ML20053D351
| ML20053D351 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 05/20/1982 |
| From: | Blumberg N, Caphton D, Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20053D349 | List: |
| References | |
| 50-309-82-06, 50-309-82-6, NUDOCS 8206040331 | |
| Download: ML20053D351 (13) | |
See also: IR 05000309/1982006
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U.S.NUCLEIRREGULATORYCOMMISSION
REGION I
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feport No. 50-309/82-06
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Docket No. 50-309
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License No. OPR-36
Priority
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Licensee: Maine Yankee Atomic Power Com;iany
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83 Edison Drive
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Augusta, Maine 04336
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Facility Name: Maine Yankee Atomic Power Station
Inspection at: Wiscasset, Maine
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Inspection condu ed: April _19-23, 1982
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Inspectors:
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Reactor Ins ~pector.
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Approved by:
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5.'L.~Ca)ht6n, Chief, Management
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Programs Section-
Inspection Summary: :InspectiononApril'19-23,[1982(R ort No. 50-309/S2-06)
Areas Inspected:
Routine, unannounced inspection by two region-based inspectors
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of licensee action on previous inspection findings; maintenance activities;
calibration activities; and plant teur. The' inspection involved 68 inspector-
hours onsite by two region-based inspectors.
Results: Of the four areas inspected, no violations were identified in three
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areas and one violation was identified in one area (Violation - Failure to
properly control, review and approve changes to controlled drawings
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2).
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8206040331 820521
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PDR ADOCK 05000309
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DETAILS
1.
Persons Contacted
R. Arsenault, Operations Department Head
- R. Bickford, Assistant to Operations Department Head
J. Brinkler, Technical Support Department Head
- F. Gleason, Maintenance Department Section Head
- J. Hebert, Director, Plant Engineering
- A. Jordan, Operational Quality Control Coordinator
" R. Lawton, Jr., Director, Operational Quality Assurance
- R. Radasch, Instrument and Control (I&C) Department Section Head
L. Speed, Lead Performance Engineer
J. Weast, Plant Shift Superintendent
- E. Wood, Plant Manager
P. Swetland, Resident Inspector
The inspectors also interviewed other licensee employees including members
of the engineering staff, quality control inspectors, I&C technicians,
maintenance personnel, and reactor operators.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings
(Closed) Unresolved Item (81-31-04):
Plant procedures require revisions to
clearly define current practices by which as-built information as a result
of modifications is placed on Control Room drawings as soon as possible
following the modification. The licensee stated that this would be done by
January 1, 1982.
The inspector verified that Control Room drawings (flow diagrams) were
being updated on an interim basis by the Engineering Department pending
final revisions to the drawings.
However, the plant procedures which were
to be revised, although revised in draft, had not yet been issued. The
inspector observed that Control Room drawings which had been temporarily
revised by an engineering draftsman received no additional review or approval
before being placed in the Control Room. The drawings were either revised
by pen and ink change or the sepia and blueprint had been revised. The
licensee stated that revision of the sepia and blueprint was now the current
method for making interim changes.
During the review of the Control Room drawings, the inspector noted, that
in addition to interim drawing changes as a resuit of modifications, drawing
changes were being made to reflect as-built conditions in the plant which
were different than that depicted on the drawings. These were made to both
safety and non-safety class drawings.
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g % , Handwritten changes not associated with current plant modif fcations', were observed-on the following drawings:
, ' 11550-FM-96A, Pr'imarbSampling Systems Piping,' Valves PR-18,'PR-19, [ -- and PR-20 were added to the drawing tG shew interfdce tc. phssurizer; i and PS-9, PS-10,N and'PS-11 position designations were changed on the
drawing from closed to open and PS-T changed from cpen,to closed - (safety class valves); A s I I 11550-FM-101QNidcellan'eob Safety Systems, - Vsives CH 119S,120S, -- l , and 121 were redesignated on the drawing as CH 1205,:119S, 121, y aie 122 v'especti.v(ly and pipe designations CH-309, 310, 311, and 312 v re added to thb charging pum'p suction _ header to vent system on the drawing (safety class piping and valves); ' 3 11550-FM-70A,IM n' Steam Piping, - Valve MS-161 was redesignated on -- the drawing as MS-M-161 to reflect the metor operator (Safety Class Valve); L1 ' < . ~ V 4 -- 11550-FM %A, Boron Recovery Piping, lhhmbeMd, valves were added to s ~drawivior the liquid radwaste portion of system to provide connectior;,, points for rc portable deminceslizer (Safat'y Class flaives); 7 o; q , 11550-FM-78BJ Secondary Component Cooliry Piping, i Valves SCC 331'and -- SCC 327,werer[deletedfromthedrawing(non-safetyclassvalves); <* _ .. . - 115504H-818, Diagram Compressed Air and Containment Leakage Monitoring -- Piping, - Valve IA-87 was deleted f m the drawing (non-safety class); . 1 ' 11550-FM-82A, Make'up Water Treatment Piping, - Valve (unnumbered) vas -- added to the drawing (non-safety class). Additionally, the valve was added to the system without use of a formal plant alteration; J.7 ~ ' ' l'.5_50-FM-84A, Gland Seal and Miscellaneous Turbine Pip'ing, - two y . Op -- valves (unnumbered) and a pressure gage and isolation _ valve werrMadded to the drawing (non-safety class); and valve GS-95 w & changed on;the; drawing from a pressure regulated valve to a manual ulve. Additionally, u . the two valves were added to the system without use of" plant alterati'on; ', .s , 11550-FM-85A, Secondary Plant Sealing Piping, - Shaft' seal instru- ' -- mentation and associated piping was added to the drawfeg.'(non-safety class); ' -- 11550-FM-91B, Chemicab and Voltme Control in Containmcet?and HP Safety,. b Injection System Piping, - four valves were added to drawing to show interface with other systems (non-safety class pcetfodiof drawing); _, f ,: -- 11550-FM-92A, RHR Containment Spray and Low Pressure defety Injectjon Piping, - Containment spray header' drain lines were reroviedt fourn~ level instruments were renumbered; and numbers were added tb th-de level instruments on the drawing (safety class nct deterdined); an'd, , 3 h u , l. g , & \\ ' .
. . 3 11550-FM-938, Primary Vents and Drains Piping, - Valve PD-234 was -- added to drawing (non-safety class portion of system). The above changes were added by operators or engineering staff at the request of operators; and were made without review for adequacy or approval by authorized personnel. Additionally, no system in effect to assure that other controlled drawings would also be updated. The inspector also reviewed procedures 0-01-1, " Design Change / Alteration", and 0-01-2, " Document Revision Procedure", and their draft revisions, and determined that they were deficient in the following areas: No provisions were made to review and approve interim changes to -- controlled drawings in Control Room which were made as the result of design changes; No provisions were made as to the method by which interin changes to -- Control Room drawings would be accomplished; and, No provisions were made to review for adequacy and properly approve -- drawing changes which are made to reflect as-built conditions not previously identified on drawings nor to assure all controlled drawings would be changed to reflect newly identified as built conditions. Prior to the conclusion of the inspection, the licensee verified the accuracy of all unreviewed drawing changes observed by the inspector except valves and piping which were inaccessible due to plant operation. Based on the above observations, the inspector determined that the licensee's corrective action for this unresolved item had not been satisfactory. This unresolved item is closed and is now considered a violation, since failure to review for adequacy and properly approve changes to drawings of safety class systems and failure to provide procedures which adequately control drawing changes is contrary to 10 CFR 50, Appendix B, Criterion VI, and ANSI N45.2 (309/82-06-01). The licensee concurred with inspectors finding to the extent that the violation applied to safety class portions of systems only; however, the licensee stated that corrective action would be taken for all controlled drawings both safety and non-safety class. During a subsequent telephone call conducted between Mr. L. Frizzle of the licensee's staff and Mr. N. Blumberg on April 28, 1982, the licensee stated that corrective action was already in progress. (Closed) Unresolved Item (79-16-04): Review cycles were not specified for corporate office procedure series such as 0QA, WE, welding and non-ISI NDE. The inspector verified that appropriate administrative procedures have been revised to require that 0QA and WE procedures De reviewed at least every two years and that welding and NDE procedures be reviewed following major
. . 4 addition revisions of the ASME Boiler and Pressure Vessel Codes, which occur every three years. Based on the above this item is closed. (0 pen) Violation (81-31-03): Licensee failed to establish and implement a QA surveillance program. The licensee, in its response, stated that a QA surveillance program would be established by May 15, 1982. The QA Department Head informed the inspector that the QA surveillance program procedure was still in draft form. In the interim, he stated that the QA Department was using random QC inspections in accordance with procedure 0-00-7, " Independent Inspection", as a temporary substitute for QA surveillance program. The inspector determined, based on a review of QC inspection records, that there is currently a significant amount of random QC inspection of various plant activities. However, the QC inspection program is limited in scope and is not a substitute for a QA surveillance program. This item remains open pending completion of licensee action. (0 pen) Unresolved Item (81-31-01): The QA Department consisted of only three people which was inadequate to perform the required QA and QC functions. Additionally, in the Inspection Report cover letter, dated January 26, 1982, the following concerns were detailed: "(1) Maine Yankee OQA Department staffing level is inadequate to effectively implement the Quality Assurance (QA) functions of inspection, surveil- lance and audit of safety related activities, and that (2) the imple- mented QA functions of design verification and inspection do not exhibit the required independence." The licensee stated in its response to item (1) above that the QA Department staff had been increased to six persons including the Department Head. The inspector verified that the QA staff is currently at six persons with four persons assigned directly to the plant. The QA Department is currently in the process of obtaining authorization for two additional QA positions. The current staffing level appears to be at the minimum level needed to carry out QA and QC functions except for formal audits. Performance of formal audits is currently contracted to Yankee Atomic Nuclear Services (YANS) with followup performed by the QA staff. Based on the above, this aspect of the item is closed. In its response to item (2) above, the licensee stated that the QA Department will perform a review, on a sampling basis, of design change documents and changes there to, to verify compliance with procedure 0-01-1, " Design Change / Alteration". The audit is to cover design changes from 1979 to the present and is to be completed by May 30, 1982. The QA Department Head informed the inspector that the above review had not yet started because r'. aner priorities. He further' stated that the extent of QA participation les ruture design change reviews will depend on the results of the audit. This aspect of the item remains open pending completion of licensee action. '
. . 5 (Closed) Unresolved Item (81-31-06): Audits were not being performed in a timely manner, in that, as of November 6,1981, only six of seventeen audits scheduled for the year 1981 had been performed. The inspector verified that the remainder of the 1981 audits were completed during December of 1981. Additionally, eight of seventeen audits scheduled for 1982 have been completed. The inspector verified that 1982 audits are being performed on schedule and audit reports are issued in a timely manner. A review of the available audit check lists for the audits performed in 1982 indicates that the audits are comprehensive. Also, the audits identify weak areas which may not be noncompliances to regulatory and procedural requirements. Based on the above, this item is closed. (Closed) Unresolved Item (80-17-02): Failure to document the personnel performing preventive maintenance (PM) work and inadequate procedural control in this area. The inspector reviewed maintenance procedure 5-207- 6, " Administration of the Preventive Maintenance Program", Rev. 3, July 21, 1981. Step 4.3.2 specifies that "the individual who conducted the work shall sign the (PM History) card acknowledging satisfactory completion". The inspector reviewed twelve Preventive Maintenance History Cards, all of which were properly signed by the worker for all PM work entries in 1981 and 1982. Based on the above, this item is closed. (0 pen) Unresolved Item (81-31-05): Failure to perform a meaningful number of independent inspections and to incorporate inspection guidelines in the plant procedures. The inspector reviewed the recent quality control (QC) k inspections of maintenance, as described in paragraph 3. Because of the increased QC staffing and increased emphasis on thorough, detailed inspections, the inspector found that the independent inspections now cover a significant portion of the safety-related maintenance. This phase of the item is closed; however, the inspector found the implementation of inspection hold points and notification points per procedure 0-00-7, " Independent Inspection," Rev. O to be poorly described and inconsistently performed. Procedure 0-00-7 defines hold points and notification points and states that plant workers must adhere to them. However, there is no guidance as to how to verify completion of the inspection points in the maintenance work instructions or where the sign-off of these inspection points should be made - e.g., in the maintenance procedure or in the QC inspection report. The inspector found examples of widely varying implementa- tion and sign-off of inspection points. The inspector informed the licensee that he should clarify this area and document the proper implementation methods in a suitable procedure. The licensee representative agreed to do this. This unresolved item continues to be open pending further licensee action and subsequent NRC:RI review. t
. . 6 3. Mainten&nce Program a. Requirements The program for conduct of safety-related maintenance was inspected against the following: Technical Specificatic9s - Section 5 (Administrative Controls); -- Regulatory Guide 1.33, " Quality Assurance Program Requirements -- (Operation)", February,1978; and ANSI N18.7-1976, " Administrative Controls and Quality Assurance -- for the Operational Phase of Nuclear Power Plants". To the above requirements, The inspector reviewed the attributes of the program for: -- Administrative controls were established; Program responsibilities were designated; -- -- Procedures for inspection and records of activities were esta- blished; -- Preventive maintenance schedules were established; -- Control of special processes were established; and -- Equipment control methods were established. b. Implementation The implementation of the maintenance program was reviewed to confirm that the performance of the maintenance work met the following: -- Technical Specification requirements were satisfied while equipmeat was out of service; Selected maintenance activities had been conducted in accordance -- j w!th administrative procedures; -- An approved procedure was used for those maintenance activities which could be considered beyond the skills normally possessed by qualified maintenance personnel; Inspections of maintenance activities as required by administrative -- procecures were performed; and, i t
. . 7 Records to substantiate quality of work and parts used were -- available. The inspector observed the following safety-related maintenance work: Measurement of check valve internals on Secondary Component -- Cooling valve (SCC) 14 under Maintenance Request (MR) 975-82; -- Cleaning of heat exchanger E-5B in Primary Component Cooling (PCC) system under MR 923-82; and, -- Relocation of Cardox line due to Plant Design Change Request (PDCR) 1-82 under MR 856-82. Additionally, the inspector discussed performance of maintenance activities with maintenance workers and quality control inspectors, c. Administrative Controls The inspector reviewed the following licensee administrative control procedures (all identified as Rev. O, August 28,1981): 0-00-7, Independent Inspection; -- -- 0-00-8, Housekeeping; 0-06-1, Procedure Preparation, Classification, and Format; -- 0-06-2, Procedure Review, Approval, and Distribution; -- -- 0-06-3, Preoperational Operational, and Special Tests and Expert- ments; -- 0-06-5, Measuring and Test Equipment; 0-07-1, Installation and Maintenance of Safety Classified System -- Components or Structures; 0-07-3, Maintenance Requests; -- i -- 0-07-5, Cleaning Procedure; and 0-08-3, Administration of Non-routine Corrective Maintenance. -- d. Maintenance Procedures Maintenance work procedures (all dated January 6, 1982) reviewed were: -- 5-15-1, Plugging of Steam Generator Tubes and Repair of Tube to Tube Sheet Leaks, Rev. 3; i -
-_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ . . 8 5-19-1, Restoration of Pressurizer Safety Valve Seating Surfaces, -- Rev. 0; -- 5-38-2, Routine Corrective Maintenance, Rev. 2; -- 5-45-2, Assembly of Containment Spray Pump, Rev. 0; -- 5-46-2, Non-routine Corrective Maintenance, Rev. 1; and, 5-50-2, Replacement of LPSI Pump Mechanical Seals, Rev. 1. -- e. Records of Maintenance Work Records of maintenance work, including Maintenance Requests (MR) reviewed were: -- Control Room MR Log, entries from March 17, 1982 to April 21, 1982; MR 1699-80, October 31, 1980, Reassembly of Containment Spray -- Pump P-61B; -- MR 704-82, March 24, 1982, HPSI Valve Stem Stops Repair; -- MR 706-82, March 24, 1982, SCC Pump Shaft - Excessive Movement; MR 709-82, March 25, 1982, Containment Purge Valve - Repair to -- Pass LLRT; MR 796-82, April 2,1982, Chemical Addition Tank Heat Tracing; -- and, -- MR 878-82, April 8, 1982, Diesel Generator 1A Relay Replacement f. Inspection , QC inspection of safety-related maintenance work reviewed included. l l 1982 QC Discrepancy Report Log; -- -- 1982 Independent Inspection Log; and, -- Fourteen Independent Inspection Reports (82-149, -152, -153, -154, -156, -165, -166, -173, -174, -175, -176, -178, -179, and -180) g. Findings No violations were found in the areas of implementation, administrative controls, procedures, or records, however, an inspector finding (unre- _ - _ - _ _____ _ __ .
l - I 9 solved item) concerning inspection hold points is discussed in paragraph 2 of this report, see item (309/81-31-05). 4. Calibration a. Requirements The requirements for the conduct of calibration of safety-related equipment are referenced in paragraph 3.a. . The licensee administrstive controls which apply to calibration are contained in the procedures referenced in paragraph 3.c plus procedure 0-10-2, Surveillance Tests and Records, Rev. O, August 28, 1981. b. Calibrations Required by Technical Specification (TS) The TS Section 4, requires specific periodic calibrations be performed. These calibrations and the procedures describing them were inspected to verify: -- TS calibration frequency requirements were satisfied; Applicable system status during component calibrations are in -- conformance with TS limiting condition for operations, where applicable; -- Procedure format included stepwise instructions in the degree of detail necessary for performing the calibrations as required by ANSI N18.7-1976; Procedure review and approval were as required by TS; -- -- The technical content of procedures was sufficient to result in satisfactory component calibration and TS limits and setpoints were met; and, Calibration data was adequately and accurately recorded and was -- within established tolerances. The inspection sample consisted of the following procedures and data: -- 3-6.2.1.1, Protective and Safeguard Channel Calibration - Pres- surizer Pressure (required during refueling outages) Revision 5, February 18, 1981; Data reviewed for calibrations completed on July 14, 1981 and January 23, 1980; -- 3-6.2.1.4, Protective and Safeguard Channel Calibration - Reactor Coolant Flow (required during refueling outages) Revision 7, February 18, 1981 ; Data reviewed for calibrations comple'ed on t July 12, 1981 and March 9, 1980; --
_ _ . . 10 --' 3-6.2.2.0, Monthly Instrumentation Surveillance Tests, Rev. 6, March 30, 1981; Data reviewed for tests completed on April 7, 1982, March 5,1982, and February 12, 1982; 3-6.2.2.2, Reactor Coolant Flow (Monthly Channel Functional -- Test), Rev. 6, May 8, 1981; Data reviewed for tests completed on April 6, 1982, March 4, 1982 and February 11, 1982; 3-6.2.2.4, High Pressurizer Pressure (Monthly Channel Functional -- Test), Rev. 6, May 8,1981; Data reviewed for tests completed on April 7, 1982, March 4, 1982, and February 11, 1982. c. Calib ations of Instruments and Gauges Used to Satisfy Technical Specification (TS) Requirements The TS has various requirements on the parameters of safety-related equipment. The licensee has a program for the calibration of the instrtments and gauges used to satisfy these TS requirements (the calibrations are not specifically delineated in the TS). The inspector reviewed the licensee's program for these calibrations to verify that: -- Established calibration schedule and frequencies are being_followed;
-- Procedures have been reviewed and approved in accordance with TS contain acceptance criteria consistent with TS requirements, and contain detailed instructions commensurate with the complexity of the calibration; -- The technical content of procedures is adequate to perform satis- factory calibration; and -- Calibration data was adequately and accurately recorded and was within established tolerances. The inspector reviewed the following: -- 1982 schedule for TS referenced and calibrations; -- 3-6.2.1.31, " Tech Spec Referenced Limiting Condition for Operation (LCO) Instrumentation Scheduling and Recalibration Program", Rev. 3, December 31, 1981; Data Sheet (3-6.2.1.31), Circulating Water Forebay Temperature -- (Instrument #TT-1623A) Calibration, April 21, 1982; -- Data Sheet (3-6.2.1.31), LPSI Flow to Loop 2 Calibration, April 23, 1981; -
. - 11 Data Sheet (3-6.2.1.31), Quench Tank Level Calibration, April 30, -- 1981; and, Data Sheet (3-6.2.1.31), VCT Level Calibration, December 10, -- 1980. d. Calibration and Control of Test Equipment The licensee program for calibration and control of test equipment was reviewed to verify: -- Test equipment is being controlled in an acceptable manner and in accordance with licensee procedure 0-06-5, Measuring and Test Equipment; -- Calibration frequency has been met and accuracy verified; -- Accuracy in traceable to the National Bureau of Standards or other independent testing organizations; and, Storage and control of the test equipmenat is proper. -- The inspector reviewed the following test equipment records: -- Controlled Equipment List, April 7, 1982; Test Equipment Log; -- -- Digital Multimeter 62-139, log sheet; RPS Digital Multimeter, Channel C, 62-087, log sheet; -- -- Test Equipment Calibration on Multimeter 62-042 performed on April 13, 1982; and, -- Test Equipment Calibration on RPS Digital Multimeter, Channel C, 62-087, perfoimed on May 12, 1981. e. Findings The inspector found no violations in the areas of requirements, TS calibrations, and calibration and control of test equipment. In the area of calibration of instruments used to satisfy TS requirements the inspector identified one discrepancy. These calibrations are administratively controlled by procedure 3-6.2.1.31 " Tech Spec Referenced Limiting Condition for Operation (LCO) Instrumentation Scheduling and Recalibration Program", Rev. 3, December 31, 1981. This administrative procedure describes the general structure of the program and provides a general procedure to do the calibrations and data sheets on which to ._.
. . . 12 record the calibrations. However, the procedure does not specify which instruments are covered under this calibration program, the frequency on which they are to be calibrated, or the range and setpoints to be covered during their calibration. Therefore, this information is not reviewed and approved as part of the station management approval ' of p ,cedure 3-6.2.1.31. The inspector reviewed the program records and found the calibrations are done in an acceptable manner and according to schedule. To satisfy the requirements of ANSI 18.7-1976 for administrative control of the calibration program, the inspector stated that the major details of the calibrations (i.e., instruments, frequency, range, and setpoints, where applicable) should be included in a procedure reviewed and approved by station management. The licensee's repre- sentative stated that this would be done. This item is unresolved pending licensee action and subsequent NRC:RI review (50-309/82-06- 02). 5. Facility Tours The inspectors observed Control Room operations to verify that the operations were in compliance with Technical Specification requirements and admini- strative procedures. The inspectors toured the Primary Auxiliary Building and the Turbine Building. Specifically, the Diesel Generator Rooms, Spent Fuel Pool, Switchgear Room, Cable Spreading Room, and Core Spray Area were inspected to verify adherence to housekeeping requirements, posting of radiation areas, and integrity of plant equipment. No violations were identified. 6. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violations. One unresolved item was identified during this inspection and is detailed in paragraph 4.e. 7. Management Meetings Lies 3;; management was informed of the scope and purpose of the inspection at an entrance interview conducted on April 20, 1982. The findings of the ,
inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview was conducted on April 23, 1982 (see paragraph 1 for attendees) at which time the findings of the inspection were presented. A subsequent telephone discussion concerning the inspection findings was conducted between the inspector and Mr. C. Frizzle on April 28, 1982 (see paragraph 2 (Item 81-31-04) for further details). l l I < l }}