ML19259B682
| ML19259B682 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/05/1979 |
| From: | Moody D VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19259B681 | List: |
| References | |
| NUDOCS 7903130539 | |
| Download: ML19259B682 (3) | |
Text
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VER710NT YAN KEE NUCLEAR POWER CORPC RATION SEVENTY SEVEN GROVE STREET B. 4... 1 RuTLAxo, VERMONT 05701 REPLY TO:
ENGINEERING OFFICE TURNPIKE RO AD WESTBORO. M ASSACHUSETTS 01581 TELEPHONE 6 9 7-364-90 t 1 WY 79-11 F6bruary 5, 1979 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: Office of Inspection and Enforcement Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) USNRC Letter to VYNPC, dated January 8,1979 (Inspection Repcrt 50-271/78-29)
Dear Sir:
Subject:
Inspection Repcre 50-271/78-29 This letter is written in response to Reference (b) which indicates that certain of our activities were not conducted in full compliance with Nuclear Regulatory requirements. The alleged items of noncompliance were noted during an inspection conducted on December 12-15,1978, at the Vermont Yankee Nuclear Power Station in Vernon, Vermont.
Information is submitted as follows in answer to the alleged infraction and deficiency contained in the ene.losure to your letter:
Item A
" Technical Specification 6.5.A states in part:
' Detailed written procedores involving nuclear safety, including applicable check-off lists and instructions, covering 6.'eas listed below shall be prepared and approved.
7 9 0 313 0 5 M 1.
Normal startup, operation and shutdown of systems and components of the facility.'
" Contrary to the above, inadequate procedures resulted in a valve check-off list performed on August 7,1978 in accordance with Procedure 0.P. 2113, Main and Auxiliary Steam, being incomplete io. that certain valves located on the High Main Steam Line Flow Switches instrument rack were cmitted from the valve check-off list. In addition, it appears insdequate controls were provided for a previously conducted valve tagging program, as a result a valve identification tag was incorrectly applied.
This combination of factors resulted in a plant startup with the High Main Steam Line Flow Switches inoperable."
~
United States Nuclear Regulatory Commission February 5, 1979 Att: Office of Inspection and Enforcement Page 2
Response
Plant Procedure, A.P. 0156, Current Valvc Lineup File, will be revised to require station operators to check the adequacy of the installed tags during each valve lineur. Any valve found with an identification tag missing or inappropriafe will be so identified on the valve lineup form (Appendix A, B, C, or 3). The valve vill not be considered to be in its ficsl, correct position until it has been properly identified by an operator using facility flow diagrams and proper identification tags have been inst'lled.
New valves which may be installed will be assigned a designation per A.P. 0155, Valve Identification. The placement of identification tags will be verified on the appropriate valve lineup form by two operators.
In addition, an investigation will be conducted to determine if system modifications should be undertaken during the 1979 refueling outage to phyaically separate existing interconnections between the demineralized water system and instrument racks. Upon completion of this effort, the appropriate valve lineup procedures will again be revised if modifications are deemed necessary.
Item B:
" Technical Specification 6.5.B.1 states in part:
'The types of events listed below shall be reported as expeditiously as possible, but within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />...
F.
Personnel error or procedural inadequacy which prevents or could prevent, by itself, the fulfillment of the functional requirements of systems required to cope with acci-dents analyzed in the SAR.'
" Contrary to the above, an event which occurred on August 14, 1978, resulting from a personnel error and/or procedural inadequacy which resulted in the loss of all the High Main Steam Line Flow Switches was not reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The event was reported in a Thirty Day Written Report."
Response
The above event was analyzed and determined to be reportable as a Thirty Day Written Report based on not exceeding the least conservative aspect of the Limiting Condition for Operation following the discovery of the event. Regulatory Guide 1.16, Reporting of Operating Information-Appendix A. Technical Specifications, states that "if specified action is taken when a system is found to be operating between the most con-servative and the least conservative aspects of a limiting condicion for operation listed in the Technical Specifications, the limiting condition for operation is not considered to have been violated and need not be reported under this item (Prompt Notification), but it may be reportable under item 2.b(2) below (Thirty Day Written Report)." The period between the dice very of the event and the restoration of the system to an operable status did not exceed the time allowed to place the reactor in the " Hot Standby" condition.
United States Nuclear Regulatory Commission February 5, 1979 Att: Office of Inspection and Enforcement Page 3 Vermont Yankee recognizes that the guidance provided for categorizing an occurrence, as detailed in the Technical Specifications, is subject to interpretation by both the licensee and the Nuclear Regulatory Commission staff. Certain inconsistencies exist within Regulatory Guide 1.16 and the interpretation of the guidance provided is always a matter of individual judgement. All events cannot be positively distinguished as those requiring Prompt Notification or a Thirty Day Written Report.
However, in over six years of operation, this event is the first of all events reported to be categorized diff erently by your staff.
All events or conditions which occur and could be considered a Reportable Occurrence are evaluated by a member of the plant's technical staff to ensure the event is properly categorized. The Plant Superintendent and/or the Assistant Plant Super'e*2ndent subsequently review and approve the category and details provided within the written report. The Plant Operations Review Comnittee and the Nuclear Safety Audit and Review Committee are also charged with the responsibility of reviewing each event. Although Vermont Yankee believes that the present methods utilized to ensure proper categorization are more than cdequate to meet this ob-j ective, a more diligent review process will be immediately implemented to prevent the recurrence of this deficiency.
We trust this information will be satisfactory.
Should additional information be required, please feel free to contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION
,/
D. E. Moody Manager of Operations DEM/em