IR 05000029/1982007
| ML20054G887 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 05/28/1982 |
| From: | Caphton D, Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054G875 | List: |
| References | |
| 50-029-82-07, 50-29-82-7, NUDOCS 8206220384 | |
| Download: ML20054G887 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-29/82-07 Docket No.
50-29 License No.
DPR-3 Priority
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Category C
Licensee:
Yankee Atomic Electric Company 1671 Worcester Road Framingham, Mass. 01701 Facility Name:
Yankee Nuclear Power Station Inspection At:
Rowe, Massachusetts Inspection Conducted:
M_ay 4-7, 1982 Inspectors:
hN-bk
. W. ~M6ybr,' Reac r Inspector date date O[b I
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Approved by:
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~0. L. Caphtoh, Chief, Management
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Programs Section, DETP Inspection Summary:
Inspection On May 4-7, 1982 (Report Number 50-29/82-07)
Areas Inspected: Routine, unannounced inspection by one regional based inspector of licensee action on previous inspection findings; audit program; and quality assurance program review.
The inspection involved 29 inspector hours onsite and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> offsite.
Results: Violations: None in two areas; one in one area [ violation -
ineffective corrective action associated with licensee identified audit findings, paragraph 3.d.(1)]
8206220384 820604 PDR ADOCK 05000029 O
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DETAILS 1.
Persons Contacted Plant Operations
- D. Moody, Manager of Operations
- N. St. Laurent, Assistant Superintendent
- B. Drawbridge, Technical Director
- J. Staub, Technical Services Manager
- L. French, Plant Engineer Quality Assurance
- D. Pike, Manager, Operational Quality Assurance (0QA)
- L. Reed, OQA Coordinator
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- N. Fetherston, 00A Engineering Assistant,
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- M. Franklin, OQA Engineering Assistant, USNRC
- T. Foley, Senior Resident Inspector
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- Denotes those persons present at the exit interview on May 7, 1982.
2.
Licensee Action on Previous Inspection Findings
(Closed) Unresolved Item 29/79-13-04: Review cycles were not specified for corporate office procedure series such as operational quality
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assurance (0QA), Westboro engineering (WE), Welding, and non-inservice inspection (non-ISI) nondestructive evaluation (NDE).
The inspector verified that appropriate administrative procedures have been revised t require hat 0QA and WE procedures be reviewed at least every two years and that welding and NDE procedures would be reviewed following major addition revisions of the ASME Boiler and Pressure Vessel Codes, which occur every three years.
Based on the above this item is closed.
(Closed) Unresolved Item (29/82-01-02):
Failure to provide audit scope and summary of findings in quality assurance audit reports. The inspector reviewed procedure OQA-XVIII-2, "In Plant Audit Program",
Rev. 14, March 1, 1982. The procedure lists a revised audit report format which includes " scope of audit" and " summary of the audit" as the two lead sections. Also, the inspector verified that Audit Report YR-82-9, Housekeeping, April 12, 1982 utilized the revised format.
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l 3.
Quality Assurance Audits a.
Requirements i
The requirements governing the performance of quality assurance audits of safety-related areas are specified in 10 CFR 50, Appendix
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8, " Quality Assurance Criteria for Nuclear Power Plants" and
Technical Specifications, Section 6, ' Administrative Controls".
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In addition, the Yankee Operational Quality Assurance Program requires compliance with the requirements of ANSI N18.7-1976,
" Administrative Controls for Nuclear Power Plants', and ANSI N45.2.12, " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants."
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Specifically, the above requirements specify that the audits achieve the following:
The content of audit reports clearly defines the scope of
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the audit and the results; Audits are conducted by trained personnel not having direct
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responsibility in the area being audited; j
Frequency of audits is in conformance with Technical Specifications
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and the QA program; Appropriate followup actions (including reaudit, if necessary)
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are being taken, are in progress or are being initiated; and l
The audited organization's response to the audit findings is
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in writing, is timely, and adequately addresses the findings and recommendations, j
b.
Program Administration The inspector reviewed the following procedures to verify that the licensee maintains an administrative system to meet the above requirements:
YOQAP-I-A, Operational Quality Assurance Program, Section
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XVIII, " Audits", Rev. 9, March 9, 1981; 00A-II-2, " Indoctrination and Training", Rev. 4, January 23,
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i 1981; 0QA-XVIII-1, " Auditor Training", Rev. 2, January 23, 1981;
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and, 00A-XVIII-2, "In Plant Audit Program", Rev. 14, March 1,
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1982.
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c.
Implementation
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The inspector reviewed the following areas to verify compliance with the audit program requirements:
In Plant Audit Summaries for 1982, 1981, and 1980, May 5,
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1982; In Plant Audit Discrepancy Report for May 5, 1982;
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Training and Certification of Auditors and Lead Auditors,
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December 21, 1981; Certifications of four auditors; and,
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Audit files for nine audits, each of which included the
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audit checklist, audit report, plant position report, Manager of Operations implementation directive, and follow-up of audit findings (audits YR-80-2; YR-81-2,
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16A, -168; and YR-82-4, -6)
d.
Findings (1) Ineffective Corrective Action 10 CFR 50, Appendix B, Criteria XVI, Corrective Action, states in part " Measures shall be established to assure that conditions adverse to quality...are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
In addition the Yankee 00A Program (YOQAP-I-A) commits to meet ANSI N.45.2.12, Draft 4, Rev. 2-1976, which states in part (paragraph 4.5.1), " Management of the audited organization or activity shall review and investigate any adverse audit findings to determine and schedule appropriate corrective action including action to prevent recurrence and shall respond to the (audit) report in writing...The response shall clearly state the corrective action taken to prevent recurrence."
During a review of audit findings, the inspector found numerous examples where the written response to the findings did not address corrective _ action taken to prevent recurrence.
Further, the inspector found the following examples of audit findings of significant conditions adverse to quality which had been identified in previous audits but for which no action had been taken to prevent recurrenc.
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(a) Audit YR-81-4, Security, completed on September 11, 1981; the licensee's auditor found that one gate of the protected area fence could be opened, although the gate was locked. The corrective action was to chain and lock the two parts of the gate together. During Audit YR-82-4, Security, completed on April 30, 1982, the auditor found that another gate of the protected area fence could be opened, although the gate was locked.
(b) Audit YR-81-4, Security; the licensee's auditor found that the owner controlled area was not properly posted with "No Trespassing" signs in one region.
The plant response to the finding was that "This item has been corrected".
In Audit YR-82-4, the auditor found that the owner controlled area was not properly posted with
"No Trespassing" in another region.
(c) Audit YR-80-2, Chemistry, completed on May 14, 1980; the licensee's auditor found four examples of chemical reagents that had incorrect expiration dates, had exceeded expiration dates, or had no expiration dates.
Audit Report YR-80-2 stated that "These out-of-date chemicals were discarded, therefore this item is closed.
The auditors feel there is a need for tighter controls of the prepared reagents". However, the plant response to this finding was "This item is closed."
During Audit YR-81-2, Chemistry, completed on March 13, 1981, the auditor found "some chemicals and reagents
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being stored in the Primary and Secondary Labs have exceeded their shelf life".
The above examples of ineffective corrective action to licensee identified findings are a violation (29/82-07-01).
The licensee's representative acknowledged the inspector's finding, but did not agree that the above examples constituted a violation of regulatory requirements.
(2) Timely Corrective Action ANSI N45.2.12, Draft 4, Rev. 2-1976, states the following concerning the time span of audit reporting and corrective action response:
Paragraph 4.4:
"The audit report shall be issued
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within thirty days after the audit"; and,
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Paragraph 4.5.1: " Management of the audited organization
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or activity...shall respond to the report in writing within thirty days after receipt...."
The licensee system for audit reporting and corrective action response is specified in OQA-XVIII-2, "In Plant Audit Program", Rev. 14, March 1, 1982, as follows:
(a) Within 30 working days of audit completion the audit report is to be issued.
(b) Within 30 working days of receipt of the audit report, the plant staff is to submit a Plant Position Report (PPR) to the Manager of Operations (M00).
(c) Upon completion of the review of the PPR by the Manager of Operations, an Implementation Directive (ID) is to be issued to the plant staff for implementation of corrective action.
(d) Af ter issuance of an Implementation Directive, the separate audit findings are to be entered onto the next Plant Audit Discrepancy Report (bi-monthly) and subsequently closed.out or carried as open.
The inspector reviewed the elapsed time span for the reporting and responses for the seventeen 1981 audits with findings.
The average time from audit completion to issuance of the Plant Position Recommendation was two and a half months and from audit completion to issuance of the Implementation
Directive was four and a half months.
The inspector's findings were as follows.
(a) The licensee interpretation that the " thirty days" of ANSI N45.2.12 for audit reporting and response to audit findings represents 30 working days is incorrect.
Procedure 0QA-XVIII-2 should be revised to properly reflect the intended thirty calendar days turnaround time.
(b) The response by the management of the audited organization to the audit findings is currently the Implementation Directive since all items on the Plant Position Report (PPR) are reviewed and approved via the Implementation Directive (10) and all scheduled dates for implementation are listed with reference to the receipt of the ID (e.g., 60 days after receipt of ID). Accordingly, the three months taken, on average, to respond to 1981
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audit reports does not appear to meet the ANSI N45.2.12 requirement of thirty days. To meet ANSI N45.2.12 it appears that the 10 must be issued within thirty days of the receipt of the audit report under the current administrative system or the system must be revised to have the Plant Position Report respond to audit findings which can be corrected within the plant's authority without further Manager of Operations approval. Those remaining audit findings which would require Manager of Operations approval would then be tracked as open items with a later due date.
(c) The timeliness of corrective action to audit findings
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could be improved by the increased management attention facilitated by an improved status report. The current bi-monthly In Plant Audit Discrepancy Report does not list audit findings until the ID for them has been issued (on 1981 audits YR-81-2 and YR-81-13, this
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occured six and a half months after audit completion).
Also, the report does not succinctly show those corrective actions that are beyond the due date.
The licensee representative stated that corrective action to audit findings is taken in a timely manner in that many audit findings are corrected in advance of the administrative audit response cycle. The inspector agreed that many findings are resolved prior to completion of the administrative response cycle and therefore questioned the licensee as to why the full response system was necessary for all audit findings.
The inspector noted that the cumbersome administrative response system hinders effective corrective action and could have been responsible, in part, for the violation cited in 3.d.(1).
This item is unresolved pending licensee action and subsequent
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NRC:RI review (29/82-07-02).
4.
Quality Assurance (QA) Program Review a.
Requirements The Yankee Operational Quality Assurance Program (Y0QAP-I-A),
Rev. 10, April 3, 1981 provides the NRC approved licensee policy to meet the quality assurance (QA) requirement of 10 CFR 50, i
Appendix B and ANSI N18.7-1976.
b.
Review The inspector reviewed the following areas to verify that the QA
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policy was being implemented in licensee procedures and activities:
Interviews with the three Operational Quality Assurance
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personnel, including the 0QA Coordinator, assigned to the Rowe facility; 1982 0QA Department Inspection Index;
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Observation on May 5, 1982 of QA surveillance of Control Rod
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Operability Check under Procedure OP-4202; Observation on May 6, 1982 of QA surveillance of liquid
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penetrant testing of welding performed under Job Order 82-70; and,'
Procedure 0QA-X-1, Quality Assurance Inspections, Rev. 3,
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April 30, 1982.
Findings The inspector found that there is cursently no formal management evaluation of the Operational Quality Assurance Program utilizing an organization outside of Yankee Atomic Electric Company.
Specifically, paragraph II.D. of YOQAP-I-A, Rev.,9, March 9, 1981 states, "The Cognizant Corporate Officer directs a thorough evaluation of the established Operational Quality Assurance Program by assigning the Nuclear Safety Audit and Review Committee (NSARC) the task of reviewing for compliance with and evaluating the effectiveness of quality related activities."
The licensee representative stated that this thorough evaluation was performed on an on going basis by the NSARC. Further, he stated that Yankee is in the process of establishing a cooperative agreement with the other licensees to have management audits of the 0QA program performed by knowledgeable personnel from other licensees. The inspector concurred with the desirability of having such audits performed.
5.
Unresolved Items Unresolved items are ma.ttert about wnich more information is required in order to-t:certain'whether they are acceptable, deviations or violations. One unresolved item was identified during this inspection and is detailed in paragraph 3.d.(2).
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6.
Management Meetings Licensee management was informed of the scope and purpose of the inspection at an entrance interview conducted on May 4, 1982. The findings of the inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview conducted on May 7, 1982 (see Paragraph I for attendees) at which time the findings of the inspection were presented.
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