View source for 05000271/LER-1995-001, :on 941230,identified That Required TS Surveillance Had Not Been Performed Prior to Performing Maintenance.Caused by Inadequate Procedure Requirements. Interim Policy Established

{{Adams
| number = ML20085H430
| issue date = 06/16/1995
| title = :on 941230,identified That Required TS Surveillance Had Not Been Performed Prior to Performing Maintenance.Caused by Inadequate Procedure Requirements. Interim Policy Established
| author name = Wanczyk R
| author affiliation = VERMONT YANKEE NUCLEAR POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000271
| license number = 
| contact person = 
| document report number = BVY-95-68, LER-95-001, LER-95-1, NUDOCS 9506210164
| document type = LICENSEE EVENT REPORT (SEE ALSO AO RO), TEXT-SAFETY REPORT
| page count = 6
}}
{{LER
| Title = :on 941230,identified That Required TS Surveillance Had Not Been Performed Prior to Performing Maintenance.Caused by Inadequate Procedure Requirements. Interim Policy Established
| Plant = 
| Reporting criterion = 10 CFR 50.73(a)(2)(iv), 10 CFR 50.73(a)(2)(v), 10 CFR 50.73(a)(2), 10 CFR 50.73(a)(2)(1), 10 CFR 50.73(a)(2)(x)
| Power level = 
| Mode = 
| Docket = 05000271
| LER year = 1995
| LER number = 1
| LER revision = 0
| Event date = 
| Report date = 
| ENS = 
| abstract = 
}}

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V, E'RMONT YANKEE NUCLEAR POWER CORPORAT/ON P.O. Box 157, Governor Hunt Road
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Vernon, Vermont 05354-0157
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(802) 257-7711 4,,
t 1995 June 16' 68 avy #95-U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 REFERENCE: Operating License DPR-28 Docket No. 50-271 Reportable Occurrence No. LER 95-01, Supp. 1 Dear Sirst As defined by 10 CFR 50.73, we are reporting the attached Reportable Occurrence as LER 95-01, Supp.
1.
Very truly yours, f
VERMONT YANKEE NUCLEAR POWER CORPORATION ert J. W zyk Plant Manager cc:
Regional Administrator J
USNRC 1
Region I 475 Allendale Road j
King of Prussia, PA 19406 i
9506210164 950616 PDR ADOCK 05000271 i
i PDR S
i l
u

NRC Form 366 U.S. NUCLEAR REGULAVOR7 COMMISSIC3 APPROVED BY OMB C*0. 3150-0106 (5-93)
EXPIRES 5/31/95 ESTIMAVED BURDEN PER RESPONSE TO COMPL7 UITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER)
COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMF.NT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO THE FAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT en BUDGET, WASHINGTON, DC 20503.
FACILITY NAME (1)
VERMONT YANKEE NUCLEAR POWER STATION DOCKET NLMBER (2)
PAGE (3) 05000271 01 0F 05 TITLE (4) FAILURE TO PERFORM SURVEILLANCE $ TO ASSURE PRIMARY CONTAINMENT INTEGRITY BEFORE RELEASING EQUIPMENT FOR MAINTENANCE DUE TO INADEQUATE PROCEDURES EVENT DATE (5)
LER NLMBER (6)
REPORT DATE (7)
OTHER FACILITIES INVOLVED (8)
CI TH DAY YEAR YEAR SEQUENTIAL REVISION MONTH DAY YEAR FACILITY NAME DOCKET NO.(S)
NUMBER NUMBER 05000 12 30 94 95
-- 001 01 06 16 95 N/A OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR i: CHECK ONE OR MORE (11)
MODE (9)
N 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b)
POWER 20.405(a)(1)(1) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c)
LEVEL (10) 100 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vil)
OTHER:
20.405(a)(1)(iii)
X 50.73(a)(2)(1) 50.73(a)(2)(vill)(A)
(Specify in 20.405(a)(1)(iv) 50.73(a)(2)(li) 50.73(a)(2)(vill)(B)
Abstract below and in Text, 20.405(a)(1)(v) 50.73(a)(2)(lii) 50.73(a)(2)(x).....................
LICENSEE CONTACT FOR THIS LER (12)
NAME TELEPHONE NO. (Include Area Code)
C10BERT J. WANCZYK, PLANT MANAGER 802 257-7711 CDFLETE ONE LINE FOR EACH COWOMENT FAILURE DESCRIBED IN THIS REPORT (13)

==CAUSE==
SYSTEM COMPONENT MANUFACTURER REPORTABLE

==CAUSE==
SYSTEM COMPONENT MANUFACTURER REPORTABLE TO NPRDS TO NPRDS N/A N/A N/A N/A SUPPLEMENTAL REPORT EXPECTED (14)
EXPECTED MO DAY YEAR I
SUBMISSION YES NO DATE (15) 1 (If yes, complete EXPECTED SUBMISSION DATE)
X 1
ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16) i At approximately 1545 hours on 12/30/94, with the reactor operating at 100% power, Vermont Yankee self identified that I
a required Technical Specification surveillance had not been performed prior to performing a maintenance activity on 6/11/94.
Subsequent to that, two other similar failures to perform the same surveillance were identified during preparation of this LER.
The other events occurred on 5/18/93 and 7/14/93.
The root cause of this event is a lack of specific requirements in written procedures or documents. The plant's administrative program does not contain controls to assure that the requirements of Technical Specification paragraph 4.7.A.3 and Table 4.7.2.b are satisfied during maintenance. Other contributing factors are included in the text.
Immediate corrective actions were performed which included: verifying primary containment integrity, reviewing maintenance records, establishing an interim policy requiring engineering review of work orders for safety class pressure boundary components that will be implemented when primary containment integrity is required, and issuing a Nuclear Network message. The short and long term corrective actions are provided in the text of the LER.
NRC Form 366 (5-92)

HRC F m 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OM8 NO. 3150-0104 (5-92)
EXP!RES 5/31/95 ESTIMATED BORDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST:
50.0' HRS. FORWARD LICENSEE EVENT REPORT (LER)
COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND TEXT CONTINUATION RECORDS MANAGEMENT BRANCH (MNBG 7714), U.S. NUCLEAR REGULATORY COMMIS$10N, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PRCJECT (3150 0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.
FACILITY NAME (1)
DOCKET NUMBER (2)
LER NLMBER (6)
PAGE (3)
YEAR SEQUENTIAL NUMBER REV #
YERMONT YANKEE NUCLEAR POWER CORPORATION 05000271 95 001 01 02 OF 05 l.
TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
DESCR PTION OF EVENT At approximately 1545 hours on 12/30/94, with the reactor operating at 100% power, it was identified that a required Technical Specification surveillance had not been performed prior to performing a maintenance activity on 6/11/94.
Subsequent to that, two similar failures to perform the same surveillance were identified during preparation of this LER. The othIr events occurred on 5/18/93 and 7/14/93.
The identification of the first event (6/11/94) occurred during engineering review of an upcoming Limited Condition for Op: ration (LCO) Maintenance Plan for the "A" Residual Heat Removal (RHR) system (Ells = BM). Identification of the other two events occurred on 1/23/95 during preparation of Rev. O of this LER.
Vermont Yankee's current design basis considers the RHR system as an extension of Primary Containment (PC). As an ext:nsion of PC, the Primary Containment isolation Valves (PClV) are exempt from 10CFR Part 50 Appendix J Type C testing, in order to assure PC integrity, the Plant's Technical Specifications require Type C testing if the pressure boundary of any of the thr e systems identified on Table 4.7.2.b will be opened when PC is required to be operable.
The first event (6/11/94) occurred when a check valve (RHR-48B) in the RHR system was opened to perform corrective maintenance and the valves bounding the opening were not Type C leak tested. During operation of the "B" RHR pump it was dsttrmined that the check valve was leaking internally and required repair. The applicable work order was reviewed and rslused by the on-shift Operation's Shift Supervisor (SS) prior to the necessary leak tests being performed.
The second event (7/14/93) occurred when a similar check valve (RHR-48D) in the RHR system was opened to perform a routine inspection of the internals and the valves bounding the opening were not Type C leak tested. As part of an LCO maintenance action, the internals of RHR-48D were to be inspected as required by the VY Check Valve inspection Program.
T% applicable work order was reviewed and released for work prior to performance of the necessary leak tests.
The third event (5/18/93) occurred during corrective maintenance on the sealin the "A" RHR pump which required replIcement due to wear. In order to replace the seal a portion of the pump casing required disassembly. The valves bounding the opening were not Type C tested. The applicable work order was reviewed and released for work prior to performance of the necessary leak tests.

==CAUSE OF EVENT==
Root Cause:
The root cause for all of these events is:
Written Procedures or Documents - The plant's administrative program did not contain controls to assure that the requirements of Technical Specification paragraph 4.7.A.3 and Table 4.7.2.b are satisfied during maintenance.
Contributina Causes:
The following are contributing causes for the events:
: 1. Wntten Procedure or Documents - The surveillance requirement in Technical Specification Section 4.7.A.3 for assuring Primary Containment integhty during maintenance on the RHR, SLC and Containment Sampling systems is not discussed in the Tech Spec sections for those three sVstems.(5-92)

NRC' Fcre 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BT OMB NO. 3150-0104 (5-92)
EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FCRWARD LICENSEE EVENT REPORT (LER)
COPMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND TEXT CONTINUATION RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISS10N, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150 0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.
FACILITY NAME (1)
DOCKET IRAWER (2)
LER NL8WER (6)
PAGE (3)
YEAR SEQUENTIAL NUMBER REV #
l VERMONT YANKEE NUCLEAR POWER CORPORATION 05000271 95 01 03 0F 05 l 001 TEXT (if more space is required, use additional copies of NRC Form 366A) (17)
: 2. Corrective Action - NRC Inspection Report 93-02 was issued before the three events occurred and detailed concerns that:
(1) the wording in TS 4.7.A.3 and Table 4.7.2.b regarding primary containment integrity is ambiguous, and (2) TS 4.7.A.3 and Table 4.7.2 requirements do not have administrative controls to assure that primary containment integrity would be maintained during maintenance.
The concerns involved the Tech Spec requirements which applied to the RHR, SLC and Containment Sampling systems. The corrective action specifically addressed only the Containment Sampling systems and did not address the ambiguous wording in paragraph 4.7.A.3 or the lack of administrative controls for maintaining primary containment integrity when performing maintenance on the RHR and SLC systems.
: 3. Training -
a. Repair personnel are required by Appendix A to the Work Order procedure to review Technical Specification requirements while planning a maintenance activity. However, they have not received training to identify potential operability issues created by the work order, b. Operations personnel have been trained to review the LCO requirements when reviewing maintenance activities for operability issues. Training has not been given to direct personnel to review the surveillance requirements as well as the bases for both the LCO and Surveillance sections.

==ANALYSIS OF EVENT==
Per Technical Specification 3.7.A, PC is necessary whenever the reactor coolant temperature is greater than 212 degrees F and fuel is in the reactor vessel. Primary Containment was required to be operable on 6/11/94, 5/18/93 and 7/14/93. In the thrse cases, all of the PCIVs for RHR were considered to be operable. Manual isolation valves, on both sides of the component being worked on were used to isolate the component from the RHR system. Isolating the component caused the associated RHR pump to be tagged out, but the other pump in the train remained operable. If a design basis Loss of Coolant Acc;dont had occurred while the check valve was being worked on:
a. the Drywell boundary valve would have been pressurized, with water, to greater than the peak containment accident pressure from the discharge of the other pump in the loop, and b. the Torus boundary valve would have been pressurized with water because the valve is lower than the Torus.
Thus, a water seal would have been maintained on the boundary valves and any leakage would have been into the drywell through the RHR PCIVs. The applicable Emergency Diesel Generator was operable while the valves were being wprked on.
The events with the check valves are very similar, while the vark performed on the sealis nearly Identical to the work that was performed on the RHR pumps in 1987. In 1987, concem of potential RHR pump wear ring problems required maintenance on the pumps while Primary Containment was necessary. A one-time exemption request was granted by NRC to use the identical valves to isolate the pumps as those used during the three events.
The system was opened for approximately two days when each of the components was worked on. The folicwing details the langth of time each comporent was open:(5-92)

^
WRC Fern 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 3150-0104 (5-92)
. ESTIMATED BURDEN PER RESPONSE TO COMPLY UITH THIS EXPIRES 5/31/95 INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER)
COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND TEXT CONTINUATION RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555 0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150 0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.
FACILITY NAME (1)
DOCKET NL5WER (2)
LER IRAGER (6)
PAGE (3)
YEAR SEQUENTIAL NUMBER REV #
YERMONT YANKEE NUCLEAR POWER CORPORATION 05000271 95 001 01 04 0F 05 l.
~
~
TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
Valve RHR-48B: released 6/11/94, PMT performed 6/14/94 "A" RHR Pump Seal: released 5/18/93, PMT performed 5/21/93 Valve RH3-46D: released 7/14/93, PMT performed 7/16/93 Although this event represents a violation of Technical Specification surveillance requirements, the health and safety of the public were not endangered since:
: 1. the PCIVs in the RHR train were operable,
: 2. the remaining operable RHR pump would have pressurized the loop during a DBA LOCA,
: 3. the open check valve flange was separated from containment by both the PCIVs and manual isolation valves, and
: 4. the boundary valves exhibited minimal leakage during the maintenance activities.
The Technical Specification Table (4.7.2.b) referenced by Section 4.7.A.3 lists all or portions of the following systems as extensions of PC:
a.RHR, b. Standby Liquid Control system (Ells =BR), and c. Hydrogen Monitoring / Containment Air Monitoring (Ells =BB/lL)

==CORRECTIVE ACTIONS==
Immediate:
: 1. Primary Containment integrity was verified.
: 2. Records of WOs since 9/91 were reviewed for the SLC and RHR systems. Two additional events were identified for the RHR system and are being reported by this LER.
: 3. An interim policy has been put into effect that requires engineering review of work orders for safety class, pressure boundary components that will be implemented when primary containment integrity is required. This policy will remain in effect until completion of all the corrective actions associated with this LER.
: 4. A notice of the 6/11/94 event was issued via Nuclear Network.
Short Term:
: 1. Include the requirements of Technical Specification Sections 4.7.A.3 into the Administrative Limits section of the operating procedures for the SLC, RHR and H 0 systems for the valves listed on Technical Specification Table 4.7.2.b.
2 2
: 2. Include the requirements of Technical Specification Section 3/4.7 into the Administrati<e Limits section of procedure OP 2115. Primary Containment.
: 3. Revise administrative procedures dealing with work order generation and release of plant equipment to assure that operability reviews include surveillance requirements, and bases sections for both LCOs and surveillances.(5-92)

'RC Ftra 366A U.S. NUCLEAR REGULATORY COMMISS10N APPROVED BY OMB NO. 3150-0104 N
.(5 92)
EXP!RES 5/31/95 r
EST! MATED BURDEN FFR RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS. FORWARD LICENSEE EVENT REPORT (LER)
COMMENTS REGARDING BURDEN ESTIMATE TO THE INFORMATION AND TEXT CONTlWUATION RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555 0001, AND TO THE I
PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.
5 FACILITY IWE (1)
DOCKET NLOWER (2)
LER IR5GER (6)
PAGE (3)
YEAR SEQUENTIAL NUMBER REV #
VERMONT YANKEE NUCLEAR POWER CORPORATION 05000271 95 001 01 05 OF 05 l,
TEXT (If more space is required, use additional copies of NRC Form 366A) (17)
: 4. Following procedure changes, identify and arrange for training of maintenance, Engineering and Operations department personnel performing LCO, surveillance and operability reviews.
Short Term corrective action items 1,2 and 3 are expected to be implemented by 10/95.
Short Term corrective action item 4 is expected to be implemented by 1/96.
Lona Term:
: 1. Finalize Revision 1 to the Appendix J Program and develop the necessary Technical Specification changes. The priority and schedule for submittal of the Technical specification changes will be determined af ter the changes are prepared.
This corrective action is expected to be implemented by 3/96.
l l
i(5-92)
}}

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