ML20079Q917
| ML20079Q917 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/17/1983 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| EA-83-034, EA-83-34, EVY-83-61, FVY-83-61, NUDOCS 8306210118 | |
| Download: ML20079Q917 (3) | |
Text
(
'iVERMONT YANKEE NUCLEAR POWER CORPORATION 2.C.2.ll FVY 83-61 R D 5, Box 169, Ferry Road, Brattleboro, VT 05301
,,,,y 7, p
ENGINEERING OFFICE 1671 WORCESTER ROAD FRAMINGHAM, MASSACHUSETTS 01701 TELEPHONE 617-872-8100 June 17, 1983 U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D.C.
20555 Attention:
Mr. Richard C. DeYoung, Director
References:
a)
License No. DPR-28 (Docket 50-271) b)
USNRC Letter to VYNPC dated 5/10/83; Proposed Civil Penalty (EA 83-34)'and NRC Inspection Report No. 50-271/83-04 c)
USNRC Letter to VYNPC dated 3/30/83; Inspection Report 50-271/83-04 d)
VYNPC Letter to USNRC dated June 16, 1983, Response to Notice of Violation and Proposed Imposition of Civil Penalty (EA 83-34)
Dear Sir:
Subject:
Response to Proposed Imposition of Civil Penalty (EA 83-34)
This letter is written in response to Reference (b) which indicates that one of our activities was not conducted in full compliance with Nuclear Regulatory Commission requirements and, further, proposes that a civil penalty in the amount of forty thousand (40,000) dollars be levied against vermont Yankee Nuclear Power Corporation.
In accordance with the provisions of 10 CFR 2.205 we request mitigation of the proposed civil penalty based on the information provided below.
References (b) and (c) have been thoroughly reviewed and to the best of our knowledge accurately summarize events occurring on March 21, 1983.
- However, with respect to the violation on which the proposed civil penalty is based, i.e., failure to follow administrative controls, we feel that several of our actions, when amplified, will support our contention that the amount of the civil penalty should be reduced.
8306210118 830617 L
gDRADOCK05000 t a
e U.S. Nuclear R:gulatory Commission
- Juns 17,' 1983 VERMONT YANKEE NUCLEAR POWER CORPORATION Pag 2 2 The first consideration is the length of time secondary containment was compromised prior to discovery and the quantity of fuel actually being moved.
The inspection report potes that the total time of the event was limited to two hours and six minutes duration. Our records indicate that the first fuel move was not initiated until 0847. Since secondary containment is required only during the actual movement of fuel within the reactor building, the length of time is one hour and thirty eight minutes (0847 - 1025) and even less if only the actual time fuel is being moved is considered.
During this period of time, three individual bundles were moved approxima-tely 30 feet from their storage location in the spent fuel pool to the inspec-tion stand also located in the spent fuel pool. Additionally, eight individual fuel rods were moved from other bundles to an inspection stand, a distance of 2
- 3 feet. While we do not dispute that these activities constitute " fuel moves within the reactor building," any postulated problems that could have occurred are far less significant than those analyzed.
Specifically, Section 5.3.3 of the FSAR defines the safety objectives of the secondary containment as a system "to minimize ground level release of airborne radioactive materials and to pro-vide means for a controlled release of the atmosphere within the building should a design basis accident occur" (emphasis added).
Section 14.6.4.1 of the FSAR concludes that "the only accident that could result in the release of signifi-cant quantities of fission products to the containment during (refueling) is one resulting from the accidental dropping of a fuel bundle onto the top of the core" (emphasis added).
The second, and more important, consideration is the promptness and extent to which management took corrective action. Within a matter of minutes after identifying the existence of a situation that required corrective action all fuel moves were terminated and the automatic logic for SBGT and RB ventilation restored. Those actions were, in and of themselves, sufficient to resolve the immediate concern.
In the short term, we also recognized the need to ascertain how and why the condition was allowed to occur to ensure ourselves that this failure to adhere to procedures was an isolated event.
To this end, meetings t
were conducted with all the affected parties and subsequently with the entire
]
l plant staff. As a result of those meetings, and an independent audit conducted by our quality assurance organization, we were assured that the event that l
occurred was, in fact, an isolated event. Additionally, immediate reviews of l
the pertinent plant procedures were initiated in an attempt to identify if other l
weaknesses were present; minor clarifications were made to those procedures l
within seven (7) days.
s The fact that qualified experienced personnel had been involved with this apparent disregard of administrative controls also caused us significant concern and in that regard we took what we consider drastic disciplinary action, the actual removal from license duty of two senior licensed operators, t
i I
l
e U.S. Nuclear Regulatory Commission
- June 17,1983 VERMONT YANKEE NUCLEAR POWER CORPORATION Paga 3 One of these operators has subsequently been returned to licensed duties; the other individual itas been permanently removed from licensed duty and reassigned to a different position.
We believe that these actions clearly demonstrate: 1) the timeliness of the corrective action; 2) the degree of management's initiative, and 3) the comprehensiveness of the corrective actions focused both, narrowly, to the specific violation and, broadly, to a general area of concern.
The mitigators, such as duration and corrective actions dicussed above are identified in 10 CFR 2, Appendix C as factors that will be considered to reduce the amount of a proposed civil penalty. We believe that the information pro-vided above clearly justifies our position that the amount of the civil penalty should be reduced.
Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION N[h Warren P. Murphy Vice President and Manager of Operations WPM /dm l
l l
I
\\
..