ML19327A888

LER 89-024-00:on 890913,noted That Requirement from Previous Inservice Test Program Rev 9 Re Leak Testing of Valve V10-18 Not Incorporated & Implemented.Caused by Incomplete Review & Omission.Procedure Changes implemented.W/891013 Ltr

ML19327A888
Person / Time
Site:	Vermont Yankee
Issue date:	10/13/1989
From:	Pelletier J, Wanczyk R VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-024, LER-89-24, VYV-89-196, NUDOCS 8910180368
Download: ML19327A888 (4)

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) ERMONT YANKEE NUCLEAR POWER CORPORATID  : ,

K P. O. BOX 157 ['1 ,

GOVERNOR llUNT ROAD -

F. ' VERNON. VERMONT 05354'. .'

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October 13, 1989 '

VYV 89-196 Y

-U.S. Nuclear Regulatory Commission-flt!

,- Document Control. Desk-E . Washington,.D.C. 20555

REFERENCE:

Ooerating_ License DPR-28 i

' Docket No. 50-271 Reportable Occurrence No. LER 89-24 ,

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Dear Sirs:

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                              .'As defined by'10CFR50.73, we are reporting the attached Reportable Occurrence as LER'89-24.

Very=truly yours, VERMONT YANKEE NUCLEAR POE R CORPORATION  : 48 / Robert J. W nczyk Acting Plant Manager

                   .cc _Regionel Administrator USNRC Region I 475 Allendale Road' King of Prussia, PA 19406 l

{0Y 891'0180368'891013

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i PDR ADOCK 05000271 S PDC

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P" , NRC-F;r3 384 U.S. NUCLEAR REGULATORY COMMISSION (9-83) : APPROVED OMS NO.3150-0IO4 LLICENSEE EVENT REPORT (LER)- EXPIRES 8/31/96  : FACILITY NAME (8) DOCKET NO. e) PAGE (8) ~ VERMON1 YANKEE NUCLEAR POWER STATION O l 5 l 010 l(0 l 2 l 70ll 1 1 10F l 0 l 3 TITLE (*) MISSE0 RESIDUAL HEAT REMOVAL SYSTEM VALVE LEAKAGE SURVEILLANCE DUE TO INCOMPLETE PROCEDURE REVIEW. EVENT DATE (8) LER NUMBER (*) REPORT DATE (?) OTMER FACILITIES INVOLVED (*) MONTH DAY YEAR YEAR SEQ. # REV# MONTH DAY YEAR FACILITY NAMES DOCKET NO.(S) NA d 5 0 0 0 0l9 1l3 8l'9 8l9 - 0l2l4 - 0l0 1l0 1l3 8l9 NA 0 5 0 0 0 OPERATING. THIS REPORT IS SUBMITTED PURSUANT TO RE0'MTS OF 10CFR 6: ( ONE OR MORE () 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 ($8) Il 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 ( e) NAME TELEPHONE NO. AREA CODE JAMES P.'PELLETIER, PLANT MANAGER dd2 ddd4 d d il 1 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT ('8) CAUSE SYST COMPNT MFR REPORTABLE ..... CAUSE SYST COMPNT MFR REPORTABLE ...... TO NPRDS ..... TO NPRDS ...... NA l l ll ll l .... NA l lll lll l..... NA l ll l lll .... NA l lll lll ...... SUPPLEMENTAL REPORT EXPECTED ('*) EXPECTED M0 DA YR SUBMISSION lYES (If ves, complete EXPECTED SUBMISSION DATE) X l NO DATE ('*) l  ! l ABSTRACT (Limit to 1400 spaces, i.e., approx. fifteen single-space typewritten lines) ( *) In order to implement the recently developed Re.ision 10 of the Vermont Yankee Inservice 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 icplemented. 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. A review of the Primary Containment penetration corresponding to valve V10-18 was per-formed. It is concluded that the integrity of this penetration is assured via closure of downstream RHR valve V10-17 and continuous penetration pressure monitoring. The requirement for leak testing valve V10-18 will be incorporated into the correspon-ding implementing procedure prior to the next refueling outage. To preclude recurrence of a similar event, future changes to implementing procedures involving IST Program testing will b3 routed to the IST Program Coordinator for a complete review. 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)

A .= (; 4 R0: o.2  ;. < q 16tC Farm 3C4AL -U.S. NUCLEAR REGULATORY COMMISSION -I l(9783,); '. . APPROVED OMS NO.3150-0104 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION- EXPIRES 8-31-96

                                                                                                                      'I UTILITY NAME (5).                                 DOCKET NO. ( e )-           LER NUMBER (*)         PAGE (8)

YEAR SEQ. # REV# VERMfJT' YANKEE NUCLEAR POWER STATION d d d d Ol d d 1 8l9 - 0l2l4 - 0l0 d2 0F d3 TEXT:(If more space is required, ute additional NRC Form 384A) (17) DESCRIPTION OF EVENT ,

                   'In order to_ implement _the recently developed Revision 10 of the Vermont Yankee
       .Inzervice 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 spproved 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

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tOcting had not been performed during the 1989 refueling outage because~it had not been cdded to the RHR system surveillance procedure. CAUSE OF EVENT

                  .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-                      .

c0dures. During revision of the RHR system implementing procedure, the subject valve leak tcat was omitted. The Operations department developed the procedure revision and provided for its internal review. Although not specifically required, the IST Program coordinator cas.then requested to provide additional review. The IST Program coordinator provided a , u . cursory review of this and all other procedures necessary to implement Revision 9 of the  ! L -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

       -wis.not included in the scope of the review. This, coupled with the initial omission of the 1stk' test during procedure development, is determined to be the root cause of this event.

l' . ANALYSIS OF EVENT L The subject valve, V10-18, is the inboard valve of the Primary Containment Isolation L -Valve pair'for the RHR Shutdown Cooling Suction line penetration. Valve V10-18 and l V10-17, the outboard valve at this penetration, have the additional function of providing a . l Lpiping pressure specification separation. These valves separate Heactor Coolant Pressure l from RHR System piping. Although these valves act as Pressure Isolation Valves (PIV's), they have no specific requirement for leak testing in Tech. Spec. Section 3.7.D concerning Primary Containment. Continuous pressure monitoring of this penetration is protided downstream of outboard valve V10-17 for leakage detection. i l

     .NRC Form 384A
      -(9-83)

O

e. .

 ;NRC.Fcra 384A                                                    U.S. NUCLEAR REGULATORY COMMISSION (9-03).                                                              APPROVED OMS NO.3150-0104 LICENSEE EVENT REPORT (LER) TEXT CONTINUATION       EXPIRES 8-31-96 UTILITY NAME (')                             DOCKET NO. (*)         LER NUMBER (5)          -PAGE (*)

YEAR SEQ. # REV# VERMONT YANKEE NUCLEAR POWER STATION ddddddd1 8l9 - 0l2l4 - 0l0 d3 OF d3 TEXT (If more space is required, use additional NRC Form 384A) (57) During development of Revision 9 of the IST. Program, Vermont Yankee committed to leak tsst valve V10-18 during.each refueling outage to determine any gross leakage. Corrective action would then be taken per ASME Section XI requirements.. Since ASME Section XI_ testing 13 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. In addition, it should be noted that although the recently self imposed IST Program laak test requirement was not performed, valve stroke time testing was accomplished. Review aof 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. 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 monitoring. 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 The requirement for leak testing V10-18 will be incorporated into the corresponding implementing procedure prior to the next refueling outage. A review is in progress to snsure all other IST Program implementing procedures adequately address all testing required by the program. This review will be completed by the beginning of November, 1989. In addi-tion, this event has been reviewed with the affected personnel responsible for procedure d:velopment and review. To further preclude recurrence of a similar event, future changes to implementing pro- '

  .csdures involving IST Program revisions will be routed to the IST Program Coordinator for a complete review.

ADDITIONAL INFORMATION Previous similar events have been reported to the Commission, in the last five years, as LER 87-04 and LER 89-20. NRC Form 384A (9-83)}}