 in April 1995. That ;
inspection confirmed that the increase in pressure drop across the cooler coils was '
not oue to silting, but possibly micro-fouling. Use of an incorrect assumption for
the fouling mechanisms in the room cooler thermal performance calculations is an
apparent violation of 10 CFR Appendix D, Criterion 111, in that the licensee f ailed to
establish the suitability of application of the room cooler thermal model. (eel 50-
271/9710 01e)
(Closed) Unresolved item 50 271/97 201 18: Equipment Classifications The A/E
team identified that the licensee had f ailed to assure the capability of the nonsafety-
related control air equipment to support the operation of the safety related diesel
generators. The A/E team report incorrectly implied that the pressure regulators
controlled cooling of both diesels. The inspectors confirmed that each diesel has its
own pressure regulator. The licensee issued ER 97 0512, dated May 9,1997, to
address this issue and replaced the questionable components on both emergency
diesel units with dedicated safety-related components. This is an apparent violation
of 10 CFR 50, Appendix B, Criterion lil, in that the licensee failed to establish the
suitability of nonsafety related components in a subsystem essential to the safety-
related function of the emergency diesel generators. (eel 50 271/9710 01f)
(Closed) IFl 50 271/97 201-25: Cable Separation The A/E team identified that the
licensee failed to document all exceptions to meeting the required cable separation
criteria. The licensee issued ER 97 0663, dated June 2,1997, for the generic
concern of documenting exceptions to cable separation criteria, and ER 97 0662,
dated June 4,1997, for the specific identified concern of lack of swaration for
cables routed through manholes for the Vernon tie. The licensee's immediate
evaluation indicated no short term corrective action was required but indicated the
separation design basis document, VYS-027, needed to be updated to document
the observed exceptions. Cable separation will be followed under unresolved item
50 271/97 03 02 pending further NRC review of the licensee's cable separation
assessment.
[Qodate) IFl 50 271/97 201 26: Instrument Calculations - The A/E team identified
that the licensee had failed to revise instrument uncertainty calculations to include
instrument drift factors. The inspectors confirmed that the licensee had previously
started an instrument setpoint program. This item will remain open pending NRC
review of the licensee's incorporation of the drift design guide into the setpoint
design guide.
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(Closed) IFl 50 271/97 201 27: RHR Flow Instrument Loop Uncertainty The A/E
team identified that the licensee had failed to include instrument uncertainty in the
determination of RHR/LPCl flow test acceptance criteria, in response to this
concern, the licensee issued ER 97 0694, dated June 6,1997. Although the
licensee found no operability concern, it did acknowledge that the large
uncertainties associated with the RHR flow required resolution. This is an apparent
violation of 10 CFR 50, Appendix B, Criterion ill, in that the licensee failed to
include instrument uncertainty into the RHR/LPCI flow specifications and
instructions. (eel 50 271/9710-01g)
(Closed) IFI 50-271/97 201 29: Calculation Control- The A/E team identified that
the licensee had failed to use the latest documents for calculation inputs, in
accordance with engineering instruction WE 103, Engineering Calculations and
Analyses. The inspectors observed that even though the licensee had embarked on
a configuration management program, including design basis documentation and
verification, two of the examples noted in the A/E report involved recent
calculations (VYC 298, Rev.10, dated April 22,1997 and VYC 1349, Rev.1,
dated April 30,1997). This is an apparent violation of 10 CFR 50, Appendix B,
Criterion Ill, in that the licensee failed to assure correct references and inputs were
used in design calculations. (eel 50 271/9710 01h)
c. Conclusions '
The inspectors concluded that the licensee had failed to maintain control of the
design process as required by 10 CFR 50, Appendix B, and Yankee Operational
Quality Assurance Plan 1 A (YOQAP 1 A), Criterion lil, Design Control, by failing to
consider all relevant effects of the design on maintaining the plant design basis.
E1.2 Deslan Basis Documentation
f a. Insoection Scoce (92903)
The cover letter to inspection report 50 271/97 201, dated August 27,1997,
included a statement where the A/E team concluded that it was unlikely that the
licensee would have uncovered some of the issues identified in that report. The
licensee had indicated at the A/E inspection exit that they would re-examine its
design basis verification program. The inspectors reviewed the design basis
document (DBD) verification results during this inspection to assess the licensee's
approach to DBD verification.
b. Observations and Findingg
The inspectors met with members of the licensee's Configuration Management
improvement Project (CMIP) to review the results of the initial validation effort. The
licensee indicated two DBDs (125 VDC system and 480/4160VAC system) were
validated using aafaty system it.nctional inspection (SSFI) techniques. This effort
started on August 11,1997, and an internal exit was held on September 30,1997,
which identified errors and inconsistencies in the refert,nced documents, along
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with calculation control problems and discrepancies in procedures. The licensee
stated that 41 event records were generated, with two potentially significant items
affecting the de system. The licensee concluded that it would continue to look at
100% of the requirements documented in the DBDs during the validation process,
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until a higher confidence level was obtained.
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c. Conclusions
The inspectors concluded that the licensse had strengthened its validation process
as a result of the lessons learned from the A/E Inspection. The inspectors
concluded tha licensee had adjusted the depth and breath of its validation inspection
using the SSFl techniques simPar to those used in the A/E team inspection and
concluded that its validation efforts should produce results similar to the A/E team .
review.
E2 Engineering Support of Facilities and Equipment
E2.1 Corrective Actions
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a. insoection Scope (92903)
Inspection report 50 271/97 201 documented examples of untimely or inadequate
corrective actions. The Irv . 'ctors reviewed the following unresolved items to
assess the licensee's corre J action process,
b. Observations and Findinas
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(Closed) Unresolved item 50 271/97 201 02: Suppression Pool Elevated
. Temperature - The A/E team identified that the licensee had failed to evaluate, in a
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timely manner, operability of the emergency core cooling system (ECCS) pumps
, when taking suction from the suppression pool at elevated temperatures. Elevated
temperatures of the suppression pool affects the available net positive suction head ;
for the ECCS pumps. This concern was first identified by the licensee in 1994 as
Engineering Deficiency Report 94 05 at Yankee Atomic, and later enter'sd into the
licensee's problem reporting system as ER 95 0644, dated November 11,1995.
This is an apparent violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective
Action, in that the licensee failed to promptly identify and correct a non-
conformance concerning elevated suction temperature on ECCS operability.
(eel 50 271/9710-03a)
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(Closed) URI 50 271/97 201 10: RHR System Operation in Suppression Pool
Cooling Mode The licensee had identified, during a revision to a calculation, a
single failure vulnerability while operating in the suppression pool cooling mode.
Under these conditions, one train of the RHR system would be operating outside its
design basis lineup for low pressure coolant inspection (LPCl). The inspectors
confirmed that the licensee had established appropriate corrective action in the form
of administrative controls, following the discovery of the potential single failure
vulnerobility. Those controls result in the RHR system being entered into the LCO
log whenever it is operated in the suppression pool cooling mode. The inspectors
found no examples where, had an LCO been entered, that the allowed outage time
would have been exceeded. Therefore, based on the scope of the inspectors'
review, no LCO violation was identified.
(Closed) Unrgsolved item 50 271/97 201 11: RHR Operability Determination To 4
operate the RHR system in the suppression pool cooling mode, the licensee takes
one sub-system out of its design basis line up, leaving the RHR system vulnerable to
a single f ailure. Technical Specification (TS) 3.5.A requires the RHR/LPCI systems
be declared inoperable if either subsystem is not available to perform its safety
function. This was previously identified in NRC inspection report 50 271/93-80as
a weakness in the administrative control process. The licensee had planned to
address this concern as part of its Improved Technical Specification (ITS) prog am.
When the ITS program was delayed, the licensee failed to take appropriate action to
address the operation of the RHR system outside its design basis. The inspectors
confirmed the licensee had f ailed to enter a limiting condition for operation (LCO) for
this condition on April 17,1997, but when the "A" LPCI subsystem was operated
on September 26,1997,it had been entered on the inoperable list. The licensee
has administratively addressed this concern since the A/E team inspection. The
f ailure to take prompt corrective action to enter LCOs when performlag testing is an
opparent violation of 10 CFR 50, Appendix 8, Criterion XVI, Corrective Action.
(eel 50 271/9710-03b)
(Closed) Unresolved item 50 271/97 201 19: Service Water (SW) Pump Operability
- The A/E team identified that the licensee had failed to revise nonconservative
technical specification 3.5.D.3 for SW pump operability in a timely nianner after it
discovered the condition on February 24,1997 (ER 97 0198). As an immediate
compensatory action, the licensee revised procedure OP 2181, Service
Water / Alternate Cooling Water Operating Procedure, to add the appropriate action
statement via department instruction (Dil 97 28. The failure to take prompt
corrective action ta revise a nonconservative technical specification is an apparent
violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. (eel
50 271/9710-03c)
[ Closed) Unresolved item 50-271/97 201 20: Use of Probabilistic Risk Assessment
(PRA) Methods to Address Tornado Missile Hazards Inspector follow-up identified
that ER 97-0584 was closed on June 19,1997, with an open internal VY
commitment item (No. ER 97 0584 01)to " determine if crimping of diesel generator
exhaust pipe is a credible failure." The ER included internal memoranda dated
May 7,1997, and May 20,1997, addressing the A/E team's question on tornado
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i missiles. The inspectors examined closed ER 97 0584 package and identified that
! the EDGs were determined to be operable and that the identified conditions were I
i not deemed reportable. However, the inspectors also determined that the Basis for !
Maintaining Operction (BMO) process had not been initiated. .
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inspectors' review of the May 20,1997, memorandum identified that the VY staff '
I was unsure of the application of PRA criteria for this issue based on their statement
that, "...use of a probabilistic approach for design basis tornado considerations is i
4 currently open to question..." The May 20,1997, memorandum also stated that
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"...it is possible we (VY) will need to separately submit an amendment for.NRC l
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review and acceptance...," referring to the VY's not yet submitted Individual Plant ;
, External Event Evaluation (IPEEE). Further, the May 20,1997, memorandum stated *
j there was an " apparent lack of specificity in the FSAR" with respect to the specific ,
! missile protection to be afforded the EDG support systems in question. !
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, Based upon these documented VY staff conclusions, the inspectors determined that
- ths VY staff should have invoked their BMO process as soon as the performance of
the EDG system was called into question to resolve these outstanding questions
- and apparent lack of design specificity. The inspectors also found the application of
PRA methods to support the EDG operability determination to be in conflict with the
Generic Letter No. 91 18 guidance, section 6.9. Consequently, the licensee failure ,
to take appropriate measures to assure conditions adverse to quality (the EDG l
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support systems tornado missile design vulnerability) were corrected, is an apparent r
violation of 10 CFR 50, Appendix B, and yOQAP 1 A, Criterion XVI, " Corrective i
Actions." (eel 50 271/9710-03d) ,
, (Closed) Insoector Follow un item 50 271/97 201 23: Standby Battery Chstger -
The A/E team identified that the licensee had failed to correct unconservative
technical specification 3.10, regarding the licensee identified potential single failure
vulnerabliity of the dc system when operating with the standby battery charger for
an indefinite period of time. The inspectors confirmed that the licensee had
originally identified this deficiency as open Ol-DC 18 in the 125V DC System Design ,
Basis Document and had lasted ER-0177 on February 21,1997, to address the
technical concern. The inspectors also confirmed that the licensee had issued
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department instruction DI 97 76 on May 5,1997, revising operating procedure
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OP 2146, Operation of 125 Volt Battery Chargers to enter the LCO when operating
with tne spare battery charger as a compensatory measure. However, the ;
licensee's failure to identify the nonconservative technical specification and take
i prompt corrective action is an apparent violation of 10 CFR 50, Appendix B,
Criterion XVI, Corrective Action. (eel 50 271/9710 3e)
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c. Conclusigna
The inspectors concluded that the licensee had f ailed to maintain an adequate
corrective action program as required by 10 CFR 50, Appendix B and YOQAP 1 A,
Criterion XVI, Corrective Action, in that the licensee f ailed to (1) take prompt
corrective action to evaluate operation of the ECCS pumps taking suction from the
suppression pool at elevated temperature, (2) take prompt corrective action to
submit TS amendment requests for nonconservative TS, and (3) evaluate the
potential degraded performance of the EDG system following a tornado using their
BMO process.
E2.2 (Undatel Unresolved item 50-271/97 201 12: Room Cooler Test Measurement
inaccuracieg
a. lncoection Scoce (92903)
Inspection report 50 271/97 201 documented an example of potentially inadequate
test control. The inspectors reviewed unresolved item 50 271/97 20112 to
assess the licensee's test control as it applied to room cooler RRU 7 thermal
performance testing,
b. Observations and Findinas
The A/E team questioned if the licensee provided adequate instructions and set
appropriate acceptance criteria for instrument accuracy when testing safety-related
unit cooler RRU 7 thermal performance. The inspectors found that calculation
VYC 1329, dated November 7,1994, which established the performanca limits,
had assumed adequate uncertainties for the differential pressure instrument used in
the thermal performance tests. The A/E team's review of the test results
questioned the largo discrepancies between the predicted pressure drop and that
actually measured. The licensee could not determine if the discrepancies were due
to modeling errors or testing. However, the licensee had questioned the differential
pressure method as the best method of determining the RRU room coder thermal
performance prior to the A/E inspection. The licensee indicated that it was
developing a better p9tformance test based on heat remoun! from the air stream and
will update the calculations accordingly. This item remains open pending the NRC
review of the licensee's revised thermal testing process and results and an NRC
determination regarding enforcement,
c. Conclusions
The bspectors concluded that, although adequate instrument accuracy had been
used in the RRU 7 thermal performance testing, the differential pressure test
method could not produce reliable results consistent with the analytical model.
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E2.3 (Closed) Unresolved item 50 271]97 201 16: MeasufjDa and Test Eauloment/RHR
Heat Exchance Thermal Performance Test
a. Insoection Scone (92903)
l The inspectors reviewed the licensee's measuring and test equipment (M&TE)
control as it applied to the RHR heat exchanger thermal performance testing to
assess the adequacy of the equipment selected,
b. Observations and Findinos
inspection report 50 271/97 201 documented an example of inadequate control of
test instruments involving f ailure to establish rnessures to assure that instruments
required for the RHR heat exchanger performance testing, including the Emergency
Response Facility Information System, were adequate for the application. The
licensee initiated Event Notification No. 32285, dated May 6,1997,in accordance
with 10 CFR 50.72 and multiple tiRs in response to this concern. The licensee
determined that improvements were required in flow instrumentaticn :end possibly
temperature instrument accuracy to enhance the thermal performance testing of the
RHR heat exchangers. The licensee confirmed that the flow instruments were
f calibrated at the wrong flow condition and the small changes in temperature across
} the heat exchanger led to large uncertainties. This is a violation of 10 CFR 50,
Appendix B, Criterion XI, Test Control, in that instruments used in activities
l
affecting quality were not p;operly selected or controlled to maintain accuracy
within necessary limits to assure that the test requirements were satisfied.
(VIO 50 271/9710-06)
c. Conclusions
The inspectors concluded that the licensee had f ailed to provide assurance that the
test instruments were adequate for their intended function, as required by 10 CFR
50, Appendix B, Criterion XI, Test Control.
E3 Engineering Procedures and Documentation
E3.1 Safety Evaluations
a.- Insoection Scoce (92903)
Inspection report 50 271/97 201 documented examples of the licensee's failure to
provide adequate safety evaluations. The inspectors reviewed the following
unresolved items to assess the licensee's safety evaluation process.
. . , .
- .-- - _ .
.
t
10
b. Observations and Findinas
(Undate) URI 50 271/97 201-07: RHR Pump Minimum Flow Protection The
licensee had identified that operator intervention was required to provide RHR pump
protection to overcome a design discrepancy between the pump manuf acturer's
recommended minimum flow of 2700 gpm and the minimum flow of 350 gpm that
cotJd be experienced on pump starting against a high system back pressure. FSAR
section 6.5 did not address operator intervention to assure pump minimum flow
protection. The RHR system is required to assure the design safety limits of FSAR
Chapter 14 are not exceeded. The inspectors confirmed that the pump vendor
would permit a one time-only pump operation at 350 gpm for 30 minutes based on
a pump previously in good condition. As stated in Vermont Yankee's reply to the
A&E team report, dated October 27,1997, VY revised BMO 97 20 to eliminate any
reliance on operator action. Since the A&E inspection, NRC has issued Information
Notice 97 78," Crediting of Operator Actions in Place of Automatic Actions and
Modifications of Operator Actions, including Response Times," on October 24,
1997. Therefore, this item remains open pending the NRC's review of the
licenses's revlr,ed BMO process that properly credits operator actions. NRC review
will otso examine whether, prior to elimination of the operator actions, an
unreviewed safety question existed.
(Closed) URI 50 271/97 201 14: Equipment Safety Classification In response to
an engineering review of the room coolers in the ECCS corner rooms during a
service water self assessment, the licensee concluded that those units did not have
a safety related cooling function. However, the licensee failed to perform a safety
evaluation prior to reclassifying the safety related unit coolers RRU 5 and 6 to
nonsafety related on December 30,1994, i SAR section 10.7.6 (Safety Evaluation)
states that the RHR service water pump spaces were provided with space coolers
(RRus 5,6,7, and 8) to prevent overheating of the motors during long periods of
operation. This is a safety-related function. This failure to perform a formal safety
evaluation of the consequencas of downgrading the classification of safety-related
equipment is a violation of 10 CFR 50.50. The licensee subsequently performed a
,
safety evaluation (SE 97-019) on July 2,1997, which indicated no unreviewed
safety question existed. (VIO 50 271/97 10 07)
c. Conclusions
The inspectors concluded that the licensee had f ailed to adequately evaluate
changes to the safety classification of safety-related ECCS corner room cooling
room units RRU 5 and RRU 6, which were described in the FSAR, as required by
.
11
53.2 (Closed) URI 50 271/97 201 22: Loss of Surveillance Records
a. Insocction Scoco 192903)
Inspection report 50 271/97 201 documented an example of inadequate control of
quality recorda. The inspectors reviewed unresolved item 97 20122 to assess the
licensee's quet!ty record keeping process with respect to the required battery
surveillance tests,
b. Qhservations and Finding 1
Technical Specification 4.10.A.2.C requires a service discharge test of the msin
station batteries once per operating cycle. A previous inspection report, 50 271/96-
09, had identified a weakness in the battery surveillance test procedure which had
permitted the licensee to use the same computer disc for succecling automati test
data recording. This caused loss of previous data when the disc had been written
over. That same inspection report noted the previous automatic computer printout
of the test results at 15 minute intervals missed the critical one minute peaks and
required the licensee to manually instruct the battery test computer to reprint the
test record at the critical times to verify the operability of the main station battery.
The inspectors confirmed that the licensee had lost the individual cell voltage (ICV)
and battery terminal voltage test records prescribed by battery test procedure
OP-4215 for the main station battery test performed on September 14,1996,as
noted by the A/E team. The inspectors also confirmed that the special test printout,
prepared during inspection 50 271/96 09,to prove battery operability, had also
be9n lost. The f ailure to maintain required surveillance records is a violation of
10 CFR 50, Appendix B, Criterion XVil, in that sufficient records of activities
affecting quality, such as the battery test records, had not been maintained.
(VIO 50 271/9710 08)
c. Conclusions
The inspectors concluded that the licensee had f ailed to maintain adequate control
of the main station battery surveillance test quality records as required by 10 CFR
50, Appendix B, Critorion XVil. Control of Quality Records.
E4 Engineering Staff Knowledge and Performance
E4.1 Reoortability_Evak:.d201
a. ingp_ection Scope 192903)
Inspection report 50 271/97 2016ocumented examples of the licensee's failure to
issue a license event report (LER). The inspectors reviewed the following
unresolved items to assess the licensee's reportability processes.
.
.
12
b. Observations and Findinas
(Closed) URI 50 271/9L20103: Suppression Pool Temperature Outside the Design
Basis The licensee had issued an event notification (EN 30175) on
March 20,1996, as required by 10 CFR 50.72(b)(1)(li)(B), indicating that operation
at suppression pool maximum operating temperature may have placed the unit
outside the design basis. Amendment No. 88 to the Vermont Yankee Technical
Specifications changed the maximum permitted suppression pool temperature to
100*F. The EN identified that the analysis that supported the technical
specification change did not include the feedwater flow in the worst case analysis.
The inspectors confirmed that the licensee failed to follow up the call to the NRC
operations center with a submittel of a written licensee event report, as required by
10 CFR 50.73(a)(2)(vill because this event (nonconservativa analysis) could render
both trains of a system required to remove residual heat (emergency core cooling
system (ECCS) Inoperable). This is an apparent violation of 10 CFR 50.73.
(eel 60 271/9710 09a)
(Closed) IFl 50 271/97 201 27: RHit Flow Instrument Uncertainty Procedure
OP 2124, Rev. 42, RHR System Operation, dated April 24,1997, and procedure
OP 4124, Rev. 46, RHR System Surveillance, dated April 24,1997, both provide
guidance for minimum pump flow requirements. When the A/E team discovered
that the instruments required to establish RHR minimum flow did not include an
allowance for the large instrument uncertainty in the minimum flow range, the
licensee performed a reportability review but failed to recognize that the procedural
inadequacy was reportable. The inspectors confirmed that the licensee f ailed to
adequately evaluate the reportability requirements. This is an apparent violation of
10 CFR 50.73(a)(2)(v),in that an event or condition (procedural errors) could have
provented the fulfillment of a safety function of a system required to remove
residual heat. (eel 50 271/3710 09b)
c. Conc Ml201
The inspectors concluded that the licensee had failed to report the above conditions
or activities outside the design basis as required by 10 CFR 50.73.
E8 Miscellaneous Engineering lasues
E8.1 Licensina Commitments
a. inspection Scone (Q21Q2)
The NRC issued Generic Letter 8913, Service Water System Problems Affecting
Safety Related Equipment, on July 18,1989. The licensee responded to the
generic letter with their latter, BVY 90 007, dated January 22,1990. In that
response, VY provided details of their testing for the affected heat exchanges.
Inspection report 50-271/97 201 documented two examples of GL 8913 program
commitments that had been revised without notifying the NRC. The inspectors
reviewed the following unresolved items identified in IR 97 201 associated with
Generic Letter (GL) 8913 to assess the licensee's control of licensing
commitments.
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ -_.
.
13
b. Obserygglons and Findinas
(Closed) URI 50-271/97 201 15: Removal of Room Coolers RRU 5 and 6 from the
GL 8913 Program The inspectors confirmed that the lice =ce had removed the
RRU 5 and 6 corner room coolers from the GL 8913 program following their
reclassification of these units as nonsafety related. Tns inspectors confirmed that
the licensee had written justification (memorandum OPVY 772 94, dated
December 30,1994) for declassifying the RRU 5 and 6 room coolers. The licensee
acknowledged that it had not infor'ned the NRC of the change to its response to
GL 8913 contained in its letter to the NRC, letter number BVY 90 007, dated
January 22,1990.
(Closed) URI 50 271/97 201 17: RHR Heat Exchanger Thermal Performance The
inspectors found that the licensee had changed the testing frequency of the RHR
heat exchangers to one per refueling outage due to the lack of time, during plant
cooldown, to adequately test both units. The licensee indicated that the reactor
coolant system cooldown rate did not permit the testing of both RHR heat
exchangers each refueling outage. The licensee also indicated that both heat
exchangers are cleaned each outage so their thermal performance should be
consistent. The licensee acknowledged that it had not informed the NRC of the
change to its response to GL 8913 contained in its letter to the NRC, letter number
BVY 90 007, dated January 22,1990.
-
I
l c. Conclusions
The inspectors concluded that the licensee had departed from commitments it had
made to the NRC as part of its response to GL 8913. The licensee acknowledged
those departures and provided adequate technical justification for the changes. The
licensee had initiated a licensing commitment tracking system to ensure the NRC is
made aware of similar changes in commitments in the future. Because no
regulatory requirements were violated, URl's 97 201 15 and 17 were closed.
E8.2 Station Blackout and Alternate Power Sunolv
a. insoection Scone (92903)
Inspection report 50-271/97 201 documented questions on the application of
General Design Criterion (GDC) 17, Electric Power Systems, and 10 CFR 50.63,
Loss of All Alternating Current Power (Station Blackout). The inspectors reviewed
two unresolved items from IR 97 201 related to the offsite power systems to
assess the licensee's design of the preferred and alternate ac power supplies,
b, Observations and Findinos
(Closed) NCV 50 271/9710-10and IFl 50 271/97 201-21: Vernon Tie Minimum
Voltage The licensee had identified a concern that sufficient voltage may not be
available at the RHR pump motor to successfully accelerate the RHR pump under
_ _ __ _ ..
14
minimum voltage conditions from the Vernon Tie. Motor torque is affected by the
applied voltage. The licensee has since determined that the RHR pump motor had
sufficient torque at less than rated minimum voltage by a comparison of the pump
and motor speed torque curves. This comparison demonstrated that the reduced
motor torque still enveloped the required pump torque. The inspectors confirmed
the operator rounds require the operator to confirm the Vernon Tie voltage is above .
3000 volts, sufficient voltage to start the RHR pump motor, i
The f ailure to demonstrate adequate voltage from the siternate power supply is a
violation of 10 CFR 50.03(c)(2),ln that no assurance existed that the alternate ac
source had the capability to start the required shutdown loads. This violation was
identified by the licensee and corrective actions were prompt and comprehensive.
As a result, this violation of NRC requirements will not be cited in accordance with
Section Vll.B.1 of the NRC Enforcement Policy. (NCV 50 217/97 10 10) i
[Q1osed) IFl 60 271/97 201 24: De!ayed Access Preferred Power Supply As a
result of a licensee review of industry concerns on the access time for a delayed
offsite power supply, the licensee recognized that there was no analysis to support
backfeed through the VY main transformer. The licensee had identified this concern
to the NRC prior to the end of the A/E team inspection (BVY 97 67, dated
May 29,1997. The inspectors confirmed the licensse had initiated engineering to
install a generator disconnect switch to reduce the time required to backfeed the
plant through the main transformer. This item is unresolved pending NRC
disposition of the enforcement issues. (URI 50 217/97 10 14)
c, Conclusions
The inspectors concluded that the licensee had adequately controlled the voltage on
the Vernon Tie. The inspectors concluded that the proposed generator disconnect
switch should satisfy the delayed access time requirement for the altornate
preferred power supply. This wili remain an open item pending NRC review of the
generator disconnect modification.
E8.3 Licensee Identified Desian issues Review
a. Inspection Scope (92903,92700)
The inspectors reviewed seven licensee identified design issues to assess the
adequacy of the VY staff's actions with respect to identification, reporting,
evaluation, and resolution of each individualissue. This onsite review included the
examination of the associated Event Reports (ERs),immediate operability
determinations, Bases for Maintaining Operation (BMOs), related safety evaluations,
selected corrective action implementation tracking, and the Licensee Event Reports
(LERs). The mspectors verified proper implementation of immediate corrective
actions, verified and discussed the adequacy of interim compensatory measures
with responsible engineering and operations staff, and assessed the overall
adequacy and timeliness of proposed actions to ensure the proper resolution and/or
a comprehensive programmatic review of the design issues.
l
. _ _ - _ - - _ - _ _ _ _ _ _ _ _ .
15
b. Observations and FindinDa
The following design Issues (identified by LER number) were examined:
(Closed) LER 9612, dated May 16,1996,IFl 97 02-02 and NCV 971011a. This
issue involved low pressure coolant injection flow potentially diverted due to
inadequate design review. This issue was previously discussed in Section 01.3 of
inspection repwt 97 02 and assigned IFl 97 02 02 for inspector follow up. The
licensee's immediate corrective action was to revise the RHR system operating
procedures to preclude operations with the alternate keep fill system in service.
This would prevent the possible diversion of the low pressure coolant injection. In
addition, a temporary modification was prepared that would have the condensate
transfer system connect to the keep fill system through the normal keep fill lines
which have safety class check valves. This modification would prevent the
backflow and diversion of low pressure coolant injection. The inspector found the
licensee's corrective actions acceptable.
IClosed) LER 96 30, dated January 13,1997 and Sucolement 1, dated
dulv 7,1997, and NCV 971011b. This issue involved the transversing in-core
probe purge solenoid valve not having been tested in accordance with Appendix J
due to an improperly implemented design change. The design change, implemented
i in 1987, erroneously included a newly installed check valve inside containment as a
containment isolation valve. However, this new valve was not fully qualified for
use as a containment isolation valve. The licensee determined that the root cause
was incorrect use of a non safety class design procedure that was used to install
the 1987 modification. While not listed in the corrective actions taken, the licensee
had previously terminated use of this process at the station. The qualified, as built
containment isolation valves, both outsido containment, were available for operation
as needed; however, one of these valves was removed from the isolation valve
testing requirements at the station. Among the immediate corrective actions, the
licensee verified that the valve removed from the testing requirements would still
receive an automatic isolation signal. The licensee also revised the testing
requirements to once again include the as designed containment isolation valve in
the test l.1g program, which was subsequently demonstrated satisfactorily. This
action restored the containment configuration to its as-designed and previously
qualified condition. The inspector found the licensee's corrective actions
acceptable.
(Closed) LER 97 02, dated March 2,1997, Suonlement 1, dated May 29,1997,
IFl 97-03-03, and NCV 9710-11c, This design issue involved maximum postulated
flood conditions which potentially could result in safety related switchgear being
jeopardized. This issue was previously discussed in Section E7.1 of inspection
report 97 03 and assigned IFl 97 03 03 for inspector follow up. The licensee
initiated actions for the operators to implement to prevent or minimize the effects of
flooding in the plant from the maximum postulated flood condition. Further, in June
1997, the licensee Installed conduit seals to aid the operators by reducing the
intrusion of water into the switchgear rooms to an easily manageable level. The
Inspector found the licensee's corrective actions acceptable.
. _ _ . .___ _ -_ _ _ _ _ _ _ __ _ _ _ .__. _ _ _ . _ . _ . . _ _ _ . _ _
,
.
t
16 !
(Closed) LER 97 03, dated Aorli 4,1997. IFis 97 02 03 and 97 03 04 and NCV
971011d. This design issue involves the determination that the turbine building i
lacks over pressure protection blowout panels which could result in exceeding the
- assumed differential pressure conditions that adjacent safety related concrete walls !
were designed to withstand in the event of a high energy line break. This issue was
previously discussed in Section 01.4 of inspection report 97 02 and Section E7.3 of
Inspection report 97 03, and assigned inspector follow up items IFl 97 02 03, and ,
IFl 97 03 04,respectively. The licensee provided some immediate administrative '
controls to ensure that certain doors are closed that prevent passage of steam into
, the affected areas. Long term corrective actions included: revisions to various ;
operating procedures for the HVAC system, and a modification to prevent steam
intrusion into the vital switchgear room HVAC syster.1 ist were implemented in
,
April 1997. The inspector found the licensee's corrective actions acceptable.
t
(Closed) LER 97-04, dated April 4,1997 and Suoolement 1. dated June 19,1997.
IFin 97 03 05. 97 03 06 and 97 04-05. and NCV 971011e. This design issue
involves fire suppression piping vulnerable to failure which could potentially result in
safety related switchgear room flooding and the potentialloss of associated safety
, system functions. The fire suppression piping issues were previously discussed in
-
Section E7.4 of inspection report 97 03 and Section E7.2 of inspection report 97-
04, and assigned inspector follow up items IFl 97 03 05,IFl 97 03 06,and IFl 97-
04 05, respectively. For each of the identified deficiencies involving internal flood
protection vulnerabilities, the licensee developed actions or guidance for the
operators to mitigate the consequences of the resultant equipment problems from
the internal flooding events, or to protect the equipment itself from the
consequences of the flooding. The inspector found the licensco's corrective actions
acceptable.
[ Closed) LER 97-05 dated April 24,1997 and Sunclement 1 dated Sootember 5.
1997. IFl 97 03 01 and NCV 97-1011f. This design issue involves the potential
for standby gas treatment system over pressurization and subsequent loss of
secondary containment integrity during containment inerting/deinerting operations, i
at power, with a concurrent loss of coolant accident. This issue was previously
discussed in Section 01.1 of inspection report 97 03 and assigned IFl 97 03 01 for
inspector follow uo. The licensee implemented administrative controls to prevent
opening the torus and drywell 18 inch inerting/deinerting lines during power
operations. The inspector found the licensee's corrective actions acceptable.
(Closed) LER 97-01. dated February 27.1997. IFl 97 02-01 and NCV 971011 a.
This design issue involved a single failure vulnerability in the primary containment
isolation system logic, which, if it occurred during a postulated loss of coolant
- accident, coincident with containment inerting/deinerting operations, could result in
the loss of a safety function (steam quenching to the tcrus bypassed) and over-
pressurization of the containment. This issue was previously discussed in Section
01.2 of inspection report 97 02 and assigned IFl 97 02 01 for inspector follow up. '
The licensee's immediate corrective actions were to change the containment
inerting and deinerting procedures, as well as other affected plant procedures to
preclude the simultaneous opening at power of both inboard containment isolation ,
- . .
- - - --
- - - - -. - .
_ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ -
.
17
valves associated with this event. The inspector reviewed the licensee's internal
event report corrective action tracking sheet and verified that the licensee's
procedure changes had been effected as described in the report. This action
prevents the sequence of events that could lead to containment suppression pool
bypass even if the associated equipment in the primcry containment isolation
system logic were to f all as describod in the report.
The inspectors found that the above licensee identified "old design issues"
(reference Enforcement Guidance Memorandum 96 005, dated October 21,1996)
were appropriately dispositioned within the guidance of Generic Letter 91 18 and
that appropriate 10 CFR 50, Appendix B, corrective action plans were developed for
each issue in accordance with the licensee's administrative control processes (ERs
and DMOs). The inspectors observed that the licensee's reporting of these issues
met 10 CFR 50.72 and 50.73 requirements for timeliness, scope and content. The
LERs typically did not provide extensive consequence assessment. However, the
information provided still met the requirements of 10 CFR 50.73 and was of
sufficient detail to understand the nature of the event. For example, LER 97 001
) stated that the event consequences could be overpressurization of the containment,
but did not state whether containment failure would result. Each of the above
issues was identified via the VY staff's efforts to consolidate the f acility's design
l basis documentation, to develop improved Technical Specifications, to correct
previously identified programmatic discrepancies, or to devolep the f acility's
Individual Plant Examination of External Events (IPEEE). The inspectors observed
i that, due to the nature of these issues, they were unlikely to have been identified
f via normal surveillance or routine quality assurance activities,
c. Conclusigna
Based upon the VY staff having identified the above stated design discrepancies via
other than routine quality assurance or surveillance activities and having
implemented or planned appropriate corrective actions to resolve the discrepancies
and/or prevent recurrence, these "old design issues" were not cited, in accordance
with the NRC Enforcement Policy, Section Vll.B.3. (NCV 50 271/971011a
through lig) In addition, the associated LERs and IFis were closed.
E8.4 (Closed) FSAR Undate
a. Scope
The inspectors reviewed the following unresolved items identified in IR 97 201
asssociated with maintaining the FSAR current to assess the licensee's control of
the FSAR changes,
b. Obsernions and Findinas
(Closed) NCV 50 271/97-1012aand URI 50-271/97 201-09: RHR Heat Exchanger
Performance - The licensee failed to revise FSAR Table 4.8.1, Figure 4.81,
Figure 0.4 3, and Section 14.0.3.3.2, Containment Response, when lower than <
expected RHR heat exchanger performance was found as a result of calculation
VYC 1290, Rev. O, dated August 1,1994.
. ..
. . .
- _ . .-- . . . _ . . - . - . _-- - - - - - - .-. - . - --
.
18
(Closed) NCV 50 271971012b and URI 50 271/97 201 28: FSAR Errors The
Vermont Yankee Final Safety Analysis Report, Revision 14, was issued on
April 29,1997. The licensee failed to revise the FSAR when they found the FSAR
Figures 4.81 and 6.4 3 not current and FSAR sections 6.3,6.4 and 8.5 not
consistent with the design.
These are violations of 10 CFR 50.71(e)(4),in that the FSAR did not reflect all
changes up to a maximum of six months prior to the date of filing. However, these
violations were considered to be of minor significance and are being treated as non-
cited violations, consistent with Section IV of the NRC Enforcement Policy.
(NCV 50 271/971012aand 12b)
c. Conclusions
The inspectors concluded that the licensee's reviews were effective in identifying
F5AH discrepancies. The inspectors also concluded the licensee's configuration
management programs that are now In place should identify similar discrepancies, if
they exist.
F8 Miscellaneous Fire Protection lesues
F8.1 Inonerable Fire Barrier Penetration Seals identified in LER 96 26
a. inspection Scope (64150)
The inspectors reviewed the licensee's corrective actions taken for the resolution of
the following deficiency identified in their fire protection program as documented in
Licensee Event Report 96 26,
b. Observations and Findinas
The inspectors reviewed the resolution of the documented firo protection issue
described in the LER. The inspectors noted that the issues were identified by the.
licensee as a result of an ongoing fire protection Improvement program /TPIP) and
Appendix R upgrade efforts conducted in response to a previous NaC ascalated
enforcement action (EA 95 268).
(Closed) NCV 971013 and LER 50 271/96-026: Inadequate Design
implementation and Subsequent Inadequate Documentation of Inspection Findings
Result in Operation Outside of Plant Design Basis for Fire Mitlgation and Technical
Specification Non-Compliance - This event report describes the licensee's discovery
of two Inoperable fire barrier penetration seals during a refueling outage in
October 19GC, The seals affected the control building cable vault and were
apparently causeo by inadequate installation in 1979. In 1993, one of the seals
was identifled as being inadequate during an improved fire penetration seal
l
Inspection. This seal was not repaired at that time. This occurred due to the
- licensee's inspector erroneously documenting the identification number of the seal
requiring repair.
_ _ _ __ _ _ _ ,
____
.
4
19
Subsequently, a routino inspection conducted by the licensee in August 1996,
revealed errors in the installation and configuration of one of the two seats. This
condition led to further discovery of the installation inadequacles of both seals, as
wel' as, the inadequate inspection / repair in 1993.
The licensee repaired both seats. The two seals were of the same design; however,
it was a unique design at VY, affecting only these two penetrations. Based on a
review of other fire seal deficiencies documented at the site, the installation errors
appeared isolated to this design. Finally, the licensee determined that due to many
design change implementation process improvements that have occurred since the
installation of those seals in 1979, that no additional corrective actions were needed
for that program.
c. Conclusions
The inspectors concluded that the licensee's analysis of this event, determination of
its root causes, and completion of short term corrective actions were appropriate. It
was further determined that operation of the facility since 1979 with inoperable fire
seals was a violation of the technical specifications. Consistent with a prior NRC
conclusion as described in NRC Inspection Report 50 271/97 80,in paragraph F8.5,
this licensee identified and corrected vlotation is being treated as a non cited
vlotation, consistent with Section Vll.B.4 of the NRC Enforcement Policy
(NCV 50 271/971013). This decision was made after consideration that the
vlotation: (1) was identified by licenseo staff as part of the corrective action for the
previous issues related to Appendix R; (2) had the same root cause as the previous
issue; and (3) did not substantially change the safety significance or the character
of the regulatory concern arising out of that f;i ding. Additionally, corrective
actions, both taken and planned, were comprehensive and reasonable. LER 96-026
is closed.
V. Manaaement Meetinas
X1 Exit Meeting Summary
An exit interview was held by the NRC inspectors with Mr. Reid, Mr. Maret and other
members of the VY staff on October 3,1997,to discuss the purpose and findings of this
inspection. At that time, the inspectors identified and reviewed the apparent violations
noted in this report.
An exit interview was held with Mr. Maret and others on November 20,1997, where the
inspectors discussed the additional licensee identified design issues documented in LERs,
and discussed in this report, but outside the scope of the A/E inspection. The licensee
acknowledged the findings of this inspection and had no additional comments.
- _
.
.
20
PARTIAL LIST OF PERSONS CONTACTED
D. Catsyn Manager, Technical Support
J. DeVincentis Assistant to Director of Engineering
R. January Manager, Electrical and l&C Engineering
J. Laughney QA Supervisor
E. Lindamood Director of Engineering
G. Marot Plant Manager
S. Miller Consultant
D. Reid Sr. Vice President, Operations
R. Wanczyk Director, Safety and Regulatory Affairs
D. Yasi Manager, Nuclear Services
INSPECTION PROCEDURES USED
IP 92903 Engineering Follow Up
IP 04150 Safe Shutdown Capability Re verification
IP 02700 Onsite Followup of Written Reports
ITEMS OPENED, CLOSED AND DISCUSSED
Opened
50 271/97 10-01 eel Failure to Maintain Design Control
50 271/97 10 02 NCV RHR/LPCI Flow Rate
50-271'97 10-03 eel Inadequate Corrective Action
50 271/97-10-06 VIO Inadequate Test Control
50 271/97-10-07 VIO Failure to Perforni a Safety Evaluation
50 271/97 10-08 VIO Failure to Maintain Control of Quality Records
50 271/97 10-09 eel Failure to Submit an LER
50 271/97 10-10 NCV Vernon Tie Voltage
50-271/97 10 11 NCV Licensee ldentified Design issues
50 271/97 10 12 NCV Failure to Maintain the FSAR
50 271/97 10-13 NCV Fire Barrier Penetration Seals
50 271/97 10 14 URI Delayed Access Preferred Power Supply
Closed
50 271/97 02-01 IFl Primary Containment isolation Logic
50 271/97-02-02 IFl RHR Keep Fill Design
50 271/97 02 03 IFl Turbine Building HELB
50 271/97 03-01 IFl Potential Overpressurization of SBGT
50 271/97-03-03 IFl Potential Flooding of Switchgear Room
50 271/97 03-04 IFl Turbine Building HELB
50 271/97-03 05 IFl Adm. Building Fire System Pipe Break
50 271/97-03-00 IFl Reactor Building Flooding
j 50 271/97-04 05 IFl Failure of Non Seismic Piping
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50 271/97 201 01 URI Suppression Pool Water Temperature
50 271/97 201 02 URI Untimely Actions to Resolve Suppression Pool Water l
Temperature Issue i
50 271/97 201 03 URI Failure to issue an LER
50 271/97 201 04 IFl Clarification of RHR Pump NPSH Margins and Correction of
Calculation Errors
50 271/97.201 05 URI Non conservative LPCI Flow Values Used in LOCA Analyses
50 271/9WO106 URI insufficient Technical Basis as Requested by lEB 88 04 for
Existing Minimum Flow
50 271/97 201 08 URI Inappropriate Operating Instructions Regarding RHR Pump
Motor Starts
50 271/97 201-09 URI FSAR Not Updated to incorporate Reduced RHR Heat
Exchanger Capacity
50 271/97 20110 URI Entry into TS LCO Conditions when Equipment is Rendered
50 271/97 201 11 URI Timeliness to Followup Self Assessment of TS Surveillan s
Requirements
50 271/97 201 13 URI Incorrect Assumption in the Calculation Methodology for
RRU 7 and 8
50 271/97 201 14 URI Downgrading RRUs 5 and 6 Without a Safety Evaluation
50 271/97 201 15 IFl Removal of RRU 5&6 from GL 8913 Program
50 271/97 20116 URI Analysis of RHR Heat Exchanger using Tests Measurem3nts ,
Collecte i and Recorded with inaccurate or Uncalibrated
instruments
50 271/97 201 17 URI Change in RHR Heat Exchanger Test Schedule
50 271/97 201-18 URI Common Mode Feliure of Non Safety Regulators Affecting
Safety Related Diesel Generators
50 271/97 201 19 URI Failure to Take Prompt Corrective Action to Revise TS
Discrepancy
50-271/97 201 20 URI Use of PRA to Address Tornado Missiles
50 271/97 201 21 IFl Vernon 69 KV Switchyard Low Voltage
50 271/97 201 22 URI Main Station Battery Service Test
50 271/97 201 23 IFl Standby Battery Charger CAB Single Failure
50 271/97 20b24 lFI Backfeed Through the Main Transformer
50 271/97 201-25 URI Cable Separation
50 271/97 201 2/ IFl Excessively High Uncertainty foi RHR Flow Indication and
Recording Loop
50 271/97 201 28 URI FSAR Deficiencies and Errors
50 271/97 201 29 URI Design Control Weakness
50 271/96 242 LER 96-12
50 271/96 567 LER 96 26
50 271/97 129 LER 97 01 1
50 271/97 060 LER 96 30
(1 271/97 280- LER 97-04
-50 271/97 281 LER 97-05
S0 271/97 437 LER 97-02
50 271/97 438 LER 97 02-01
50 271/97 439 LER 97 04 01
50 271/97 445 LER 97 03
50 271/97 527 LER 97 05-01
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Discuund
50 271/97 201 07 URI RHR Miniflow Protection
50 271/97 20112 URI Instrument Accuracy
50 271/97 20126 IFl Instrument Setpoint Program
LIST OF ACRONYMS USED
A/E Architect / Engineer
ANSI American National Gtandards Institute
l BMO Basis for Maintaining Operation-
I CFR Code of Fed 3ral Regulations
EDG Emergency Diesel Generator
eel Escalated Enforcement item
ER Event Report
FSAR Final Safety Analysis Report
GDC General Design Criterion
GL Generic Letter
GPM Gallons Per Mb.nete
-HELB High Energy Lins Naak
HPCI High Pressure Coolant injection
ICV Individual Cell Voltage
IFl Inspector Follow Up item
IPEEE Individual Plant External Event Evaluation
ITS Improved Technical Specification
LCO Limiting Condition for Operation
LER Licensee Event Report
LOCA Loss of Coolant Accident
LPCI Low Pressure Coolant Injection
NCV Non Cited Violation
NPSH Net Positive Suction Head
PDR- Public Document Room
PRA Probabilistic Risk Assessment '
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RRU Room Refrigeration Unit '
SBGT Standby Gas Treatment
1S Technical Specification
QA Quality Assurance
URI Unresolved item
VIO Violation -
VY Vermont Yankee Nuclear Power Station
.YOQAP Yankee Operational Quality Assurance Plan
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A/E INSPECTION TEAM OPEN ITEMS
CROSS REFERENCE TO
IR 97-10 FINDINGS !
Item Number Findina Status Replaced By Report 97-201 Oriainal Title and Section Reference
Type New item Number ,
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50-271/97-201-01 URI C EEI 50-271/97-10-01a Suppression Pool Water Temperature - Past Operation
Outside Design Basis (E1.1.2.2.a)
50-271/97-201-02 URI C eel 50-271/97-10-03a Untimely Actens to Resolve Suppression Pool Water
Temperature issue - 10 CFR Part 50, Appendix B, i
Criterion XVI, Corrective Action (E1.1.2.2.a}
50-271/97-201-03 IFl C EEI 50-271/97-10-09a Failure to issue an LER (E1.1.2.2.a) ;
i
50-271/97-201-04 URI C EEI 50-271/97-10-01b Clanfication of RHR Pump NPSH Marges and !
Correction of Calculation Errors (E1.1.2.2.b)
50-271/97-201-05 URI C NCV 50-271/97-10-02 Norm:onservatwe LPCI Flow Vaives Used in LOCA l
Analyses - 10 CFR Part 50, Appendix B, Critenon III,
Design Control (E1.1.2.2.c) ;
i
50-271/97-201-06 URI C EEI 50-271/97-10-01c Insufficient technical basis as requested by Bulletin !
88-04 for existing minimum flow, IEB 88-04
(E1.1.2.2.d)
50-271/97-201-07 URI Open Change to LPCI Mode of RHR Operation as descid,ed
in FSAR (E1.1.2.2.d)
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50-271/97-201-08 URI C EE150-271/97-10-01d inappropriate operating instructrons regarding RHR
pump motor starts,10 CFR Part 50, Appendix B,
Criterion ill, Design Control (E1.1.2.2.e)
50-271/97-201-09 URI C NCV 50-271/97-10-12a FSAR Not Updated to incorporate Reduced RHR Heat
Exchanger Capacity - 10 CFR 50.71(el (E1.1.2.2.f)
50-271/97-201-10 URI Closed Entry into TS LCO conditions when equipment is
rendered inoperable - TS 3.5.A.2 and TS 3.5.A.3
(E1.1.2.2.g)
00-271/97-201-11 URI C eel 50-271/97-10-03b Timeliness to Follow-Up Self-Assessment of TS
Surveillance Requirements (E1.1.2.2.g)
50-271/97-201-12 URI Open
50-271/97-201-13 IFl C LEI 50-271/97-10-01e RRU 7 & 8 - Calculation Methodology, incorrect
Assumption,10 CFR 50, Appendix B, Critenon III,
Design Control (E1.2.2.2.b)
50-271/97-201-14 URI C VIO 50-271/97-10-07 Downgrading RRUs 5 and 6 Without a Safety
Evalcation,10CFR50.59, Changes, Tests, and
Expenments (E1.2.2.2.c)
50-271/97-201-15 URI ~ Closed Deleting RRUs 5 and 6 from the GL 89-13 program,
Commitment in Response to Genenc Letter GL 89-13
(E1.2.2.2.e)
50-271/97-201-16 URI C VIO 50-271/97-10-06 RHR Heat Exchangers - Analysis of Tests
Measurements Collected and Recorded with inaccurate
/ uncalibrated instruments,10CFR50, Appendix B,
Criterion Xil, Control of Measuring and Test Equ:pment
(E1.2.2.2.f)
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50-271/97-201-17 URI Closed GL 89-13 Commitment - Not inspecting RHR Heat
Exchanger 18, Commitment in Response to Generic
Letter GL 89-13 (E1.2.2.2.gl
50-271/97-201-18 URI C eel 50-271/97-10-01f Common Mode Failure of Non-Safety regulators
Affecting Safety Related Diesel Generators,10CFR50
Appendix B, Criterion III, Design Control (E1.2.2.2.h)
30-271/97-201-19 URI C eel 50-271/97-10-03c Effectively Changing a Technical Specification by a
Revision to an Operating Procedure, NUREG 1606,
Proposed Regulatory Guidance Related to
implementation of 10CFR50.53 (E1.2.2.2.j)
50-271/97-201-20 URI C eel 50-271/97-10-03d Use of PRA to address tomado missiles in lieu of
providing positive protection as described la licensing
documentation. NRC acceptance of PRA as design 4
and licensing basis may be necessary. (E1.2.2.2.k)
~
50-271/97-201-21 IFl C NCV 50-271/97-10-10 Vernon 69kv switchyard low voltage - 10 CDR Part
50, Appendix B, Criterion !!I, Design Control
(El '!.3.2.a) )
50-271/97-201-22 URI C VIO 50-271/97-10-08 Main Station Battery Service Test-10CFR50 Appendix
B, Criterion XVil, QA Records (E1.3.3.2.b)
50-271/97-201-23 IFl C eel 50-271/97-10-03e Standby Battery Charger CAB Single Failure,
(E1.3.3.2.c)
50-271/97-201-24 IFl C URI 50-271/97-10-15 Unapproved Use Offsite Vernon Tie as Station
Blackout AAC Power Source and as Offsite Delayed
Access Source of Power (E1.3.3.2.a)
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.50-271/97-201-25 IFl Closed Lack of documentation within separation criteria
,
regarding NEDO .10139 for analys:s and documentation -
- of separation exceptions (E1.3.3.2.b) ~
50-271/97-201-26 IFl Open. Lack of provisions for instrument drift in Instrummit >
l
Uncertainty Calculation Methodologv'(E1.3.3.3.d) !
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50-271/97-201-27 IFl C eel 50-271/97-10-01g . Excessively high Uncertainty for RHR Flow Indication , ;
, eel 50-271/97-10-09b .and Recording Loop (E1.3.3.3.e) :
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50-271/97-201-28 URI
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C NCV 50-271/97-10-12b - FSAR deficiencies and errors (E1.4.3)
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50-271/97-201-29 URI C eel 50-271/97-10-01h Design Control Weakness, (E1.5.3) .
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