ML20081D991
| ML20081D991 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/15/1995 |
| From: | Pelletier J VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-95-31, NUDOCS 9503210099 | |
| Download: ML20081D991 (3) | |
Text
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' VERMONT YANKEE
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NUCLEAR POWER ' CORPORATION
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Ferry Road, Brattleboro, VT 05301-7002 ENGINEERING OFFICE
$80 MAIN STREET BOLTON, MA 01740 (508) 77S 4711 March 15,1995 BVY 95-31 United States Nuclear Regulatory Commission
~ ATTN: Document Control Desk
. Washington, DC 20555
References:
(a)
License No. DPR-28 (Docket No. 50-271)
(b)
Letter, USNRC to VYNPC, inspection Report No. 50-271/94-31, dated February 13,1995
Subject:
Reply to a Notice of Violation -Inspection Report No. 50-271/94-31 This letter is written in response to Reference (b), which documents that our activities were not conducted in full compliance with NRC requirements. The violation was identified
' during a routine inspection conducte i from December 11,1994 to January 21,1995. Our response to the violation is provided elow.
VIOLATION:
Vermont Yankee Technical Specification 6.5 requires that-procedures involving safety shall be adhered to. Administrative Procedure (AP) 0020, Rev.17, " Control of Temporary and Minor Modifications," was written pursuant to Technical Specification 6.5 to administratively assure that appropriate engineering and safety reviews are conducted for the modification of systems. Procedure AP 0020, Step, A.1.b requires,in part, that modifications be evaluated in accordance with AP 6002, Rev. 3, " Preparing 50.59 Evaluation," for determining if an unreviewed safety question exists.
Contrary to the above, from October 4 - 28 and November 7 - 10,1994, safety related Class 1E reactor vessel water level instrument 2 3 72B was modified without the use of a Temportiry Modification by the connection of a recorder to the instrument's test jacks and without conducting an evaluation to demonstrate that this condition did not create an unreviewed safety question. Instrument 2-3-72B provides initiation and control signals to the core standby cooling systems. The modification extended the environmentally and seismically qualified electrical integrity boundary of the Instrument beyond its original design configuration.potentially affecting the precision and reliabliity of levelinstrument 2-3-72B required for accident conditions.
j This instance constitutes a Severity Level IV Violation.
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PD DO Oo 71 U
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' VERMONT YCKEE NUCLEAR POWER CORPORATION
' United States Nuclear Regulatory Commission March 15,1995 Page 2
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RESPONSE
1):
. Reason For The Violation
-Vermont Yankee does not contest this violation. The cause of this violation is attributed to a failure by management to timely implement corrective actions identified following a similar event that occurred on March 17,1994. The cause assessment, performed in response to the March event, identified that Procedure AP 0020 did not provide sufficient guidance in the application of intrusive test equipment. Appropriate corrective actions had been identified as a result of the March event but processing of the corrective action document and subsequent implementation of the corrective I
actions were not timely.. The corrective actions in progress from the March event were reviewed and it was concluded that, had they been fully implemented, they would have prevented the occurrence which is the subject of this violation.
2)
Corrective Steps That Have Been Taken And The Results Achieved
}
Short term corrective actions already taken and the results achieved are summarized as follows:
a)
Draft guidance on the use of test and monitoring equipment was developed and was discussed along with the two events at the daily Plant Manager's meeting on January 19,1995 as a means of increasing awareness of the event and to prevent similar occurrences. This draft guidance was finalized and discussed further at the daily Plant Manager's meeting on February 27,1995. This has resulted in additional review of proposed testing methods on operable equipment.
b)
A Failure Modes and Effects Analysis (FMEA) and a 10CFP.50.59(a)(2) Safety Evaluation were performed on.his occurrence which documented that there were no potential adverse consequences of this event and that the connection of the test equipment did not result in an unreviewed safety question, c)
The necessity for timely implementation of corrective actions was discussed with Plant Superintendents and Department Managers at the daily Plant Manager's meeting on February 23,1995.
d)
An improved corrective action procedure, AP 0009, was implemented on February 27 1995. This new corrective action process incorporates improvements which include enhanced initial review and assessment of events and the incorporation of specific time frames for the processing of significant corrective action documents. These changes were in progress as a result of other corrective action improvements and are considered to address the cause of this event.
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- n IUnited States'Nucibr Regulatory Commission March.15,1995 -
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LThe Temporary Modification procedure, AP 0020, was changed on March 3, 1995.to include criteria on the application of monitoring and test equipment.
On February 27, 1995, prior to issuing the change to AP 0020, all Plant Department Managers were notified cf the change and requested to review the -
criteria with their staff.
3),
' Corrective Steps That Will be Taken to Avoid Further Violations Additional corrective actions, in progress or planned, to avoid further occurrences are summarized as follows:
1 a)
To further reinforce the significance of this event, it is being added to the.
Continuing Training Program for Engineering Support personnel to be reviewed again during the second quarter of 1995.
b)
A review will be performed during the third quarter of 1995 of the various 1995 activities involving the application of monitoring equipment to "in-service" structures, systems and components. This effort will ensure that proper controls t
have been impler.1ented to control work activities in accordance with the criteria incorporated into the Temporary Modification procedure for monitoring.
e equipment.
4)
Date When Full Compliance Will Be Achieved Full compliance was achieved with the removal of the temporary recorder on November 10,1994.
' We trust that the information provided is fully responsive to your concerns; however, should you have additional questions or require any additional information, please do not hesitate to contact us.
Sincerely, VERMONT YANKEE NUCLEAR POWER CORP.
PPM pames P. Pelletier Vice President, Engineering cc:
USNRC Region I Administrator USNRC Resident inspector - VYNPS USNRC Project Manager - VYNPS
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