ML20153C609
| ML20153C609 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/17/1998 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Maret G VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| 50-271-97-11, 50-271-97-12, 50-271-98-04, 50-271-98-4, NUDOCS 9809240146 | |
| Download: ML20153C609 (2) | |
See also: IR 05000271/1997011
Text
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September 17,1998
' Mr. Gregory A. Maret
Director of Operations
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. Vermont Yankee Naclear Power Corporation
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185 Old Ferry Hoad
Brattleboro, Vermont 05301
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SUBJECT:
NRC INTEGRATED INSPECTION REPORTS 50-271/ 97-11,50-271/ 97-12,
50-271/ 98-04 AND NOTICES OF VIOLATION
Dear Mr. Maret:
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. This It' c r refers to several letters from you that were written in response to the subject
inspecs
reports and associated Notices of Violation, including: your January 10,1998
correspondence responding to our December 23,1997 letter; your March 9,1998
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correspondence responding to our February 6,1998 letter; and your July 2,1998
- correspondence responding to our June 4,1998 letter.
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Thank you for informing us of the corrective and preventive actions documented in your
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letters. These actions will be examined during future inspections of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
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Original Signed By: R. Summers
Curtis J. Cowgill, Ill, Chief
Reactor Projects Branch 5
' Division of Reactor Pro lects
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Docket No. 50-271
cc w/o cy of Licensee Response Letter:-
-R. McCullough, Operating Experience Coordinator - Vermont Yankee
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G. Sen Licensing Manager, Vermont Yankee Nuclear Power Corporation
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cc w/cy of Licensee Response Letter:
D. Rapaport, Director, Vermont Public Interest Research Group, Inc.
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D. Tefft, Administrator,' Bureau of Radiological Health, State of New Hampshire
Chief, Safety Unit, Office of the Attorney General, Commonwealth of Massachusetts
-- D. Lewis, Esquire
G. Bisbee, Esquire
J. Block, Esquire
T. Rapone, Massachusetts Executive Office of Public Safety
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D. Kct.;, Citizens Awareness Network (CAN)
M. Daley, New England Coaktion on Nuclear Pollution, Inc. (NECNP)
State of New Hampshire, SLO Designee
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State of Vermont, SLO Designee
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Commonwealth of Massachusetts, SLO Designee
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Mr. Gregory A. Maret
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"/ermont Yankee
Distribution w/cy of Licensee Response:
Region i Docket Room (with concurrences).
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PUBLIC -
Nuclear Safety Information Center (NSIC)
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'NRC Resident Inspector
H. Miller, RA/W. Axelson, DRA
D. Screnci, PAO
C. Cowgill, DRP-
R. Summers, DRP
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C. O'Daniell, DRP
B. McCabe, OEDO
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' C. Thomas, NRR (COT)
R. Croteau, NRR
R. Correia, NRR
F. Talbot, NRR
inspection Program Branch, NRR (IPAS)
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DOCUMENT NAME: G:\\ BRANCH 5\\RPLY-LTRWY-RPY.898
Ta recobre a Qy of this document, Indicate in the box: 'C' = Copy without attachment / enclosure
"E" = Copy with attachment / enclosure
'N'=
_ No copy
OFFICE
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NAME
CCowgill
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DATE
09/29/98
08/ /98
08/ /98
08/ /98
08/ /98
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OFFICIAL RECORD COPY -
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NUCLEAR POWER CORPOR
VERMONT YANKEE
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185 Old Ferry Road, Brattleboro, VT 05301 7002
(802) 257-5271
July 2,1998
U.S. Nuclear Regulatory Commission
ATTN: DocumentControlDesk
Washington, D.C. 20555
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Reference: (c)
Letter, U'SNRC to VYNPC, NRC Inspection Report 50-271/98-04 and Notice
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of Violation, NVY 98 80, dated June 4,1998
Subject:
Vermont Yankee Nuclear Power Corporation
License No. DPR-28 (Docket No. 50-271)
Renly to e Notice of Violation - NRC Insnection Report 50-271/98-04
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This letter is written in response to Reference (a), which documents the findings of an inspection
conducted from March 15 to May 2,1998. The inspection identified two violations of regulatory
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requirements. Our response to the violations is provided below.
VIOLATION A
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Technical specification 6.5, " Plant Operating Procedures," section A, states that, " Detailed
written procedures. . . covering areas written below shall be prepared and approved. All
procedures shall be adhered to." Item 6 of the listed areas is, " surveillance and testing
requirements."
Technical specification 4.10, " Auxiliary Electrica! Power Systems
Surveillance Requirements," section A.2, " Battery Systems," includes the requirement to
conduct performance tests of the main station batteries.
Contrary to the above, oa April 1,1998, while performing the appivved written procedure
for conduct of the "A" main station battery performance test, Operating Procedure OP
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4215," Main Station Battery Performance / Service Test," the procedure was not adhered to,
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la that steps 53,5.4, and 5.5 were not performed in the sequence that was required by the
procedus e.
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This is a Severity Ievel IV violation (Supplement I).
RESPONSE:
Reason For The Violation:
Vermont Yankee does not contest this violation. Personnel error resulted in the failure to
sequentially follow the steps, as written, in a Technical Specification required surveillance
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VERMONT YANKEE NUCLEAR POWER CORPORATION
BVY 98-92 / Page 2
procedure. Specifically, two steps of the procedure were performed but not signed off and
procedural steps were implemented simultaneously and out of squence. This is contrary to
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AP 06',7 " Plant Procedures" which requires that a " continuous-use' procedure be in hand during
- performance of the procedure. AP 0037 also requires reading each step prior to performing that
' step, performing each step in the sequence specified, and where required, signing off each step
. before proceeding to the next step. This procedural noncompliance resulted in a direct short of
the "A" main station battery bank.
Corrective Steos That Have Been Taken and the Results Achieved:
- In response to this event, a level-one event report (the highest event level per Vermont Yankee's
corrective action program procedure) was generated. A task force was formed to investigate the
event and to perform the root cause evaluation. In addition, work on energized electrical
equipment was suspended, pending an assessmert of the event.
He evaluation documented in the event report detailed several corrective actions. However, with
regard to the procedural noncompliance, management met with the workers on site iterating the
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requirement for procedural adherence by providing examples of the safety consequences of
failing to adhere to procedures. In addition, on site electricians read and signed INPO SER-2-98
regarding recurring electrical shock events in the industry.
Vermont Yankee's first line supervisors were provided with a copy of the INPO Human
Perform.mce Fundamentals " Leadership Tool Kit". This tool kit, when incorporated into
departmental work processes, would reduce the chance of human error.
Following the above actions, the remainder of the work on energized electrical equipment and
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personnel risk significant work received additional management over.;ight and was performed
without incident.
It should be noted that in addition to the above corrective actions, the procedures utilized for
testing the main station and ECCS battery banks were revised to provide greater clarity and
information to the workers. They were also revised to provide a more rigorous structure to the
- steps that make the connections to and from the battery terminals. These procedure changes were
made and reviewed by the workers prior to the surveillance procedurer being used for the
remaining battery tests during the refueling outage.
Corrective Steos %at Will Be Taken to Avoid Further Violations:
The corrective actions described above are complete and are considered sufficient to prevent
further recurrence of such an event.
Date When Full Comoliance Will Be Achieved:
Full compliance was achieved on April 4,1998, when the recharge of the "A" main station
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VERMONT YANKEE NUCLEAR POWER CORPORATION
BVY 98-93 / Pcge 3
VIOLATION B
The Vermont Yankee Physical Security Plan, section 4.3, " Vital Area Barriers,"
paragraph k, states that,"All entrances to Vital Areas. . . are locked or guarded. . ."
Contrary to the above, on March 31, 1998, an entrance pathway to the reactor building
vital area was identifled that was neither locked nor guarded.
This is a Severity Level IV violation (Supplement III).
RESPONSE:
Reason For The Violation:
Vermont Yankee does not contest th:s violation. The reason for the violation has been the
acceptance of the subject configuraf an as a suitable vital area barrier and as such was not
considered an entrance.
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The basis for Vermont Yankee's long standing acceptance of the barrier configuration was
founded on the following aspects, unique to this barrier:
1. The barrier, by reason ofits operational purpose, design and remote location, is not intended
for use as a normal point of access into, or out of, the vital area.
2. In its fixed configuration, the barrier, comprised of a solid steel plate weighing several
hundred pounds, presents neither an opening nor a penetration through which personnel or
material can pass.
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3. He physical appearance of the barrier is that of a scaled steel enclosure and, in its fixed
configuration, does not offer to the observer a location for normal passage, as through a
doorway or window.
4. The access pathway leading to the barrier was felt to be tortuous in nature. The barrier is
located on the inboard side of an elevated shelf, approximately fourteen feet above floor
level. The barrier is not visible from f!vor level. It can only be seen when the observer is on
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the shelf within several feet of the barrier itself. This is due to low lighting conditions and
obstructions between the barrier and the outboard edge of the shelf. He barrier is reached
after gaining access to the elevated shelf, crossing the shelfin a crouched position, in close
quarters, with a low ceiling overhead and, all the while, straddling 2 variety of obstructions.
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S. Once the barrier is reached, there is limited space for maneuvering. He heavy steel plate
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must be separated away from its mount, re noved and re-positioned to efTect an opening.
6. Lasdy, during plant operation, the area approaching and surrounding the barrier for some
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distance is environmentally and radiolcgically hazardous.
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Vermont Yankee agrees that during periods of non-operation environmental and radiological
hazards are not sufficiently present to be counted as a deterrent to barrier access. Vermont
Yankee also agrees that a compromise of the barrier, were it achieved via the difficult process of
removing an repositioning of the steel plate, would provide an opening sufficient enough to
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permit access to the vital area.
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VERMONT Y ANKEE Nuct EAR POWER CORPORATION
BVY 98-92 / Page 4
Corrective Steos That Have Been Taken and the Results Achieved:
Compensatory actions, in accordance with plant security procedures, were hiitiated on
April 1,1998, immediately upon identification of the' barrier's potential vulnerability.
Compensatomy measures remained in place during the installation of an additional barrier which
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surrounds the existing barrier. He additional barrier, w!.ich satisfies the requirements of
Vermont Yankee's Physical Security Plan, represents an increased impediment to unauthorized
access and is a signincant enhancement to the existing barrier. The development of these long
term corrective actions were discussed with the inspector prior to their completion and before the
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relief of compensatory measures on May 26,1998.
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Corrective Steos That Will Be Taken to Avoid Further Violations:
The installation of an additional barrier surrounding the existing barrier provides a significant
enhancement and an on-going deterrence against unauthorized access.
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' Date WhgtEu!! Comoliance Will Be Achieved:
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Vermont Yankee achieved full compliance on April 1,1998, when compensatory measures were
initiated, following identification of the potential vulnerability of the barrier. On May 26,1998
upon installatien of an additional permanently installed barrier, compensatory measures were
relieved.
We trust that the enclosed information is responsive to your concerns. Should you have any
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questions, please contact Mr. Romas B. Silko at (802) 258-4146.
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Sincerely,
VERMCNT YANKEE NUCL. EAR POMR CORPORADON
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Gregory A. Maret
Director of Operations
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cc:
US2!h0 Region l' Administrator
- USNRC Resident Inspector-VYNPS
USNRC Project Manager--VYNPS
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-Vermont Department of Public Service '
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VERMONT YANKEE
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NUCLEAR POWER CORPORATION
185 Old Ferry Road, Brattleboro, VT 05301 7002
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(802) 257-5271
March 31.1998
U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington, D.C. 20555
Reference:
(a)
Letter, USNRC to VYNPC, NRC Inspection Report 50-271/97-12 and
Notice of Violation. NVY98-29 dated March 3,1998
Subject:
Vermont Yankee Nuclear Power Station
License No. DPR 28 (Docket No. 50 271)
Response to Notice of Violation: NRC Inspection Report 50-271/9712
This Ic.tter is written in response to reference (a), which documents that certain c,f our activities
were uct conducted in full compliance wit NRCrequirements. This violation, classified as
' Severity Level IV, was identified during a NRC inspection conducted from December 7,1997 to
January 24,1998. Our response to the violation is provided below.
Statement of Violation (50-271/9712)
Vermont Yankee Technical Specification 6.5.A " Plant Operating Procedures, " states that detailed
written procedures shall be prepared, approved and adhered to includingfire protection program
implementing procedures. The Vermont Yankee Safe Shutdown Capability Analysis, revisto., S,
dated November 19,1996, identiped the High Pressure Coolant Injection (HPCI) system as a safe
shutdown system, and l'udicated tat the wall that separates the HPCI roomfrom the torus room
shall be maintained as apre barrier in accordance with Appendix A ofBranch Technical Position
APCSB 9.51, " Guidelines for Fire Protectionfor Nuclear Power Plants. "
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Contrary to the above, the HPCI toom Appendix A pre barrier wasfound to be inoperable on
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January 13,1998, in that the closure mechanismfor the associated automatic self-closingpre
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door was inoperable and the door would not close.
PsESPONSE
Reason for the Violation
Vermont Yankee Nuclear Power Corporation does not contest this violation. The cause of this
violation was an inadequate design of the automatic self-closing fire door. This door was installed
during original construction. The drop weight and cable attached to the back of the door provides
motive force to pull the HPCI room door to a closed position when a fusible link is activated. The
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VERMONT Y ANKEE NUCLEAR POWER CORPORATION
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Docket No.50-27i
Page 2 of 3
cable passes from the door through a pulley to the weight. The cable was observed by a NRC
inspector to be out of the pulley and res'ing on the pulley axle.
Trouble shooting of this door on January 13,1998 determined the most likely cause of the cable
coming off the pulley was the combination of pushing the door further open than the normal full
open position, the closure cable length and the size of the cable clamping devices. When the door
was pushed further open than its normal full open position, the short cable run to the pulley
allowed the closest cable clamp to contact the pulley and ride up on the pulley rim. Once in this
position it could easily fall out of the pulley and come to rest on the pulley axle. This rendered the
door automatic closure mechanism inoperative.
The automatic feature of the HPCf fire door is tested semi-annually in accordance with the
applicable surveillance procedure and was last tested satisfactorily in October 1997,
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Immediate Corrective Actions Taken and Results Achieved
(1)
Following discovery, the HPCI door was tested to determine if the door would self-close
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in the as-found condition. The door failed to shut. Troubleshooting was initiated to
determine the cause and possible corrective actions. Once the cable was placed back into
the pulley, the door closed properly.
(2)
Immediate corrective action included attempts to replicate the condition causing the cable
tojump the pulley. This involved pushing the door past the full open position. After
several trials, it was noted that it took one particular orientation of the large cable clamps
riding up on the pulley to cause the cable to fall out of the pulley.
(3)
Paint was applied to the floor to indicate that this door is a fire door and should not be
interfered with or blocked in any way.
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(4)
The Fire Protection Engineer determined that there were no other fire doors with this type
of automatic closing mechanism in the plant.
(5)
The failure mechanism that caused the door to become inoperable was discussed with the
fire protection staff. This information was provided to increase awareness about off
normal conditions that could be observed and prevented during routine fire protection
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tours.
Actions Taken to Prevent Recurrence
The existing cable clamps will be replaced with smaller, more streamlined crimped cable clamps.
This ;maller clamp will easily be able to travel up into the cable pulley without causing the cable
to jump out of the track. Free travel of the door past the full open position is needed to reset the
door after testing activities or following door actuation. The smaller clamps will provide
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Docket No. 50-271
Page 3 of 3
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additional travel distance without the risk of the cable jumping out of the track. The new cable
clamps will be installed by May 14,1998.
Date When Full Comoliance Will Be Achieved
Compliance was achieved on January 13,1998 when the cable was placed back in the pulley and
the HPCI fire door was verified to perform its intended function.
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Should you have any questions about this matter please contact this office.
Sincerely,
VERMONT YANKEE NUCLEAR POWER CORPORATION
Donald A. Reid
Senior Vice President, Operations
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cc:
,USNRC Region 1 Administrator-
USNRC Resident Inspector . VYNPS
Vermont Department of Public Service
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VERMONT YANKEE
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NUCLEAR POWER CORPORATION
185 Old Ferry Road, Brattleboro, VT 05301 7002
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(802)257 5271
January 22,1998
U. S. Nuclear Regulatory Commission
ATTN: Document ControlDesk
Washington, D.C. 20555
References:
(a)
Letter, USNRC to VYNPC, NRC Inspection Report 50-271/97-11 and Notice of
Violation, NVY 97-185, dated December 23,1997
(b)
VY LER 97-023,"A Component Failure in the Main Generator Protection Circuitry
Results in a Reactor Scram", BVY 97-178, dated December 23,1997
Subject:
Vermont Yankee Nuclear Power Station
License No. DPR-28 (Docket No. 50-271)
Response to a Notice of Violation - NRC Inspection Report 50-271/9-11
This letter is written in response to reference (a), which documents that certain of our activities were not
e m iuctM in full compliance with NRC requirements. This violation, classified as Severity Level IV, was
identified during an NRC inspection conducted from October 31 to December 6,1997. Our response to the
violation is provided below.
Statement of Violation (50-271/97-11-01)
Technical Specifcation 6.5, " Plant Operating Procedures, " states that detailed written procedures,
involving both nuclear and non-nuclear safety, shall be prevared, approved, and adhered to covering the
areas ofpreventive andcorrective maintenance operations which couldhave an effect on the safety ofthe
reactor.
Contrary to the above, plant auxiliary operators were implementing an unapproved (by Vetmont Yankee)
Vermont Electric Power Company (VELCO) switching order on November 25,1997 to open the 345 KV
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Scoble Line No. 379-3 disconnects when at 6:48 A.M. an automatic reactor scram resultedfrom the
manipulation ofthe disconnects while the line was energizedper the switching sequence.
RESPONSF
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Reason for the Violation
Vermont Yankee does not contest this violation. The sequence of events that led to an automatic reactor scram started with the cited violation. The failure of a non. safety related turbine protection device actually
caused the scram when it failed to properly reset after the electrical transient induced by the manipulation of
the electrical disconnects in the switchyard.
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Docket No. 50-271
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The contributing causes to the event in the switchyard are as follows:
1.
The responsibility of the Control Room Shift Supervisor to oversee switchyard activities wa
not well defined. Excessive reliance was placed on the technical expertise of the Vermont
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Electric Company (VELCO) to provide an appropriate switching sequence without any
explicit VY review and approval. These process deficiencies resulted in a missed
opportunity to review the switching sequence and question the appropriateness of
uncoupling the motor operated disconnect drive motor
2.
There was a lack of knowledge and understandmg on the part of the plaat operations staff
about some of the potential risks involved in the uncoupling or coupling of tnotor operated
disconnects.
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Corrective Steos That Have BeenTaken And The Results Achieved
1.
The operations staff placed the plant in a nonnal shutdown configuration.
2.
An inspection of the affected motor operated disconnect was performed to determme if the
are had caused any equipment damage. The inspection revealed no equipment damage.
3.
The Operations Manager made a presentation of the particulars of the event to all crews.
4.
Agreements were reached with VELCO for the Vermont Yankee control room to obtain
advance copies of VELCO tagouts for normal maintenance and routine operations for review
and concun nce.
5.
An operating standard on switchyard operations has becri implemented. It dermes Vermont
Yankee management's expectations for the level of revimvs, oversight, uxi authority the
Vermont Yankee Shift Supervisor is expected to exhibit over switchyard activities. It also
provides the expectations for pre-job briefs and communications requirements for
switchyard activities.
Corrective Steos That Will Be Taken To Avoid Further Violations
In addition to implementing an operating standard for the switchyard and reaching agreement on advanced
notice for switching with VELCO, the following actions wiU be taken:
1.
Vermont Yankee will incorporate the Switchyard Operations Standard into the 345 and
115 KV operating procedures. Expected completion date is March 15,1998.
2.
Vermont Yankee will conduct Auxiliary Operator refresher training on the rnotor
operated disconnect rnotor uncoupling and locking evolution. The training will
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AR POWER CORPORATION
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Docket No. 50 271
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include a discussion on the potential impact of operating disconnects when one
side of the disconnect is energized. Vermont Yankee will also ensure that
Auxiliary Operator initial training includes this issue. Expected completion date is
July 1998.
3.
Vermont Yankee has conducted discussions with VELCO about the practice of
uncoupling the motors from motor operated disconnects and locking the operating
mechanisms. Since the objective is to achieve personnel safety, reliance on the
strict control imposed by the Vermont Yankee danger tagging system may be a
logical alternative to physically uncoupling and locking the mechanisms. An
evaluation will be performed to identify options which may make uncoupling
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unnecessary. Expcted completion date is September 1998.
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Date When Full Comoliance Will Be Achieved
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Full compliance will be achieved on March 15,1998 when the 345 and i 15 IG' operating procedures are
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revised to incorporate the Switchyard Operations Standard.
We trust that the enclosed information is responsive to your concesas, however, should you have any
questions or require additional information, please contact us.
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Sincerely,
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VERMONT YANKEE NUCLEAR FoWER CORPORATION
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Donald A. Reid
Senior Vice President, Operations
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cc:
USNRC Region 1 Administrator
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. USNRC Resident Inspector -VYNPS
USNRC Project Manager-VYNPS
Vermont Department of Public Senice
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