ML20207N342
| ML20207N342 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee, Yankee Rowe, 05000000 |
| Issue date: | 12/05/1986 |
| From: | YANKEE ATOMIC ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20207N336 | List: |
| References | |
| RTR-REGGD-01.026, RTR-REGGD-01.029, RTR-REGGD-1.026, RTR-REGGD-1.029 YOQAP-1-A, NUDOCS 8701140141 | |
| Download: ML20207N342 (14) | |
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.j APPENDIX B (Exceptions)
The sub-categories of this Appendix summarize the exceptions noted in Section II of the Yankee Atomic Electric Company Operational Quality Assurance Manual.
Appendix B Sub-Category Standard / Guide Title I. ANSI N45.2.3-1973 Housekeeping During the Construction Phase of Nuclear Power Plants II. ANSI N45.2.10-1973 Quality Assurance Terms and Definitions III. ANSI N45.2.12-1977 Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants IV. ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants V. ANSI N45.2.6-1978 Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants VI. R.G. 1.26, Rev. 3 Quality Group Classifications and Standards for Water , Steam- and Radioactive-Waste-Containing Components of Nuclear Power Plants VII. R.G. 1.29, Rev. 3 Seismic Design Classification VIII. ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants TITLE PAGF REV. NO. IIATF APPENDIX B (EXCEPTIONS) 1 of 14 17 12/5/86 8701140141 870109 PCR P
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I. ANSI N45.2.3 - 1973 Housekeeping During the Construction Phase of Nuclear Power Plants A. EXCEPTION:
Subsection 2.1 - Planning The Yankee operating plants take exception to the five-zane requirements specified in the subject standard.
ALTERNATIVE:
The Yankee operating plants shall establish as a minimum a three zone program as follows:
Zone III Zone III criteria shall be applied to major portions of the 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.
NOTE: 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.
Zone IV Zone IV criteria shall te 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 TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 2 of 14 17 12/5/86
g e YANKEE ATOMIC ELECTRIC COMPANY in the areas of Housekeeping, Plant and Personnel Safety and Fire Protection.
- 2. Additional housekeeping requirements shall be implemented as required for the control of radioactive contamination.
- 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.
- 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 Safety and Fire Protection.
B. EXCEPTION:
Subsection 3.2 - Control of Facilities The Yankee operating plants take exception to the control of tools, equipment, materials and supplies used in Zone III. ,
ALTERNATIVE:
The Yankee operating plants shall verify control for Zone III is indicated in Exception A of this sub-category.
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'i t; TITLE PAGE REV. NO. DATE l' APPENDIX B (EXCEPTIONS) 3 of 14 17 12/5/86
YANKEE ATOMIC ELECTRIC COMPANY .
II. ANSI N45.2.10 - 1973, Quality Assurance Terms and Definitions A. EXCEPTION:
Subsection 2 - Terms and Definitions The Yankee operating plants take exception to the definitions of
" Certificate of Conformance" and " Certificate of Coopliance".
ALTERNATIVE:
The Yankee operating plants 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.
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TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 4 of 14 17 12/5/86
YANKEE ATOMIC ELECTRIC COMPANY III. ANSI N45.2.12 - 1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants A. EXCEPTION:
Subsection 4.2.2 Team Selection -
The Yankee operating plants take exception to the requirement for a
" Lead Auditor".
, ALTERNATIVE:
I Team Selection - Audits shall be performed under the cognizance of a Lead Auditor. In selecting personnel for auditing assignments,
, consideration shall be given to special abilities, specialized I
technical training, prior pertinent experience, personal characteristics, and education. One or more auditors comprise an audit team. Auditor responsibilities include establishing the pace of the audit, assuring communications with the organization being audited, participation in the audit performance, and preparation and
- issuance of reports.
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O TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 5 of 14 17 12/5/86
YANKEE ATOMIC ELECTRIC COMPANY IV. ANSI M45.2.2 - 1972, Packaging, Shipping, Receiving, Storage & Handling of Items for Nuclear Power Plants A. EXCEPTION:
Subsection 3.7.1 & A3.7.i - Containers
- The Yankee operating plants take exception to the specific requirements for containers.
ALTERNATIVE:
Containers shall be of suitable construction to assure material is I
received undamaged.
i' JUSTIFICATION:
1 Containers shipped by closed carrier, stored inside and not subjected to a wet environmen't do not require weather resistant fiberboard, therefore, this is an unnecessary expense.
Additionally, numerous vendors utilize shipping cont.ainers 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 Yankee operating plants take exception to the requirement that skids and runners shall be used on boxes with a gross weight of 100 pounds or more.
ALTERNATIVE:
Skids or runners shall be used on boxes with a gross weight of 100 pounds or more if practical.
TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 6 of 14 17 12/5/86
YANKEE ATOMIC ELECTRIC COMPANY JUSTIFICATION:
Storage methods and container design frequently are such that runners or skids are not feasible.
C. EXCEPTION: -
Subsection 5.2.1 - Shipping Damage Inspection The Yankee operating plants take exception to the requirement that a preliminary visual inspection or examination be performed prior to unloading.
ALTERNATIVE:
The Yankee operating plants shall perform those required inspections after unloading. In special instances, pre-unloading inspections shall be performed.
JUSTIFICATION:
Post unloading inspection is adequate to determine any damage that may have been incurred during shipping and handling.
D. EXCEPTION:
Subsection 5.2.2 - Item Inspection The Yankee operating plants take 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 Yankee operating plants 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 TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 7 of 14 17 12/5/86
YANKEE ATOMIC ELECTRIC COMPANY l
, shall be such that deterioration is prevented and applicable manufacturer recommendations are addressed.
JUSTIFICATION: '
Receipt inspection activities are for a much shorEer duration and i
therefore should not be subjected to the same stringent requirements
- as required for storage.
E. EXCEPTION:
- Subsection 5.2.3 - Special Inspection i
The Yankee operating plants take exception to attaching special inspection procedures to the item or container.
i ALTERNATIVE:
Special inspection procedures shall be readily available to personnel performing inspections.
JUSTIFICATION:
1 Procedures are subject to less abuse and more stringent controls s when maintained on file and not attached to the item. Inspection l l status is maintained by tagging and procedure control.
F. EXCEPTION: -
l Subsection 6.1.2 - Levels of Storage ,
The Yankee operating plants' take exception to two specific 4
requirements associated with fuel storage (classified level A).
ALTERNATIVE:
The Yankee operating plants shall meet the requirements of level A storage for new fuel with the exception of special air filtering; and temperature and humidity controls.
t TITLE PAGE REV. NO. DATE APPENDIX B l
(EXCEPTIONS) 8 of 14 17 12/5/86
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YANKEE AT0MIC ELECTRIC COMPANY JUSTIFICATION:
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The existing storage conditions at the Yankee operating plants 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 protectiori 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) I where the uranium pellets may be exposed to the atmosphere and not l in its fully encapsulated, and therefore, fully protected form in a l completed fuel assembly.
G. EXCEPTION:
Appendix A-3 Subsection A3.5.1(1) - Caps & Plugs The Yankee operating plants take exception to the requirement that non-metallic plugs and caps shall be brightly colored.
ALTERNATIVE:
Non-metallic 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 contrastine color this objective can be achieved.
H. EXCEPTION:
Appendix A-3 Subsection A3.9(1) - Second Group, Markings The Yankee operating plants take exception to the requirement that j container markings shall appear on a minimum of two sides.
! ALTERNATIVE:
Containers shall be adequately marked to provide identification and retrievability.
TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 9 of 14 17 12/5/86
YANKEE ATOMIC ELECTRIC COMPANY 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. EXCEPTION:
Appendix A-3, Subsection A.3.9(4) - Second Group. Marking The Yankee operating plants take exception to the requirement that container markings shall be no less than 3/4- high container permitting.
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:
Appendix A-3 Subsection A.3.9(6) - Second Group, Marking The Yankee operating plants take exception to the information required for container marking.
- ALTERNATIVE:
Marking shall be adequate in each case to provide identification, traceability and instructions for special handling, as applicable.
JUSTIFICATION:
The information required is excessive. Cluttering a container with excessive markings only reduces the main abjectives, maintaining identification and establishing special controls.
TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 10 of 14 17 12/5/86
YANKEE ATOMIC ELECTRIC COMPANY V. ANSI N45.2.6 - 1978, Qualification of Inspection, Examination and Testing Personnel for Nuclear Power Plants A. EXCEPTION:
The Yankee operating plants take exception to the* application of the Standard to all Yankee and Vermont Yankee personnel performing inspection, examination and testing.
ALTERNATIVE:
Yankee and Vermont Yankee personnel identified in ANSI N18.1-1971 who perform inspection, examination and testing will be qualified to ANSI N18.1-1971.
Yankee and 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.
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! DATE TITLE PAGE REV. NO.
APPENDIX B (EXCEPTIONS) 11 of 14 17 12/5/86 l
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YANKEE ATOMIC ELECTRIC COMPANY VI.
Regulatory Guide 1.26, Rev. 3, (2/76), Quality Group Classifications and
-Standards for Water , Steam- and Radioactive-Waste-Containing Components of Nuclear Power Plants A. EXCEPTION:
The Yankee operating plants take exception to the Regulatory Guide in its entirety.
ALTERNATIVES:
Yankee Yankee shall continue to classify structures, components, and systems in accordance with ANSI Standard N18.2, January 1973, " Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants", as in the past.
Vermont Yankee Vermont Yankee shall continue to classify stiructures, components and systems in accordance with ANS-22, Draft No. 4, Rev. 1, May 1973,
" Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants", as in the past.
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C i TITLE hAGE REV. NO. DATE i
APPENDIX B (EXCEPTIONS) 12 of 14 17 12/5/86 l _ _
YANKEE ATOMIC ELECTRIC COMPANY VII. Regulatory Guide 1.29, Rev. 3, (9/78), Seismic Design Classification A. EXCEPTION:
The Yankee operating plants take exception to the application of Regulatory Guide 1.29, Rev. 3, (9/78).
ALTERNATIVES:
Yankee Yankee shall apply Regulatory Guide 1.29~, Rev. 3, (9/78), to those structures, systems and components as determined by the USNRC System Evaluation Program.
i Vermont Yankee The seismic design classification of structures, systems, and components at Vermont Yankee shall be as defined in the Vermont Yankee FSAR.
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TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 13 of 14 17 12/5/86 2
YANKEE ATOMIC ELECTRIC COMPANY VIII. ANSI N18.7 - 1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants A. EXCEPTION: (Vermont Yankee Plant only)
Subsection 5.3.9 - Emergency Procedures
- The Vermont Yankee Operating Plant 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.
JUSTIFICATION:
NUREG 0737 supercedes ANSI N18.7-1976 in the area of Emergency Operating Procedures. Changes to procedure format are required fu order to develop Symptom / Function-Based Procedures.
t l- TITLE PAGE REV. NO. DATE APPENDIX B (EXCEPTIONS) 14 of 14 17 12/5/86 l
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