ML20214W509
| ML20214W509 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 11/25/1986 |
| From: | Whittier G Maine Yankee |
| To: | Thadani A Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20214W512 | List: |
| References | |
| GDW-86-255, MN-86-130, NUDOCS 8612100259 | |
| Download: ML20214W509 (17) | |
Text
.
MAIRE HARHEE 'ATOMICPOWERCOMPARUe avaus,,Ka?,l eta"3s g
November 25, 1986 (207) 623-3521 MN-86-130 GDH-86-255 9
Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Ashok C. Thadani, Director PHR Project Directorate #8 Division of Licensing
References:
(a) License No. DPR-36 (Docket No. 50-309)
Subject:
Maine Yankee Operational Quality Assurance Program Gentlemen:
Enclosed is Revisio1 3 of the Maine Yankee Operational Quality Assurance Program for your review and acceptance. To aid your review, a summary of the changes is included and the changes have been marked in the margin.
Four exceptions to ANSI standards have been taken.
However, we believe there is no reduction of commitments since the requirements are specified in the Maine Yankee Technical Specifications or NRC regulations.
Further, we believe the program has been enhanced by the format change identifying responsibilities for all requirements.
He understand per 10CFR50.54(a)(3)(iv) that changes to the program description shall be regarded as accepted by the Commission upon receipt of a letter to this effect from you or 60 days after submittal, whichever occurs first.
If you have any questions regarding the content of the program revision, please contact R. Lawton, (207) 623-3521, Ext. 2159.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY hAV G. D. Whittier, Manager Nuclear Engineering and Licensing GDH/plb Enclosures
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cc: Dr. Thomas E. Murley l$d23055 I So 0 0 Mr. Pat Sears P
PDR 1
Mr. Cornelius F. Holden i
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,a MAINE YANKEE ATOMIC POWER COMPANY Operational Quality Assurance Program Summary of Changes for Rev. 3 GENERAL CHANGES 1.
Changed management titles from " Director" to " Manager".
2.
Incorporated paragraph C, " Implementation" into paragraph B
" Responsibilities" for Sections III thru XVIII.
3.
Former Appendix B, Exceptions, was incorporated into Section II, paragraph F.
4.
Former Appendix D, Responsibilities, is Appendix B.
5.
Quality Assurance "Surveillances" are now called " Evaluations".
SPECIFIC CHANGES BY SECTION SECTION II - OA Program II.A Scope Added a reference to Appendix C to better define the systems, components and structures covered by the QA Program.
II.c NOTE (4)
Revised to incorporate NRC QA Program acceptance criteria in 10CFR50.54(a)(3)(lv).
(Identified to the YAEC Program revision currently accepted by the NRC).
II.c ANSI Standards and Reg. Guides have been moved to II.F and exceptions listed in former Appendix B have been incorporated into II.F with the applicable reg. guide and standard.
Basis:
To provide the exceptions along with the standard reference for clarity.
II.E.1.d Added "where applicable" for flexibility for documenting training.
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II.F.2 Exception c ANSI N18.7 conflicts with the technical specifications concerning the approval of temporary procedure changes. N18.7 requires that one of the approvers be in charge of the shift. Tech. Spec. 5.8 requires approval by two members of the plant staff, at least one of whom holds a Senior Reactor Operator's License.
(Not necessarily "in charge of the shift").
Exception d ANSI N18.7, Section 5.8.3 is obsolete concerning Emergency Operating Procedures. Maine Yankee is complying with NRC Order dated July 10, 1981 confirming our commitment to NUREG 0737, supplement ICI concerning TMI related items. The procedures will be written to our E0P Writers Guide based upon NUREG 0899 and submitted to the NRC for review.
Exception e ANSI N18.7 requirements for the onsite and offsite review committees are already stipulated in the Tech. Specs. 5.5 and is redundant to the QA Program. There is no need to restate these requirements in the program.
II.F.3 Exception a 10CFR73 requires that Security Plans be established and approved by the NRC. This provides adequate assurance that the plan will meet or exceed ANSI N18.17 requirements.
SECTION III - Design Control III.B.1.b Reworded for clarity and includes additional responsibilities for inclusion of quality assurance requirements and inspection and test requirements for the QA Department.
III.B.I.c Transferred the requirements for review of design basis for inclusion of QA requirements to III.B.2.b and VI.B.1.c.
III.B.2.a Removed the reference to interfaces which is in III.B.2.n.3 and independent review which is III.B.S.b.
Our independent reviews are totally independent since they are performed by YNSD.
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.o III.8.2.b Former III.C.l.a reworded for clarity and accuracy.
III.B.2.c Former III.C l.b and inclusion of activities for Field Design Engineering and quality standards.
" Reactor" was removed from reactor physics since PgD is not responsible for reactor physics.
III.B.2.a Former III.C l.d and wording changes for clarity.
The second sentence dealing with a test program using a prototype unit was deleted since it is redundant with the next sentence; "If the verification method is only by test...." and we are still committed to ANSI N45.2.ll per III.B.2.n.4.
III.B.2.h Former III.C.l.3.
III.B.2.1 Former III.C.l.s with a brooding of scope to safety classified systems, components and structures versus safety functions and changed from " prior to selection" to " prior to use" for flexibility.
III.B.2.1 New QA program requirement for notification to others that a design change may affect their areas of responsibility.
This reflects current practice.
III.B.2.n New QA Program commitment to ensure that responsibilits for design control procedures is prescribed and contain the proper esquirements.
III.B.3 Former III.B.3 to designate that the YNSD Fire Protection Coordinator is the person responsible and that his responsibility includes only review of design changes. Plant Engineering is responsible for the design of fire protection systems.
.IL tl Deleted former III.B.4 and III.B.6 concerning the onsite and offsite review committee responsibilities since they are specified in Tech.
Spec. 5.5 (see II.F.2.e exception).
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III.B.4 and III.B.5 Slight wording changes for clarity. No changes in content.
SECTION IV - Procurement Document Control IV.8.1.c Requirement transferred from the Inspection Section X.
The requirement to review purchase specifications is better suited to
" Procurement Document Control".
IV.8.2 Responsibility for purchasing was transferred from the Administration Department to a newly formed Natorials Management Department.
IV.8.2.b Added the word " temporary" for storage of documents since the Admin.
Department is responsible for permanent storage of documents (see XVII.B.3.a&b).
IV.S.2.c Previous commitments of former IV.C have been incorporated into IV.8.2.c.
Two additional items were added:
IV.8.2.1 procedures that prescribe the preparation of procurement documents.
IV.8.2.c.7 concerning control for procurement of commercial items for nuclear applications.
IV.8.2.c.9 provisions to ensure that the requirements of ANSI N45.2.13 are contained in procurement procedures.
IV.8.3.a&b Changed engineering responsibility to indicate " review" instead of
" preparation" or "providing" as stated in old QAD, rev. 2 IV.B.3.a&b.
IV.8.4 Added a requirement that departments must adhere to the requirements of the established procurement procedures.
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SECTION V - Instructions. Procedures and Drawings V.A The scope was changed-to clearly state the 10CFR50 Appendix B requirements for establishing measures to assure that activities affecting quality are prescribed by instructions, procedures and drawings appropriate to the circumstances. Old scope just mentioned establishing QA measures for approved drawings, instructions and procedures.
V The intent of this section was changed to closely follow 10CFR50 Appendix B in distinguishing between content of instructions and procedures versus review and approval of instructions, procedures and drawings.
Review and approval requirements were transferred to Section VI Document Control.
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V.B.2 i
The Admin. Department is only responsible for procedures, therefore, j
reference to instructions and drawings was transferred to V.B.3 as a j
PED responsibility.
(Part of former V.B.2).
i v.B.3 a
Provides PED responsibilities for preparation and implementation of instructions and drawings.
(Part of former V.B.2 & V.B.3) including changes.
V.B.4 New requirement for all departments to be responsible to prepare and implement procedures affecting quality and that they contain proper requirements.
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V.B i
Former V.B.4 referenced PORC responsibilities which were removed since j
they are stipulated in Tech. Spec. 5.5 (see II.F.2.e exception).
SECTION VI - Document Control V1.A The scope was expanded to include review, approval and control of r
documents and that proper documents are available for use. The previous scope stated that measures be established for control of documents for activities affecting quality. This is more in i
accordance with 10CFR50 Appendix 8.
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VI.B.1.b&c Transferred the review and approval requirements of the QA Department from V.B.1.b&c.
No change in content.
VI.B.2 Stipulates that the Admin. Department is responsible for establishing document control procedures.
VI.B.2.a Former V.C.1.a transferred to the document control section to comply with the scope change (see VI.A).
VI.B.2.b Transferred requirement from V.C.1.c with no content chans.
VI.B.2.c Former VI.B.1.d requirement with no content changes.
VI.B.2.d Former VI.B.1.e requirement with no content changes.
VI.B.2.e-1 Incorporates former VI.C.1.a-e requirements with no content changes.
VI.B.3.a-c Former VI.B.3.a-c requirements except the addition of " implementation instructions" in VI.B.3.c which are controlled by PED.
VI.B.4 New requirement that states that all departments must adhere to the document control procedures established by the Admin. Department in VI.B.2.
SECTION VII - Control of Purchased Material. Equipment and Services VII.B.1.a Incorporates requirements for performing vendor audits of former VII.B.I.a and audit criteria of former VII.C.1.a with some minor wording changes for clarity.
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e o VII.B.1.b Former VII.C.1.c with no changes.
Responsibility for vendor surveillance is in the QA Department.
VII.B.I.c Former VII.C.1.b with no changes.
Vendor audit records are the responsibility of the QA Department.
VII.B.1.d&e Former VII.B.1.c and e requirements with no content changes.
Surveillance of material or services control and adequacy of bids for QA requirements is a QA Department responsibility.
VII.B.I.f Receipt inspection of incoming materials is a QA Department responsibility. Combines former VII.B.1.d for QA Department responsibility with former VII.C.1.f specifying receipt inspection requirements. No changes in content.
Includes certificate of conformance requirements of former VII.c.1.h to locate associated requirements together.
VII.B.1.g Former VII.B.1.f requirement for QA Department to verify the validity of supplier certificates of conformance.
VII.B.I.h New commitment to establish procedures to satisfy the requirements of ANSI Standards and Reg. Guides committed to in Section II.
VII.B.2.a Former Stores requirement VII.B.3 transferred to Materials Management for control of material and equipn.ent until issued.
VII.B.2.b Establishes Materials Control Department responsibility to establish procedures for control of purchased material, equipment and services in accordance with applicable ANSI Standards and Reg. Guides listed in Section II.
VII.B.3.a-c Incorporates requirements for control of material after issue from Stores, bid evaluation and evaluation of services from former VII.B.2.a-c with some wording changes for clarity.
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SECTION VIII - Identification and Control of Materials. Parts and Components VIII.B.2 Identifies responsibility for establishing procedures for identification and control of materials, parts and components to the Materials Management Department and adds requirementssfor partially fabricated sub-assemblies and to prevent the use of incorrect, defective or outdated items.
VIII.B.2.a-c Incorporate former VIII.C.1.a-c with some minor wording changes. No change in content.
VIII.B.3 New requirement that all departments are responsible for adhering to the procedures developed by the Materials Control Department for control of material, parts and components per VIII.B.2.
SECTION IX - Control of Special Processes IX.B.1.c Reference to liquid penetrant examination was replaced by nondestructive testing since we now perform magnetic particle examination. This will allow more flexibility in the future if other forms of NDE are used.
IX.B.l.d Added "for use on-site and when otherwise specified" to reflect actual practice and provide for flexibility to review vendor procedures used at their facilities when specified in procurement documents.
IX.B.2.a-c Added responsibility for the Plant Engineering Department to prepare Special Process procedures and includes requirements from former IX.C.1.a-c.
IX.B.3 Former IX.B.2 requirement for YNSD to prepare special process documents. Heat treating was deleted since it is a Maine Yankee responsibility and implied in IX.B.2 since it is addressed in the
" Scope" for Special Processes.
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IX.B.4.a-c Former IX.B.3.a-c providing for review of special process documents.
"As applicable" and "for use on-site and when otherwise specified" was added to reflect actual practice and provide flexibility for review of documents used at the vendor's facility if specified in procurement documents.
SECTION X - Inspection X.A Revised the scope to include "affecting quality" instead of " requiring quality assurance" and added "for accomplishing the activities" to be more consistant with the wording of 10CFR50, Appendix B, Criteria X.
X.B.1 Old X.B.l.a " Review of Engineering Purchase Specifications..." was moved to IV.B.l.c for clarity.
X.B.I.d&e Added "and/or reviewing" since we review hold and notification points in some cases and are not totally responsible for establishing them.
X.B.l.g New requirement that designates QA as responsible for preparing inspection procedures and specifies the requirements for inspection from former X.C.1.a-h including the requirements of former XVII.C.l.a for record requirements.
SECTION XI - Test Control XI.B.2.c Identifies PED as responsible for establishing procedures for testing and incorporates test document requirements from former XI.C.1.b.
XI.B.3 Establishes that the Operations Department is responsible for establishing procedures for surveillance testing including the requirements stated above (XI.B.2.c) and the as-found, as-left conditions and corrective actions if any.
XI Deleted reference to PORC and NSARC, former XI.B.4&5 per the exception of II.F.2.d&e.
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SECTION III - Control of Measuring and Test Equipment III.A Revised the scope to more accurately reflect the verbiage in 10CFR50, Appendix B.
XII.B.1 i
l Deleted a requirement that QA review and approve all implementing documents for control of measuring and test equipment. QA must approve the QA implementing procedure for M&TE and all departments must adhere to'the procedure established for M&TE (see XII.B.3.e).
Also, QA still evaluates or audits the M&TE program. QA still provides an adequate overview.
XII.B.2 d
I Maintenance Department has designated responsibility for the M&TE procedure.
XII.B.3.a-h Procedure requirements of former XII.C.l.a-g commitments with the following exceptions:
I XII.B.2.b allows other means to indicate calibration due dates other than labelling or tagging.
Putting labels or tags on a component within an enclosed cabinet is not practical and flexibility is needed as long as control is maintained.
XII.B.2.c new requirement for installed plant equipment to be calibrated to assure conformance with Tech. Specs.
XII.B.2.e deleted the word " transfer" since reference standards include transfer standards.
XII.B.2.f expanded explanation of the required accuracy requirements between reference standards and M&TE, and M&TE and installed instrumentation. This is an important distinction to assure proper accuracy requirements without placing undue burdens on the plant.
IEEE Std. 498-1975 was used as a basis for this change.
XII.B.3 M&TE control requirements for all departments from former XII.B.2 and i
the addition of XII.B.3.e requiring all departments to adhere to the i
procedure for M&TE established by the Maintenance Department per i
XII.B.2.
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SECTION XIII - Handlint. Storage and Shipping XIII.B.I.b l
Commitment change from review of handling, storage and shipping documents to evaluation and/or audit to provide a better overview without being in line with 100% review.
XIII.B.l.c Deleted referer.ce to review of plant specifications since it is redundant with engineering specifications for handling, shipping and storage. Expanded the QA commitment to include review of procurement
. documents for handling, shipping and storage requirements.
XIII.B.2.c The Materials Management Department is now responsible for establishing procedures which prescribe proper handling, shipping and storage requirements.
Includes the requirements of former XIII.C.I.a&b and former VIII.B.2.a requirements for the storage of consumables, chemicals and reagents (including shelf life).
4 XIII.B.2.d New commitment that the procedures established by the Materials Management Department satisfy the requirements of ANSI N45.2.2 and Reg. Guide 1.38.
XIII.B.2.e New commitment that the procedures prescribe a preventive maintenance program for stored materials, as applicable, to ensure that they j
function properly when issued for use.
XIII.B.3 New requirements that the Chemistry Department establish procedures for the storage of chemicals and reagents (including shelf life) under their control.
XIII.B.4 Same commitments as in former XIII.B.2.a-d except the addition in XIII.B.4.a of satisfying the established procedures in XIII.B.2 above.
i SECTION XIV - Inspection. Test and Operating Status XIV.A Added " log books" to the scope to reflect practice and provide flexibility while maintaining control.
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i XIV.B.2.e Additional commitment to ensure that the procedures established for equipment control satisfy the requirements of ANSI N18.7, Section 5.2.6.
Former XIV.C.l.a-c was deleted, however, the requirements of ANSI N18.7. 5.2.6 contain all of these elements, therefore, there is no reduction of commitments.
SECTION XV - Nonconforming Materials. parts and Components XV.A Scope was revised to include services and activities to reflect current practice and ANSI N18.7 requirements.
XV.B.2 Former commitment XV.B.2.c for QA to perform surveillance of repetitive conforming materials was deleted since QA performs trending of NCRs (see XV.B.2.e.5).
Former ccmmitment XV.B.2.d for QA to establish a feedback system with vendor representatives for nonconforming material has been transferred to the Materials Management Department (see XV.B.4).
XV.B.2.e QA is responsible for establishing procedures for nonconforming items which include former XV.C.1.a-e and former XV.C.2 for nonconformance report requirements.
XV.B.4 Former XV.B.2.d QA requirement that was transferred to the Materials Management Department for establishing a vendor feedback system for nonconforming materials.
SECTION XVI - Corrective Action XVI.A The scope was revised to more closely follow the verbiage used in 10CFR50, Appendix B.
XVI.B.1.c New commitment for QA to establish corrective action procedures for conditions adverse to quality including significant conditions per 10CFR50, Appendix B requirements.
Incorporated former XVI.C.1.a&c.
Former XVI.C.1.b was deleted since QA performs evaluations and/or audits of corrective actions.
Evaluations and audits are on a sampling basis instead of 100% follow-up for better utilization of QA manpower while providing an adequate level of overview.
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i XVI.B.2.b Added "significant" to design deficiencies to reflect 10CFR50, Appendix B requirements to preclude repetition for significant conditions adverse to quality.
XVI.B.3 Incorporate former XVI.B.2.a-d with some minor wording changes for clarity. No change in commitments.
XVI.B Deleted former XVI.B.4 concerning PORC responsibilities which are stipulated in Tech. Specs. (see II.F.2.e exception).
SECTION XVII - Quality Assurance Records XVII.A Added a reference to Tech. Spec. required records to the scope of the QA Records section.
XVII.B.2 New commitment to clarify YNSD responsibilities for records they generate for Maine Yankee.
XVII.B.3 New commitment for the Admin. Department to control and properly store records which incorporates former XVII.C requirements.
XVII.C.l.a.1-6 was transferred to X.B.1.g for inspection procedure requirements.
XVII.B.4 New commitment for all departments to adhere to the procedures established by the Admin. Department for QA records and for all departments to identify their QA records and retention periods per ANSI N45.2.9.
SECTION XVIII - Audits i
XVIII.B.1 Added "in conjunction with YNSD Quality Assurance" since they provide services for supporting the internal audit program.
XVIII.B.l.a Used the word " audit" instead of " surveillance" since this section deals with audits and is more accurate.
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XVIII.B.l.d (1-6) Identical cctamitments to former XVIII.C.2.a-f except XVIII.C.2.f.1-10 which identified specific audit areas. The Maine Yankee Tech. Specs. Identifies audit areas. A reference to the Tech.
Specs. is made in XVIII.B.1.d.7 which is a new QA Program commitment.
XVIII.B.1.e New commitment to implement the audit program per ANSI N45.2.12 and Reg. Guide 1.144.
XVIII.B n
Deleted former XVIII.B.1.h-j since they are part of ANSI N45.2.12 committed to in XVII.B.1.e.
Deleted former XVIII.B.4 which specifies NSARC responsibilities.
NSARC responsibilities are specified in the Tech. Specs. 5.5 (see II.F.2.e exception).
XVIII.B.2 Commitment change for review and approval of corrective action for audit deficiencies. Former XVIII.B.2 specified the Manager of Operations was responsible for evaluation of recommended corrective actions. Now, XVIII.B.2 specifies that the responsible Department Manager is responsible for evaluation and approval of corrective action for audit deficiencies.
XVIII.B.3 Same commitments as former XVIII.B.3 with slight rewording for clarify. No change in content.
Appendix B (Former Appendix D) l l
Reflects:
1.
Organization changes 2.
Added training responsibilities of former II.E into each designated position responsibilities 3.
" Manager" titles changed from " Director" Exceptions of former Appendix B were added to Section II.
l Appendix C Former II.M cable trays, were deleted since there is no such thing as a IE cable tray.
Former II.N. containment penetration assemblies, was deleted since they are included in I " Structures" mechanically and electrically are included as part of the existing II requirements.
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III.2 Changed " qualified for use" to " accepted for use" to reflect current practice.
V.5.a Added Lithium Hydroxide to the chemicals list since it is used on safety class systems.
Table C.1
- Feedwater System, added Auxiliary Feedwater Piping, Valves and Pumps since they are classified as Safety Class 3.
- Deleted "and Floor" from the title " Equipment and Floor Drainage System" since we have no safety class " floor" drainage systems.
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