ML19340E421
| ML19340E421 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/18/1980 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Groce R Maine Yankee |
| References | |
| NUDOCS 8101140458 | |
| Download: ML19340E421 (7) | |
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UNITED STATES y'
NUCLEAR REGULATORY COMMISSION E
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December 18, 1980 N
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- S Mr. Robert H. Groce d
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Maine Yankee Atomic Power Company 25 Research Drive Westboro, Massachusetts 01581 Dea-Mr. Groce:
SUBJECT:
MAINE YANKEE OPERATIONAL QUALITY ASSURANCE PROGRAM We have reviewed your current operational QA program description submitted with your September 17, 1980 letter to W. P. Haass to determine its conformance with Appendix B to 10 CFR Part 50. The basis for our review was the SRP (NUREG-75/087, Rev.1) da,:ed February 1979.
We find that we will need additional information before we can complete our, review and evaluation. The enclosure contains questions and corrrnents that -require written responses from you. Please provide your responses wit *.in 60 days following receipt of this letter.
Appendix C, " Maine Yankee Classification," of your QA program description is under review and we will notify you concerning the results of this review shortly.
Should you have any questions or if you desire a meeting regarding our review, please feel free to contact Mr. G. Requa at (301) 492-8478.
Sincerely, h
A Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing
Enclosure:
Request for Additional Information cc: See next page W
8101140 P
cc:
Mrs. L. Patricia Doyle, President E. W. Thurlow, President SAFE POWER FOR MAINE Maine Yankee Atomic Power Company Post Of fice Box 774 Edison Drive Camden, Haine 04843 Augusta, Maine 04336 First Selectman of Wiscasset Mr. Donald E. Vandenburgh M'unicipal Building Vice President - Engineering U. S. Route 1 Yankee Atomic Electric Company Wiscasset, Maine 04578 20 Turnpike Road Westboro, Massachusetts 01581 Director, Criteria and Standards Division Office of Radiation Programs (Ah%460)
John A. Ritsher, Esquire U.S. Emirorinental Protection Agency Ropes & Gray Washington, D.C.
20460 225 Franklin Street Boston, Massachusetts 02110 U. S. Envirorsnental Protection Agency Region 1 Of fice Mr. John M. R. Paterson ATTN:
EIS COORDINATOR Assistant Attorney General JFK Federal Building State of Maine Boston, Massachusetts 02203 Augusta, Maine 04330 Stanley R. Tupper, Esq.
Mr. Nicholas Barth Tupper and Bradley Executive Director 102 Townsend Avenue Sheepscot Valley Conservation Boothbay Harbor, Maine 04538 Association, Inc.
P. O. Box 125 David Santee Miller, Esq.
Alan, Maine 04535 213 Morgan Street, N. W.
Viscassett Public Library Association High Street Mr. Paul Swetland Wiscasst:t. Maine 04578 Resident Inspector / Maine Yankee Mr. Torbert H. Macdonald, Jr.
c/o U.S. NRC P. O. Box E Office of Energy Resources Wiscasset, Maine 04 8 State House Station #53 Augusta, Maine 04333 Mr. Charles B. Brinkman Robert M. Lazo, Esq., Chairman Manager - Washington Nuclear Atomic Safety and Licensing Board Operations U. S. Nuclear Regulatory Commission C-E Power Systems Combustion Engineering, Inc.
Washington, D. C.
20555 4853 Cordell Ave., Suite A-1 Bethesda, Maryland 20014 Dr. Cadet H. Hand, Jr., Director Bodega Marine Laboratory University of California Bodega Bay, California 94923 State Planning Officer Nr. Gustavo A.' Linenbergor Executive artment Atomic Safety and Licensing Board U. S. Nuclear Regulatory Cornission 189 State Street Washington, D. C.
20555 Augusta, Maine 04330
MAINE YANKEE- (50-309)
Request for Additional Information
- 1.
Identify the position that is responsible for managing the onsite QA program.
2.
Identify the QA personnel who have the responsibility delineated in writing to stop unsatisfactory work and control further processing, delivery, or instal'a-tion of nonconforming material.
3.
In Ficure 1, identify the MYAPC onsite and offsite organizations including the Plant Operations Review Committee.
4.
The qualification requirements in Appendix A for the Director Operational Quality Assurance Department are not satisfactory.
It is an NRC staff position that the qualifications and experience of the Director Operational Quality Assurance Department (offsite) bc at least equivalent to those described in Section 4.4.5 of ANSI /ANS 3.1-1978, " Selection and Training of Nuclear Power Plant Personnel."
In lieu of the above, we would accept a commitment to the education and exper-ience described in the following Section 4.4.5 of ANS 3.1-1979:
EDUCATION:
Bachelor Degree in Engineering or related science.
EXPERIENCE: Four (4) years experience in the field of quality assurance, or equivalent number of years of nuclear plant experi-ence in a supervisory position preferably at an operating nuclear plant or a combination of the two.
At least one (1) year of this four years experience shall be nuclear power plant experience in the implementation of the quality assurance program.
Six (6) months of the one year experience shall be obtained within a quality assurance organization.
Drovide a description to satisfy this position.
5.
A commitment is made in the Policy Statement that "The Program shall be consis-tent with... Regulatory Guides scecified in Section II...." Quality assurance programs should reflect the degree of conformance to current regulatory and industry guidance. Accordingly, Maine Yankee's QA program description should be ucdated to reflect conformance with the regulatory positions provided by the NRC in the following regulatory guides for future operational activities includ-ing maintenance and modification:
1.8-Rev. 1-R (5/77); 1.26-Rev. 3 (2/76);
1.28-Rev. 2 (2/79); 1.29-Rev. 3 (9/78); 1.30 (8/11/72); 1.33-Rev. 2 (2/78);
1.37 (3/16/73); 1.38-Rev. 2 (5/77); 1.39-Rev. 2 (9/77); 1.58-Rev.1 (9/80);
1.64-Rev. 2 (6/76); 1.74 (2/74); 1.88-Rev. 2 (10/76); 1.94-Rev. 1 (4/76);
1.116-Rev. 0-R (5/77); 1.123-Rev.1 (7/77); 1.144 (1/79); and 1.146 (8/80).
Section II should be modified to address this position. To preclude any mis-inter >retation regarding the commitment statement, it is recommended that the first sentence under Part C.
Implementation be revised as follows: Replace "where applicable... federal documents" with the following:
"with the Regulatory Position in the below listed Regulatory Guides as ;nodified in Appendix B."
Iden-l tify the Guides by number and revisicn number and/or date as noted above.
. /
6.
In the Policy Statement, it is noted that "The Nuclear Safety Audit and Review Committee shall periodically review...."
Clarify if this means monthly, annually, etc.
7.
The verbs " directs" and "provides" are used throughout Section I in describing QA program responsibilities.
Identify the specific individuals or groups who perfor.n the activity when either verb is used.
8.
Provide a commitment that the development, control, and use of computer code pro-grams will b2 c'onducted in accordance with the QA program and include a description of how the QA program will be applied.
~
9.
Identify those personnel authorized to approve changes to the "Q-list" and des-cribe methods for controlling its distribution.
10.
Provide a commitment that the fire protection program will be covered by the appli-cable criteria of Maine Yankee's operational QA program.
11.
Provice a commitment that special equipment, environmental conditions, skills, or processes will be provided as necessary.
12.
Give a brief summary of Maine Yankee's corporate QA policies.
13.
Provide a matrix of existing or proposed QA procedures cross referenced against each criterion of 10 CFR 50 Appendix B.
14.
Section II, page 4 - Modify note No. 5 to satisfy the following requirement:
Frovisions are included for notifying NRC of changes (1) for review and acceptance in the a'ccepted description of the QA program prior to imple-tentation, and (2) in organizational elements within 30 days after announcement.
(Note - editorial changes or personnel reassignments of a non-substantive nature do not require NRC notification.)
- 15. Describe the provisions which assure that deviations from specified quality standards are identified and procedures are established to ensure their control.
16.
Describe the provisions which assure that internal and external design interface controls, procedures, and lines of communication among participating design organi-zatior.s and across technical disciplines are established and described for the review, approval, release, distribution, and revision of documents involving design interfar:es.
17.
Describe the provisions'which assure that guidelines or criteria are established for determining the method of design verification (design review, alternate cal-culations, or test).
18.
For design verification activities, describe the provisions which assure the following:
The verifier is qualified and is not directly responsible for the design a.
'(i.e., neither the performer or his immediate supervisor).
In exceptional d
circumstances, the designer's immediate supervisor can perform the veri-fication provided:
(1) The supervisor is the only technically qualified individual.
(2) The need is individually documented and approved in advance by the supervisor's management.
(3) QA aud.its cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.
19.
The responsibilities of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the extent of documentation should be identified in procedures. Modify Section 3 to address this position.
20.
Provide a commitment that the following provisions are included if the verification method is only by test:
a.
Procedures provide criteria that specify when verification should be by test.
b.
Prototype, component or feature testing is performed as early as possible prior to installation of plant equipment, or prior to the point when the installation would become irreversible.
21.
Procedures should be established to assure that verified computer codes are certi-fied and specified for a particular use. Modify Section III to address this posi-tion.
22.
Describe the organizational responsibilities, including the involvement of the QA organization, for (1) procurement planning; (2) the preparation, review, approval, and control of procurement documents; (3) supplier selection; (4) bid evaluations; and (5) review and concurrence of supplier QA programs prior to initiation of activities affected by the program.
23.
Describe the provisions which assure that maintenance, modification, and inspection procedures are reviewed by qualified personnel knowledgeable in QA disciplines (ncrmally the QA organization) to determine:
The need for inspection, identification of inspection personnel, and docu-a.
mentation of inspection results.
i b.
That the necessary inspection requirements, methods, and acceptance criteria '
have been identified.
24.
Provide a commitment that procedures are established and described to assure that obsolete or superseded documents are removed and replaced by applicable revisions in work areas in a timely ma..ner.
25.
Describe the specific organization (s) at Maine Yankee responsible for the control of purchased material, equipment, and services including interfaces between design, procurement, and QA organizations.
f 26.
Describe the provisions which assure that procurement of spare or replacement parts for structures, systems, and components important to safety is subject to present QA program controls, to codes and standards, and to technical requirements equal to or better than the original technical requirements, or as required to preclude repetition of defects.
- 27. Describe the provisions which assure that suppliers' certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure they are valid.
28.
Describe the specific organization (s) at Maine ukee cosronsible for identifying and controlling materials (including consumchids'), part3, and components including partially fabricated subassemblies.
29.
Describe the criteria for determining those processes that are controlled as special processes.
- 30. Describe the processes whir.h ass _re that when inspections associated with normal operations of the plant (such as routine maintenance, surveillance, and tes:s) are perfonned by individuals other than those who performed or directly supervised the work, but are witnin the sune group, the following controls are met:
a.
The quality of the work can be demonstrated through a functional test when the activity involves breaching a pressure ' retaining item.
b.
The qualification criteria for inspection personnel are reviewed and found acceptable by the QA organization prior to initiating the inspection.
31.
Provide a commitment that inspection procedures, instructions, or checklists pro-vide, as required, for the following:
a.
Identification of characteristics and activities to be inspected.
b.
Acceptance and rejection criteria.
c.
Identification of required procedures, drawings, and specifications and-revisions.
d.
Specifying necessary measuring and test equipment including accuracy require-ments.
32.
Describe tiie provisions which assure that inspection results are documenteb, evaluated, and their acceptability determined by a responsible individual or group.
33.
Describe the provisions which assure that procedures provide criteria for determin-ing tne accuracy requirements of test equipment and criteria for determining when a test is required or how and when testing activities are performed.
34.
Describe the provisions which assure that test results are documented, evaluated, and their acceptability determined by a responsible individual or group.
4 r
'35.
Describe the specific organization (s) at Maine Yankee responsible for establishing, e
icplementing, and assuring effectiveness of the calibration program.
36.
Describe the provisions which assure that calibration of measuring and test equip-ment should be against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated or, when this is not possible, have an accuracy that assures the equipment being calibrated will be within required tolerance and that the basis of acceptance is documented and authorized by respon-sible management.
37.
05<cribe the provisions for the storage of chemicals, reagents (including control Of shelf life), lubricants, and other consumable materials.
38.
Describe the provisions which assure that the application and removal of inspec-tion and welding stamps and status indicators such as tags, markings, labels, and stamps are controlled.
39.
Describe the provisions which assure that the status of nonconforming, inoperative, or..alfunctioning structures, systems, and components is documented and identified to prevent inadvertent use.
40.
Identify those individuals or groups responsible for the disposition of nonconform-ing items.
.