IR 05000271/1985022

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-271/85-22.Planned Actions,Including Review of safety-related Maint Requests for Jul-Dec 1984,will Be Examined in Future Insp

ML20138R545
Person / Time
Site:	Vermont Yankee
Issue date:	12/24/1985
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8512310356
Download: ML20138R545 (2)

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DEC 2 41985

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Docket No. 50-271 Vermont Yankee Nuclear Power Corporation i ATTN: Mr. Warren P. Murphy Vice President and Manager of Operations RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Gentlemen:

Subject: Inspection Report No. 50-271/85-22 This refers to your letter dated August 20, 1985, in response to our letter dated July 26, 1985.

Thank you for informing us of the corrective and preventive actions documented in your letter regarding the specific components (a core spray test switch and a main steam isolation valve power relay coil).

In addition, based upon a phone conversation between Mr. J. Johnson and Mr.

R. Milligan on September 17, 1985, it is our understanding that your planned actions also include a review of safety-related maintenance requests for the period July - December,1984 to confirm the proper application of safety classification. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

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cyd Stewart D. Eb eter, Director Division of Reactor Safety 8512310356 851224 PDR ADOCK 05000271 G PDR l

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i e OFFICIAL RECORD COPY RL VY 85-22 - 0001.0.0 09/25/85

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'i Vermont Yankee Nuclear Power Corp. -2-

I cc w/ encl:

Mr. R. W. Capstick, Licensing Engineer

. Mr. W. F. Conway, President and Chief Executive Officer

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Mr. J. P. Pelletier, Plant Manager Mr. Donald Hunter, Vice President Mr. Cort Richardson, Vermont Public l Interest Research Group, Inc.

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Public Document Room (PDR)

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Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Hampshire State of Vermont

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bcc w/ encl:

Region I Docket Room (with concurrences)

Senior Operations Officer (w/o encis)

Section Chief, DPRP M. McBride, SRI, Pilgrim H. Eichenholz, SRI, Yankee V. Rooney, LPM, NRR

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&Q RI:DRS s Johnson /kl. Bettenhausen Ebneter 9/ /85 /2/23 /85 74 hg /85 l 81l1Dl%%

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0FFICIAL RECORD COPY RL VY 85-22 - 0002.0.0 09/25/85 i

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, VERMONT YANKEE NUCLEAR POWER CORPORATION

- FVY 85-77

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RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 yg, y ENGINEERING OFFICE 1671 WORCESTER ROAO

FR AMIN GH A M, M ASS ACHUSETTS 01701 TRENONE 64472 W .

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August 20, 1985 _

U.S. Nuclear Regulatory Commission

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Office of Inspection & Enforcement Region I .

631 Park Avenue King of Prussia, PA 19406 Attention: Stewart D. Ebneter, Director Division of Reactor Safety References: a) License No. DPR-28 (Docket No. 50-271)

b) Letter, USNRC to VYNPC, dated 7/26/85 and Inspection Report No. 85-22, Appendix A (Notice of Violation)

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Dear Sir:

Subject: Response to Inspection Report No. 85-22 This letter is written in response to Reference b), which indicates that one of our activities was not conducted in full compliance with Nuclear l Regulatory Commission requirements. This alleged Level V violation was iden-tified es a result of an inspection conducted by your Mr. J. Johnson during the period of June 3-12, 1985.

Information is submitted as follows in answer to the alleged violation con-tained in the Appendix to your letter.

ITEM: 10 CFR, Appendix B, Criterion IV, requires measures to assure that requirements necessary to assure adequate quality are included in pro-curement documents. Criterion VIII further requires measures to control parts and components to prevent the use of incorrect or defec-tive material.

Section IV of the Yankee Operational Quality Assurance Manual, YOQAP-1-A, Rev. 15, and Sections VII and VIII of YAEC Operating Guideline No. 1, Rev. 7, require traceability of the identification of parts to drawings, specifications, purchase orders and documented verification prior to release for use. Small spare parts with no tra-ceability (as specified in Appendix C to YOQAP-1-A) must be qualified for use. Procedure AP 0800, Rev. 11, specifies that material requiring quality assurance be ordered with Appendix A, " Quality Assurance Requirements" included. Procedure AP 0310, Rev. O, alter-nately specifies that if off-the-shelf parts are used rather than tra-ceable parts, a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> burn-in period is required for qualification testing.

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VERMONT YANKEE NUCLEAR POWER CORPORATION

U.S. Nuclear Regulatory Commission August 20, 1985 Page 2

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Contrary to the above, as of June 10, 1985, two parts designated as safety related on the Safety Related Class IE Instrument List were

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purchased and installed without having Appendix A to AP 0800, " Quality Assurance Requirements" included in the procurement documents, nor documented verification of traceability of the parts, nor alternative qualification testing performed prior to return to service. These parts had minimal safety significance.

RESPONSE:

On February 6, 1985, a non-safety related switch was issued erroneously to a safety related MR (85-256) on Material Issue Slip #02A0042. The part wt correctly labeled with a non-safety related tag. The Material Issue Slip was incorrectly written leading to the issuance of a component of the wrong classification. It was determined that the switch is acceptable "as is" since the new switch was verified to be identical to the switch that was replaced and that the newly installed switch has been subjected to a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> operational test and a satisfactory resistance check.

On June 12, 1985, a Non-Conformance Report was generated in order to eva-luate and disposition a MSIV coil replacement accomplished by a safety-related MR (85-986). The part was correctly labeled with a non-safety related tag, however, at the time of issuance the Stores Clerk failed to recognize that the material was identified (tagged) as non-safety related.

The part was issued as documented by Material Issue Slip #05A0137 and was the component requested by part number and description. It was determined that the coil is acceptable "as is" since the new coil was verified to be identical to the coil that was replaced and that the newly installed coil has been subjected to a 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> operational test (measured coil voltage and verification of energized coil), which provides the required qualifica-tion in accordance with our quality assurance manual (VYOQAP-1A).

Because of these events, a step was added to the Issuing and Returning of Parts, Materials, and Components procedure, AP 0806, which states that the Stores Clerk, when issuing safety-related materials will verify that the item is properly identified and marked with a "P" tag in accordance with AP 0802, " Identification and Control of Materials, Parts and Components".

This will ensure safety-related materials are being issued for safety-related applications. It should be noted that the above types of parts are referenced under the QA Topical Report YOQAP-1-A, Appendix C, page 8, paragraph V.2, as acceptable for use in safety class systems after being qualified.

In addition to the corrective actions detailed above, Procedure AP 0806 was revised and issued on July 30, 1985 to incorporate a checkoff box on the Material Issue and Material Return form indicating that the materials being requested are applicable to either safety or non-safety work efforts.

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VEllMONT YANKEE NUCLEAR POWEll COllPOllATION h

U.S. Nuclear Regulatory Commission August 20, 1985 Page 3

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Additionally,-Stores personnel have been instructed to issue only safety-related materials for safety-related work efforts, unless an approved Non-Conformance Report is generated.

We consider the above actions adequate to prevent recurrence of this event and to achieve full compliance.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION I

W r?+vu_ un Warren P.fMurphy Vice President and Manager of Operations

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