ML20036B043
| ML20036B043 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/13/1993 |
| From: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Reid D VERMONT YANKEE NUCLEAR POWER CORP. |
| Shared Package | |
| ML20036B044 | List: |
| References | |
| EA-93-050, EA-93-50, IEIN-88-004, IEIN-88-056, IEIN-88-4, IEIN-88-56, NUDOCS 9305180100 | |
| Download: ML20036B043 (5) | |
See also: IR 05000271/1993005
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2AY 131993
Docket No. 50-271
' License No. DPR-28
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Mr. Donald A. Reid
Vice President, Operations
Vennont Yankee Nuclear Power Corporation
RD 5, Box 169
Ferry Road
Bmttleboro, Vermont 05301
Dear Mr. Reid:
SUBJECT: NOTICE OF VIOLATION - INSPECTION REPORT NO. 50-271/93-05 '
This refers to the safety inspection conducted from February 17 - 25,1993, at the Vermont
Yankee Nuclear Power Plant, Vernon, Vermont, and an in-office review of documents in the
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Region 1 office until March 8,1993. During the inspection, three apparent violations related
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to your fire protection program were identified. The inspection report, which documents
these findings, was transmitted to you on April 1,1993. The issues related to the apparent
violations were discussed at an enforcement conference at the Region I office on
April 21,- 1993. Persons attending the conference are identified in Attachment 1. Also,
copies of your visual presentation material used at the conference are included as Attachment
2 to this letter.
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The violations discussed below are of concern to the NRC because each of the violations
could be attribeted to the inadequate application of quality principles to the original
installation and the subsequent ineffective periodic inspections of the fire barrier penetration
seals. A lack of management oversight to the fire protection program allowed these
violations to occur undetected over a considerable period of time despite prior notification of
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potential fire barrier deficiencies provided to you in NRC Information Notices (IN) 88-04
and 88-04 Supplement 1. " Inadequate Qualification and Documentation of Fire Barrier
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Penetration Seals" and IN 88-56, " Potential Problems With Silicone Foam Fire Barrier
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Penetration Seals." Additionally, your organization's review of prior industry experience
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involving degraded fire barriers and the manner in which you implemented your technical
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specification _-required surveillance program strongly suggests that a good questioning attitude
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- on the part of your staff was lacking. Therefore, any recurrence of these violations in the
future could result in esedated enforcement action.
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OFFICIAL RECORD COPY
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Mr. Donald A. Reid
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y,AY 131333
The first violation concemed your failure to maintain adequate fire barrier penetration seals,
which protect the Reactor Building, Control Building, and the Diesel Generator Rooms as
required by 10 CFR 50 Appendix R, and your Technical Specifications. This finding was
first identified by your organization during the removal of piping insulation from penetration
RA-512-SF on December 17, 1992, and penetration RA-519-CA on December 22,1992.
Your detailed investigation of the condition of your fire barrier penetration seals began on
December 23,1992, and is continuing. A series of event notifications, starting on
December 23,1992, were made in accordance with 10 CFR 50.72. The program you
initiated in December 1992 has continued to identify problems with the fire barrier
penetration seals, which are then reviewed and repaired as necessary in accordance with you
corrective action plan.
The second violation concerned the inadequate implementation of your Technical
Specification surveillance and inspection programs to verify the functional operability of the
fire barrier penetration seals at least once per operating cycle since the original seal
installation in 1980. You stated that you have enhanced your surveillance program
procedures to correct the original procedure problems. Also, you have indicated that you are
using tne enhanced surveillance procedures during your present penetration seal inspection
and repair program that is scheduled for completion during May 1993.
The third apparent violation concerned the failure to perform bench sensitivity testing of
smoke detectors. You presented, during the enforcement conference, records of sensitivity
testing at installation of these detectors. These records showed that you did perform the
required bench testing on your smoke detectors prior their installadon. This data was not
available during the NRC inspection. Therefore, this violation did not occur and is
withdrawn.
Although the first two violations noted above were considered for escalated enforcement
action, we have determined that escalated action was not appropriate in this instance. Our
determination is based on: (1) your assessment of the fire areas with affected barriers, which
revealed that capability to safely shut down the plant as required by 10 CFR 50, Appendix R
in the case of a fire was not impacted; (2) your description of the causes; (3) the minor
safety significance of the violations since the other components of an effective fire protection
system, such as combustible loading, active detection and suppression systems, ignition
source control, and a responsive fire brigade were in place; (4) our own determination of
limited safety impact based on our own review, in February 1993, of your safe shutdown
analysis; (5) your compensatory actions upon discovery; (6) your actions to correct the
identified deficiencies; and (7) our review of the adequacy of those corrective actions.
Therefore, these violations are classified at Severity Level IV in accordance with the,
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C.
OFFICIAL RECORD COPY
G:VY9305.NJB
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Mr. Donald A. Reid
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MAY l 3 1333
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You are requimd to respond to this letter and should follow the instructions specified in the
enclosed Notice of Violation (Notice) when preparing your response. In your response, you
should document the specific actions taken and any additional actions you plan to prevent
recurrence. After reviewing your msponse to this Notice, including your proposed corrective
actions and the results of future inspections, the NRC will determine whether further NRC
enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and
its enclosures will be placed in the NRC Public Document room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance
procedures of the Office of Management and Budget as required by the Paperwork Reduction
Act of 1980, Pub. L. No. 96.511.
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Sincerely,
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Marvin W. Hodges, Director
Division of Reactor Safety
Enclosures:
1. Appendix A, Notice of Violation
2. Attachment 1, Personnel Attending the
Enforcement Conference
3. Attachment 2, Licensee Response Presented
at the Enforcement Conference
OFFICIAL RECORD COPY
G:VY9305.NJB
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Mr. Donald A. Reid
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MAY 131393
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cc w/ encl and Attachments.
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R. Wanczyk, Plant Manager
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J. Thayer, Vice President, Yankee Atomic Electric Company
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L. Tremblay, Senior Licensing Engineer, Yankee Atomic Electric Company
J. Gilroy, Director, Vermont Public Interest Research Group, Inc.
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D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire
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Chief, Safety Unit, Office of the Attorney General, Commonwealth of Massachusetts
R. Gad, Esquire
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G. Bisbee, Esquire
R. Sedano, Vermont Department of Public Service
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T. Rapone, Massachusetts Executive Office of Public Safety
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
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K. Abraham, PAO (2)
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NRC Resident Inspector
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State of New Hampshire, SLO Designee
State of Vermont, SLO Designee
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Commonwealth of Massachusetts, SLO Designee
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Region I Docket Room (with concurrences)
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OFFICIAL RECORD COPY
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Mr. Donald A. Reid
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h'.AY 131993
bec w/o encls and w/o Attachments (VIA E-MAIL):
T. Martin, RA
W. Kane, DRA
R. Cooper, DRSS
C. Hehl, DRP
M. Hodges, DRS
E. Imbro, DRS
W. Lanning, DRP
J. Wiggins, DRP
L. Bettenhausen, DRS
J. Joyner, DRSS
DRS/EB SALP Coordinator
N. Blumberg, DRS
J. Linville, DRP
E. Kelly, DRP
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H. Eichenholz, SRI - Vermont Yankee (w/ concurrences)
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V. McCree, OEDO
D. Dorman, NRR
W. Butler, NRR
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W. Ruland, DRS
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D. Holody, EO
J. Lieberman, OE
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M. Banerjee, ORA
A. Finkel, DRS
bec w/encis; w/ Attachments:
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