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{{Adams | |||
| number = ML20199L465 | |||
| issue date = 11/20/1997 | |||
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-271/97-05 on 970819 | |||
| author name = Cowgill C | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | |||
| addressee name = Reid D | |||
| addressee affiliation = VERMONT YANKEE NUCLEAR POWER CORP. | |||
| docket = 05000271 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-271-97-05, 50-271-97-5, NUDOCS 9712020031 | |||
| title reference date = 09-18-1997 | |||
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | |||
| page count = 3 | |||
}} | |||
See also: [[see also::IR 05000271/1997005]] | |||
=Text= | |||
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9, | |||
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November 20, 1997 | |||
! | |||
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 | |||
9 | |||
SUBJECT: NRC INSPECTION REPORT NO. 50 271/97 05 REPLY , | |||
, | |||
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 | |||
' | |||
05-02. | |||
, | |||
' | |||
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, | |||
(1 | |||
ORIGINAL SIGNEJ BY: | |||
} | |||
Curtis J. Cowgill, Ill, Chief i | |||
Projects Branch No. 5 l | |||
Division of Reactor Projects | |||
Docket No. 50 271 / , | |||
I | |||
9712020031 971120 ' | |||
PDR ADOCK 0 71 | |||
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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 ; | |||
' | |||
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 | |||
> | |||
, | |||
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 | |||
Rl/DRP { | |||
CJCOWGl".LA | |||
( (b / l / l | |||
l DATE l do M7' ' | |||
11/ /97 | |||
OFFICIAL RECORD COPY | |||
.i | |||
, | |||
- .-. - | |||
..-,,,n..,,--- g -ww,_..,_,. -,r- ,,-----.ye ,#-, ,,- | |||
. . | |||
. . - | |||
, | |||
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 | |||
- _ . | |||
. - . . . _ - - . _ _ - - - - . _ . - - - . . | |||
. | |||
. ~ | |||
VERMONT YANKEE , | |||
NUCLEAR POWER CORPORATION , | |||
* | |||
s | |||
. | |||
9 h Ferry Road. Brattleboro. VT 05301-7002 | |||
{g | |||
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~ | |||
ENGINEERING OFFICE | |||
$60 MAIN STR(ET | |||
BOLToN. MA 01740 | |||
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. | |||
' | |||
(608) 77M711 | |||
September 18,1997 | |||
BW 97117 | |||
" | |||
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 hour 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 | |||
. . | |||
/ VORMONT Y ANKOE NUCLE AR POWER CORPOR ATION | |||
U.S. Nuclear Regulatory Commission | |||
September 18,1997 | |||
Page 2 | |||
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. | |||
, , | |||
. . | |||
! | |||
' | |||
VERMONT YANKEE NUC1. EAR POWER CORPOR ATION | |||
U.S. Nuoloar R*gulatory Commission | |||
September 18,1997 , | |||
Page 3 j | |||
1 | |||
, | |||
' | |||
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. | |||
i | |||
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: | |||
, | |||
1. five seismic hangers in the containment air dilution system that were found not to be | |||
' I | |||
property adjusted; | |||
l | |||
l 11. e ono-quarter inch gap that was found between the end battery cell and the seismic | |||
' | |||
support rock for one of 18 groups of cells in the "A" urcinterruptible power supply i | |||
l | |||
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. | |||
1 | |||
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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. . l | |||
~ | |||
7 VORMONT YANKEE NUCLEAR POWER CORPORATION | |||
U.S. Nuclear Regulatory Commission | |||
September IP,1997 | |||
Page 4 | |||
1 | |||
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 | |||
, | |||
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. | |||
. | |||
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 | |||
l | |||
evaluations and the resultant implementation of corrective actions is projected to be completed by | |||
l | |||
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 | |||
t | |||
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 | |||
i | |||
' | |||
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. | |||
I | |||
1 | |||
-.__ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ - _ _ . - - _ _ _ _ _ _ _ _ | |||
e e | |||
~ | |||
s' VERMONT YANKEE NUCLEAR PowEn CORPORATION | |||
U.S. Nuoiser Regulatory Commission | |||
. September 18,1997 | |||
Page5 | |||
y | |||
l | |||
l | |||
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. | |||
1 | |||
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 ; | |||
4 | |||
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. ' | |||
, | |||
! | |||
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 | |||
' | |||
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 | |||
i i | |||
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 | |||
! | |||
, | |||
questions or require additionalinformation, please do not hesitate to contact us. | |||
( | |||
Sincerely, | |||
, | |||
2 | |||
I | |||
VERMONT YANKEE NUCLEAR POWER CORPORATION | |||
: | |||
' | |||
s | |||
I | |||
l s | |||
' | |||
Donald A. Reid | |||
Senior Vice President, Operatiens | |||
CC: USNRC Region I Administrator -! | |||
. USNRC Resident inspector VYNPS > | |||
USNRC Project Manager VYNPS _ | |||
._ ! | |||
i . | |||
.. - | |||
? | |||
}} |
Latest revision as of 22:40, 7 December 2021
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
Text
_ . .
. . . . .
. . . .
..,
.- . j
.. ..
9,
!
November 20, 1997
!
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
9
SUBJECT: NRC INSPECTION REPORT NO. 50 271/97 05 REPLY ,
,
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
'
05-02.
,
'
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,
(1
ORIGINAL SIGNEJ BY:
}
Curtis J. Cowgill, Ill, Chief i
Projects Branch No. 5 l
Division of Reactor Projects
Docket No. 50 271 / ,
I
9712020031 971120 '
PDR ADOCK 0 71
a e < gAlt.algs!ss
.
1
'\
.
,.
_ ,, , m _ m ., ... ,,..y, _. _ , . _ .
- ._ .__. - . ... - ._. - . - - - - . - - - - . . . - . . _ . . - . _ - - - . - . _ -
- .* !
. ... ;
,
.f !
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 ;
'
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
>
,
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
Rl/DRP {
CJCOWGl".LA
( (b / l / l
l DATE l do M7' '
11/ /97
OFFICIAL RECORD COPY
.i
,
- .-. -
..-,,,n..,,--- g -ww,_..,_,. -,r- ,,-----.ye ,#-, ,,-
. .
. . -
,
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
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.
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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 >
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