ML20066K511
| ML20066K511 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/28/1991 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-91-13, NUDOCS 9102060038 | |
| Download: ML20066K511 (3) | |
Text
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VERMONT YANKEE Nuct EAR POWER CORPORATION.
^*
ab Ferry Road, Brattleboro, VT 05001-7002
%g ENGINEERING OFFICE M-580 MAIN STREET -
i DoLioN, MA 01740 (508) 779 67 t t January 28,1991
- U.S. Nuclear Regulatory Commission Washington, D.C.
20555.
Attn: Document Control Desk'
References:
a)
License No. OPR 28 (Docket No. 50 271) 3 b) -
Letter, USNRC to WNPC, NW.90 212, dated 11/27/90 c)
Letter, WNPC to USNRC, BW 90-126, dated 12/27/90
Dear Sir:
Subject:
Revision to our Response to inspection Repor; 50 271/90 10, Notice of Violation, Notice of Deviation and identified Weaknesses After our discussions with Jon R. Johnson, Chlaf, Reactor Projects Branch No', 3, Tand Harold Eichenholz, Senior.NRC Resident Inspector, we more fully understand the bases for the NRC's position on the violations transmitted in Reference -b).
Based on this additional Information, we are submitting this revision to our response submitted as Reference c).
The alleged violations, classified as Severity -Level IV,' were identified as a result of inspections conducted by the NRC Resident inspector during the period August.13 October 9, 1990.
4 l-VIOLATION -
Technical Specification Section ; 6.5,-- Plant 10perating Procedures,.
requires that detailed written procedures involving both nuclear and -
non nuclear safety,. covering operation of-systems ~ and components -
of the facility _ including applicable check off lists and Instructions shall be prepared, approved, and adhered to.
Operating Procedure OP-i l
2184, Fuel Pool Cooling System.. requires that from and after the date that.one of the fuel' pool cooling subsystems-is made or found inoperable (and the remaining _ subsystem is capable of maintaining the fuel pool temperature below 150 degrees F) then the reector shall' L
be in cold shutdown within-thirty days unless such subsystem is sooner made cperable.
Contrary to the above, between August 4,1989 and ' July 3,' 1990 the reactor was not placed in a cold shutdown condition, when the "A" fuel pool cooling subsystem remained inoperable for more than thirty days with the "A" fuel pool cooling pump power supply breaker, P9-1 A white tagged (Danger Tagged) in the open position, 9102060038 910128
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l VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission January 20,1991 Page 2 ftESPONSE An Investigation of an intermittent ground was completed on June 13, 1989 and the breaker for the "A" fuel pool cooling pump was opened and white tagged. The. intention of placing the white tag was to provide additional assurance beyond a caution tag that the "B" pump would be preferentially operated, it was understood by appropriate operations and maintenance personnel that the Intermittent electrical ground on'the "A" pump did not preclude its use.
Although there are Instructions in procedure AP 0140, Vermont Yankee Local Control Switching Rules, on how the white tag could have been cleared if the "A" pump was needed, we agree that the use of a white tag in this situation is potentially confusing and therefore, not a desirable practice for providing limitations on operable components. Although Vermont Yankoo has on occasion used white tags on components that havo been considered operable, we now agree that this practice should be discontinued. We will revise AP 0140 by March 1,1991 to ensure white tags will not bo used on operable equipment.
VIOLATION 10 CFR 50, Appendix B, Critorion XVI, requires that conditions adverso to quality, such as defective equipment and nonconformances be promptly identified and corrected.
Additionally, 10 CFR-50.49(f) requires that electrical equipment important to safety be quallflod, in part, by testing or by analysis in combination with partial type test data. As stated in the licensee's Environmental Qualification Program Manual, the "A"
Spent Fuel Pool cooling pump motor is-environmentally quallfled (electrical) equipment important to safety.
Contrary. to the above, the " A" Spent Fuel Pool cooling pump motor was not qualified, due to lack of testing or analysis in the degraded condition. Between June 9,1989 and July 27,1990,- the pump motor.
was in a degraded condition in that at least ono phase of the motor winding shorted to ground following a brief period of operation. The condition adverso to quality represents a nonconformance that was not promptly identified and corrected.
RESPONSE
As discussed in Attachment A to the inspection Report, Vermont Yankee promptly identified the potentially degraded condition of the "A" Spent Fuel Pool cooling pump motor and performed the appropriate troubleshooting and testing, including resistance to ground measurements. Further testing of this motor would have required destructive testing which was considered inappropriate. Based on the results of the testing performed, it was concluded at the time that the motor was capable of performing its intended function In the as found condition. The motor was not considered as being in an indeterminant condition as identified by the EO Program and therefore no further engineering evaluation was performed.
Vermont Yankee agrees that the evaluation should have included further engineering analysis to assure the qualification of the equipment was maintained in accordance with 10CFR50.49. To assure that we provide comprehensive evaluations of potential degradations
' U.S. Nuclear Regulatory Commission VERMONT YANKEE NUCLEAR POWER CORPORATION January 28, 1991 Page 3 of equipment qualification, we will revise the corrective maintenance process by March 1,1991 to require a written engineering evaluation, whenever necessary, to assure that potentially degraded equipment is fully qualified in accordance with the Vermont Yankee EO Program.
We trust the information provided above adequately addresses your concerns; however, should you have any questions or desire additional information, please do not hesitate to contact us.
Very truly yours, Vermont Yankee Nuclear Power Corporation d A v -~
Warrer. P.
urphy Senior Vice President, er ons
/dm cc:
USNRC Regional Administrator, Region i USNRC Resident inspector,' VYNPS USNRC Project Manager, VYNPS l
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