ML20096D207

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Responds to NRC Re Violations Noted in Insp Rept 50-271/92-04 on 920211-0306.Corrective Actions:Alarm Response Sheet Revised to Remove Misleading Statements
ML20096D207
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 04/16/1992
From: Murphy W
VERMONT YANKEE NUCLEAR POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20096D188 List:
References
NUDOCS 9205150140
Download: ML20096D207 (3)


Text

_ _ _ _ -

VERMONT YANKEE NUCLEAR POWER CORPORATION

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April 16,1992 h'

U.S. Nuclear Regulatory Commission ATTN:

Do:ument Control Des'<

Washington, DC 20555

References:

a)

License No. DPR 28 (Docket No. 50-271) b)

Letter, USNRC to VYNPC, inspection Report 92 04 (NW 92 42), dated 3/17/92 c)

Licencee Event Report 92-004, dated 3/20/92

Dear Sir:

l

Subject:

Inspectior' Report 92 04, Reply to Notice of Violation This lettef is written in response to Reference b), which indicates that one of our activities was not conducted in full compliance with NRC requirements. The apparent violation, classified as a Severity Level IV, was identified during a routine safety inspection conducted on February 11 March 6,1992, in addition, Reference b) requested information relative to on shift reporting expertise. Our response to thou items is provided below.

VIOLATION

" Technical Specification 6.0 requires, in part, that administrative procedures shall be adhered to. Vermont Yankee administrativo procedure AP 0156, Rev.

16, " Notification of Significant Everits" requires, in part, that if any single train systems such as the high pressure ccdant injection (HPCI) system f all, or are found degraded in such a manner that it would not perform its intended function, then it is reportable to the NRC as a 10 CFR 50.72 4-nour report.

Vermont Yankee administrative proceduro AP 0010, Rev. 22, " Occurrence Reports / Notifications and Reports Due" requires M part, that the Engineering Support Supervisor immediatelyinform the Shift Suporvisor if a more restrictive notification is required.

920515o140 920506 PDR AD0CK 05000271 j

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April 16,1992 Page 2 Contrary to the above, on February 20,1992, the Sh;ft Supervisor failed to effectively implement the requirements of AP 0156 requiring the ident!!! cation of the HPCI system in a degraded status and to initiate a subsequent event report to the NRC; and on February 24, 1992, the Engineering Support Supervisor failed to immediately notify the Shift Supervisor a: required by AP 0010 that the HPCI system was in a degraded status following his determination that the event was reportable. On February 26,1992 Vermont Yankee notified the NRC that the event was reportab!c in accordance with 10 CFR 50.72 "

i This is a Severity Level IV Violation (Supplement I)

RESPONSE

The results of our review indicate that the notification was missed duu to a 4

combination of a procedural inadequacy and personnel error. The alarm responso sheet (ARS) in effect at the time of the event implied that if the DC inverter could be reset, then HPCI need not be considered inoperable. This conclualon was in error,_ Because the inverter had tripped, HPCI was not capable of performing it's safety function and therefore a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> repoi

>er 10 CFR 50,72(b)(2)(iii) should have been made. Subsequently, the Operations Supervisor conducted reviews with the other Shif t Supervisors to determine if the misunderstanding was a generic issue. It was determined that the other Shift Supervisors would have recognized HPCI to be inoperable and made the required notification, in addition, an interview with the Shift Supervicor involved revealed that he was aware of the reporting requirement for instances when HPCI was declared inoperable.

To prevent recurrence, the tnllowing corrective actions have, or will occur:

The alarm response sheet has been revised to remove the misleading

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L statements ar:d specifically state that HPCI should be considered i

inoperable anytime the inverter trips, Discussions between the Operations Superviser and the involved Shift

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y Supervisor were conducted to ensure his understanding of 10 CFF. 50.72 l

requirements and the status of HPCI with a tripped inverter.

l At the next Shift Supervisor meeting, the Operations Supervisor will

=

review this incident with the Shift Supervisors and reiterate the need for accurate operability determinations and reporting.

1 i

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o WNW WE WM AR PWR %qPCR AW U.S. Nuclear Regulatory Commission April 16,1992 Page 3 3

e With regard to the AP 0310 issue, the failure of an engineering supervisor to immediately notify the Shif t Supervisor was deterrnined to be a personnel error, The individual Involved, when interviewed, indicated that he was aware of the procedure requirement, but simply overlooked it.

The requirement was discussed with the other engineering supervisors and all Indicated they understood their responsibilities as defined in AP 0010. To ensure that the engineering supervisors were absolutely clear on the requirements, the Engineering Director provided re training to the supervisors on March 24,1992, ADDITIONAL INFORMATION Dr: spite the tact that the specific failures discussed above were deemed to be 4

isolated events, we have taken additional measures to further improvo our event assessment / notification process. The Operations Department will establish the Shift Engineer as the on shift incividual knowledgeable in 10 CFR 60,72 requirements, including the basis for such requirements, and for providing the Shift Supervisor with engineering input.

Previously, training was focused on the specific procedure requirements con'ained in AP 0156.

The overall reporting and operability responsioliity will remain with the Shift Supervisor, To su ) ort this change, appropriate reference material will be placed in the Control Room to assist the Shift Eaineer and crew members in making reportability determinations. Additiontily, the Shif t Engineer init'ai and continuing training programs will be levised to include more 10 CPR 50,72 elements, including related NUREG and industry guidance documents, The reference material will be available in the Control Room by May 1,1992 and the training programs revised and presented by December 1,199;-

We believe that the actions described above address the s,necific incident and resolve any concerns that may have existed about on shif t reporting expertise. Should ycu have any questions about our response, please do not hesitate to contact us.

Very truly yours, i

l Vermont Yankee Nucinar Power Corporation

/ Wl Warren P. fAurphy' q /

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Senior Vice Presiden, Qrprations cc:

USNRC Regional Administrator, Region i USNRC Resident Inspector. VYNPS USNRC Project Manager, VYNPG

.