ML20133F829

Ack Receipt of 850524 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-271/85-06. Corrective Actions Reviewed in Insp Rept 50-271/85-22 Acceptable

ML20133F829
Person / Time
Site:	Vermont Yankee
Issue date:	07/26/1985
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8508080454
Download: ML20133F829 (1)

See also: IR 05000271/1985022

Text

, _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

'

. i ,

JUL 2 61985

4

Docket No. 50-271

i Vermont Yankee Nuclear Power Corporation

ATTN: Mr. Warren P. Murphy

Vice President and Manager

l of Operations

! RD 5, Box 169

Ferry Road

l

Brattleboro, Vermont 05301

Gentlemen:

'

Subject: Inspection Report No. 50-271/85-06

This refers to your letter dated May 24, 1985, in response to our letter

,

dated April 16, 1985.

2

I

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

in your letter. These actions were reviewed during an NRC Inspection 50-271/

85-22 conducted on June 3-12, 1985, and found acceptable.

Your cooperation with us is appreciated.

Sincerely,

Original Signed By:

Lee H. Hettenhauson

tewart D. Ebneter, Director

Division of Reactor Safety

,

cc:

R. W. Capstick, Licensing Engineer

W. F. Conway, President and Chief Executive Officer

J. P. Pelletier, Plant Manager

D. Hunter, Vice President

C. Richardson, Vermont Public Interest Research Group, Inc.

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of New Hampshire

State of Vermont

Region I Docket Room (with concurrences)

DRP Sectio Chief

RI D RI:DRS

bRI:DRS RI:DRS

&-

k

P 1, Johnson Bettenhausen Ebneter p/D

) fvj.6/2YM OFFICIA COPY y R 85-06 - 0001.0.0

)I

8508080454 e50726

PDR

0 ADOCK 05000271

PDR

-

, ,

VERMONT YANKEE

NUCLEAR POWER CORPORATION

-

FVY 85-50

.

RD 5. Box 169. Ferry Road Brattleboro, VT 05301 ,,, g

g ENGINEERING OFFICE

1671 WORCESTER ROAD

,

= FR AMINGHAM. MASSACHUSETTS 01701

- **

May 24, 1985

U.S. Nuclear Regulatory Commission

Office of Inspection & Enforcement

Region I

631 Park Avenue

King of Prussia, PA 19406

Attention: Mr. Stewart D. Ebneter, Director

Division of Reactor Safety

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

, b) Letter, USNRC to VYNPC, Inspection Report No. 50-271/85-06,

dated 4/16/85

Dear Sir:

Subject: Response to I&E Inspection Report 50-271/85-06

This letter is written in response to Reference b) which indicates that

some of our activities concerning corrective actions were not conducted in full

compliance with Nuclear Regulatory Commission requirements. The alleged Sever-

ity Level IV violation was cited during an inspection conducted January 28 -

February 1, 1985 by your Mr. J. Prell at Vermont Yankee Nuclear Power Station in

Vernon, Vermont. Information is submitted in the following paragraphs in answer

to the alleged Severity Level IV violation.

FINDING

As a result of the inspection conducted on January 28-February 1, 1985, and

in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the

following violation was identified:

Criterion XVI of 10 CFR 50 Appendix B states in part " Measures shall be

established to assure that conditions adverse to quality...are promptly...

corrected."

Section XVI.C.1 of the Yankee Operational Quality Assurance Program I-A

states in part:

" Satisfaction of this criterion (Criterion XVI of 10 CFR 50, Appendix

B) shall be assured through the implementation of... actions listed

below:

N/ d o r/ m i rf

p yvuya M

. Y PP-

'

, , .

VERMONT YANKEE NUCLEAR POWER CORPORATION

>

U.S. Nuclear Regulatory Commission

May 24, 1985

Page 2

a. Initiation of corrective action following the determination of a

condition adverse to quality to preclude recurrence.

b. Follow-up reviews to verify proper implementation of corrective

actions and to close out the corrective action documentation...."

Contrary to the above, as of February 1, 1985, the initiations and follow-

up reviews of corrective actions following the determination of an adequate

biennial ~ plant procedure review program, by NRC in 1980 (Report No.

50-271/80-19) and by the licensee's QA audits in 1983 and 1984 (Audit Nos.

83-01, 84-01, 84-02 and 84-13), were inadequate. As a result, sixty five

VYNPS procedures, identified in paragraph 3.5 of the enclosed report,

remain unreviewed for periods up to seventeen months beyond their required

bienniel review dates.

This is a Severity Level IV violation (10 CFR 2, Appendix C, Supplement I).

RESPONSE

ehr agree with the inspector's finding on this item. The number of proce-

dures beyond their review date is and has been an ongoing concern to Vermont

Yankee. Corrective actions following the 1980 NRC audit were intiated and imple-

mented. Follow-up reviews were conducted and additional changes made to improve

the process. In 1984, reviews of the status of overdue procedures identified a

need for further corrective action.

' During 1984, changes were made to Administrative Procedure AP 0831, Plant

Procedures, to streamline the procedure review process and further enhancements

to the procedure tracking system were implemented. Personnel performance goals

were established to reduce the procedure backlog and maintain it at a low level.

As can be seen from the attached Figure, these measures have been effective. To

further enhance this process and ensure the backlog remains low, the following

~

changes will be made immediately. The procedure changes will be implemented by

September 1, 1985.

1. AP 0831 will be revised to require additional management attention for

all procedures which exceed their review date. For each procedure

exceeding its review date by more than 3 nonths, the Plant Operations

Review Committee will review the siti'at .an

. and recommend action to the

Plant Manager.

• *

, . ,

VEitMONT YANKEE NUCLEAR POWER CORPORATION

U.S. Nuclear Regulatory Commission

May 24, 1985

Page 3

2. AP 0831 will be revised to clearly state individuals' responsibility in

meeting procedure review dates and in expediting addressing procedures

beyond their review date.

Contained in the Notice of Violation are references to findings by our QA

Audit Program. These findings were directed toward problems in the timely

incorporation into procedures of temporary changes (Department Instructions).

The procedure which controls these changes, AP 0832, Department Instructions,

has been modified a number of times to streamline this process. The most recent

change was in November 1984 and results show it to be effective.

On a semi-annual basis, our QA group will conduct audits of AP 0831 and AP

0832 to ensure these changes effectively result in either no backlog or complete

justification for overdue procedures. These audits will continue for at least

two years.

We conclude that the corrective action committed to herein is sufficient to

assure that the violation cited will not be repeated and that the safe and effi-

cient operation of Vermont Yankee will continue.

Appendix A to Inspection Report 85-05 requires that a reply to the subject

violation be submitted within 30 days of transmittal. Please note that a 10-day

extension of this period has been granted by the NRC Resident Inspector.

Very truly yours,

VERMONT YANKEE NUCLEAR POWER CORPORATION

q

arren P. Murphy

Vice President and

Manager of Operations

-

WPM /dm

4 6 h h

1 200RES 3AS" M:N JA"]

150

140 --

130 -

120 -

110 -

3 100 -

-

2

p 90 -

0

y80-

0

% 70 -

4 2

'

g 60 -

0 ,

" "

3

50 - ,

~

40

.

'

30 - ,

'

20 -- ,

.

A

'

.

0,,,,,,,,,,,,,,,,,, ,,,,,,,

OCT NOV DEC JAN TEB MAR FR MAY

OCT 1984 - MAY 1985

0 TOTALOVERDUE + >6MONODUE o >3 MON ODUE

i

,

L _