IR 05000271/1989080

Ack Receipt of Informing NRC of Steps to Correct Violations Noted in Insp Rept 50-271/89-80

ML20248G254
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	09/25/1989
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8910100156
Download: ML20248G254 (2)

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I-t SEP 2 51989 Docket No. 50-271 Vermont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Gentlemen:

Subject: Inspection No. 50-271/89-80 This refers to your letter dated August 11, 1989, in response to our letter dated June 2, 1989.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program. # ,,/

Your cooperation with us is appreciated.

Sincerely, Original Signidiyi Cliff crd J. f.rderson j Jacque P. Durr, Chief

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Engineering Branch Division of Reactor Safety cc: w/ encl:

J. Weigand, President and Chief Executive Officer J. Pelletier, Plant Manager J. DeVincentis, Vice President, Yankee Atomic Electric Company R. Capstick, Licensing Engineer, Yankee Atomic Electric Company J. Gilroy, Director, Vermont Public Interest Research Group, Inc.

G. Sterzinger, Commissioner, Vermont Department of Public Service P. Agnes, Assistant Secretary of Public Safety, Commonwealth of  ;

Massachusetts '

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Hampshire State of Vermont Commonwealth of Massachusetts Vermont Yankee Hearing Service List 0FFICIAL RECORD COPY RL VY 89-80 - 0001.0.0 8910100156 890925 09/25/89 PDR ADOCK 05000271 O PDC ,

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YI ERMONT YANKEE.

o NUCLEARL POWER CORPORATION

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. Ferry Road, Brattleboro, VT 05301-7002 BVY,.,89-75 i

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ENGINEERING OFFICE

$80 MAIN STREET

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bot. TON, MA 01740

(508)779-671i August 11, 1989 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk References: a) License No. DPR-28 (Docket No. 50-271) i b) Letter, USNRC to VYNPC, NW 89-126, Inspec '.' ion Report 1 No. 89-80, dated 6/2/89 l c). Letter, WNPC to USNRC, BW 89-58, Response to Inspection 0 6. ,

Report 89-80, Notice of Violation, dated 6/30/89 ~ 3 q

d) Letter, WNPC to USNRC, BW 89-124, Vermont Yankee / ]

Response to NRC Request for Information Regarding )

Condition of Drywell Paint, dated 7/1/89 _

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Dear Sir:

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Subject: Additional Response to Inspection Report }

89-80 Request for Information  !

A special maintenance :eam inspection was conducted at the Vermont Yankee site between February 27 nd March 10, 1989. The subject Inspection Report  !

[ Reference b)] identified several areas of weakness, three unresolved items, and j one violation connected with the performance of maintenance activities. The NRC i requested notification in writing of actions taken, or planned, in order to "

enhance our maintenance activities in areas where weaknesses were identified and to resolve the identified unresolved items. Vermont Yankee responded to the l Inspection Report Notice of Violation by letter, dated June 30, 1989 (Reference '

c)]. Unresolved Item 89-80-01, concerning the issue of peeling paint in the drywell, was addressed as requested in a separate submittal, dated July 1, 1989

[ Reference d)].

The purpose of this letter is to provide, as Enclosure 1, Vermont Yankee's requested response to the Appendix 3 and Appendix 4 items of the subject Inspection Report. As stated in the report, the inspection team concluded that Vermont Yankee is implementing a generally effective maintenance program with the main area of needed improvement being the development of a set of documents pro-viding a comprehensive description of maintenance practices, responsibilities, and authorities to assure that good maintenance activities continue in the future.

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,', ..', VERMONT YANKEE NUCLEAR POWER CORPORAT;ON U.S. Nuclear Regulatory Commission F . August 11, 1989 Page 2 -

Vermont Yankee fully supports the maintenance team's assessment and recognizes the need to. enhance certain aspects of our Maintenance Program.

Accordingly, Vermont Yankee herewith commits to develop and implement a compre-hensive and formal maintenance program document. An outline of a formal main-tenance program has been prepared and is currently undergoing management review.

The formal program document is expected to be approved and issued by the end of 1989.

The intent of the formal maintenance program document is to provide compre-hensive and formally documented maintenance policies and practices for Vermont

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Yankee. We recognize the need to formalize maintenance requirements in order to ensure continued good performance in the maintenance area. The maintenance program document under development will incorporate the many good maintenance practices, presently in place at Vermont Yankee, identified in the Inspection Report. Further, Vermont Yankee is examining the potential development of a Computerized Maintenance Material. Management System. A development plan has been established; however, the actual scope of the plan and expectations of the system are not yet determined.

We trust that this information is responsive to the subject request.

However, should you have any questions or require further information concerning this matter, please do not hesitate to contact us.

Very truly yours, VERMGNT YANKEE NUCLEAR POWER CORPORATION n y f Warren P. urphy 7 Vice President and Manager of Operations

/dm l.. cc USNRC Regional Administrator, Region I USNRC Resident Inspector, VYNPS l^

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l. ENCLOSURE 1 I

VERMONT YANKEE'S RESPONSE TO NRC INSPECTION REPORT 89-80 REQUEST FOR INFORMATION APPENDIX 3 - SUMMARY OF WEAKNESSES APPENDIX 4 - SUMRARY OF UNRESOLVED ITEMS Appendix 3 to the NRC's Special Maintenance Team Inspection of Vermont Yankee (Reference b)) provided a summary list of maintenance program weaknesses.

Appendix 4 to the NRC's Special Maintenance Team Inspection Report identified three unresolved items. Each of the seven weaknesses and three unresolved items, as well as Vermont Yankee's planned or completed actions, are addressed below: ..'

1. Lack of comprehensive and formally documented mair.cenance plan and poli- ]

cies. j i

Status - Vermont Yankee concurs with this concern and has initiated a pro-

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cess to develop a comprehensive formal maintenance program document. An outline of this maintenance program has been prepared and is under manage-ment review. This program is intended to clearly document objectives, policies, responsibilities, authorities, and accountability. The document is to be comprehensive and will not only provide a consistent approach to maintenance activities, but will also establish formal programmatic controls. The comprehensive formal program document is expected to be approved and issued by the end of 1989.

.2. Lack of comprehensive and structured review for adequacy and applicability of the plant's maintenance requirements.

Status - The inspection report noted the effectiveness of Vermont Yankee's maintenance program as reflected by the absence of repeat corrective main-tenance and generally effective predictive and preventive maintenance acti-vities. However, a formal program for comprehensive and structured review for adequacy and applicability of maintenance requirements is not in place.

The formal maintenance program document under development will establish a policy regarding comprehensive and structured reviews of plant maintenance requirements. This policy will address adequacy and applicability of plant maintenance requirements and will incorporate many of the present informal review methods that have proven successful over the plant's operating history. This policy will provice guidance for conducting comprehensive reviews and what circumstances will prompt such reviews.

3. Review for the appropriateness and technical adequacy of completed main-tenance activities were not being performed in a timely manner.

Status - As stated in the Inspection Report, Vermont Yankee has a program to review the appropriateness and technical adequacy of completed main-tenance activities. This program will be formally incorporated into the

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l~ Enclosure 1 p' Page 2 maintenance program document. The Inspection Team's concern.with respect toKthe timeliness of these reviews'has been addressed through recent orga-

, nizational. changes within the site Maintenance-Department. Specifically, l the responsibilities'of the Maintenance Department's senior engineering position have:been divided into two separate senior engineer positions, one

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electrical and one mechanical.

Vermont Yankee believes that these organizational changes within the-Maintenance Department will serve to expedite the timeliness of the subject reviews,,by improving management's ability to. focus on the review of main-tenance activities and reduce the~ backlog of completed maintenance requests awaiting review, by.the 1990 outage, to.a level that will ensure future maintenance activities'are reviewed in a timely manner.

4. Lack of effective policy and procedures'for controlling and updating manu-facturer technical manuals.

Status - Vermont Yankee was previously aware of the need for an effective policy and procedure for. controlling and updating manufacturer technical manuals in the' maintenance program. In response to this need, Vermont'

Yankee had a' contract in place, prior to the inspection team' visit, to ini-tiate a review of manufacturer equipment vendor technical manuals and files. With the assistance of on-site contractor support, over 300 manu-facturer, technical manuals, dealing with safety-related equipment, have been identified. Vermont Yankee has estabished a schedule for updating these manuals such that 60% will be reviewed and updated by the end of 1989. A schedule for reviewing and updating the remaining 40% will also be established by the end of 1989.

Additionally, as part of the technical information review process, guidance will be provided by the contractor to assist in the formation of a policy and implementing procedures for controlling and updating-manufacturer tech-nical manuals. This policy will be incorporated into the formal main-tenance program document.

5. PRA concept not incorporated into Vermont-Yankee's maintenance program.

Status - As stated in the Inspection Report, the Inspection Team examined the maintenance activities of selected PRA-significant systems and com-ponents, and found them to have effective maintenance and technical sup-port. Vermont Yankee will address the formal incorporation of PRA concepts into the maintenance program in response to Generic Letter 88-20,

" Individual Plant Examination for Severe Accident Vulnerabilities." The level of formal incorporation including necessary programmatic changes will be scheduled, as appropriate, in Vermont Yankee's response to the Generic Letter.

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L Enclosure 1 Page 3 6. No integrated Master Equipment List for Vermont Yankee.

Status - The Vermont Yankee Maintenance Department, and Instrument and Control Department use the Visi-Record system as an equipment list in con-junction with the plant master. equipment list for safety-related equipment; and the Master Equipmer.t List for Environmentally Qualified (EQ) equipment as defined in the EQ manual.

The present scope of the maintenance program document outline provides guidance for the use of the above lists and will eliminate the potential for the confusion identified in the subject inspection report.

Accordingly, the maintenance program document that will be. issued by the end of this year will contain clear descriptions of the maintenance equip-ment and component lists in place at this time. Vermont Yankee will deter-mine if additional actions are necessary in conjunction with the evaluation associated with the development of a computerized Maintenance Material Management System.

7. Post Maintenance Testing (PMT) requirements were not proceduralized in the administrative procedure.

Status - The Maintenance Request Procedure (AP 0021), which controls main-tenance' activities, is currently being revised and is expected to be issued by'the end of 1989. Changes include a description of the expectations of post-maintenance testing and acceptance criteria. Also, instructions will be added to the procedure to direct workers to contact their supervisors when there are any questions concerning the type of post-maintenance test required or the acceptance criteria.

The process and criteria of PMT will also be formalized in the maintenance program document.

SUMMARY OF UNRESOLVED ITEMS 1. 89-80-1 - Potential for drywell paint peeling to clog the ECCS pump suction screen.

Status - As requested, this issue was responded to within 30 days of receipt of the Inspection Report by separate letter, dated July 1, 1989

[ Reference d)].

2. 89-80-02 - Radiation exposure control above the radiological shield during fuel movement.

Status - The Inspection Report identified that Vermont Yankee had performed a detailed evaluation and verification of the concerns identified by General Electric in Operating Experience Report, OER 78, and SIL 354.

Vermont Yankee has re-evaluated administrative controls during fuel move-ment and concluded that more stringent administrative controls could give

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additional' assurance of the protection of individuals. Consequently,;the .;

following actions will be implemented. prior to the next refueling outage,.  ;

currently scheduled for September 1990. j f

Fuel handling procedural changes will include controls regarding the move-

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ment of irradiated fuel close to the reactor vessel wall above the biologi-cal' shield. Appropriate caution statements will also be added to remind

, personnel of the potential hazards of fuel movement in this area when the l orywell is occupied.

l Training will be provided prior to the outage to personnel involved in the.

refueling process or who may work in susceptible areas of the drywell. <

This training will review the potential hazards, controls, and limits asso- '

cited with work in the drywell'during refueling.

3. 89-80-03 - Administrative control of " tag-out" as it applies to an additional work party.- q Status - The inspection team noted that Procedure AP 0140, " Vermont Yankee Local Control Switching Rules," does not address how to add an additional work party to an existing l tag. . In accordance with Vermont Yankee's commit-ment to evaluate the need to strengthen controis-in this area, this proce- 4

' dure is currently undergoing review by a task force. This task force is also addressing several weaknesses associated with the switching and tagging process identified during the internal critique of our latest

. refueling outage. The task force's recommended corrective actions are to-l be formulated and an implementation schedule established by the end of 1989. These recommendations will address strengthened controls associated with this unresolved item.

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