ML20247Q642

Responds to NRC Re Violations Noted in Insp Rept 50-029/88-22.Corrective Actions:Mod to Original Engineering Design Change & Evaluation of Engineering Deficiency Performed W/Actions Specific to Prevent Recurrence

ML20247Q642
Person / Time
Site:	Yankee Rowe
Issue date:	03/31/1989
From:	Drawbridge B YANKEE ATOMIC ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BYR-89-62, NUDOCS 8904070178
Download: ML20247Q642 (4)

Text

~

. r o

'% l YANKEE ATOMICELECTRIC COMPANY "'%"',?g"go"f,*g" 7 '

- p.

.YAN hI.

KEM 580 Main Street, Bolton, Massachusetts 01740-1398

~ -.

i March 31, 1989 BYR 89-62 ,,

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

References:

(a) License No. DPR-3 (Docket No. 50-29) 1 (b) Letter, USNRC to YAEC, dated March 2, 1989

Subject:

Reply to Notice of Violation l

Dear Sir:

1 Reference (b), Inspection Report 50-29/88-22, documents a routine NRC

! Resident Safety Inspection conducted by Messrs H. Eichenholz and M. Markley on November 15, 1988 through January 17, 1989, at the Yankee Nuclear Power l l Station, Rowe, Massachusetts. The report identifies two activities that were not conducted in full compliance with the NRC requirements. These activities l

were identified as violations. In accordance with 10CFR2.201, we hereby submit the following information l

The first violation (Severity Level IV) is restated from Reference-(b) as follows:

Violation A 10CFR20.203(c)(1), requires, in part, that each high radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words " Caution" or " Danger, High Radiation Area".

Contrary to the above, on January 7, 1989, a high radiation area in the shield tank cavity in the Vapor Container (VC) was not conspicuously posted with a sign or signs bearing the radiation caution symbol, and the words " Caution" or " Danger, High Radiation Area" as required.

Response

As discussed in Reference (b), "no response to' Violation A is required because immediate corrective actions and actions to preclude recurrence were both timely and adequate."

l l

'8904070178 890331 PDR o

ADOCK 05000029 PDC

i. / i 1 6

' United States Nuclear Regulatory Commission March 31, 1989 Attention: Document Control Desk Page 2 BYR 89-62 As noted in Reference (b), the posted condition problem had existed for only fifteen minutes prior to identification by the inspector.

The second violation (Severity Level V) is restated from Reference (b) as follows:

Violation B 10CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures shall be established to assure that the identification, the cause, and corrective action taken to preclude repetition of significant conditions adverse to quality are documented and reported to appropriate levels of l management.

Yankee Atomic Electric Company (YAEC) Operational Quality Assurance Manual,Section XVI requires that the Nuclear Services Division (NSD)

Quality Assurance (QA) Department shall be responsible for review of recommendations to prevent recurrence of significant conditions adverse to quality, and that the NSD Engineering and/or Project Departments shall be responsible for review of conditions adverse to quality which involve design deficiencies to determine the cause of the condition, and provide i recommendations of corrective action to preclude repetition of design deficiencies.

l However, contrary to 10CFR50, Appendix B, Criterion XVI, the licencee l failed to establish effective measures, in the form of clear procedures, to translate corrective action requirements for the proper documentation, and reporting to appropriate levels of management of significant conditions adverse to quality involving design deficiencies, in that, existing administrative controls did not provide: (1) that the QA Department be responsible for review of recommendations to prevent recurrence, and (2) that Engineering and/or Project Departments be responsible for review and determination of cause, and provide recommendations for corrective action to preclude repetition.

Response

We concur with the Notice of Violation as described above and in Reference (b).

The YAEC NSD procedures to control engineering activities at NSD are contained in the Engineering Manual. The Engineering Manual Procedure No. WE-001, " Administration of the Engineering Manual," directs reporting of deficiencies or nonconformances to be reported to management. WE-001 directs that the method for reporting shall be in accordance with Engineering Manual Procedure No. WE-005, " Standard Memorandum".

The Yankee Operational QA Program as defined in YOQAP-1-A,Section XVI, Corrective Action, requires that "the NSD QA Department shall be responsible for review of recommendations to prevent recurrence of significant conditions adverse to quality."

l o

e. -

United States Nuclear Regulatory Commission March 31, 1989 Attention: Document Control Desk Page 3 BYR 89-62 The procedures, WE-001 and WE-005, do address corrective actions, l however, they do not clearly require the inline review of the corrective action recommendations by the QA Department.

Corrective _Ac.tions_Taken )

1. The original engineering deficiency as discussed in Reference (b) was corrected by a modification to the original Engineering Design Change.

l

2. An evaluation of the engineering deficiency was performed with I corrective actions specified to prevent recurrence. The evaluation )

and corrective actions were sent to the NSD Director of QA.

3. A new Procedure, WE-109, " Engineering Deficiency Reports," has been developed and issued to clarify the review of engineering deficiencies. Training on WE-109 has been provided to the NSD Engineering staff.

4. Engineering Manual Procedure WE-100, " Engineering Design Change Request," is in the process of a major revision. Modifications to WE-100 will be made to provide additional procedural improvements.

This revision is expected to be completed by September 1, 1989.

i

5. A review of revisions to design changes for the last two years are l being performed to determine if engineering deficiencies were responsible for the revisions. A similar review and determination will be made for calculation revisions that were performed in the last year. These reviews are nearly complete. The results to date indicate that engineering deficiencies have not been the reason for those revisions. Completion of the above reviews is expected by May 1, 1989.

Actions _to_freclude_Returrence

1. The new Engineering Procedure WE-109, Engineering Deficiency Reports, has been issued to assure that any engineering deficiencies are identified, evaluated, and corrective actions taken to preclude recurrence. The procedure assures that reporting is made to the appropriate levels of management including the QA Department.

2. Initial training on WE-109 has been completed. Training will be provided annually on any changes to WE-109 in the future. New employees performing design activities will review WE-109 as a part of their Indoctrination Training.

w--___-_--------------_- - - _ _ - _ - _ _ _ _ - - -

e.

• United States Nuclear Regulatory Commission March 31, 1989 Attention: Document Control Desk Page 4 BYR 89-62 Date of Full Compliance Full compliance was achieved when KE-109 was issued on March 27, 1989.

If you have any questions or desire additional information, please contact us.

Very truly yours, s YANKEE ATOMIC ELECT C COMPANY L~~~. s

,, g, /:g;, /5 S Bruce L. Drawb' ridge Vice President and Manager of Operations BLD/bil/0278v cc: USNRC Region I USNRC Resident Inspector, YNPS William V. Johnston Acting Director, Division of Reactor Safety USNRC Region I l

l

___.