ML20154M638

Responds to NRC Re Violations Noted in Insp Rept 50-029/88-02.Corrective Actions:Program for Dedicating commercial-grade Fuses to Be Used in QA Applications Established,Consistent W/Plant Procedure AP-0212

ML20154M638
Person / Time
Site:	Yankee Rowe
Issue date:	05/25/1988
From:	Drawbridge B YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
FYR-88-76, NUDOCS 8806020027
Download: ML20154M638 (3)

Text

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Ttlephone (617) 872-8100 TWX 710-380-7619 YANKEE ATOMIC ELECTRIC COMPANY y a T 1671 Worcester Road, Framingham, Massachusetts 01701 v

May 25, 1988 FYR 88-76 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) Letter, USNRC to YAEC, dated April 27, 1988 (c) Letter, YAEC to USNRC, dated April 26, 1988 (d) YAEC, LER 50-29/87-15 Revision 1, dated April 26, 1988

Subject:

Response to Inspection Report No. 50-29/88-02

Dear Sir:

Reference (b) documents a safety assessment team inspection conducted by Mr. N. Blumberg on January 10 through 15, 1988 at the Yankee Nuclear Power Station, Rowe, Massachusetts and the Yankee Atomic Electric Company, Framingham, Massachusetts. The report identified an activity that was not conducted in full compliance with NRC requirements. This activity was identified as a Severity Level IV violation. In accordance with 10CFR2.201, we hereby submit the following information:

Violation 10CFR50, Appendix B, Criterion VII, "Control of Purchased Material.

Equipment, and Services," the Yankee Operational Quality Assurance Program Manual, and Administrative Procedure AE-0211. "Material & Service Procurement Program" require that measures be taken to assure that purchased material conforms to procurement documents and that records of such conformance be I

retained. Additionally, 10CFR50, Appendix B, Criterion III, "Design Control" and the Yankee Operational Quality Assurance Program Manual require that ceasures be established to assure that regulatory requirements and the design bases are translated into specifications, drawings, procedures, and Jnstructions.

Contrary to the above, on January 13, 1988 during repair of a safety-related vapor containment high pressure alarm, fuses in the alarm bistable were replaced "in kind" with commercial grade fuses which were not purchased in conformance to procurement documents. In addition, although the fuses were replaced "in kind," the exact fuse size required for the vapor containment alarm was not translatrd into specifications, drawings, procedares, or instructions.

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.' Unitsd States Nuclear Rsgulatory Commission May 25, 1988 Page 2 FYR 88-76

Response

We concur with the Notice of Violation as described above and in Reference (b).

I. Event Description On Ja.nuary 13, 1988, Maintenance Request MR 88-89 was initiated for the Instrumentation and Control Department to troubleshoot and repair a failed vapor container pressure channel, VC-PI-243. The failure was determined to be a blown fuse in the alarming circuit.

The fuse was replaced "in kind" from the stock in the Control Room.

This stock of fuses was not purchased under a program to ensure that commercial grade fuses pesress the required measures of assurance to allow their use in safety-related applications.

II. Corrective Steps Which Have Been Taken and Results Achieved A program has been established for the dedication of commercial grade fuses to be used in Quality Assurance (QA) applications. The program consists of purchasing the fuses in accordance with plant Precedure AP-0212. "Control of Purchased Material, Equipment, and Services." Plant maintenance personnel have been instructed in this program.

III. Corr.ective Steps Which Will Be Taken To Avoid Further Violations Yankee intends to perform the following steps:

A. QA Fuse Documentation Program We plan to implement a fuse documentation program. The program will consist of preparing a work instruction to identify the scope of fuses requiring QA, standardizing fuse size guidelines, performing a walkdown of plant systems to document fuse location and sizes, and updating the applicable plant drawings.

B. Utilization of Commercial Grade Items We intend to modify Yankee procedures to include specific guidance on the acceptance of all commercial grade equipment for use in QA applications. This guidance will be developed using EPRI NP-5652 "Guidance for the Utilization of Commercial Grade Items in Nuclear Safety-Related Applications (NCIG-07)."

It will include a requirement to determine the critical characteristics and the means by which verifiestion of acceptability will be performed when any commercial grade item is used in a QA application.

.- V.

~I United States Nuclear Regulatory Commission May 25, 1988 FYR 88-76 Page 3 IV. The Date When Full Compliance Will Be Achieved The QA Fuse Documentation Program will begin this summer to support initial system walkdowns during our Cycle 19-20 refueling outage scheduled late this year. We intend to complete our system walkdowns during our Cycle 20-21 refueling outage (Summer 1990) with a final verification walkdown, if necessary, during the Cycle 21-22 refueling outage (Spring 1992).

The modification to the Yankee procedures to include specific guidance on the acceptance of all commercial grade equipment for use in QA applications will be completed by November 1, 1988.

Additionally, we were requested in Reference (b) to respond to four questions about our main steam line pressure switches and three identified weaknesses. These items will be addressed in a separate letter by June 30, 1988. However, as an update to your report, Yankee submitted a 10CFR21 Report and a revision to LER 50-29/87-15 on the main steam line pressure switches on April 26, 1988, Reference (c) and (d).

If you have any questions or desire additional information, please contact us.

Very truly yours, YANKEE ATOMIC LECTRIC COMPANY h A Av, f B. L. Drawbr(dge Vice Presidenhtd Manager of Operations GP/25.607 cc: USNRC Region I USNRG Resident Inspector, YNPS William V. Johnston Acting Director, Division of Reactor Safety USNRC Region I

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