ML20236Q883
| ML20236Q883 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236Q872 | List: |
| References | |
| 50-271-98-80, NUDOCS 9807210103 | |
| Download: ML20236Q883 (34) | |
See also: IR 05000271/1998080
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No:
50-271
License No:
DAR-28
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Report No:
50-271/98-80
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Licensee:
Vermont Yankee Nuclear Power Corporation
Facility:
Vermont Yankee Nuclear Power Station
Location:
Vernon, VT and Region 1
Dates:
May 18 - June 5,1998
Inspectors:
George W. Morris, Senior Reactor Engineer
Brian T. McDermott, Senior Resident inspector
Gregory V. Cranston, Reactor Engineer
Keith A. Young, Reactor Engineer
Approved by:
William H. Ruland, Chief
Electrical Engineering Branch
Division of Reactor Safety
9907210103 990716
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ADOCK 05000271
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EXECUTIVE SUMMARY
Vermont Yankee Nuclear Power Station
NRC Inspection Report No. 50-271/98-80
This combined core engineering inspection included aspects of licensee engineering and
technical support operations as they pertained to the corrective action program, safety
evaluation and core engineering programs and processes. As a result of this inspection,
five violations of NRC regulations were identified.
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Maintenance
The only medium voltage cable preventive maintenance that VY presently performed
was associated with the insulation resistance testing of the connected loads and
was consistent with general industry practice. (Section M2.1)
The licensee's initiative to establish periodic cable testing of the medium voltage
cables from the AUX and SUT transformers would be appropriate in light of two
cable failures in five years. (Section M2.1)
The licensee's informal handling of the cable vendor's failure analysis of the failed
cable from startup transformer T-3-8 to Bus 2 did not properly control the vendor-
supplied service. (Section M2.1)
Enaineerina
The licensee's safety evaluation for the 1974 HPCl/RCIC Vacuum Breaker
Modification (EDCR 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. (Section E1.1)
The licensee's safety evaluation for the control room HVAC temporary modification
and procedure change failed to address the impact of required operator actions and
was a violation of 10 CFR 50.59. (Sections E1,1 and E2.4)
Personnel responsible for the commercial grade dedication program were
knowledgeable of the program and appeared to be implementing the program
properly. (Section E1.2)
Modification EDCR 97-414, AOG Modifications, was acceptable with sufficient
documentation 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. (Section E2.1)
Modification EDCR 98-402, HPCl/RCIC Vacuum Breakers, resolved the technical
issue associated with water hammer problems and installed a design that is
consistent with other utilities and with General Electric recommendations.
(Section E2.1)
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The configuration control documentation for the proposed changes to the FSAR and
DBD associated with the HPCl/RCIC Vacuum Breaker modification EDCR 98-402 did
not describe all key aspects of the design change but would be subject to further
licensee review as part of the change process for those documents and was
acceptable. (Section E2.1)
The Minor Modification procedure was appropriately being used to make minor
design changes. The Equivalency Evaluation procedure provides for a detailed
assessment of alternate replacement items and this process was properly
implemented for the items sampled. (Section E2.2)
The licensee was working off their TM backlog and had a procedure in place to
minimize future TM's. PORC review of the overdue TMs was also evidenced and
the team concluded sufficient managernent attention was being given to TMs.
(Section E2.3)
Corrective actions for the control room i entilation system temporary modification, if
the 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. (Section E2.4
and E5.2)
The licensee failed to report the control room HVAC design deficiency as required
by10 CFR 50.73 and a violation was issued. (Sections E2.4 and E5.1)
The DBD program was concentrating on the most risk significant systems artd this
program was an essential part of the transition of design engineering responsibility
to VY. (Section E3.1)
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The licensee's failure to maintain control of the new design basis documents
resulted in a violation against Appendix B, Criterion Ill, Design Control. (Section
E3.1)
The Event Report (ER) process provided sufficient information to support the early
identification of emerging problems to licensee management. ER screening
meetings contributed the perspectives of all departments to ER disposition plans.
(Section E4.1)
Trend report frequency (annual) and corrective action for recurring problems areas
were being evaluated by the licensee as part of AP-OO28 commitments. (Section
E4.1)
The documentation of initial operability determinations was not always consistent
with procedural guidance. (Section E4.1)
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The licensee issued a late LER for the HPCl/RCIC vacuum breaker, a violation of
50 73. This item was similar to the violation recently issued with inspection Report
50 271/97-10. This deportability issue was not cited in accordance with
Enforcement Policy Vll.B.1 (Section E5.1)
The licensee's control of vendor supplied services for the steam relief valve
setpoints was weak. (Section E5.2)
The licensee's conservative approach for containment pressure, using an analysis
from a similar plant with key VY values incorporated, provided reasonable assurance
that the plant could startup and operate safely. An inspector follow up item was
opened pending reviaw by the NRC of the VY specific analysis. (Section E5.2)
The Design Engineering organization and the transfer of design responsibility to the
site continued to be progressing without any observed problems that would affect
plant safety. (Section E6.1)
The VY Systems Engineering organization continued to show progress in
implementing its mission consistent with the industry expectations for system
engineers. The system engineers' notebooks and system health reports reviewed
by the team were consistent with those goals. (Section E6.2)
A change to the Quality Assurance Program that reduced previous commitments
was implemented prior to NRC approval and was a violation of 10 CFR 50.54.
(Section E7.1)
The licensee did not address the potentialimpact on plant equipment and a
continued implementation of the unapproved standard. This indicated a weakness
in implementation of the corrective action process. An unresolved item was opened
pending the completion of the NRC's review of a related licensee submittal.
(Section E7.1)
The QA program instituted at VY to provide oversight of the functional area
assessments was acceptable and use of the self assessment program was effective.
(Section E7.2)
The station service transformer, bus 9 rating and bus 9 feeder breaker overcurrent
relay setting had sufficient margin available to permit the testing of the fire pump
under all operating conditions. (Section E8.1)
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TABLE OF CONTENTS
PAGE
EX EC UTIVE S U M M A RY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii
11. M a i nt e n a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
M2
Maintenance Support of Facilities and Equipment ................. 1
M2.1 C a ble Te st Prog ram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
111. E n gi n e ering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
El
Conduct o f Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
' E1.1
Sa f ety Evaluations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
E1.2 Commercial Grade Dedication
.........................4
E2
Engineering Support of Facilities and Equipment ..................5
E2.1
M odific atio ns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
E2.2 Minor Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
.............................8
E2.4 Control Room Ventilation (CRV) Temporary Modification 96-043 .. 9
E3
Engineering Procedures and Documentation . . . . . . . . . . . . . . . . . . . . 12
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E3.1
Configuration Control Program . . . . . . . . . . . . . . . . . . . . . . . . . 12
E4
Engineering Staff Knowledge and Performance . . . . . . . . . . . . . . . . . . 13
E4.1
Corrective Action Program . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Engineering Staff Training and Performance
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E5.1
R e port a bility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 5
E5.2 Operability Determinations ...........................16
E6
Engineering Organization and Administration . . . . . . . . . . . . . . . . . . . . 18
E6.1
De sign Engineering . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
E6.2 Systems Engineering
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E7
Quality Assurance in Engineering Activities . . . . . . . . . . . . . . . . . . . . . 19
E7.1
Quality Assurance Program Change . . . . . . . . . . . . . . . . . . . . . 19
E7.2 Self Assessments
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E8
Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
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E8.1
Loading on Safety Bus Number 9 . . . . . . . . . . . . . . . . . . . . . . . 22
E8.2 Licensee Event Reports
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E8.3 Previously Reviewed items . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
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(Closed) VIO 50-271/97-10-07 . . . . . . . . . . . . . . . . . . . . . . . . 24
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(Closed) VIO 9 7 -0 6-0 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 4
(Closed) IFl 50-2 71/9 6-200-01 . . . . . . . . . . . . . . . . . . . . . . . . 24
V. Managem e nt Meeting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 5
X1
Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 5
PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
ITEMS OPENED, CLOSED and DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
LIST OF AC RO NYM S USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 8
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Report Details
Summary of Plant Status
At the beginning of this inspection, Vermont Yankee (VY) was in the middle of a planned
maintenance and refueling outage,
ll. Maintenance
M2
Maintenance Support of Facilities and Equipment
M 2.1 Cable Test Proaram (92903)
a.
Insoection Scope
The team reviewed Vermont Yankee's cable test program for medium voltage cable
to determine its approach to cable preventive maintenance in light of the recent
intermittent ground on one cable. This included review of event reports (ERs), of
maintenance and surveillance procedures, cable problems, cable test results,
equivalency evaluations and interviews with licensee personnel.
b.
Observations and Findinas
The team reviewed procedure OP 0023, " Installation and Testing of Cable and
Conduit," Revision 8, which provides a generic installation and test procedure for
cable and conduit specified in engineering design change requests (EDCRs), minor
modifications (mms), temporary modifications (TMs), and/or maintenance planning
and control (MPAC) work orders. Through review of the above procedure and
discussions with licensee personnel, the team determined that the only cable
preventive maintenance (with limited exception of some trend data gathered in
1995 following a 1993 cable failure) the licensee had performed was associated
with de insulation testing of the connected loads (OP-5235, AC and DC Motor
Maintenance.) The team found that, with the exception of initial post-installation
high potential tests and troubleshooting, no preventive maintenance (PM) testing of
medium voltage cable was performed while disconnected from the supplied load.
The team also reviewed procedure OP 4142, "Vernon Tie and Delayed Access
Power Source Backfeed Surveillance," Revision 7, and the results of that
surveillance to determine what testing was accomplished for cables at Vermont
Yankee. The surveillance for the Vernon tie testing was accomplished May 25,
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1998, during refueling outage (RFO) 20. The team found that the Vernon tie was
tested by loading it to within the acceptance criteria of 2210 kW to 2762 kW for at
least one hour at nominal operating voltage. The team found that no separate PM
testing of the cable itself was required by this surveillance procedure nor performed
by the licensee.
The team reviewed ER 97-1655 which documented an intermittent ground on the
non-safety related medium voltage cable between the start-up transformer (SUT) T-
3-B and Bus 2. (The medium voltage cables from the SUT and the auxiliary
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. transformer are composed of multiple single phase conductors from the
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transformers, through underground duct banks, to the 4160 Volt Buses 1 and 2.)
The licensee identified and replaced the defective conductor in the affected circuit
and identified and replaced another deteriorated conductor in the redundant
transformer T-3 B circuit as part of its extent-of-condition review. As part of the
long term corrective action associated with this ER, the licensee initiated a
commitment, under the AP 0028 Commitment Tracking process, to establish a
preventive maintenance program for the cables from the auxiliary (AUX) and
startup transformers on a refueling outage basis.
The team was informed by the licensee that it sent a sample of the failed cable,
found in response to ER 97-1655, to the new cable vendor's laboratory for failure
analysis. This failure analysis was not docomented in any formal agreement with
the vendor therefore it was not clear how the results would support the licensee's
corrective action program. The results of the cable failure analyt.:is were not
available from the cable vendor at the conclusion of this inspection.
c.
Conclusions
The team concluded that the only medium voltage cable preventive maintenance
that VY presently performed was associated with the insulation resistance testing
of the connected loads. This was consistent with industry practice, and did not
violate any NRC regulation. The team concluded that the licensee's initiative to
establish periodic cable testing of the medium volvage cables from the AUX and
SUT transformers would be appropiate in light of two cable failures in five years and
was consirtent with NRC's expectations for adequMe corrective action.
While the team concluded that the licensee's informal handling of the cable
vendor's failure analysis of the failed cable from startup transformer T-3-B to Bus 2
would not have satisfied quality assurance program requirements for control the
vendor-supplied service, since the cable involved was not safety-related, no
violation was identified.
Ill. Enaineerina
E1
Conduct of Engineering
E1.1
Safety Evaluations (370011
a.
Scope of Inspection
The team reviewed the licensee's procedural guidance for the safety evaluation
program to assess that program against the latest guidance contained in NRC
Inspection Manual Chapter 9900 and regulatory requirements of 10 CFR 50.59.
The team reviewed selected safety screenings and safety evaluations the licensee
performed for design changes and procedure revisions.
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b.
Observations and Findi al
D
BPCl/RCIC Vacuum Breakers
As noted in Section E2.1 of this report, the team's review of modification EDCR 98-
402, HPCl/RCIC Vacuum Breakers, found that the licensee's safety evaluation
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adequately described that the check valves would be Type C tested in accordance
with the 10CRF 50, Appendix J, localleakage rate testing program.
However, as part of that review, the team also reviewed EDCR 73-32 HPCl/RCIC
Vacuum Breakers, which originally installed the vacuum breakers in the turbine
exhaust lines between the torus and the containment isolation check valves. The
team determined that the licensee's review of modification EDCR 73 32, HPCl/RCIC
Vacuum Breakers, and associated safety evaluation, failed to address all relevant
water hammer issues, in that a new water hammer potential on turbine restart,
resulting from the design change, created a possibility for an accident or
malfunction of a different type than any evaluated previously in the safety analysis
report.
10 CFR 50.59 states a proposed change, test, or experiment shall be deemed to
involve an unroviewed safety question (l) if the probability of occurrence or the
consequences of an accident or malfunction of equipment important to safety
previously evaluated in the safety analysis report may be increased; or (ii) if a
possibility for an accident or malfunction of a different type than any evaluated
previously in the safety analysis report may be created; or (iii) if the margin of
safety as defined in the basis for any technical specification is resced.
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The licensee's failure to address the creation of the second water hammer event in
EDCR 73-32 (creating possibility for an accident or malfunction of a different type
than any evaluated previously in the safety analysis report) resulted in an
incomplete safety evaluation and an unreviewed safety question. This was a
violation of 10CFR 50.59. However, this item was licensee-identified during its
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validation of the HPCl/RCIC design basis document initiative. The immediate and
long-term corrective actions were comprehensive and performed within a reasonable
time frame. (Refer to Section E2.1 of this report.) The issue also was not likely to
be identified by routine licensee activities. Therefore, in accordance with the NRC's
Enforcement Policy Vll.B.3, involving old design issues, this violation was not cited.
(NCV 50 271/98-80-09)
Control Room HVAC
As noted in Section E2.4 of this report, the licensee discovered, in 1996, that the
Control Room HVAC would not function as expected on the loss of nonsafety-
related instrument air. Although a temporary modification (TM 96-043) was
processed and procedures were revised to help mitigate the degraded condition, the
team found that the safety evaluation for the TM failed to address the impact of
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required operator actions.
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c .'
Conclusions
- The team concluded that the licensee provided an adequate safety evaluation for
the HPCl/RCIC Vacuum Breaker modification (EDCR 98-402).
The team concluded that the licensee's safety evaluation for the 1974 HPCl/RCIC
Vacuum Breaker Modification (EDCR 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.
The team concluded that the licensee's safety evaluation for the control room
HVAC temporary modification failed to address the impact of required operator
actions and was a violation of 10 CFR 50.59 as noted in Section E2.4 of this
report.
E1.2 Commercial Grade Dedication (37550)
a.
Inspection Scope (37550)
The team reviewed the engineering involvement in the evaluation of components
used in safety-related systems commercial grade. The team conducted discussions
with Procurement Engineering personnel responsible for commercial grade
dedication (CGD) to assess their knowledge of the program.
In addition, the team reviewed Temporary Modification 94-019 (which installed air
isolation valves on the EDG starting air system) and documentation associated with
a CGD purchase of replacement parts (rupture discs) for the control rod drive
hydraulic control units to assess the licensee's conformance to its program
requirements.
b.
Observations and Findinas
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The team found that the analyses and reviews for the commercial grade dedication
for the isolation valves and rupture discs were appropriate.
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Conclusions
Personnel responsible for the CGD program were knowledgeable of the program and
appeared to be implementing the program properly.
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E2
Engineering Support of Facilities and Equipment
E2.1
Modifications (37550)
a.
Inspection Scope (37550)
The team reviewed engineering design change requests focusing on the design
change program implementation and the licensee's review of the plant configuration
changes to ensure that the criteria outlined in 10 CFR 50.59 and 10 CFR,
Appendix 8, " Design Control," were met. Specific items reviewed were: related
FSAR sections, safety evaluations, drawing modifications, post-modification
testing, and acceptance criteria,
b.
Observations and Findinas
Advanced Off-Gas (AOG) System
The team reviewed EDCR 97-414, AOG Modifications, approved February 3,1998,
to determine the extent and the adequacy of this modification. This modification
was implemented during RFO 20. The scope of the modification included
reconfiguration of control room panel (CRP) 9-50 to provide separation of the "A",
"B", and common trains' components, replacement of 24 VDC supplies, and several
other component replacements. The team found that the EDCR was of acceptable
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quality with sufficient documentation to permit evaluation of the effect of this
change on the design and licensing basis. The package also included necessary
procedure changes, drawing changes, adequate installation instructions, and
appropriate retest instructions. The team verified the installation and changes made
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during a walk down of CRP 9-50. The team noted that part of this modification
was to ensure that no crossed neutral wires existed in the AOG panel. The team
6etermined that acceptable post modification testing was conducted to ensure no
crossed neutral wires existed and that the installed condition was per the drawings.
Through discussions with licensee personnel, the team determined that the AOG
system was energized as the plant was returned to power operation after RFO 20.
As of the exit date of this inspection, no AOG concerns were identified.
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HPCl/RCIC Vacuum Breakers
The team reviewed EDCR 98-402, HPCl/RCIC Vacuum Breake's, which modified the
existing vacuum breakers on the HPCl and RCIC turbina exhaust lines to take
suction from the torus atmosphere rather than from the reactor building Standby
Gas Treatment System. This review included a walkdown of the new installation
from the suppression pool penetration to the HPCI and RCIC containment isolation
valves. The Safety Evaluation (50.59) for the modification and the proposed
. changes M update the FSAR and the draft Design Basis Documents (DBD) for HPCI
and RCnl aere also reviewed. (Previously there was no discussion of the vacuum
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breakers in the FSAR.) The team reviewed the sizing calculations for the vacuum
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breaker lines for HPCI and RCIC. The team noted that the licensee had prepared a
Basis for Maintaining Operation, BMO 98-01, HPCl/RC!C Water Hammer, which
addressed the team's water hammer concerns.
Additionally, based on a review of the proposed changes to the FSAR and the draft
DBDs, associated with modification EDCR 98-402, the team observed that the
proposed changes to those documents did not adequately describe the design bases
for the HPCI or RCIC vacuum breakers / pressure equalizing lines although the
proposed changes to the FSAR figures for HPCI and RCIC adequately incorporate
the change. Also, the Training Module for that design change did not completely
describe the bases for the change. The licensee indicated the proposed changes to
the FSAR and the DBD would be further reviewed as part of their respective change
processes.
The team's review of FSAR Chapter 14, Accident Analysis, found that it was silent
regarding starting and stopping the turbine, which could result in water hammer.
The team also reviewed EDCR 73-32, HPCl/RCIC Vacuum Breakers, which installed
the vacuum breakers in the turbine exhaust lines between the torus and the
containment isolation check valves. This modification was not described in the
FSAR.
The team determined that the licensee's review of modification EDCR 73-32,
HPCl/RCIC Vacuum Breakers, and associated safety evaluation, failed to address all
relevant water hammer issues, in that the new water hammer potential on turbine
restart, resulting from the design change, created a possibility for an accident or
malfunction of a different type than any evaluated previously in the safety analysis
report. However, the 50.59 safety evaluation failed to conclude that the restart
-water hammer was an unreviewed safety question requiring NRC approval prior to
implementing the design change. This was a violation of 10 CFR 50.59. (Refer to
Section E1.1 of this report.)
The team also reviewed other modifications that may have been done on the
HPCI and RCIC systems that could have been affected by EDCR 73-32 and
the associated lack of description of the vacuum breaker systems in the
FSAR. Also the team walked down the HPCI and RCIC syctems between the
torus and the containment isolation to verify that the configuration including
the new design change (EDCR 98-402) was consistent with the existing
controlled P&lD's and confirmed that the mark-ups reflecting the changes
associated with EDCR 98-402 were correct. No concerns or discrepancies
were found.
c.
Conclusions
The team concluded that modification EDCR 97-414 was acceptable with sufficient
documentation and justifications, adequate installation instructions, and adequate
post modification testing to ensure operability. The team also concluded that the
o
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program for designing and installing configuration changes to plant systerns was
adequate and the 10 CFR 50.59 program was properly applied in this case.
The team concluded that modification EDCR 98-402 resolved the technical issue
associated with water hammer problems and installed a design that was consistent
with other utilities and with General Electric SIL No. 30. The proposed changes for
the FSAR and DBD associated with modification EDCR 98-402 package did not
describe all key aspects of the design change but would be subject to further
licensee review and was acceptable.
The team concluded that the licensee's previous design change, EDCR 73-
32, and the associated safety evaluation, constituted an unreviewed safety
question and was subject to enforcement discretion as an old design issue.
The team concluded that based on a review of previous modifications
associated with the vacuum breaker system for the HPCI and RCIC turbine
exhaast lines by a walkdown of the system that there was reasonable
assurance that there was no other adverse impact to plant safety due to
other modifications or due to lack of a description of the vacuum breaker
system in the FSAR.
E2.2 Minor Modifications (37550)
a.
Inspection Scope (37550)
The team reviewed the Minor Modification Procedure, AP-OO20, Control Of
Temporary and Minor Modifications and Minor Modifications (MM)97-059,97-073
and 98-015, to assess the licensee's categorization of minor mods and the
implementation of its program. Procedure AP-0842, Equivalency Evaluation, and
Equivalency Evaluation Worksheets #.581, #582, and #838, were also reviewed to
assess the licensee's process for verifying alternate replacement items can be
installed without a plant design change.
b.
Observations and Findinas
The team observed that the MM proradure has specific requirements and guidelines
regarding what qualifies as a minor modification (MM). The MM procedure can be
used to efficiently and effectively install minor modifications permanently without
the additional procedural steps required to install an EDCR. The procedure also
includes the method to install temporary modifications (TM), how long a TM should
be in place, and periodic review requirements of existing TMs. As noted below, the
team noted that there are existing TM's in place that could be converted, essentially
as is, into permanent installations using the MM process but are still being carried
as temporary modifications and have been so for well over the recommended time
limit of six months.
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8
The equivalency enluation process provides a means to verify that any physical or
functional differences in the replacement item are better than, or equal to, the
original item. The evaluation procedure addresses critical design characteristics;
interrelated plant components, systems, and structures; plant technical programs;
preventive maintenance; simulator fidelity; operating procedures; and design
calculations and configuration control databases. The inspector noted that in all
cases, other than administrative changes, a 50.59(a)(1) screening evaluation must
be completed in accordance with AP-6002.
The team's review of the selected minor modifications indicated the licensee was
conforming to its guidance procedures. No technical questions were raised by the
team on the minor modifications or equivalency evaluation worksheets reviewed.
c.
Conclusion _
The team concluded that the Minor Modification procedure was appropriately being
used to make minor design changes. The Equivalency Evaluation procedure
provides for a detsited assessment of alternate replacement items and this process
was properly implemented for the items sampled.
E2.3 Temocrary Modifications (37550)
a.
insoection Scope (37550)
The team reviewed Temporary Modification (TM) Procedure, AP-0020, Control Of
Temporary and Minor Modifications, to assess the licensee's control of TM's. Three
TMs were reviewed by the team to assess the licensee's implementation of the
program: TM 92-18, which installed vent valves on Pumps P-49-1 A & 18; TM 94-
019, which installed two manual ball valves on the EDG starting air system; and
TM 96-043, which replaced the actuator for a control room cooling valve and added
restraints for manual operation of control room fan dampers.
I
b.
Observations and Findinas
The Temporary Modification (TM) procedure has specific requirements and
guidelines regarding what qualifies as a TM, how long a TM should be in place, and
periodic review requirements of existing TMs.
TM 92-18, which installed vent valves on Pumps P-49-1 A and 18, had been in
place more than six years and was revised under the current procedure in January
1998. Acccrding to the current procedure TM 92-18 would not qualify as a TM
and should be installed permanently using the Minor Modification (MM) process,
l
Additionally, the procedure states that a TM should not be installed for more than 6
months. Therefore, rather than revising the TM, a MM should have been generated.
For this situation, where a procedure change impacts existing TMs, VY has not
provided guidance on how existing TM's should be handled and whether ' grand
fathering' applied when new or revised procedures were issued.
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TM 94-019, which installed two manual ball valves on the EDG starting air system,
had been in place for more than three years. This TM was made permanent during
the recent 1998 refueling outage per EDCR 97-401 which required commercial
grade dedication of the valves. The team found that appropriate analyses and
reviews were completed in conjunction with superseding TM 94-019 with
permanent modification EDCR 97-401.
TM 96-043 modified the control room ventilation system to compensate for two
design deficiencies. Several concerns were identified regarding this issue and they
are discussed in detailin Section E2.4 of this report.
The team observed that those temporary modifications that had been installed more
than six months were walked down by the responsible department and engineering.
The results of the walkdowns were also presented to PORC for its review and
approval of future plans with the TMs. In addition, the licensee was working off the
backlog of overdue TMs.
c.
Conclusion
The team concluded that the licensee was working off its TM backlog and had a
procedure in place to minimize future TM's. PORC review of the overdue TMs was
also evidenced and the team concluded sufficient management attention was being
given to TMs. However, the team concluded that the licensee had missed
opportunities to use the current procedure to remove additional TM's by extending
an existing TM rather then making the modification permtnent using the MM
procedure.
E2.4 Control Room Ventilation (CRV) Temocrary Modification 96-043
a.
Inspection Scope (37550. 37001)
Temporary Modification (TM)96-043 was selected for review to assess the TM
process, its implementation, the quality of supporting engineering evaluations, and
the functionalimpacts of the change. This TM was selected for review based on its
age and its potentialimpact on control room aquipmcat.
b.
Observations and Findinas
The VY FSAR Section 10.12.3.3 describes the main contro1 room ventilating system
which is designed to provide summer air conditioning and winter heating. The
FSAR states, "A remote manual switch located in the main control room permits
closure af the outside air damper, control room kitchen and bathroom exhaust
dampers,' and computer room supply damper, in order to isolate the control room
, during an accident." Operator response to high unexpected or unexplained radiation
levels is directed by off normal procedure ON-3153, Excessive Radiation Levels.
Step 11 of ON-3153, directs operators to place the CRV recirculation mode switch
to the emergency position. This action accomplishes the isolation described by the
FSAR. The CRV system is support equipment necessary to maintain temperatures
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within the requirements for safety-related equipment in the control room and it has
been classified by VY as a safety class three system.
The team observed that the licensee identified on August 19,1996, that control
room chilled water control valve would fait closed on the loss of nonsafety-related
instrument air. The initial ER 96-0550 documentation noted that there was a two
to four hour time delay before significant temperature increases in the control room
would occur. The ER also indicated that an operability determination (i.e., BMO)
was required within 30 days based on the system's safety classification. The team
found that the ER deportability review had indicated that no reports to the NRC were
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required.
The inspectors' review of the TM 96-043 package found that the licensee had
identified a second deficiency associated with the CRV. Dampers associated with
the suction and discharge of the two CRV fans will fail closed on loss of nonsafety-
related instrument air, isolating the air flow to the control room. The temporary
modification included a valve actuator design change, mechanical restraints to
secure the fan dampers open, and procedure changes to implement the manual
actions outside the control room, if necessary. Because the manual actions required
by the operators would expose them to higher radiation levels than if they would
remain in the contro: .u n., Go consequences of an accident may be increased.
10 CFR 50.59, Changes, tests and experiments, specifies that the licensee may
make changes to its facility and procedures as described in the safety analysis
report and conduct tests or experiments not described in the safety analysis report
without prior Commission approval, provided the change does not involve a change
in the technical specifications or an unreviewed safety question (USO); and requires
the licensee to maintain records of changes in the facility, including written safety
evaluations providing the bases for the determination that the change does not
involve an USO.
The inspector found that the safety evaluation, dated October 8,1996, did not
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address the potential consequences of the compensatory operator actions.
Although the system would not operate as described in the FSAR after the TM
installation, the safety evaluation states "This TM brings the control room HVAC
j
system into compliance with its intended function." Therefore there was not a
I
sufficient basis to conclude that the change did not increase the consequences to
the control room operator. The inspector also noted that the safety evaluation
appeared to be a justification for the TM as a change to the original design of the
facility, rather than an evaluation of the temporary modification itself. This concept
is discussed in Section 4.7 of NRC Inspection Manual 9900, Resolution of Degraded
and Nonconforming Conditions.
The guidance states, "If an interim compensatory action is taken to address the
condition and involves a procedure change or temporary modification, a 10 CFR 50.59 review should be conducted and may result in a safety evaluation. The
intent is to determine whether the compensatory action itself (not the degraded
condition) impacts other aspects of the facility described in the SAR."
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Ti.u licensee's f ailure to perform an adequate safety evaluation for the procedure
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'
changes and temporary modification associated with the control room ventilation
system was a violatic.) of 10 CFR 50.59. (VIO 50-271/98-80-01)
Other aspects of the licensee's corrective action for this Nonconforming condition
were also found to be inadequate. The team found that the licensee had not
performed an operability determination (i.e., a BMO) as was required by the initial
screening of ER 96-0550. Vermont Yankee (VY) administrative procedure AP 0009,
c
Revision 3, Event Report, describes the licensee's process used to assess events
resulting in adverse condition, problems or deficiencies affecting VY to initiate the
{
appropriate level of corrective action. Section C of procedure AP 0009 states,
'
" Operability concerns resulting from non-conforming plant equipment are assessed
using the BMO (Basis for Maintaining Operation) process to determine the impact of
continued operation with potentially degraded equipment."
In addition, the team noted that the licensee's root cause evaluation for ER 96-0550
attributed the problem to inadequate design review. This root cause evaluation did
not recognize that the CRV chilled water valve and dampers were missed in VY's
1989 review of NRC Generic Letter 88-14," Instrument Air Supply Problems
Affecting Safety-Related Equipment." The results of VY's 1989 review were
submitted to the NRC by letter dated February 16,1989. VY failed to identify the
1989 evaluation error and, as a result, no effort was made to evaluate other safety-
related components that may have been missed during the evaluation. Section J of
procedure requires that the ER shall have attached a report listing all root and
contributing causes.
10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions," states that, " measures
shall be established to assure that conditions adverse to quality, such as failures,
malfunctions, deficiencies, deviations, defective material and equipment, and non-
conformances are promptly identified and corrected. In the case of significant
conditions adverse to quality, the measures shall assure that the cause of the
condition is determined and corrective action taken to preclude repetition." VY
failed to promptly correct the CRV deficiencies, in part, by not performing an
operability determination required by the Event Report process. VY failed to
adequately determine the cause of a condition, as evidenced by the failure to
identify and reassess the deficient 1989 engineering review for GL 88-14. The
team concluded that the two to four hour time delay required for the temperatures
in the control room to reach a significant level reduced the safety significance of
this concern and did not render the control room ventilation inoperable. The
licensee's failure to perform an operability determination as required by its
corrective action procedures, and the failure to perform an adequate cause
evaluation, are examples of inadequate corrective action and constitute a violation
of 10 CFR 50 Appendix B, Criterion XVI, Corrective Action.
(VIO 50 271/98-80-02)
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The team found that because the control room ventilation system is a system
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required to mitigate the consequences of an accident and the loss of nonsafety-
related control air would have rendered the system inoperable and this potential
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condition required the initiation of TM 96-043,the licensee should have submitted a
Licensee Event Report (LER) as required by 10 CFR 50.73(a)(2)(v)(D). The
licensee's f ailure to submit the required report was therefore a violation of 10 CFR 50.73. (VIO 50-271/98-80-03)
c.
Conclusions
The team concluded that the corrective actions for the control room temporary
modification were inadequate in that no operability determination was performed in
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accordance with administrative procedures and the cause determination f ailed to
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identify that the components were previously overlooked during engineering reviews
in response to NRC Generic Letter 88-14," Instrument Air Supply Problems
Affecting Safety-Related Equipment." The team concluded that the 10 CFR 50.59
safety evaluation supporting the temporary modification and procedure change
failed to address the impact of required operator actions. In addition, the +eam
concluded that the deficiency in the CR HVAC system was reportable under 10 CFR 50.73. Three violations were cited.
E3
Engineering Procedures and Documentation
E3.1
Configuration Con m1Proaram (37550)
a.
Scope of inspection
VY began a Configuration Management improvement Project (CMIP) in early 1997.
Developing design basis documents (DBDs) was one of the major projects
established in that program to retrieve, capture and maintain control of the design
basis. The team reviewed the licensee's design basis document program to assess
the licensee's control of these design documents, its control of DBD open items,
validation and changes to the DBDs.
b.
Observations and Findinas
The team observed that the intended purpose of the VY DBDs, as noted in the
licensee's Configuration Management Improvement Project Plan, dated January 22,
1988, was to be design documents for plant operations, used to respond to plant
events and to form the basis for future modifications. The team observed that
seven DBDs had been issued to date. The remaining 16 DBDs presently scheduled
were expected to be issued by the end of October 1998 in accordance with the
licensee's commitment on the docket. At present, only five of the DBDs had been
validated with the site. The remaining validations were scheduled into 2000, but
the schedule had been prioritized by system according to risk worth.
VY had failed to maintain control of pending changes to the issued DBDs. The
design control procedure AP 6007, Control, Update, and Maintenance of Vermont
Yankee Design Basis Documents, required pending or interim changes to the DBDs
(for unreviewed or unapproved and reviewed and approved changes, respectively)
to be distributed to all controlled copies of the DBDs. The team found that none of
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the controlled copies of the issued DBDs reviewed by the team had either interim or
pending change notices issued against them. The team identified examples of
interim or pending changes that should have been issued against the 4160 V ac and
the emergency diesel generator DBDs to identify the need for changes due to
revisions to the Motor Protection Guidelines, the Breaker Coordination Study, and
the Open items closeout list. The team also identified in inspection Report
50-271/98-09that the Emergency Diesel Generator DBD EDG-1 was issued without
a pending change for steady state frequency limit. 10 CFR 50, Appendix B,
Criterion ill, Design Control, requires the identification and control of design
interfaces, ir.cluding revisions of documents involving design interfaces. Failure to
control changes to the DBDs in accordance with the plant procedures is a violation
of 10 CFR 50, Appendix B, Criterion Ill, Design Control. (VIO 50-271/98-80-04)
c.
Conclusions
The team concluded that the DBD program was concentrating on the most risk
significant systems and this program was an essential part of the transition of
design engineering responsibility to VY. The team found evidence of the licensee's
failure to maintain control of changes to the issued design basis documents which
resulted in a violatior, against design control.
E4
Engineering Staff Knowledge and Performance
E4.1
Corrective Action Proaram (40500)
a.
Scope of Insoection
The licensee's process for identification of degraded or Nonconforming conditions is
described in Vermont Yankee administrative procedure AP 0009, Event Reports.
Selected portions of the Event Report (ER) process were reviewed to assess the
licensee's ability to identify and correct problems. Attributes of the process
reviewed during this inspection included the threshold for identification of problems,
the screening and prioritization of issues, the timeliness of ER evaluations, and the
trending of ER data.
A sample of approximately 35 items in the Event Report (ER) process initiated after
January 1,1998, were reviewed. The sample focused on engineering related
issues and items were selected on the basis of apparent safety / regulatory
significance from a list of approximately fourteen hundred ER descriptions. Several
of the ERs reviewed were initiated prior to January 1998 and the corrective actions
were awaiting implementation.
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b.
Observations and Findinos
The licensee's threshold for initiation of ERs appeared to be appropriate based on
the number of problems reported and the types of issues identified. The ER process
provides sufficient information to support the early identification of emerging
problerns to licensee management.
T# e team attended a sample of the VY's ER screening meetings and observed that
the meetings provide a timely and diversified assessment of new issues. The
screening committee is presented a summary of each new ER by a responsible
department head. This process allows the screening committee to evaluate the
initial response, identify the need for additional reviews, and assign a significance
level to the ER. The team observed that screening committee discussions added
value to the proposed disposition of ERs. Typically, the licensee was observed to
default to a higher significance level and request that the issue be rescreened when
more information was available. The inspectors considered this a conservative
approach.
Previous NRC inspections and SALP assessments identified ER trending as a
weakness and no significant progress has been made in this area. There are no
formal evaluations performed to assess performance trends. However, observations
by the VY staff and management have resulted in approximately 90 trend reports
for 1997. At present, the licensee is still developing the tools necessary to perform
more frequent trend evaluations and the only formal trend assessment is performed
annually. During a review of annual trend reports, the inspector noted that the
trend reports for 1993,1995,1996 and 1997 show the three most prevalent cause
codes are for written procedures, work practice, and design. It does not appear
that VY's effort to address these during past Functional Area Assessments (FAA)
[ department self assessments) have been effective. The inspector noted that as of
February 1998,23% of all ERs written in 1997 were still open and that this was an
improvement over 53% which were open during the 1996 trend report preparation.
The 1998 Trend Report indicates departmental corrective action plans are to be
developed as part of the 1998 FAA, and AP-0028 commitments had been
generated for superintendents and directors to evaluate the recurring problem areas
highlighted by the report.
The team's sample review of ERs found no examples where the operability of plant
equipment was incorrectly evaluated by the licensee. Although several examples,
such as the one discussed in Section E2.4 of this report, indicate the licensee is not
rigorous in documentation of initial operability determinations.
One of the older ERs reviewed was ER 96-0163,concerning a discrepancy between
the VY safety class manual and the approved Yankee Operational Quality Assurance
Program. Several NRC identified weaknesses associated with VY's corrective
actic,n for this ER are discussed in Section E7.1 of this report. Other examples of
the team's concerns of VY's deportability process are discussed in Section E5.1 of
this repert.
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15
c.
Conclusions
The Event Report (ER) process provides sufficient information to support the early
identification of emerging problems to licensee management. ER screening
meetings contribute the perspectives of all departments to ER disposition plans.
Trend report frequency (annual), and corrective action for recurring problems are
being evaluated by the licensee as part of AP-0028 commitments. The
documentation of initial operability determinations was not always consistent with
procedural guidance and was cited as part of a violation in Section E2.4 of this
report.
E5
Engineering Staff Training and Performance
E5.1
Deportability (37550)
a.
Scone of insoection
The team reviewed the licensee's procedural guidance on deportability to assess the
licensee's program compared to regulatory requirements contained in 10 CFR 50.72
and 50.73 and regulatory guidance contained in NUREG 1022, Rev.1, Event
Reporting Guidelines. The team reviewed selected ERs to assess the licensee's
review of problems for deportability determinations.
b.
Observations and Findinas
The team noted that the latest revision to AP 0010, Notifications and Reports Due,
Rev.1, was issued March 31,1998, and added specific reference to NUREG 1022,
Rev.1, Second Draft, but not the issued Rev.1 of NUREG 1022, which was issued
January 1998. The issued procedure contained clear, specific guidance for different
reports required by the regulations. Appendix K to the procedure contained sections
which duplicated or paraphrased the words from the regulations.
As noted in Section E8.2 of this report, prior to this inspection, the licensee had
failed to issue a timely LER for the HPCl/RCIC vacuum breaker, which is a violation
of 10 CFR 50.73. The licensee identified that it had not submitted the LER and
took prompt corrective action. The licensee's failure to meet the required 30 day
period was similar to the violation issued on April 14,1998, with Inspection Report
50-271/97-10. It was not reasonable to expect that this violation could have been
prevented by the licensee's corrective action to the previous violation. In
accordance with the Enforcement Policy Vil.B.1, this violation was not cited. (NCV
50 271/98-80-05)
As noted in Section E2.4 of this report, the team found that the licensee had failed
to evaluate ER 96-0550(on the failure of the control room HVAC on loss of
instrument air) for deportability, which was a violation of 10 CFR 50.73.
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c.
Conclusions
The team concluded the licensee issued a late LER for the HPCl/RCIC vacuum
breaker, a violation of 10 CFR 50.73. This item was similar to the violation issued
on April 14,1998 with inspection Report 50-271/97-10. No violation was issued in
accordance with the NRC's Enforcement Policy Vll.B.1.
The team concluded that the licensee's failure to evaluate the CR HVAC Event
Report for deportability as required by 10 CFR 50.73 and was a violation.
E5.2 Operability Determinations (37550, GL 91-18)
a.
Scope of Inspection
The team reviewed the licensee's guidance for operability determinations, or Basis
for Maintaining Operations (BMO), to assess the licensee's program implementation
as it related to the event reports and modifications reviewed during this inspection.
b.
Observations and Findinas
Steam Relief Valve Setooint
AP-0009, step C.1.a requires that Department Heads review ERs and contact the
appropriate individuals, as needed (e.g., Engineering or Operations's Management),
to address the operability of plant equipment. Initial operability determinations are
to be documented on Part 2.B of form VYAPF 0009.01,if degraded or non-
conforming structures, systems, or components will be considered operable. As
discussed in NRC Inspection Report 50-271/96-200,the licensee had not always
been rigorous about documenting operability determinations and VY was not able to
promptly determine whether operability was affected or even considered. For
example, ER 98-0421 documented that the FSAR described relief valve setpoint
range for the nuclear steam supply system was greater than allowed by Technical
Specifications. The team's review of the vendor's documentation, the licensee's
purchase order and calibration criteria found that the acceptance criteria used by the
vendor to accept the relief valve setpoints were verbally changed by the licensee to
conform to the Technical Specification 2.2 allowed limits without any formal
procurement controls. The ER was assigned a significance level of three, and no
l
assessment was documented as to the operability of the installed relief valves.
'
Based on the team's questions, the licensee was able to provide documentation
showing the relief valve setpoints were set in accordance with the Technical
Specifications. The failure to document the initial operability determination as
required by AP-OOO9 constitutes a violation of minor significance and is not subject
to formal enforcement action. However, this item was another example of weak
licensee control of vendor supplied services.
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Primary Containment Peak Pressure
The team observed that the licensee had identified a potential concern with post-
LOCA primary containment pressure and associsted 10 CFR 50, Appendix J testing
requirements. Two issues had been identified by the licensee or its nuclear steam
system supplier (NSSS), General Electric (GE): (1) based on a review of the analysis
associated with operating the reactor under Extended Load Line Limit Analysis
(ELLLA) it was determined that the primary containment peak pressure would be
increased by 2.6 psig; and, (2) recalculation of the torus free air volume resulted in
an increase of 1 psig to th( primary containment peak pressure.
Regarding item (1), based on GE's review of the analysis associated with operating
the reactor under ELLLA, it determined that the primary containment peak pressure
would be increased by 2.S psig. Also, recalculation of the torus free air volume
resulted in an increase ci 1 psig to the primary containment peak pressure. When
these values are added to the FSAR 14.6.3.3.2 calculated value of 42.2 psig, the
new peak accident pressure becomes 45.8 psig. This exceeds the current leak rate
testing test pressure (Pa = 44 psig) by 1.8 psig and potentially invalidated the
Appendix J leak rate testing results. A higher post accident primary containment
pressure could result in releases of airborne radioactivity outside the design limits.
Regarding item (2), new torus free air volume calculations were recently done by
the licensee and showed that the free air volume was less than that used before
which translates into a higher (by 1 psig) post accident containment pressure.
A Basis for Maintaining Operation (BMO) has been issued to allow the plant to
startup. Per the BMO a conservative reanalysis has been done by General Electric
which provided a new calculated peak accident pressure, including the ELLLA and
reduced torus volume concerns, that is less than the current primary containment
test pressure (Pa) of 44 psig.
This item will remain open pending completion by General Electric of the final
analysis for VY showing that with VY specific data the resulting peak accident
pressure, considering ELLLA and the reduced torus air volume, is less than or equal
to 44 psig. (IFl 60 271/98-80-06)
Control Room HVAC
As noted in Section 2.4 of this report, the team found that the licensee had failed to
perform an opervuii;ty evaluation for ER 96-0550, failure of the CR HVAC on loss of
instrument air, and contributed to the violation of 10 CFR 50, Appendix B, Criterion
XVI, Corrective Action,
c
Conclusions
The team concluded that the licensee's control of vendor supplied services for the
steam relief valve setpoints was weak.
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The team concluded that, even though the analysis had not been finalized
specifically for Vermont Yankee, the licensee's conservative approach, using an
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analysis from a.similar plant with key VY values incorporated, provided reasonable
assurance that the plant could startup and operate safely. An inspector follow-up
item was opened.
The team concluded that the licensee's failure to produce a BMO to support the ER
on the CR HVAC issue was a violation of Criterion XVI, Corrective Action.
E6
Engineering Organization and Administration
E6.1
Desian Enaineerina (37550)
a.
Scope of Insoection
The team interviewed engineering management, design engineering supervision and
design engineers to assess the progress to date of the transition from a Yankee
Atomic Electric Cornpany (YAEC) to a Vermont Yankee (VY) design engineering
staff located at the Vermont site.
b.
Observations and Findinas
The team found that the reorganization of engineering under the VY staff has
resulted in the establishment of the new position of Vice President (VP) of
Engineering and a realignment of the engineering groups directly under the new VP.
Prior to this reorganization, engineering reported to the VP of Operations, through
the plant manager. Retention of the former YAEC engineering personnel that had
been assigned to the VY project remained high. The transition to a site-based
design engineering organization was expected to be completed by the end of 1999.
The Configuration Management improvement Project (CMIP) was being managed
from the former YAEC-now Duke Engineering and Services-offices in Bolton, MA.
This major engineering effort to support the engineering transition to the site was
progressing, but behind the original schedule submitted to the NRC as part of the
industry 50.54(f) request on design information. VY had informed the NRC of the
change to the DBD preparation slippage, but had not formally told the NRC about
the DBD Validation schedule change. The licensee indicated it was reviewing its
manpower loading forecasts before it submitted the revised validation schedule to
the NRC. Six DBDs had been issued by the end of the inspection. Five of those
had been validated. Following the close of the inspection, the team was informed
that this effort would be managed from the VY site and a VY site manager had been
named to lead this effort.
c.
Conclusions -
The team concluded that the design engineering organization and the transfer of
design responsibility to the site continues to be progressing without any observed
problems that would affect plant safety.
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E6.2 Systems Enaineerina (37550)
a.
Scooe of Insoection
The team interviewed engineering management, design engineering supervision and
system engineers to assess the progress in the development of the system
engineering program at Vermont Yankee. The team also reviewed selected systems
engineering
. ;k procedures and work products, such as system notebooks and
system health reports, to assess the sensitivity of the system engineers to potential
system problems.
b.
Observations and Findinas
The team found that the system engineering organization at VY consisted of sixteen
engineers who monitor the status of 81 maintenance rule systems. At present, the
system engineers are not the first level responders to daily problems; that task
falling to the maintenance engineers. The primary task for the VY system engineers
is to step back and take a broad assessment of the system to identify potential
problem components and recommend system improvements. The notebooks and
system health reports reviewed by the team demonstrated good knowledge of the
system and an understanding of system problems. The system engineers training
followed the Institute of Nuclear Power Operations (INPO) guidelines for engineering
support personnel (ESP).
c.
C inclusions
The team concluded that the VY Systems Engineering organization continued to
show progress in implementing its mission consistent with the industry expectations
for system engineers. The team concluded that the system engineers' notebooks
and system health reports reviewed by the team were consistent with those goals.
E7
Quality Assurance in Engineering Activities
E7.1
Quality Assurance Proaram Chanae
a.
jnpoection Scope (40500)
On March 11,1996, Event Report 96-0163 was initiated to document that the
Vermont Yankee Safety Classification Manual (VYSCM) was not in compliance with
the approved Yankee Operational Quality Assurance Program (YOOAP),
Revision 27. The team reviewed the licensee's corrective actions and compliance
with the requirements of 10 CFR 50.54(a) for changes to the approved quality
assurance plan.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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_ _ _ _ _ _ _ _ _ - _
__ _ _ _ _-_- _
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_---
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-
.
f:
20
b.
Observations and Findinas
..The VY Final Safety Analysis Report (FSAR), Appendix.D, " Quality Assurance
Program During the Operational Phase," references the Quality Assurance Prograrr.
as described in FSAR Section 1.9. Section 1.9 describes the Yankee Operational
Quality Assurance Program (YOQAP) as the means for compliance with 10 CFR 50
Appendix B requirements. Section Vil, of YOQAP, Appendix B, identifies that VY'
has taken exception to Regulatory Guide 1.26, Revision 3, " Quality Group
Classifications and Standards for Water , Steam- and Radioactive-Waste-Containing
Components of Nuclear Power Plants." As an alternative, the exception states that
,
_ VY_ will continue to classify structures, systems, and components (SSC) in
!=
accordance with ANS-22, Draft No. 4, Rev.1, May 1973, " Nuclear Safety Criteria
for the Design of Stationary Boiling Water Reactor Plants." This exception was
accepted by the NRC as far back as 1982 as part of Revision 11 to YOQAP.
The licensee's evaluation of ER 96-0163in 1996 found that classification of SSCs
was being made using ANS-52.1,1983, Nuclear Safety Criteria for the Design of
Stationary Boiling Water Reactors,"instead of the Draft 4 version of ANS-22 that
was approved by exception by the NRC.
As corrective action for the ER, Yankee Atomic Electric Company (YAEC) submitted
Revision 28 of the YOQAP, on behalf of VY, to the NRC for approval on October 1,
1997. This revision identified VY's new alternative to Regulatory Guide 1.26 as a
change to a regulatory commitment (i.e., a reduction in commitment) that needed
NRC approval.
10 CFR 50.54(a) states that " Changes to the quality assurance program description
that do reduce the commitments must be submitted to the NRC and receive NRC
approval prior to implementation..." When Revision 28 of YOQAP was submitted to
the NRC for approval, the licensee had already determined that the change was a
reduction in commitment but allowed its continued implementation under the
existing version of the VYSCM. The failure to receive NRC approval prior to
implementing a change reducing previous quality assurance (QA) program
commitments is a violation of 10 CFR 50.54(a). (VIO 50-271/98-80-07)
The inspector also noted that on February 6,1998, a contractor study performed
for VY clearly identified a discrepancy between the criteria for classification of
Radioactive Waste Processing Systems in ANS 22 and the VYSCM. The
discrepancy concerns the whole body dose limit used to assess system failures.
ANS 22 requires failures which result in a dose of 170 mrem or greater (at the site
boundary) be designated as safety class and the VYSCM specifies a limit of
500 mrom. As a result, systems which should be designated as safety class, under
the YOQAP may be designated as non nuclear safety. The inspector found that the
licensee had not evaluated the impact on plant equipment that could result from this
discrepancy. The licensee's initial review found that the classification of the
refueling equipment was potentially affected by implementation of the less
restrictive standard. The licensee initiated ER 98-1235, on May 21,1998, to
~ investigate, this issue and adequate compensatory measures were established.
I
.
.
21
A letter from VY to the NRC, dated February 25,1998, described the VY licensing
basis, relative to dose criteria for classification of safety class equipment, as
1
500 mrem. Based on the FSAR reference used by VY, this appears to be incorrect
and may have been confused with 10 CFR 20 limits. This issue needs further NRC
review to determine if quality assurance requirements were met since the inspectors
l
did not complete its review of the February 25,1998, submittal. (URI 50-271/98-
,
'
80-08)
c.
Conclusions
l
A change to the Quality Assurance Program that reduced previous commitments
was implemented prior to NRC approval and is cited as a violation of 10 CFR 50.54.
!
'
The licensee did not address the potential impact on plant equipment and continued
implementation of the unapproved standard. This indicated a weakness in
implementation of the corrective action process. An unresolved item was opened
pending completion of NRC's review of a related licensee submittal.
E7.2 Self Assessments
a.
Inspection Scopa (40500)
The team reviewed the effectiveness of the quality assurance organization in
identifying problems in functional areas. This was accomplished by reviewing
audits and assessments. The team selected Functional Area Assessments (FAAs)
from the 1996-1997 for review. These included the following FAAs:
Technical Support, including Audit No. VY 98-17, " Corrective
Action / Operating Experience"
Systems En;;.neering
Mechanical Engineering
Electrical and Controls Maintenance
General Plant Performance
b.
Observations and Findings
The team's review of the FAA program and results of the QA audits found the
assessment program plan was appropriate. The team found that the assessments
were broad in scope and presented substantial findings and observations including
recommendations for those functional areas requiring additional management
attention. The team noted that the findings were clearly stated, directed to the
appropriate personnel, and appropriately entered into the corrective actions
program. The team verified appropriate resolutun of selected findings.
Additionally, the team found that required periodic audits were appropriately
performed by the QA program.
.
.
22
c.
Conclusions
The team concluded that the QA program instituted at VY to provide oversight of
the FAA were acceptable and use of the self assessment program was effective.
E8
Miscellaneous Engineering tssues
E8.1
Loadina on Safety Bus Number 9
a.
Insoection Scope
The team reviewed loading on safety bus number 9 to assess the capability of the
bus to support fire pump testing independent of the connected load. This consisted
of reviewing procedures and calculations to determine what, if any, initial conditions
are required or implemented on 480 Volt bus 9 prior to testing the electric driven
fire pump. The team also reviewed Maintenance Planning and Control (MPAC) data
for bus number 9 equipment and computer records during the last test of the
electric driven fire pump to assess the margin on bus 9.
b.
Observations and Findinas
The team reviewed procedure number OP 4105, " Fire Protection System
Surveillance," Revision 8, to determine if initial conditions should be specified or
precautions stated prior to performing fire pump testing on bus number 9. The
team found that there were no initial conditions or precautions identified nor
required in the procedure for bus loading concerns. In addition, the team confirmed,
from a review of the computer records, that the last test of the 250 hp electric
driven fire pump performed prior to the refueling outage (RFO 20) was performed
with the 250 hp control rod drive pump also being powered from the same bus
without incident.
The team reviewed calculation VYC-1688, Transient Voltage on 480 Volt Power
System, and confirmed that the assumptions used in the analysis were conservative
and the results demonstrated sufficient margin exists to start and accelerate the fire
pump without overloading the station service transformer T-9-1 A or bus 9 or having
a negative effect on the running equipment.
The team also reviewed MPAC data for equipment located on bus number 9 and
found that there had been no equipment trips since June 22,1992. On that date,
the team found that motor generator rotating uninterruptible power supply 1 A
tripped as reported in LER 92-018.
c.
Conclusions
The team concluded that there was sufficient margin available with the station
service transformer, bus 9 rating and bus 9 feeder breaker overcurrent relay setting
to permit the testing of the fire pump under all operating conditions.
l
l
t
.
.
23
E8.2 Licensee Event Reports (92903)
(Ocen) LER 98-005: HPC1/RCIC Exhaust Lines Susceptible to Water Hammer. This
LER, issued on April 9,1998, documented a discrepancy, identified by the licensee
on January 15,1998 as a result of its DBD effort, that the current installation of the
HPCl/RCIC vacuum breakers could result in water hammer in those lines.10 CFR 50.73 requires an LER be submitted to the NRC within 30 days after the discovery
of the event. Deportability was discussed in Section E5.1 of this report.
Modification EDCR 98-402, HPCl/RCIC Vacuum Breakers, moved the location of the
vacuum breakers in the syste;m and provided updates to the FSAR and the Design
Basis Documents (DBD) for HPCI and RCIC to include a description of the installed
vacuum breaker configuration. Previously there was no discussion of the vacuum
breakers in the FSAR. The DBDs are in the initial draft stage.
This issue will close with: (1) the installation of EDCR 98-402, HPCl/RCIC Vacuum
Breakers; (2) issuance of associated documentation updates to maintain
configuration control; and, (3) corrections to the Safety Evaluation associated with
EDCR 98-402.
Regarding item (1), the recently installed design change modified the existing
vacuum breaker arrangement on the HPCI and RCIC turbine exhaust lines to take
suction from the torus atmosphere rather than from the reactor building Standby
Gas Treatment System. The modification resolved the water hammer problems and
installed a design that was consistent with other utilities and with General Electric
service information letter (SIL) No. 30, which addressed this problem in 1973. This
portion of the LER is closed.
Regarding item (2), a review of the proposed changes to the FSAR and the DBDs
indicated that the proposed changes did not adequately describe the design basis
for the HPCI or RCIC vacuum breakers / pressure equalizing lines. Also, the Training
Module for the design change inadequately describes the basis for the change.
This issue will remain open until the configuration control input documentation for
the FSAR and the DBD's have been adequately revised.
Regarding item (3), the Safety Evaluation associated with EDCR 98-402 was
inadequate in that it failed to address the new containment leakage path created
and the associated impact on 10 CFR 100. Also, the safety evaluation did not
adequately address all applicable water hammer scenarios for which the design
I
change was needed to eliminate. This issue, discussed in Section E2.1 of this
report, was cited as a violation of 10 CFR 50.59 and will remain open pending NRC
l
review of the licensee's response to that violation.
l
This LER will remain open pending resolution of items (2) and (3).
l
l
(Open) LER 98-010: Potential challenge to containment systems in the event of a
LOCA. The emergency operating procedures (EOPs) regarding Torus Rupture Disc
Burst Pressure were inadequate in that they did not prevent or caution the operators
about the possibility of prematurely bursting the rupture disc which causes a loss of
L
_ _ - _ _ - _ - _
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _
_
.
.
24
l
primary containment integrity. The Licensee failed to issue a timely LER when the
problem was discovered and, consequently, a violation was issued in inspection
report 50-271/98-06.
The licensee has closed a motor operated valve in the hardened vent discharge line
to provide short term corrective action to ensure that primary containment integrity
was maintained during a containment flooding evolution. A Basis for Maintaining
Operations (BMO) had been prepared to support continued operation with the torus
vent system isolation valve closed pending final resolution of this issue. This LER
remains open pending resolution of the issue, closure of the BMO and final review
by the NRC.
E8.3 Previousiv Reviewed items
LQlosed) VIO 50-271/97-10-07: Failure to Perform a Safety Evaluation
The licensee failed to perform a safety evaluation prior to reclassi'ying the safety-
related unit coolers RRU 5 and RRU 6 to nonsafety-related on December 30,1994.
The licensee's March 6,1998, response to the NRC's February 5,1998, notice of
violation identified corrective actions including a safety evaluation for the
reclassification of the coolers, update of design basis documentation and the FSAR,
and programmatic enhancements in the areas of design control and configuration
management. The inspector reviewed the safety evaluation, the pending FSAR
change, and the Configuration Management Improvement Project Plan dated
January 22,1998. No problems were identified with the licensee's safety
evaluation or proposed programmatic improvements. The inspector had no further
questions.
(Closed) VIO 97-06-03: Failure to Take Effective Corrective Action for SBGT
System Potential Over-pressurization
On April 24,1997, the licensee prematurely concluded that inerting and de-inerting
operations with the reactor at power were in accordance with the VY licensing
bases. Subsequent to inerting activities on May 8,1997, with the reactor at
power, the licensee determined that this conclusion was incorrect and that VY had
been operated outside its licensing basis. The inspector verified a sample of the
licensee's commitments in the October 31,1997, response to the violation.
Corrective actions included interim administrative controls and a final resolution
through a TS amendment issued on May 14,1998. Through a review of records,
the inspector found that the licenseo provided training to management and
en0 neering staff on design and licencing basis issues and that the Licensing
i
Department had delineated the roles and expectations for licensing engineers.
1 Closed) IFl 50-271/96-200-01: Event Report Program Weaknesses
The 1996 Corrective Action Program inspection identified weaknesses in the
implementation of the ER program and its procedural guidance. Specifically,
timeliness goak of the ER process were not routinely met and procedural guidance
_ _ _ _ _ _ ___-___ __ __________
_ _ - _ _ _ _
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__
j
.
.
25
was weak regarding the threshold for identification of issues and the process for ER
closure. In response to these issues, the licensee eliminated ER due date extensions
and established corporate timeliness goals to monitor overdue ERs and the backlog
of ER commitments. By the end of 1997, the licensee essentially eliminated its
backlog of approximately 150 overdue ERs. Although the licensee's process allows
extension of commitment due dates, the corporate goal is based on the commitment
age and therefore is independent of the extension process. In 1997 the corporate
performance goal was met. A review of AP 0009, Event Reports, Revision 8, found
,
l
that the licensee had made revisions to clarify expectations for ER initiation
thresholds and the process for ER closure. Based on the number of ERs generated
since this IFl was opened, it was apparent the licensee had lowered the threshold
for initiating ERs. This inspector follow-up item is closed.
E8.4 FSAR Review
A recent discovery of a licensee operating its facility in a manner contrary to the
Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a
special focused review that compares plant practices, procedures and/or parameters
to the FSAR description. While performing the inspections discussed in this report,
the inspectors reviewed the applicable portions of the FSAR that related to the
areas inspected. The following inconsistencies were noted between the wording of
the UFSAR and the plant practices, procedures and/or parameters observed by the
inspectors.
The team reviewed portions of FSAR Chapters 1,6,10,14 and Appendix D during
this inspection. The team noted that the VY quality assurance program was
described in Chapter 1 and Appendix D and referred to the YOOAP. As noted in
Section E7.1 of this report, a violation was issued for failing to obtain NRC approval
prior to making changes to QA commitments. The team noted that the HPCl/RCIC
system operation was described in Chapters 6 and 14 and the control room
ventilation system was described in Chapter 10. As noted in Sections E2.1 and
E2.4 of this report, a violation was issued for incomplete safety evaluations of
changes to these systems.
V. Manaoement Meetinos
X1
Exit Meeting Summary
A exit meeting was held on June 5,1998 with Mr. Leach and others on the VY
staff to discuss the purpose and to review the results of the inspection, including
the violations cited in this report. Mr. Maret attended the meeting by phone. The
meeting was attended by Mr. J. Wiggins, Director, Division of Reactor Safety, for
the NRC in Region 1. The licensee did not question the observations and findings
presented by the team during the meeting. The licensee confirmed that no
. proprietary information was used during this inspection.
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_ _ _ _
_ _ _ - _ _ _ - _ _
_
.
.
PARTIAL LIST OF PERSONS CONTACTED
Vermont Yankee
M. Balduzzi
Plant Manager, formally Operations Superintendent
R. Barkhurst
President and CEO
K. Bronson
Operations Manager
D. Catsyn
Technical Support Manager
P. Corbett
Project Engineering Manager
J. DeVincentis
Assistant to Director of Engineering
A. Doyle
DBD Program Manager
F. Helin
Operations Superintendent / Technical Services Supt.
R. January
Electrical and l&C Design Engineering Manager
D. Leach
VP, Engineering
D. Legere
Systems Engineering Manager
E. Lindamood
Director of Engineering
D. McElwee
Liaison Engineer
P. McKinney
Lead Systems Engineer - Electrical
G. Maret
Director of Operations, formally Plant Manager
M. Metell
Mechanical Design Engineer
R. Ramsdel
Tech Support Corrective Actions Engineer
M. Watson
Maintenance Superintendent
G. Werzbowski
Lead Systems Engineer - Mechanical
NRC
W. Rutand
Chief, Electrical Engineering Branch, DRS, Region 1
J. Wiggins
Director, Division of Reactor Safety, Region 1
I
1
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.
.
INSPECTION PROCEDURES USED
37001
10 CFR 50.59 Safety Evaluation Program
37550
Engineering
40500
Effectiveness of Licensee Controls in Identifying, Resolving,
and Preventing Problems
92903
Follow-up - Engineering
ITEMS OPENED, CLOSED and DISCUSSED
Qoened
50-271/98-80-01
Failure to Perform Adequate Safety Evaluation
50-271/98-80-02
Inadequate implementation of Corrective Action Program
50-271/98-80-03
Failure to issue Required Reports to NRC
50-271/98-80-04
Failure to Control Changes to Design Basis Documents
50-271/98 80-06
IFl
Containment Pressure Response
50-271/98-80-07
Failure to Obtain NRC Approval Prior to Revising QA
Commitments
50-271/98-80-08
Complete Review of February 25,1998 Submittal
Opened / Closed
50-271/98-80-05
NCV Failure to submit a Timely LER
50 271/98-80-09
NCV inadequate Safety Evaluation
Closed
50-271/97-06-03
Criterion XVI
50-271/97 10-07
Safety Evaluation
50-271/97-200-01 IFl
Event Report Program Weaknesses
Discussed
50-271/98 276
LER
LER 98-005-00
HPCl/RCIC Exhaust Lines Susceptible to
50-271/98-306
LER
LER 98-010-00
Challenge Containrnent Systems in Event
of LOCA
l
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_ . _ - _ = .
. - - _ _ _
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.
.
LIST OF ACRONYMS USED
Atomic Energy Commission
ACS
Alternate Cooling Source
American Nuclear Society
AOG
Advanced Off-Gas System
AUX
Auxiliary Transformer
BMO
Basis for Maintaining Operation
CFR
Code of Federal Regulations
CMIP
Configuration Management improvement Project
CRP
Control Room Panel
Control Room Ventilation
Design Basis Document
Direct Current
DE&S
Duke Engineering and Services
Diesel Generator
EDCR
Engineering / Design Change Request
eel
Escalated Enforcement item
ELLLA
Extended Load Line Limit Analysis
ER
Event Report
Functional Area Assessment
Final Safety Analysis Report
GDC
General Design Criteria
Horsepower
High Pressure Coolant injection
Heating, Ventilating and Air Conditioning
IFl
Inspector Follow-up Item
Institute of Nuclear Power Operations
KV
kilovolt
LCO
Limited Condition for Operation
LER
Licensee Event Report
Loss of Coolant Accident
MM
Minor Modification
MPAC
Maintenance Planning and Control
Non-Cited Violation
NRC
Nuclear Regulatory Commission
Nuclear Reactor Regulation
Nuclear Steam Supply System
P&lD -
Piping and Instrument Diagram
Plant Operations Review Committee
Pounds per Square Inch Gauge
!
Quality Assurance
Reactor Building Closed Cooling Water
Reactor Core isolation Cooling
i
Refueling Outage
Regulatory Guide
Residual Heat Removal Service Water
1
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____ _ _ _ ___ _
.
.
2
Systematic Assessment of Licensee Performance
Service information Letter
Structures, Systems, and Components
Startup Transformer
Trans Incore Probe
TM
TS
Technical Specification
Unresolved item
USO
Unreviewed Safety Question
Violation
Vermont Yankee
VYSCM
Vermont Yankee Safety Classification Manual
YAEC
Yankee Atomic Electric Company
YOQAP
Yankee Operational Quality Assurance Program
..
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