IR 05000271/1988005

Ack Receipt of 880826 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-271/88-05

ML20154J928
Person / Time
Site:	Vermont Yankee
Issue date:	09/16/1988
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8809230180
Download: ML20154J928 (2)

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SEP 161989 Docket No. 50-271 Vermont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy Vice President and Manager of Operations  !

RD 5, Box 169 l Ferry Road Brattleboro, Vermont 05301  :

Gentlemen:

Subject: Inspection 50-271/88-05 This refers to your letter dated August 26, 1988, in response to our letter dated June 21, 1988.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of ,

your licensed ptagram. [

Your cooperation with us is appreciated. '

Sincerely, 3 ORIGINAL SIGNED BY

) WILLIAM V. JOHNSTON t

Thomas T. Martin, Director t Division of Reactor Safety

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cc w/ encl:  !

J. Weigand, 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, 01ractor, 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 Room (POR) .

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Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector j State of New Hampshire State of Vermont  :

Commonwealth of Massachusetts r

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0FFICIAL RECORD COPY RL VY 88-05 - 0001,0.0 09/14/S8 8009030100 000916 POR ADOCK 05000071 O PNV

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Region I Docket Room (with concurrences)

MrPeiki65, "e6e;eme6 Anhtent r-ORMA-(*/o-enel-)

D. Haverkamp, Section Chief, ORP G. Grant, SRI - Vermont Yankee (w/ concurrences)

H. Eichenholz, SRI - Yankee V. Rooney, PM, NRR R. Bores, Technical Assistant, DRSS K. Abraham, PA0 (12) (sal.P Reports Only)

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CIA RI:DAS Anderson /pmb/rw 9//f/88 0FFICIAL RECORD COPY RL VY 88-05 - 0002.0.0 09/14/88

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.,, VERMONT YANKEE

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NUCLEAR POWER CORPORATION FVY 88-69

. x RD 5 boa 169, Ferry Road Brattleboro.VT 05301 , ,,

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ENGINEERING OrFICE 1671 WORCESTER AOAo

• F R ALHNG H AM. M ASS ACHUSETT S 01 T01

. estin o e...r wo August 26, 1988 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk References: a) License No. OPR-28 (Docket No. 50-271)

b) Letter, USNRC to VYNFC, NVY 88 114, Inspect le Report No. 50-271/88-05, dated 6/21/81 Dear Sir Subject: 9esponse to Inspection Report No. 50-271/88-05 This letter is written in response to Heferente b), which characterites some of your findings as program weaknesses. These items were identified as a result of a safety Assessment Team :nspection conducted by Mr. C. Andersc,n on April 4-8, 1988, at Vermont Yankee Nuclear Power Staticn, Vernon, Vermont, and Yankee Atomic Electric Company, Framingham, Massachusetts.

Information is submitted as follows with regard to corrective actions taken and/or planned for items identified as program weaknesses.

ITEM _1 The respirator program does not require oenetration testing of respirator filter cartridges prior to ute.

Response The concerns identified by the inspector regarding the testing performed on filter cartridges for respirators have been addressed. Based on the information in the Inspection Report and subsequent telephone conversation clarifications with Mr. R. Loesch of t'.ie NRC, Plant Procedure AP 0505, "Respir. tory Protection",

, was revised. This revision includes a differential pressure test for filter canisters with an upper and lower limit and a filter efficiency ?est on par-ticulate filters. The procedure revision also prohibits the re-use of charcoat canisters. These implemented changes are responsive to the concerns identified in the Inspection Report and will verify the integrity of reused filter units.

l ITEM 2 Tnere is a lack of aggressiveness to address deficiencies in pro-cedures in the Radiation Protection Area.

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U.S. Nuclear Regulatory Commission '

August 26, 1988 '

Page 2

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Rgsponse This Inspection Report identifies our deliberateness in developing and ,

implementing a hot particle procedure as an indicati of a lack of aggressive. ,

ness to implement corrective action. We agtee that it has taken soma exttnded t period of time to generate a final product since we made the cotsmitment at i Vermont Yankee /USNRC meeting held at Region I Headquarters in July 1987.

However, it should be pointed out that several activities were ongoing during  :

that tims frame, including the evaluation of other utilities programs, deve- t loping a hot particle / skin dose correlation, and assessing Vermont Yankee sDeci-fic data. These efforts allowed us to establish conversion factors er the RM-14 and the R0-2 to assess potential skin dose problems quickly. Once completed, ir.terim guidance was issued to Radiation Protection Department per- '

sonnel incorporating all that had been learned. All significant skin con- '

teminations that have occurred during this period were assessed using the practice described above and the Varskin computer cois. The dose that was the most conservative was assigned to the exposure recced. r The interim guidance has been replaced by plant procedure AP 0520 which was issued on August 4, 1988. This procedure formally establishes the skin dose assessment methodology used at Vermont Yankee. The procedure that addresses additional hot particle administrative controls has been drafted and will be ,

introduced into the review cycle shortly: it is expected that this procedure  ;

will be issued before November 1, 1988.

It should be pointed out that we have not had a significant hot carticle problem at Vermont Yankee, however, should we get into a situation where a hot

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particle problem is anticipated prior to finalization of the remaining proce-dure, we will proactively apply the necessary actions and management controls.

It has always been Vermont Yankee's policy to address issues requiring ,

corrective action in a timely manner with careful consideration of priority and available resources. We recognize that there is always room far imprevement and i therefore do not take your comments lightly. We have ir,et 'tuted a nuceer of ,

improvements, including procedure improvements, tracking " commitmer.ts and ,

development of complote documentation packages to close est commitments. Wo would be more than happy to review these process changes and other issues iden- t tified in the Inspection Report with the NRC inspector during his next visit to the site. [

) ITEM 3 There is a olant staff over reliance on surveillance orocedures to satisfy Technical Snecification reouirements without '

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recognizing their responsibility to identify and correct ?roce-dural inconsistenctes. ,

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U.S. Nuclear Regulatory Commission i August ?S, 1988 l Page 3 l

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l Response l The Ir.spection Report indicated that a number of initt 4 have oeen taken by Vermont Yankee to address this area. Improvement' being made to AP 4000, the Surveillance Program procedure, to provide a cit. . . - link between Technical Specification requirements, the surveillance list and the implementing procedures. Vermont Yankee will perform an independent review of the Technical Specifications and the. surveillance list to ensure the list is complete. This review will also verify the exi7tence of an implementing procedure.

Additionally, the surveillance list will be computerized, which will allow for stringent control of revisions to the list.

Our orogram is based on the philosophy that surveillance procedures should be written such that successful completion of the procedure ensures the Technical Specification requicement has been met. The enhancem nts planned will provide additional assurance that this is the case.

I_T_EM 4 Inadequate supporting bases for 10 CFR50.59 reviews.

Response Vermont Yankee has recognized the need to improve written support for 10 CFR 50.59 reviews. Additional training for appropriate personnel has been provided and further training is planned. The need to specifically address the criteria of 10 CFR 50.59 with tupporting technical rationale is being emphasized tv. all those performing safety evaluations. Plant menagement is giving this area add 4' onal attention (including conducting the training) to ensure the desired improveme 's are achieved. The need to generate a proceduce or other v uidance documen,s for performing 10 CFR 50.59 evaluations is being pursued by --

l Vermont Yankee management.

l l We trust that this information is satisfactory; however, should you have any questions or desire further information, please do not hesitate to contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION I

l' ism >N,-,

Warren P. Murphy Vice President and /

Manager of Operatihns d

/dm cc William V. Johnston. R gion !

USNRC Regional Administrator, Region !

USNRC Resident Inspector, YYNPC