ML20216F369

Responds to 980312 RAI Re Vermont Yankee Adherence to Quality Assurance Program Provisions.Listed Schedule Has Been Established

ML20216F369
Person / Time
Site:	Vermont Yankee
Issue date:	04/10/1998
From:	Reid D VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-98-55, NUDOCS 9804170043
Download: ML20216F369 (6)

Text

VERMONT YANKEE NUCLEAR POWER CORPORATION 185 Old Ferry Road, Brattleboro, VT 05301 7002 (802) 257-5271 April 10,1998 j BVY 98-55 '

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Reference:

(a) Letter, USNRC to VYNPC, Request for Information Regarding Adherence to Quality Assurance Program Provisions, NVY 98-33, dated March 12,1998 l (b) letter, Yankee Atomic Electric Company to USNRC, Sale of Yankee Nuclear l Services Division Assets, BYR 97-060, dated December 5,1997 (c) Letter, Yankee Atomic Electric Company to USNRC, Yankee Atomic Electric Company Operational Quality Assurance Program (YOQAP-1-A), l Rev. 28, dated June 23,1997 (d) letter, Yankee Atomic Electric Company to USNRC, Yankee Atomic Electric Company Operational Quality Assurance Program (YOQAP-1-A),

Rev. 28, dated October 1,1997 l

(e) Letter, USNRC to VYNPC, Request for Additional Information (RAI)

Regarding the Vermont Yankee Nuclear Station Operational Quality Assurance Program, Revision 28 (TAC No. M99265), dated November 24, 1997 (f) Letter, VYNPC to USNRC, Operational Quality Assurance Program, Revision 28, TAC No. (M99265), dated February 25,1998 l

l

Subject:

Vermont Yankee Nuclear Power Station l License No. DPR-28 (Docket No. 50-271) l Response to Request for Information Regarding Adherence to Quality Assurance Program Provisions This letter responds to the request for information contained in reference (a). The basis for the questions appears to be rooted in a fundamental misunderstanding of the transaction wherein Duke Engineering and Services (DE&S) purchased the Yankee Nuclear Service Division (YNSD) of Yankee Atomic Electric Company (YAEC). Before responding to the questions in detail, a summary of the transaction as it affects Vermont Yankee Nuclear Power Corporat.on (VYNPC), the licensee for the Vermont Yankee Nuclear Power Station (VYNPS), may be useful.

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VERMONT Y ANKEE NUCLEAR POWER CORPORATION Docket 50-271 BVY98-55 2 of 6

Background:

On December 1,1997, YAEC completed the sale of YNSD to DE&S. YNSD provided quality 1 assurance and engince.pg services to YAEC and to the affiliated Yankee organization and companies. VYNPC used many of these services including quality assurance. As reference (a) points out, the NRC has approved the Yankee Atomic Operational Quality Assurance Program (YOQAP-1-A) for VYNPS. Prior to consummation of the sale an evaluation was made in accordance with the requirements of 10CFR50.54(a)(3). This evaluation explicitly examined the transaction and its impact on the effectiveness of the VY operational quality assurance program.

Since VYNPC, the license holder for VYNPS, is a separate corporation, the transaction involved only a name change for an organization providing QA services to VYNPS. The conclusion was that the effect was purely administrative in nature and prior approval of the transaction was not required. This arrangement satisned the requirements of 10CFR50, Appendix B, Criterion 1 ]

before the sale and those requirements are still satisfied. All QA processes used by YNSD remain the same and are being used by DE&S engineering and QA personnel.

YOQAP-1-A, Revision 27, is a quality assurance plan shared by both Vermont Yankee and the Yankee Rowe Plant. YAEC is the licensee for Yankee Rowe whereas the licensee for Vermont Yankee is the Vermont Yankee Nuclear Power Corporation, a separate corporation. Therefore, the sale of YNSD has a different effect on Yankee Rowe than on Vermont Yankee. Reference (b) speaks to how Yankee Rowe is addressing the transition associated with the sale of another division of YAEC and hiring it back as a contractor. In the Vermont Yankee case, YNSD has always been a fee for service organization and now it is called DE&S Bolton.

As identified earlier, YNSD provided engineering services to VYNPC, Prior to the sale a substantial number of YNSD engineering and support personnel were put on the VY pay roll.

These personnel were and remain engaged in full time support of the VYNPS. Most of the YNSD personnel that remained in the YNSD (now DE&S Bolton) organization are available to support VYNPS.

In related matters, references (c) and (d) submitted Revision 28 to the Yankee Atomic Operational Quality Assurance Program (YOQAP-1-A), Revision 27. This revision contained an update to reflect organizational changes and to correct a selfidentined deviation between j YOQAP-1-A, Revision 27 and the Safety Classification Manual. The Safety Classincation Manual had been changed to recognize ANS 52.1 as an additional industry standard that could be used for safety classification determinations. YOQAP-1-A, Revision 27 takes exception to Regulatory Guide 1.26,identines ANS-22 only as the basis for system classification, but does l not recognize ANS 52.1. Reference (c) requested information about the exception taken to Regulatory Guide 1.26 in both Revision 27 and proposed Revision 28 of YOQAP-1-A.

Reference (f) responded to reference (c) and provided information on the safety classification I

VERMONT YANKEE NUCLEAR POWER CORPORATION i

O Docket 50-271 BVY98-55 3 of 6 issue. While VYNPC was developing a response to reference (c), DE&S bought YNSD.

VYNPC has implemented the organizational changes detailed in Revision 28. The major elements of these changes are the creation of the position of Director of Safety and Regulatory l Affairs reporting to the President and Chief Executive Officer. The Executive Director of i Quality Assurance now reports to this individual rather than to the Senior Vice President of Operations. A Director of Procurement pcsition has been added. A Systems Engineering Department headed by a Systems Engineering Manager has also been added. This individual reports to a VY Vice President. The position of Performance Engineering Manager has been climinated. These changes have been evaluated using the criteria of 10CFR50.54(a) and found to result in no reduction in commitment to quality. The requirements of Criterion 1 of 10CFR50, Appendix B are fully met in the new reporting relationships.

Action Plan:

Given the sale of YNSD and the need for future flexibility and the need to eliminate the confusion associated with YOQAP-1-A, VYNPC has decided to adopt an operational quality assurance program exclusively for VYNPC. Therefore, VYNPC declares that the current NRC 1 approved version of YOQAP-1-A, Revision 27, will become the VYNPC Operational Quality Assurance Manual (VOQAM), Revision 0, on May 1,1998. References to Yankee Rowe remain inoperative for VYNPS. This does not constitute a reduction of con.mitment in our QA program and therefore does not require prior NRC approval as determined by 10CFR50.54(a). The l appropriate contractual changes will also be made between VYNPC and DE&S Bolton '

recognizing the VOQAM. .

We recognize that the issues addressed in Revision 28 to YOQAP-1-A still need to be resolved along with removing references to YNSD. To minimize confusion, Vermont Yankee is withdrawing references (c) and (d). We will provide a c'urrent VY organizational structure in a revision to VOQAM and address any remaining administrative issues resulting from the Yankee Atomic organization change. Additionally, VY will resubmit a change to VOQAM clearly defining the basis and justification for resolving the safety classification issue.

Therefore we have established the following schedule:

(1) Issue Revision I to the VY QA Pian in the near term to update the organizational information. This revision will remove all vestiges of YOQAP-1-A. It will delineate the relationship of the new Duke Engineering and Services Bolton in the VOQAM. This revision will contain no reductions in commitments and therefore require no prior approval from the NRC in accordance with the requirements of 10 CFR 50.54(a)(3). This revision will be issued by June 1,1998.

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VERMONT Y ANKEE NUCLEAR POWER CORPORATION Docket 50-271 l BVY98-55 4 of 6 (2) Revision 2 to the VOQAM will address the VY system classification program.

This change will clearly document VY's intentions regarding the goveming l standards intended to be used. As part of our effort, an assessment will be made l as to whether the exception to Regulatory Guide 1.26 should continue to be contained in the QA Manual or be relocated to the Updated Final Safety Analysis Report.

Response to reference (ah In the following, each request from reference (a) is repeated prior to the response.

Request (a): Inscribe how the present quality assurance organizational structure and functions delineated in YOQAP-1-A, Revision 27, are being implemented with respect to the activities performed by DE&S and the applicable inter-relationships between YAEC and DE&S.

Response: Until now Vermont Yankee Nuclear Power Station and Yankee Rowe Nuclear Power Station have shared the same QA Program, YOQAP-1-A, Revision 27. As discussed above, the QA organization is described in Revision 27 of the YOQAP-1-A and is the same as prior to the sale of YNSD. DE&S Bolton QA Services are supplying the QA services. The same people are in the same organizational positions as before. The Senior Vice President, Nuclear Operations, VYNPC remains the senior official responsible for the implementation of the quality assurance program.

l Effective December 1,1997, the responsibilities for VYNPS quality assurance defined in the YOQAP-1-A, and previously assigned to the YNSD are now assigned to DE&S Bolton by the Senior.Vice President, Operations, VYNPC.

The same personnel will be implementing the same policies and procedures as performed under the contract with YNSD. The contract between Vermont Yankee and DE&S Bolton requires all work to be performed in accordance with l VY's approved QA topical report, YOQAP-1-A. The licensee has evaluated the l change and concluded that the requirements of 10CFR50, Appendix B, Criterion 1, are being satisfied fully. The Executive Director of Quality Assurance continues to be a contractor supplying quality assurance services as well as I providing QA staff. This individual continues to report to a VY management level that is a direct report to the VYNPC President and CEO just as before.

Request (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.

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VERMONT Y ANKEE NUCLEAR POWER CORPORATION Docket 50-271 I BVY98-55 5 of 6 Response: As described above, a 10CFR50.54(a) evaluation of the YOQAP-1-A was performed prior to the sale of YNSD. The evaluation concluded that no deviations were taken from the YOQAP-1-A. The responsibility changes from YNSD to DE&S Bolton involved no reduction in QA program commitments. The evaluation concluded that the same people were doing the same job using the i same procedures.

Request (c): Describe how the requirements of Criterion IV, " Procurement Document Control," and Criterion VII, " Control of Purchased Material, Equipment, and j Services," of Appendix B to 10CFR50 and the provisions of YOQAP-1-A are being met for services such as engineering and quality assurance that are (

performed by DE&S.

l Response: The VYNPC contract with DE&S Bolton requires all work to be performed in accordance with the applicable requirements of the YOQAP-1-A which addresses i I

these two criteria. DE&S Bolton is on the VYNPC approved vendors list which is currently the Yankee Rowe approved vendors list as well. YNSD was originally put on the approved vendors list based on an audit performed by the Boston Edison Company in 1996 on behalf of the Yankee affiliated organizations, i.e.,

VYNPC, Maine Yankee, Seabrook Station, Boston Edison, and Northeast Utilities. The same organizations approved the change from YNSD to DE&S Bolton, because the people, processes, and QA Program remain the same. For VYNPC, the effectiveness of the control of quality by DE&S Bolton is assessed by use of VY management oversight, by review and approval of QA audits conducted by DE&S Bolton and by sponsor audits. All audits are performed under the cognizance of the Vermont Yankee Nuclear Safety and Review Committee (NSARC). In addition, DE&S Bolton is assessed by the Joint Utility Management Audit (JUMA) audits, participation in the Joint Quality Group for approved vendors list activities, and the Joint Quality Audit Group for audit activities.

Request (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-1-A, Revision 27.

Response: The contract between VYNPC and DE&S Bolton requires DE&S Bolton to conform to the requirements of YOQAP-1-A. Since the same people, policies, and procedures are involved, there is little chance for deviation from the QA program in the near future. However, in order to provide additional assurance of a  !

good quality program and good contractor performance, the triennial audit scheduled for 1999 has been moved up to the third quarter of 1998. As pointed

gg VERMONT YANKEH NUCLEAR POWER CORPORATION Docket 50-271 BVY98-55 6 of 6 out previously, the VY Senior Vice President, Operations, continues to be the final management authority for assuring the QA Program is acceptably l

implemented within the VY Nuclear Power Corporation. DE&S Bolton has been retained by VY to provide QA management, engineering, and administrative services. All work performed by DE&S Bolton under the terms of the contract l shall be performed in accordance with the VY QA Program. In most cases, the personnel, program, and procedures remain the same as under the contract with YNSD.

Request (e): Identify any deviations from the provisions of YOQAP-1-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-1-A, Revision 27, that resulted from the purchase of YNSD by DE&S.

Response: There were no deviations from the provisions of YOQAP-1-A identified resulting from the purchase of YNSD by DE&S.

Should there be any questions please contact this office.

Sincerely, VERMONT YANKEE NUC1 EAR POWER CoRPoRATloN Donald A. Reid Senior Vice President, Operations cc: USNRC Region 1 Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager - VYNPS Vermont Department of Public Service