ML20203K950
| ML20203K950 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/12/1986 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| FVY-86-72, NUDOCS 8608220276 | |
| Download: ML20203K950 (4) | |
Text
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' VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 86-72 RD 5. Box 169. Ferry Road, Brattleboro, VT 05301
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ENGINEERING OFFICE 1671 WORCESTER ROAD FRAMINGHAM, MASSACHUSETTS 01701 TELEPHONE 617-872-8100 August 12, 1986 U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attn:
Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, NVY 86-135, Inspection Report 50-271/86-08, dated 7/3/86
Dear Sfr:
Subject:
Response to Inspection Report 50-271/86-08 This letter is written in response to Reference b) which indicates that certain activities were not conducted in full compliance with Nuclear Regulatory Commission requirements.
The alleged Severity Level IV violation was cited during a routine resident safety inspection conducted by Mr. W.J. Raymond on March 18-May 5, 1986 at the Vermont Yankee Nuclear Power Station, Vernon, Vermont.
Information is submitted in the following paragraphs in answer to the l
alleged violation.
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VIOLATION I
10CFR50, Appendix B Criterion XV - Nonconforming Materials, Parts or Components, requires that measures be established to control nonconforming materials in order to prevent their inadvertent use or installation.
Criterion XVI of 10 CFR 50 - Corrective Actions, requires the license to establish measures to assure that conditions adverse to quality such as defective material be promptly identified and corrected, including actions i
to preclude the recurrence of significant conditions.
Section XV and XVI of the licensee Quality Assurance Manual, Topical Report YOQAP-I-A Revision 15 estalishes measures to assure the requirements of 10 CFR 50 are met.
YOQAP Section XV.C.1 states that satisfaction of the requirements of Criterion XV shall be assured through the identification, inspection and segregation of nonconforming items. YOQAP Section XVI.B.3 860G2?O270 G
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission August 12, 1986 Page 2 l
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states that the satisfaction of the requirements of Criterion XVI shall be assured by plant actions to identify the cause of conditions adverse to l
quality and the implementation of corrective actions.
Nonconformance Report (NCR) 86-07 was written on 1/1/86 to document the identification of 15 defective contact blocks purchased in 1983. The NCR was dispositioned as satisfactorily closed on 3/19/86 following segregation and return of the 15 defective blocks back to the vendor for credit, and pending completion of actions to perform a followup evaluation of the vendor QA program.
i Contrary to the above, nonconforming materials were not controlled to pre-vent inadvertent use or installation, in that NRC inspection from May 27-l April 8, 1986 identified the following defective NAMCO parts: Stores - 2 parts (of 18) with crack defects; MSVI's - 8 parts (of 32) with chip defects. Additionally, required measures were not taken to prevent l
recurrence of installation or use of such potentially defective materials, in that the licensee's corrective actions per NCR 86-07 did not address inspection / review of similar (bakelite) parts in Stores to verify whether
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similar defects existed.
This is a Severity Level IV Violation (Supplement I.D.).
RESPONSE
Vermont Yankee procured and accepted into Stores 35 contact blocks from the l
NAMCO Controls Company under Purchase Order (PO) 20145 in 1983. All 35 blocks f
were accepted as satisfactory based on a sampling review during receipt inspec-tion. While rebuilding Reactor Protection System (RPS) and position indicction j
switches for the Main Steam Isolation Valves (MSIV's) in January 1986, Vermont
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Yankee I&C technicians noted chip defects on the arc suppression barriers on 15 of the 35 contact bocks from P0 20145, 1
A subsequent NRC inspection during the period March 27-April 8, 1986
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revealed two additional defects for parts in Stores, one cracked contact block and one cracked contact carrier. Previous inspections were for chips out of the arc suppression barrier on the contact blocks. Contact carriers had not been inspected because they do not contain arc suppression barriers and are not con-sidered similar parts / defects.
Following Vermont Yankee observation of defects in January, 13 new, re-inspected contact blocks from PO 20145 were installed in the outboard (86 A-D) i NAMCO switches. Three of the original blocks with no defects were left in place.
Of the 13 re-inspected blocks, 2 were subsequently (March - April) found to be defective by the resident NRC inspector:
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VERMONT YANKEE NUCLEAR POWER CORPORATION 1
l U.S. Nuclear Regulatory Commission August 12, 1986 Page 3 i
o The 86-B A-1 contact block had some slight chips out of the arc j
suppression barrier.
It is probable that these chips were caused i
during installation following the re-inspection.
These chips did not change the shape of the arc suppression barrier and were considered cosmetic by the installer.
The 86-B shut contact block was cracked along the arc suppression 4
o barrier. Hairline cracks on 86-B, also caused during installation, went undetected due to location and the fact that the cracks were not i
identified as an area of concern by NCR 86-07.
Six contact blocks with discrepancies were found on the inboard MSIV's during the March-April inspection. The plant staff did not consider inspection
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of the contact blocks on the inboard MSIV's necessary during the NCR evaluation j
in January since the blocks had operated for at least one full cycle without a failure and required surveillances had not indicated any improper operation of l
the blocks. Further, the installed contact blocks were not from the suspect PO 20145.
j On discovery of the inboard block problems, Vermont Yankee contacted NAMCO and determined their inspection criteria. As a result, the Vermont Yankee inspection program for all contact blocks and carriers to be used in safety related circuits was expanded to include checks for hairline cracks, contact alignment and spacing. During receipt inspection of contact blocks shipped from l
NAMCO as replacements for the original order, 16 blocks were rejected for j
failing the contact position criteria.
An evaluation of the chips out of the arc suppression barrier and a sub-i sequent functional test at NAMCO showed that these defects would not have i
affected the operability of the switch unless the chipping occurred during operation and the broken piece were to jam the switch (no loose parts were ever found inside the switch casings).
CORRECTIVE ACTION l
4 The following corrective actions have been taken to ensure quality contact blocks and contact carriers are installed in the safety-related NAMCO limit j
switches.
o NAMCO was contacted to provide inspection criteria, The PO to replace the contact blocks received with defects was subjected to o
a QA pre-shipment inspection.
I&C Department Quality Control staff, utilizing the criteria provided by o
NAMCO, generated a receipt inspection program that would ensure that all contact carriers and contact blocks would meet the quality requirements of the application prior to placement on stockroom shelves.
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s VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission August 12, 1986 Page 4 o
All contact blocks and contact carriers installed in the MSIV and turbine stop valve switch locations were 100% inspected to the same receipt inspec-tion criteria, o
Any installed contact blocks or carriers not meeting the criteria were replaced with Stores stock which had successfully passed the new inspection criteria.
CORRECTIVE ACTIONS TAKEN TO PREVENT FURTHER VIOLATIONS o
A a result of the in-depth investigation, NAMCO has planned changes to several manufacturing processes, including the QA pre-shipment inspection process, as well as the method of attaching the contact assembly to the
- block, o
Future orders from NAMCO will be 100% receipt inspected utilizing the cri-teria generated for the replacement order, until such time as Vermont Yankee is confident NAMCO has corrected apparent programmatic deficiencies.
In conclusion, the corrective actions taken to respond to the NAMCO issue were a direct result of the Vermont Yankee NCR and Part 21 notification.
Vermont Yankee feels that these actions would have been initiated without the intervention of the Resident Inspector. These corrective actions were in effect prior to the subject notice of violation, and were not instituted as a result of the violation. The actions were developed over the course of the process pre-viously described in this response.
We trust that this information is deemed to be satisfactory; however, should you have any questions regarding this matter, please contact me.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION l $11% ft*4f Warren P. >
rphy V
Vice Presicent and Manager of Operations
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