ML20151P121
| ML20151P121 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 12/13/1985 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| EVY-85-118, NUDOCS 8601030306 | |
| Download: ML20151P121 (4) | |
Text
H V,ERMONT YANKEE NUCLEAR POWER CORPORATION RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 FgYg5-ll8 g
ENGINEERING OFFICE 1671 WORCESTER ROAD r-FR AMINGHAM. MASS ACHUSETTS 01701 YELEPHONE 617-872 8100 December 13, 1985 U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attn:
Mr. Edward E. Wenzinger, Chief Project Branch #3 Division of Reactor Projects
References:
a)
License No. OPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, Inspection Report 50-271/85-25, dated November 12, 1985 c)
Letter, USNRC to VYNPC, Inspection Report 50-271/83-22, dated September 30, 1983 d)
Letter, VYNPC to USNRC, Response to Notice of Violation and Enforcement Conference 50-271/85-11, dated May 29, 1985 e)
Letter, VYNPC to USNRC, FVY 85-116, Additional Information -
Follow-Up Actions to Address Receipt Inspection Program Deficiencies, dated 12/6/85
Dear Sir:
Subject:
Response to I&E Inspection Report 85-25 This letter is written in response to Reference b) which indicates that certain of our activities were not conducted in full compliance with the Nuclear Regulatory Commmission requirements.
These alleged violations (Levels V and IV, respectively) were identified as a result of a routine NRC inspection by your Resident Inspector, Mr. William J. Raymond.
The information is submitted as follows in answer to the alleged violations contained in the appendix of your letter.
Technical Specification (TS) 6.5.A requires that detailed written burveillance Procedures be prepared, implemented and followed. Procedure OP 4382 was written pursuant to the above and requires test personnel to verify that the recorder for Stack Gas Channel I meets the acceptance cri-teria of 2% accuracy at full scale output during quarterly calibration checks.
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y VIIItMONT YANKlit? NUCLl? Alt POWt!It COltI OllATION U.S. Nuclear Regulatory Commission December 13, 1985 Page 2 Contrary to the above, during calibration checks on Stack Gas Channel I on February 4 and April 30, 1985, the stack gas recorder did not meet the acceptance criteria of 2% accuracy, in that it indicated 9.0X10+5 counts per minute (cpm) when an output value of 1.0X10+6 cpm was required.
Further, technicians and supervisory personnel who reviewed the completed tests failed to detect the discrepant test results and initiate corrective actions.
This is a Severity Level V Violation (Supplement I.E.)
RESPONSE
1.
Corrective Steps Which Have Been Taken And The Results Achieved Subsequent to the discovery that the As Found/As Left data taken on the Stack Gas I recorder was out of tolerance and had not been identified as such during the data entry review process, the following steps were taken:
1.
AP 0310 was reviewed on 6/19/85 with all deportment personnel.
Emphasis was placed upon step A.13 "As Found/As Left data which is out of tolerance is to be circled and noted in the discrepancy section of the Data Sheet."
2.
AP 0310 was reviewed on 6/19/85 with the department foremen to re-emphasize their responsibility in the review process.
Additionally, the number of independent inspections verifying the proper data recording and supervisory review have been increased. No further occurrences of this nature have been identified to data.
Further, subsequent to this event and as a result of the violation iden-tified in NRC Inspection 50-271/85-11, a memo was issued by the Manager of Operations to all employees, emphasizing the responsibilities of personnel signing documentation.
2.
Corrective Steps That Will Be Taken to Avoid Future Violations Vermont Yankee's QA organization will perform a surveillance in this area by February 1, 1986 to assess the effectiveness of the corrective actions taken.
3.
Date When Corrective Action Will Be CompAt_ed The indicated corrective actions have been completed.
Further actions, however, may be dictated by the results of the surveillance to be completed by February 1, 1986.
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VEltMONT YANKEE NUCI.EAlt POWElt COltPOllATION U.S. Nuclear Regulatory Commission December 13, 1985 Page 3 VIOLATION B 10CFR50, Appendix B, Criterion XVI, Corrective Action, requires that measures be established to identify and correct conditions adverse to quality.Section XVI.C.I.a of the Operational Quality Assurance Program, YOQAP-1-A, implements the requirements of 10CFR50, Appendix B, and requires the licensee to implement corrective actions to preclude recurrence of a condition that is adverse to quality.
Contrary to the above, the licensee failed to implement corrective actions to preclude recurrence of deficiencies in the on-site QC Peer Inspection Program.
Deficiencies in the Peer Inspection Program were identified in Item A of the Notice of Violation transmitted to the licensee in NRC Region I inspec-tion (IR 83-22), dated September 30, 1983.
By letters FVY 83-114, d'ted a
Ocotober 26, 1983, and FVY 84-42, dated May 1, 1984, the licensee reported that corrective actions would be taken by November 1, 1984 to assure the proper performance and documentation of QA inspection of maintenance acti-vities completed under procedure AP 0021.
A licensee audit completed in March 1985 on (0QA Audit Report 85-11, dated April 5, 1985) identified several deficiencies in the on-site peer inspection process. Deficiency Items 1 through 4 of Audit 85-11 represent recurrence of NRC identified deficiencies that resulted in the above violation.
This is a Severity Level IV Violation (Supplement I.D.).
RESPONSE
As identified by our audit report, we agree with the NRC that improvements were necessary to the Quality Control Program.
1.
Corrective Steps Which Have Been Taken And The Results Achieved As stated in the NRC Inspection Report [ Reference b)], corrective action with respect to the deficiencies identified in QA Audit 85-11 have been in progress since April 1985. These actions were reviewed with the NRC at a meeting on 8/7/85 at Region I and include the creation of a Quality control Task Force, implementation of an enhanced interim QC Program, and the generation of a draft procedure to reflect the improved QC Program to be implemented at VY.
2.
Corrective Steps That Will Be Taken To Avoid Future Violations Our response to in-house QA Audit 85-11, as described in Item 1 above, represents a broad and comprehensive upgrade of our QC Program.
In addi-tion, we have committed to a comprehensive management review of our Quality Assurance Program, as described in Reference d), which will result in an assessment of the effectiveness of QA implementing procedures and their administration.
This review of our program is further described in our December 6, 1985 letter to Region I.
a VEllMONT YANKEE NUCLEAlt POWEll COltPOltATION U.S. Nuclear Regulatory Commission December 13, 1985 Page 4 3.
Date When Corrective Actions Will Be Completed Changes to procedures to reflect the improved QC Program discussed in 1 above as well as training to support the improved program, will be completed by January 1, 1986. An audit of the implementation of this program by our QA group has been scheduled for the second quarter of 1986.
The comprehensive management review of our QA Program is scheduled to be complete in early February 1986.
We trust that this information will be satisfactory; however, should you have any questions or desire additional information, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION adu~
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Warren P. Murphy Vice President and Manager of Operations
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