ML20216G656

Responds to 980318 Request for Info Contained in QA Program

ML20216G656
Person / Time
Site:	Yankee Rowe
Issue date:	04/14/1998
From:	Desiree Davis YANKEE ATOMIC ELECTRIC CO.
To:	Fairtile M NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BYR-98-025, BYR-98-25, NUDOCS 9804200429
Download: ML20216G656 (5)

Text

I Telephons(508) 538 2233 Facsimile (508) 568-3703 YANKEE ATOMIC ELECTRIC COMPANY ~ ~ ~ ~ ~

580 Main Street, Bolton, Massachusetts 01740-1398 YA$*xmu .

DON K. DAVIS cwEEuTv"tLecn April 14,1998 BYR 98-025 l

United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 l

Attention: Mr. Morton Fairtile Senior Project Manager l

Non Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation h

l

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) Letter, M. B. Fairtile, U.S. Nuclear Regulatory Commission I (NRC), to F. N. Williams, Yankee Atomic Electric l Company (YAEC), Request for Information Regarding the Quality l Assurance Program at the Yankee Nuclear Power Station, dated March 18,1998 (c) Letter, YAEC to NRC, Sale of Yankee Nuclear Services i

Division Assets, dated December 5,1997 (d) Letter, YAEC to NRC, Yankee Atomic Electric Company Operational Quality Assurance Program (YOQAP-1-A), Rev. 28, dated June 23,1997

, (e) Letter, YAEC to NRC, Yankee Atomic Electric Company l Operational Quality Assurance Program (YOQAP-1-A), Rev. 28.

dated October 1,1997 l

(f) Letter, D. A. Reid, Vermont Yankee Nuclear Power Corporation (VYNPC), to NRC, Request for Information Regarding Adherence to Quality Assurance Program Provisions, dated April 10,1998

Subject:

REQUEST FOR INFORMATION REGARDING TliE QUALITY ASSURANCE PROGRAM AT TliE YANKEE NUCLEAR POWER STATION

Dear Mr. Fairtile:

g u, This letter responds to the request for information contained in Reference (b). The request . fx appears to be the result of a possible misunderstanding of the details of the transaction whereby O'

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9804200429 980418 PDR ADOCK 05000029 W PUR

1 United States Nuclear Regulatory Commission April 14,1998 Attention: Mr. Morton Fairtile Page 2 l Duke Engineering & Services (DE&S) purchased the Yankee Nuclear Services Division (YNSD) l of Yankee Atomic Electric Company (YAEC).

On December 1,1997, YAEC completed the sale of YNSD to DE&S as discussed in Reference (c). As one aspect of this sale, YAEC retained DE&S to provide certain project management, engineering, procurement and related technical, administrative and general support services, all of which are performed by DE&S in accordance with the applicable YAEC programs and procedures which remain in effect. In addition, the President of YAEC contractually delegated responsibility for the continuing review and audit of the implementation of the Yankee Operational Quality Assurance Program (YOQAP-1-A) to DE&S. In accordance with Appendix B to 10 CFR Part 50, the President of YAEC retains the responsibility and authority to assure that the Quality Assurance Program is implemented within the scope of services provided by DE&S and in accordance with YOQAP-1-A for YAEC activities.

Prior to the consummation of the sale of YNSD to DE&S, an evaluation was performed in accordance with the requirements of 10 CFR Part 50.54(a)(3). The evaluation explicitly examined the impact of the transaction on the effectiveness of the Quality . Assurance Program.

The evaluation concluded that the sale of YNSD to DE&S did not constitute a reduction of YAEC's Quality Assurance Program commitments.

Each specific infonnation request in Reference (b) is repeated below and followed by the Yankee Atomic Electric Company response.

Request (a): Describe how the nresent auality assurance organizational structure and functions delineated in YOOAP-1-A. Revision 27. are being imnlemented with resnect to the activities performed by DE&S and annlicable inter-relationshins between {

YAEC and DE&S.

Answer: The Quality Assurance organization described in Revision 27 of the YOQAP-1-A is the same as that prior to the sale of the Yankee Nuclear Services Division except that the quality assurance services are now being supplied by the DE&S QA Services Organization. The same personnel occupy the same organizational positions as before the sale. The President of Yankee Atomic l Electric Company is still the senior corporate officer responsible for the YAEC j Quality Assurance Program.

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Revision 28 to YOQAP-1-A was submitted to the NRC for review in June 1997 i (Reference (d)). Revision 28 included changes to YOQAP-1-A to address I j

specific operational needs for Vermont Yankee and specific

! decommissioning needs for Yankee Nuclear Power Station (YNPS). Res ision 28 i was subsequently resubmitted in October 1997 (Reference (c)) to address  !

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United States Nuclear Regulatory Commission April 14,1998 Attention: . Mr. Morton Fairtile Page 3 NRC questions regarding the changes pertaining to Vermont Yankee.

(There were no questions or comments offered by the NRC regarding the changes for YNPS.) Revision 28 described organizational changes within YAEC which were unrelated to the Quality Assurance organization but which were appropriate for a decommissioning facility as it progressed further toward completion of decommissioning. The organizational changes for YAEC werejudged to not reduce any commitments in the program description previously accepted by the NRC. The organizational changes in question were implemented.

1 Effective December 1,1997, the YAEC Quality Assurance responsibilities defined in the YOQAP-1-A which were previously assigned to YNSD were contractually reassigned to DE&S by the President of YAEC. The same personnel are implementing the same policies and procedures utilized previously by YNSD, and the contract between YAEC and DE&S requires all work to be performed in accordance with the YOQAP-1-A. The President of YAEC retains the responsibility and authority to assure implementation of YAEC's Quality Assurance Program.

l Request (b): Discuss how the DE&S ourchase of YNSD was evaluated with resocet to the provisions of 50.54(a) regarding OA orogram commitment change control.

Answer: A 10CFR50.54(a) evaluation of the YOQAP-1-A was performed prior to the sale )

of YNSD. The evaluation concluded that there were no deviations from the YOQAP-1-A. The changes in responsibilities from YNSD to DE&S involved no reduction in the Quality Assurance Program commitments. The evaluation )

concluded that the same personnel were doing the same job using the same procedures and that the President of YAEC was still responsible for implementation and oversight of the YAEC quality assurance program.

Request (c)

Describe how the reauirements of Criterion IV. " Procurement Document j Control." and Criterion VII. " Control of Purchased Material. Eauipment. and l

Services." of Apoendix B to 10 CFR Part 50 and the orovisions of YOOAP-1-A l

are being met for services such as engineering and auality assurance that are oerformed by DE&S.

l l Answer: The YAEC contract with DE&S requires all work to be perfomted in accordance l, with the applicable requirements of the YOQAP-1-A which addresses these two criteria. DE&S Bolton is on the YAEC Approved Vendors List. The Yankee Nuclear Services Division, which was the only part of YAEC acquired by i

DE&S, was originally qualified for 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., Vermont Yankee, Seabrook Station, Boston Edison, l

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i d

! United States Nuclear Regulatory Commission April 14,1998 t

Attention: Mr. Morton Fairtile Page 4  ;

l l l and Northeast Utilities. The same organizations approved the change from YNSD to DE&S because the personnel, the processes, and the Quality Assurance Program have remained the same. For YAEC, the effectiveness of the control of quality by DE&S is assessed by YAEC l management oversight, sponsor audits, and Yankee Nuclear Safety Audit Review Committee reviews and evaluations. In addition, DE&S quality assurance services are assessed by the Joint Utility Management Audit (JUMA), and DE&S participates in the Joint Quality Group for approved vendor list activities and the l

Joint Quality Audit Group for audit activities. YAEC reviews the results of the Joint Utilities Management Audits of DE&S quality assurance activities. '

Request (d): Provide the rationale for concluding that the OA nrocram fynstions previously perfomied by YNSD. now performed by DE&S. continue to satisfy the nrovisions of YOOAP-1-A. Revision 27.

Answer: The contract betv'een YAEC and DE&S requires DE&S to conform to the requirements of YOQAP-1-A. Because the same personnel, policies, and I l procedures are involved, there will be minimal opportunity for deviation from the

Quality Assurance Program in the near future. However,in order to provide )

additional assurance of satisfactory quality program implementation and good contractor performance, the triennial audit scheduled for 1999 has been rescheduled for the third quarter of 1998. As noted previously, the President of YAEC continues to have the ultimate responsibility for assuring the satisfactory j implementation of the YOQAP-1-A. DE&S has been retained by YAEC to  !

provide quality assurance management, engineering, and administrative services.

All work performed by DE&S under the terms ofits contract with YAEC shall be

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l performed in accordance with YAEC's Quality Assurance Program.

Request (e): Identify any deviations from the nrovisions of YOOAP-1-A. Revision 27. for the 1 current imnlementation of the cuality assurance functions and a descrintion of any corrective action for any deviation (s) from thqprovisions of YOOAP-1-A.

Revision 27. that resulted from the nurchase of YNSD by DE&S.

Answer: No deviations from the provisions of the YOQAP-1-A were identified. DE&S has been retained by YAEC to provide certain project management, quality assurance, engineering support, procurement, and other related technical and administrative support services. As noted above, all work performed by DE&S under the terms ofits agreement with YAEC will be performed in accordance with the applicable YAEC programs and procedures including YOQAP-1-A. The

, overwhelming majority of the staff which will be providing these services will be t

i former YAEC employees who have accepted employment with DE&S. l l

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l l United State Nuclear Regulatory Commission April 14,1998 l A

' ttentibn: Mr. Morton Fairtile Page 5 l

l The YOQAP-1-A manual will be revised to eliminate all outdated references to YNSD. ~

j As you are aware, the quality assurance program YOQAP-1-A, Revision 27, is presently shared by YAEC and Vemiont Yankee Nuclear Power Corporation (VYNPC). YAEC and VYNPC are separate corporations. The arrangement whereby YAEC and VYNPC have shared the YOQAP-1-A has worked well for many years. It has pemlitted both organizations to benefit from efficiencies and cost savings with no detrimental effect on their abilities to satisfy their regulatory obligations and to protect the public health and safety. However, at this point in time YAEC and VYNPC havejointly detemiined that the needs and concems of an operating plant (Vermont Yankee Nuclear Power Station) and a plant in the later stages of decommissioning (Yankee Nuclear Power Station) are sufficiently different that it is appropriate for the two organizations to establish independent quality assurance programs. The VYNPC notification to the NRC of this decision is provided in Reference (f).

As noted previously, References (d) and (e) submitted a proposed Revision 28 to the j YOQAP-1-A. As the first step in effecting the establishment ofindependent YAEC and VYNPC quality assurance plans, YAEC is hereby withdrawing Revision 28. YAEC will issue a new Revision 28 to the YOQAP-1-A which will climinate all references to VYNPC/ VYNPS and which will delineate the YAEC decommissioning organization as noted in the response to request (a). This revision will be issued in the near future. .

We trust you will find this submittal satisfactory; however, should you desire additional infom1ation, please contact Walter K. Peterson at (978) 568-2877.

Very truly yours, YANKEE ATOMIC ELECTRIC vdMPANY

( M

% L- l Don K. Davis Chairman and Chief Executive Officer l

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