ML20198H548

From kanterella
Jump to navigation Jump to search
Rev 2 to Vermont Operational QA Manual,Voqam
ML20198H548
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 12/23/1998
From: Limberger W
VERMONT YANKEE NUCLEAR POWER CORP.
To:
Shared Package
ML20198H530 List:
References
RTR-REGGD-01.026, RTR-REGGD-1.026 NUDOCS 9812290364
Download: ML20198H548 (44)
v • d • e


Text

_ _ __ _ _ _ . _ . . . _ . . _ .. .. _ ._. _ _ . . . _

I VERMONT YANKEE NUCLEAR POWER CORPORATION l

Vermont operational Quality Assurance Manual VOQAM PREPARED BY: M_

WayneM[Limberger W  ;

Sr. Lic Engine REVIEWED BY: -

N

/.RussellClark Direc); , Quality Assurance REvrEWED DYs

/

i> lt/d/l[.

Robert J. W AAL&kV}

k[

_s i

Director of ety and Regulatory Affairs l

. .1 ,. L APPROVED BY: 7 TM4h '

i GrTo .

JedJre$

Director s operations '

vermont Y ee I

I l

l r

I' Titles voQAM Page: I 2

l Rev.:

l I 9812290364'981223 PDR ADOCK 05000271 e i P PM ,

___ . _ . . . , . . . . _ - - . _ . - . _ _ . _ , . _ _ _ _ _ _ . _m . _ _ _ . - . _ _ .

I l

VOOAM ]

l AMENDMENT / REVISION SHEET i l

)

Revision No. Date Reason I

l 0~ 5/1/98 To adopt Rev. 27 of the YOQAP as Rev. O for the l VOQAM. (Reference VY letter to NRC, dated j 4/12/98.) I 1 10/16/98 To update organizational changes, removed all references to YAEC and YNSD. VY assumed all YNSD responsibilities. Changed Sr. Vice President, Operations, to Director of Operations.

-l 2 TBD Revised Table of Contents /Index to identify l number of effective pages in each VOQAM l section. Adopted ANSI N101.4-1972/ Reg. Guide l 1.54 in Section II, page 4 of 7. Revised l Appendix B, page 17 OF 26, to address a l specific application of ANS-52.1-1983. Revised l Appendix B, page 23 of 26, to clarify j provisions for initiating procedure changes in l response to plant events, violations and l l nonconformances. l l

l I

l 1

. l l

Title:

Amendment / Revision Sheet

, Page: 1 l Rev.: 2 l

l 1

.. . . . _ _ _ , . _ . _ . . _ - . . - __ - _ _ . _ . _-.._---.._...-,._..m_m__

VOQAM TABLE OF CONTENTS /INDEX l Effective Current  ;

l Section'No. T, igg Pace (s) Revision-l l

AMENDMENT / REVISION -IV 2 )

I l

POLICY STATEMENT 1-2 1 1

'l I' ORGANIZATION 1 - 26 1

o l~ II QUALITY ASSURANCE PROGRAM 1-7 2 I j l III DESIGN CONTROL 1-4 1 l I i l IV PROCUREMENT DOCUMENT CONTROL 1-3 1 i

.l l V INSTRUCTIONS, PROCEDURES, AND 1-2 1

l. DRAWINGS j
l. l

-l. VI DOCUMENT CONTROL 1-4 1

-l l VII , CONTROL OF PURCHASED MATERIAL, 1-3 1 l EQUIPMENT, AND SERVICES e

I

'l VIII IDENTIFICATION AND CONTROL OF 1-2 1 l' MATERIAL, PARTS, AND COMPONENTS I -!

.l IX CONTROL OF SPECIAL PROCESSES 1-2 1 l

l' X INSPECTION 1-2 1 1

l-. XI TEST CONTROL 1-3 1 l

l XII CONTROL OF MEASURING AFD TEST 1-2 1 l EQUIPMENT l

l XIII HANDLING, STORAGE, AND SHIPPING 1-2 1 l

l XIV INSPECTION, TEST, AND OPERATING 1-2 1

,, l STATUS l

l t

l'

Title:

Table of Contents Pages- 1 of 2

.j Rev.
2

/

I _ , . . _. .

. _ _ . _.,_..._.m___,. . . _ . _ . . . . . . _ _ _.. _ ., . . . _ - . . . _ . . . _ . - - . . . _ _ _ . _ . . . . _ . . . . _ . . _ . . , .

1 I

-3 l~ VOQAM TABLE OF CONTENTS /INDEX l' Effective Current

' l Section No; Tidg Pace (s) Revision L I .

- l- XV NONCONFORMING MATERIALS, PARTS, 1-3 l' l AND COMPONENTS i l

l XVI ' CORRECTIVE ACTION 1-2 1 I l I

l XVII QUALITY ASSURANCE RECORDS 1-3 1 I

i

' l XVIII' AUDITS 1-4 1- ,

I i l ' APPENDIX A QUALIFICATION REQUIREMENTS l' 1 l 1

i l APPENDIX B' EXCEPTIONS 1 - 26 2 l l ,

l ' APPENDIX C VY CLASSIFICATION 1 1' j l

i l

l l

Title:

Table of Contents

-Page: 2'of 2 l l Rev.: 2 I '

. - . - . - - . - . _ - - _ - . . - . . . - _ - ~ . . . - - - - - - - - . . .-. - . - . . . . _ . .. -.

VERMONT YANKEE NUCLEAR POWER CORPORATION f

i l

II. OUALITY ASSURANCE PROGRAM t

! A. SCOPE This section establishes the criteria to be applied to systems requiring Quality Assurance which prevent or mitigate the consequences of postulated accidents which could cause undue risk l to the health and safety of the public. The structures, systems, components and other items requiring quality assurance are listed t in the vermont Yankee Safety classification Manual.

B. RESPONSIBILITIES

1. Compliance with the requirements of the Operational Quality Assurance Program - based on the criteria of Title 10 of the Code of Federal Regulations, Part 50, Appendix B, and ANSI N18.7-1976 - shall be the responsibility.of all personnel involved with activities affecting operational safety. The Plant shall have a matrix of major quality assurance procedures cross referenced to each applicable criteria of 10CFR50 Appendix B. The performance of quality-related activities shall be accomplished with specified equipment under suitable environmental conditions.

E213: Each criterion section for the Program incorporates the designation of specific organizational responsibilities.

2. Individuals having direct responsibilities for l establishment / distribution control / implementation of the Operational Quality Assurance Program are delineated in Section I " Organization" of the Program.

l l

Title:

Section II, Quality Assurance Program

! Page 1 of 7 l l Rev.: 2 l

l

- _ . _ . _ - - - ~ . - . - - - . . . - - .~ .

l VERMONT YANKEE NUCLEAR POWER CORPORATION i

l l

l C. IMPLEMENTATION Establishment of an effective Operational Quality Assurance Program is assured through consideration of and conformance with the Regulatory Position in the below listed Regulatory Guides as modified in Appendix B. Implementation of this Program is assured through Quality Assurance procedures derived from Quality Assurance policies, goals and objectives. The Quality Assurance Department shall review Quality Assurance program procedures to l 1

assure their derivation from the policies, goals and objectives established by the President.

1. Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants
3. ANSI N45.2.1-1973, Cleanina of Fluid Systems and Associated Comoonents Durina Construction Phase of Nuclear Power Plants (Endorsed by Regulatory Guide 1.37, March 16, 1973)
6. ANSI N45.2.4-1972, Installation, Insoection and Testina

, Reauirements for Instrumentacion and Electric Eculoment Durina the Construction of Nuclear Power Generatina Plants (Endorsed by Regulatory Guide 1.30, August 11, 1972)

Title:

Section II, Quality Assurance Program Page: 2 of 7 l Rev.s 2  ;

r

l l

VERMONT YANKEE NUCLEAR POWER CORPORATION i

7. ANSI N45.2.5-1974, Succlementary Ouality Assurance Reauirements for Installation, Insoection and Testino of I Structural Concrete and Structyral Steel Durina the Construction Phase of Nuclear Power Plants (Endorsed by Regulatory Guide 1.94, Revision 1) l
9. ANSI N45.2.8-1975, Sucolementary Ouality Assurance Recuirements for Installation, Insoection and Testina of Mechanical Eculoment and Systems for the Construction Phase l of Nuclear Power Plants (Endorsed by Regulatory Guide 1.116, Revision 0-R)
12. ANSI N45.2.11-1974, Quality Assurance Reauirements for the Desian of Nuclear Power PlantP, (Endorsed by Regulatory Guide 1.64, Revision 2)
13. ANSI N45.2.12-1977, Recuirements for Auditino of Ouality Assurance Procram for Nuclear Power Plants (Endorsed by Regulatory Guide 1.144, Revision 1)
14. ANSI N45.2.13-1976, Quality Assurance Recuirements for Control of Procurement of Items and Services for Nuclear Power Plants (Endorsed by Regulatory Guide 1.123, Revision 1)

Title:

Section II, Quality Assurance Program Page: 3 of 7 l Rev.: 2

.. -> - . - . .. . . - - . . . - ~ ~ . - - _ . - . -

t l

j VERMONT YANKEE NUCLEAR POWER CORPORATION

15. ANSI N45.2.23-1978, Qualification of Ouality Assurance Procram Audit Personnel for Nuclear Power Plants (Endorsed by Regulatory Guide 1.146, August 1980)
16. ANSI N18.1-1971, Selection and Trainina of Nuclear Power Plant Personnel (Endorsed by Regulatory Guide 1.8, Revision 1-R) l 17 ANSI.N101.4-1972, Quality Assurance for Protective Coatinas l Anolied to Nuclear Facilities (Endorsed by Regulatory Guide l 1.54) l f 18. Regulatory Guide 1.26, Revision 3, Qgality Grouc Classifications and Standards for Water . Steam , and Radioactive-Waste-Containino Comoonents of Nuclear Power Plants l
  • 19. Regulatory Guide 1.29, Revision 3, Seismic Desien Classification Notes: 1) When conflicts in similar requirements contained in Technical Specifications and the above documents exist, the requirements contained in Technical Specifications override those in the documents. Requirements in the documents will be considered when they supplement and are not in conflict with similar requirements in Technical Specifications.
2) Revisions to the above listed documents will be considered for applicability to the Vermont operational Quality Assurance Program upon written direction thereof by the Regional Administrator, Nuclear Regulatory Commission - Office of Inspection and Enforcement - Region I.

Title:

Section II, Quality Assurance Program Page: 4 of 7

( l Rev.: 2 l

VERMONT YANKEE NUCLEAR POWER CORPORATION

3) Only those documents listed above shall be considered applicable to the Vermont Yankee plant. Documents further referenced by the above listed documents shall not be considered applicable. They may, however, be considered as guidelines.
  • Exceptions and alternatives to the provisions contained in this Standard / Guide are detailed in Appendix B.
4) This Program shall be applicable to those activities requiring quality assurance which occur commencing within 90 days after acceptance of the Program by the Nuclear Regulatory Commission.
5) The NRC shall be notified of changes, that reduce commitments in the accepted description of the QA program, for their review and acceptance prior to implementation. Acceptance will be assumed 60 days after submittal unless notified otherwise.
6) Changes that do not reduce QA program commitments shall be submitted to the NRC at least annually.
7) Editorial changes or personnel reassignments of a nonsubstantive nature do not require NRC notification.

e I-I t

Title:

Section II, Quality Assurance Program Page: 5 of 7 l Rev.: 2 t

VERMONT YANKEE NUCLEAR POWER CORPORATION D. MANAGEMENT EVALUATION l

l The Director of Operations directs a thorough evaluation of the established Operational Quality Assurance Program by assigning the Nuclear Safety Audit and Review Committee the task of reviewing f for compliance with and evaluating the effectiver.ess of quality related activities.

! E. TRAINING i

! 1. The Training Manager is responsible for the indoctrination and training of staff personnel performing activities affecting operations or requiring quality assurance, and of the operators who are formally licensed or qualified.

2. Each Department Director / Manager is responsible for the indoctrination and training of department personnel performing activities affecting quality in applicable design and engineering, test, operational, construction, or quality phases.
3. The indoctrination and training programs shall provide the following:

l l

a. Instruction as to the purpose, scope, and i implementation of quality-related manuals, I instructions, and procedures.
b. Training and qualification in the principles and techniques of the activity being performed.
c. Documentation of the scope, objective, and method of implementing the program.
d. Maintenance of personnel proficiency by retraining, l j re-examining, and/or recertifying.

I,

Title:

Section II, Quality Assurance Program l Page: 6 of 7 i l Rev.: 2 l

., _ l

. . . _ , . _m-_ . - ,. . . _ . _ . . . . . _ _ . _ _ _ _ . . _ _ _ _ - . . . . . . _ . . _ _ . . - . . _ . _ . . . . _ . _ , _ . - _

i VERMONT. YANKEE NUCLEAR POWER CORPORATION

e. Documentation of the training sessions including content, attendance, dates, and results where applicable.

l k

l l

l f

I i

l d

Title:

Section II, Quality Assurance Progrart, i Page: 7 of 7 l Rev.: 2

,. , e . . ~.y- , - - - - - . _

f j APPENDIX B Exceptions The sub-categories of this Appendix summarize the exceptions noted in Section II of the Vermont Yankee Operational Quality Assurance Manual.

Appendix B Sub-cateoory Standard / Guide Title I. ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants II. ANSI N45.2.9-1974 Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants III. ANSI N45.2.10-1973 Quality Assurance Terms and Definitions IV. R.G. 1.64, Rev. 2 Quality Assurance Requirements for the Design of Nuclear Power Plants V. ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants VI. ANSI N45.2.6-1978 Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants VII. R.G. 1.26, Rev. 3 Quality Group Classifications and Standards for Water , Stean and Radioactive-Waste-Containing Components of Nuclear Power Plants VIII. R.G. 1.29, Rev. 3 Seismic Design Classification IX. ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants l

Title:

Appendix B, Exceptions Page: 1 of 26 l Rev.: 2 I

1

l~ r

(-

I APPENDIX B ,

(continued) .i l

1

-Appendix B l Sub-cateoorv Standard / Guide Title X. R.G. 1.33, Rev. 2 Quality Assurance Program l Requirements (Operations) l-I l 4

I i

I P

l l

i j

Title:

Appendix B, Exceptions Pages- 2 of 26 l Rev.: 2 i

- - , - .s-. -

w a n' -- g- r

I I

l l

l' I

APPENDIX B (continued) l I

.I. . ANSI N45.2.3'- 1973, Housekeenino Durina the Construction Phase of

( Nuclear Power Plgggg- 'j l

A. EXCEPTION: ,

Subsection 2.1 - Plannino The Vermont Yankee plant takes exception to the five-zone requirements specified in the subject standard.

ALTERNATIVE:

The Vermont Yankee plant shall establish as a minimum a three zone program as follows:

Zone III 1

Zone III criteria shall be applied to major portions of the j reactor coolant system which are opened for inspection, maintenance or repair.

1. Access control over personnel shall be required.
2. Cleanliness shall be maintained, commensurate with the work being performed, so as to preclude the entry of foreign material to the Reactor Coolant System.
3. A documented cleanliness inspection shall be performed immediately prior to closure.

Eg.t.g : The Zone III requirements may be expanded for certain maintenance repair activities if deemed appropriate by plant management. In such instances applicable sections of Zones I & II shall be specified.

j .

Title:

Appendix B, Exceptions

(; Page: 3 of 26 l l Rev.: -2 .

l

.. - _ . .- . . . - . _-.- - . . . - _ . . .- . . . . - . _ - _ ~

APPENDIX B (continued)

Zone IV Zone IV criteria shall be applied to the radiation control areas of the plant.

1. Standard janitorial and work practices shall be utilized to maintain a level of cleanliness commensurate with company policy in the areas of Housekeeping, Plant and Personnel l Safety and Fire Protection.

l

2. Additional housekeeping requirements shall be implemented as l required for the control of radioactive contamination.

l l 3. Smoking and eating shall be controlled consistent with good health physics practices and to maintain cleanliness.

Zone v Zone V criteria shall be applied to the remainder of the plant.

I 1. Standard janitorial and work practices shall be utilized to l maintain a level of cleanliness commensurate with company policy in the areas of Housekeeping, Plant and Personnel Safety and Fire Protection.

B. EXCEPTION:

Subsection 3.2 - Control of Facilities The Vermont Yankee plant takes exception to the control of tools, i equipment, materials and supplies used in Zone III.

l 6

Title:

Appendix 3, Exceptions Page 4 of 26 l Rev.: 2 i

O I

APPENDIX B

-(continued) 6 ALTERNATIVE:

The Vermont Yankee plant shall verify control for Zone III as indicated in Exception A of this sub-category.

1

Title:

Appendix B, Exceptions Page: 5 of 26 l Rev.: 2

. . _ . , _ . _ _ . _ _ . . _ . . _ _ . . ~ . . . . _ _ . . ~ _ _ . . _. . . _ . _ . . _ _ . _ . - _.,_ _ ._ _ . _ . . _ _.. . _ _ _ . . _

l l APPENDIX B (continued) i II. ANSI N45.2.9 - 1974, Reauirements for Collection, Storace, and t Maintanance of Quality Assgrance Records for Nuclear Power Plants A'. EXCEPTION:

Subsection 5.6 (3) Facility The Vermont Yankee plant takes exception to " structures, doors, frames, and hardware should be Class A fire rated with a recommended four hour minimum rating."

T ALTERNATIVE:

I

" Doors, structures, frames, and hardware shall be designed to comply with the requirements of a minimum two (2) hour fire rating, meeting NFPA No. 232 guidelines."

JUSTIFICATI.QN:

The two (2) hour rating has been endorsed by the NRC Standard Review Plan NUREG-0800, Revision 2, dated July 1981.

r.

- Title : Appendix B, Exceptions l- Page: 6 of 26 l .l Rev.:

2 i

i

, - . . -. ,m -- ,. - . . , . . . . _ . . . . . _ . -

f i- l APPENDIX B I (continued) I j III. ANSI N45.2.10 - 1973, Quality Assurance Terms and Definitions A. EXCEPTION:

Subsection 2 - Terms and Definitions The Vermont Yankee plant takes exception to the definitions of

" Certificate of conformance" and " Certificate of Compliance". I ALTERNATIVE l

The Vermont Yankee plant shall reverse the definitions of the above terms so our Program will be in compliance with the implied definitions in the ASME B&PV Code and Yankee specifications.

)

l l-i-

I

Title:

Appendix B, Exceptions Page: 7 of 26

l Rev.
2 f

l i-

. ~ . . - _ . _ . - . . ~ . . . _ ~ . _ _ _ . _ - _ ___ _ ._ _ _ _ .., _ _ ---.m._ -

APPENDIX B (continued)

IV. Reg.?latory Guide 1.64, Revision 2, " Quality Assurance Reauirements for the Desian of Nuclear Power Plants" A. EXCEPTION:

subsection c.2 The Vermont Yankee plant takes exception to the regulatory guide

]

position-on the exclusion of supervisors performing design i l

verification.

ALTERNATIVE:

J The Vermont Yankee plant will continue the accepted practices for independent design verification in accordance with-the provisions of ANSI N45.2.11-1974, Section 6.1.

JUSTIFICATION:

The exclusion of line supervision to peri cm design verification has proven to be an unnecessary burden on the resources within the engineering organizations of the company, and counterproductive during heightened periods of engineering activities. ANSI N45.2.11 contains specific limitations on the situations in which a supervisor is permitted to perform design verification. The standard states, "This verification may be performed by the originator's supervisor provided the supervisor did not specify a singular design approach, or rule out certain design considerations and did not establish the design inputs used in the i design, or if the supervisor is the only individual in the organization ~ competent to perform the verification." This control was developed throug'. realistic evaluation of the practicable limits that restrictions impose on engineering organizations by the working group that developed ANSI N45.2.11.

Title:

Appendix B, Exceptions Page: 8 of 26 j

, l Rev.: 2 l

l

APPENDIX B (continued)

V. ' ANSI N45.2.2 - 1972, Packmaina, Shineina, Receivina, Storace & Handlina of Items for Nuclear Power Plants A. EXCEPTION:

Subsection 3.7.1 & A3.7.1 - Containers The Vermont Yankee plant takes exception to the specific requirements for containers.

ALTERNATIVE:

Containers shall be of suitable construction to assure material is received undamaged.

JUSTIFICATION:

Containers shipped by closed carrier, stored inside and not subjected to a wet environment do not require weather resistant fiberboard, therefore, this is an unnecessary expense.

Additionally, numerous vendors utilize shipping containers that do not comply with the specific requirements of this section, i.e.,

flaps overlap. The acceptance criteria for a shipping container should be established based on the capability of the container to maintain the' component material in a safe condition. Technology has advanced beyond the standard.

B. EXCEPTION:

Subsection 3.7.2 - Crates and Skids The Vermont Yankee plant takes exception to the requirement that skids and runners shall be used on boxes with a gross weight of 100 pounds or more.

Title:

' Appendix B, Exceptions Page: 9 of 26 l Rev.: 2

. - . .. - . . . . - ._ _ .. . - -. .. ~- . ~ - - _ - . .. -. - ._ . . .

APPENDIX B (continued) 1 ALTERNATIVE: '

Skids or runners shall be used on boxes with a gross weight of ,

100 pounds or more if practical.

JUSTIFICATION: I Storage methods and container design frequently are such that l

runners or skids are not feasible.  !

l I

C. EXCEPTION.

Subsection 5.2.1 - Shiccina Damage Insoection The Vermont Yankee plant takes exception to the requirement that a preliminary visual inspection or examination be performed prior to unloading. i ALTERNATIVE:

The Vermont Yankee plant shall perform those required inspections

.after unloading. In special instances, preunloading inspections shall be performed.

JUSTIFICATION -

Post unloading inspection is adequate to determine any damage that may have been incurred during shipping and handling.

Title:

Appendix B, Exceptions Page: 10 of 26 l Rev.: 2

APPENDIX B (continued)

D. EXCEPTION:

subsection 5.2.2 - Item Insoection The Vermont Yankee plant takes exception to the requirement, that "The inspections shall be performed in an area equivalent to the level of storage requirements for the item."

ALTERNATIVE:

The Vermont Yankee plant shall perform receiving inspection in a manner and in an environment which do not endanger the requisite quality of the item; however, receiving area environmental controls may be less stringent than storage environmental controls for that item. When inspections are performed in receiving areas with environmental controls less stringent than storage area environmental controls, a time limit shall be established on a case basis for retention of items in the receiving area.

Retention time shall be such that deterioration is prevented and applicable manufacturer recommendations are addressed.

JUSTIFICATION:

Receipt inspection activities are for a much shorter duration and therefore should not be subjected to the same stringent requirements as required for storage.

E. EXCEPTION:

' Subsection 5.2.3 - Soecial Insoection The Vermont Yankee plant takes exception to attaching special inspection procedures to the item or container.

Title:

Appendix B, Exceptions Page: 11 of 26 l Rev.: 2 P

APPENDIX B (continued)

ALTERNATIVE:

Special inspection procedures shall be readily available to personnel performing inspections.

JUSTIFICATION:

Procedures are subject to less abuse and more stringent controls when maintained on file and not attached to the item. Inspection status is maintained by tagging and procedure control.

F. EXCEPTION:

Subsection 6.1.2 - Levels of Storace The Vermont Yankee plant takes exception to two specific requirements associated with fuel storage (classified Level A).

ALTERNATIVE:

The Vermont Yankee plant shall meet the requirements of Level A storage for new fuel with the exception of special air filtering; and temperature and humidity controls.

JUSTIFICATION:

The existing storage conditions at the Vermont Yankee operating plant are consistent with the protection provided to the fuel while in storage at the manufacturer (vendor) and/or while in transit to the plant site and are judged to provide adequate protection to the fuel assembly structure which is of highly corrosion resistant materials. We believe that the above listed requirements are intended for application at the manufacturing facility (vendor) where the uranium pellets may be exposed to the

Title:

Appendix B, Exceptions Page: 12 of 26 l Rev.. 2

i l

l APPENDIX B (continued) l l atmcaphere and not in its fully encapsulated, and therefore, fully l protected form in a completed fuel assembly.

l J l G. EXCEPTIONJ  !

l i t

l l Anoendix A-3 Subsection A3. 5.1(1) - Caos & Pluas The Vermont Yankee olant takes exception to the requirement that ,

nonmetallic plugs and caps shall be brightly colored. I 1

R.TERNATIVE:

l Nonmetallic plugs and caps shall be of a contrasting color.

JUSTIFICATION:

The purpose of utilizing brightly colored plugs and caps is to assist in assuring obstructions are not inadvertently placed in operating components or systems. By using plugs and caps of a contrasting color this objective can be achieved.

H. EXCEPTION:

Anoendix A-3 Subsection A3. 9 (1) - Second Grouo, Markinos The Vermont Yankee plant takes exception to the requirement that container markings shall appear on a minimum of two sides.

i ALTERNATIVE:

Containers shall be adequately marked to provide identification and retrievability.

Title:

Appendix B, Exceptions l Page: 13 of 26 l Rev.: 2 i

I

l l

l l

l l

l APPENDIX B (continued) l l

l JUSTIFICATION:

Containers are tagged to provide identification and inspection status. Employment of two tags on small containers adds bulk and confusion and does not provide for better identification or traceability.

I. EKCEPTION:

1 ADoendix A-3, Subsection A.3.9(4) - Second Groun, Markina '

l l

The Vermont Yankee plant takes exception to the requirement that container markings shall be no less than 3/4" high, container permitting.

1 ALTERNATIVE:

Container markings shall be of a size which permits easy recognition.

JUSTIFICATION:

Markings were intended to provide identification and instructions.

The criteria should be that the markings clearly provide the same.

J. EXCEPTION:

Accendix A-3 Subsection A.3. 9 (6) - Second Grouo, Markina The Vermont Yankee plant takes exception to the information required for container marking.

l l

Title:

Appendix B, Exceptions Page: 14 of 26 l Rev.: 2 I

i i

i l

l l

APPENDIX B (continued)

Y ALTERNATIVE:

Marking shall be adequate in each case to provide identification, I

traceability and instructions for special handling, as applicable.

JUST1FICATION:

The information required is excessive. Cluttering a container  !

with excessive markings only reduces the main objectives, l maintaining identification and establishing special controls.

1 I

l l

1 l

i i

i f

Title:

Appendix B, Exceptions Page: 15 of 26 i

i l Rev.: 2

. . . _ . .- . ..-, . -, ~.-... - _-.- ~~ - .- -.... - .- . _ . . . - - . . . _._n_ . ~.. _ ... - . - ,

l APPENDIX B (continued) l VI. ANSI N45.2.6 - 1978, Qualification of InsDection, Examination and

'Testina Personnel for Nuclear Power Plants )

l l

A. EXCEPTION:

l l

The Vermont Yankee plant takes exception to the application of the Standard to all Vermont Yankee personnel performing inspection, l examination and testing.

l ALTERNATIVE:

Vermont Yankee personnel identified in ANSI N18.1-1971 who perform inspection, examination and testing will be qualified to ANSI N18.1-1971.

Vermont Yankee personnel not identified in ANSI N18.1-1971 who perform inspection, examination and testing will be qualified to ANSI N45.2.6-1978.

Title:

Appendix B, Exceptions Page 16 of 26 l Rev.: 2

l APPENDIX B (continued)

VII. Regulatory Guide 1.26, Rev. 3, (2/76), Quality Group Classifications and Standards for Water , Steam- and Radioactive-Waste-Containino Components of Nuclear Power Plants A. EXCEPTION:

Vermont Yankee takes exception to the Regulatory Guide in its l entirety.

ALTERNATIVES:

l Vermont Yankee shall continue to classify structures, systems and l components in accordance with the safety classification provisions of ANS-22, Draft No. 4, Rev. 1, May 1973, " Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants," as in l the past, with the following specific exception:

I l FUEL HANDLING EOUIPMENT I

l The fuel handling equipment is presently required to be Safety l Class 3 by paragraph 4.14.5.1 of ANS-22, but it is original plant l equipment (designed and manufactured before 1973) that was not l designed, fabricated, erected or tested to Safety Class 3 l criteria. Vermont Yankee will apply the provisions of ANS-52.1-l 1983, paragraphs 4.13.1, 4.13.4, 3.3.1.4 and 3.4.5.2.j (except l that quality assurance shall be applied using selected l requirements of ANSI N18.7-1976 in lieu of NQA-1-1979), to ensure l that operational-phase activities (design control, procurement, l installation, testing, etc.) affecting this equipment are l conducted to quality standards commensurate with the safety l function to be performed. Vermont Yankee will classify the l equipment as non-safety-related with supplemental QA (" augmented" l quality assurance) to be applied in accordance with ANS-52.1 l criteria.

Title:

Appendix B, Exceptions Page: 17 of 26 l Rev.: 2

m_- . . _ . ~ . . - .. _. . . . _ . . _ . _ _ . . - _ . _ . - _ _ _ . _ . _ . _ _. . .

l APPENDIX B (continued)

VIII. Regulatory Guide 1.29, Rev. 3, (9/78), Seismic Desion Classification A. EXCEPTION:

The Vermont Yankee plant takes exception to the application of Regulatory Guide 1.29, Rev. 3, (9/78),

ALTERNATIVES:

Vermont Yankee-The seismic design classification of structures, systems, and components at Vermont Yankee shall be as defined in the Vermont Yankee FSAP.

i r

l l

Title:

Appendix B, Exceptions i Page: 18 of 26 l Rev.: 2 i

l I

Tw i

l 1

1 l

l l

APPENDIX B (continued)

IX. ANSI N18 .7-1976, Administrative Controls and Ouality Assurance for the Operational Phase of Nuclear Power Plants A. EXCEPTION Subsection 4.5 - Audit Program The Vermont Yankee Plant takes exception to the requirement that audits of all safety-related functions shall be completed within a period of two (2) years.

Alternative:

Audits of selected aspects of operational phase activities shall be performed with a frequency commensurate with their safety significance and in such a manner as to assure that an audit of all safety-related functions is completed at least once within a three (3) year period, based upon the results of an annual Functional Area Assessment.

.The Annual Ptnctional Area Assessment is a documented analysis of functional areas important to safety. The purpose is to identify strengths and weaknesses (if applicable) to determine the level and focus of independent oversight activities for the upcoming year. The basis for the assessment shall include the results of QA Audits and Surveillance, NRC Inspections, Event Reports, Nonconformance Reports, Corrective Action Reports, and Self-Assessments. Other indicators such as Personnel Changes, change / increase in functional area responsibilities, Industry Findings, and INPO evaluations will also be considered. Each area will be assigned a rating with a comparisen to previous years.

Title:

Appendix B, Exceptions Page: 19 of 26 l Rev.: 2 I

l APPENDIX B (continued) l- This assessment will be reviewed and approved by QA and Plant I 1

Management. This document is considered a QA record and will be available for NRC review.

i-i Justification: f I

t.

[. To utilize quality oversight resources more effectively, senior management desires the flexibility to direct resources to areas which have perceived weaknesses. The two-year audit cycle has not

[ ensured that the frequency, scope and associated resources.are j l based on the. risk associated with the audit area.

Vermont Yankee proposes to adjust the audit schedule based on i empirical data and performance history to complete audits of l safety-related functions.within a period of three years. This modification meets the intent of published regulatory requirements  ;

l involving activities important to safety.

B. EXCEPTION:

l Subsection 5.2.15 - Review. Art e tval und Control of Procedures Vermont Yankee takes exception to the following paragraph; L .

" Plant procedures shall be reviewed by an individual knowledgeable in the area.affected by the procedure no less frequently than every two years to deteomine if changes are

.necessary or desirable". -

l, .

Title:

Appendix B, Exceptions

! Page: 20 of 26:

.l Rev.: 2

APPENDIX B (continued)

Alternativg:

I Plant procedures will be periodically reviewed in accordant'e with l administrative controls. These controls will establish a achedule for these periodic reviews. All applicable plant procedures will be reviewed following an unusual incident, unexpected transient, operator error, or equipment failure (malfunction), and following a modification to a system.

Nonroutine procedures such as Emergency Operating Procedures, Emergency Plan Implementing Procedures, or other procedures whose ,

i use may be event driven, will be reviewed every two years.

However, if a nonroutine procedure is fully exercised and there is a detailed scrutiny of the entire procedure as part of a documented training program, this may serve as the biennial review of the procedure used.

At least every two years, the Quality Assurance (or other independent) organization shall audit a representative sample of routine plant procedures that are used more frequently than every two years. The audit is to ensure the acceptability of the procedures and verify that the procedure review and revision program is being implemented effectively. The root cause of significant deficiencies is to be determined and corrected.

Routine plant procedures that have not been used for two years will be reviewed before use to determine if changes are necessary or desirable.

l i

f

Title:

Appendix B, Exceptions Page: 21 of 26 l Rev.: 2

.. - . . - -.~. .- - . ~ . - . _ - . . . . . - _ . - . . . - .

_ ~ , - . .

APPENL2X B (continued)

Justification:

The current requirement to review each safety-related procedure on a biannial cycle results in the expenditure of significant technical and administrative resources. Programmatic controls and practices are in place to provide adequate reviews, including the following:

  • The plant modification processes require that procedures affected by the modification be identifie1 during the design change preparation, and revised prior to closure of the modification package.

e The Operating Experience Program involves the review of USNRC, INPO, and vendor supplied information for applicability and determination of further action. This review includes an evaluation of applicable documents such as procedures and the initiation of required changes.

e Admdnistrative controls currently exist requiring that if a procedure cannot be performed as written, a procedure change must be completed prior to continuation of the procedure.

e Temporary changes are occasionally generated during, or prior to procedure use. Current administrative controls require that those changes that are permanent shall be incorporated into the procedure via the procedure revision process.

  • As part of the audit and surveillance process, procedures are evaluated as to adequacy, ease of use, proper technical content, and compliance with applicable plans and programs.

Title:

Appendix B, Exceptions Page: 22 of 26 l Rev.: 2

APPENDIX B (continued) l

  • When procedures are identified as contributing factors for l plant events, violations and nonconforming conditions, l changes are initiated.

l l

e Changes to Technical Specifications and the FSAR are reviewed for potential impact on, and initiation of changes to plant procedures.

  • Plant procedures are approved by appropriate personnel prior to initial use. Current administrative controls also require pre-job briefings for procedures identified as i 1

infrequent. '

This modification meets the intent of published regulatory requirements involving activities important to safety.

l C. EXCEPTION:

l Subsection 5.3.9 Vermont Yankee takes exception to the requirements that detail Emergency Procedures be in accordance with Paragraph 5.3.9.

Alternative:

Vermont Yankee Emergency Operating Procedures are written in accordance with the Symptom / Function-Based Guidelines developed by the BWR Owners Group and accepted by the NRC. These Symptom / Function Based Procedures, mandated by the NRC in NUREG-0737, have format and content different from the Event-Oriented Emergency Procedures described in ANSI N18.7-1976.

Title:

Appendix B, Exceptions Page: 23 of 26 l Rev.: 2

. . . . . - - - . . - ..~ -. . _ . . - . . . . . . . - - . - ~ - - . ~ . - . . - - . - . . ~ - - . - ~ ,

APPENDIX B (continued)

Justification:

NUREG 0737 supersedes ANSI N18.7-1976 in the area of Emergency operating Procedures, Changes to procedure format are required in order to develop Symptom / Function-Based Procedures, i'

l

Title:

Appendix B, Exceptions Page: 24 of 26 i

l Rev.: 2 i

. - _ _ . . ..m -. .- _. ._ _ _ _ - _ . . - _ . _ _ _ _ _ _ . _ _ _ _ _ _ - . .m,_ .

l

[

t APPENDIX B

-(continued)

X. Reaulatory Guide 1.33, Revision 2. Quality Assurance Recuirements (Onerational)

{ l l A. EXCEPTION: j l

Subsection 4.5 - Audit Procram ]

The Vermont Yankee Plant takes exception to the following:

e Section 4.5 states that "all audits of safety related functions are completed within a two (2) year period".

I l e Paragraph 4.a. "The results of actions taken to correct deficiencies that affect nuclear safety and occur in  !

facility equipment, structures, systems, or method of operations - shall be audited at least once per 6 months".

]

e Paragraph 4.b. "The conformance of facility operation to j provisions contained within the technical specifications and applicable license conditions - shall be audited at least once per 12 months."

l 1

  • Paragraph 4.c. "The performance, training, and

~

qualifications of the facility staff - shall be audited at least once per 12 months." l l Alternatives ,

l 1 Audits of selected aspects of the functional areas listed above, shall be performed within a frequency commensurate with their l safety significance and will be completed at least once within a three (3) year period, based upon the results of an annual functional area assessment.

l l'

l L

Title:

Appendix B, Exceptions Page: 25 of 26 l_Rev.: 2 l

I I

AEEENDIX B (continued)

Justification:

To utilize quality oversight resources more effectively, senior management desires the flexibility to direct resources to ersas which have perceived weaknesses. The two-year audit cycle has not ensured that the frequency, scope and associated resources are based on the risk associated with the audit area.

Vermont Yankee proposes to adjust the audit schedule based on empirical data and performance history to complete audits of safety-related functions within a period of three years. This modification meets the intent of published regulatory requirements involving activities important to safety.

Title:

Appendix B, Exceptions Page: 26 of 26 l Rev.: 2 l

I 1

i l

ATTACHMENT C l Lined-out Version of Revised VOQAM Pages i

l 1

l t

I

!~

VERMONT YANKEE NUCLEAR POWER CORPORATION I

VOQAM l

I&RLE OF CONTENTS /INDEX Effective Current i Section No. Title Pace (s) Revision AMENDMENT / REVISION IV 42 l

POLICY STATEMENT 1-2 1

}

I ORGANIZATION 1-26 1 II QUALITY ASSURANCE PROGRAM 1-7 42 III DESIGN CONTROL 1-4 1 IV PROCUREMENT DOCUMENT CONTROL 1-3 1

.V INSTRUCTIONS, PROCEDURES, AND 1-2 1 DRAWINGS VI DOCUMENT CONTROL 1-4 1 VII CONTROL OF PURCHASED MATERIAL, 1-3 1 EQUIPMENT, AND SERVICES l

VIII IDENTIFICATION AND CONTROL OF 1-2 1 MATERIAL, PARTS, AND COMPONENTS i

IX CONTROL OF SPECIAL PROCESSES 1-2 1  ;

X INSPECTION 1-2 1 XI TEST CONTROL 1-3 1 XII CONTROL OF MEASURING AND TEST 1-2 1 EQUIPMENT XIII HANDLING, STORAGE, AND SHIPPING 1-2 1 XIV INSPECTION, TEST, AND OPERATING 1-2 1 I STATUS XV- NONCONFORMING MATERIALS, PARTS, 1-3 1 l AND COMPONENTS l

i I

l

i l

! VERMONT YANKEE M M&M PONER CORPORATION V@M TABLE OF CONTENTS /INDEX )

,. (Continued) l i Section No. Title Revision XVI CORRECTIVE ACTION 1-2 1 XVII QUALITY ASSURANCE RECORDS 1-3 1 XVIII AUDITS 1-4 1 APPENDIX A QUALIFICATION REQUIREMENTS 1 1 APPENDIX B EXCEPTIONS 1-26 42 APPENDIX C VY CLASSIFICATION 1 1 l

i l

i l

l l

l t

i

Title:

Table of Contents Page: H4 Page 2 of 2 I

Rev.: 42 l

l t

. . _ _ _ _ _ _ . _ _ - . __m .. . _ _ . . _ _ _ . . _ . . .m . _ . _ . _ .__ _ . ___ ..

I VOOAM AMENDMENT / REVISION SHEET Revision No. Date Reason l

0 5/1/98 To adopt Rev. 27 of the YOQAP as Rev. O for the VOQAM. (Reference VY letter to NRC, dated 4/12/98.)

1 10/16/98 To update organizational changes, removed all references to YAEC and YNSD. VY assumed all j YNSD responsibilities. Changed Sr. Vice President, Operations, to Director of Operations.

2 TBD Revised Table of Contents /Index to identify number of effective pages in each VOQAM section. Adopted ANSI N101.4-1972/ Reg. Guide l 1.54 in Section II, page 4 of 7. Revised Appendix B, page 17 OF 26, to address a specific application of ANS-52.1-1983. Revised Appendix B, page 23 of 26, to clarify provisions for initiating procedure changes in response to plant events, violations and nonconformances.

Title:

Amendment / Revision Sheet j Page: 1 Rev.: 42

l VERMONT YANKEE NUCLEAR POWER CORPORATION l

L l

l 15. ANSI N45.2.23-1978, Oualification of Quality Assurance Procram Audit Personnel for Nuclear Power Plants (Endorsed by Regulatory Guide 1.146, August 1980)

16. ANSI N18.1-1971, Selection and Trainino of Nuclear Power Plant Personnel (Endorsed by Regulatory < Guide 1.0, Revision 1-R) l
17. ANSI N101.4-1972, Quality Assurance for Protective Coatinos Apolied to Nuclear Facilities (Endorsed by Regulatory Guide 1.54)
Classifications and Standards for Water , steam . and Radioactive-Waste-Containino Comoonente of Nuclear Power Plants

Notes: 1) When conflicts in similar requirements contained in Technical Specifications and the above documents exist, the requirements contained in Technical Specifications override those in the documents. Requirements in the documents will be considered when they supplement and are not in conflict with similar requirements in Technical Specifications.

2) Revisions to the above listed documents will be considered for applicability to the Vermont Operational Quality Assurance Program upon written direction thereof by l the Regional Administrator, Nuclear l Regulatory Commission - Office of l

Inspection and Enforc3 ment - Region I.

Title:

Section II, Quality Assurance Program Page: 4 of 7

, Rev.: 42 f

l I

VERMONT YANKEE NUCLEAR POWER CORPORATION APPENDIX B (continued)

VII. Regulatory Guide 1.26, Rev. 3, (2/76), Quality Groun Classifications and Standards for Water , Steam- and Radioactive-Waste-Containina Comoonents of Nuclear Power Plante A. EXCEPTION:

h e Vermont Yankee plane takes exception to the Regulatory Guide in its :ntir:1y entirety. )

I ALTERNATIVES:

Vermont Yankee shall continue to classify structures, ;;ngen:nt; and systems and components in meeeedneee accordance with the safety classification provisions of ANS-22, Draft No. 4, Rev. 1, May 1973, " Nuclear Safety Criteria for the Design of Stationary l Boiling Water Reactor Plants," as in the past, with the following 1

specific exception:

FUEL HANDLING EQUIPMENT The fuel handling equipment is presently required to be safety l Class 3 by paragraph 4.14.5.1 of ANS-22, but it is original plant equipment (designed and manufactured before 1973) that was not i designed, fabricated, erected or tested to Safety Class 3 criteria. Vermont Yankee will apply the provisions of ANS-52.1-1983, paragraphs 4.13.1, 4.13.4, 3.3.1.4 and 3.4.5.2.j (except that quality assurance shall be applied using selected requirements of ANSI N18.7-1976 in lieu of NQA-1-1979), to ensure that operational-phase activities (design control, procurement, installation, testing, etc.) affecting this equipment are conducted to quality standards commensurate with the safety function to be performed. Vermont Yankee will classify the equipment as non-safety-related with supplemental QA (" augmented" quality assurance) to be applied in accordance with ANS-52.1 criteria.

l

Title:

Appendix B, Exceptions Page: 17 of 26 Rev.: 42

VERMONT YANKEE NUCLEAR POWER CORPORATION APPENDIX B (continued) e Th: ::::::tiv: ::ti: p ::::: 'Er :t n:;::t:} ::;uir:: th:t

:::t :::: :n:1yri: h: ;: f::::d f:: cr :t , viel:t::: 2nd

.._.. _ ___ _ _ _ ......, _ _.._ _ _ _ ____ . When Whece procedure s are identified as contributing factors for plant events, violations and nonconforming conditions, p :::dur changes are initiated.

e Changes to Technical Specifications and the FSAR are reviewed for potential impact on, and initiation of changes to plant procedures, e Plant procedures are approved by appropriate personnel prior to initial use. Current administrative controls also require pre-job briefings for procedures identified as infrequent.

This modification meets the intent of published regulatory requirements involving activities important to safety.

C. EXCEPTION:

Subsection 5.3.9 Vermont Yankee takes exception to the requirements that detail Emergency Procedures be in accordance with Paragraph 5.3.9.

Alternativer Vermont Yankee Emergency Operating Procedures are written in accordance with the Symptom / Function-Based Guidelines developed by the BWR Owners Group and accepted by the NRC. These Symptom / Function Based Procedures, mandated by the NRC in NUREG-0737, have format and content different from the Event-Oriented Emergency Procedures described in ANSI N18.7-1976.

Title:

Appendix B, Exceptions Page: 23 of 26 Rev.: 42

Retrieved from "https://kanterella.com/w/index.php?title=ML20198H548&oldid=3006199"