ML20042B338
| ML20042B338 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/23/1982 |
| From: | Randazza J Maine Yankee |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20042B325 | List: |
| References | |
| MN-82-32, NUDOCS 8203250227 | |
| Download: ML20042B338 (4) | |
Text
1 a
m e usan onive MAIRE, MAHARHEE Aleml0 Pol'IER00MPARU, Nd AUGUSTA, MAINE 04336 1
c.
T? -
M (207) 623-3521 wO j
February 23, 1982
)
MN-82-32 thited States Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention:
Mr. Ronald C. Haynes, Director Re ferences:
(a) License No. DPR-36 (Decket 50-309)
(b) USNRC Letter to MYAPCO. Dated January 26, 1982
Subject:
Response to Inspection 50-309/81-31, Quality Assurance Inspection
Dear Sir:
In reply to the violation identified in the Notice of Violation, Appendix A of Reference (b), the following information is submitted:
Finding A 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawing, requires that activities affecting quality shall be presented by documented procedures appropriate to the circumstances and shall be accomplished in accord.ince with these procedures. The MY OQAP requires that the Operational Quality Assurance Department conduct QA surveillance of activities includin9 material control; control of special processes; and handling; storage and shipping of materials and parts.
Contrary to the above on November 2-6, 1981; the OQAD had not established written procedures for, or implemented QA surveillance of, the following activities:
8203250227 820319 PDR ADOCK 05000309 G
PDR f
M AINE YANKEE ATOMIC POWER COMPANY
,,,, Controls and issuance of materials, parts and components covered by the
- 00AP, Control of special processes, and handling, storage and shipping of materials, parts and components.
This is a Severity Level IV Violation (Supplement I)
Response
Maine Yankee recognizes the benefit of more formal surveillance activities being perfomed. Therefore, Maine Yankee will implement an " Internal Surveillance" procedure on or before May 15, 1982, whereby surveillance will be perfomed on a random basis for those activities identified in the Operational Quality Assurance Program as requiring surveillance.
A schedule will be developed as part of the procedure.
Finding B 10 CFR 50, Appendix B, Criterion X requires that inspections shall be perfomed by individuals other than those who performed the activity being inspected. Criterion IX requires that nondestructive testing shall be accomplished by qualified personnel and Criterion XVII requires that records shall include qualifications of those personnel.
The Maine Yankee (MY) Operational Quality Assurance Program (0QAP)Section II commits to ANSI N45.2-1977, which requires that inspection be performed by persons other than those who perfomed the work, and that those persons shall not report directly to the immediate supervisor responsible for the work.
The MY OQAP also commits to ANSI N45.2.6-1978, which requires qualification and certification of NDE personnel.
Contrary to the above, on July 19, 1981:
The NDE inspector who performed the Liquid Penetrant Test on the weld associated with Maintenance Request 1436-81 reported to the same immediate supervisor as the welder The NDE inspector's certification had expired in January,1980 This is a Severity Level V Violation (Supplement I)
Response
The R11ne Yankee Operational Quality Assurance Department will take over responsibility for performing Liquid Penetrant Examination (LPE) from the Maintenance Department.
Training for certification of LPE personnel is expected to be complete ey April 30, 1982.
?
MOIRE YANKEE QTOMIC POWER COMPANY
. Other Concern 1 We are concerned that the mine Yankee OQA Department staffing level is inadequate to effectively implement the quality assurance (QA) functions of inspection, surveillance and audit of safety related activities.
,Re sponse Maine Yankee recognized the need for additional QA personnel and requisitions were prepared in September 1981 and approved in October 1981. Recruiting and staffing began shortly thereafter for these additional personnel.
Three new personnel were on board by December 7,1981, bringing the total on-site staff to four and off-site staff to two.
Responsibilities of QA personnel have been specified to insure that the functions of inspection, surveillance and audit of safety related activities are performed.
As evidence of the effectiveness of these measures to date, for 1982, over fifty Independent Inspections have been initiated, some of which include surveillances, and three audits completed on schedule for the 1982 audit cycle.
Other Concern 2 We are concerned that the implemented QA functions of design verification and inspection do not exhibit the required independence.
Response
A.
Design Verification The requirement to perform an independent design verification is specified in Maine Yankee Procedure 0-01-1, Rev. 1, Para. 4.10 and Para. 7.3 for changes to design change documents.
The Operational Quality Assurance Department will perform a review, on a sampling basis, of design change documents and changes thereto to verify compliance with procedure 0-01-1.
Additionally, the scope of the review will cover design changes for 1979 through the present.
It is expected that the review will be complete by May 30, 1982.
B.
Inspection As stated abom in our response to finding 8, the Operational Quality Assurance Department will assume responsibility for liquid penetrant examination by April 30, 1982.
This will provide the required independence from the Maintenance Department.
M AINE YANKEE ATOMIC POWER COMPANY
.- - We trust that this information is satisfactory. Should you have any further questions, please feel free to contact us.
Sincerely, MAINE YANKEE ATOMIC POWER COMPANY A
John B. Randazza Vice President STATE OF MAINE
)
)ss COUNTY OF KENNEBEC )
Then personnally appeared before me, John B. Randazza, who, being duly sworn, did state that he is a Vice President of Maine Yankee Atomic Power Company, that is duly authorized to execute and file the foregoing request in the name and on the behalf of Maine Yankee Atomic Power Company, and that the statements therein are true to the best of his knowledge and belief.
AL Notary Public MY. Commission EXPlRCs OCJoBEll 27,1939 l
l I
s