ML20023D651
| ML20023D651 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/10/1983 |
| From: | Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20023D650 | List: |
| References | |
| REF-SSINS-6020 EA-83-034, EA-83-34, NUDOCS 8305250577 | |
| Download: ML20023D651 (4) | |
Text
....
1
?
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Vermont Yankee. Nuclear Power Corporation-Docket No. 50-271 Vermont Yankee Nuclear Power Station License No. DPR-28 EA 83-34
-During a special inspection conducted between March 21 and 25, 1983, violations of NRC requirements were identified. One violation involved the failure to maintain l'
secondary containment integrity for a period of approximately two hours in violation of a technical specification limiting condition for operation. This l
violation was apparently caused.by a failure to follow procedures. Another violation involved the failure to report this condition to the NRC Operations 4
Center within one hour after it was identifed.
On March 21, 1983, at 6:49 a.m., with the reactor shut down, reactor protection 4
system motor generator (RPS MG). set "A" was removed from service for planned 9-modifications. When RPS MG set "A" was removed, both trains of the standby l
gas treatment system (SBGT) automatically started and the reactor building (RB) ventilation system automatically isolated. At that time, outage work was being performed in the RB and consequently there was concern about the air quality for the workers because of smoke and particulates. Since SBGT provides about one RB air change per day compared to about 75 RB air changes per day with normal ventilation, the day shift supervisor requested an instrument and control (I&C) technician to provide a jumper and lifted lead arrangement to restore normal RB ventilation.
At 8:17 a.m., the senior I&C technician, in the presence of the senior control room operator (SCRO), opened slide links TAC-3 and TP-1 at control room panel i
(CRP).9-26 to restore normal RB ventilation. This activity was performed without initiating, reviewing, and approving a jumper and lifted lead request, as required by administrative procedures. Opening the slide links resulted in i
loss of the auto-start capability of both SBGT trains and loss-of the automatic isolation capability for the RB ventilation system.
After the slide links were opened, the SBGT wn manually secured and RB ventilation was restored. This condition existed 'until-the slide l_ inks were closed at 10:23 a.m.
The auto-start capability'of the SBGT and the automatic isolation capability for the RB ventilation system are required as conditions to maintain secondary containment integrity. Between 8:17 a.m. and 10:23 a.m.,
. integrity.was required because irradiated fuel was being moved in the spent.
L fuel pool.
Although plant management was aware of this condition at-12:00 noon on March 21, 1983, the NRC Operations Center was not notified within one hour as required.
The NRC resident inspector was verbally notified by the licensee at approxi-mately 11:40 a.m..on March 22, 1983.
To emphasize the need for' improved performance at Vermont Yankee to assure ad-i-
herence to plant procedures and administrative requirements by all personnel,
' including senior plant supervisors, so that whenever equipment or systems are modified, the modifications are properly reviewed and approved prior to 0FFICIAL RECORD COPY 4,
8305250577'830510
1 PDR ADOCK 05000271 4
.G-PDR 1.L
Notice of Violation implementation, the Nuclear Regulatory Commission proposes to impose a civil penalty in the amount of Forty Thousand Dollars (540,000) for the violation set forth in Section I of this Notice.
In accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), 47 FR 9987 (March 9, 1982), and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, 42 U.S.C. 2282, PL 96-295 and 10 CFR 2.205, this particular violation and its associated civil penalty are set forth below:
I.
VIOLATION ASSESSED A CIVIL PENALTY Technical Specification Limiting Condition for Operation (LCO) 3.7.C.1.d requires that secondary containment integrity be maintained whenever irradi-ated fuel is being moved in the reactor building.
Section 1.U of the Technical Specifications defines secondary containment integrity and specifies as two of its conditions that (1) the standby gas treatment system (SBGT) is operable and (2) all reactor building automatic venti-lation system isolation valves are operable or are secured in the isolated position.
Contrary to the above, between 8:17 a.m. and 10:23 a.m. on March 21, 1983, secondary containment integrity was not maintained, as required when 15 irradiated fuel rods and three irradiated fuel bundles were moved within the spent fuel pool in the reactor building, in that the automatic start capability of both trains of SBGT was inoperable and the automatic isolation feature of the reactor building ventilation system isolation valves was inoperable and these valves were not secured in the isolated position. This resulted from the failure to follow an administrative procedure as required bv Technical Specification 6.5.A:
A.P. 0020, Revision 6, entitled Temporary Electrical Jumpers, Lifted Lead (LLJ) and Mechanical Bypasses, requires that, during modification of plant equipment involving installation of temporary electrical jumpers or mechanical bypasses, or lifting of electrical leads, this procedure must be followed to assure safe plant operation.
Section II.A of the procedure requires that VYAPF 0020.01 (Temporary Electrical Lifted Lead / Installed Jumper (LLJ)) be completed; reviewed by the originating department supervisor for need, accuracy and pertinent comments; reviewed by the operations department for impact on plant conditions and technical specification compliance; and reviewed by the shift supervisor and the implementing department before performance by two qualified individuals.
However, on March 21, 1983, at 8:17 a.m. a temporary modification was performed in that slide links TAC-3 and TP-1 were opened at control room panel (CRP) 9-26 by a qualified Instrument and Control (I&C) technician and witnessed by the on-duty senior control room operator (SCRO) without preparation and completion of an approved LLJ request.
OFFICIAL RECORD COPY
Notice of Violation The activity had not been reviewed by the originating department supervisor, the operations department, nor the shift supervisor.
The opening of the slide links rendered the auto-start capability of SBGT inoperable and also rendered the automatic isolation feature of the ventilation system isolation valves inoperable.
This is a Severity Level III Violation (Supplement I)
Civil Penalty - $40,000 II. VIOLATION NOT ASSESSED A CIVIL PENALTY 10 CFR 50.72 (a) requires, in part, that the NRC Operations Center be notified as soon as possible and in all cases within one hour of any significant event resulting from failure to follow procedures which, during normal operations, anticipated operational occurrences, or accident conditions prevents or could prevent, by itself, the fulfillment of the safety function of those systems important to safety that are needed to limit the release of radioactive material to acceptable levels.
-A.P.0010, section VI, written pursuant to 10 CFR 50.72 requires that plant management, the duty shift supervisor, or the duty and call officer notify the NRC via the Red Telephone within one hour when an event or condition described in Appendix D of A.P.0010 occurs. Appendix D o'f A.P.0010 requires that in the absence of higher plant management, the duty shift supervisor or the duty and call officer shall notify the NRC Operations Center as soon as possible and in all cases within one hour by tele-phone of the occurrence of significant events and shall identify that event as being reported pursuant to 10 CFR,50.72.
Contrary to the above, as of approximately 12:00 noon on March 21, 1983, plant manegement was aware that secondary containment integrity had not been maintained as required between 8:17 a.m. and 10:23 a.m. on March 21, 1983, a condition which resulted from personnel error involving a failure to follow a procedure, and the NRC Operations Center was not notified of this occurrence.
This is a Severity Level IV Violation.
(Supplement I)
Pursuant to 10 CFR 2.201, the Vermont Yankee Nuclear Power Corporation is hereby required to submit to the Director, Office of Inspection and Enforce-l ment, USNRC, Washington, D. C. 20555, with a copy to this office, within 30 days of the date of this Notice, a written statement or explanation, including for each alleged violation; (1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.
Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C.
2232, this response shall be submitted under oath of affirmation.
OFFICIAL RECORD COPY
Within the same time as provided for the response required above under 10 CFR 2.201, Vermont Yankee Nuclear Power Corporation may pay the civil penalty in the amount of Forty Thousand Dollars ($40,000) for the violation, or may protest imposition of the civil penalty in whole or in part by a written answer. Should Vermont Yankee Nuclear Power Corporation fail to answer within I
the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalty in the amount proposed above.
Should Vermont Yankee Nuclear Power Corporation elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may:
(1) deny the violations listed in this Notice in whole or in part; (2) demonstrate extenu-ating circumstances; (3) show error in this Notice, or (4) show other reasons i
why the penalty should not be imposed.
In addition to protesting the civil l
penalty in whole or in part, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the five i
factors contained in Section IV(B) of 10 CFR 2, Appendix C, should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth sepa-rately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. Vermont Yankee Nuclear Power Corporation's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay the civil penalty due, which has been subsequently deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION CRIGINAL SIGNED BY-JMES M ALLAN thMes M. Allan l
Acting Regional Administrator Dated at King of Prussia, Pennsylvania l
this /c day of May 1983.
OFFICIAL RECORD COPY