ML20004E729

Responds to NRC 810316 Ltr Re Violations Noted in IE Insp Rept 50-271/80-19.Corrective Actions:Valve Lineups Will Be Properly Documented & Initialed by Shift Supervisor & Incorrectly Classified Plant Procedures to Be Reclassified

ML20004E729
Person / Time
Site:	Vermont Yankee
Issue date:	03/16/1981
From:	Conway W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20004E728	List: ML20004E729
References
FVY-81-42, NUDOCS 8106150126
Download: ML20004E729 (6)

Text

. ,.

VERMONT YAN KEE NUCLEAR POWER CORPORATION Sr.sENTY SEVEN GROVE STREET 2.C.2.11 RUTLAND. VERMONT 05701 FVY 81-42 REPLY TO:

ENGINEERING OFFICE 1671 WORCESTER ROAD FR AMINGH AM, M ASS ACH USETTS o17ol TELEPHONE $17 872-0100 March 16, 1981 United States Nuclear Regulatory Commission Office ef' Inspection and Enforcement Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: Of f Lee of Inspection and Enforcement Mr Eldon J. Brunner, Chief Retetor Operations and Nuclear Support Branch

References:

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

(b) USNRC Letter to Mr. Robert L. Smith, VYNPC, dated February 12, 1981, Inspection No. 80-19

Dear Sir:

Subjecr: Response to I&E Inspection No. 80-19 Thir - is written in response to Reference (b) which indicates that son _c activities were not conducted in full compliance with Nuclear Rebalatory Commission requirements. The Alleged Severity Level V and Level VI violations were cited during an inspection conducted November 17-21, 1980, by your Mr. N. Blumberg, at Vermont Yankee Nuclear Power Station in Vernon, Vermont. Information is s.Jamitted in the fol-lowing paragraphs in answer to the alleged Item A (Severity Level V) and Item B (Severity Level VI) violations.

A. Technical Specifications 6.5.A, C, and D, state, in part, the following:

"A. Detailed written procedures... including applicable checkoff lists... covering...(operation...of systems and components of the facility...) shall be prepared...ap-proved (and)... adhered to... C. Procedures...shall be reviewed and approved by the Plant Superintendent...and the Manager of Operations... D. Temporary changes to procedures...shall be documented and subsequently re-viewed by the PORC and approved by the Plant Superin-tendent..."

!84106150 @

~

VERMONT YANKEE NUCLEAR POWER CORPORATION United States Nuclear Regulatory Commission March 16, 1981 Page 2 Contrary to the above, improperly approved system valve lineup checkoff lists were performed; in that:

I. 0.P. 2123, Core Spray System, system valve lineup COL, Revision 10; 0.P. 2112, Reactor Water Cleanup System, system valve lineup COL, Revision 10; 0.P. 2126, Diesel Generator, system valve lineup COL, Revision 9; and several other system valve lineup COLs with revision numbers later than the currently approved revision numbers were observed in use. These revisions to the valve lineup COLs had been reviewed by tho ?0RC but had not yet been approved by the Plant Superintendent and/or the Manager of Operations.

Response

We disagree with the inspector's findings on this item.

Subsequent to his exit interview, we determined that the pro-cedures in question had, in fact, been reviewed by the Plant Operati s Reviev Committee and approved by the Operations Superv! ,r and the Plant Superintendent prior to the valve lineup sheets being released to the operators. None of the plant systems identified in the Notice of Violation were re-quired to be operable for the mode trat the plant was,in at the time. Specifically, there was n, fuel in the reactor vessel from the period of November 11, 1980, to December 9, 1980. Subsequent review and approval of the prccedures by the Manager of Operations resulted in absolutely no changes to the valve lineups as they were approved by the Plant Su-perintendent.

II. Valves were added or deleted from the following valve lineups previously performed during 1979 without changes being documented, reviewed by the PORC, or ap-proved by the Plant Superintendent:

(1) Valve CU-50 was deleted from 0.P. 2112, Reactor Water Cleanup System, Appendix A, valve lineup COL, Revision 8; (2) Valve VG-4B-1A was added to 0.P. 2125, Contvinment Atmosphere Dilution System, Appendix A, valve lineup COL, Revision 3; and (3) Valves SW-200A-D were deleted from 0.P. 2181, Service Water, Appendix A, system valve lineup COL, Revision 8.

.o VERMONT YANKEE NUCLEAR POWER CORPORATION United States Nuclear Regulatory Commission March 16, 1981 Page 3

Response

Procedure A.P. 0156, Valve Lineup File, provides for exceptions to normal valve lineups with certain stipulations.

We have traditionally interpreted that procedure to permit corrections to valve lineup sheets even to the extent of adding or deleting valves if such errors were discovered.

Permanent revision would, in those cases, be made to the affected procedure during its next routine review. A de-tailed review of that practice, in light of the inspector's findings, has led us to conclude that his finding is cor-rect and we will, therefore, revise the controlling proce-dure, A.P. 0156, to specifically limit the exceptions to valve positions to those that must be different as dictated by sys:em status, and will specifically require a procedure change for those valves that must be added or deleted from the lineup list.

B. 10 CFR 50, Appendix B, Criterion V, states, in part, "Activ-ities affecting quality shall be prescribed by documented instructions (or procedures...of a type appropriate to the circumstances..."

Yankee Operational Quality Assurance Program I-A (YOQAP-I-A),

Section II, Quality Assurance Program, requires, in part, compliance to the requirements of ANSI 18.7-1976.

ANSI 18.7-1976, Administrative Controls and Quality Assur-ance for the Operational Phase of Nuclear Power Plants, paragraph 5.2.12, states, in part, "The administrative con-trols...shall provide measures to control... issuance of documents...which prescribe activities affecting safety-related... systems or components...elso include (ing)...oper-ating prec.edures. . . (and) Paragraph 5.2.2 states, in part,

" Procedures shall be followed..."

The following administrative control procedures were not followed, in that:

- Procedure A.P. 0156, Valve Lineup File, paragraph 4, states " Changes to the normal valve positions are per-mitted when the system status dictates such changes are necessary. Each change, however, must be reviewed and initialed by the Shift Supervisor and provided with an explanatory note."

Contrary to the above, the following valve lineups performed by 1979 and maintained on file in the control

VERMONT YANKEE NUCLEAR POWER CORPORATION -

United States Nuclear Regulatory Commission March 16, 1981 Page 4 Room as the latest official valve lineups contained numerous valves or circuit breakers whose positionc l

were changed without an explanatory note being added or being initialed by the Shif t Supervisor:

(1) 0.P. 2143, 480 VAC System, Appendix A valve lineup COL, sheets 3 and 6.

(2) 0.P. 2153, Solid Radwaste, Appendix A valve linaup COL, sheets 2, 3, and 4.

(3) R.P. 2171, Condensate Demineralizer System, Appendix A valve lineup COL.

(4) 0.P. 2180, Circulating Water / Cooling Tower -

Operation, Appendix A, valve lineup COL, sheet 7.

- A.P. 0156, Valve Lineup File, paragraph 3, states, in part, " Completed copies of valve lineup sheets are re-turned to the Control Room and reviewed and signed by the Shift Supervisor..."  ;

Contrary to the above, the following valves were not lined up and were annctated as "Can't Locate" for 0.2.

2150, Advanced Off Gas System, Appendix V valve lineup performed during 1979 although the valve lineup sheet was signed as completed by the Shift Supervisor:

(1) OG-8, DP0 Generator Discharge (2) SRS-8, Stack Gas II Vent

Response

We agree with the inspector's findings with the excep-tion of example B.I(1) . Tae items referred to on sheet 3 were marked with the position they were found in and the procedure calls for "As Required." The reason for the "As Required" is that the breakers control heaters which are off in the summer and on in the winter. The items referred to on page 6 were specifically marked " Tagged Open" and were changed by the Shift Supervisor once the tags were cleared.

The discrepancies noted in the other valve lineups were resolved immediately and properly documented in the valve lineup file. The requirement in A.P. 0156 that each i

VERMONT YANKEE NUCLEAR POV/ER CORPORATION United States Nuclear Regulatory Commission March 16, 1981 Page 5 change aust be reviewed and initialed by the Shift Super-visor has to date been considered met by the Shif t Super-visor's signature at the end of the valve lineup. We agree, however, that some valve lineups are participated in by more than one shift and better control is assured if each individual exception is specifically initialed by the Shift Supervisor who approves the change. A.P. 0156 will be revised to more clearly stipulate this and training will be conducted on the new procedure.

The revision to A.P. 0156 to address the areas of concern in violations A and B above, and training to the new pro-cedure will be completed by July 15, 1981.

- A.P. 0001, Plant Procedures, which defines the cate-gories of plant procedures states, in part, "Ocerating Procedures (OP). These procedures describe a sequence of steps to be performed to properly operate some equipment, a component, a system of a combination of systems. Operating Precedures are required for...all Safety Class Systems as listed in YOQAP-1A [ Appendix E]

...[and] will be ... reviewed by the PORC... Routine Procedures (RP). These procedures concern those areas of plant operations not covered by Operating Procedures and encompass nonsafety related plant systems...[and]

will be reviewed by the PORC... Department Procedureg (DP). These procedures affect only the originating de-partment and include such subjects as: operation of department equipment, test methods... schedules... logs

...anl recordkeeping. [DPs do not require review by the PORC]."

Contrary to the above, the following procedures, which by definition, shou.J have been issued as OP3 or RPs were in-correctly issued as DPs and, in addition, did not receive PORC review:

(1) D.P. 1412, Jct Pump Inspection. This is a safety class component listed in YOQAP-1A, Appendix E.

(2) D.P. 2430, High fansity Fuel Boral Test. This is a safety class component listed in YOQAP-1A, Appendix E.

(3) D.P. 2445, IRM Calibration to Heat Balance. This is a safety class system listed in YOQAP-1A, Appendix E.

(4) D.P. 5334, TIP Shear Velve Squib Charge Replacement.

This is a nonsafety class system outside of the scope of the definition of DPs.

a , e VERMONT YANKEE NUCLEAR POWER CORPORATION United States Nuclear Regulatory Commission March 16, 1981 Page 6

Response

We agree with the inspector's findings. A review of all plant procedures against the procedure classification definitions will be conducted by May 15, 1981. All proce-dures deemed to be incorrectly classified will be reclassi-fied, reviewed, and approved at the appropriate levels by June 15, 1981.

We acknowledge your concern over the management control systems at Vermont Yankee; however, do not chare the same level of concern. With respect to Item A of the Notice of Violation, as we stated above, the procedures in question were approved by the Plant Superintendent prior to implementing the subject valve lineups. The judgements made took into full consideration the status of the plant which, as you acknowl-edge, was completely defueled; the fact that the systems referenced were not required to be operable for the plant conditions that existed; and that the new valve lineups sere an improvement over the previous revision of tha procedures.

We concluded, therefore, that the corrective action committed to herein is sufficient to assure that the minor technical violations cited will not be repeated and that the safe and efficient operation of Vermont Yankee will continue.

Very truly yours, t VERMONT YANKEE NUCLEAR POWER CORPORATION William F. Co ay Vice President and Manager of Operations STATE OF VERMONT )

)ss WINDHAM COUNTY )

Then personally 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.

liN _. h1Hib

. Jud Lth f. Harris Notr*y Public My Commission Expires Feb. ary 14, 1983 l

l a

4r-r"**MW-"1'W W M'e m*1rr MS T 44 -M t 7- F *'yP4NMe t'