ML20199L465

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-271/97-05 on 970819

ML20199L465
Person / Time
Site:	Vermont Yankee
Issue date:	11/20/1997
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Reid D VERMONT YANKEE NUCLEAR POWER CORP.
References
50-271-97-05, 50-271-97-5, NUDOCS 9712020031
Download: ML20199L465 (3)

See also: IR 05000271/1997005

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November 20, 1997

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Mr. Donald A. Reid l

Senior Vice President, Operations

Vermont Yankee Nuclear Power Corporation l

RD 5, Box 169 ,

Ferry Road i

Brattleboro, Vermont 05301

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SUBJECT: NRC INSPECTION REPORT NO. 50 271/97 05 REPLY ,

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Dear Mr. Reid:

This refers to your September 18,199' correspondence, in response to our letter dated, l

August 19,1997, regarding Vermont Yankee. This correspondence dealt with inspection

report 50 271/97-05and enclosed Notices of Violation 50 271/97-05 01 and 50 271/97- t

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05-02.

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We have reviewed this matter in accordance with NRC Inspection Manual Procedure

92901," Followup - Plant Operations." Based upon our preliminary review of your staff's

root cause determinations, the associated short and long-term corrective actions appear to

be appropriate. These actiono will be examined during future inspections to assess their

overall effectiveness. l

Your cooperation with us is appreciated.

Sincerely,

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ORIGINAL SIGNEJ BY:

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Curtis J. Cowgill, Ill, Chief i

Projects Branch No. 5 l

Division of Reactor Projects

Docket No. 50 271 / ,

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9712020031 971120 '

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Mr. Donald A. Reid 2

cc w/ encl: '

R. McCullough, Operating Experience Coordinator Vermont Yankee

R. Wanczyk, Director, Safety and Reguln+ory Aff airs

G. Maret, Plant Manager ,

J. Daffy, Licosing Engineer. Vermont Yankee Nuclear Power Corperation  ;

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J. Tilroy, Director, Vermont Public Interest Research Group, Inc.

- D. .tfft, 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 i

J. Block, Esquire  :

T. Rapone, Massachusetts Executive Office of Public Safety ,

State of New Hampshire, SLO Designee

State of Vermont, SLO Designee

Commonwealth of Massachusetts, SLO Designee

D. Katz, Citizens Awareness Network (CAN)

Distribution w/ encl:

Region l Docket Room (with concurrences)

.UBLIC '

Nuclear Safety information Center (NSIC)

NRC Resident inspector

H. Miller, RA/W. Axelson, DRA

D. Screnci, PAO (2) *

G. Morris, DRS

C. Cowgill, DRP

D. Boarde, DRP

Distribution w/enci (VIA E MAIL): i

W. Dean, OEDO

K. Jabbour, NRR

S. Bajwa, NRR

R. Correia, NRR j

F. Talbot, NRR

inspection Program Branch, NRR (IPAS) e

DOCDESK i

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DOCUMENT NAME: G:\ BRANCH 5\NOVR9705.CPC

To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "

E" =

Copy with attachment / enclosure * N" = No copy

OFFICE

NAME

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CJCOWGl".LA

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11/ /97

OFFICIAL RECORD COPY

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Mr. Donald A. Reid 2

cc w/ encl:

R. McCullough, Operating Experience Coordinator Vermont Yankee

R. Wanczyk, Director, Safety and Regulatory Affairs

G. Maret, Plant Manager

J. Duffy, Licensing Engineer, Vermont Yankee Nuclear Power Corporation

J. Gilroy, Director, Vermont Public Interest Research Group, Inc.

D. Teff t, Administrator, Bureau of Radiologice':. alth, State of New Hampshire

Chief, Safety Unit, Office of the Attorney General, Commonwealth of M6ssachusetts

D. Lewis, Esquire

G. Bisbee, Esquire

J. Block, Esquire

T. Rapone, Massachusetts Executive Office of Public Safety

State of New Hampshire, SLO Designee

State of Vermont SLO Designee

Commonwealth of Massachusetts, SLO Designee

D. Katz, Citizens Awareness Network (CAN)

Distribution w/ encl:

Region I Docket Room (with concurrences)

PUBLIC

Nuclear Safety Information Center (NSIC)

NRC Resident inspector

H. Miller, RA/W. Axelson, DRA

D. Screnci, PAO (2)

G. Morris, DRS

C. Cowgill, DRP

D. Bearde, DRP

DistribydQD w/enct (VIA E MAIL):

W. Dean, OEDO

K. Jabbour, NRR

S. Bajwa, NRR

R. Correia, NRR

F. Talbot, NRR

Inspection Program Branch, NRR (IPAS)

DOCDESK

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VERMONT YANKEE ,

NUCLEAR POWER CORPORATION ,

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9 h Ferry Road. Brattleboro. VT 05301-7002

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ENGINEERING OFFICE

$60 MAIN STR(ET

BOLToN. MA 01740

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(608) 77M711

September 18,1997

BW 97117

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United States Nuclear Regulatory Commission

ATTN: Document Control Desk .

Washington, D.C. 20555

References: (a) License No. DPR 28 (Docket No. 50-271)

(b) Letter, USNRG to WNPC, NRC Inspection Report 50 271/97 05 and Notice of

Violation, dated 8/19/97

Subject: Reply to a Notice of Violation . Inspection Report No. 50 271/97 05

This letter is written in response to Reference (b), which documents that certain of our activities were

not conducted in full compilance with NRC requirements. Ther.e violations, classified as Severity Level

IV, were identified during an NRC Inspection conducted from June 1 to JuY 19,1997. Our response

to the violations la provided below.

VIOLATION 1:

Technical Specification 3.7.A.7.b requires that, within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period subsequent to placing

the reactor in the RUN modo following a shutdown, the containment atmosphere oxygen

concentration shall be reduced to less than four percent and maintained in this condition.

Contrary to the above, the reactor was placed in the RUN mode t.t 8:20 p.m. on May 7,1997, but

atmosphere oxygen concentration in the torus alt space remained greater than four percent until

the morning of May 12,1997, a pe lod of approximately four and one half days..

RESPONSE TO VIOLATION 1

Reason For The Violation

Vermont Yankwe does not contest this vlotation.

The root cause of this everst was an inadeque'.e procedure which led to the use of Insufficient nitrogen

purge flowrate resulting in the torus not oeing inerted to less than 4%. Prior to this event the

procedure for inerting the primary ec.itainment was revised to require separate inerting of the

containment drywell and containment torus air volumes. The previous procedure revision allowed

Inerting of the torus and drywell volumes either simultaneously or sequentially.

- GiQ C ? 2KOf0 TJW

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/ VORMONT Y ANKOE NUCLE AR POWER CORPOR ATION

U.S. Nuclear Regulatory Commission

September 18,1997

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Contributing causes of this event, during Initial procedure development and subsequent revisions, were:

1. There was a lack of available technical basis Information which would have f acilitated a more

thorough assessment of tne procedure changes.

2. The failure on the part of the procedure writers and reviewers to obtain all the information

needed to support the procedure changes in the absence of available Information.

Corrective StsDe That Have Been Taken And The Results Achieved

1. Upon determination that oxygen concentrations were greater than technical specification

requirements, a reactor shutdown was initiated.

2. Troubleshooting activities were conducted and no significant primary containment air leaks

were located.

3. Containment inerting was agaln initiated and torus oxygen concentration was restored to less

than four percent.

4. The primary containment operating procedure which provides guidance for containment inerting

was revised as follows;

a. Additional guldance was added for establishing minimum inerting flowrates.

b. Additional guidance was added regarding the time required to inert to technical

specification requirements.

c. Instructions were added for monitoring drywell and torus pressures while inerting.

d. Instructions were added for obtaining grab samples to confirm that an oxygen

concentration of less than four percent has been attained.

5. An event report was initiated to document this event, determine the root cause, and corrective

actions.

Corrective Steo1That Will Be Taken To Avoid Further Violations

1. Vermont Yankee is revising the containment inerting calculation to optimize inerting times and

inerting purge flowrates that reflect the configuration of the nitrogen purge system and the

primary containment. This revision will provide a documented basis for inerting the drywell and

the torus volumes. This is expected to be complete by Nnvember 1997.

2. Based on the revised containment inerting calculation, Vermont Yankee will revise the primary

containment operating procedure and supporting design documents as necessary. This IP

expected to be complete by January 1998.

3. The ongo!w Design Basis Document (DBD) project will provide additional and more easily

retrievable d4 sign Information and beludes a validation of design requirements against

applicable implementing procedures. In addition, the procedure change process will be revised

to require the review of DBDs in addition to other reviews, to support any procedure changes.

This is expected to be complete by January 1998.

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VERMONT YANKEE NUC1. EAR POWER CORPOR ATION

U.S. Nuoloar R*gulatory Commission

September 18,1997 ,

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4. The event report will be provided to the Training Depattment for review by the Operations and

Engineering curriculum committees for inclusion as a lessons learned case study to reinforce

the need to verify or obtain technical lnformation to support procedure development or revision.

This is expected to be complete by April 1998.

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Date When Full.Com9tlance Will De Achieved ,

Full compliance was achieved on 05/12/97 when torus oxygen concentration was returned to less than

four percent.

YlOLATlON 21

10 CFR 50, Appendix S, 'Ouality Assurance Criteria for Nuclear Power Plants and Fuel

Reprocessing Plants,' Critorion XVI, ' Corrective Actions ' states that, " measures shall be .

established to nasure that conditions. adverse to quality, such as failures, malfunctions,

deficiencies, deviations, defective material and equipment, and non conformances are promptly

identitled and corrected."

Contrary to the above, during the period June 1 to July 19,1997, the inspectors substantiated

that appropriate measures were not being implemented to assure prompt identification and ,

correction of tsoveral conditions adverse to quality, including:

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1. five seismic hangers in the containment air dilution system that were found not to be

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property adjusted;

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l 11. e ono-quarter inch gap that was found between the end battery cell and the seismic

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support rock for one of 18 groups of cells in the "A" urcinterruptible power supply i

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battery

lil, a conduit to class 1E junction box B 504 SI that was found to be missing the first unistrut

clamp from the junction box, and class 1E conduit 11188E S11 that was missing two

adjacent unistrut clamps; and,

iv. cracked caps that were found on the positive terminal of four celle in the un interruptible

power supply batteries indicating deterioration of the terminsi's electrolyte seals.

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RESPONSE TO VIOLATION 2

Respon For The Ylolation

Vermont Yankee does oct contest this violation.

The conditions identified in the inspection report indicate that certain of our processes have a '

programmatic weakness in that they rio not force the complete restoration of the plant Systeins,

Structures and Components (SSCs) from maintenance and construction activities. In addition, we have >

determined that the threshold for questioning and identifying potentiel concerns and deviations from

structural, environmental and housekeeping requiremente was too high. The conditions identified by

the NRC inspectors were prcmotty addressed and resolved. However, Vermont Yankee's precesses,

programs and staff either d!d not identify them or, if previously identified and analyzed as acceptable,

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U.S. Nuclear Regulatory Commission

September IP,1997

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did not fully resolve the fletd conditions. The latter, allowed field conditions to exist which were either

continualty subject to question or fostered an environment and culture that assumed the conditions i

were acceptable. l

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Based on the initial assessments Vermont Yankee has made to date, we do not believe that this issue

is indicative of a negatke trend in current performatice. The conditions noted are a result of past

practices for which new administrative direction and expectations are in place to adequately address

or prever i the problems.

Corrective Steps That Have Been Taken And The Results Achieved

Based on the trend of material condition issues identifled by the NRC Resloent inspector and

recognizing that it has been Vermont Yankee's expectation that VY staff also identify such issues,

Vermont Yankee commissioned a multi-disciplined task team to systematically assess the existing

material condition of the plant. This naam was organized, trained and a detailed Inspection plan and

schedule was prepared and initiated on July 29,1997. All safety related plant areas accessible during

plant operation (34 distinct areas) have been inspected with additional deficiencies / concerns identified.

All discrepancies have been ident! fled in Vermont Yankee's Work Order Request process and the

corrective action process, if appropriate. This action is complete.

Corrective Steps That Will Be Taken To Avold Further Violations

1. The task team will continue to evaluate the discrepancies identified in the systematic material

condition inspection to determine if they are indicative of any weakness in our work control and/or

implementation processes, if weaknesses are identified, additional event reports will be generated.

This la expected to be complete by October 1997.

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2. The responsible departments will evaluate the causes of these issues and initlate corrective actions

to address any identified weaknesses. Management will ensure that all personnel are aware of

Vermont Yankee's expectation for the material condition of the plant. Estimated completion of these

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evaluations and the resultant implementation of corrective actions is projected to be completed by

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December 1997,

3. The task team w!!! track and ensure the evaluation, disposition and resolution of the

discrepancies / concerns identified in the systumatic material condition assessment. Allitems that r:an

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be immediately resolved will be, via the appropriate process. The majority of the other items will be

! corrected by Work Orders, scheduled for completion at the earliest available system work week. By

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October 1997, tracking items will be added to Vermont Yankee's Corrective Action Program for the

remaining discrepancies,

l 4. The System Enginaering Program Document will be modified to take advantage of the training and

i experience gained by the System Engineers in conducting these systematl0 walkdowns. Quarterly,

! system and structure walk downs will be conducted by all system engineers. This process will provide

verificatlin of the effectiveness of corrective actions implemented via items 2 and 3 above. This is

expected to be complete by November 1997.

5. Safe *y related plant areas that are not accessible during plant operation will be similarly inspected

prior to startup from the next refueling outage. This is expected to be completed by May 1998.

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U.S. Nuoiser Regulatory Commission

. September 18,1997

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Date When Full Comol'ance Will se A thieved

Corrective actions required to address Von iont Yankee's programmatic weaknesses and threshol.1 for j

identifying material oo edition deficiencies wJ' be completed by 12/31/97. Resolution of the additional i

identitled deficiencies concems will be completed commensurate with their safety significance and the I

plant work schedules.

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AdditionalInformation  ;

in the course of reviewing eves.3 per M event report process, human performance, procedure quality,

commonloations, and work practk.g have been recently identified and acknowledged as areas needing j

inoroased management oversight snC Involvement. . Vermont Yankee does not believe recent

p performance issues identifled are i.Mative of an overall adverse performance trend. Station

management continues to foster a low threshold for initiating event reports. Consequently, the quantity  ;

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of event reports has increased significantly and has resulted in identifying an adverse precursor

performance trend similar to those identified in Reference (b). Senior management has and continues

to provide strong day-to day involvement in the corrective action process resulting in early identification  ;

of adverse perfonnance trends and development of commensurate corrective actions. '

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i Senior plant management has established en action plan for improving human performance at Vermont

Yankee. input into the action plan was discussed with all sentar Vermont Yankee managers in a

workshop on July 23 24,1997. A senior manager has been assigned responsibility to implement this

action plan. The plan will be Initiated in October 1997 and is considered a priority initiative by senior

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management. The Vermont Yankee Observation Program is also being modified to emphasize human .

performance during field observations. We have also recently developed and implemented a Stop,

Think, Act and Review (STAR) laboratory. This training has been provided to limited plant staff. We -

anticipate wider application of this important training in the future. We are confident these initlatives

will result in improved human performance. Also, we continue to look for negathe trends through our

correctiv!, action process and apply corrective actions focused on improving performance.

in Reference @) you also requested information regarding any additional actions associated with the ,

l manipulation of a wrong hydraulic control unit drain valve by the plant operating staff, in addition to

the human performance initiatives, observation program improvements, and STAR training described

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above a human factors review of the hydraulic control unit alarm panel will be performed. This review

will consider lines of demarcation, labels engraved with arrows indicating the appropriate push button,  !

, and any additional operator aids needed. Following this review any necessary modifications to the

l hydraulic control unit alarm panel will be performed. This is expected to be complete by April 1998.

We trust that the enclosed information is responsive to your concems; however, should you have any

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questions or require additionalinformation, please do not hesitate to contact us.

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Sincerely,

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VERMONT YANKEE NUCLEAR POWER CORPORATION

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Donald A. Reid

Senior Vice President, Operatiens

CC: USNRC Region I Administrator -!

. USNRC Resident inspector VYNPS >

USNRC Project Manager VYNPS _

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