View source for 05000271/LER-1987-003, :on 880412,personnel Found Functional Testing Not Been Tested in Accordance W/Tech Spec Requirements. Caused by Programmatic Tracking Program.Programmatic Tracking Sys Revised as Described in LER 87-03

{{Adams
| number = ML20154C484
| issue date = 05/10/1988
| title = :on 880412,personnel Found Functional Testing Not Been Tested in Accordance W/Tech Spec Requirements. Caused by Programmatic Tracking Program.Programmatic Tracking Sys Revised as Described in LER 87-03
| author name = Pelletier J
| author affiliation = VERMONT YANKEE NUCLEAR POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000271
| license number = 
| contact person = 
| document report number = IEB-80-17, LER-88-003, LER-88-3, VYV-88-089, VYV-88-89, NUDOCS 8805180191
| document type = LICENSEE EVENT REPORT (SEE ALSO AO RO), TEXT-SAFETY REPORT
| page count = 4
}}
{{LER
| Title = :on 880412,personnel Found Functional Testing Not Been Tested in Accordance W/Tech Spec Requirements. Caused by Programmatic Tracking Program.Programmatic Tracking Sys Revised as Described in LER 87-03
| Plant = 
| Reporting criterion = 
| Power level = 
| Mode = 
| Docket = 05000271
| LER year = 2087
| LER number = 3
| LER revision = 
| Event date = 
| Report date = 
| ENS = 
| abstract = 
}}

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s LER 88-03
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ABSTRACT On 4-12-88, during normal operation at 100% power it .as discovered that functional testing of the Scram Discharge Volum High Water Level Trip (UIS=JC) had not been tested in accordance with Technical Specification Table 4.1.1 requirements. Table 4.1.1, Note 1 requires that testing shall be conducted monthly initially and between one and three month intervals thereafter. A review of past records has revealed that this testing was not done monthly initially.
The root cause of this event is that the progrannatic tracking Drogram in place at the time Amndnent 7C was issued did not require procedural reviews ter Technical Specifications Amendments prior to issuance.
The corrective action initiated in LER 87-03 is responsible for the disco-very of this event.                        The progrannatic tracking system has been revised as described in LER 87-03. This corrective action is aopreoriate to oreclude future problems of this type and will continue to review existino procedural compliance with Technical Soecificatiuns, 8805180191 880510 PDR          ADOCK 05000271                                                                                                          A h           i S                                    DCD                                                                                                             j
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LER 88-o3
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09             e, corne           . -       sm-. .me w m . e DESCRIPTION OF EVENT During a review of Technical Specification surveillance requirements on 4-12-88 with the plant at 100% power, Instrument and Control (I/t) sersonnel found that functional testing of the Scram Discharge Volume (SDV) 16gh Level Trip (EIIS=JC) was not being tested in accordance with the requirenents of Table 4.1.1,       Note 1 requires testing initially monthly and thereafter at an interval of not less than one month nor more than three months. When this system was modified in 1983 and the functional test frequency was changed to Note 1, the functional testing continued at the three mnth interval with no initial monthly testing being performed.
The sequence of events leading up to this event are as follows:
: 1. In response to IEB 80-17 Vermont Yankee comitted to modify the Scram Discharge Volumes to replace the single instrument volume with two instrument volumes each having its own level instrumntation.
In My 1980, Vermont Yankee was requested to change the functional test frequency for the Scram Discharge Volum High Level Trip from every three months to monthly in order to conform to Standard Technical Specifications. Vermont Yankee responded to the USNRC on October 14, 1980 defendino the three month testing interval. This resoonse and the proposed modifications to the Scram Discharge Volume were reviewed by the NRC and Franklin Research Center (TER-C-5506-64) and the conclusion was that the three month testing interval was acceptable. The results of this review were contained in the SER for Amendment 73 to Vermont Yankee Technical Specifications which approved testing at the three month interval.
: 2. In 1983, the Scram Discharge Volum modifications were implemented. In the design changes which performed these nodifications the proposed revision to the Technical Specification paces did not change the three month functional test interval for the SOV instrumnts.
: 3. In January 1983, Proposed Change 103 was submitted to the NRC reqm s',ing the Technical Specifications be changed to reflect the installation of the new Scram Discharge Volumes.          In this proposed change, the func-tional test interval for SOV instrumnts was changed to Note 1 instead of the three month interval. Amendment 76 (Proposed Change 103) was issued in March 1983.
: 4. In January 1985, a review of the Technical Specification Surveillan.:e testing intervals was conducted by I/C Department. This review noted that all other epulpment tested undet Note 1 to Table 4.1.1 was beirq tested monthly while the SDV instrumnts were being tested at three month intervals. The conclusion at thGt time was that, based upon the SER for Amandment 73, that. the three month testing interval for SDV instrumnts had been reviewed and accepted and that the three mnth test interval was appropriate, e...._-.

LER 88-03
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: 5. In response to the concern on 4-12-88 and corrective action per LER 87-03, Vermont Yankee reviewed all past functional testing performed since the SDV was modified in 1983. We have determined that since the 50V functional testing was not initially performed monthly, the requirements of Note 1 to Table 4.1.1 were not technically met.
CAUSE OF EVENT The root cause of this event is that the programmatic tracking program in place at the time Amndment 76 was issued did not require procedural reviews for Technical Specifications Amendments prior to issuance.
ANALYSIS OF EVENT The testing requirements specified by Note 1 to Table 4.1.1 are to ensure that the equipment is tested more frequently @en initially installed.                   After more experience has proven the reliability of the equipment, the testino fre-quency may be extended.
In the case of the SDV instruments, the instrumntation installed is iden-tical to eaaioment which has been installed in other applications at Vermont Yankee since 1980 and the reliability has been proven to be acceptable. In addition, the proposed modification and the three month test frequency were reviewed and accepted by the NRC in 1980 prior to the modification of the Scran Discharge Volumes.
All functional tests performed since the new instruments were installed in 1983 were reviewed for reliability, instrumnt drift, and failure rate. Based upon this review, we have determined that there is no need to increase the sur-veillance frequency.
Based uoan the above, Vermont Yankee has determined that the three conth functional test frequency is appropriate, and there has been no impact on public health and safety.
CORRECTIVE ACTIONS The corrective action initiated in LER 87-03 is responsible for the disco-very of this event. The programatic tracking system has been revised as described in LER 87-03.          This corrective action is accropriate to areclude future problems of this type and will continue to review existing procedural compliance with Technical Specifications.
SIMILAR EVENTS A similar event has been reported to the NRC in LE( 87-03.
                  .s....==

VERMONT YANKElc NUCLICAR POWICR COltl'OR ATION P. O. BOX 157 GMERNOR llUNT ROAD VEltNON, VEllMONT 05354 May 10, 1988 VYV No. 88-089 U.S. Nuclear Regulatory Commission Docurnent Control Desk                                                              r Washington, D.C. 20555

==REFERENCE:==
Operating License DPR-28 Docket No. 50-271 Reportable Occurrence No. LER 88-03

==Dear Sirs:==

As defined by 10CFR50.73, we are reporting the attached Reportable Occurrence as LER 88-03.
Very truly yours, VERMONT YANKEE NUCLEAR POER CORPORATION ames P. Pelletier Plant Manager cc   Regional Administrator USNRC Office of Inspection and Enforcement C71on I 475 Allendale Road King of Prussia, PA 19406 hb
                                                                                   '!l
_  .             _,   -.
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