ML20246K637

Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Insp Rept 50-271/89-80

ML20246K637
Person / Time
Site:	Vermont Yankee
Issue date:	08/23/1989
From:	Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8909060025
Download: ML20246K637 (2)

See also: IR 05000271/1989080

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AUG 2 3.1989

Docket No. 50-271:<

Vermont.. Yankee Nuclear Power Corporation

' AYTN: < Mr. Warren P.< Murphy -

Vice President and Manager

of Operations

'RD 5, Box 169-

-- Ferry Road

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'Brattleboro, Vermont 05301- ~

Gentlemen:

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Subject: . Inspection No. 50-271/89-80

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This refers to your letter dated June 30 1989, in response to our letter

dated June 2,'1989.z

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Thank you for informing us of ~ the corrective and preventive actions documented

in your. letter. ~ These- actions will examined during a future inspection 'of

.yourJ11 M sed program.

1Your cooperation with us.-is appreciated.

Sincerely,;

, ,

original Signed By:

Clirtc ~! ,7. 6krm

Jacque P. Ourr, Chief

Engineering Branch

Division'of Reactor Safety

cc: w/ enc 1: '

'J. Weigand,l President and Chief Executive Officer

J.- Pelletier, Plant Manager

J. DeVincentis, Vice President, Yankee Atomic Electric Company

R. Capstick,' Licensing Engineer, Yankee Atomic Electric Company

.J. Gilroy,: Director,-Vermont Public Interest Research Group, Inc.

G.'Sterzinger, Commissioner, Vermont Department of Public Service

P. Agnes, Assistant Secretary of Public Safety, Commonwealth of

Massachusetts-

Public Document Roorr ..iDR)

' Local.Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident: Inspector

State'of.New Hampshire

State of Vermont

. Commonwealth of Massachusetts

. Vermont Yankee Hearing Service List

OFFICIAL RECORD COPY RL VY 89-80 - 0001.0.0

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[ ' YERMONT YANKEE

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1 NUCLEAR POWER. CORPORATION

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Ferry Road Brattleboro, VT 05301-7002

/ ENGINEERING OFFICE

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580 MAIN STREET

BOLTON tAA 01740

f!>08) 779 6711

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June 30, 1989

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

Attention: Document Control Desk

References: a) License No. OPR-28 (Docket No. 50-271)

b) Letter, USNRC to VYNPC, NVY 89-126, Inspection Report 89-80,

Notice of Violation, dated 6/2/89

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 torque 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

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.

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" June 30, 1989

Page 2

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C. Licensee procedure AP 0201, Section 6.8 requires that any.

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tools removed from the tool area be logged by=the tool

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attendant on MT&E. sign-out sheet VYAPF 0201.01. . However,

-from February 27 to March 10, 1989,-three "Hytorc" wrenches

L-2176, 2177 and 2178 designated on the;11st as being out of

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service for calibration did not have. supporting documen-

1tation on MT&E sign out sheets VYAPF 0210.01- maintained ir.

, the tool room.

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This-isLa Severity Level V violation.

RESPONSE

'

In order to correct the deficiencies identified during the. inspection,

g . Vermont Yankee instituted the=following actions to address each issue:

,

7A. Immediate corrective actions. initiated at the' time of the NRC Maintenance

l Team: Inspection were to review procedure AP 0201 and associated forms used

.

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in-the tool room. This deview was initiated to verify the current revision

ofjthe procedure and associated forms were being used. Any old revisions.

or outdated forms.found were removed.and destroyed and replaced with

3currentleevisions. Any forms with data recorded on them were collected and'

U sent.to document control for retention.- A search was conducted to address

-potential use offoutdated forms.in other areas of'the department. Some

iadditional outdated forms were found, nii.d-destroyed. Personnel were

1 reminded.that any unused' forms must either be returned to the control file

a. ..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, E 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 Ysnkee also recognizes that this item could also pertain to more

than.the Maintenance Department. 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. Subsequeat to the identification of torque wrenches not having labels iden-

tifying tue 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 attritwted to the possibi-

lity of the labels being dislodged during cleaning. In order to reduce the

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VERMONT YANKEE NUCLEAR POWER CORPCf4ATION

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U.S. Nuclear ~ Regulatory Commission

June 30, 1989-

Page 3

potential for the labels from separating from the equipment during use or

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 I, 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.

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

to this potential.

-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.

In sup> mary, we agree with the findings and attribute'"the failure to follow

procedures" to the lack of attention to detail. These issues have been iden- 'l

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

have questions or desire additional information, please do not hesitate to con-

tact us.

Very truly yours,

VERMONT YANKEE NUCLEAR POWER CORPORATION

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Presi e

Manager of Operations

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cc: USNRC Regional Administrator, Region I

USNRC Resident Inspector, VYNPS

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