ML20042F361

LER 90-006-00:on 900403,Tech Spec Surveillance Requirement Missed Due to Failure to Include Basis on Tracking List. Caused by Personnel Error.Changes to Master Surveillance List & Any Affected Procedures Will Be made.W/900502 Ltr

ML20042F361
Person / Time
Site:	Vermont Yankee
Issue date:	05/02/1990
From:	Pelletier J VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-90-006, LER-90-6, VYV-90-134, NUDOCS 9005080232
Download: ML20042F361 (4)

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U.S._ Nuclear Hegulatory; Commission f

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REFERENCE:

_ Operating' License'DPf1-28 ];

Docket No. 50-271 Reportable Occurrence No. i.ER 90-006- ~

Dear Sirst.

< ,, .'As-detined by 10CFR50.73,-we are reporting the attached Reportable Occurrence as LER 90-005. 'I a

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NRC.Fcra 366: U.S. NUCLEAR REOULATORY COMMISSION APPR9VED OMS NO.3150-0104 u-(6-89)'

• . EXPIRES:4/30/92' ESTIMATED BURDEN PER-RESPONSE TO-COMPLY--

WITH THIS INFORMATION_ COLLECTION REQUEST:

j i

, . .50.0 HRS. FORWARD COMMENTS REGARDING' .

' LICENSEE EVENT REPORT (LER) BURDEN ESTIMATE TO THE RECORDS AND REPORTS i MANAGEMENT BRANCH (P-530). U.S;. NUCLEAR '!

REGULATORY COMMISSION,' WASHINGTON, DC j y

20555,;AND TO THE PAPERWORK REDUCTION = i p PROJECT (3160-0104),-0FFICE OF MANAGEMENT f

AND BUDGET, WASHINGTON, DC 206032 FACILITY NAME (5) . PAGE (*)

-VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. (*)l 217 Ol5l0l0l0 l1 0l110Fl013 TITLE (*) TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT MISSED.DUE'TO A FAILURE TO INCLUDE TECHNICAL SPECIFICATION BASIS ON TRACKING LIST-EVENT DATE-(*) LER NUMBER (*) REPORT DATE (?) OTHER-FACILITIES INVOLVED (*)  ;[

MONTH DAY- YEAR YEAR SEQ. #' REV# MONTH DAY YEAR FACILITY NAMES-N/A DOCKET.No.(S)l 0 5 0 0 0 t

Old Ol3 910 910 -

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OIO Ol5 0'l 2 9l0 __

N/A 0 5 0 0 0 l [

OPERATING THIS REPORT IS SUDMITTED PURSUANT TO REQ'MTS OF-10CFR 6:- ( ONE OR MORE ('5)

MODE (*)2 N 20.402(b)- _ 20.405(c) _ 50.73(a)(2)(iv) _ 73.71(b) q POWER _ 20.405(a)(1)(I) _ _ 50.36(c)(1): _ 50.73(a)(2)(v). _ 73.71(c)

LEVEL (56) 1l010 20.405(a)(1)(II) _ 50.36(c)(2) _ 50.73(a)(2)(vii) _

0THER: ,

................ _ 20.405(a)~(I)(III) X 50.73(a)(2)(I) _ 50.73(a)(2)(viii)(A)- -f

............... _ 20.405(a)(1)(iv) , 50.73(a)(2)(II) _ 50.73(a)(2)(viii)(B) l

............... 20.405(a)(1)(v) '

'50.73(a)(2)(III)- 50.73(a)(2)(x) J LICENSEE CONTACT FOR THIS LER (18)

NAME TELEPHONE NO.-

• AREA-CODE- .

JAMES P.-PELLETIER, PLANT MANAGER 8l 0l 2 2l 5l 7l -l 7l 7l Il 1 [

COMPLETE ONE LINE FOR EACH COMPONENT' FAILURE DESCRIBED IN:THIS REPORT (ia)

CAUSE SYST. COMPNT MFR REPORTABLE ..... CAUSE SYST COMPNT MFR REPORTABLE . . . , . . . .

TO'NPRDS ..... TO NPRDS- ......  !

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l 'N/A ------------------------------- ' ..... 'N/A -------------------------------- ......

l l l. ..... -l: j l ......

N/A -------------------------------- ..... N/A -------------------------------- ......

SUPPLEMENTAL REPORT EXPECTED ('*) EXPECTED MO DA YR- j; i' SUBMISSION '

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lYES (If ves, complete EXPECTED SUBMISSION DATE) XlNO DATE (15) l l j ABSTRACT (Limit to 1400 spaces,'i.e., approx. fifteen _ single-space typewritten; lines)-(?') H l

On 4/3/90,'with the' plant operating.at 100% power, it was_ identified that the flow trans-citters that supply Advanced.0ff-Gas (A00) (EIIS=VL) System Flow Indication had not!been  !

calibrated in accordance with Technical Specifications-(TS)._ Upon identification of this condition,.a full loop calibration was performed on the A00 flow monitors, as-found data indicated'that loop accuracies were'within the specifiedirange'.

i Invsstigation into the cause of this event revealed that.the proper surveillance interval ~

for calibrating the flow monitoring equipment was_ included on Vermont Yankee's Mastar- J Surveillance List (MSL), a document utilized to track such activities. However, the i rcquirement to perform the surveillance was not identified as being TS. A. Technical;  :

-Specification. Amendment issued in 1985 invoked surveillance requirements for the' flow moni-tcring equipment. 3 The root._cause of this event is personnel error. Incomplete information was provided for l

-the update of the MSL as a result of a TS Amendment. A review of the. applicable portion 1 of TS is being performed to ensure no other similar conditions exist.

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NRC Form 366 (6-89)-

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NRC Fcro 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED OMS NO.3150-0104 (6-89) ' EXPIRES 4/30/92 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST:

50.0 HRS. FORWARD COMMENTS REGARDING LICENSEE EVENT REPORT (LER) BURDEN ESTIMATE TO THE RECORDS AND REPORTS TEXT CONTINUATION MANAGEMENT BRANCH (P-530), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC i 20555, AND TO THE PAPERWORK REDUCTION {

PROJECT (3160-0104), OFFICE OF MANAGEMENT

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AND BUDGET, WASHINGTON, DC 20600.

UFILITY NAME (5) DOCKET NO. (*) LER NUMBER (*) PAGE (*) .

YEAR SEQ. # REV#

\

VERMONT YANKEE NUCLEAR POWER STATION 0l 5l 0l 0l 0l 2] 7l 1 9l0 -

0l0l6 -

0l0 Ol 2 0F 0l3 TEXT (If more space is required, use additional NRC Form 366A) ()

DESCRIPTION OF EVENT On 4/3/90, with the plant operating at 100% power, it was identified that the flow transmit-ters that supply Advanced Off-Gas (A00) System Fle? Indication had not been calibrated in the last eighteen months as required by Vermont Yankee Technical Specifications (TS). There are three flow transmitters (FT-0G-1902, 1904 and 1905) (EIIS=FT) which are used to provide 1 A0G flow indication. Any or ' " the three flow indicators can be used to meet the TS {

requirement depending on the system operating configuration. The flow indicators had been calibrated on 3/1/89, however, the flow transmitters that supply them were last calibrated j on 9/15/87. Upon identification of this condition, a full loop calibration was performed I on the A0G Flow Monitor's, and based upon '-f e nd calibration data, no overall loop accu-racies were exceeded.

Investigation into the cause of this evem revealed that the pro p surveillance interval I for calibrating the flow monitoring equipment was included on Vermont Yankee's Master Surveillance List (MSL), a document utilized to track such activities. However, the P requirement to perform the survefilance was not identified as being TS. The basis for the flow monitor surveillance frequency was identified on the MSL as being administrative, in which case the department responsible for the surveillance h'as the flexibility to reschedule l testing as needed. This flexibility is not permitted when the surveillanas is required by I TS.

In January, 1984, Proposed Technical Specification Change #78 was submitted to the NRC for review and approval. Included in this change were revisions based upon NUREG 0472, Standard Radialogical Effluent Technical Specifications (RETS). The addition of TS surevillance ,

requirements for the flow instruments occurred when the Proposed Change was issued in Octobe., 1984 as TS Amendment #83, with an effective date of April, 1985. ,

i When TS Amendment #83 was issued, the procedure used to calibrate the flow instrumentation I was revised to indicate it contained TS equipment. However, the MSL was not revised to reflect that the basis for the flow monitors to be calibrated changed from an Administrative Requirement to a TS Surveillance Requirement.

CAUSE OF EVENT The root cause of this event is personnel error. The responsible department provided incom- l plete opdate information to revise the MSL upon issuance of Technical Specification Amendment #83. The TS surveillance requirement for flow monitor calibration was not added l l

to the MSL and this resulted in insufficient control of this activity.

Contributing Factor:

The section of TS that contains the flow monitor surveillance requirements (RETS) does not contain specific instrument numbers, therefore, interpretation of the applicable requirement is necessary.

NRC Form 366A (6-89)

NRC FCr3 366A :U.S. NUCLEAR REGULATORY COMMISSION APPROVED OMS NO.3150-0104: 1 L ( 6-89 ) '

• EXPIRES 4/30/92-ESTIMATED BURDEN PER RESPONSE'TO COMPLY-i . -WITH THIS~INFORMATION COLLECTION' REQUEST:. j l

.. ,'. - 150.0 HRS. FORWARD' COMMENTS REGARDING:

< BURDEN ESTIMATE.TO THE RECORDS AND REPORTS i

• LICENSEE EVENT REPORT _(LER)

TEXT CONTINUATION _ gMANAGEMENT BRANCH (P-530), U.S. NUCLEAR-REGULATORY COMMISSION, WASHINGTON,-DC 20565, AND-TO-THE. PAPERWORK ~ REDUCTION:

PROJECT (3160-0104), OFFICE OF MANAGEMENT u

AND BUDGET, WASHINGTON, DC 20603. .;

L" UTILITY NAME.(?) DOCKET NO.-(8). _

LER NUMBER =(*) PAGE (*)- J L YEAR SEO. # REV# q 9l0 0l0

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VERMONT YANKEE NUCLEAR POWER STATION 0l Sl 0l'0l Ol 2l 7l 1 -

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0l'3 0F 0l3 TEXT (If mo.e space is required,:use additional.NRC-Form 366A) (iT)

ANALYSIS OF EVENT-thy 1ack of:the flow transmitters to be calibrated within.the time frame provided:in- E!

Technical Specifications:(TS) posed no adverse. safety consequences.x The flow' transmitters

were promptly calibrated upon discovery of this_ event and the as-found loop-. accuracies were .

L: : all .within' tolerance. The flow transmitters provide indication onlyLand do not_ perform a-

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control or protective function.:

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' CORRECTIVE ACTIONS .l l- , .

Li Immediate:  ;

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Following identification of this event,-the TS. flow monitoring, loops were calibrated. -

--Sub equent:-

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'1. The responsibility to update the MSL has been recentlylstressed-to,the personnel- J

-involved in the surveillance _ testing process.

i 2.- All remaining equipment controlled.by the RETS section of_the TS is being reviewed to j]

define specific instrument. numbers.

3. Based.upon the results of Corrective Action #2, changes.to the_ Master Surveillance List (MSL) and any affected procedures will beimade. .i

4. Consideration will be given to include specific ~ equipment identifications in a future proposed.TS Change. q

.?

Due to previously identified weaknesses in this area,.the: program for implementation of TS,

-.chinges now requires the Technica1' Services Superintendent:to verify that plant documen- j

'tation is revised to= reflect the2 change prior to issuance. This requirement was not in'

-place at the' time of TS Amendment #83' issuance. ]':

1 ADDITIONAL INFORMATION

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(. No occurrences have-been reported te the Commission in the last five years that involved a i ciesed surveillance relative to the status of the MSL. However, LER 87-04, LER 89-20 and LER-89-24 were similar in that personnel error was involved in missed surveillance activi-D t ins . ' 4 a

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NRC Form 366Ac(6-89)

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