ML20211H864
| ML20211H864 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 02/18/1987 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| FYR-87-017, FYR-87-17, NUDOCS 8702260310 | |
| Download: ML20211H864 (5) | |
Text
T
~
' YANKEE ATOMIC ELECTRIC COMPANY T=':pho"' (6 ") * ' - 'oo THoc 710-380-7619 i ' ~ }-
. i.y tillf a)Q.:
1671 Worcester Road, Framingham, Massachusetts 01701 2.C2.11
?j
(/. alC GE -
February 18, 1987 FYR 87-017 United States Nuclear Regu3 story Commission Document Control Desk Washington, DC 20555
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b) I&E Letter to YAEC, I&E Inspection No. 50-029/86-17, dated December 3, 1986.
Stiject:
Response to Inspection 50-029/86-17
Dear Sir:
Reference is made to I&E Inspection No. 50-029/86-17 conducted by Mr. Robert W. Winters during the period September 29 through October 3, 1986, at the Yankee Atomic Electric Company, Yankee Nuclear Power Station in Rowe, Massachusetts.
The report made subsequent to that inspection identified several activities which apparently were not conducted in full compliance with NRC requirements.
These activities constitute a single, severity level 4 violation which is com-prised of five items, eech of which is discussed below.
It was agreed that the written response could be deferred, pending a discussion of these items.
This discussion was held on February 11, 1987 In accordance with Section 2.201 of the NRC's " Rules and Practices", Part 2, Title 10, Code of Faderal Regulations, we hereby submit the following information:
Apparent Violation Technical Specification 6.8.1 statec in part:
" Written procedures shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Sections... 5 3 of ANSI N18 7-1976...".
ANSI N18 7 Section 5 3 requires procedures for safety-related activities including main-tenance, test and inspections.
As of October 3, 1986, the implementation of procedures affecting safety-related maintenance, test and inspection activities were inadequate as evidenced by the following examples:
Item 1: AP-0205, " Maintenance Request", requires:
a.
That any maintenance performed on systems, components or structures that require quality assurance utilizing mater-ials, parts, replacement components or documentation shall necessitate the use of a Maintenance Request (MR),
8702260310 870218
$60 /
PDR ADOCK 05000029 G
United States Nuclear Regulatory Commission Page 2 FYR 87-017 b.
A description of the actual maintenance performed includ-ing procedure number if applicuble, c.
A description of the rctest performed and procedure used if applicable, d.
A description of materials used including a description of the items or the Q/A or MI number and, e.
Completion of form APF-0205 2 for QA required MRs.
Contrary to the above:
Several examples of alleged maintenance deficiencies were cited as examples of the above requirements not being met.
Response to Item 1:
Immediately following the identification of the apparent violation, the Maintenance Department evaluated the identified violations and, based upon the conclusions reached, discussed with maintenance per-sonnel the alleged violations, emphasizing the necessary actions and requirements of AP-0205 and reinforcing the importance of adequate descriptions and attention to detail on the MR form. This process has been completed.
The evaluation of the examples of the alleged maintenance deficiencies led to the conclusion that more attention must be provided in describing those actions taken on maintenance requests, with special attention given to the details of the problem and corrective action. To accom-plish this, programmatic procedure AP-0205 " Maintenance Requests" uill be revised to add guidance and clarification on the adequacy of detail necessary when initiating, performing, completing and cancelling a maintenance request.
In addition, Procedure OP-5103, " Inspection, Maintenance and Testing of Safety Relief Valve No. SV805", will be revised to include manufacturer's instructions, when applicable.
Follou-ing these procedural revisions, training will be conducted for all appropriate maintenance and operations personnel. These activities will be completed by May 1, 1987 The 1987 audit and surveillance programs will include evaluations of the various plant functional areas to ensure that sufficient detail is provided in documenting all plant activities, and in identifying problems and delineating corrective actions.
Item 2: Procedure AP-0209 states in part "... Inspection of safety-related activities shall be performed in accordance with approved uritten procedures, which set forth the requirements and acceptance limits and specify the inspection responsibilities...".
( Unitid Stat:s Nuclear Rsgulatory Commission Paga 3 FYR 87-017 Contrary to the above, the licensee's Quality Control (QC) inspections of safety-related activities, as documented in QCIRs 86-26, 86-33, 86-54, 86-56,86-181, 86-198, and 86-199 and others, were performed without utilizing' approved written procedures which set forth the re-quirements, acceptance limits, and inspection responsibilities.
Response to Item 2:
Subsequent to the identification of this violation, Quality Control personnel were provided retraining with regard to procedure OQA-X-5,
" Quality Control Inspections." Where QC Guidelines applied, their use was made mandatory; where Guidelines were not applicable, the QC Supervisor established proper inspection requirements and acceptance criteria. This action was completed on January 12, 1987 The Inspection Guidelines will be revised and used as " checklists".
Their use will be made mandatory when performing inspections. These will provide specific qualitative and quantitative acceptance criteria 1
specific to the activity being performed. Procedure 0QA-X-5 will also be revised to provide a mechanism for specifying appropriate QC inspection attributes for non-routine maintenance activities.
These activities will be completed in conjunction with the procedural review discussed in response to Item 3, below.
A revision to AP-0209 is in progress and will be completed by May 31, 1987 This revision will address internally generated QA audit deficien-cies as well as add clarifying statements regarding this NRC inspection.
Item 3: Procedure 0QA-X-5 states in part ".. 000 personnel will review all Maintenance Requests (MR) to determine / establish the following:
hold points have been invoked as deemed necessary for inspection, based upon a review of repair plans or procedures; Notification points have been established to monitor specific facets of a process-or repair Contrary to the above, the licersee's QC group did not establish hold points necessary for inspection based on a review of the repair plans and procedures to be used for each of the MRs. Rather than establishing specific hold points, the QC inspectors established notification points requiring notification prior to the start of work on all of the MRs reviewed.
Response to Item 3:
Procedure 0QA-X-5 presently provides for the use of " Hold" or "Notifi-cation Points" without defining when each should be used. Guidelines will be established and will define the criteria for their use.
In addition, Procedure 00A-X-5 will be revised to clarify the use of " Hold i
Points" and " Notification Points". This will be completed by May 1, 1987 Quality control personnel will review Plant maintenance procedures and will evaluate the need for QC inspection " Hold Points". When deemed appropriate, these " Hold Points" may be introduced into those Maintenance Requests which call for the utilization of those procedures with the pre-established " Hold Points". This process will be completed within a 12-month period.
1
United States Nuclear Regulatory Commission Page 4 FYR 87-017 Item 4: Procedure OQA-X-5, regarding the final QC review, states in part,
...Any deficiencies or deviations identified from the review shall be noted on the inspection form...".
Contrary to the above, the licensee's QC final review of the QCIRs was inadequate in that the QC inspectors failed to identify and document the aforementioned MR deficiencies and deviations (item 1 above) on the inspection form.
Response to Item 4:
Inspection checklists will be developed for use in final reviews of completed maintenance requests in order to improve the depth and con-sistency of this portion of the inspection program. Quality control inspectors will also be instructed in Maintenance Request and Proced-ural requirements to permit their evaluation of Maintenance practices.
However, it will remain the responsibility of Maintenance supervision to determine the needs for Maintenance Requests and whether written procedures are required in accordance with AP-0205 and AP-0214.
These acticas will be completed by May 1, 1987 Item 5: The licensee's Equipment Classification Manual section 3 5 states:
The requirements of the Yankee Atomic Operational Quality Assurance Manual (YOQAP-1-A) shall be applied to "... equipment... that:
provide support to a safety system but are not covered by... Safety Class (e.g. gaskets, packing, lubricants, etc.)...".
YOQAP-1-A Section VIII, states in part, "... The plant shall be re-4 sponsible for:
the identification and control of materials...
storage of lubricants... (and) maintenance of traceability of materials... stored, installed and used in the plant...".
Contrary to the above, the requirements of YOQAP-1-A were not applied to turbine lubricating oil, used as hydraulic fluid providing support to safety systems, in that the licensee did not maintain the lubricant in accordance with the QA program requirements for controlling issuance and storage and maintaining traceability.
Response to Item 5:
Future purchases of lubricating oils for safety-related equipment will be in accordance with the QA program. These lubricating oils will require a C of C and will be issued to the lube oil storage room to maintain traceability. Procedures will require that lubricating oil usage be logged upon withdrawal and that it be recorded, as applicable, on Maintenance Requests. These actions will be completed by May 1, 1987
.-r m.,,.
mm m,.
' United States Nuclear Regulatory Commission Page 5 FYR-87-017 We trust that you will' find this information satisfactory; however, should you have any questions regarding this matter, please contact us.
Very truly yours, YANKEE ATOMIC ELECTRIC COMPANY L. H. Heider Vice President and Manager of Operations LH/aed Attachnent cc: USNRC Region 1 USNRC Residant Inspector, YNPS I
i l
i i
i
- l-i