ML19339A894
| ML19339A894 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/09/1974 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19339A893 | List: |
| References | |
| WYR-74-49, NUDOCS 8011050650 | |
| Download: ML19339A894 (3) | |
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Tiphone 6I7 366-9011
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710 390 0739 YANKEE ATOMIC ELECTRIC COMPANY m
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k 20 Turnpoko Road Westborough, Massachusetts 01581 YANKEE December 9, 1974 United States Atomic Energy Co= mission Directorate of Regulatory Operations Region I 631 vark Avenue King of Prussia, Pennsylvania 19406 Attention: Reactor Operations Branch
Reference:
a) License No. DPR-3
[ Docket No. 50-29) b) USAEC letter dated November 14, 1974
Dear Sir:
This letter is written in response to your letter dated November 14, 1974 which indicates four items that appeared to be in violation of AEC F
requirements. These items were reported as a result of RO Inspection No.
50-29/74-14 conducted on October 22-25, 1974 at the Yankee Facility in g.
Rcwe, Massachusetts.
Information is submitted in answer to the alleged violations contained in the enclosure to your letter as follows:
Category II Violations 1.
Criterion V, Appendix B, 10 CFR 50 states in part:
" Activities affecting quality shall be... accomplished in accordance with these (prescribed) instructions, procedures, or drawings."
Contrary to the above, maintenance adjustment to Sesmic Class I pipe hangers was not conducted with an approved procedure as required by Administrative Procedure AP-0214.
Response
USAEC Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations), Appendix A,Section I.1 1
states in fact:
" Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineation in a procedure."
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'usc;mber 9, 1974 Attn Re:ctar Operation 3 Brcnch P;ga Two It was determined that the subject activity was con-sistent with the above criteria for performing this work.
Instructions were delineated in a memo originating from our Mechanical Engineering Group precluding the necessity of having a step-by-step procedure. This instructional memo was submitted to the plant as a directive from the Manager of Operations. PORC reviewed the SI hanger displacement situation and recommended, in Meeting No. 74-20, that the Yankee Nuclear Services Division evaluate the problem. The above memo was the result of this evaluation.
b All work associated with this activity was inspected by Maintenance Department Supervision and by the Quality control and Audit Coordinator.
Based on the above discussion, we disagree that this item is a violation.
E 2.
Criterion V, Appendix B, 10 CFR 50 states that in part:
"... Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for ietermining that impcrtant activities have
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been satisfactorily accceplished."
Contrary to the above, modification maintenance to a main coolant check valve was performed without acceptance < rd " s p -
as required by Administrative Procedure AP-0214 being specified.
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Response
Maintenance Procedure OP-5200 will be revised to include an acceptance criteria. Additionally, all maintenance procedures shall be reviewed and revised if needed in a timely manner to insure that they contain an appropriate quantitative or qualitative acceptance criteria.
p Category III Violations 1.
Criterion VI, Appendix B, 10 CFR 50 states in part:
"... Changes to documents shall be reviewed and q
approved by the same organizations that performed the L
original review and approval..."
Contrary to the above, corrective maintenance was performed on a main coolant pump with a procedure il containing unauthorized changes contrary to the requirements of Administrative Procedure AP-0001 H
concerning procedure changes.
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United St-t0D Atomic Ensrgy Ccemincicn Dsc:rtar 9,1974 k+
Altr.: Reactor Operations Branch Page three
Response
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Maintenance personnel have been reminded of the require-ments of AP-0001 stating that:
"... Operating and fI Administrative Procedures may be temporarily changed
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with the signal approval of two Senior Reactor Operators
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and that such changes shall be documented and subse--
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quently reviewed by PORC and approved by the Plant Superintendent or the Asst. Plant Superintendent..."
Maintenance Procedure OP-5204, Main Coolant Pump Inspection and Repairs, is in the process of being revised to incorporate the new torque and clearance limits.
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2.
Criterion V, Appendix B,10 CFR 50 states in part:
" Activities affecting quality shall be... accomplished in accordance with those (prescribed) instructions, procedures, or drawings."
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Contrary to the above, shift supervisors and control room 2
operators failed to document their review of active Bypass h:
of Safety Functions and Jumper Control Requests as required l?
by Administrative Procedure AP-0018.
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Response
Shift supervisors and control room cperators have been reminded of the Administrative Procedure AP-0018 requirement to review active " Bypass of Safety Function and Jumper Control Requests. Additionally, the Operations Supervisor shall monitor the " Active" requests more closely to insure that shift supervisors and control room operators document their reviews.
i-We trust you find this info mation satisfactory; however, should you desire additional information please contact us.
Very truly yours, YANKEE A'IOMIC ELECTRIC COMPANY a
L. H. Heider Manager of Operations NNS/kg i:
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