Responds to NRC 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
BVY-99-084, Forwards Proprietary Application & Medical Certificate for Mod of Listed SRO License,For Gj Leclair.Gj Leclair Will Be Trained & Evaluated in Accordance with Util Lsro Training Description.Proprietary Info Withheld,Per 10CFR2.790
ML20196G524
ML20209C375
ML20209B586
ML20196J742
ML20196J243
ML20209B611
ML20196J232
ML20209G153
ML20209G693
ML20209G272
ML20209J060
ML20216D732
ML20210J303
ML20210G504
ML20210G427
ML20211E170
ML20210M579
BVY-99-100, Forwards Revised Floor Response Spectra Diagrams,Originally Sent as Attachment 1 to Licensee to Nrc.Revised Diagrams Have More Legible Scale Markings
BVY-99-103, Informs That Util Expects to Submit Approx Twenty Licensing Actions in FY00 & FY01,in Response to Administrative Ltr 99-02
BVY-99-108, Requests That Gv Bogue,Bj Croke,Vs Ferrizzi,Me French, Bk Mcnutt,Jf Meyer & DM Navarro Take BWR Gfes of OL Exam Administered on 991006.DA Daigler & ST Brown Will Have Access to Exams Before Tests Administered
ML20211H085
ML20211E137
ML20211E884
BVY-99-107, Submits Response to NRC RAI Re Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355 Fuel Assemblies
ML20211G479
BVY-99-110, Informs of Util Intent to Replace Commitments Made in Licensee & Subsequently Ack in NRC with Containment Insp Criteria Defined in 10CFR50.55a(b)(2)(vi),per Drywell Coating Insp
BVY-99-111, Informs That Encl TS Bases Page 91 Has Been Revised to Allow Reactivity Anomaly BOC Steady State Core Reactivity to Be Normalized Between off-line Uncorrected Solution & on-line 3D-Monicore Exposure Corrected Solution
ML20216F317
BVY-99-118, Responds to RAI Concerning GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions
BVY-99-115, Forwards non-proprietary & Proprietary Responses to 990714 RAI Re Civil & Mechanical Engineering Considerations for Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355.Proprietary Encls Withheld
ML20212C162
BVY-99-121, Requests Extension Until 990929 to Respond to Violations Noted in Insp Rept 50-271/99-12,dtd 990819.Licensee Did Not Receive Rept Until 990830 & Addl Time Is Needed to Prepare & Allow for Adequate Review of Violation Response Submittal
BVY-99-114, Provides Notification That Licensee Completed Y2K Remediation Efforts Described in Util 990608 Response to NRC GL 98-01,Suppl 1
BVY-99-113, Requests Approval to Perform Alternative Testing to That Specified by ASME Boiler & Pressure Vessel Code,Section XI & Asme/Ansi OM, Operation & Maint of Nuclear Power Plants. Attachment 1 Provides Justification for Alternative Testing
BVY-99-116, Informs of Determination That Wh Schulze,License SOP-10528-1,will No Longer Maintain License at Facility. Termination of License Requested
BVY-99-122, Notifies of Intention to Reinstate Original Version of App F in FSAR & Correct Docket Re Assumption That Electrical Power Sys Are Designed IAW Requirements of GDC-17
ML20216J353
ML20212J650
ML20212J789
BVY-99-128, Submits Listed Addl Info in Support of 990414 Request for Clarification to SER Confirming Adequacy of Space Cooling for HPCI & RCIC Sys,Re Item II.K.3.24 of NUREG-0737.Copy of NEDE-24955,encl
ML20217C150
BVY-99-130, Provides Clarification of Method for Determining MSIV Maximum & Minimum Pathway at Vermont Yankee Nuclear Power Station
BVY-99-067, Informs That Bw Metcalf,License SOP-1761-9,has Retired from VYNPS & Will No Longer Require License.Nrc Is Requested to Terminate License
ML20195B408
BVY-99-074, Forwards Application & Medical Certificate Required for Renewal of Jd Livingston,License OP-10049,RO License.Medical Certificate Withheld
ML20195C589
ML20195D534
ML20195H174
BVY-99-084, Forwards Proprietary Application & Medical Certificate for Mod of Listed SRO License,For Gj Leclair.Gj Leclair Will Be Trained & Evaluated in Accordance with Util Lsro Training Description.Proprietary Info Withheld,Per 10CFR2.790
ML20209C375
ML20209B586
ML20196J742
ML20209B611
ML20196J232
ML20209G153
ML20209J060
ML20210G504
ML20210J303
ML20210G427
ML20211E170
ML20210M579
BVY-99-100, Forwards Revised Floor Response Spectra Diagrams,Originally Sent as Attachment 1 to Licensee to Nrc.Revised Diagrams Have More Legible Scale Markings
BVY-99-103, Informs That Util Expects to Submit Approx Twenty Licensing Actions in FY00 & FY01,in Response to Administrative Ltr 99-02
BVY-99-108, Requests That Gv Bogue,Bj Croke,Vs Ferrizzi,Me French, Bk Mcnutt,Jf Meyer & DM Navarro Take BWR Gfes of OL Exam Administered on 991006.DA Daigler & ST Brown Will Have Access to Exams Before Tests Administered
BVY-99-107, Submits Response to NRC RAI Re Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355 Fuel Assemblies
BVY-99-110, Informs of Util Intent to Replace Commitments Made in Licensee & Subsequently Ack in NRC with Containment Insp Criteria Defined in 10CFR50.55a(b)(2)(vi),per Drywell Coating Insp
BVY-99-111, Informs That Encl TS Bases Page 91 Has Been Revised to Allow Reactivity Anomaly BOC Steady State Core Reactivity to Be Normalized Between off-line Uncorrected Solution & on-line 3D-Monicore Exposure Corrected Solution
BVY-99-115, Forwards non-proprietary & Proprietary Responses to 990714 RAI Re Civil & Mechanical Engineering Considerations for Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355.Proprietary Encls Withheld
BVY-99-118, Responds to RAI Concerning GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions
BVY-99-121, Requests Extension Until 990929 to Respond to Violations Noted in Insp Rept 50-271/99-12,dtd 990819.Licensee Did Not Receive Rept Until 990830 & Addl Time Is Needed to Prepare & Allow for Adequate Review of Violation Response Submittal
BVY-99-114, Provides Notification That Licensee Completed Y2K Remediation Efforts Described in Util 990608 Response to NRC GL 98-01,Suppl 1
BVY-99-113, Requests Approval to Perform Alternative Testing to That Specified by ASME Boiler & Pressure Vessel Code,Section XI & Asme/Ansi OM, Operation & Maint of Nuclear Power Plants. Attachment 1 Provides Justification for Alternative Testing
BVY-99-116, Informs of Determination That Wh Schulze,License SOP-10528-1,will No Longer Maintain License at Facility. Termination of License Requested
BVY-99-122, Notifies of Intention to Reinstate Original Version of App F in FSAR & Correct Docket Re Assumption That Electrical Power Sys Are Designed IAW Requirements of GDC-17
ML20216J353
BVY-99-128, Submits Listed Addl Info in Support of 990414 Request for Clarification to SER Confirming Adequacy of Space Cooling for HPCI & RCIC Sys,Re Item II.K.3.24 of NUREG-0737.Copy of NEDE-24955,encl
BVY-99-130, Provides Clarification of Method for Determining MSIV Maximum & Minimum Pathway at Vermont Yankee Nuclear Power Station
BVY-89-117, Responds to Violations Noted in Insp Rept 50-271/89-17 on 890906-1016.Corrective Actions:Plant Procedures Revised & Addl Meetings Between Plant Manager,Dept Supervisors & Personnel to Take Place
BVY-90-003, Forwards Minutes of NRC 890907 Meeting W/Util in Rockville,Md Re Util LOCA Analysis Program.List of Attendees Also Encl
BVY-90-002, Informs That Util Has Implemented Fitness for Duty Program, in Compliance w/10CFR26
ML20005G084
BVY-90-005, Forwards Revised Page 127 of Tech Specs to Clarify Proposed Change 134, Rev of Pressure Suppression - Reactor Bldg Vacuum Breaker Sys Operability Requirements. Change Involves Adoption of Language Consistent W/Bwr STS
BVY-90-006, Forwards Addl Info Re Testing of Cable Vault C02 Suppression Sys During 891031-1102,per NRC 890518 & 0821 Requests.Encl Final Test Rept Demonstrates That Carbon Dioxide Sys Will Satisfy Design Bases for Greater than 10 Minutes in Room
BVY-90-007, Forwards Responses to Generic Ltr 89-13 Re Svc Water Sys Problems Affecting safety-related Equipment.Establishment of Program Revs Prior to Startup from Next Refueling Outage, Scheduled for Fall 1990,planned
BVY-90-011, Responds to 891226 Request for Addl Info Re YAEC-1683 on MICBURN-3/CASMO-3/TABLES-3/SIMULATE-3 Benchmarking.Hot Eigenvalue Std Deviation on Table 5.7 of YAEC-1683 Reduced to 0.00098 w/SIMULATE-3
BVY-90-012, Responds to Weaknesses Noted in SALP Rept 50-271/88-99 for Jul 1988 to Sept 1989.Implementation of Emergency Response Facility Info Sys Nearing Completion & Remaining Safety Class Vendor Manuals Will Be Completed During 1990
BVY-90-016, Provides NRC W/Results of Licensee Review of Design Bases & Operability Status of torus-to-reactor Bldg Vacuum Breakers
BVY-90-024, Responds to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey. Completed Survey Questionnaire Sheets Re Various Insps,Audits or Evaluations Encl
BVY-90-028, Forwards Proprietary Vermont Yankee Evaluation Model Sample Problem 0.7 Ft(2) Break in Recirculation Discharge Loop, in Response to 900208 Telcon.Rept Withheld (Ref 10CFR2.790)
ML20033F086
BVY-90-027, Informs of Schedular Changes Made W/Regard to Plant Licensed Operator Requalification Training Program
BVY-90-031, Forwards Method for Generation of One-Dimensional Kinetics Data for RETRAN-02, Per NUREG-0393 & 891211 Request
BVY-90-030, Forwards Rev 1 to YAEC-1693-A, Application of One- Dimensional Kinetics to BWR Transient Analysis Methods, Per NUREG-0390
BVY-90-033, Forwards Supplemental Info Re Feedwater Check Valve V28B Flaws Evaluation,Per NRC Request.Util Remains Committed to Replacement of Subj Valve During Upcoming 1990 Refueling Outage
ML20012D030
BVY-90-036, Forwards Supplemental Info to 1989 Primary Containment Leak Rate Test Rept,Justifying Test Duration of Less than 24 H & Clarifying Verification of Calculation,Per NRC Request
BVY-90-037, Confirms Util Plans to Install Passive Containment Overpressure Protection Capability.Sys Will Be Designed Under 10CFR50.50 Rules & Installed During 1992 Refueling Outage
BVY-90-038, Provides Supplemental Response to Station Blackout Rule (10CFR50.63).Util Will Use Alternate Ac Power Source Available within 10 Minutes of Onset of Station Blackout to Meet Requirements of Station Blackout Rule
ML20034A969
BVY-90-045, Forwards Proprietary Responses to Questions 1 & 4 of NRC Re Rev to FROSSTEY-2 Fuel Performance Code.Encl Withheld (Ref 10CFR2.790)
ML20042E729
BVY-90-050, Responds to NRC Bulletin 90-002, Loss of Thermal Margin Caused by Channel Box Bow. Util Does Not Presently Use Channel Boxes in-core for Longer than One Bundle Lifetime
ML20034C815
BVY-90-049, Forwards Vermont Yankee Nuclear Power Station Annual Radiological Environ Surveillance Rept 1989
BVY-90-051, Ack That NRC Will Issue Supplementary Info to NRC 900307 Request for Installation of Neutron Flux Monitoring Instrumentation That Conforms to Requirements of Reg Guide 1.97 & 10CFR50.49 at Plant
BVY-90-054, Forwards Proprietary Supplemental Info to 900419 Response to NRC Re FROSSTEY-2 Fuel Performance Code.Info Withheld
BVY-90-058, Forwards Public Version of Vermont Yankee Nuclear Power Station Emergency Response Preparedness Exercise 1990. Exercise Scenario Package Includes All Info Pertinent to Performance of Exercise Scheduled for 900718
BVY-90-061, Informs That Util Intends to Utilize Relationship Between Frosstey & FROSSTEY-2 to Support Cycle 15 Calculations.Nrc Approval of FROSSTEY-2 Needed by Aug 1990 for LOCA Analysis Program
BVY-90-062, Informs of Three Organizational Changes That Will Become Effective on 900601.WP Murphy,Jp Pelletier & DA Reid Will Be Senior Vice President of Operations,Newly Created Vice President of Engineering & Plant Manager,Respectively
BVY-90-065, Forwards Accepted Version of YAEC-1363-A, CASMO-3G Validation, Per NRC
BVY-90-064, Forwards Accepted Version of YAEC-1683-A, MICBURN-3/ CASMO-3/TABLES-3/SIMULATE-3 Benchmarking of Vermont Yankee Cycles 9 Through 13
BVY-90-067, Responds to Second Request for Addl Info on Use of RELAP5YA. Explanation Re Why More Accurate View Factor Calculation Not Included in Huxy Code Addressed
BVY-90-070, Requests Temporary Waiver of Compliance from Tech Spec Requirements for Limiting Conditions for Operation for Certain post-accident Monitoring Instrumentation Listed in Tech Spec Table 3.2.6.Parameters Listed
BVY-90-072, Forwards Supplemental Effluent & Waste Disposal Semiannual Rept for Third & Fourth Quarters 1989,Including Annual Radiological Impact on Man for 1989
BVY-90-078, Forwards List of Refs for Proposed Change 161 to Facility OL & Tech Specs
BVY-90-071, Forwards Rev 2 to Training & Qualification Plan.Rev Withheld (Ref 10CFR73.21)
BVY-90-082, Informs That Effective 900723 Facility Implemented Rev 4 of Procedure Generating Package & Corresponding Revs to Eops. Revs Developed Per Rev 4 of BWR Owners Group Emergency Procedure Guidelines
BVY-90-084, Notifies NRC of Intentions to Install Test Fuel Assemblies & Test Control Blades During Cycle 15 Refueling Outage in Sept 1990
BVY-90-085, Informs That Sys Testing & Operator Training Successfully Completed & SPDS Declared Operable on 900813.Util Intends to Operate SPDS in Parallel W/Original Honeywell Gepac Plant Computer Until mid-Nov 1990
ML20059F668
BVY-90-086, Responds to NRC Re Violations Noted in Insp Rept 50-271/90-06.Corrective Actions:Incident Rept Initiated & All Required Locking Devices in Place by 900706
ML20059D983
BVY-90-087, Forwards Addl Info on Use of RELAP5YA Program for LOCA Analyses.Proprietary Encl Withheld
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
(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."
J 011 GOC 76p6i 5
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."
" 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.
L
4 9
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