ML20236D596

Responds to NRC Re Violations Noted in Insp Rept 50-029/88-09.Corrective Actions:Specific Remedial Training Included in Prestartup Training Program Attended by All Licensed Operators & Shift Technical Advisors

ML20236D596
Person / Time
Site:	Yankee Rowe
Issue date:	03/17/1989
From:	Drawbridge B YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BYR-89-52, NUDOCS 8903230176
Download: ML20236D596 (4)

Text

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. YANKEE ATOMIC ELECTRIC COMPANY "*fy'#o"lg)l7f*l" 580 Main Street, Bolton, Massachusetts 01740-1398

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March 17, 1989 BYR 89-52 l

l l United States Nuclear Regulatory Commission i l Document Control Desk i

( Washington, DC 20555

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) Letter, YAEC to USNRC, dated January 6, 1989 (c) Letter, USNRC to YAEC, dated January 19, 1989 (d) Letter, USNRC to YAEC, dated February 15, 1989

Subject:

Reply to Notice of Violation

Dear Sir:

On November 9, 1988, Yankee Atomic Electric Company (YAEC) identified an apparent violation of a Technical Specification, limiting condition for operation. It was reported via ENS and Reference (b), Licensee Event Report No. 50-29/88-09. A special Nuclear Regulatory Commission (NRC) safety inspection was conducted on December 27 through 30, 1988 to review the associated circumstances and is documented in Reference (c).

On January 27, 1989, at an enforcement conference held in the Region I Headquarters, YAEC presented an explanation of the violation, its causes, and our corrective actions to preclude recurrence. Subsequently, per Reference (d), the event was determined to be a Severity Level III violation.

In accordance with 100FR2.201, we hereby submit the following information:

Violation l Technical Specification 3.3.1 and Table 3.3-1, " Reactor Protective System Instrumentation," require a minimum of four operable channels of power range neutron flux instrumentation and intermediate power range neutron flux l

. instrumentation whenever the reactor is in either Mode 1 or 2, or whenever the

l. Reactor' Trip System Breakers are in the closed position and the Control Rod Drive System is capable of rod withdrawal. If less than four channels are operable, Technical Specification 3.0.3 requires the facility be placed in at l

1 east hot standby within one hour and cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

.For channel operability, Technical Specification 2.2.1, " Limiting Safety System Settings," requires that the Reactor Protective System (RPS) instrumentation setpoints shall be consistent with the trip setpoint values 1 8903230176 990317 g PDR ADOCK 05000029 I O Q PDC

( . a United States Nuclear Regulatory Commission March 17, 1989  :

Page 2 BYR 89-52 l

contained in Technical Specification Table 2.2-1. Table 2.2-1 states that the power range and intermediate power range neutron flux high setpoints must be set less than or equal to 108% of rated thermal power, and the power range neutron flux low setpoint must be set at less than or equal to 35% of rated thermal power. Technical Specification Table 3.3-1 requires that the power range neutron flux low setpoint shall be operable whenever reactor power is less than 15 MWe.

Contrary to the above, for an indeterminate number of times prior to ')

November 9, 1988, while the reactor was operated in either Mode 1 at power less than 15 MWe, Mode 2, or with the Reactor Trip System breakers closed and the Rod Control System capable of rod withdrawal, all six of the power range i and intermediate power range nuclear instrument channels were inoperable, and the reactor was not placed in hot standby. Those instrument channels were j rendered inoperable during those times because of operator (s) adjusting the fine gains on those RPS instruments, resulting in the intermediate power range ,

neutron flux high trip value being greater than 108%, and the power range i neutron flux low trip value being greater than 35%, which is less conservative than the setpoint values set forth in Table 2.2-1 of the Technical Specifications.

Responam -

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'1 We concur with the Notice of Violation as described above and in Reference (d).

The primary cause of this violation was a procedural inadequacy which allowed operations below 15 MWe with nuclear instrumentation fine gain settings less conservative than required to meet Technical Specifications.

During our investigation, we also found contributing factors which date from the inception of Standard Technical Specifications at Yankee in 1977.

For power operations above 15 MWe, the plant procedures have always provided {

definitive guidance. I Prior to 1977, Yankee Technical Specifications required the nuclear instrwnentation high power trip setpoints to be operable only in the context of power operations. Reactor protection from transients initiated during low power or zero power operations was provided by a combination of the high start-up rate and low main coolant pressure trips. Accordingly, operating procedures and the operator training programs addressed the proper control of nuclear instrumentation gain settings at power levels above 15 MWe.

Procedural guidance and training for operation below 15 MWe consisted only of cautionary notes against adjusting the gains prior to reaching 15 MWe.

In 1977, YAEC adopted Standard Technical Specifications (STS), which 1 required operability of high power trip setpoints below 15 MWe. At that time an assumption was made which accepted operator knowledge (with an existing cautionary note) as a reliable means of controlling the gain settings for the ,

new requirements. Based on that assumption, operating procedures were not modified to provide specific guidance. Thus the potential for a violation was j created by the omission of specific procedural guidance for the new l requirements. j i

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, United States Nuclear Regulatory Commission March 17, 1989 Page 3 BYR 89-52 The nuclear instrumentation training module for operators addressed the I component performance characteristics, the Technical Specification requirements for operability, and the existing procedural guidance. With that training, the majority of the operators were able to comply with Technical Specification requirements despite the omission of specific procedural guidance. Our survey indicates that at least one, and as many as three operators, did not understand the potential for improperly adjusting the gain settings.

Given the duration of the inadequacy, two opportunities to identify and  !

correct the omission must also be included in the reasons for the violation.

First, formal procedure reviews occur on a regular basis and, effectively, whenever an operator uses a procedure. Even though an error of omission is more difficult to identify than a technical error, this procedural inadequacy I should have been identified sooner. Secondly, the training program provides i an environment in which operators critique concepts and existing guidance to develope an appropriate knowledge base. This process should have also identified the deficiency sooner. j Corrective Actions Taken

1. All affected shutdown procedures were immediately revised and, with a refueling shutdown scheduled just three days after the November 9, 1988 determination, a hold order was placed on any plant startup pending actions to achieve full compliance.

2. An independent investigating team was appointed by the Manager of Operations to conduct a full review of the event and to recommend further actions. The Task Force Report was submitted to the Plant Operational Review Committee for use in generating the Licensee Event Report (Reference (b)). A copy was also provided to the NRC inspectors during their investigation (Reference (c)).

3. All affected start-up and operating procedures were revised prior to resuming operation.

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4. Specific remedial training was included in the Refueling Prestartup Training Program attended by all licensed operators and Shift Technical Advisors (STA).

l 5. Nuclear instrumentation initial and requalification training was modified to assure the operators are aware of the relationship between gain settings and trip setpoints. Special emphasis has been placed on operations below 15 MWe.

6. All Technical Specifications limiting safety system setpoints were re-reviewed to assure there were no similar circumstances.

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. United States Nuclear Regulatory Commission March 17, 1989 Page_4 BYR 89-52.

Lon; Te m "errective ACJ; ions

1. 'The Yankee plant specific simulator is currently in construction and will be available in 1991 to provide an enhance training environment.

2. Additional improvements in operator' training this year'will further integrate operator actions, FSAR, transient analysis assumptions, and Technical Specifications.

3. Plant management will continue an ongoing effort begun in-1988 to encourage operators to be more critical and demanding of procedures and training materials. The objective is'a healthy, questioning j L

L attitude'. There was clear evidence of improvement in this area-during the recent refueling outage.. .

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4. During 1989, the plant Peer and Supervisory Observation Program will: l be focused on operator _ performance to provide more information to 4 the Training Feedback Program and' plant management. I

5. The Technical Specification to Operating Procedure Cross Referencing System currently being developed will be completed during 1989.

With its implementation, an additional verification of: compliance will be included.

l Date of Full Compliance Full compliance was achieved prior to startup for the current operating; cycle. All affected start-up and operating procedures have been revised to I include specific guidance on nuclear instrumentation power indication settings j and adjustments, and prestartup training has been completed. )

1 If you have any questions or desire additional information, please contact us.

Ve r tElT ) urs, i

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YANKEE ATOM ELECTRIC COMPANY 47N #

B. L. Drhwbrid Vice President and. Manager of Operations ELD /b11/0255v cc: USNRC Region I USNRC Resident Inspector, YNPS William V. Johnston Acting Director, Division-of Reactor Safety USNRC Region I