ML20238F740
| ML20238F740 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/10/1987 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| FVY-87-92, NUDOCS 8709160315 | |
| Download: ML20238F740 (3) | |
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e-4 YERMONT YANKEE NUCLEAR POWER CORPORATION FVY 87-92 RD 5, Box 169 Ferry Road, Brattleboro, VT 05301 y,g g ENGINEERING OFFICE s
1671 WORCESTER ROAD
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FR AMINGHAM. M ASSACHUSE TTS 01701 TELE PHONE 617-672-8100 September 10, 1987 U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19405 Attp Edward C. Wenzinger, Chief Project Branch No. 3 Division of Reactor Projects
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, NVY 87-133, Inspection Report 50-271/87-12, dated 8/21/87
Dear Sir:
Subject:
Response to Inspection Report 50-271/87-12 During an NRC routine resident safety inspection conducted by Mr. D.R.
Haverkamp on June 2-July 31, 1987, a violation of NRC requirements was iden-tified.
In accordance with the " General Statement Policy and Procedure for NRC Enforcement Actions", 10CFR Part 2, Appendix C (Enforcement Policy 1986), the violation is listed below.
Technical Specification 3.2.J was issued by Amendment 96 on August 11, 1986 and requires that the Toxic Gas Monitoring System be operable whenever the Control Room is required to be manned, with trip settings as specified in Table 3.2.7.
Table 3.2.7 requires that a trip setting of 5 ppm be established for the redundant chlorine gas detector channels.
Contrary to the above, for a period of plant operations from August 11, 1986 until July 23, 1987, the redundant chlorine gas detection channels of the Toxic Gas Monitoring System had non-conservative trip setpoints at 7 ppm. The Control Room was required to be continually manned during this period due to the operational status of the plant.
It is noted that, subsequent to NRC inspection of the area on July 23, 1987, actions were taken by licensee personnel to estalish 5 ppm trip set-points in the redundant chlorine gas detection channels.
This is a Severity Level IV Violation (Supplement I.D.).
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear' Regulatory Commission September 10, 1987 Page 2 I
RESPONSE
ine FSAR states that the purpose of the chlorine analyzer is to monitor and protect the Control Room operators from a Control Room atmosphere of 15 ppm 1
chlorine. The limit is based on thc tire the detectable limit at the outside duct and the toxicity limit inside the Control Room are reached following a chlorine accident near the Vermont Yankee plant.
An FSAR setooint of 5 ppm was selected with a subsequent Technical Specification limit of 5 5 ppm. However, from the engineering analysis of a chlorine accident, a theoretical limit of 13.5 ppm would have been acceptable.
L Considering the limitations of the instrument, accuracy and response time, a 9 ppm limit was the absolute upper value for the monitor.
This yielded a 4 ppm i
l margin from the design limit to the monitor setpoint.
Therefore, since the current procedural alarm setpoint was 2 ppm over the FSAR/ Technical Specification l
limit, the effect was not significant. Consequently, if a chlorine accident had occurred, the Control Room operators would not have been affected. Thus, the health and safety of the public was not endangered.
REASON FOR VIOLATION The root cause of the event is that the Vermont Yankee tracking programs did not ensure that station procedure reviews were completed prior to incorporating j
l an approved Technical Specification amendment. As a result, the calibration l
procedure did not specify the correct value for the chlorine analysis setpoint in the Toxic Gas Monitoring System.
Licensee Event Report (LER) 87-03, detailing the occurrence, was submitted to the NRC on August 2, 1987.
CORRECTIVE ACTIONS The following actions have been completed and the Toxic Gas Monitoring System for chlorine is now in full compliance with the Technical Specifications.
1.
The Toxic Gas Monitor calibration procedure has been revised to reflect the alarm / initiating setpoint for the chlorine analyzer to 3.75 + 0.25 ppm.
This revision accounts for instrument tolerances and drift in order to satisfy the Technical Specification requirements.
2.
The existing in-house tracking program / procedure was changed in May 1987 (i.e., before this event occurred) as a result of an in-house Quality Assurance audit finding. The audit identified that no apparent administra-tive process or controls were in place to assure the timeliness or tracking of procedure reviews as a result of Technical Specification amendments.
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l VERMONT YANKEE NUCLEAR POWER CORPORATION l
U.S. Nuclear Regulatory Commission September 10, 1987 Page 3
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3, Upon receipt of an approved license amendment from the NRC, Vermont Yankee will administrative 1y establish a date the amendment is to become effective, allowing time for procedure reviews and revisions to be approved.
Procedure reviews will also be tracked by the in-house tracking program.
LONG TERM CORRECTIVE ACTION The station Procedure Writers Guide will be revised by November 1, 1987 to incorporate a specific review of the applicable setpoints. This review will assure that new/ revised setpoints are established and will consider expected instrument drift and tolerances to assure that Technical Specification require-ments are met.
l In summary, we believe that the corrective measures taken address this con-cern. We trust the information provided is acceptable, however, should you have further questions or desire additional information, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION dw----
Warren P.
urphy Vice Pres 1 dent an Manager of Operations
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