IR 05000029/1981019
| ML20039E304 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 11/25/1981 |
| From: | Blumberg N, Caphton D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20039E301 | List: |
| References | |
| 50-029-81-19, 50-29-81-19, NUDOCS 8201070132 | |
| Download: ML20039E304 (10) | |
Text
{{#Wiki_filter:__ . _.
_ _ _. - _ _ . _ . _ _ _ _ _ , '
?..
e ' U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT , a, Region I i ' Report No.
50-29/81-19 Docket No.
50-29 License No.
DPR-3 Priority Category C --
Licensee: Yankee Atomic Electric Company .. 1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Yankee Nuclear Power Station (Yankee-Rowe) Inspection at: Rowe, Massachusetts , ' Inspection co'nducted: November 3-6, 1981 . Inspectors: ' // g / NormanNr.' Bl umberg,' date signed ~ Reactor Insp cto ' Approved by: 4: MB/ [[ D. L. Capht'an, Chief, dhte s'igned Management Programs Section. Engineering , ' Inspection Branch Inspection Summary: Inspection on November 3-6, 1981 (Report No. 50-29/81-19_1 Areas Inspected: Routine, unannounced inspection by one region-based inspector of licensee action on previous inspection findings; administra-tive controls for surveillance tests and calibrations; Technical Speci-i fication calibrations; calibrations of safety related instruments which > I verify Technical Specificat1on surveillance test 5, Technical Speci-fication surveillance tests; and calibration ano control of measuring
and. test equipment. This inspection involved 27 inspector-hours onsite by cne region-based inspector.
Results: (Violation - Failure to use approved procedures for the calibration of ! instruments which are used to verify Technical Specification surveillance requirements).
I
l , f i 82Gic?0132 811223 PDR ADDCK 05000029 G PDR . .. . -. . .. ..-. .
. . DETAILS 1.
Persons Contacted R. Aron Operations Technical Assistant H. Autto Plant Superintendent R. Boutwell Technical Assistant " B. Darcy Instrument and Control (I&C) Foreman B. Drawbridge Technical Director N. Fetherston Operational Quality Assurance
L. French Technical Assistant
K. Jurentkuff Assistant Operations Manager
B. Kirk Shift Supervisor P. Laird Plant Maintenance Manager
W. Loomis lac Supervisor
J. Staub Technical Services Manager
N. St. Laurent Assis'. ant Plant Superintendent
The inspector also interviewed other licensee personnel including instrument technicians, reactor operators and members of the clerical staff.
Denotes those present at the exit interview.
- 2.
Licensee Action on Previous Inspection Findings (Closed) Unres:lved Item (50-29/79-13-03): Required engineering restraint analysis and calculations was not among the microfilmed records for Plant Design Change Request (PDCR) 78-2.
The inspector observed that documentation of the pipang stress analysis for this PDCR was forwarded to the plant by lette.- from Teledyne Engineering Services (Ltr: 3161-1) dated January 29, 1980 and has been processed into the plant microfilmed records.
Based on this observation, this item is closed.
. e
. .
3.
Administrative Controls for Safety Related Calibrations and Surve111ances Administrative controls governing the performance of safety related calibrations and surveillances wcre inspected to deten tae their conformance with the requirements of 10 CFR 50 Appendix B, " Quality Assurance Criteria for Nuclear Power Plants..."; Technical Specification Section 6, " Administrative Controls"; Regulatcry Guide 1.33 - 1978, " Quality Assurance Program Requirements (Operation)" and ANSI N18.7 - 1976, " Administrative Control and Quality Assurance for the Operational Phase of Nuclear Power Plants". The following procedures were reviewed: Yankee Atomic Electric Company, Operational Quality Assurance -- Program, Y0QAP-I-A: (1) Section II, Quality Assurance Program, Revision 9, March 9, 1981; (2) Section V, Instructions, Procedures, Drawings, Revision 2, November 2, 1977; (3) Section XI, Test Control, Revision 1, September 15, 1977; (4) Section XII, Control of Measuring and Test Equipment, Revision 1, September 15, 1977; (5) Section XVI, Corrective Action, Revision 1, September 15, 1977; AP-0001, Plant Procedures and Instructions, Revision 8; -- AP-0003, Plant Operations Review Committee Responsibilities -- and Authorities, Revision 5; AP-0041, Plant Surveillance Schedule, Revision 6; -- -- AP-0215, Control of Measuring and Test Equipment, Revision 5; AP-0218, Test Control, Revision 5; -- AP-0220, Surveillance Tests and Records, Revision 12; -- AP-0221, Plant Record Management, Revision 6; -- AP-0223, Document Control, Revision 4; -- -- AP-2005, Operations Department Surveillance Schedules, Revision 20; and, . _ _ _.
. .
-- AP-6003, I&C Department Maintenance Program, Revision 5.
No items of nonccmpliance were identified.
4.
Inspection of Program and Implementation for Calibr cions, Calibration Checks, and Instruments Functional Tests Required By Technical Specifications: a.
A sampiing inspection was cenducted of the program and its implementaticn for instrument calibrations, calibeccion checks, and functional tests required by the Technical Specifications.
The program and implementation was inspected for conformance to sne requirements of the Technical Specifications, Regulatory Guiue 1.33,278, ANSI N18.7 - 1976, and the appropriate plant administrative requirements detailed in paragraph 3. The follcwing areas were verified: -- A master schedule has been established for surveillance calibration testing; -- Responsibilities have been assigned for performance of surveillance calibrations and to assure that calibration schedules are satisfied; -- Methodt and responsibilities have been established for review and evaluation of calibration data, for reporting calibration deficiencies and failures, and for verifi-cation that LCO requiremetns have been satisfied; -- Applicable system status during c mponent calibrations was in conformance with Technical Specification limiting condition for operations, where applicable; -- Procedure format provided detailed stepwise instructions in the degree of detail necessary for performing the calibratiors; -- Procedure review and approval were as required by Technical Spec 1fications; -- The technical content of procedures was sufficient to result in satisfactory component calibration and Tech-nical Specification limits and setpoints were complied with; and -- Calibration data was adequately and accurately recorded and was within established tolerances.
b.
The following procedures were reviewed:
, e , , -,, - - - , - - - -, _,. -. - ,, _. ,
- . - - - _. . , -. -- - - -. - - -. - - . - . .. i
OP-4601, Nuclear Instrumentation Channel Functional Test, -- Revision 10. Data reviewed for tests performed on July 27, 1981; August 27, 1981; September 24, 1981; and October-22, 1981; ! -- OP-4611, Nuclear Instrumentation and Reactor Protection l System Precritical Check, Revision 10. Data reviewed for tests performed on September 12,1981; July 30,1981;
August 20, 1981; and July 27, 1981; j OP-4606, Main Coolant Flow Trip (MC Pump Current) Functional -- Test, Revision 8.
Data reviewed for test performed September 10, 1981; October 8, 1981; August 13, 1981; and July 24, 1981; i OP-4610, Containment Isolation System Calibration, Revision -- , j 7.
Data reviewed for test performed July 13, 1981; ' . l -- OP-4644, Functional Test of-the Fire Detection Instrumen-
tation, Revision 2.
Data reviewed for tests performed on ' September 24, 1981 and February 12, 1981; and, ! -- OP-4630, Accumulator Time Delay Activation Verification, Revision 6.
Data reviewed for tests performed October 13, 1981; September 15, 1981; August 19, 1981; and-July 28, 1981.
No items of noncompliance were identified.
. l 5.
Inspection of Program and Implementation For Calibration of Plant Instrumentation Used For Verification of Technical Specification Surveillances
l a.
A samplin3 inspection was conducted of the program and its j implementation for calibration of plant installed instrumen-tation used to verify satisfactory performance of Technical
Specification surveillance tests or Inservice Testing. The l program and implementation was inspected for conformance to the requirements of the Technical Specifications, Regulatory l Guide - 1.33 - 1978. ANSI N18.7 - 1976, and the appropriate plant administrative procedures detailed in paragraph 3. The ' following areas were verified: A master schedule has been established for alibration --
testing; i -- Responsibilities have been assigned for performance of , ' calibrations and to assure that calibration schedules are satisfied; e i b
' s ,~+,----,,,,.,_..,-,,..,,,,,.,.,. ,,w e.,,,% ,,,,,,, _, ,.._.-__,,..,_,.,..y._y.. ..,r.,,, , -.m._,,_,_v,,y._,_,, __,_,,_<,,r- -._, _,, m.m -
! . .
-- Calibratio, " t.Jule and frequencies as established by the licensee are being followed; -- Procedures have been reviewed and approved in accordance with Technical Specifications, contain acceptance criteria consistent with Technical Specification requirements and contain detailed instructions commensurate with the complexity of the calibration; The technical content of procedures is adequate to perform -- satisfacto > calibration; and -- Calibration data was adequately and accurately recorded and was within established tolerances.
b.
The following procedures were reviewed: -- Maintenance History Card (MHC) for FO-LIT-1, Diesel Fuel Oil Tank Local Level Indicator. Data reviewed for initial installation calibration performed on May 27, 1980; -- MHC for FW-PI-1060, Emergency Boiler Feed Pump Discharge Pressure.
Data reviewed for calibrations performed on July 31, 1979 and September 9, 1980; -- MHC for FS-LT-1, Fire System Tank Level Transmitter. Data reviewed for calibration performed January 20, 1981; -- OP-6475, Diesel Generator Day Tank Level Control System Calibration, Revision 0.
Data reviewed for Calibration performed May 13, 1981; -- OP-6473, Diesel Generator Ammeter Calibration, Revision 1.
Data reviewed for calibration performed May 15, 1981; -- OP-4632, O'd Vapor Container Temperature Indicator Calibration, Revision 2.
Data reviewed for test performed May 12, 1981; and, -- OP-6463, SI Accumulatcr Level Channel Calibration, Revision 4.
Data reviewed for calibration performed September 5, 1980.
c.
Findings: The inspector determined that the licensee did not have an approved, documented program / procedure which specifically identified those instruments which were used to verify Technical Specification surveillance tests. However, the inspector did note that the licensee did have a procedure, AP-6003, "I&C
. .
Department Maintenance Program", which does state that such instruments will normally be calibrated at 24 month intervals.
Additionally, a licensee representative stated that all plant , instruments were calibrated including both safety and nonsafety related instruments. A randem sampling by the inspector appeared to confirm thi. ? The records of calibrations of most instruments were maintained on Maintenance History Cards (MHC'S) for each instrument.
These MHC'S included calibrations for safety related and non-safety related instruments, although some safety related instrumants were calibrated using an approved procedure.
The MHC'S were blank cards in which the technician (or supervisor) entered the calibration points, tolerances, and calibration frequencies. The MHC'S had no formal review or approval prior to use nor was there any documented review of the completed data.
Changes could be made to the MHC by instrument technicians without any further review. Although reviews of completed MHC data were not documented, a licensee representative stated that the I&C Foreman did review completed MHC data for completeness and accuracy.
The inspector observed that the following instruments which are used to verify Technical Specification surveillance re-quirements were calibrated using MHC'S rather than an approved procedure: Diesel Fuel Oil Local Level Indicator, -- -- Emergency Boiler Feed Pump Discharge Pressure, -- Fire System Tank Level Transmitter, and, -- Safety Injection Accumulator Pressure Indicators.
Other instruments sampled during this inspection were calibrated using an approved procedure. The inspector informed the licensee that calibrations of safety related instruments require the same review and approval as other procedures and that calibration inputs, frequencies, and tolerances must have formal approval.
In addition, supervisory review of completed data must be documented.
Failure to use an approved procedure for the calibration of instruments which are used to verify Technical Specification surveillance requirements is contrary to Regulatory Guide 1.33, November 1972, Appendix A, paragraph H.
_ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. .
6.
Inspection of Program and Implementation For Technical Specification Surveillance Testing a.
A sampling inspection was conducted of the program and its implementation for the surveillance testing of equipment and systems as required by the Technical Specifications.
The program and implementation was inspected for conformance to the requirements of the Technical Specifications, Regulatory Guide 1.33-1978, ANSI N18.7 - 1976, and the appropriate plant administrative requirements detailed in paragraph 3.
The following areas were verified: -- A master schedule has been established for surveillance testing; Responsibilities have been assigned for performance of -- tests and to assure that test schedules are satisfied; -- Methods and responsibilities have been established for review and evaluation of test data, for reporting test deficiencies and failures, and for verification that LCO requirements have been satisfied; -- Tests required by Technical Specifications are available and covered by properly approved procedures; -- Test format and technical content are adequate and provide satisfactory testing of related systems or components; -- Tests have been reviewed as required by facility administra-tive requirements; and, -- Tests were performed within the time frequencies specified by the Technical Specifications and appropriate action was taken for any item failing acceptance criteria.
b.
The following surveillance tests and data for completed tests were reviewed: -- OP-4216, Testing of The Post Accident Hydrogen Venting System, Revision 10.
Data reviewed for tests performed on October 6, 1981; September 8, 1981; August 11, 1981; and July 24, 1981.
-- OP-4204, Monthly Test or Special Operation of The Safety - Injection Pumps, Revision 21. Data reviewed for tests performed on October 29: 1981; October 16, 1981; October 22, 1981; October 5, 1981; and October 9, 198.. .
-- OP-4215 Surveillance of The Boron Injection Flowpath, Revision 2.
Data reviewed for test performed on June 7, 1981.
OP-4263, Emergency Power Supply Tests For PR-MOV-512 and -- Pressurizer Heaters, Revision 0.
Data reviewed for test performed on July 21, 1981.
-- OP-2100, Plant Startup From Cold Shutdown, Revision 27, Attachment A, Step 7, Inspection of Vapor Container Recirculator System.
Data reviewed for inspection performed July,1981.
OP-2475, Vapor Container Access, Revision 6.
Data reviewed -- for inspections performed October 28, 1981. October 20, 1981; and October 6, 1981.
-- OP-4245, Flow Test of The Fire Suppression System, Revision 0.
Data reviewed for test performed May 1, 1981.
c.
Findings ANSI N18.7 - 1976, paragraph 5.3.4.4., specifies that the monitoring of safety related parameters be accomplished through uce of appropriate operating procedures.
The inspector determined that although a procedure existed for the use of plant logs and monitoring of plant parameters, the specific information required by the logs was not included in the procedure. The inspector also determined that, although plant logs were not part of a procedure, the logs were controlled and reviewed by piant management and were updated, as required, to reflect latest Technical Specification information.
The inspector informed the licensee taat, as a minimum, logs which monitor safety related plant parameters must be controlled, reviewed, and approved as other procedures covered by ANSI N18.7.
The licensee stated that su:5 logs would be procedurally controlled in the future. This item is unresolved pending licensee action and subsequent NRC:RI review (50-29/81-19-02).
. 7.
Inspection of Program and Implementation for The Calibration and Control of Test and Measurement Equipment A sampling inspection was conducted of program and its implementation for the calibration and control of measuring and test equipment.
The program and implementations was inspected for conformance to Regulatory Guide 1.33-1978, ANSI N18.7 - 1976, ANSI N45.2.4, " Installation, In: vection and Testing Requirements for Instrumentatiun and Electric Equipment During the Construction of Nuclear Power Generating Stations", and the appropriate plant administrative requirements detailed in paragraph 3.
The following areas were verified: - --. - - - . .-.. - - - - -
.. .
Establishment and maintenance of a master equipment list; -- -- Establishment and adherence to calibration schedule; Test equipment was in calibration when in use; -- -- Calibration data, where available, was adequate and accurate and within specified tolerances; -- Maintenance of calibration records identifying standards used which have traceability to the National Bureau of Standards or other testing organization; -- Test equipment custody control records; -- Storage and labeling of test equipment; -- Test equipment used as primary standards for in plant cali-brations of est equipment were in calibration; -- Traceability of out of calibration test equipment to usage of that equipment; -- Establishment of responsibilities for control of test equipment; and, -- Control and calibration of nine pieces of test equipment used for calibration or test of components identified in paragraphs 4.b, 5.b, and 6.b.
' No items of noncompliance were identified.
8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations, or items of noncompliance.
One unresolved item was identified during this inspection and is detailed in paragraph 6.c.
9.
Management Meetings Licensee Management was informed of the scope and purpose of the inspection at the entrance interview conducted on November 3, 1981.
The findings of the inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview was conducted on November 6, 1981 (see paragraph I for attendees) at which time the findings of the inspection were presented.
- ---__, __ . . _ _ _ _ _ _ _ _ _ __ }}