ML19340E865

Responds to NRC 801023 Ltr Re Violations Noted in IE Insp Rept 50-271/80-12.Corrective Actions:Weld Data Sheet & Valve Packing List Rewritten from Other Job Associated Documentation

ML19340E865
Person / Time
Site:	Vermont Yankee
Issue date:	11/14/1980
From:	Conway W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19340E856	List: ML19340E865
References
WVY-80-160, NUDOCS 8101160065
Download: ML19340E865 (5)

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VERMONT YAN KEE NUCLEAR POWER CORPORATION SEVENTY sEVEN GROVE STREET RUTLAND, VERMONT 05701 8b160 REPLY TO:

ENGINEERING OFFICE TURNPIKE ROAD WESTBORO, M ASS ACHUSETTS 01581 TELEPHONE 417-3 6 4 9 0 t t November 14, 1980 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 ATIENTION: Office of Inspection and Enforcement Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch

REFERENCES:

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

(b) USNRC letter to VYNPC, dated October 23, 1980 (Inspection Report 50-271/80-12)

Dear Sir:

l Subj ect: Response to I&E Inspection No. 80-12 This letter is written in response to Reference (b) which indi-cates that two of our activities were not conducted in full compli-ance with Nuclear Regulatory requirements. The alleged infraction and deficiency were noted during an inspection conducted on August 12-15, 1980, at the Vermont Yankee Nuclear Power Station in Vernon, Vermont. Information is submitted as follows in answer to the alleged Item A (Infraction) and Item B (Deficiency) contained in the enclosure of this letter.

Item A: Yankee Atomic Electric Company Operational Quality Assurance Program (YOQAP-1-A),Section II, Quality Assurance Program, Paragraph C, Implementation, states in part:

" Establishment of an effective Operational Quality Assurance Program, is assured through consideration of and conformance, where applicable, with the below listed Federal documents and ANSI standards.

1. Title 10 of the Code of Federal _ Regulations, Part 50, Appendix B, Quality Assurance Cri-teria for Nuclear Power Plants."

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l VERMONT YANKEE NUCLEAR POWER CORPORATIO3 United States Nuclear Regulatory Commission November 14, 1980 Page 2 10 CFR 50, Appendix B, Criterion V, requires, in part:

" Instructions, procedures, or drawings shall in-clude appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

YOQAP-1-A,Section V, Paragraph B, requires, in part:

" Persons preparing and approving documents are re-sponsible for assuring that specifications, in-structions, procedures, and drawings include ap-propriate quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished; ...and assuring that the documents are kept current."

10 CFR 50, Appendix B, Criterion VI, requires in part:

" Measurements shall be established to control the issuance of documents, such as instructions, pro-cedures, and drawings, including changes thereto, which prescribe all activities affecting quality (and further) these measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is per-formed."

YOQAP-1-A,Section V, Paragraph C, requires, in part:

" Establishment of provisions which clearly delin-eate the sequence of actions to be accomplished in the preparation, review, approval, and control of instructions, procedures, and drawings."

YOQAP-1-A,Section VI, Paragraph C.1, requires, in part:

" Inclusion of approved changes in instructions, drawings, and other applicable documents prior to placing the system in operating status."

VERMONT YANKEE NUCLEAR POWER CORPORATIOR United States Nuclear Regulatory Commission November 14, 1980 Page 3 Contrary to the above, as of August 15, 1980, with the Instrument Air System in an operating status, the inspector determined that Valves V72-90E, Inline Isolation Valve (Air Supply Valve to Main Steam Iso-lation Accumulators and the Main Steam Safety Relief Accumulator), and V72-152, test connection valve and associated downstream cap, were installed in the In-strument Air System on January 10, 1980 in' accord-ance with Plant Design Change Request (PDCR) No.

79-08 without the valve numbers, description, or actual position being incorporated into the appli-cable system operating procedure, R.P. 2191, Contain-ment Instrument Air System. Additionally, VYAP 6000, Plant Design Change Request, Revision 7, dated May 5, 1978, does not contain provisions for con-trolling procedure change documents to assure their inclusion into applicable documents prior to placing the system in operating status.

Response: Although we feel that this event is a rare occurrence with our present procedural controls, plant proce-dures controlling design changes and alterations are being upgraded to require that cognizant personnel be responsible for:

1) research of all plant procedures which may be affected by the design change or alteration;

2) listing of all al ected procedures in the con-trolling document;

3) inclusion of preliminary marked up copies of the affected procedures in the design change or alteration package prior to PORC review; and

4) ensuring that operating procedures for the af-fected system (s) are revised as necessary prior to the release of system (s) for normal opera-tions.

Until these procedures are fully implemented, spe-cific efforts have been initiated to insure appro-priate personnel are fully cognizant of the new design changes and modifications and to identify and implement changes as required to the plant operating procedures in a timely manner.

VERMONT YANKEE NUCLEAR POWER CORPORATIOR United States Nuclear Regulatory Commission November 14, 1980 Page 4 These reviewed controlling procedures will be pub-lished and implemented, and personnel will be fully trained, on or before February 1, 1981.

Item B: Technical Specification 6.6.A.2 requires that rec-ords of principal maintenance activities, including inspection and repair of principal items of equip-ment pertaining to nuclear safety be retained for at least five years.

(1) A.P. 0013, Plant Record Retention, Appendix A, requires retention of maintenance procedure data sheets for six years.

Contrary to the above, procedure data sheets concerning maintenance of the following prin-cipal items of equipment pertaining to nuclear safety were not maintained:

Weld date sheet (VYAPF 0203.01) associated with Maintenance Request No. 79-0852, per-formed November 1, 1979, which provided various certifications and inspections for the cutting and rewelding of a section of piping in the Standby Liquid Control Sys-tem piping.

-- Valve packing checklist required by Proce-dure 0.P. 5201, Safety System Valves, which provides various certifications for re-packing of safety-related valves used for Maintenance Request No. 80-0014, performed January 5, 1980, for repacking of RHR Sys-tem Valve RHR-81B.

(2) Yankee Atomic Electric Company Quality'Assur-ance Program,Section II, which in part, pro-vides the requirements for plant inspections, requires compliance to the requirements of ANSI N18.7-1976. ANSI N18.7-1976, Paragraph 5.2.17, requires that independent inspection records of routine, safety-related, maintenance be main-tained.

Contrary to the above, records of independent c inspections performed-for safety-related rou-tine maintenance were not being maintained.

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VERMONT YANKEE NUCLEAR POWER CORPORATIOR United States Nuclear Regulatory Commission November 14, 1980 Page 5 Response: Appropriate personnel have been reinstructed and re-minded of the necessity to maintain required detailed work package documentation in accordance with plant procedures.

The subject weld data sheet and valve packing list were subsequently rewritten from other job associated documentation.

We trust this information will be satisfactory. Should addi-tional information be required, please feel free to contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION Wil am F. D y Vice President and Manager of Operations i

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