ML20148R924

Responds to 780929 NRC Ltr Re Violations Noted in Inspec Rept 50-309/78-17.Corrective Actions:During Future Requal Progs Quizzes Will Be Admin & Tygon H2o Manometer Calibr. Suggests Item C Be Withdrawn

ML20148R924
Person / Time
Site:	Maine Yankee
Issue date:	10/20/1978
From:	Moody D Maine Yankee
To:	Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20148R917	List: IR 05000309/1978017 ML20148R924 ML20148R938 ML20148R952
References
WYR-78-98, NUDOCS 7812010093
Download: ML20148R924 (4)

Text

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TURNPlKE ROAD (RT. 9)

• • ENGINEERING OFFICE WESTBORO, MA3SACHUSETTS 01581 s *, 617-306-9011 llh . 71 $D B.4.1.1 WMY 78-98 October 20, 1978 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 l

Attention: Office of Inspection and Enforcement Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch

Reference:

(a) License No. DPR-36 (Docket No. 50-309)

(b) I&E Letter to MYAPC dated September 29, 1978, Inspection Report No. 50-309/78-17

Subject:

Response to Inspection No. 50-309/78-17 In reply to Reference (b), the Maine Yankee Atomic Power Company hereby submits the following information:

Item A. Apparent Item of Non-Compliance:

10 CFR 55, Appendix A states in part, "4. Evaluation. The requali-fication program shall include: ...b. Written examinations which determine licensed operators' and senior operators' knowledge of subjects covered in the requalification program and provide a basis for evaluating their knowledge of abnormal and emergency procedures...."

The accepted Operator Requalification Program as described in Pro-cedure 0-00-05, Revision 6, states in part, "5.2.5 Periodic quizzes shall be admindstered to monitor the progress of those individuals who have shown deficiencies, and to provide input relative to the effectiveness of the lecture series...."

Contrary to the above, for the June 1977 through May 1978 requali-fication training cycle, no post lecture quizzes were administered.

During this period 11 of 18 participating operators were required to attend lectures based on deficiencies shown on the 1977 annual requalification examination.

Reply A.:

The 1977 - 1978 requalification program consisted of three weeks of classroom / simulator training for each crew. The first week of retraining for each crew consisted of a week of classroom and simulator study at the CE simulator facility in Windsor, Conn.

7812010093

United States Nuclear Regulatotty Commission October 20, 1978 Att: Office of Inspection an/. Enforcement Page 2 Maine Yankee received a written evaluation of each licensee's performance at the simulator facility. It was felt by the Training Coordinator that this evaluation met the intent of the requirement of Appendix A and, therefore, no quiz was administered. The second week consisted of lectures which, for the most part, did not relate to license material (i.e. first aid, security, industrial safety, etc.). The only subject that approached a license subject was a discussion of the previous requalification examination and sugges- ..

tions on how to better accomplish the requirements of the requali-fication program. Based on this, it was decideu 17 ' he Training Coordinator that no quiz was required. The third week of the requalification program concluded with the requalification examina-tion and, because of this, no quiz was again given. .

During the NRC I&E inspection this item was discussed with the NRC, Operator Licensing Branch. Although it is felt that the objectives and intent of Appendix A vere met, the lack of formally j administered quizzes did not meet the exact specified requirements. 1 l

l Because all of the licensees successfully passed the requalifica-tion examination prior to the I&E inspection, it was determined that nothing further need be done concerning the lack of quizzes during the 1977 - 1978 requalification program. However, during future programs, written quizzes will be administered.

It*m B. Apparent Item of Non-Compliance:

10 CFR 50, Appendix B, Criterion XII, states in part, " Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated. . .to maintain accuracy within necessary limits." The accepted Quality Assurance Program (YOQAP-A-1)Section XII.C.1 states in part, " Satisfaction of this criterion shall be assured through the implementation of the Nuclear Services Division and/or plant actions listed below:...g. Trace- ^

ability of reference and transf er standards to nationally recognized standards; or, documentation of the basis for calibration where national standards are nonexistent."

Contrary to the abcve, as of September 8, 1978, the "Tygon H 2O Manometer" that was fabricated by plant personnel did not have calibration documentation traceable to national standards nor was the basis for 1ts calibration documented. This manometer was used to calibrate other test and measurement equipment that was subsequently utilized for in-plant safety related activities.

Reply B.:

The referenced "Tygon H2 O Manometer" consisted of a simple U-tube manometer with a co=mercial ruler or machinists scale between the

United States Nuclear Regulatory Commission October 20, 1978 Att: Office of Inspection and Enforcement Page 3 vertical legs. The unit was used to compare calibrated, NES traceable, air dead weight testers with other plant air dead weight testers. These testers were then used to calibrate in-plant safety class transmitters.

The manufacturer's acceptability criteria for the air dead weight testers is 1 0.025% of Full Scale. Full scale equals 100 psi, therefore the tester must be accurate 1 0.6932 inches of water.

To be even further conservative, Maine Yankee utilizes a 1 0.600 inches of water tolerance.

The safety class transmitters which are calibrated by the air l dead weight testers have an acceptability criteria of i 1% of Full Scale. For 100 psi this results in an acceptability criteria of i 27.73 ir.ches of water. Because the calibration device must be 4 times more accurate than the device being calibrated, the air dead weight tester must be accurate i 6.9325 inches of water.

If the ruler for the water manometer must be 4 times more accurate than the air dead weight tester, then its accuracy must be i 1.73".

It is felt that all commercially available rulers are accurate to this tolerance over the 0.60" range required.

Because of the simplicity of the instrument involved and the acceptance tolerance required as described above, the basis for its calibration had not been documented. To be in full compliance, a basis similar to that described above has been prepared and placed in the plant records.

Item C. Apparent Item of Non-Compliance:

10 CFR 50, Appendix B, Criterion XVI, states in part, " Measures shall be established to assure that conditions adverse to quality...

are promptly identified and corrected. In case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition." The accepted Quality Assurance Program (YOQAP-1-A)Section XVI, Paragraph B.1 states in part, "The Nuclear Services Division Operational Quality Assurance Department shall be responsible f or: . . .c. Preparation of recommendations to prevent reoccurance (SIC) of a deficiency." Paragraph C.l.a further states in part, " Satisfaction of this criterion shall be assured through the implementation of the Nuclear Services Division and/or plant actions listed below: a. Initiation of corrective action following the determination of a condition adverse to quality to preclude recurrence...."

Contrary to the above, as of September 8,1978, the corrective action with respect to Item 12 of Audit 77-12 did not prevent repetition in that improper corrective action has resulted in at least two vendors being used without the benefit of an evalua-tion and approval in accordance with the YOQAP-1-A.

United States Nuclear Regulatory Commission October 20, 1978 -

Att: Office of Inspection and Enforcement Page 4 l

Item C. Reply:

Structures, systems, components and other items requiring quality assurance are listed in Appendix C of the YOQAP Topical Report.

Appendix C lists those items designed to IEEE Standard 279, " Criteria for Protection Systems for Nuclear Power Generating Stations" and IEEE Standard 308, " Criteria for Class IE Electric Systems for Nuclear Power Generating Stations" and mechanical systems and components nuclear safety classified in accordance with ANSI Standard 18.2,

" Nuclear Safety Criteria for the Des 1gn of Stationary Pressurized .

Water Reactor Plants".

Measuring and test equipment utilized at the plant are not designed to the above criteria and are not separately listed in Appendix C, as "Other Items Requiring Quality Assurance". The approved Vendors List established and maintained by Yankee Atomic Electric Company applies to those structures, components and systems listed in YOQAP, App. C and, therefore, M.Y. corrective action in response to NSD Audit 77-12, Item 12 was considered appropriate.

Maine Yankee has established an Operational Quality Assurance Program for measuring and test equipment which is considered to be in compliance with the requirements of 10 CFR 50, App. B, Art.

XII including certification traceability to National Bureau of Standards, where applicable.

For these reasons, Ites C should be withdrawn as an item of non-l compliance.

l We trust this information vill be satisfactory. Should any addi-tional information be required, please feel free to contact us.

Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY E& (

D. E . Moody NbtWIJ

/

Manager of Operations EWJ/em .

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