IR 05000271/1993014
| ML20058E269 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/22/1993 |
| From: | Linville J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Reid D VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| NUDOCS 9312060229 | |
| Download: ML20058E269 (3) | |
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NOV 2 2 l993 Docket No. 50-271 Mr. Donald Vice President, Operations Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301
Dear Mr. Reid:
Silfu ECT:
INS PECTION 50-271/93-14 This letter refers to your September 27,1993, correspondence, in response to our August 27, 1093 letter regarding violations for an unrecognized temporary modification to the alternate shutdown panel for the reactor core isolation cooling system (RCIC) and poor housekeeping and material conditions in the "B" emergency core cooling system corner room.
The effectiveness of your actions, including formal revision to your administrative controls for overtime, will be examined during future inspections of your licensed program.
Your cooperation with us is appreciated.
Sincerely, C4C:.' ':lEned B EL13 C. Linyjpg, y,-
James C. Linville, Chief Reactor Projects Branch 3 Division of Reactor Projects s
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R. Wanczyk, Plant Manager 1 Tremblay, Senior Licensing Enginect, Yankee Atomic Electric Company J. Thayer, Vice President Yankee Atomic Electric Company
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l Mr. Donald NOV 2 21993 i
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cc w/cy of Licensee's Response Letter:
i J. Gilroy, Director, Vermont Public Interest Research Group, Inc.
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D. Tefft, Administrator, Hureau of Radiological Health, State of New IIampshire I
Chief. Safety Unit, Office of the Attorney General, Commonwealth of Massachusetts
R. Gad, Esquire
G. llisbee, Esquire R. Sedano, Vermont Department of Public Service T. Rapone, Massachusetts Executive Of0cc of Public Safety
Public Document Room (PDR)
local Public Document Room (LPDR)
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Nuclear Safety information Center (NSIC)
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K. Abraham, PAO (2 copies)
NRC Resident inspector
4 State of New Hampshire, SLO Designee j
State of Vermont, SLO Designee Commonwealth of Massachusetts, SLO Designee i
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j E. Kelly, DRP J. Shediosky, DRP
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M. Oprendek, DRP V. McCree, OEDO
- D. Dorman, NRR W. Butler, NRR
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I VERMONT YANKEE NUCLEAR POWER CORPORATION
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Ferry Road, Drettlebwo. VT C5301-7002
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ENGINEERING OFFICE
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580 M AIN 3'DLE T
GOLTON MA 01740
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September 27,1993 BW 93-108 United States Nuclear F 4 7latory Commission ATTN: Document Cont of i: 1sk Washington, DC 20555 References:
(a)
License No. DPR-28 (Docket No. 50-271)
(b)
Letter, USNRC to WNPC, inspection Report 93-14, dated 8/27/93 Subject:
Reply to a Notice of Violation and Controls for Outago 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 provido our intended administrativo controls for overtime during outages. Our response to both of these items is provided below.
VIO_LATION; Vermont Yankee Technical Specification 6.5 requires that procedures involving safety shall be adhered to. Plant administrative Procedures AP 0020, Rovlslon 15, " Temporary Modifications," and AP 6024, Revision 8,
" Plant Housekeeping," were written pursuant to TechnicalSpecifications 6.5. Procedure AP 0020 requires,in part, that ovaluations of temporary modifications to plant equipment be evaluated.. Procedure AP 6024 requiren, in part, that good housekeeping practicos be maintained.
Contrary to the above, during July 22-23,1993, alternato shutdown panel, CP-82-1, was modified by the addition of a ptoxiglass panel that provented operation of equipment controls.
No evaluation of this condition was performed.
Additionally, on July 27, 1993, good housekeeping practicos did not exist in the "B" emergoney core cooling system corner room of the reactor building In that materials were placed on the residual heat removal pump motor and piping, as well as debris on the floor near sump pumps.
These Instancos constitute a Severity Lovel IV violation.
S/do/07K7
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VERMONT YANKEE NUCLEAR POWER CORPORATioto United States Nuclear Regulatory Commission i
September 27,1993
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Page 2 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
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onsure that operation of plant systems, structuros and components were not adversely l
affected. A contributing cause was an error in communications.
Installation of the plexiglass panel in front of the RCIC Afternate Shutdown Panel, CP-82-1, was controIIed under procedure AP 0019, Revision 9, " Control of Tamparary 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 RClO 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.
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The worker discussed the installation with the Operations Planning Group via tcIcphone and no concerns were noted. However, the worker incorrectly identified 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 idontified 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.
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As an interim measure, to ensure scaffolding and temporary maiorials do not r aersely affect operation of plant systems, structures and components, increased Engineering Department attention is being provided in the area of temporary modifications. Vermont Yankee Engincoring Department personnel are using a system oriented checklist developed to evaluate our performance particularly in areas where operable safety related, vital fire protection, or Appendix R oquipment may be i-W J
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VERMONT YANKCC NUCLEAR POWER CORPORATION
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United States Nuclear Regulatory Commission September 27,1993 Page 3
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affected. This checklist was developed from a review of similar procedures from other
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utilities. Additionally, during the present refueling outage, when the number of systems available to perform safety functions is reduced, barriers requiring Shift 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 weeklywalkdowns 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 housekeeping problems are increased, daily walkdowns are conducted by Vermont Yankeo personnel. We believe that walkdown results to date indicate improvements in worker performance in this area.
'Following the refueling outage,11 is Vermont Yankoo's intent to review the lessons learned specific to both housekeeping and temporary modifications.
Procedures AP 0019 and AP 6024 will be revised as required and our staff and 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 required revisions to our programs and/or procedures are in effect.
CONTROLS FOR OUTAGE OVERTIME Reference (b) also requested that we provide our intended administrative 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 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 incpcetion report, the Outage Guideline does the following; 1)
requires pre-approved exceptions to exceed working hour limits including the need to consider compensatory actions.
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requires routine discussions regarding fatigue, fitness for duty and overtime, and re-emphasis of working hour limits during management outage meetings.
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provides direction regarding the applicability of the limits to Radiation and Chemistry technicians.
Following the refueling outage, it is Vermont Yankee's intent to review the lessons learned from the outage specific to the uso of the interim guidance and formally incorporate changes into procedure AP 0894, " Shift Staffing and Overtime
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Controls." This effort will be completed by the end of 1993.
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VERMONT YANKEE NUCLEAR POWER CORPORATION
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United States Nuclear Regulatory Commission
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September 27,1993
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Page 4 We trust that the information provided is adequate; however, should you have i
any questions or require additional information, please do not hesitate to contact us.
Sincerely, L
Vermont Yankee Nuclear Powcr Co'rporation hh James P. Pelletier Vice President, Engineering cc:
USNRC Region i Administrator USNRC Resident inspector - WNPS USNRC Project Manager - VYNPS b
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