ML20128P277
| ML20128P277 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/29/1985 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| FVY-85-48, NUDOCS 8506030498 | |
| Download: ML20128P277 (11) | |
Text
a i
VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 85-48 l
RD 5. Box 169, Ferry Road, Brattleboro, VT 05301
,,,Ly 7g.
ENGINEERING OFFICE p
1671 WORCESTER ROAD FRAMINGHAM, MASSACHUSETTS 01701 TELEPHONE 617-872-8100 May 29, 1985 U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Dr. Thomas E. Murley Regional Adminis':rator
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, Inspection Report No. 50-271/85-11, dated 4/2/85 c).
Letter, USNRC to VYNPC, NVY 85-72, Notice of Violation and Enforcement Conference Report, dated 4/25/85
Dear Sir:
Subject:
Response to Notice of Violation and Enforcement Conference 50-271/85-11 This letter is written in response to your April 25, 1985 Notice of Violation and Enforcement Conference Report [ Reference c)], which pertains to findings resulting from the inspection of our Receipt Inspection Program con-ducted on March 11-15, 1985. These findings are detailed in Inspection Report No. 50-271/85-11 [ Reference b)]. The April 25 Notice of Violation indicates that certain activities were not conducted in full compliance with Nuclear Regulatory Commission requirements. The alleged violation has been categorized as Severity Level IV.
The following information is submitted in response to the alleged violation contained in Appendix A of the April 25 Notice of Violation.
FINDING 10 CFR 50, Appendix B, Criterion VII states in part:
" Measures shall be established to assure that purchased material, equipment...whether purchased directly or through contractors and subcontractors conform to the procurement documents. These measures shall include provision, as appropriate, for... examination of products upon delivery." Additionally, 10 CFR 50, Appendix B, Criterion XIII states in part:
" Measures shall be established to control the... storage,...and preservatio1 of material and equipment in accordance with work and inspection instructions to prevent... deterioration."
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission May 29,-1985 Page 2 Paragraph C.1.f of Section VII, of the Yankee Operational Quality Assurance Manual, YOQAP-1-A, states:
" Satisfaction of this criterion (VII) shall be assured through... receipt inspection of vender furnished material to assure... material and documentation are inspected in accordance with pre-determined instructions and are determined acceptable prior to use."
Paragraph C.1.b of Section XIII of YOQAP-1-A states:
" Satisfaction of this criterion (XIII) shall be assured through the... preparation of instructions in accordance with design and specification requirements which control the... storage...of safety classified materials...to preclude... deterioration by environmental conditions such as temperature or humidity."
Contrary to the above, as of-March 15, 1985, VY implementing procedures AP 0801 and AP 0803 were inadequate in that these procedures:
(1) failed to provide sufficient predetermined instructions which resulted in incomplete, careless and nonrepresentative receipt inspections as exemplified by receipt inspection reports for solenoid valves (PO 14409, PO 9706), collets and pistons (PO 16480, PO 12259), relays.(PO 10269, PO 18047), Diesel Generator Fuel Filter cartridges (PO 22041), ninety degree angles (P0 22396, PO 22711) and Kwik bolts (PO 22554, 22706); (2) failed to define preventive maintenance requirements for the storage of safety classified materials to preclude deterioration by environmental conditions such as temperature and humidity and as exemplified by PO 10269 whose items had not been examined for six years although the manufacturer recommended examina-tions at three year intervals.
This is a Severity Level IV Violation (Supplement I).
RESPONSE
The receipt inspection procedure deficiencies described in Appendix A of the April 25 Notice of Violation have resulted in the following corrective actions:
l I.
Corrective Steps Which Have Been Taken And The Results Achieved A.
~0n March 18, 1985, the Plant Manager issued an "Immediate Action" memorandum which documented certain corrective measures that were put into place on March 14 and were to remain in effect until further notice. These measures are as follows:
1.
All safety class materials requested to be issued from plant Stores required an additional receipt inspection (second receipt inspection) prior to being released from Stores for use in the plant.
Department Instruction (85-01), which provided guidelines for performing the second Receipt Inspection, was issued on March 20, 1985.
f' VERMONT YANKEE NUCLEAR POWER CORPORATION
.U.S. Nuclear Regulatory Commission
~May 29, 1985 Page_3
-No problems have been noted during any of the second receipt
. inspections performed that resulted in any item being rejected or not released for its intended use.
22.
All purchase orders with affected materials cited by the NRC inspectors were tagged and relocated into a " Material Hold" area pending a further receipt. inspection before being placed back into-inventory and made available for use in the plant.
A second inspection was performed on each of the eleven (11) purchase order items in question and no problems were dis-covered causing any materials / parts to be rejected. These inspections were performed in accordance with the provisions of Department Instruction 85-01.
-3.
The. Operational Quality Assurance Department (0QAD) was
' instructed to review the past two years of internal audits in the area of receipt inspection to determine if any related issues had been addressed.
A review was performed by OQAD on the procurement and-material control audits for the past two years to see if any receipt inspection issues were identified that were similar 7
to the problems identified in the NRC audit. The l~
Procurement and Material Control Audit Reports reviewed were l
A/R Nos. VY-93-08 dated 8/1-5/83, and VY-94-8 dated p
10/16-19/84.- The review indicated that the audits have identified deficiencies involving compliance with VY pro-
.cedure AP 0801, " Receipt Inspection and Shipment of Material and Equipment." However, these deficiencies were not the same as those~ identified by the NRC.
4.
For those purchase orders and materials specifically cited by the NRC Inspectors as examples leading to their findings, san engineering evaluation was performed for any related
' parts or materials known to be in use at the plant.
The engineering evaluations addressed the significance or
. potential impact of each component that is in service.
Evaluations were based upon inspections performed prior to or during installation,' post-installation testing of the component or associated system, observation or demonstra-tion of systems' operability and periodic surveillance testir.g of the component or associated system. The eval-untion was further supported by the results of receipt
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VERMONT YANKEE NUCLEAR POWER CORPORATION j
-U.S. Nuclear Regulatory Commission May 29, 1985 Page 4 inspection of representative samples of identical line items from the purchase orders involved. The results of the evaluations indicate that there is no concern that the associated part or component will not perform its intended safety function.
B.
On March 18, 1985, a Receipt Inspection Task Force was formed to review the Receipt Inspection Program and safety-related materials storage preventive maintenance practices, and make recommendations to the Plant Manager for programmatic improvements.
The Task Force review included an evaluation of specific procedures, interviews with receipt inspectors, review of NRC Inspection Report No. 50-271/85-11, a review of standards specific to receipt inspection and the review of receipt inspection practices at other facilities.
~The Task Force was also responsible for developing short-term and long-term recommendations that would enhance or otherwise improve the Receipt Inspection Program at Vermont Yankee by clarifying and better defining receipt inspection actions and requirements.
The first action of the Task Force was to implement additional interim measures until long-term programmatic improvements could be developed and approved by management. These measures included:
1.
To ensure that all subsequent receipt inspections were properly performed and documented, guidelines were developed to supplement the existing plant receipt inspection procedure (VYAP 0801) and the associated checklist (VYAPF 0801.01). As discussed above, these guidelines were formally adopted and incorporated into the procedure on March 20, 1985 (Department Instruction 85-01).
2.
Effective March 18, 1985, all safety class parts and materials received shall be 100% receipt inspected, except for specifically approved and documented situations, until an appropriate sampling program is established and approved by management.
3.
Stores personnel were directed to perform a complete check of warehouse facilities to determine if any additional safety class material existed similar to that discovered by the Nuclear Regulatory Commission (e.g., unopened boxes) during their inspec-tion (Inspection No. 85-11). Twenty-two (22) such purchase orders were identified. All twenty-two (22) purchase orders underwent a second receipt inspection and no items were found to be unacceptable for use in the plant.
p VERMONT YANKEE NUCLEAR POWER CORPORATION.
- U.S'. Nuclear Regulatory Commission May 29,~1985 Page 5 4.
All safety-related items with dessicant, including the items'spe--
cifically cited in the Notice of Violation, have been identified and the dessicant inspected. No expended dessicant was found.
A list of safety-related items stored with dessicant has been developed and is being maintained for future periodic inspections.
II.
Corrective Steps Which Will Be Taken T_o Avoid Further Violations b
The results and recommendations of the Task Force efforts have been f^
documented in a report which was submitted to the Plant Manager on May 1,.1985.
In summary, the Task Force Report concluded that the following enhance-ments.should be incorporated into the Receipt Inspection Program at Vermont Yankee:
1)-
Procedural Revisions Vermont Yankee Procedures AP 0800, Material and Service Procurement; AP 0801, Receipt Inspection and Shipment of Material and Equipment; AP 0803, Storace o,f_ Materials and Equipment; AP 0806, Issuina and Returning o_f, Material, Parts and Components; and DP.0811, Administrative Department Personnel Trainina be revised to ensure, among other things, that:
o
. Ordering department personnel provide additional technical information on purchase requests to aid the receipt inspec-tor in performing an inspection.
t o
The level of qualifications for receipt inspectors be clearly specified.
o Provisions for deferred receipt inspection of parts received in hermetically sealed containers or otherwise specially packaged for long-term storage be established.
o Specific sampling criteria to be used for receipt inspection of parts and materials be established.
o The Receipt Inspection Checklist (VYAPF 0001.01) includes specific guidance to inspectors to ensure that the scope of the inspection is accurately indicated. Disposition terms "yes" and "no" should be changed to the more appropriate terms " satisfactory" and " unsatisfactory". Also, the
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission i
May 29, 1985 Page 6 l
checklist should incorporate provisions to indicate that certain inspection requirements are not applicable for cer-tain items / materials and include a " reviewed by" sign-off block to insure that a second review is performed.
o A method is established to identify and track materials received which require special periodic monitoring or pre-ventive maintenance while in storage.
This includes main-taining a log of all such items and formally documenting these activities.
o Reference is made to ANSI N45.2.6-1978, Qualification of i
Inspection, Examination, and Trainina Personnel for Nuclear Power Plants, which is used as the governing document for certifying Stores Quality Assurance Technicians to a Level II classification.
o A Receipt Inspection Training and Retraining Certification form is initiated for the purposes of documenting each receipt inspector's certification level and qualifications.
2)
General Guidelines for Document Review A document review guideline should be established to provide guidance to receipt inspectors when reviewing (1) certificates of conformance; (2) certified material test reports; (3) type test reports and certifications; (4) special process reports; (5) major repair records; and other such technical reports.
3)
General Inspection Guidelines for Mechanical Components A mechanical component inspection guideline should be established to be used as a reference document to support receipt inspections of certain product forms, raw materials, major components, parts, and subcomponents for mechanical applications.
4)
General Inspection Guidelines for Electrical Components An electrical component inspection guideline, similar in scope to that described in item (3), should be established.
VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission May 29, 1985 Page 7 5)
Recommendation For Measuring And Test Equipment To Aid In The Performance Of Receipt Inspections A basic list of calibrated and non-calibrated devices / tools to aid the receipt inspector has been developed.
It was recommended that these devices be purchased and made available to qualified receipt inspectors.
6)
Establishment of a Reference Library A reference library should be established in the Quality Assurance receipt inspection area to provide ready reference documents for receipt inspectors. Reference materials would include, but not be limited to, ANSI Standards, material specifi-cations, reference handbooks, manufacturer standard specifica-tions, manufacturer catalogs, etc.
7)
Establishment of a Formal Trainino Program A formal training program should be developed and conducted by the plant Training Department. The program should provide training on all aspects of the Receipt Inspection Program as well as the filling out and processing of Material / Service Purchase Requests (MSPR's). This training should be provided to indivi-duals involved in the ordering of any Safety Class materials /
parts or having responsibility for receipt inspection activities.
8)
Receipt Inspection Manpower Requirements Because of the scope of the recommended programmatic enhancements described above, the Task Force concluded that two (2) full-time receipt inspectors dedicated to the receipt inspection process will be necessary. Additionally, realignment of other duties and responsibilities presently placed on receipt inspection personnel should be addressed. The report includes several options to remedy this situation.
The proposed revisions to the receipt inspection implementing proce-dures and associated training procedures, as well as the proposed administrative guidelines, were included in the Task Force Final Report. The Plant Manager reviewed the Final Report and met with the Task Force on May 13, 1985 to discuss their findings and to clarify the scope and intent of certain recommendations. As a result of this meeting, the Plant Manager issued a memorandum on May 15, 1985 which:
-u VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission May 29, 1985 Page 8 2
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U 1)
Endorsed all of the Task Force procedure revisions and admin-istrative guidelines (with minor revisions), directed the establishment of a mechanism for control of the administrative r
guidelines, and directed further strengthening of the proposed preventive maintenance requirements for the storage of safety
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classified materials.
t 2)
Directed the Task Force to incorporate additional clarification language into certain procedures and guidelines which were agreed to at the May 13 meeting.
3)
Directed the Stores Supervisor to provide for the necessary 4
training of receipt inspection personnel.
4)
Committed to pursuing the additional personnel necessary to augment the exinting receipt inspection staff.
]
5)
Directed the Stores Supervisor to purchase the recommended measuring devices / tools and establish necessary control and calibration provisions.
1 3
6)
Directed the Stores Supervisor to procure the Task Force recom-5 mended technical reference documents (as well as any others that 3
are deemed necessary).
5 III. The Date When Full Compliance Will Be Achieved
-u The programmatic enhancements described above are scheduled to be imple-1 mented as follows:
]
o The procedure revisions a7d new guidelines are scheduled to be for-mally reviewed and approved no later than July 10, 1985.
m o
The necessary additional formal training of receipt inspection person-nei, as well as other employees with responsibilities for materials and
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service purchase, is scheduled to be complete by the end of July 1985.
g The formal training of any new receipt inspection personnel will be completed prior to their assuming receipt inspection duties.
2 8
o The upgraded Receipt Inspection Program, including the enhanced pre-5 ventive maintenance practices, will be in effect on or before August i
1, 1985.
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission May 29, 1985 Page 9 1
Until the upgraded program is fully implemented, the Department Instruction and related administrative guidelines that were put into place as interin measures will remain in effect. However, based on the satisfactory results of the interim requirement to perform second receipt inspections-(those performed to date) and the completed engineering evaluations, the interim requirement for the second receipt inspection of any safety-related materials released by Stores for use in the plant has been rescinded.
IV.. Actions Taken Or Planned To Assure That The Adequacy of Safety-Related Material Received, Stored Or Installed At the Plant Has Not Been Affected By The Deficiencies In The Receipt Inspection Program 1.
Since the initiation of the second receipt inspection of safety related items being issued from Stores, 64 items have undergone this special inspection and none have been rejected (March 15 to May 6, 1985).
2.
Of the eleven (11) safety class purchase order items identifieo by the
'NRC and the twenty-two (22) identified by Vermont Yankee, all under-went a second receipt inspection and no items were rejected.
3.
For those eleven (11) safety class purchase order items identified by the NRC, all have undergone an engineering evaluation, accounting for materials issued and installed in the plant. This engineering eval-uation ensured a high confidence level of the acceptability for those parts issued and in service in the plant.
4.
The surveillance program at Vermont Yankee demonstrates the operabi-lity of safety-related equipment on a' continuing basis. The reliabi-lity of this equipment continues to be excellent.
5.
Vermont Yankee is in the process of performing an engineering eval-uation on those safety class purchase order items (22 purchase orders) identified by Vermont Yankee. This evaluation will be con-ducted similarly to the previous one for the NRC identified items and is expected-to be completed by June 30, 1985.
V.
Actions Taken Or Planned To Improve The Effectiveness Of Vermont Yankee's 0/A Program Implementina Procedures And Their Administration As discussed above, Vermont Yankee is in the process of revising the imple-menting procedures associated with the Receipt Inspection Program. We believe these revisions, coupled with the increased emphasis on receipt inspector training provisions, adequately address the NRC's concerns and assure that Vermont Yankee can demonstrate compliance with 10CFR50 Appendix 8 requirements for receipt inspection.
VERMONT YANKEE NUCLEAIt POWEll CORPORATION U.S. Nuclear Regulatory Commission May 29, 1985 Page 10 We recognize that the recent Region I inspections of our Quality Assurance related activities have identified specific deficiencies which raise questions relative to Vermont Yankee management's control of these activi-ties. Although we have taken prompt action to address specific areas of concern, we have concluded that a comprehensive management review of our Quality Assurance Program is warranted. We are presently determining the level of review necessary to demonstrate the adequacy of Quality Assurance related activities and expect to define the scope and schedule for this review in the near future.
l At a minimum, the assessment will address the effectiveness of our Quality Assurance implementing procedures and their administration. We will keep our Region I Resident Inspector appraised of our plans as well as the results of thic assessment and any actions deemed necessary by Vermont Yankee management to address assessment findings.
VI.
Additional Clarification As you are aware, Vermont Yankee and Yankee Atomic Electric Company person-nel were in the process of performing an assessment of our receipt inspec-tion practices in early 1985. The purpose of this assessment was to identify and scope out perceived deficiencies in the existing Receipt Inspection Program and formulate recommendations for any necessary modifi-cations or improvements to the program. The recommendations would then be forwarded to management for consideration and disposition. The assessment was not intended to specifically address our compliance to the provisions of Appendix B to 10 CFR 50, nor did it conclude that any specific procedure or practice was in non-compliance with Appendix B.
Thus, the statement in your April 25, 1985 letter that the Administrative Supervisor, who par-ticipated in the assessment effort,
"...was aware as early as January 1985 that your receiving inspection practices were not in compliance with NRC requirements," implies that non-compliances were identified as a result of the assessment, which is not the case.
As discussed at the Enforcement Conference held on April 11, 1985, the for-mal results of Vermont Yankee's internal assessment of our Receipt Inspection Program were issued by the assessment team to Vermont Yankee management during the same week that the Region I inspectors were con-ducting their audit. When the Plant Manager became aware of the findings, he related them to the Region I inspectors.
It was not his intent to miti-gate the severity of the findings, as stated in your April 25 letter, but to make the inspectors aware of the assessment team's findings and their proposed corrective actions. Because Vermont Yankee management had not had an opportunity to review and assess the team's findings, any notification to the NRC prior to that time would have been premature.
i
VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission May 29, 1985 Page 11 i-We recognize the time lapse between the time the assessment team completed
- their evaluation and the time management was made aware of the results. We will reemphasize the need for personnel to ensure that such findings are brought to the attention of Vermont Yankee management in a timely manner.
In addition, any such findings, as well as any necessary corrective actions, will be brought to the attention of our Resident Inspector.
We trust that this information is deemed to be satisfactory; however, should you have any questions regarding this matter, please contact ur,.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION Warren P Murph Vice President a Manager of Operations c.
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