ML20004B727
| ML20004B727 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/09/1981 |
| From: | Conway W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20004B722 | List: |
| References | |
| FVY-81-60, NUDOCS 8105290382 | |
| Download: ML20004B727 (3) | |
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VERMONT Y AN KEE NUCLEAR POWER CORPORATION SEVENTY SEVEN GROVE STREET 2.C.2.11 RUTLAND, VERMONT 05701 FVY 81-60 REPLY TO:
ENGINEERING OFFICE 1671 WORCESTER ROAD FRAMING H AM. M ASS ACH U9ETTS 01701 7sLsPHONE 017 872+4100 April 9, 1981 United States Nuclear Regulatpry Commission Office of Inspection and Enforcement Region I 531 Park Avenue King of Prussia. Pennsylvania 19406 Attention:
Mr. Eldon J. Brunner, Chief Reactor Projects Branch #1, DRPI
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) USNRC Letter to Mr. Robert L. Smith, VYNPC, dated March 17, 1981, Inspection 50-271/80-22
Dear Sir:
Subject:
Response to I&E Inspection Report No. 80-2.
This letter is written in rest.nnse to Reference (b) which indi-cates that one of our activities was not conducted in full compitance with Nuclear Regulatory requirements. This was noted as a result of findings during an inspection on November 17, 1980-January 3, 1981, at the Vermont Yankee Nuclear Power f ration in Vernon, Vermont.
Information is submitted as follows in answer to the alleged violation.
Item A (Severity Level V):
Technical Specification 6.5.A re-quiras that " Detailed written procedures involving Nuclear Safety, including applicable check-off lists and instructions, shall be prepared and approved.
All procedures shall be adhered to.
Procedures shall be prepared and approved covering the areas listed below... 6. Surveillance and Testing Requiremcnts."
Plant Procedure O.P. 4029 was developed pursuant to Technical Specification 6.5.A requirements. Appen-dix B to 0.P. 4029 specifies the specific plant sys-tem Type A valve lineup that shall be performed to establish the CILRT test boundary.
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N VERMONT YANKEE NUCLEAR POWER CCRPORATION United 3tates Nuclear Regulatory Commission April 9, 1981 Page 2 Technical Specification 6.5.0 states that temporary changes to procedures described in Technical Specifi-cation 6.5.A which do not change the intent of the original procedure may be made with the concurrence of two individuals holding an SRO license. Procedure A.P. 0002 was developed pursuant to the requirements of Technical Specification 6.5.D to allow temporary changes to be made to procedures described in Tech-nical Specification 6.5.A by requiring the concur-rence of two individuals holding an SRO license and the issuance of a Department Instruction.
Contrary to the above, on December 18, 1980, temporary changes were made to Steps A.1, A.3, and A.10 of Ap-pendix B to 0.P. 4029 without the issuance of a De-partment Instruction. Although instructions contained in Appendix B allowed exceptions to the valve lineup list to be noted, the instruction did not provide for the required concurrence of two individuals holding an SRO license, or as otherwise specified by A.P. 0002 ar.d Technical Specification 6.5.D.
Response: We do not concur with certain findings associated with this Item. Exceptions taken in Procedure Steps A.1 and A.3 have no bearing on valve positions as refer-enced in the Inspection Report. These exceptions simply correct typographical errors.
O.P. 4029 is a properly approved procedure with respect to Technical Specification 6.5.C and, as noted by your Violation Notice, allows excepciens to valve lineups in Ap-pendix B of the procedure. We maintain that the ex-ceptions taken to the valve lineup were entirely proper and were resolved in the required manner.
Enceptions are specifically authorized by certain pro-cedures to allo? the Cognizant Individual the ability to make minor improvements to the procedure that do not change the intent of that procedure. These proce-dures generally involve activities that are large or complex such as valve lineups or integrated station startup precodures where the Cognizant Individual is extremely knowledgeable of the activity.
Exceptions teken that involve realignment of plant equipment are always accomplished through the Shift Supervisor in accordance with establisned practice. Additionally, the Type A Test Procedure contains provfaions for re-storing the affected systems to the normal mode.
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VERMONT YANKEE NUCLEAR POWER CORPOf1 ATION United States Nuclear Regulatory Co n ission April 9, 1981 Page 3 We find no reason to discontinue or limit the use of these types of exceptions at this time; however, we will ensure that the shift supervisor concurrence to changes to the status of plant equipment is docu-mented. Procedure O.P. 4029 will be modified to in-clude this requirement prior to the next Primary Con-tainment Integrated Leak Rate Test.
We trust the above is responsive to the Notice of Violation; how-ever, should you have further questions, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION William F. Con ay Vice President and Manager of Operations WFC/jh STATE OF VERMONT)
) ss WINDHAM COUNTY )
Then persoanally appeared before me, William F. Conway, who, being duly sworn, did state that he is a Vice President of Vermont Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Vermont Yankee Nuclear Power Corporation, and that the statements therein are true to the best of his knowledge and belief.
IIAlb 0*
Jud@hA.H'arris Notary Public My Commission Expires February 10, 1983
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