BVY-93-108, Responds to Violations Noted in Insp Rept 50-271/93-14. Corrective Actions:Nonconforming Matls Removed & Independent Insp of Remaining Scaffolding & Temporary Matls within Reactor Bldg Performed

Responds to Violations Noted in Insp Rept 50-271/93-14. Corrective Actions:Nonconforming Matls Removed & Independent Insp of Remaining Scaffolding & Temporary Matls within Reactor Bldg Performed

ML20057D152
Person / Time
Site:	Vermont Yankee
Issue date:	09/27/1993
From:	Pelletier J VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-93-108, GL-82-12, NUDOCS 9310010189
Download: ML20057D152 (4)

Text

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. l VERMONT YANKEE NUCLEAR POWER CORPORATION

.. . $8 Ferry Road, Brattleboro VT 05301-7002 ,,

ENGINEERING OFFICE

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M0 MAIN STREET 90L TON. M A 01740

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@)St 7794711 i

September 27,1993 BVY 93-108 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

(a) License No. DPR-28 (Docket No. 50-271) -

(b) Letter, USNRC to VYNPC, inspection Report 9314, dated ,

8/27/93 '

Subject:

Reply to a Notice of Violation and Controls for Outage Overtime -

Inspection Report 93-14 This letter is written in response to Reference (b), which documents that our activities were not conducted in full compliance with NRC requirements. The violation, classified as a Severity Level IV, was identified during an NRC inspection conducted from June 27 to August 7,1993. Reference (b) also requested that we provide our intended administrative controls for overtime during outages. Our response to both of these items is provided below.

VIOLATION:

Vermont Yankee Technical Specification 6.5 requires that procedures involving safety shall be adhered to. Plant administrative Procedures AP 0020, Revision 15, " Temporary Modifications," and AP 6024, Revision 8,

" Plant Housekeeping," were written pursuant to TechnicalSpecifications -

6.5. Procedure AP 0020 requires,in part, that evaluations of temporary modifications to plant equipment be evaluated. Procedure AP 6024 requires, in part, that good housekeeping practices be maintained. ,

Contrary to the above, during July 22-23,1993, alternate shutdown panel, l CP-82-1, was modified by the addition of a plexiglass panel that prevented operation of equipment controls. No evaluation of this condition was performed. Additionally, on- July 27, 1993, good' housekeeping practices did not exist in the "B" emergency core cooling system corner room of the reactor building in that materials were placed on the residual heat removal pump motor end piping, as well as debris I on the floor near sump pumps.

I These instances constitute a Severity Level IV violation. 01 h

9310010189 930927 PDR ADOCK 05000271 r:j G PDR &

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VERMONT YANKEE NUCLEAR POWER CORPORATIC,N

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United States Nuclear Regulatory Commission September 27,1993 Page 2 l

VIOLATION RESPONSE Based on our review, the improper installation of the plexiglass panel occurred due to the lack of a system oriented review of scaffolding and temporary materials to ensure that operation of plant systems, structures and components were not adversely affected. A contributing cause was an error in communications.

Installation of the plexiglass panel in front of the RCIC Alternate Shutdown Panel, CP-82-1, was controlled under procedure AP 0019, Revision 9, " Control of Temporary and/or Portable Materials." AP 0019 contains requirements to ensure that direct loads are not placed on, and access is not blocked to, operable safety related equipment and to assess the need for a temporary modification request under AP 0020. The plexiglass panel was installed to protect the RCIC Alternate Shutdown Panel from adjacent work activities. The worker who installed the plexiglass maintained a space between the plexiglass and the RCIC Alternate Shutdown Panel.

He intended to allow for access to the RCIC Alternate Shutdown Panelif required.

The worker discussed the installation with the Operations Planning Group via telephone and no concerns were noted. However, the worker incorrectlyidentified the panel, which led to an incorrect assessment by the Operations Planning Group. In addition, no inspections of the installation were performed by Vermont Yankee personnel.

The housekeeping problems that existed in the 'B' emergency core cooling system corner room were the result of inadequate performance on the part of the work crew. Additionally, a contributing cause was the failure to ensure the work crew fully understood the expectations of Vermont Yankee with regard to work near operable systems.

For both the RCIC and ECCS Rooms,immediate corrective actions were taken to remove the nonconforming materials and to perform an independent inspection of the remaining scaffolding and temporary materials within the Reactor Building. No other significant discrepancies were identified during this inspection and full compliance with Technical Specifications 6.5 was achieved on July 29,1993. In addition, the requirements of procedures AP 0019, AP 6024, and the Vermont Yankee Safety Manual were discussed with the appropriate workers and supervisors to ensure that Vermont Yankee's expectations are clearly understood.

As an interim measure, to ensure scaffolding and temporary materials do not adversely affect operation of plant systems, structures and components, increased Engineering Department attention is being provided in the area of temporary modifications. Vermont Yankee Engineering Department personnel are using a system oriented checklist developed to evaluate our performance particularly in areas where l operable safety related, vital fire protection, or Appendix R equipment may be l

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VERMONT YANKEE NUCLEAR POWER CORPORATION j United States Nuclear Regulatory Commission

{ September 27,1993 Page 3 i

affected. This checklist was developed from a review of similar procedures from other utilities. Additionally, during the present refueling outage, when the number of systems available to perform safety functions is reduced, barriers requiring Shift 1

Supervisor permission to enter are placed around areas containing vital systems. This action occurred as a result of comments by the Outage Safety Review Committee.

During non-outage periods weekly walkdowns are performed using the Vermont  ;

Yankee Observation Program. This program includes lists of both acceptable and

} poor housekeeping practices. During refueling outages, when the potential for j housekeeping problems are increased, daily walkdowns are conducted by Vermont  !

1 Yankee personnel. We believe that walkdown results to date indicate improvements in worker performance in this area.

, Following the refueling outage, it is Vermont Yankee's intent to review the lessons learned specific to both housekeeping and temporary modifications.

j Procedures AP 0019 and AP 6024 will be revised as required and our staff and l contractor training programs will also be modified accordingly. These actions will be completed by the end of 1993. Our interim measures will remain in place until the i

! required revisions to our programs and/or procedures are in effect.

3 l CONTROLS FOR OUTAGE OVERTIME i

j Reference (b) also requested that we provide our intended administrative l controls for overtime in outages. The overtime guidance contained in a Plant Manager memorandum to station personnel was formalized and issued as part of our approved  :

1 Outage Guideline. The revised requirements conform to Generic Letter 82-12 guidance and apply to all safety class work during this outage. As noted in the

] inspection report, the Outage Guideline does the following; I l 1) requires pre-approved exceptions to exceed working hour limits including the i

need to consider compensatory actions.

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2) requires routino discussions regarding fatigue, fitness for duty and overtime, j and re-emphasis of working hour limits during management outage meetings.

3) provides direction regarding the applicability of the limits to Radiation and l i

Chemistry technicians.

i l Following the refueling outage, it is Vermont Yankee's intent to review the

lessons learned from the outage specific to the use of the interim guidance and 3 formally incorporate changes into procedure AP 0894, " Shift Staffing and Overtime Controls." This effort will be completed by the end of 1993.

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VERMONT YANKEE NUCLEAR POWER CORPORATION United States Nuclear Regulatory Commission September 27,1993 Page 4 We trust that the information provided is adequate; however, should you have any questions or require additional information, please do not hesitate to contact us.

Sincerely, Vermont Yankee Nuclear Power Corporation l

James P. Pelletier Vice President, Engineering l

cc: USNRC Region 1 Administrator USNRC Resident inspector - VYNPS l USNRC Project Manager - VYNPS i

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