ML20040G013
| ML20040G013 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/19/1982 |
| From: | Caphton D, Lazarus W, Napuda G, Swetland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20040G009 | List: |
| References | |
| 50-309-81-31, NUDOCS 8202110083 | |
| Download: ML20040G013 (9) | |
See also: IR 05000309/1981031
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
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Report No. 309/81-31
Docket No. 50-309
License No. DPR-36
Priority
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Category
C
Licensee: Maine Yankee Atomic Power Company
1671 Worcester Road
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Framingham, Massachusetts 01701
Facility Name: Maine Yankee Atomic Power Station
Inspection at: Wiscasset and Augusta, Maine
Inspection conducted:
November 2-6, 1981
Inspectors:
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Ge'/Na uda, Reactor Inspector
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(G LC64e+ Y
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W.<1 Eazarus) Reactor Inspector
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D.
wet
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Resident Inspector
date signed
Approved by: 4/ .,[/47[
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M
D. L. C&phton, Chief, Management Programs
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Section, Division of Engineering and
Technical Inspection
Inspection Summary:
Inspection on November 2-6,1981 (Inspection Report No. 50-309/81-31)
Areas Inspected: Routine, unannounced inspection by two region based inspectors
and the resident inspector of the Quality Assurance Program (QAP) implementation
including audits; design changes / modifications; offsite support staff; OA/QC
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administration; QA/QC surveillance; and followup on previously identified items.
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The inspection involved 61 inspector hours onsite by two region based inspectors,
12 inspector hours at the corporate office by a regicn based and the resident
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inspector, and 15 inspector hours in-office by a region based inspector,
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Results: Of the seven areas inspected no items of noncompliance were identified
in five areas and two items of noncompliance were identified in two areas
(Failure to establish and implement QA surveillance of specified activities,
paragraphs 5.b; maintenance workers performing NDE of each others welding,
paragraph 4. c).
Region I Fonn 12
(Rev. April 77)
r202110083 820126
PDR ADOCK 05000309
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DETAILS
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1.
Persons Contacted
- C. Frizzle, Manager, Nuclear Support
- J. Hebert, Director, Plant Engineering
- A. Jordan, Operation QA Coordinator
R. Jutras, Plant Engineer
- R. Lawton, Director, Operational QA
- J. Randazza, Manager of Operations (Vice President)
- D. Sturniolo, Assistant to Plant Manager
- E. Wood, Plant Manager-
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- Denotes those present at the exit interview conducted on November 6,
1981.
The inspectors also contacted and interviewed other licensee employees
including staff engineers, technicians, and administrative and operations
personnel.
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2.
Licensee Action on Previous Inspection Findings
(Closed) Unresolved Item (309/79-16-02):
Revise appropriate procedure to
clarify that QA personnel can initiate NCR for non audit discrepancies.
This item is closed for record purposes as the new Operational Quality
Assurance Program (0QAP) and implementing procedures now address the issue.
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(Closed) Unresolved Item (309/79-16-03): Scope, authority, duties and-
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responsibilities of PEQAG to be addressed in a procedure. This item is
closed for record purposes as the new organization does not retain this-
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group nor does the new 00AP make provisions for such a group.
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(Closed) Unresolved Item (309/79-16-05) Control of Temporary Procedures.
Licensee control measures for temporary procedures are specified in Quality
Assurance Procedures 0-06-1 Procedure Preparation, Classification, and
Format; Revision 0, dated 8/28/81 and 0-06-02 Procedure Review, Approval
and Distribution; Revision 0, dated 8/28/81.
The inspector verified that
temporary procedures are controlled in accordance with the above procedures
and that expiration dates are specified and observed. The inspector reviewed
the active temporary procedures (4-112 through 4-123); no items of non-
compliance were identified, this item is closed.
(0 pen) Unresolved Item (309/79-16-06) NRC to review revised licensee procedure
classification. The inspector reviewed Quality Assurance Procedure 0-06-
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01, Procedure Preparation, Classification, and Format, Revision 0 dated
8/28/81. The inspector identified that procedures classified in accordance
with the above procedure may be in conflict with the procedural requirements
of Technical Specification 5.8, ANSI N18.7, and Regulatory Guide 1.33.
For
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example, Chemistry Department analytical procedures for safety-related
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analyses require Onsite Committee review and Plant Manager approval at two
year intervals.
Procedure 0-06-01 specifies a 4 year review cycle'by the
department head for such procedures. The licensee stated that Procedure 0-
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06-01 would be revised to remove conflicts with these other regulatory
requirements and that required changes to plant procedures would be accom-
plished prior to the next annual quality assurance program review.
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3.
QA Program
a.
Introduction
The Maine Yankee organization has established a QA program that is
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designed to be controlled and implemented by Maine Yankee. This
represents a significant departure from the past concept of QA at MY
which relied heavily on the Yankee Atomic Electric Company, Nuclear
Services Division (YAEC-NSD). Maine Yankee developed an internal
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Operational Quality Assurance program (0QAP) which was submitted to
the NRC for review. A primary goal of this inspection was to determine
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the adequacy of implementation of this new MY 00AP concept. The new
concept was implemented by MY in September of 1981 and therefore this
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inspection concentrated on the implementation and effectiveness of
the 0QAP since September 1981.
b.
References
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-- 0-00-3, Audits, Rev. 0
-- 0-00-8, Housekeeping, Rev. 0
-- 0-06-1, Procedure Preparation, Classification and Format, Rev. 0
-- 0-06-2, Procedure Review, Approval and Distribution, Rev. 0
-- 0-08-4, Discsepancy Reports, Rev. 0
c.
Program Review
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The inspector reviewed at the Region I office the changes made to the
organization, the above referenced procedures, and procedures references
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in other paragraphs of this report identified by an asterisk to
ascertain that they were consistent with the QA Program as described
in the Maine Yankee Atomic Power Company (MYAP) Operational Quality
Assurance Program (0QAP), Revision 1, that was accepted by the NRC
(with two outstanding exceptions).
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Quality Assurance Procedure 0-01-1 Design Change Alteration, Revision
0, describes the method for making changes to approved design change
documents.
Paragraph 7.3.2, which requires concurrence of proposed
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changes to design documents, does not insure independency of review as
specified by 10 CFR 50 Appendix B and ANSI N45.2. The procedure as
written permits the initiating engineer of 3 proposed change to also
concur in the proposal which circumvents the in. dependent review. Tre
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licensee stated that the intent of procedure 0-01-1 was to require
independent review and that the procedure would be clarified.
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As a preventive measure to possibly eliminate future problems, the
inspector discussed the need for clarity in procedures related to
audit response time and use of uncontrolled drawings. Other paragraphs
of this report discuss concerns with the implementation of the QA
Program.
d.
Organization
The Operational Quality Assurance Program described key organizational
responsibilities and major functions, and provided organization charts.
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The licensee recently developed manpower organization charts and job
descriptions that detail individual duties and responsibilities for
the Administrative, Nuclear Engineering and Licensin'g, Training,
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Quality Assurance, Plant Engineering, and Operational Support Depart-
ments.
The MY OQAP is in a transition wherein Operational Quality Assurance
responsibility is being assumed by the MY organization.
Previously,
much of the 00AP implementation had been accomplished by Yankee Atomic
Electric Company (YAEC). MY retains the YAEC on a contractual basis to
supplement the MY staff to assure implementation of OQAP commitments.
The inspector reviewed the MYAP Policy for Interaction Between Yantee
Atomic Electric Company, Nuclear Services Division (YAEC-NSD) and
Maine Yankee Atomic Power Company, November 1980. This document
describes organizational relationships; communications; support services;
use of outside contracted services; FSAR and drawing maintenance and
update; cost control; authorized responsibilities; and, communications
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and correspondence with the NRC.
Another document, the Contract Between Yankee Atomic Electric Company'
and Maine Yankee Atomic Power Company, detailed man-hour services;
assignment of traditional services to others; term of the agreement
(three years); automatic renewal (two years); reduction in agreement
scope (can be exercised with cne year notice as long as it is less
than 10% of the average man-hours for the preceeding three years);
and, types of services.
The QA Department staffing to implement the crganization is discussed
in paragraph 8b.
e.
QA/QC Administration
The inspector reviewed the referenced documents to verify that:
-- The scope and applicability of the QA Program were defined
-- Appropriate guidance was provided by the procedures for the intended
area
-- Adequate implementation of the procedures would fulfill QA Program
requirements
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-- Management controls and overview were addressed
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-- Authority and responsibility for each QA position was specified
Staffing level ~and program implementation are discussed in other
paragraphs of this report.
4.
QA Inspections
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a.
References
- -- 0-00-4, Safety Classification of Systems, Components, and Structures,
-- 0 Ob
, Independent Inspeciion, Rev. 0
,, -- 0-07-1, Installation and Maintenance of Safety Classified Systams,
Components, and-Structures, Rev. 0
- -- 0-07-2, Control of Special Processes, Rev. 0
- -- 0-07-3, Maintenance Requests, Rev. O
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b.
_ Implementation Review
The inspector reviewed onsite records of maintenance activities from
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September 11, 1981 until October 30, 1981 to verify that safety related
maintenance activities were being controlled in accordance with the
Maine Yankee Operational Quality Assurance Program as implemented by'
the above procedures.
The inspector's-findings are:
A total of 214 completed maintenance requests were reviewed. Of
these, 32 involved safety class, Class IE, or QA related-equipment.
Only-one of the 32 included independent inspection by the QA Department.
Although the QA Department reviews each Maintenance Request to determine
whether independent inspection is required, there are no guidelines in
plant procedures to determine which activities will receive independent
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inspection. This low percentage of independent inspections being
performed, combined with the lack of any routine surveillance of
maintenance activities is objective evidence of inadequate implementation
of the approved Qual.ity Assurance Program. -
The failure to perform a meaningful number of independent QA inspections
and to incorporate guidelines in plant procedures regarding activities
to receive independent inspections is an unresolved item (50-309/81-
31-05) and considered to be a major weakness in the MY 0QAP.
c.
Independence of QA Inspection Function
Review of documentation associated with Maintenance Request 1436-81,
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(Letdown Line Weld Repair July 19,1981) was made to determine whether
QA Program requirements were being met and QA independence was being
maintained.
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The inspector's findings are:
-- The NDE examiner who performed the LP inspection on the
weld, reports to the same immediate supervisor as the
welder.
This is contrary to the requirements of ANSI
N45.2-1977Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2-1977" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., "QA Program Requirements for Nuclear Facilities"
(Section II)
-- The qualifications of the NDE examiner were not reviewed
by the Operational Quality Assurance Department as required
by Section X, paragraph h of the Maine Yankee Operational
Quality Assurance Manual
-- The NDE examiner's certification to perform LP testing
had expired in January, 1980
The above three examples constitute a violation with 10 CFR 50,
Appendix B, Criterion X, which states in part, "A program for
inspection activities affecting quality shall be established and
executed ...." (50-309/81-31-02).
5.
QA Surveillance
a.
References
-- MYAP Operational Quality Assurance Program (00AP), Revision 1
b.
Implementation
The inspector noted that implementing procedures failed to address QA
surveillance activities.
Discussions and interviews with licensee
representatives confirmed this to be the case and further, identified
that the licensee did not establish or implement a system of QA surveil-
lance for ongoing activities.
This is contrary to the 0QAP which states in part, "The Operational
Quality Assurance department shall be responsible for:
a. Surveillance,
audit and/or inspection of the controls and issuance of materials,
part, and components covered by the Operational Quality Assurance
Program."(Section VIII.B.1); "The Operational Quality Assurance Depart-
ment shall be responsible for:
A. Providing surveillance, audit
and/or inspection of the control of special processes."(Section IX.B.1);
"The Operational Quality Assurance Department shall be responsible
for: a. Providing surveillance, audit and/or inspection of the handling,
storage, and shipping of materials, parts, and comp eents."(Section
XIII.B.1).
Several other sections also require surveillance of appli-
cable activities by QA.
The failure to establish and implement a system of QA surveillance is
an item of noncompliance with 10 CFR 50, Appendix B, Criterion II,
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which states in part, "This program shall be documented by written
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policies, procedures, or instructions and shall be carried out throughout
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plant life in accordance with those policies, procedures or instructions."
(50-309/81-31-03).
6.
Mdits
a.
References
-- Applicable procedures in paragraph 3.a
b.
Implementation
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The inspector reviewed 1980 and 1981 Inplant Audit Summaries (schedules)
and noted that only six of the ;cheduled 17 audits for 1981 had been
- conducted to date. The inspector also reviewed each completed audit
cover sheet to determine man days expended on these audits. The
inspector then determined that the 11 audits yet-to be conducted would
require approximately 34 man days.
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The above was discussed with the Director-QA who stated that two
audits were in process and the others would be completed within the
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required time period. The Director-QA also stated-that MYAP intended
to continue using YAEC-NSD for 10 CFR 50 Appendix B and Technical
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Specifications required audits (see paragraph 3.c).
The insper. tor stated that the technical adequacy of audits would be
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reviewed during a future routine inspection.~ The inspector questioned-
the licensee regarding the ability of the audits as scheduled to meet
the intent of ANSI 18.7 paragraph 4.5 "To verify compliance with all
aspects of the administrative and-quality assurance program" since on.lv
six of the scheduled 17 audits for 1981 had been conducted as of
November 6.
The matter of not performing timely audits that will
verify compliance with all aspects of the QA program concurrent with
the conduct of the on going activities is considered a weakness in the
program and is unresolved (50-309/81-31-06).
7.
Design Changes / Modifications
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References
- -- 0-01-1, Design Change Alteration, Revision 0
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- -- 0-01-2, Document Revision, Revision 0
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b.
Implementation
The inspectors selected and reviewed-the design changes listed below
to verify, as applicable, that: they were accomplished in accordance
with 10 CFR 50.59 and the licensee's QA Program requirements; code
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requirements and specifications were included; records of equipment
performance were reviewed and accepted; and, prints / drawings and
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operating procedures were revised (a sample).
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The following modification packages were reviewed.
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-- EDCR 81-16, Safety Injection Header
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The inspector also reviewed the log of outstanding /open modificatices
and noted that a significant portion had the. work completed in 1981
and only two were of 1979 vintage.
c.
Drawings
The inspector noted instances-where the dissemination of as-built
information to holders of controlled drawings affected by modifi-
cations was not performed in accordance with established procedures.
The inspector also noted clerical errors in the annotation of drawings
affected by modifications.
The inspector stated that the cause for the noted errors appeared to be
the result of insufficient manpower. The licensee stated that this
had been recognized and additional personnel had been authorized for
this area within the past few days.
The inspectors reviewed a sample of full size drawings used in the
Control Room for operations activities.
The inspectors verified.that
recent modifications were correctly depicted on these drawings.
The licensee stated that as a result of a recent.INPO inspection and
plant experience the system of providing as-built information to those
who have immediate need of it had been revised to the present method.
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Other document / drawing control practices have been affected and are in
need of revision. The licensee stated that the current practices will
be clearly defined in appropriate procedures or revisions to existing
procedures by January 1, 1982.
This item is unresolved pending review of 1icensee action (50-309/81-
31-04).
8.
Review of Staffing and Support
a.
Off Site Support
A review of the offsite support staff was conducted by the inspectors
which included procedure reviews, reviews of personnel qualifications,
and procedure implementation to verify the following.
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Administrative controls which describe the eesponsibilities, authori-
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ties and l'ines of communications have been develooed and are readily
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--Theapplicablereferencedproceduresin+subdaragraphsofother
paragraphs in this report are in conformance yith the ' requirements
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of, C3 CFR'50,' Appendix B and the licensee's approved QA Program
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-- The managers, and group leaders are aware of their responsibilities
and' authorities as defined by the applicable re'ferenced procedures
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-- The personnel which comprise the offsite support. staff are qualified
toexecutethe7esponsibilitiesdefinedbytheapplicablereferenced
procedures
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' Based on the above rertie'w, no jiolations were identified.
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QA Department
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A reyiew tof the currer,tistt#f3ng of the QA Departnie/.t indicated a
Inrea man staff: A QA Engi'neer (corporate offick); an 07.erational
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Qm . Quali'ty Assurance Coordinator (on site); and a Dfrector-Operational
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All work including review of Maintenance Requests) and design changes /
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modifications, and performance of receidt inspections,and independent
insp?ctions must be accomplished by the latt ~ two inbividuals. The
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inspector expressed his concern regarding
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the QX Program with the existing staff.
exit interview, the
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Vice President and Manager of Operations acknowledged the inspector's
conce'rns and indicated that they were in the process of adding a
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Senior 00A Coordinator and two QC inspectors to the plant staff to
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improve the plant QA capabilities.
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t-This item.is unresolved pending further review of the adequacy of the
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implementation of the QA Inspection System (50-309/81-31-01).
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t)hresolved Items
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' N Unresolved ' Items are mati.ers about which more informat}c[ is hhquired in
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ordertoascertainwhethertheyareacceptableitems;bilasp,ectionare..
tems of noncompliance
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or deviations. Unresolvedkitems identified during thi
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discussed in paragra Ssd.b. , 6.b. , 7 c. and 8.b.
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Exit Interview
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The inspectors met with licensee repre entatives (denoted in paragraph 1)
at the conclusion of the' inspection on November 6, 1981.
The qcope and-
findings of the inspection as stated in this reportswere presented, and
licensee representatives confirmed the specific date contained within this
report as applicable to the specific action.
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