ML20245K312
| ML20245K312 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/30/1989 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-89-58, NUDOCS 8907050090 | |
| Download: ML20245K312 (3) | |
Text
s _..
-V, ERMONT YANKEE NUCLEAR POWER CORPORATION BVY 89-58
~s Ferry Road, Brattleboro, VT 05301-7002 ENGINEERING OFFICE N
v-580 MAIN STREET DOLTON. MA 01740 '
(500)779 6711 June 30, 1989 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Document Control Desk
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, NVY 89-126, Inspection Report 83-80, Notice of Violation, dated 6/2/89 l
Dear Sir:
Subject:
Response to Inspection Report 89-80, Notice of Violation During a special maintenance team inspection between February 27 and March 10, 1989 [ Reference b)], a violation of NRC requirements was identified.
The following provides Vermont Yankee's response to that Notice of Violation.
VIOLATION 10 CFR 50, Appendix B, Criterion V, states in part, that
" Activities affecting quality shall be accomplished in accordance with instructions, procedures or drawings."
Contrary to the above, the following examples of failure to follow procedure were identified:
A.
Licensee procedure number AP 6805, Section 3C requires that old procedure data sheets and forms be destroyed when a new revision to the applicable procedure is issued. However, on March 6, 1989, Revision 7 of Form 0201.03 (Calibration Data Sheet) of Procedure AP 0201 was observed to contain the calibration data for terque wrench number VY #5115 recorded on February 21, 1989. Revision 8 to procedure AP 0201 and form 0201.03 was issued on February 9, 1989, prior to the i
calibration of wrench number VY 5115.
B.
Licensee procedure number AP 0201, Appendix A, Section 1.2 requires that all torque wrenches are to be clearly labeled with "CW" and/or "CCW" to indicate which direction-(clockwise and/or counterclockwise) the wrench is calibra-ted. From February 27 to March 10, 1989, no torque wrench observed in the tool room, and none observed in use in the plant had the required labeling to indicate the applicable direction of calibration, j
I Q9't/C3609*> 690600
/t rOR ADOCK 05000271 Q
PDC l0
VERMONT YANKEE NUCLEAR POWER CORPORATION
./
U.S. Nuclear Regulatory Commission j
June 30, 1989
{
Page 2
]
C.
Licensee procedure AP 0201, Section 6.8 requires that any tools removed from the tool area be logged by the tool l
attendant on MT&E sign-out sheet VYAPF 0201.01. However, I
from February 27 to March 10, 1989, three "Hytorc" wrenches L-2176, 2177 and 2178 designated on the list as being out of service for calibration did not have supporting documen-tation on MT&E sign out sheets VYAPF 0210.01 maintained in the tool room.
This is a Severity Level V violation.
j
RESPONSE
In order to correct the deficiencies identified during the inspection, Vermont Yankee instituted the following actions to address each issue:
A.
Immediate corrective actions initiated at the time of the NRC Maintenance Team Inspection were to review procedure AP 0201 and associated forms used in the tool room. This review was initiated to verify the current revision of the procedure and associated forms were being used. Any old revisions or outdated forms found were removed and destroyed and replaced with I
current revisions. Any forms with data recorded on them were collected and sent to document control for retention. A search was conducted to address potential use of outdated forms in other areas of the department. Some additional outdated forms were found, and destroyed.
Personnel were reminded that any unused forms must either be returned to the control file or destroyed.
To insure that the corrective action is permanent to this issue, the department internal program for notification of the issuance of new proce-dure revisions has been updated as of June 23, 1989, to include on the transmittal form, a notice to the users to review their current work in progress for the use of the affected procedure and the need to obtain new copies of the document and associated forms.
Additionally, a new revision to AP 0201 has been drafted, which more clearly assigns the responsibility for the MT&E program to a management level position in the Maintenance Department.
This new revision was issued June 27, 1989.
Vermont Yankee also recognizes that this item could also pertain to more than the Maintenance Depsrtment. All other plant departments have been requested to review their files and determine if this problem exists and perform appropriate corrective actions by September 1, 1989.
B.
Subsequent to the identification of torque wrenches not having labels iden-tifying the direction, i.e.,
clockwise or counterclockwise, in which it was calibrated, all such equipment was retrieved, rechecked and labeled.
It was identified that part of this problem may be attributed to the possibi-lity of the labels being dislodged during cleaning.
In order to reduce the
e VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission June 30, 1989 Page 3 potential for the labels from separating from the equipment during use or i
in the decontamination process, clear tape was placed over the label in a manner which would require a deliberate effort to remove. This effort was completed as of April 1, 1989.
A revision of.AP 0201,' Appendix A, has been drafted to more clearly define the labeling of torque wrenches in regard to the calibration direction, and-was issued June 27, 1989.
l I
C.
The wrenches in question, because of the size, were stored remotely from the main tool area. The equipment consists of a hydraulic pump, connection hoses and a special wrench head, all of which must be used together in order to calibrate the unit. To prevent a recurrence of this deficiency, the special wrench heads for this equipment have been placed in the main tool room to insure the tool room attendant is aware when this equipment is to be used or out of. service for calibration and log it according to the requirements of AP 0201.
Based on a review, no other equipment is subject j
to this potential.
(
1 The draft revision to procedure AP 0201 now includes a clear statement of the importance for.the Measuring and Test Equipment Sign-Out Sheet (VYAPF
)
0201.01), and of recording the status of all equipment in the MT&E program.
I In summary, we agree with the findings and attribute "the' failure to follow procedures" to the lack of attention to detail.
These issues have been iden-tified and discussed with the Maintenance Department supervision by the Department Manager, and will continue to be stressed as a high priority in the conduct of department operation.
We believe that the corrective measures identified above address the viola-tion and we trust that the information provided is acceptable.
If, however, you d
have questions or desire additional information, please do not hesitate to con-tact us.
i Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION l
n.
p Warren P Murphy Vice President a j
Manager of Operations
/dm cc:
USNRC Regional Administrator, Region I USNRC Resident Inspector, VYNPS l
_-__ - - -