ML20028F293
| ML20028F293 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/18/1983 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20028F291 | List: |
| References | |
| 50-309-82-19, NUDOCS 8301310351 | |
| Download: ML20028F293 (3) | |
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APPENDIX A NOTICE OF VIOLATION Maine Yankee Atomic Power Company Docket No. 50-309 Maine Yankee Atomic Power Station License No. DPR-36 As a result of the inspection conducted on October 6 - November 26, 1982, and in accordance with the NRC Enforcement Policy (10 CFR 2. Appendix C) published in the Federal Register on March 9, 1982 (47 FR 9987), the following violations were identified:
A.
10 CFR 50, Appendix B, requires a quality assurance program to be established to provide control over activities affecting the quality of systems important to safety. The Maine Yankee Operational Quality Assurance (QA)
Program assures an effective QA Program through confomance with specified industry standards inclLding ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operating Phase of Nuclear Power Plants.
ANSI N18.7 requires equipment control procedures to be implemented and followed, including equipment release and return to service.
Pursuant to the above, Maine Yankee Quality Assurance Procedure 0-07-3, Maintenance Requests, Revision 0, implements equipment control measures including: (1) a requirement for an on-duty senior reactor operator to stipulate on the maintenance request any restrictions which are necessary to insure that Technical Specification (TS) limitations are not exceeded, including how long the equ' pment may be out of service; and (2) a require-i ment for the Plant Shift Superintendent (PSS) to confim the functional acceptability of the completed maintenance and document his approval of the equipment readiness for service.
Contrary to the above, when on October 29, 1982, the low pressure safety injection pumps were removed from service and subsequently returned to operation on October 30, November 4 and November 9 to meet the require-ments of TS 3.8; no stipulation of how long these pumps could be out of service was documented on the maintenance requests nor did the PSS certify the functional acceptability of these systems for return to operation until November 12, 1982.
This is a Severity Level V violation (Supplement I.E.).
B.
Technical Specification 5.8 requires pro mdures to be established, implemented and maintained for surveillance testing of safety-related equipment. Surveillance procedure 3.17.2, Surveillance Functional Testing of Hydraulic Shock Suppressors, Revision 2, requires in step 7.4.3 that snubbers be shimmed on the test stand to prevent the pivoting bushing from moving laterally.
Contrary to the above, on October 16, 1982, during functional testing of snubber RC-HSS-102, test personnel did not shim the pivoting bearings on h$
0 0
Appendix A 2
the test stand.
This is a Severity Level V violation.
(SupplementI.E.).
C.
10CFR50, Appendix B Criterion III requires design control measures which assurethecorrectfranslationofthedesignbasisintodrawingsand procedures, the specification and use of appropriate quality standards, and proper approval of any design changes, including field changes.
Appendix B of the Maine Yankee (MY) Final Safety Analysis Report references a Quality Assurance (QA) Program which implements these design control measures, specifically as discussed in the MY Operational QA Program,Section III.
Plant modifications, as exemplified by Engineering Design Change Request (EDCR 81-47) and Plant Design Change Request (PDCR 4-81),
require the implementation of both the MY design control procedures and the installing contractor (NPS Energy Services) Quality Assurance procedures to assure the conduct of work in accordance with design.
Contrary to the above, as of November 1, 1982, work conducted on the plant modifications specified by EDCR 81-47 and PDCR 4-81 was in variance with the governing design control requirements in that standard minimum fillet weld sizes had been incorrectly translated into certain drawing details (eg: NPS-SKE-EDCR-81-47-103); the appropriate AWS quality standards for structural welds (eg: conduit supports) were neither specified, nor in use; and a field change to a structural angle affected by the PDCR 4-81 modification was accomplished without proper approval.
This is a Severity Level IV violation (Supplement I).
D.
10CFR50, Appendix B, Criterion IX requires the control of special processes, including welding to assure the use of qualified procedures in accordance with applicable codes and other specified criteria. Appendix B of the Maine Yankee Final Safety Analysis Report references a Quality Assurance Program which implements special process controls, specifically as discussed in the MY Operational QA Program Section IX.
Both the MY QA Manual and the NPS Energy Services QA Procedures Manual specify welding process controls, to include welding procedure qualification to the requirements of the ASME Boiler and Pressure Vessel (B&PV) Code,Section IX; weld data documentation in a Weld History Record; and inspection of weld joint installation to the applicable drawing details.
EDCR 81-11 and PDCR 4-81 require the utilization of the welding process in accomplishing specified plant modifications.
Contrary to the above, as of November 3, 1982, the welding processes in use on plant modifications, EDCR 81-11 and PDCR 4-81, were unqualified or otherwise inadequately controlled as evidenced by the following identified items:
-- Unqualified use.of Gas Tungsten-Arc Welding (GTAW) without filler metal, violating an essential variable of the ASME B&PV Code,Section IX (EDCR 81-11).
Appendix A 3
-- Misuse of a welding procedure to weld a double-Vee groove joint.
when procedural directions for single-groove joints only were specified (PDCR 4-81).
-- Inadequate verification of an installed weld joint to its drawing details (NPS sketch SKM-PDCR-4-81-112), resulting in a QA-accepted weld with penetration half as much as was detailed (PDCR 4-81).
-- Improper documentation of weld data for a joint where the Weld History Record identified only one of the two types of filler material actually used in the welding process (PDCR 4-81).
This is a Severity Level V violation (Supplement I).
E.
Technical Specification 5.11 requires procedures for personnel radiation protection to be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Procedure 9.1.10, Radiation Work Pennits, Revision 12, requires an air sample to be taken and requires respiratory protection devices to be worn whenever the potential for release of airborne activity exists while opening a radioactive system.
Contrary to the above, on October 14, 1982, Radiation Work Permit
- 82-10-688 authorized opening a radioactive system at valve WD 436; and no air sample or respiratory protection was prescribed or implemented. The poten-tial for release of airborne activity had been demonstrated by an unplanned release during similar maintenance on October 12, 1982.
This is a Severity Level V violation.
(Supplement IV.E.).
Pursuant to the provisions of 10 CFR 2.201, Maine Yankee Atomic Power Company is hereby required to submit to this office within thirty days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) the corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
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