IR 05000309/1989003
| ML20247M642 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/24/1989 |
| From: | Blumberg N, Finkel A, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247M626 | List: |
| References | |
| 50-309-89-03, 50-309-89-3, NUDOCS 8904060095 | |
| Download: ML20247M642 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-309/89-03-
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Docket No.
50-309 License No.
DPR-36 Priority Category C
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Licensee: Maine Yankee Atomic Power Company 83 Edison Drive A of:sta, Maine 04336 l
Facility Name: Maine Yankee Atomic Power Plant Inspection At: Wiscasset, Maine Inspection Conducted:
February 28 - March 3, 1989 Inspectors:
Ef A. Finkel,/ Senior Reactor Engineer
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G'.fapuaa, Senior Reactor Engineer
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Approved by:
Ub"/T hk N. Blumberg, Chief, Operational Programs date Section, OB, DRS
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Inspection Summary: Announced Inspection on February 28 - March 3, 1989 (50-309/89-03)
Areas Inspected: An inspection to evaluate Maine Yankee Atomic Power Company (MYAPC) corrective actions to respond to the potential enforcement findings l
88-200-01 and 02, described in inspection report 50-309/88-200.
i Results: Maine Yankee Atomic Power Plant (MYAPP) commitments described in its letters of July 12, 1988 (MN-88-72), August 10, 1988 (MN-88-80) and j
November 8, 1988 (MN-88-108) (Reference Attachment A), addressed the potential enforcement findings documented in NRC Inspection Report 50-309/88-200(items
Q1 and 02). The inspectors review of MYAPP commitments and their supporting
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data indicated that the findings of NRC Inspection Report (items 50-309/88-200-01 and 02) did not present a safety concern with respect to continued plant operation.
The inspectors did verify that the following violations reported in 50-309/88-200 did occur.
8904060095 890324 PDR ADOCK 05000309 Q
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(1) Engineering decisions on the acceptability of parts and materials were j
not documented in an adequate manner (Paragraph 2.0).
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(2) Failure to impose provisions of 10 CFR 21 on purchase orders, associated with nuclear specifications, therefore, not meeting the definition of commercial grade parts per 10 CFR 21.3 (Paragraph 2.0).
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Failure to validate Certificates of Conformance (C0C) from vendors not on the Approved Vendor List (AVL) (Paragraph 2.0).
(4) Failure to enter into the Operational Assessment System (OAS) General Motors / Electro-Motive Division (GM/EMD) Power Pointers and Maintenance Instructions for the emergency diesel generators (Paragraph 3.0).
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DETAILS 1.0 Persons Contacted Maine Yankee Atomic Power Company
- J. Atkinson, Director of Material Management
- E. Boulette, VP Operations / Plant Manager
- J. Garrity, VP Licensing and Engineering
- J. Frothingham, Manager, Quality Programs
- J. Herberi, Manager, Plant Engineering
- S. Nichols, Licensing Supervisor
- G. Whittier, Manager, Nuclear Engineering and Licensing State of Maine
- P. Dostie, State Nuclear Safety Inspector U.S. Nuclear Regulatory Commission
- C. Holden, Senior Resident Inspector
- R. Freudenberger, Resident Inspector The inspectors also held discussions with other licensee personnel during the cause of this inspection.
- Denotes those present at the exit meeting on March 3, 1989.
2.0 Potential Enforcement Finding 50-309/88-200-01 2.1 Procurement Activities Potential Enforcement Finding 88-200-01 discussed the licensee's failure to (1) dedicate and provide proper documentation of commercial grade items procured for safety-related applications; (2) impose on vendors the provisions of 10 CFR 21 when the purchase orders specify nuclear specifications; and, (3) validate certificates l
of conformance received and accepted from vendors not on the approved vendors list.
The licensee had committed to the illowing immediate corrective actions with respect to their procurement practices in letters dated i
July 12, 1988 (MN-88-72) and August 10, 1988 (MN-88-80) and provided l
the status of these actions in a letter dated November 8, 1988 (MN-88-108).
Reassessment of criteria for classifying purchases as
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Procurement Level 1 (i.e. safety-related)
Revise procedures to specifically require applicability of
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10 CFR 21 for all Procurement Level 1 (PL-1) purchases I
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Revise procedures to account for the guidance provided in
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the, Electric Power Research Institute document " Guidelines for Utilization of Commercial Grade Items in Nuclear Safety-Related Applications" Review purchases made during the past five years to identify
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Procurement Level 2 (PL-2) purchases and evaluate items to ensure they are equal to or better than the originals l
2.2 Inspection Findings 2.2.1 Licensee Commitments i
With respect to the above licensee commitments, Procedure 0-04-1 has been revised to provide specific criteria for classification of purchases as PL-1, assign this responsibility to the Plant Engineering Department and emphasize the applicability of 10 CFR 21 to all PL-1 purchases. Also, the guidelines in the EPRI document have been incorporated into new procedure 0-04-4 which has been implemented. Approximately 17,000 Purchase Orders issued in the
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past five years have been re-reviewed and about 800 were classified as Commercial Grade Procurement.
Engineering has identified that 404 commercial grade Purchase Orders were used in safety related applications. Engineering evaluations have been completed with dedication documented for 339 Purchase Orders. The remaining 65 purchase orders were in the re-review process.
The licensee has not identified any safety concern to date.
2.2.3 Potential Enforcement Finding The inspectors reviewed several of the 339 Purchase Order packages (see Attachment B); matrices of licensee Purchase Order re-reviews and results; and, reviewed a sample of re-reviewed purchase order packages and held discussions with involved personnel to evaluate the
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technical adequacy of licensee re-reviews and status of corrective actions. The inspectors concluded that evaluations had been originally done to dedicate the commercial grade items for safety related use but most had not been formally documented. The licensee re-reviews did not identify any safety concerns and the inspectors concurred based on an assessment of the technical data contained in the several purchase order packages reviewed.
The licensee re-review of Purchase Orders identified a number of instances where the provisions of 10 CFR 21 (Part 21) should have been imposed. These vendors were contacted and all but two stated that Part 21 had been automatically imposed by the vendor upon receipt of the particular Purchase Orders. One vendor who had not acted as the others has stated that Part 21 was being accepted and
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any identified defects would be henceforth reported.. Communications are ongoing with the other vendor. Additionally, discussions with licensee personnel and reviews of document packages indicated that Purchase Orders that did not require imposition of Part 21 required the vendor to implement a 10 CFR 50, Appendix B Quality Assurance Program (QAP). The licensee imposed the QAP requirements on Purchase Orders to vendors known to be acceptably implementing such a program.
The licensee re-review of this issue did not identify a safety.
concern and the inspectors assessment concurred.
I The licensee re review of Purchase Orders with respect to acceptance of Certificates of Conformance (C0C) from unapproved vendors identified that approximately 30 had been on their Approved Vendor List at the time the Purchase Order was issued.
Common licensee findings included cases where the Commercial Grade vendor had originally provided material / test certifications to support the C0Cs or certified compliance of the current purchase to an original Purchase Order. Other licensee findings varied, but overall no safety concern was identified by the licensee. Approximately 15 Purchase Orders were under current review.
Based on a sample review of the technical data support packages and discussions with licensee personnel the inspectors did not identify a safety concern.
3.0 Potential Enforcement Finding 50-309/88-200-02 3.1 General Motors / Electro-Motive Division Power Pointers / Maintenance Instructions Potential Enforcement Finding 50-309/88-200-02 discussed the maintenance organization's failure to enter into the Operational Assessment System (0AS) 98 of the 99 General Motors / Electro-Motive Division (GM/EMD) Power Pointers and Maintenance Instructions for the emergency diesel generators. Also, documented evaluations had been performed for only one of the Power Pointers and Maintenance Instructions.
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The inspectors verified through the licensee re-evaluation program i
that GM/EMD Power Pointers and Maintenance Instructions were received and reviewed by the maintenance organization as required by procedure Operational Assessment System (OAS) No. 20-2-1.
The GM/EMD data,
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however, was not sent to the Operational Assessment Coordinator (OAC)
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for entering into their tracking system. The original engineering analyses performed on the GM/EMD data lacked supporting data which was reconstructed by the licensee during their re-evaluation program.
The re-evaluation program has reconstructed and supported their original GM/EMD Power Pointer / Maintenance Instructions decisions
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from 1974 to 1989. The documented results are listed in a report titled, " Power Pointer Status Report," dated March 2, 1989. This report was performed in conjunction with Morrison-Knudsen the i
diesel service company and authorized part supply for GM/EMD.
The inspectors, on a sampling basis, reviewed approximately 25 Power Pointers / Maintenance Instructions (1979-1987) and determined that the licensee's re-evaluation analysis supported their original engineering analyses and that there were no safety concerns identified.
The Operational Assessment System procedure No. 20-2-1, Revision 5,.
November 3,1988 has been issued and should correct the problems of handling vendor received data and supporting analysis documentation.
The inspectors verified that training has been given to the site personnel on both the NRC findings and the revised site procedure.
4.0 Conclusion Except for the violation discussed in NRC Inspection Report 50-309/88-200-01 and 02, the engineering activities at the site related to technical assessments were observed to be conducted using plant and industry history data files and vendor supporting data. The licensee's re-evaluation program has reconstructed and supported their original engineering decisions. Based on the NRC review of the results of the re-evatuation program, no safety concerns have been identified.
5.0 Exit Interview At the conclusion of the site inspection on March 3, 1989, an exit interview was conducted with the licensee's senior site representatives (listed in paragraph 1.0).
The findings were identified and inspection items were discussed.
At no time during this inspection was written material provided to the licensee by the inspectors. Based on the NRC Region I review of this report and discussions held with the licensee representatives during i
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this inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restrictions.
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ATTACHMENT A 1.0 Maine Yankee Correspondence July 12,1988 (MN-88-72), G. Whitter to NRC Region 1, W. Russell,
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Regional Administrator, Procurement Audit.
-August 10,1988 (MN-88-80), J. Randazza to NRC Region 1, W. Russell,
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Regional Administrator, NRC Procurement Inspection (88-200).
i November 8, 1988 (MN-88-108) G. Whittier to NRC R. Wessman,
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Project Director, Washington, D.C., Status Report of Procurement Improvements.
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ATTACHMENT B i
1.0 Purchase Orders (PO) Reviewed PO 41181, 1/2 inch SS Whitey Valve PO 42096, 1/2 inch SS Whitey Globe Valve i
l PO 44236, 1/2 inch SS Whitey Globe Valve l
P0 41487, 0 Rings PO 43361, Rupture Discs for Main Stream Excess Flow Check Valves 2.0 Procedures Reviewed No. 0-04-1, Material, Equipment, and Service Requisitioning, Rev. 4 No. 0-04-4, Procurement of Commercial Grade Items for Safety Class Applications, Revs. 0 and W (a draft)
No. 20-2-1, Operational Assessment System, Revision 5 3.0 Other Documents Reviewed Memorandum Resolution of NRC Procurement Audit Concerns, Rev. 1 Memorandum Receiving -Verification Critical Characteristics Project Handwritten Matrix Comparing NRC Inspection 50-309/88-200 oral exit P0 examples to written report examples Maine Yankee Atomic Power Station (MYAPS) Seismic Design Margins Program, Letter NRC, P. Sears, Project Manager to MYAPS, J. Randazza, March 26, 1987 Critical Characteristics / Verification Plans Data Sheets Emergency Diesel Generator Power Pointer Audit, June 30, 1988