ML20087G062
| ML20087G062 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/11/1995 |
| From: | Pelletier J VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-95-86, NUDOCS 9508160215 | |
| Download: ML20087G062 (3) | |
Text
p VERMONT YANKEE NUCLEAR POWER CORPORATION w
3 Ferry Road, Bratt.'eboro, VT 05301-7002 3
ENGINEERING OFFICE N
k
$80 MAIN STREET BOLTON. MA 01740 (508)779-6711 August 11,1995 BVY 95-86 j
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, " Notice of Violation (Vermont Yankee inspection 95-11)", dated July 14,1995
Subject:
Reply to a Notice of Violation -Inspection Report No. 50-271/95-11 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, classified as Severity Level IV, was the result of an NRC inspection conducted on April 23 through June 3,1995. Our reply to the Notice of Violation is provided below.
VIOLATION:
10 CFR Part 50, Appendix J, Paragraph V.A. requires, in part, that general inspections of containment interior surfaces shall be performed to uncover any evidence of structural deterioration.10 CFR Part 50, Appendix B, Criterion 10,
" Inspection," requires that an inspection program be established to assure that structures, systems, and components will perform satisfactory in service.
Contrary to the above, as of June 3,1995, facility procedures (Operating Procedures Nos. 4029 and 5250) do not include detailed instructions for the generalinspection of the interior surface of the drywell head which is part of 1
tho' containment structure.
This resulted in Vermont Yankee's failure to j
Inspect the drywell head inner surface prior to the performance of the Type "A"
containment integrated leak rate test during the 1995 refueling / maintenance outage.
This is a Severity Level IV violation.
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0271 O
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D VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission Aug0st 11,1995 Page 2
RESPONSE
l Reason for the Violation:
l i
Vermont Yankee does not contest this violation. We have attributed the violation to be the result of an inadequate procedure in that we previously did not consider the
(
interior of the drywell head to be accessible and consequently did not require this inspection in our procedures. We have since compared the requirements stated in
.j Appendix J, Paragraph V.A. and Appendix B, Criterion 10 to OP 4029 " Type 'A' -
d Primary Containment integrated Leak Rate Testing," and agree that prior to the Type -
"A" test, the general inspection of the accessible interior surfaces of the containment structures (drywell & torus) should include the interior of the drywell head.
{
lt was our intention that the inspection performed under Operating Procedure 4029 i
would meet the requirements of 10 CFR Part 50, Appendix J, Paragraph V.A. OP _
j 4029 also requires that the Primary Containment inspections performed under OP-5250 " Maintenance / Inspection of Primary Containment interior Surfaces" be reviewed to ensure there were no repairs made that could affect the Type "A" test and/or require reporting under Appendix J, Paragraph V.A. OP 5250 was never intended to i
be the document used to satisfy the requirements of 10 CFR Part 50, Appendix J, l
Paragraph V.A.
A general inspection of the accessible containment surfaces (including the exterior of the drywell head) was performed prior to the 1995 Type "A" test in accordance with OP 4029. An informal inspection of the drywell head interior is performed each outage by the Maintenance Department during drywell head disassembly and reassembly.
j Immediate Corrective Actions:
Based on the Engineering inspection (of the drywell head exterior) per our procedure, l
OP. 4029, the informal Maintenance inspection, the inspection performed by the Operations Department after the Type "A" test, and the successful completion of the l
Type "A" integrated leak test, Vermont Yankee has determined there is no evidence l
of structural deterioration and that there is reasonable ass urance that this structure will perform satisfactorily in service.
-l Continuina Corrective Actions:
Our procedure (s) will be revised to ensure that a general inspection of the drywell j
head interior is performed prior to the performance of Type "A" integrated leak rate i
test in accordance with Appendix J, Paragraph V.A. In the future. We expect these procedures will be revised by January 1,1996.
-1
VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclqar Regulatory Commission August 11,1995 Page 3 An Event Report (Vermont Yankee's Corrective Action Program) has been initiated to further evaluate this event. A Root Cause Analysis will be performed to determine why the previous containment inspections did not include the interior of the drywell head.
This Event Report will be completed by October 1,1995.
We trust that the enclosed information is satisfactory; however, should you have any questions or desire additional information on this issue, please do not hesitate to contact us.
Sincerely, VERMONTYANKEE NUCLEAR POWER CORPORATION l
wh0 James P. Pelletier Vice President, Engineering cc:
USNRC Regional Administrator, Region i USNRC Resident inspector, VYNPS USNRC Project Manager, VYNPS STATE OF VERMONT
)
)ss WINDHAM COUNTY
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1 Then personally appeared before me, James P. Pelletier, who, being duly sworn, did state that he is Vice President.
Engineering, of Vermont Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoing j
document in the name and on the behalf of Vermont Yankee Nuclear Power Corporation, and that the statements therein are j
true to the best of his knowledge and belief.
l A
A h Ih. W h f/A -
Gina M. Vitello, Notary Public
-l My Commission expires February 10,1999 I
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