IR 05000271/1986020

Insp Rept 50-271/86-20 on 860825-29.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Qa Program & Nonlicense Staff Training

ML20215N664
Person / Time
Site:	Vermont Yankee
Issue date:	10/29/1986
From:	Dev M, Eapen P, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215N652	List: IR 05000271/1986020 ML20215N651
References
50-271-86-20, NUDOCS 8611070138
Download: ML20215N664 (13)

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U.S. NUCLEAR REGULATORf COMMISSION

REGION I

Report No. 50-271/86-20 Docket N License No. DPR-28 Licensee: Vermont Yankee Nuclear Power Corporation RD 5, Box 169

~ Ferry Road Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Station Inspection At: Vernon, VT Inspection Conducted: August 25-29, 1986 Inspectors:

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liveira, React r Engineer

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ln v L 80*28 96 M. Dev, Reactor Engineer date Approyed b - {,t at ':,' ^ / o/2 9/8 G r. P a . Eapen, Chief, Quality Assurance / date Section, 08, DRS Inspection Summary: Routine, unannounced inspection conducted on August 25-29, 1986 (Report No. 50-271/86-20)

Areas Inspected: Licensee Action on Previous Inspection Findings, Quality Assurance Program and Non-License Staff Trainin Results: No violations or deviations were identifie Nk R G

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DETAILS 1.0 Persons Contacted H. Atkins, Assistant Foreman (Electrical)

F. Burger, Quality Assurance (QA) Coordinator

• P. Howard, Plant Training Instructor

• D. Pike, Operations Quality Manager (Yankee Atomic Electric Company)

R. Gardner, Training Department Program Specialist

• R. Lopriore, Maintenance Department Supervisor

• R. Pagodin, Plant Services Supervisor

• D. Reid, Operations Department Supervisor R. Spinney, Training Department Manager T. Watson, Instrument and Control Department (I&C) Supervisor S. Wender, Engineering Assistant D. Dyer, Senior Quality Assurance Engineer, Yankee Nuclear Service Division G. Gilmore, Stores Department Supervisor R. McCullough, Assessment Coordinator C. Porrovecchio, Stores Quality Assurance Technician-2.0 Licensee's Action on Previous NRC Concerns (Closed) Unresolved Item (50-271/83-22-02): Non-safety-related procurement order The licensee initiated a pilot program to provide a structured approach for making determination of component safety classification. Also, administrative procedure AP-0806 was revised to instruct the store personnel to review the Material Issue Form for its completeness. The implementation of this procedure assures that the materials will be used only for the application identified on the Material Issue For The licensee also revised and updated administrative procedure AP-0800 which implements the general quality assurance requirements, including the equipment safety classification, related to procurement of materials, parts, and components, as applicabl Based on the review of the licensee's action, this item is close (Closed) Unresolved Item (50-271/84-23-02): Shelf-life for safety-related stored item The licensee contracted with Stone & Webster Engineering Company (SWECo)

to determine end-of-life date for all age-sensitive safety-related spare parts and components stored at the Vermont Yankee Nuclear Plant

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l Warehouse. SWECo established shelf-life for these materials based on vendor contacts and recommendation, material evaluation and testing, as applicable. The materials, parts, .and components whose useful shelf-life could not be' justified were considered expired shelf-life and dispost-tioned as-such. The licensee initiated fresh purchase orders to procure ;

shelf-life identified qualified replacement '

Based on-the review of the licensee's action and physical ver'ification, the licensee's corrective action is considered adequate. This item is .

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i (Closed) Unresolved Item (50-271/84-23-03): Shelf-life for non-metallic

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i The licensee reviewed all safety class spare parts and materials presently existing in the Vermont Yankee store inventory, to determine their acceptability for use. Subsequently, expiration dates were assigned to each. item in this category, as applicable, and a tracking mechanism was established to insure their proper contro Based on the review of the licensee's action, the licensee's corrective

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action is considered adequate. Thiscitem is closed.

~ (Closed) Unresolved Item (50-271/84-23-04): Emergency Diesel Generator non-safety-related spare parts.

i The licensee has revised administrative procedure AP-806, " Issuing and

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returning of materials, parts and components." Consequently, implement-ation of this procedure has precluded issuance of non-safety-related materials to safety-related work activities.

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. Based on the review of the licensee's action, the licensee's corrective

action is considered adequate. This item is close (Closed) Notice of Violation (50-271/85-11-01): Inadequate Receipt

Inspection Program Implementation.

I' The licensee evaluated Yankee Operational Quality Assurance Program

'. (Y0QAP-1-A) and updated it in adherance to 10 CFR 50, Appendix B require-l ments. A detailed review of the previous QA Program Surveillances and l Audits was also initiated to identify programatic weaknesses and resolve them in a timely manner. Also, recommendations of the licensee's internal Receipt Inspection Program was evaluated and implemented, as applicabl In addition, the plant management reemphasized-the need for prompt evalu-

!. ation and correction of identified deficiencies, and assigned individual l responsibilities. The cognizant departments provided training to the l station personnel performing quality control activities of operations, i maintenance, procurement and receipt inspection to familiarize them with

! the requirements of procedures AP-0800, AP-0801, AP-0803 and AP-806.

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Based on the review of the licensee's action, this item is close (Closed) Inspection Follow Item (50-271/85-18-04): Follow-up on Receipt Inspection Corrective Action Implementatio The licensee revised and updated administrative procedures AP-0800, AP-0801, AP-0803, AP-0806, and DP-0811 to clarify receipt inspection instructions, provide revised checklists for receipt inspections, and provide inspection guidance for mechanical and electrical component The station warehouse is presently staffed with two qualified Quality Assurance Technicians to perform quality control activities of receipt inspection, and review procurement documentation. A reference library has been established and adequate measuring and test equipment are provided to the receipt inspectors to enhance execution.of receipt inspection and other procurement related activities. In addition, the licensee has improved warehouse preventive maintenance program, instituted the shelf-life program for the age-sensitive materials in the warehouse, and pro-vided training to the station operation, maintenance and warehouse

. personnel to familiarize them with the above procedure Based on the review of the licensee's action, t'his item is close (Closed) Violation (50-271/85-22-01): Procurement and installation of switch (MR 85-256), and coils in main steam isolation valves (MR 85-986)

without verification of their proper safety classificatio The licensee conducted an engineering evaluation and determined that the use of the non-safety related switch (MR 85-256) for safety-related work was acceptable, based on their 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> operational test and satisfactory resistance chec Similarly, the licensee's Non-Conformance Report properly evaluated and dispositioned the use of non-safety-related coil (MR 85-986) for the replacement of MSIV coil, as acceptable, based on 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> operational test. To preclude this from recurring in future, the licensee revised the procedure AP-0806, which requires that the Store Clerk when issuing safety-related materials will verify that the items are properly identi-fied as "P" tagged, in accordance with AP-0802. This insures that safety-related materials are being used for safety-related application.

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In addition, the revised procedure AP-0806 provides for a check-off box on the Material Issue and Material Return Form to facilitate indication of issuance of material for either safety or non-safety work effort. The licensee also provided proper indoctrination and instruction'to the store room personnel ~to implement the intent of AP-080 Based on the review of the licensee efforts, this item is close . . - _ .

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,(Closed) Unresolved ItemL(50-271/85-26-03): Revise Receipt Inspection Checklist ~ to incorporate ANSI N45.2.2-1972 inspection attribut The licensee has revised and. updated administrative procedure AP-0301-including Receipt Inspection Checklist-and General Inspection Guidelines to incorporate the receipt inspection requirements of ANS N45.2.2-1972. Currently, the receipt' inspection is conducted in accordance with this revised procedure which; assures-that the required inspection attributes are verified prior.to the acceptance of materials'

by the Quality Assurance Technicians at the Vermont Yankee Nuclear Plant

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Warehous ' Based on the above, this item.is close (Closed) Unresolved Item (50-271/85-36-08): Upgrade of Commercial grade item The licensee generated a Non-Conformance Report 85-44 which established an evaluation- process for the. items in stock.' Consequently, procedure YAGEN-1, Appendix I was amended, and steps were established to upgrade .

f r.dividual item's for specific use. Also, additional training was provided to.all individuals involved .in . implementation of the evaluation process to insure their familiarization with the ~ regulatory requirements, and

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requirements of maintenance and material traceability. A materials upgrade evaluation (MUE) sheet with specific instruction for its use and .

requirements was. included in the procedure. A " Required" column was added to MUE sheet in addition to " Satisfactory" and Unsatisfactory" columns to

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. provide proper material categorization. The Operation Quality Assurance conducted necessary surveillance and verified that the procedure was implemented correctly. The licensee also revised procedure AP-0800 to insure that the purchase orders (safety and non-safety-related) receive the proper stock code which verifies their intended applicatio Based on the review of the licensee's action,-this item is closed,

! 3.0 Quality Assurance Program Review

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3.1 Audits Program l '~,

The licensee's Operations Quality Assurance procedure 0QA-XVIII-3,

! In-Plant Audit Program delineates methods and process for conducting

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audits at Vermont. Yankee Nuclear Plant. Accordingly, the Yankee Nuclear Service Division QA Audit Group prepares audit schedule, and conducts QA program audits of operational activities. The auditors are qualified and certified-in.accordance with the procedure OQA-XVIII-1. The auditors prepare a comprehensive audit checklist to insure depth and continuity of audits. Subsequent to the conclusion of the audit, an audit report is

. generated and any'nonconformances are documented as audit findings. The audit group manager reviews and approves audit reports. The audit i

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reports are then distributed to audited organization, cognizant plant disciplines, and the upper management, as applicable. The Operations-QA

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. Group at the site conducts surveillances, and reaudits'to verify the implementation of audit finding correction action for the previously identified deficiencies. The Operation QA Group updates and issues Plant Audit' Discrepancies Status Reports bimonthly to the Yankee Nuclear Service Division QA Audit Group to indicate the status of the action item The inspector reviewed the QA audit schedule for the current calendar

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year. 'The schedule covered all major QA-related activities such as design, modifications, purchase,' refueling, preventive maintenance,-

in-service testing, inspection, storage and handling, and corrective action. A review of the~ completed audit reports indicated that they were adequately planned, and conducted within_the targeted schedule. The audit checklists'were comprehensive and covered applicable aspects of 10 CFR 50, Appendix B criteria, other applicable-industry standards, and the licensee's commitments. The following completed audits were reviewed and found to be in compliance with the facility's procedural requirements:

VY-85-088,. Procurement / Material Control VY-85-11, Inspection and Test In accordance with the procedure OQA-XVIII-2, the-licensee is required to issue, within 30 days of the receipt of the audit report, a plant positio : report, and Manager of'0peration (M00) implementation directive to resolve audit finding and implement corrective action. The Audit VY-85-08B indicated 5 programmatic. discrepancies and 1 observation in the audited areas of~ station procurement, receipt' inspection, material control, and trainin It was noted that the manager of operation neither issued the implementation directive within 30 days, nor: requested an extension to the effect. As a result, the-audit finding corrective action was not implemented as of the conclusion of this inspection. The licensee's implementation of the corrective action-for the above audit finding is an unresolved item (50-271/86-20-01).

The audit finding corrective action implementation for audit VY-85-11 was adequate and timely. Three other audits are discussed in Section .2 QA/QC Interface The licensee is in the process of restructuring the station organizatio Accordingly, the plant services (previously administrative services)

department has been assigned to the plant technical services superinten-dent. This necessitated the move of store QA Technicians from the-plant services department to the QA Group under Engineering Support Superviso The reorganization will provide effective communication and prompt exe-

.cution of plant directives and activitie .

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The inspector also reviewed administrative procedure AP-0021, Maintenance Requests, and safety-related MRs 86-1303, 86-1359 and 86-1386.Section IV.2.g of this procedure states that the plant personnel who are assigned to perform the repair shall " document completion of QC hold points and any special inspections in the appropriate blank". Accordingly, the specific section for QA/QC hold point on the MRs was signed by an indivi-dual other than the-inspecting individuals assigned to witness the hold points and witness steps. However, the inspecting individual did issue his own inspection reports indicating witness of the hold points and the result thereof. The licensee agreed to review the aaequacy of procedure for lack of clarity for verification of witness and hold points remains unresolve (50-271/86-20-02).

4.0 Non-Licensed Staff Training 4.1 General The purpose of this portion of the inspection was to assess the effectiveness of the non-licensed training program implementation. As a representative sample, the inspectors chose the training programs for instrumentation and control (I&C)' technicians, electrical and mechanical maintenance personnel, Auxiliary Operators (AO) and Peer Inspector The A0 Training is the only non licensed staff tra1ning program that is INPO accredited. The licensee is committed and expects to have the other five non-licensed training programs INP0 accredited by December 31, 1986.

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The effectiveness of the existing program was determined by reviewing the following to the requirements of the applicable procedures listed i Attachment Shift turnover for NP0 (0630,1530, 2315)

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A0 activities on day shift (conducting nuclear roving rounds; and system and equipment verification).

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MR 86-1236, Installation of Spring-Pack Grease Release Tubing on RHR Valve 1031B operator

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MR 85-1977, Modification of Impeller to Clean Up Pump P49-1A

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MR 86-1781, Repair Seal on Pump P49-1A

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Training and qualification records of two instructors, six A0s, one electrician, four I&C technicians, one Shift Engineer (STA), four engi.neers, five supervisors, and four principle staff member "Les:ons . learned" factored. into the training progra . - - - --

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Lesson plans and' Student-Evaluations in A0 Training Program

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Quality Assurance (QA) Audits and Surveillance Audits 4.2 Details of the Review For each of the job functions identified in paragraph 3.1, the inspector reviewed the established training program, implementing procedures, qualification, and experience of personnel, qualification and training of instructors, quality of on-the-job (0JT) or Job Performance Measure (JPM)

training,-and the effectiveness of training as evidenced in daily activitie The comments and evaluations from the trainees, line supervisors, and instructors were also reviewed to establish how this feedback was factored into future training. Management and Quality Assurance (QA) involvement in the training area'were assessed for effectivenes .3 Observation of Work Activities The ins'pector witnessed the work activities identified in Section above. The activities were conducted in accordance with the~ procedures by personnel knowledgeable in the requirements of the procedures and technical specifications. This was especially evident in the following:

During the nuclear rounds, the A0 noted that the Clean Up Differential Gage for.the.Demineralizer Pump was reading zero rather than 3.7 psi He immediately notified the control room and recorded the event in'the site log and his rounds log (VYAPF 0150.02, Rev 23).

MR 86-1879 required that the solenoid valve internals be replaced in accordance with ASCO Bulletin 8210. When the internals were removed it was noted that the diaphragm sealing area was " crushed". The new internals were installed and the valve assembly was to be torqued to 144115 in-lbs. in accordance with the Bulletin. When the torque value

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reached 100 in-lbs, the I&C quality control (QC) inspector (peer l inspector) notified the I&C Supervisor and they agreed to torque to 129

in-lbs. With the lower limit value the valve did not' fail and the l licensee will be advising ASCO of the results.

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Special training was conducted by the assistant foreman in accordance with the Limitorque letter for installing spring pack grease release j tubing, and OP 5220. Thi5 training was performed prior to conducting work in accordance with MR 86-123 Assurance of the need for peer inspections to be " independent" was demon-strated during the processing of the QC Inspection Report No.86-147 of MR 86-1781. The QC Inspection Report contained the signatures of three l individuals performing peer inspection. The first inspector had a minor I part in the job and supervision replaced him. The second inspector had l not completed his qualifications for peer inspector and was also replaced.

! The third inspector verified the previously inspected work prior to pro-l ceeding with the completion of the inspection.

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4.4 Training Policy and Progress The inspector reviewed selected proce'dures, to understand the documented training program. The key procedures are the Training Program Management Plan (TPMP) and Administrative Procedure (AP) 0700 for Training Policy; AP 0715 for A0 Training, Department Procedure (DP) 0204 for Maintenance Training and DP0303 for I&C; these documents establish the bases for and the commitment to training, 0JT/JPM and measuring program effectivenes The training for A0's is conducted by two instructors at the new Training Center located in Brattleboro, Vermont. The inspector reviewed the lesson plans, student evaluations, and the instructor continued training. These were complete and processed in accordance with procedures. To obtain end of course or session evaluations, a program specialist meets with the students without the instructor being present. The specialist provides and discusses the results of the meeting with the instructor. In addition to this evaluation and periodic appraisals, unscheduled " class room observations" by peers are also conducted. Student critique sheets are evaluated and actions, if required, are taken in a timely manne Training for example, added a CDR Hydraulics course, and a Simulator -

Training for A0s course in' response to student critiques. They are also preparing a Heat Transfer and Fluid Flow course in response to student request All Licensee Event Reports (LERs) were reviewed and one (LER 86-04) will be incorporated in the next requalification session. To measure effectiveness, the instructors visit the plant at least once per wee These visits included review of training adequacy with supervision, review of recent hardware and procedure changes at the plant and discussions with student Th2 Maintenance Department training for foremen, assistant foremen, lead plant mechanics, assistant mechanics, utility men, and engineers is being revised for INPO accreditation. A training coordinator spends two days per week at the Training Center to assist the training experts in developing a training program for INP0 accreditation. The present training is in accordance with DP 0204. The procedures states that the training "will consist of a on-the-job training, on-site training by j vendor representatives, and off-site training at vendor schools. DP 0204 further states "All department personnel have exhibited proficiency in one or more trades prior to being hired." DP 0204 intends "to demonstrate that department personnel are trained in the application of their trade as it applies to the plant equipment." The inspector reviewed the implementation of the department training through MR 85-1977, MR 86-1236, and MR 86-178 The personnel involved in the work were journeyman prior to being hired and were qualified. They had spent 8-18 months as assistant plant mechanics learning the plant specific Upon completing the requirements

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listed on form VYDPF 0204.02 of OP0204, they were given a written

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examination. Upon passing the examination they were promoted to plant

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mechanic. Continued training is provided on an as needed basis at vendor and/or.off-site schools". They'are also required to review annually subjects such as LERs, technical specification, safety manual, the emergency plans, and review of plant modifications as they apply to the Maintenance Departmen Like the Maintenance Department, the I&C Department is revising it's training program for INPO accredition. The I&C training coordinator is spending two days per week to develop a program for the department supervisor, foremen, engineering assistants, and the technicians. The present-training is in accordance with DP 0303. .The training includes a three week systems course for I&C personnel given at the Training Center by licensee personnel, as well as the regular 0JT, required reading, in-house lectures, and vendor training. Again like the Maintenance Department, all I&C personnel were hired with prior experience, trained on the plant specifics and promoted to technician Peer inspection was formally instituted in January 1986 by the issuance of AP 6.025. With the outage underway, the peer inspection was conducted by qualified contractor QC inspector personnel. After the outage, I&C Department continued to use a contractor QC inspector to perform peer inspections under the direction of the I&C Department Supervisor. Post Maintenance Department peer inspection was conducted by supervisory personnel until recently when-the inspector reviewed the peer inspection for MR 86-1781, (see paragraphs 4.3 and 4.5).

The inspector reviewed the training records of those personnel who conducted the activities identified in paragraph The records were complete, easily accessible, properly filed and in compliance with Regulatory Guide (RG) .5 Findings Peer inspection is not addressed in the General Employee Training (GET)

or in the new employee indoctrination course Senior personnel qualify as peer inspectors by reading AP 6025 and passing a test regarding'the contents of the AP. The inspector discussed the training question with supervisory personnel and two peer inspector They all agreed that additional training was required. Concerns discussed included: acceptance criteria, (e.g. how clean is clean); communications; and writing credible reports. This is an unresolved item pending the development and implementation of additional training. (50-271/86-20-03).

4.6 QA/QC Interface with Non Licensed Staff Training The inspector reviewed three audit reports conducted in 1984-86 that I involved training. The audits were thorough, and the files contained the

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checklists and the audit responses. In one case, audit report VY-86-18 noted that the Engineering Support Department personnel had not received peer inspection training in accordance with AP 6025. The response was being prepared by the audited organization at the time of this inspectio The Operations Quality Group (0QG) was tasked by the Plant Manager to perform extensive surveillance audits during the periods of July 1 through October 22, 1985, and April 7-11, 1986. The results of the surveillances did not deal with any training problem No violations were identifie .0 Unresolved Items Unresolved Items are matters about which more information is required to ascertain whether they acceptable items or violations. Unresolved items are discussed in paragraphs 2, 3, and .0 Management Meetings Licensee management was informed of the scope and. purpose of the inspec-tion'at the entrance interview on August 25, 1986. The findings of the inspection were discussed with licensee representatives during the course

, of the inspection and presented to licensee management at the August 29, 1986 exit interview (see paragraph 1 for attendees).

At no time during the inspection was written material provided to the licensee by the inspectors. The licensee indicated that no proprietary information was involved within the scope of this inspection.

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ATTACHMENT A References and Documents Reviewed Y0QAP-I-A, Yankee Operational Quality Assurance Program, Rev 16 Yankee Nuclear Service Division, Operation Quality Assurance (00A)-XVIII-2, In-Plant Audit Program, Rev 21 OQA-XVIII-3, Vendor Audit, Rev 14 Administrative Procedure (AP) 0021, Maintenance Requests, Rev 14 AP 0700, Plant Staff Training, Rev 4 AP 0715, Non-licensed Operator Training, Rev 7 AP 0720, Vermont Yankee Staff Certification, Rev 2 AP 0800, Material and Service Procurement, Rev 12 AP 0801, Receipt, Inspection, and Shipment of Material and Equipment, Rev 15 AP 0803, Storage of Materials and Equipment, Rev 9 AP 0806, Issuing and Returning of Material, Parts and Conponents, Rev 4 AP 6025, Quality Control / Independent Inspection, Rev 0

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DP 0204, Maintenance Department Training, Rev 4 DP 0303, Instrument and Control Training and Retraining Procedures, Rev 6 Operational Quality Assurance (0QA-X-1), Quality Assurance Surveillance, Rev 7 Operational Procedure (0P) 4353, RHR Pump Discharge Pressure l Function / Calibration,-Rev 10 l OP 5220, Limitorque Operator Inspection, Rev 7

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j Training Department Directives (TDD)-17, Rev 0 Training Program Management Plan (TPMP)-1, Introduction, Rev 0 t

TPMP-2-14, Training Program Organization, Goals, and Objectives, Rev 1 TPMP13-13, Instructor Certification Program, Rev 0 l

TMPMP13-20, Instructor Evaluation, Rev i s

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Audit Report (AR) VY 84-5,' Training . . ((.

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AR VY 85-05, Training .

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AR VY 86-18, Inspection and Test y 0QG Surveillance No.85-112 ,

0QG Surveillance No.86-101 ;4 t k Nb &

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