ML20011D490

LER 89-024-01:on 890913,while Reviewing RHR Sys Surveillance Procedure,Determined That Leak Testing of RHR Valve V10-18 Not Incorporated & Implemented in Rev 9.Caused by Incomplete Review.Event Reviewed w/personnel.W/891220 Ltr

ML20011D490
Person / Time
Site:	Vermont Yankee
Issue date:	12/20/1989
From:	Pelletier J VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-024, LER-89-24, VYV-89-261, NUDOCS 8912270316
Download: ML20011D490 (4)

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,. o VERMONT YANKEE NUCLEAR PowEn CORPORATION P. O. DOX 157 ,

l GOVERNOR HUNT TtOAD VERNON, VERMONT 05354 December'20, 1989  !

VYV 89-261 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 89-24

[

Dear _ Sirs:

As defined by 10CFR50.73, we are reporting the attached Reportable j Occurrence as LER 89-14 Rev. 1. This revision was issued based on additional information obtained during a subsequent documentation review.

Very truly yours, 1-i VERMONT YANKEE NUCLEAR POWER CORPORATION '

James P. Pelletier Plant Manager ,

cc: Regional Administrator USNRC l Region I l 475 Allendale Road  ;

King of Prussia, PA- 19406 >

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L 8912270316 891220

.S-PDR- ADOCK 05000271 ' ' - 8 $

PDC < >

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NRC Form 384 U.S. NUCL EAR REGULATORY COMMISSION (9-83) APPROVED OMS NO.3150-0104 LICENSEE EVENT REPORT (LER) EXPIRES 8/31/96 FACILITY NAME (5) DOCKET NO. e) PAGE (8)

VERMONT YANKEE NUCLEAR POWER STATION O l 5 l 0 l 0 l(0 l 2 l 70 ll 1 1 l 0F l 0 l 3 TITLE (*) MISSED RESIDUAL HEAT REMOVAL SYSTEM VALVE LEAKAGE SURVEILLANCE DUE TO INCOMPLETE PROCEDURE REVIEW.

EVENT DATE (*) LER NUMBER (5) REPORT DATE (?) OTHER FACILITIES INVOLVED (*)

MONTH DAY YEAR YEAR SEO # REV# MONTH DAY YEAR FACILITY NAMES DOCKET NO.(S)

NA 0 5 0 0 0 1 0l9 1__[3 _ 819 8l9 -

0l2l4 -

0l1 1l2 2l0 8l9 NA 0 5 0 0 0 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO REQ'MTS OF 10CFR 6: / ONE OR MORE ('1)

MODE (*) N 20.402(b) __ 20.405(c) __ 50.73(a)(2)(iv) __ 73.71(b)

POWER __ 20.405(a)(1)(I) __ 50.36(c)(1) __ 50.73(a)(2)(v) __ 73.71(c)

LEVEL (t*) 1l d 0 20.405(a)(1)(II) ._ 50.36(c)(2) __ 50.73(a)(2)(vii) __

OTHER:

............... __ 20.405(a)(1)(III) _X 50.73(a)(2)(I) __ 50.73(a)(2)(viii)(A)

............... __ 20.405(a)(1)(iv) __ 50.73(a)(2)(II) __ 50.73(a)(2)(viii)(B)

............... 20.405(a)(1)(v) 50.73(a)(2)(III) 50.73(a)(2)(x) '

LICENSEE CONTACT FOR THIS LER (ie)

NAME TELEPHONE NO. ~ '

AREA CODE JAMES P. PELLETIER, PLANT MANAGER 8ld22l5l7[-l7l7lIl1  ;

COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (18)  ;

CAUSE SYST COMPNT MFR REPORTABLE ..... CAUSE SYST COMPNT MFR REPORTABLE ...... i TO NPRDS ..... TO NPRDS ......

NA l lll lll ll. NA l lll lll .

NA l lll lll . .l NA l lll lll SUPPLEMENTAL REPORT EXPECTED ('*) EXPECTED M0 DA YR SUBMISSION

~~l YES (If ves, complete EXPECTED SUBMISSION DATE) 'X1 NO DATE (15) l l l ABSTRACT (Limit to 1400 spaces, i.e., approx. fifteen single-space typewritten lines) ('*)

In order to implement the recently developed Revision 10 of the Vermont Yankee Intervice Testing (IST) program, various system surveillance procedures were being revised to incorporate program changes. On 9/13/89, while reviewing the Residual Heat Removal _(RHR)

(EIIS=BO) System surveillance procedure, it was noted that a requirement from previous IST Program Revision 9 concerning leak testing of RHR valve V10-18 had not been incorporated and izplemented.

The root cause of this event has been determined to be incomplete review and omission of the V10-18 leak test requirement during RHR System implementing procedure development. j Vermont Yankee's subsequent documentation review reveals that per VY's design basis (i.e., Technical Specifications, B 31.1 - 1967) and Generic Letter 89-04, that RHR-18 did not require IST testing. Based on this investigation the IST Program requirement to leak tett RHR-18 will be removed from the program.

To preclude recurrence of a similar event, future changes to implementing procedures involving IST Program testing will be routed to the IST Program Coordinator for a complete rsview.

Previous similar events have been reported to the Commission, in the last five years, as LER 87-04 and LER 89-20.

NRC Form 384 -

(9-83)

]

NRCForb384A U.S. NUCLEAR REGULATORY COMMISSION (9-83) APPROVED OMS NO.3150-0104 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION EXPIRES 8-31-96 UTILITY NAME (i) DOCKET NO. (e) LER NUMBER (*) PAGE (8)

YEAR SEQ. # REV#

VERMONT YANKEE NUCl. EAR POWER STATION d d d d d 2l711 8l9 -

0l2l4 -

0l1 d2 0F d3 TEXT (If more space is required, use additional NRC Form 384A) ( ') ,

DESCRIPTION OF EVENT In order to implement the recently developed Revision 10 of the Vermont Yankee Intervice Testing (IST) Program, various system surveillance procedures were being revised to incorporate program changes. On 9/13/89, while reviewing the Residual Heat Removal (RHR)

(EIIS=BO) System surveillance procedure, it was noted that a requirement from previous IST Program Revision 9 had not been incorporated and implemented.

Revision 9 of the IST Program, which was approved on 7/28/88 and implemented on 1/17/89, added a requirement for leak testing RHR valve V10-18 during each refueling outage.

(NOTE: Valve V10-18 is the inboard Shutdown Cooling Suction Valve.) It was noted that-this tasting had not been performed during the 1989 refueling outage because it had not been cdded to the RHR system surveillance procedure.

Vermont Yankee's subsequent investigation into this event revealed that the requirement to leak test the V10-18 valve does not belong in the IST program.

When Vermont Yankee was licensed, ASME B31.1 1967 Edition, required only one valve at a high pressure to low pressure boundary. This valve needed to be qualified to the higher of tha two pressures. This requirement is currently met. Additionally, the Code required prcrsure relief valve is provided along with pressure monitoring of the low pressure side of tha piping that alarms in the Control Room. Pressure Isolation Valves (PIV's) were not a d2 sign bases that was addressed in the Technical Specifications.

Generic Letter 89-04 " Guidance on Developing Acceptable Inservice Testing (IST)

Programs" requires those PIVs listed in plant Technical Specifications to be listed in the IST program. Since Vermont Yankee's investigation revealed that this valve is not a PIV Vsrmont Yankee plans to remove the requirement to test V10-18 valves from the IST program.

l CAUSE OF EVENT l

After completion of program changes by the IST Program coordinator, Revision 9 of the IST Program was tracked on the Vermont Yankee commitment system and forwarded, with all chtnges identified, to the Operations Department to allow for revision of implementing pro-crdures. During revision of the RHR system implementing procedure, the' subject valve leak tset was omi,tted. The Operations department developed the procedure revision and provided for its internal review. Although not specifically required, the IST Program coordinator w:s then requested to provide additional review. The IST Program coordinator provided a curzory review of this and all other procedures necessary to implement Revision-9 of the program. All procedure changes covered by this random review were found to be complete and to adequately reflect program testing requirements. However, the subject valve leak test His not included in the scope of the review. This, coupled with the initial omission of the l leak test during procedure development, is determined to be the root cause of this event.

i l ANALYSIS OF EVENT The subject valve, V10-18, is the inboard valve of the Primary Containment Isolation Valve pair for the RHR Shutdown Cooling Suction line penetration. Valve V10-18 and j V10-17, the outboard valve at this penetration, have the additional function of providina a NRC Form 384A (9-83)

NgC-For's 384A U.S. NUCLEAR REGULATORY COMMISSION (9-83) APPROVED OMS NO.3150-0104 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION EXPIRES 8-31-96 UTILITY NAME (5) DOCKET NO. (*) LER NUMBER (*) PAGE (a)

YEAR SEO, # REV#

VERMONT YANKEE NUCLEAR POWER STATION d d d d d 2l7]1 8l9 -

0l2l4 -

0l1 ,d3 0F d3 ,

TEXT (If more space is required, use additional NRC Form 384A) ( ')

ANALYSIS OF EVENT (Continued) piping pressure specification separation. These valves separate Reactor Coolant Pressure

.from RHR System piping. Although these valves act as Pressure Isolation Valves (PIV's),

thsy have no specific requirement for leak testing in Tech. Spec. Section 3.7.D concerning Primary Containment.

In addition, it should be noted that although the recently self imposed IST Program lack test requirement was not performed, valve stroke time testing was accomplished. Review of this stroke time data shows no indication of valve operator degradation. It should also be noted that in the worst case scenario of valve V10-18 being inoperable in the fully open position, reactor operation is permitted if the next valve downstream is closed.

During development of Revision 9 of the IST Program, Vermont Yankee committed to leak tcst valve V10-18 during each refueling outage to determine any gross leakage. Corrective Ection would then be taken per ASME Section XI requirements. Since ASME Section XI testing is referenced in Tech. Spec. 4.6.E.2, this event can be considered a missed Tech. Spec. sur-vaillance. Although the leak test was not performed, system pressure indication downstream of the subject containment penetration has been normal during the current operating cycle.

Based on the above, it is concluded that the integrity of the corresponding Primary Containment penetration is assured via closure of valve V10-17 and continuous pressure tonitoring.

Therefore, during the events of this report and for the remainder of the current operating cycle, there is reasonable assurance that there are no adverse safety implications to plant equipment, personnel, or to the public.

CORRECTIVE ACTION l Based on the guidance provided in GL 89-04, and review of the design basis for the V10-18 valve, the requirement to leak test RHR-18 valves will be removed from the IST program.

A review has been completed and all other IST Program implementing procedures adequately l address all testing required by the program. In addition, this event has been reviewed with L th3 affected personnel responsible for procedu're development and review.

To further preclude recurrence of a similar event, future changes to implementing pro-i c dures involving IST Program revisions will be routed to the IST Program Coordinator for l c complete review.

ADDITIONAL INFORMATION Previous similar events have been reported to the Commission, in the last five years, L as LER 87-04 and LER 89-20.

NRC Form 384A L

(9-83) l-