ML20126C338
| ML20126C338 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/24/1985 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| FVY-85-49, NUDOCS 8506140386 | |
| Download: ML20126C338 (3) | |
Text
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q VERMONT YANKEE
(
NUCLEAR POWEll COI1PORATION RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 gY85-49 m
y ENGINEERING OFFICE 1671 WORCESTER ROAD g
FRAMINGHAM. MASSACHUSE TTS 01701 T Elt PHOPvE 6 t r-872-8100 May 24, 1985 U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Edward C Wenzinger, Chief Projects Branch #3 Division of Reactor Projects
References:
(a)
License No. OPR-28 (Docket 50-271)
(b)
Letter, USNRC to VYNPC, Inspection Report 50-271/85-08, dated April 15, 1985
Dear Sir:
Subject:
Response to Inspection Report 50-271/85-08 This letter is written in response to Reference (b) which indicates that certain activities were not conducted in full compliance with Nuclear Regulatory Commission requirements.
The alleged Severity Level IV and V violations were cited during a routine resident safety inspection conducted by Mr. W.J. Raymond on February 5 - March 4, 1985 at the Vermont Yankee Nuclear Power Station, Vernon, Vermont.
Information is submitted in the following paragraphs in answer to the alleged violations.
Violation A Technical Specification (TS) 6.5.A requires that detailed written pro-cedures, including applicable check-off lists, be prepared, implemented and followed.
Procedure AP Gn00 was written pursuant to the above and requires that the procedures required for the operation of modified systems be revised and reissued prior to initial operation of the system following installation of the design change.
AP 6000 further require
- that surveillance procedures be revised and reissued within 30 days of the insta11ction, or prior to the next scheduled use of the procedures, whichever is earlier.
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VEHMONT YANKEE NUCLEAR POWEH CORPORATION c,
U.S. Nuclear Regulatory Commission May 24, 1985 Page 2 Contrary to the above, upon completion of modifications for PDCR 84-03, the sprinkler system for the northwest (NW) corner of the Reactor Building was returned to service and declared operable at 1:10 p.m. on January 18, 1985, and operating and surveillance procedures OP 2190, OP 2186, and OP 4020 were not revised and reissued until February 13, 1985 as required to reflect the plant configuration affected by the modifications. The failure to revise OP 4020 contributed to an inadvertent actuation of the NW sprinkler system deluge valve DV-301 on February 12, 1985, when the sur-veillance test was performed.
This is a Severity Level IV Violation (Supplement I.D.).
Resp _o_ns e A review of the circumstances involving the inadvertent actuation of the NW sprinkler valve has identified the need to increase the level of design change review in order to ensure that all procedures affected by a change have been identified prior to design change approval.
As a corrective action, Department Heads have been made aware of this violation and have been reinstructed in their responsibilities for ensuring that consideration is given to procedure impact when design changes are reviewed.
Further, to allow reviewers to more readily determine the boundaries of work under consideration, appropriate plant Engineering personnel have been instructed to ensure that the scope of work is clearly defined within the intro-ductory section of the design change.
Additionally, by July 1, 1985, all Vermont Yankee procedures controlling the revision of plant operation and surveillance procedures (AP 6000, AP 6001, AP 6003, and AP 6004) will be revised to require that surveillance procedures affected by a design modification be updated and issued prior to use following turnover of that system.
As a further precaution, responsible Operations per-sonnel have been been instructed to verify that operating procedures are revised and issued prior to declaring an altered system operable.
Vermont Yankee Delieves that these changes will preclude future events of this nature.
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a VEHMONT YANKun NUCLEAR POWER CORPORATION Q,
U.S. Nuclear Regulatory Comnission May 23, 1985 Page 3 VIOLATION B Technical Specification 4.13.B requires that each testable valve in the flow path of the vital fire water system be fully cycled at least once per 12 months while the system is operable.
Contrary to the above, between July 1983 and December 1984, valve FP 302, a testable valve in the flow path of the vital fire water system, was not fully cycled while the system was operable.
This is a Severity Level V Violation (Supplement I.E.).
RESPONSE
e As stated in Inspection Report 50-271/84-08, the failure to test valve number 302 was the result of a typographical error on the surveillance sheet (VYOPF 4020.18) that was not identified during the final review of revision 10 to OP 4020, " Surveillance of Fire Protection Equipment". Although the typographical error is viewed as an isolated incident, the individual respon-sible for the oversight of this procedure has been informed of the potential consequences of errors of this nature.
On April 5, 1985, Revision 11 to OP 4020 was issued to correct the discrepant valve number.
It should be noted that upon identification of the error, an immediate review of pertinent plant records was conducted and a determination made that the 302 valve had been cycled proving operability approximately one month beyond the allowable time period.
Appendix A to Inspection Report 85-08 requested that we reply to the sub-ject violations within 30 days of the date of the formal report.
Please note that the need for a 10-day extension of this period was discussed and agreed to by Mr. W. J. Raymond.
We trust that this information is deemed to be satisfactory; however, should you have any questions regarding this matter, please contact me.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION p~renP.MurphydPR;4 War Vice President and Manager of Operations WPM /dm
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