ML20236Q880
| ML20236Q880 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236Q872 | List: |
| References | |
| 50-271-98-80, EA-98-333, NUDOCS 9807210102 | |
| Download: ML20236Q880 (4) | |
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NOTICE OF VIOLATION Vermont Yankee Nuclear Power Corporation Docket No:
50-271 Vermont Yankee Nuclear Power Station License No: DAR-28 EA No:
98-333 During an NRC inspection conducted on May 18,1998, through June 5,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, Revision 1, the violations are listed below:
1.
10 CFR 50.59, Changes, tests and experiments, specifies that the licensee may make changes to its facility and procedures as described in the safety analysis report and conduct tests or experiments not described in the safety analysis report without prior Commission approval, provided the change does not involve a change in the technical specifications or an unreviewed safety question (USQ); and requires the licensee to maintain records of changes in the facility, including written safety evaluations providing the bases for the determination that the change does not involve an USQ.
Contrary to the above, in 1996, the safety evaluation performed by the licensee to support a temporary modification to the Main Control Room HVAC system, as described in section 10.12 of the FSAR, did not provide a sufficient basis to determine that the change did not involve an USQ. Specifically, the licensee discovered the Control Room HVAC would not function as expected on the loss of nonsafety-related instrument air. A temporary modification (TM 96-043) was installed to allow for operation of the chilled water valves and dampers during a loss of instrument air and procedures were revised to help mitigate the degraded condition. The safety evaluation for the temporary modification failed to address the impact of required operator actions.
This is a Severity Level IV violation (Supplement 1).
2.
10 CFR Part 50 Appendix B, Criterion XVI, Corrective Action, states that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. in the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Vermont Yankee (VY) administrative procedure AP 0009, Revision 3, Event Report, describes the licensee's process used to assess events resulting in adverse conditions, problems or deficiencies affecting VY to initiate the appropriate level of corrective action. Section C states, " Operability concerns resulting from non-conforming plant equipment are assessed using the BMO [ Basis for Maintaining Operation] process to determine the impact of continued operation with potentially degraded equipment." Section J requires that the event report shall have a list of all root and contributing causes.
9007210102 980716 1
PDR ADOCK 05000271 G
2 Contrary to the above, between 1989 and June 5,1998, Vermont Yankee failed to identify and adequately correct a condition adverse to quality,in that the control room ventilation system was subject to a f ailure on loss of nonsafety instrument air.
VY did not recognize in the evaluation performed in response to Generic Letter 88-14, " Instrument Air Supply Problems Affecting Safety-Related Equipment," that the control room ventilation system dampers and chilled water valves were subject to failure on loss of nonsafety instrument air. The licensee identified this condition on October 18,1996; however, the root cause evaluation for the condition was not comprehensive in that a review for similar failures was not conducted. Additionally, VY failed to perform the required operability determination when the condition was identified in 1996.
This is a Sev#+y Level IV violation (Supplement 1).
3.
10 CFR Part 50.73(a)(2)(v)(D) states that licensee shall submit a Licensee Event Report (LER) within 30 days for any condition that alone could have prevented the fulfillment of the safety function of systems that are needed to mitigate the consequences of an accident.
Contrary to the above, on or before June 5,1998, the licensee failed to submit the required report to the NRC as required above, in that on August 19,1996, VY found that the loss of the nonsafety-related control air alone would have rendered the control room ventilation system, which is needed to mitigate an accident, degraded and no Licensee Event Report was submitted to the NRC.
This is a Severity Level IV violation (Supplement I).
4.
10 CFR Part 50 Appendix B, Criterion 111, Design Control, states, in part, that measures shall be established for the identification and control of design interfaces.
These measures shall include the revision of documents involving design interfaces.
Procedure AP 6007, Rev. O, dated October 31,1997, " Procedure for the Control, Update, and Maintenance of Vermont Yankee Design Basis Documents,"
implements these measures and indicates the purpose of the Design Basis Document (DBD) Program was to capture and organize the current Design, Operational and Licensing Basis of Vermont Yankee. Section 4 of the DBD, describes System Interfaces. Procedure AP 6007 requires that all pending or interim change notices be documented and distributed to all controlled copies of the affected DBDs and copies of the change notices be maintained with each controlled copy of the associated DBD.
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3 Contrary to the above, on or before June 5,1998, the licensee failed to implement the measures established by AP 6007 to control design interfaces in that (1) the design basis document for the 4160 and 480 Volt AC Systems was ;ssued without any notices prepared to identify the need for changes to the DBD resulting from revisions to the Motor Protection Guidelines and the Breaker Coordination Study, and (2) the Emergency Diesel Generator System DBD was issued without a pending change associated with frequency requirements.
This is a Severity Level IV violation (Supplement 1).
5.
10 CFR 50.54(a) states, in part, that " Changes to the quality assurance program description that do reduce the commitments must be submitted to the NRC and receive NRC approvm!.nrinr to implementation.
The Yankee Operational Quality Assurance Program (YOQAP) was approved by the NRC with an exception regarding use of Regulatory Guide 1.26 for classification of structures, components, and systems. Since 1982, Appendix B of the YOQAP, section Vll.A, states " Vermont Yankee shall continue to classify structures, components and systems in accordance with ANS-22, Draft No. 4, i!ev.1, May 1973,' Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants', as in the past." The Vermont Yankee Safety Classification Manual is used to implement this quality assurance program commitment.
Contrary to the above, in July 1988, Vermont Yankee reduced commitments contained in their NRC-approved QA program (YOQAP), without prior NRC approval, by using ANS-52.1,1983,' Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants', which contained a higher threshold for safety classification of SSCs than the draft issue of the ANS-22 standard referenced in the approved QA program. In addition, Vermont Yankee failed to evaluate the effect of using the issued standard on SSCs that had already been classified.
This is a Severity Level IV violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Vermont Yankee Nuclear Power Corporation is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a l
copy to the Regional Administrator, Region 1, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter j
transmitting this Notice of Violation (Notice). This reply should be clearly marked as a l
" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
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4 If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withhold-ing (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at King of Prussia, Pennsylvania this 16th day of July,1998 l
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