ML20133G547
| ML20133G547 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/26/1985 |
| From: | Bettenhausen L, Jerrica Johnson, Oliveira W, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20133G525 | List: |
| References | |
| 50-271-85-22, GL-83-28, NUDOCS 8508080738 | |
| Download: ML20133G547 (17) | |
See also: IR 05000271/1985022
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-271/85-22
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Docket-No' . 50-271
License No. DPR-28
. Licensee: Vermont Yankee Nuclear Power Corporation
RD 5, Box 169
Ferry Road, Brattleboro, Vermont 05301 .
Facility Name: Vermont Yankee Nuclear Power Station
Inspection At: Brattleboro, Vermont and Framingham, Massachusetts
Inspection Conducted: June 3-12, 1985
Inspectors: b N YLY N
J. 'dohnson, ' Senior Resident Inspector - Date
Pilgrim
f$ <<,'
W. Oliveiraf Reactor Engineer
fW
' Date
q b
C. Woodard, Reactor Engineer
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Date
Approved by: A A
E Bettenhausen (Dr.) Chief, Operations Date
Branch, Division of Reactor Safety
Inspection Summary:
Announced inspection conducted June 3-12, 1985 (Inspection No. 50-271/85-22)
Areas Inspected: Licensee's actions to address the concerns identified in NRC
Generic Letter 83-28 in the areas of Equipment Classification, Vendor
Interfaces and Post Maintenance Testing.
The inspection involved 165 inspector hours by two region-based inspectors and one
resident inspector.
Results: One vio'ation was -identified (failure to properly control the
installation of replacement parts in instrumentation classified as safety
related, paragraph 2.2.5). One unresolved item was identified - the imple-
mentation of an overall vendor interface. program (paragraph 2.3.4).
8508080738 850726
PDR ADOCK 05000271
G PDR 1
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DETAILS
1. Persons Contacted
D. Bauer, Assessment Engineer
F. Burger, Quality Assurance (QA) Coordinator
P. Caruso, Operations Quality Control Group (0QG) Inspector, YAEC
- J. Desilets, Operations Department Supervisor
- P. Donnelly, Technical Services Superintendent (Acting)
D. Dyer, 0QG Engineer, YAEC
W. Finnell, Assistant Maintenance Foreman
J. Humphries, Mechanical Engineer
R. Lopriore, Maintenance Supervisor
G. Gilmore, Storekeeper
J. Golanka, Maintenance Technician
H. Heilman, Instrumentation Engineer
D. McElwee, Equipment Qualification (EQ) Coordinator
M. Metill, Engineering Support Department Supervisor (Acting)
R. Milligan, Administrative Supervisor
S. Miller, VY Engineering Project Manager, YAEC
S. Jefferson, Assistant to Plant Manager
A. Parker, Quality Audit and Engineering Engineer, YAEC
- J. Pelletier, Plant Manager
C. Porrevecchio, QA Technician
D. Phillips, Senior Electrical Engineer
- D. Pike, 0QG Supervisor, YAEC
- D. Reid, Operations Superintendent
R. Selby, Assistant Instrument and Control (I&C) Foreman '
D. Taylor, Assistant Electrical Foreman
T. Trask, Plant Inservice Test Coordinator
D. Yasi, Lead Systems Engineer, YAEC
United States Nuclear Regulatory Commission
- G. Meyer, Project Engineer
W. Raymond, Senior Resident Engineer
- Indicates those who attended the exit meeting on June 11, 1985.
The inspectors also interviewed other site and corporate personnel during
the inspection.
2. Follow-up on NRC Generic Letter 83-28, " Generic Implications of Salem
ATWS Events"
2.1 Background
The reactor trip system, a subsystem of the reactor protection system, is
fundamental to the safety of all nuclear power reactors. Analyses to
support and justify the fuel designs assume that the reactor trip system
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is available and will automatically initiate the reactivity control
system on demand. The design and regulatory philosophies for assuring
high reliability for the reactor trip system are based primarily on
system redundancy, periodic testing and quality assurance.
In February,1983, the Salem Nuclear Generating Station experienced two
failures of the reactor trip system to function on demand. Regulatory
and industry task forces were established to review and determine the
safety significance and generic implications of these events. Based on
the findings of these task forces, the NRC issued Generic Letter 83-28 to
require specific actions for all licensees to review and improve post
trip review, equipment classification and vendor interface,
post-maintenance testing and reactor trip system reliability.
The licensee provided responses to the above Generic Letter in letters
dated September 2, 1983, November 7, 1983, March 23, 1984, June 26, 1984,
September 25, 1984 and October 5, 1984. This inspection included a
review and assessment of the effectiveness of the licensee's actions in
response to Generic Letter 83-28 as detailed below:
2.2 Equipment Classification
2.2.1 References / Requirements
J 1. NRC Generic Letter 83-28, " Generic Implications of Salem
ATWS Events"
2. Vermont Yankee (VY) Nuclear Power Corporation response letters
to reference 1 above dated November 7, 1983, March 23, 1984,
and October 5, 1984.
3. Yankee Atomic Electric Company Operational Quality Assurance
Manual (YOQAP-1-A), dated February 15, 1985.
2.2.2 Program Documents and Activities Reviewed
- Appendix C, YOQAP-1-A, Classification of Structures, Components
and Systems, February 15, 1984
- YAEC Guideline No.1, Policy for Material Purchases, Design
Changes, Repairs and Alterations, Bids, Nonconformance Reports,
QA Records, July 10, 1977.
- YAEC Memorandum OPVY 333/85, Salem ATWS - Proposed Action
Plan, dated May 16, 1985.
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Memorandum, EEVY 6/77, Classification of Electric Equipment
dated April 15, 1977.
- Memoranda, 1.18.3, Safety Classification of Electrical
Equipment, dated April 19, 1978.
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Memorandum VYB 85/83, NSD Recommendation - Changes to Safety
and Seismic Classifications, dated February 1,1985.
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Piping flow diagrams and electrical distribution one-line
diagrams.
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Safety related (Class IE) instrument list dated November 15,
1984 as revised up to change No. 4 dated June 2, 1985.
Fifty-nine -(59) Maintenance. Requests (MRs), with classifications
both safety related and non-safety related, initiated between
January and March, 1985; and seven (7) MRs with safety related
classification completed in May 1985.
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. Engineering Design Change Request No. 79-02, Section 15,
Safety Evaluation (Recirculation Pump Trip and Alternate Rod
Insertion equipment installation).
- YAEC personnel indoctrination certification forms WE-003-1,
for two staff engineers.
- Station procedures regarding document control, maintenance,
equipment purchasing and issuance.
- Procurement documents for nine (9) maintenance requests
implemented between January and May, 1985, designated
safety related, and which had materials or components
replaced.
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Purchase order 6860, supplement 1, dated January 8, 1983, to
the Mobil Oil Corporation for lubricating greases and oils.
The VYNPS program for equipment classification, described by
references in section 2.3.1, was reviewed to determine:
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The criteria and source documents which form the bases for
classifying . systems, structures, and components
- The assignment of responsibility for reviewing and updating the
classification of items 1
- The distribution, control, and use of documents / lists
describing the safety (or quality) classification, and
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The level of training and knowledge of personnel in different
functional areas who perform classification activities.
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2.3.3 Program Implementation
As stated in the licensee's letters dated November 7, 1983, March
23, 1984 and October 5,-1984, the licensee's equipment
classification system consists of three basic types of documents:
1) Appendix C to the QA Manual (Y0QAP-1-A) classifies structures,
systems, and major components (piping, valves, pumps, turbines,
4160v buses, 480v MCCs), 2) controlled piping flow drawings and
electrical one-line distribution drawings are provided with safety
classification boundary (flag system) designations, and 3) a
controlled document, the safety related (Class IE) Instrument List
of individual. switches, relays, etc. that have been designed as
safety related.
These documents have been prepared using the guidance provided in
ANS-22, Draft No. 4, Revision 1, May 1973, " Nuclear Safety Criteria
for the Design of Stationary Boiling Water Reactor Plants". If it
is desired to classify an item which is not specifically listed then
an engineering evaluation or judgement is made based upon the
criteria and documents above as well as the function or purpose
described in the FSAR.
In light of the Salem ATWS Events and in response to the NRC Generic
Letter 83-28, the licensee's engineering staff at Yankee Atomic
Electric Co. performed a review of programs in place to assure that
all components necessary for accomplishing safety-related functions
are properly identified in documents used to control activities.
The results of this review are documented in YAEC memorandum VYS
107/84 dated September 5, 1984, " Recommendations for Improvements to
VY Equipment Classification System in Respense to Generic Letter 83-28." The licensee determined that improvements were needed in
the following areas: 1) a formal procedure should be written to
provide guidelines for making a determination of ccmponent safety
classification, 2) a single list of all safety related components
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should be created, 3) all component classifications would be
determined using the new procedure and, 4) a new set of
administrative controls would be established for the MEL.
The Vice President and Manager of Operations of VYNPC endorsed these
recommendations for an Equipment Classification Enhancement Program
and in a letter to the NRC dated October 5, 1984 (FVY 84-120)
described these plans and stated that existing Plant-Specific Lists
would remain in place under existing controls until the MEL is
developed and approved with an estimated completion date of
December, 1986.
The inspector reviewed the implementation of the licensee's existing
system as well as plans and progress being made with the Enhancement
Program.
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The inspector selected components and systems and reviewed how the
. licensee treated them. Items selected included Emergency Diesel
Generators including fuel oil, lubricating oil, and cooling water
systems, RHR and Core Spray quadrant room area coolers, HPCI steam
line drain level controller components, containment atmosphere
gaseous radiation monitoring equipment, and reactor vessel water
level and pressure transmitters used in the Recirculation Pump Trip
- and Alternate-Rod Insertion (ATWS protection) systems.
This review included a plant tour, visual observation of selected
equipment and discussions with licensee personnel. A comprehensive
sampling of maintenance request activities was reviewed because of
1) the results of NUREG-1000, Generic Implications of ATWS Events at'
the Salem Nuclear Power Plant, April 1983, 2) the large number of
these activities which require decisions regarding equipment
classification. This also included procurement activities for those
maintenance requests involving replacement of parts.
Because of the lack of a " master list", and a concise procedure
regarding classification, the inspector reviewed case-by-case
evaluations performed by the licensee's engineering and management
personnel to determine the criteria used and thoroughness.
The inspector interviewed personnel responsible for implementing the
Enhancement Program, and reviewed progress to date as described in
YAEC memorandum VYS 63/85, " Salem ATWS - Proposed Action Plan",
dated May 15, 1985. A Salem ATWS Project Team has been established
(with lead responsibility assigned to a YAEC Systems Engineer on the
VY project) and a meeting was held on March 6, 1985 to discuss the
development of the Master Equipment List (MEL) including format and
field of data for computerization. A schedule has been developed
with milestones including a pilot program of listing and classifying
RPS components first. To date the only concrete product the
licensee presented to the inspector was the Action Plan dated May
15, 1985.
2.2.4 QA/QC Involvement in Equipment Classification
The licensee's quality assurance organization performed an audit
(no. VY 85-11) in March, 1985 of the inspection and test program at
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the site. This audit identified that the inspection program for
maintenance activities was inadequate and confusing. The plant
manager established a task force to evaluate repair department peer
inspections, QC inspections and make recommendations for
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improvements. The inspector reviewed the activities in progress and
ascertained that the licensee's actions in this area should result in
improved review of safety related maintenance.
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Also, during discussions with the YAEC QA&E Engineer, the' licensee
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representative stated that no specific problems were identified
during a special audit in February-March,1985 (No. SVY 85-101) '
_ performed at the plants request regarding training on system
classification and QA/QC policies. '
The'on-site Operations Quality Group initiated a'Non-Conformance
Report (NCR) No. 85-03 because of failure of the repair departments
(I&C Maintenance) to notify 0QG prior to work on safety related
components as required by the MR procedure (AP 0021, Rev. 12). The
inspector discussed the present status with two 0QG inspectors,
reviewed ~ completed MR's, and a status report log maintained by 0QG.
2.2.5 Findings
One violation was identified. Other areas needing improvement
were noted, and for which the licensee is taking action,
1 In two Maintenance Requests (MR's) designated as safety-related,
material that was procured in a non-safety class manner was
installed in equipment designated by the licensee as safety class ,
~(IE). instrumentation. Information regarding these items is '
described below:
Material Procurement
M.R. Material Replaced Issue No. Document
85-256 Core spray test switch 02A0042 17325, 2V10683
14AS148 and contacts
I&J of test connection
14AJ18.85-986 MSIV AC power relay, 05A0137 15641
16AK16, coil
The procurement methods (quality treatment,' reviews, approvals,
traceability, certificates of conformance, receipt inspection and
testing etc.) and identification (tag) were for non-safety class
applications.
Purchase Order 17325 was a September 30, 1981 non safety-class order
for post accident sampling system instrumentation. P.O. 2V106(83)
was a material returned slip regarding turn back in to stores on
February 14, 1983 of two switches for which no original purchase
order nor safety class documentation was provided as required by AP
0806. Purchase Order 15641 was a November, 1980 non safety-related
purchase of " spare parts (coils for CR120 industrial relays) for
various systems."
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The inspector reviewed the plant equipment involved with these two
repairs in order to independently assess the function performed.
Discussions were held with the licensee's I&C supervisor and a
review of equipment technical manuals, parts lists, and controlled
wiring diagrams was made. The inspector determined that the correct
type (model number) of parts had been installed. The core spray
switch (14AS148) is in a test circuit and during normal operation
performs no safety function. During surveillance testing it can
either prevent the emergency diesels from starting or allow the
diesels to start depending on licensee procedures. The MSIV AC
power relay (16AK16) is used during normal operation for a " holding
function" to keep the AC pilot solenoids energized on each of the
four outboard MSIVs. If an isolation signal is generated, 16AK16
de-energizes and subsequently de-energizes all 4 AC pilot solenoids.
This coil in this relay was replaced with MR 85-986 because it had
failed (open circuit) in the safe direction. On the basis of this
assessment, the safety significance of these components is minimal.
The licensee initiated immediate action to review these two items.
A nonconformance report was issued in order to evaluate and
disposition the MSIV coil replacement. The licensee had not
completed an evaluation of the core spray switch replacement by the
end of this inspection.
The failure to properly control two components (14AS14B and a coil
for 16AK16) to prevent use of incorrect material in locations
designated as safety related is a violation (85-22-01).
2. During this review the inspector noted some confusion among
licensee personnel in the potential treatment of certain components
such as the following: 1) diesel generator lubricating oil and
cooling water systems, and 2) core spray /RHR area room coolers
(RRUs). For example, the licensee stated that equipment in the
Environmental Qualification program would be treated as
safety-related although the RRU fan motors are in the non-safety
class section of the electrical one-line drawings.
The inspector determined that, in general, licensee personnel of all
disciplines were using the three documents described in section
2.2.1 for classification decisions. When a question came up, the
1_icensee personnel evaluated the safety function and consulted the
VYNPS FSAR. The licensee has recognized the need for improvements
in this area and has initiated actions to generate a formal
procedure for classifying components, and to establish one Master
Equipment List by the end of 1986.
At the exit meeting the Itcensee stated that additional review of
these areas would be performed to alleviate any confusion regarding
these systems. In addition, the licensee stated that a certain set
of vendor flow drawings (5920 series) would be reviewed for
consistency with the safety-class flag designation provided on other
flow drawings.
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f The inspector had no further questions and noted that these
additional actions should strengthen the licensee's system while
implementing the Enhancement Program.
2.3 Vendor Interface
2.3.1 Requirements / References
1. Generic Letter 83-28, " Generic Implications of Salem ATWS
Events"
2. Vermont Yankee letter dated November 7, 1983 from Warren P.
Murphy to Domenic Vassallo (NRC), " Response to Generic Letter 83-28".
3. Vermont Yankee letter dated March 23, 1984 from Warren P.
Murphy to Domenic Vassallo (NRC), " Response to Generic Letter 83-28".
4. Final draft of the Nuclear Utility Task Action Committee
(NUTAC) report " Vendor Equipment Technical Information
Program," February 1984.
5. Regulatory Guide 1.38, " Quality Assurance Requirement for
Packaging, Shipping, Receiving, Storage and Handling of Items
for Nuclear Power Plants," which endorses ANSI N1817-1976.
6. Vermont Yankee letter dated June 26, 1984 from Warren P. Murphy
to Domenic Vassallo (NRC) " Response to Generic Letter 83-28,
Section 2.2.2".
7. NRC letter dated April 24, 1985 from Domenic Vassallo to
Robert Capstick (Vermont Yankee), " Request for Additional
Information Following Preliminary Staff Review of Licensee
Responses to Generic Letter 83-28.
8. Vermont Yankee Administrative Control Procedure AP 0831,
Revision 10 " Plant Procedures".
9. Vermont Yankee Administrative Control Procedure AP 0200,
Revision 10 " Maintenance Program".
10. Vermont Yankee Administrative Control Procedure AP 0310,
Revision 0, " Safety-Related Instrumentation and Components
Preventive and/or Corrective Maintenance".
11. Vermont Yankee Administrative Control Procedure AP 0028,
Revision 3, " Operating Experience Review and
Assessment /Committment Tracking"
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, 12. Vermont Yankee Quality Assurance Manual YOQAP-I-A,
Revision 15, " Operational Quality Assurance Program".
2.3.2 Program Review
The vendor interface program described in the references listed in
Section 2.3.1 has been reviewed to determine if Vermont Yankee has:
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a continuing program to assure that vendor information is
complete, current and controlled.
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incorporated this vendor information into the documentation for
procurement, receipt, inspection, tests, storage and preventive
maintenance of safety-related systems and equipment.
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established means to develop procurement, inspection, tests and
qualification of replacement safety-related items when the
exact replacement is no longer available (vendor out of
business or product manufacture discontinued).
2.3.3. Program Implementation
To evaluate the effectiveness of the implementation of the licensee
venaar interface program, several safety-related components and a
major safety system of equipment were randomly selected and their
, documentation reviewed. Components and systems included:
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Barksdale pressure switches, differential pressure switches and
bourdon tubes as described in General Electric Technical Manual
GEK-27800 (latest revision February 20,1985)
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Gems Leak Seals as described in Gems Detector Technical Manual for
part number 12156 (latest revision February 20,1985).
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ITT Barton Transmitters Models 295 and 296 as described by Barton
Technical Manual (latest revision May 8, 1985).
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Fairbanks Morse Emergency Diesel Generator sets as described in
Fairbanks Morse Technical Manual (latest revision March 22,1985).
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Limitorque Type SMB Valve operators as described in Limitorque
Instruction and Maintenance Manual SMB 1-828 (latest revision
May 21, 1984).
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General Electric Low Voltage Power Circuit Breakers, Types
AK-50/75/100, AKT-50, AKV-50 and AKF-2C/2D/2E as described by GE
Technical Manual GEK-7303C (latest revision April 23,1984).
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General Electric Power Circuit Breaker, Renewal Parts for AK-2-50
Breakers, GE Technical Manual GEF-4150F (latest revision
March 2, 1984).
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-General Electric Power Circuit Breaker,-Types AK-2/2A-75, AK-3/3A-75,
AK-4/4A-75 and AK-5/5A-75,.GE Technical Manual GEF-4151 (latest
revision April 23,1984).
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General Electric Power Circuit Breaker, GE Technical Manual
GEF-4395B (issued April 23, 1984 and supersedes in part GEF-4151).
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Victoreen letter of April 26, 1985 advising that Photo-multiplier
tube manufacturer (SRC) for Victoreen radiation monitoring
instruments went out of business. (Victoreen qualified a new
supplier (EMI) and enclosed appropriate data sheets and
specifications for the replacement tube).
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-Fairbanks Morse letter of March 22, 1985 advising that the engine
jacket water pressure switch manufacturer, United Electric, could no
longer supply the qualified pressure switch. (Fairbanks Morse
selected and specified a qualified alternate switch (United Electric
J54A to replace the J17A).
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Selected safety related components that are in the Licensee Vendor
Equipment Technical Information Program (VETIP) computer data file
were reviewed for source information, description of information, and
licensee action scheduled or taken. The VETIP file draws from~the
Nuclear Utility Task Action Committee (NUTAC) VETIP program. The
NUTAC VETIP Jata is obtained from many sources including the INPO
nuclear licensee members, NRC generic and Part 21 letters, NRC
resident inspectors daily reports, NRC bulletins, notices and vendor
inputs. There are currently approximately 900 data entries in the
Vermont Yankee data file of which there are approximately 200
outstanding which require internal response within Vermont Yankee.
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Evaluation of rear mounted springs on Westinghouse 08-50 circuit
breakers'--- completed August 20, 1984.
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Evaluation of Louis Allis Part 21 Notification of Emergency Diesel
Generator amortisseur strap breakage problem - opened June 3;
action due date July 4, 1985.
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Evaluation of Automatic Sprinkler Model C deluge valves - opened
January 15, 1985; completed January 24, 1985.
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Evaluation of recommendations for Rand RWCU Pump Impeller retention
. problems -- due date April 15, 1985; completed February 17, 1985.
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Evaluation of safety letter regarding sampling oil from energized
transformers -- due date March 1, 1985; completed March 8, 1985.
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Evaluation of Fairbanks Morse revised procedure revisions for Emergency
Diesel Generator sets -- due date March 1, 1984; completed
March 20, 1984.
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Evaluation of Fairbanks Morse letter relative to closed water cooling
system -- due date September 21, 1984;_ completed October 15, 1984.
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Evaluation of SER regarding undetected valve stem failure at TVA ---
due date October 1, 1984; completed September 17, 1984.
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Review SER concerning water hammer in main steam and feedwater
systems -- due date June 20, 1985; completed June 3, 1985.
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Evaluation of information notice concerning defective ITE/Siemens - Allis
circuit breakers -- due date August 1, 1985.
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The licensee had received a Part 21 Notice from the vendor of the
Emergency Diesel Generator Systems, Fairbanks Morse. The Part 21
Notice was based upon a failure of an inter polar connector bar
. (amortisseur winding) on one of the Calvert Cliffs generators on
May 15, 1985. NRC Region I management was notified by the vendor of
the failure by telephone on May 17 and by official Part 21 letter on
May 21. Vermont Yankee management was notified by the vendor by
telephone on May 29, 1985.
The licensee was also notifed by the NRC resident inspector during
this same time frame.
The inspector found that on June 4 the licensee had already inspected
the generators and had confirmed that the Vermont Yankee generators
are equipped with the inter polar connector bar. The licensee had
also discussed the nature of the problem with both the vendor and
with Calvert Cliffs.
The licensee made a decision on June 11 that they would remove the
potentially troublesome inter polar connector bar in accordance with
vendor recommendations and with vendor representative direction during
the removal. A target date for completion of the removal was set at
July 4, 1985 prior to the next scheduled running of the generators.
Accomplishment within this time frame was based upon being able to
secure the services of the vendor representative on site during this
time.
2.3.4 Findings
No violations were identified.
There was one concern identified during this inspection. The
licensee has not implemented a system to assure that vendor
information is current and complete. Vendor information received or
obtained appears to be based upon safety related item failure
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either at the licensee's plant or others and does not include vendor
interface for improvements, changes in maintenance / preventive
maintenance, service, etc. There is no program for establishing and
maintaining an on going relationship with safety related parts,
equipment, and systems vendors in order to assure current and
complete vendor information for the purposes of preventive
maintenance, upgrading, replacement,and alerting to possible
problems because of historical failures incurred by other users.
This is an Unresolved Item 85-22-02.
2.4.0 Post-Maintenance Testing
2.4.1 Requirements / References
1. 10 CFR, Appendix B
2. YOQAP-1-A, Operations Quality Assurance Manual, Revision 15
3. AP 0020 Temporary Electrical Jumpers, Lifted Leads, and
Mechanical Bypass, Revision 8.
4. AP 0021 Maintenance Requests, Revision 12
5. AP 0025 Plant Equipment Control, Revision 4
6. AP 0200 Maintenance Program, Revision 10
7. AP 0834 Plant Record Retention, Revision 12
8. AP 0310 Safety-Related Instrumentation and Components
Preventive and/or Corrective Maintenance, Revision 0
9. AP 6001 Installation, Test and Special Test Procedures,
Revision 9
10. AP 6010 In-Plant Audits, Revision 9
11. OP 4610 Filter Testing, Revision 11
12. OP 5223 Emergency Diesel Generator Maintenance, Revision 5
13. OP 5305 Solenoid Valve Maintenance, Revision 5
14. Exide Technical Manual Section 58.00
15. General Electric Service Manual GEK-9582 Hydraulic
Control Unit; Installation, Operation and Maintenance
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2.4.2 Program Review
The references in 2.4.1 were reviewed to determine that Vermont
Yankee (VY) is implementing a post maintenance testing program. AP
0021 for maintenance test activities and AP 6001 for new installa-
tions and modification are the key procedures for initiating
post-maintenance testing. They also provide the criteria and re-
sponsibilities for: review and approval of post-maintenance activ-
ities; the bases for designating the activity as safety /nonsafety
related; and for performing tests. Methods for performing functional
testing are designated in the applicable APs and ops as well as those
in reference 2.4.1. AP 0834 assures that post-maintenance testing
records are prepared, assembled and reviewed for transfer to storage.
2.4.3 Program Implementation
Implementation of the licensee's post-maintenance testing program
was assessed by:
1. Selecting and reviewing the test data for the following 1985
safety-related corrective maintenance requests (MRs):
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MR 85-0019, 0210, 0211, 0213, 0246, 0256, 2057, 0266,
0280, 0290, 0293, 0330, 0377, 0389, 0411, 0426, 0429,
0845, 0995, 1001, 1024, 1988
2. Having the Plant Inservice Test Coordinator discuss his
evaluation of MR 85-0845 Service Water Pump Seal test results.
The evaluation was a ASME Section XI requirement.
3. Witnessing the new bearing temperature checks of the B
Condensate Transfer Pump P-4-18. The old bearings were
replaced in accordance with MR 85-1001 and the results i.e.
alignment checks,.were discussed with the mechanic and later
, with the supervisor. Ti.e mechanic and his supervisor
were knowledgeable of the acceptance criteria.
4. Reviewing MR-85-0377 which required repair kit changes to the
scram solenoid valve for control rod 06-31 in accordance with
OP 5305. The Assistant Instrument and Control (I&C) Foreman
walked through the tes.ing requirements of this specific OP
which required I&C to check for air leaks while Operations was
conducting operability tests.
5. The testing requirement > for the scram pilot valve which were
taken from a General Electric Service Manual GEK-9582. This
manual was maintained current by the I&C Department (See Vendor
Interface Section 2.3).
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6. Discussing with the Electric Foreman the replacement of the 172
battery cell which was performed to the current Exide Manual
Section 58 as required by MR-85-0429. Operations Quality Group
(0QG) witnessed the tests.
7. Discussing with the Maintenance Supervisor MR-85-0257 which was
a major non safety related task to rebuild or replace the motor
bearings on the "A" Feed Pump. The supplemental pages to the
MR contained inspection hold points and additional testing re-
quirements which were witnessed and initiated by the foreman
and senior engineer. The requirements and witnessing are re-
served for safety-related equipment / systems.
8. Reviewing Schedule Maintenance Tests, e.g. A.2 Fuel Oil System
tests for "all injection nozzles and adjustment," were reported
in accordance with OP 5223.
9. F.! viewing the Plant Design Change Request (PDCR) 84-01 with the
Plant Cognizant Engineer and QA Coordinator. The PDCR was pre-
pared in accordance with AP 6001. All test data were signed /ini-
tialed and evaluated (as well as changes to the requirements or
test results). The Plant Cognizant Engineer and QA Coordinator
were knowledgeable of the testing requirements. OQG witnessed
the tests.
2.4.3 .A/QC
Q Interface
The on site OperationssQuality Group (0QG) receives copies of all Main-
tenance Requests (MRs) and is being notified prior to start of any
safety-related work. This was not the case last year. 0QG does not
in all cases witness tests though the percentage of witnessing tests
is increasing. It is the goal of 0QG to witness as much safety-relat-
ed MR work as practicable. OQG reviews design change documentation
and installation and test procedures, and decides whether to witness
inspections and tests.
A special audit (No. VY-83 SPECIAL) of the inservice testing program
for pumps and valves required by ASME Section XI was conducted in
June 1983. The audit was critical of the inservice testing program
as not meeting code requirements, departments not coordinating their
efforts, and a better preventive maintenance program was needed. The
inspector's review of PDCR 84-01 did not indicate that these problems
still existed.
The Inspection and Test audit (No.VY-85-11) conducted in March 1985,
though it did not address Post Maintenance Testing specifically, had
prompted the Plant Manager to establish a task force to review compli-
ance to the QA program described in the YOQAP Manual. One area of
special interest was peer inspection which was addressed by the task
force report submitted on June 7, 1985 to the Plant Manager.
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2.4.4 Findings
No violations were identified.
3. Licensee Actions on Previous Inspection Findings
(Closed) Violation (83-22-01). Traceability information not entered on
maintenance work orders. The inspector noted improvement in the completion
of required items on the maintenance request forms. Traceability informa-
tion (material issue number) was entered on fourteen (14) MRs where safety
related material was replaced out of sixteen (16) sampled. The other two
had "non-inventoried" parts. Licensee actions regarding training and coun-
seling have been effective in this area. This item is closed.
(0 pen) Follow item (84-12-02). Review licensee's resolution of concerns
(VYB 84/105) regarding safety and seismic classification of the spent fuel
pool cooling system (EDCR 83-32). ECN Number 2 to the design change (EDCR
83-32) was issued to state that the electrical portion of the fuel pool
cooling system was reclassified as safety class to meet the safety objec-
tive. It is not clear whether this is only for environmental qualification
reasons. Licensee memorandum VYB 84/346 dated August 3, 1984 requested
resolution from YAEC of these two areas by November 1, 1984. This had not
been completed by the end of this inspection.
The inspector expressed concern that the licensee should resolve whether
there was a problem with the as-built design with respect to requirements
or commitments. Apparently, delays in resolution of these concerns stemmed
from uncertainties about recommendations for future system upgrades. The
licensee's engineering staff acknowledged the inspector's concern, stated
that a preliminary evaluation indicated no problem with the current system
status and agreed that this item should be resolved in an expeditious man-
ner. Pending a review of the licensee's resolution of fuel pool cooling
system design basis, this item remains open.
(Closed) Unresolved item (84-12-03). Revise safety classification and doc-
ument seismic evaluation of the RHR service water pump motor bearing cool-
ing water lines. The inspector verified that the piping safety classifica-
tion was revised on the service water flow diagram (G-191159 sheet 1, Rev.
23 dated January 9, 1985) and that the seismic evaluation was documented in
memo VYM 224/84 dated August 1, 1984. In addition, YAEC analysis (M.A.G.
Rev. O approved October 11,1984) Section 5 concludes that the service
water system is adequate as built. This item is closed.
(Closed) Unresolved Item (271/84-23-01) Correction action response to in
plant findings exceeding the ninety day due date. Review of the licensee's
Summary of Status of Corrective Action - In-Plant Audits indicate that the
corrective action response dates are within the ninety day due date. This
item is closed.
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!
- (Closed) Violation (271/85-06-01) Followup actions for correcting biennial
! plant procedure review program are inadequate. Review of the licensee's
, corrective action and the status of the biennial plant procedure review
i. program indicate that.the review has vastly improved and is continually
, being monitored and tracked. =;
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!
! 4. Unresolved' Items
l Unresolved items are matters about which more information is required in
l order to ascertain whether they are acceptable items, violations or devia-
l tions. An unresolved item disclosed during the inspection is discussed on
paragraph 2.3.5.
5. Exit Interview
l
The inspector met with licensee management representatives on June 11, 1985
at the site to discuss the findings of the inspection. (See paragraph 1 of
this report for the attendees at the meeting). The licensee representatives
l acknowledged the inspection findings.
.At no time during this inspection was written material provided to the 4
Ifcensee by the inspector.
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