ML20216C810

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Requests Addl Info Re Adherence to QA Program Provisions
ML20216C810
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 03/12/1998
From: Croteau R
NRC (Affiliation Not Assigned)
To: Reid D
VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 9803160192
Download: ML20216C810 (4)


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WASHINGTON, D.C. 2066H001 March 12, 1998 Mr. Donald A. Reid Senior Vice President, Operations Vermont Yankee Nuclear Power Corporation 185 Old Ferry Road Brattleboro,VT 05301

SUBJECT:

REQUEST FOR INFORMATION REGARDING ADHERENCE TO QUALITY ASSURANCE PROGRAM PROVISIONS

Dear Mr. Reid:

The purpose of this request for information is to provide the U.S. Nuclear Regulatory -

Commission (NRC) with adequate assurance that the Vermont Yankee Nuclear Power Station is operated in accordance with the provisions of the Vermont Yankee Nuclear Power Corporation quality assurance program description following the sale of the Yankee Nuclear Services Division (YNSD) to Duke Engineering and Services (DE&S)

The staff has previously reviewed your Operational Quality Assurance Program, YOQAP-l-A, Revision 27, and concluded that it is acceptable and properly describes how the requirements of Appendix B to 10 CFR Part 50 will be satisfied.

10 CFR 50.34(b) " Final safety analysis report," (FSAR) requires that each application for a license to operate a facility shall include a final safety analysis report, and requires that this report include information that describes the facility, presents the design basis and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole and shall include certain information, analysis, and descriptions among which is the following information concerning facility operation:

10 CFR 50.34(b)(6)(ii) Managerial and administrative controls to be used to assure safe operation. Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," sets forth the requirements for such controls for nuclear power plants and fuel reprocessing plants. The information on the controls to be used for a nuclear power plant or fuel reprocessing plant shall include a discussion on how the requirements of Appendix B will be satisfied.

Appendix B to 10 CFR Part 50 (Appendix B) establishes quality assurance requirements, for the design, construction, and operation of a nuclear power plant's safety-related systems,

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structures, and components. Included in Criterion 1, " Organization," of Appendix B is a requirement for the establishment and execution of the quality assurance program which includes establishing and delineating in writing the authority and duties of persons and organizations perfurming activities affecting the safety-related functions of structures, systems, and components. These activities include both the performing functions of obtaining quality and the quality assurance functions. The quality assurance functions are those of (a) assuring that an appropriate quality assurance program is established and effectively executed and, (b) l 9803160192 980312 PDR ADOCK 05000271 P

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D. Reid l verifying, such as by checking, auditing, and inspection, that activities affecting safety-related functions have been correctly performed.

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i The provisions contained in Vermont Yankee Nuclear Power Corporation's FSAR are part of its licensing basis and need to be complied with. We are currently reviewing the reduction in j

commitment, associated with Regulatory Guide 1.26, identifed in proposed YOQAP-l-A, Revision 28, which was forwarded to the NRC by Yankee Atomic Electric Company (YAEC) letter dated June 23,1997, and supplemented by Vermont Yankee Nuclear Power Corporation letters dated December 23,1997, and February 25,1998.

The NRC staffis aware of the recent purchase of the YAEC's Yankee Nuclear Services Division by Duke Engineering & Services (DE&S). As a consequence of this action, the staff has a concem about how the regulatory requirements and commitments in your YOQAP-l-A Quality i

Assurance Program description document are being fulfilled under the new organizational structure created as a result of this purchase.

1 The NRC requires the information, requested below, in order to: (1) verify compliance with the i

terms and conditions of your license and NRC regulations, and (2) to confirm that the plant QA Program description properly describes how the requirements of Appendix B to 10 CFR Part 50 will be satisfied.

(a)

Describe how the present quality assurance organizational structure and functions delineated in YOQAP-I-A, Revision 27, are being implemented with respect to the activities performed by DE&S and applicable inter-relationships i

between YAEC and DE&S.

j (b)

Discuss how the DE&S purchase of YNSD was evaluated with respect to the provisions of 50.54(a) regarding QA program commitment change control.

(c)

Describe how the requirements of Criterion IV, " Procurement Document Control,"

and Criterion Vil, " Control of Purchased Material, Equipment, arid Services," of Appendix B to 10 CFR Part 50 and the provisions of YOQAP-l-A are being met for services such as engineering and quality assurance that are performed by DE&S.

(d)

Provide the rationale for concluding that the QA program functions previously performed by YNSD, now performed by DE&S, continue to satisfy the provisions of YOQAP-t-A, Revision 27.

(e)

Identify any deviations from the provisions of YOQAP-l-A, Revision 27, for the current implementation of the quality assurance functions and a description of any corrective action for any deviation (s) from the provisions of YOQAP-l-A, Revision 27, that resulted from the purchase of YNSD by DE&S.

D. Reid 3

Please respond within 30 days of receipt of this letter so that we may complete our review; contact me at (301) 415-1475 with any questions you may have about this request.

Sincerel,

f Richard P. Croteau, Project Manager Project Directorate 1-3 Division of Reactor Projects - 1/Il Office of Nuclear Reactor Regulation Docket No. 50-271 cc: See next page DISTRIBUTION Docket File.

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l D. Reid Vermont Yankee Nuclear Power Station ec:

Regional Administrator, Region i Mr. Raymond N. McCandless U. S. Nuclear Regulatory Commission Vermont Division of Occupational 475 Allendale Road and Radiological Health King of Prussia, PA 19406 Administration Building Montpelier,VT 05602 Mr. David R. Lewis Shaw, Pittman, Potts & Trowbridge Mr. Gautam Sen i

2300 N Street, N.W.

Licensing Manager Washington, DC 20037-1128 Vermont Yankee Nuclear Power Corporation Mr. Richard P. Sedano, Commissioner 185 Old Ferry Road Vermont Department of Public Service Brattleboro,VT 05301 120 State Street,3rd Floor Montpelier, VT 05602 Resident inspector Vermont Yankee Nuclear Power Station Public Service Board U. S. Nuclear Regulatory Commission State of Vermont P.O. Box 176 120 State Street Vemon, VT 05354 Montpelier, VT 05602 Mr. Peter LaPorte, Director Chairman, Board of Selectmen ATTN: James Muckerheide Town of Vemon Massachusetts Emergency Management P.O. Box 116 Agency Vemon, VT 05354-0116 400 Worcester Rd.

P.O. Box 1496 Mr. Richard E. McCullough Framingham, MA 01701-0317 Operatir g Experience Coordinator Vermont Yankee Nuclear Power Station Jonathan M. Block, Esq.

P.O. Box 157 Maln Street Govemor Hunt Road P. O. Box 566 Vemon, VT 05354 Putney, VT 05346-0566 G. Dana Bisbee, Esq.

Deputy Attomey General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attomey General One Ashburton Place,19th Floor Boston, MA 02108 Ms. Deborah B. Katz Box 83 Shellbume Falls, MA 01370 i