IR 05000029/1985020

Insp Rept 50-029/85-20 on 851021-25.No Violation Noted.Major Areas Inspected:Maint Program

ML20136H778
Person / Time
Site:	Yankee Rowe
Issue date:	11/14/1985
From:	Jerrica Johnson, Prell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20136H769	List: IR 05000029/1985020 ML20136H765
References
50-029-85-20, 50-29-85-20, NUDOCS 8511250194
Download: ML20136H778 (9)

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P U.S. NUCLEAR REGULATORY COMMISSION

REGION I

i -i'" Report N /85-20 Docket N License N DPR-3 Licensee: Yankee Atomic Electric Company 1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Yankee Nuclear Power Station Inspection At: Rowe, Massachusetts Inspection Conducted: -October 21-25, 1985 Inspectors: /' W W llj/L/fTf5^

JameY Prell,' Reactor Engineer, OPS, OB, '

date Division of Reactor Safety Approved by: -

( "* I#!/N E Jon Johnson, Chfe'f, Operational Programs date Section,-Operations Branch, Division of

' Reactor Safety Inspection Summary: ' Routine unannounced inspection on October 21-25, 1985 (Report No. 50-029/85-20).

Areas Inspected: A review of the maintenance program was conducte The inspection involved 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> on-site by one region based inspecto Results: No violations were identifie >

0511250194 851118 9 PDR ADOCK 050 G

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DETAILS 1.0 Persons Contacted Yankee Nuclear Power Station

• R. Boutwell, Senior Technical Service Engineer B. Darcy, Instrumentation and Control (I&C) Supervisor L. Bozek, Quality Control (QC) Supervisor

• B. Drawbridge, Assistant Plant Superintendent D. Fogarty, I&C Engineer

• T. Henderson, Technical Director R. Jodoin, Shift Supervisor

• J. Kay, Technical Services Manager >

• P. Laird, Maintenance Manager

• R. Mitchell, Maintenance Support Supervisor D. Pike, Operation Quality Group Manager

• N. St. Laurent, Plant Superintendent U. S. Nuclear Regulatory Commission

• J. Johnson, Chief, Operational Programs Section

• H. Eichenholz, Senior Resident Inspector

• Denotes those present at the exit meeting on October 25, 1985. The inspector also interviewed other personnel during the inspectio .0 Licensees Actions On Previous Inspection Findings (Closed) Level V violation (029/82-07-01) Ineffective corrective action to audit findings - repetitive findings and lack of action to prevent recurrenc NRC inspection report 50-029/85-01 reviewed among other things the licensee's audit / surveillance program. During this inspection, the inspector verified that the licensee's corrective action program was timely and that their response to audit findings was appropriate. In addition, the inspector reviewed the new trending program being imple-mented to help identify and correct repetitive finding The 1985 Systematic Assessment of Licensee Performance (SALP) report, Inspection Report No. 50-29/85-99, states in part in Section I, " Design Control / Quality Assurance (12%)," that " Licensee audits are becoming increasingly comprehensive, with corrective actions being both timely and responsive."

Based on the above, this item is close . -

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(Closed) Unresolved (029/82-07-02) Timeliness of corrective action - the y administrative system takes too long to respond to audit findings and lack E

of a good status report. Inspection Report No. 82-07 found that it was taking the licensee an average of 10 weeks from the time of the audit to when the licensee responded to the audit, and an average of 18 weeks for the Manager of Operations (M00) to concur with the proposed corrective actio A review of the average time taken in 1984 to respond to audit findings and receive M00 concurrence was made. It was found that the licensee had reduced by about 2.8 weeks the average length of time to respond to audit findings (7.2 weeks average), and by 6.5 weeks the length of time to get the M00's concurrence (11.5 weeks average).

Based on the above, this item is close .

3.0 Maintenance Program 3.1 References / Requirements

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Yankee Atomic Electric Company (YAEC) Operational Quality Assurance Manual Y0QAP-1-A, Revision 15, Sections 1, 2, 9, 12, 16 and Appendices B and ANSI NI8.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plant ANSI N45.2.1-1973, Cleaning of Fluid Systems and Associated Components During the Construction Phase of Nuclear Power Plant ANSI N 45.2.3-1973, Housekeeping During the Construction Phase of Nuclear Power Plant ANSI N 45.2.9-1974, Requirements for Collection, Storage and Maintenance of Quality Assurance Records for Nuclear Power Plant Regulatory Guide 1.33, Revision 2, Quality Assurance Program Requirement .2 Program Review The following administrative and maintenance procedures and documents were reviewed to determine if they were consistent with the require-ments and references identified in Section Operating Procedure (0P)-1510, Revision 9, Reactor Upper Core Barrel and Plates - Removal and Storage

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Administrative Procedure (AP) - 0017, Revision 7, Switching and Tagging of Plant Equipment

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AP-0018, Revision 11, Jumper and Lifted Lead Control

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AP-0042, Revision 3, Housekeeping For Maintenance and Modifications

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AP-0205, Revision 9, Maintenance Request

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AP-0214, Revision 9, Maintenance and Changes of Safety Classified Systems, Components or Structures

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AP-0207, Revision 6, Equipment Control

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AP-5002, Revision 8, Maintenance Department Corrective and Preventive Maintenance Program

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AP-5010, Revision 5, Maintenance Department Corrective Maintenance

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AP-5005, Revision 8, Standard Welding and Inspection Procedure

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Department Procedure (DP)-6001, Revision 8, I&C Department Equipment History Card / Loop Folder System

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AP-6000, Revision 4, I&C Department Work Log

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AP-6003, Revision 8, I&C Department Maintenance Program

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DP-6007, Revision 8, I&C Department Corrective Maintenance

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Licensee Event Report (LER) Status Log

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OP 6000.209, Revision 0, Installation and Testing of the Incore Thermocouple Upgrade for ICC (EDCR 83-31)

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EDCR 83-31, Revision 2, Thermocouple Upgrade for ICC System

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OP-6200, Revision 8, Main Coolant Cold Leg Wide Range Channel and TCWR Auctioneer Calibration and Main Coolant Stop Valve Interlock Operability Check

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Audit Report #Y-85-06, March 26-29, 1985, Maintenance Based upon a review of the above procedures and discussions with maintenance and operations personnel it was determined that:

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the licensee has established:

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written procedures for initiating requests for routine and emergency maintenance

criteria and responsibilities for review and approval of maintenance requests, designating the activity as safety or non-safety related and inspection of maintenance activities

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provisions and responsibilities for identifying hold points and performing post maintenance testing

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administrative controls have been established which require records of the following maintenance related activities:

maintenance requests approvals

identification of personnel who performed the maintenance task

identification of personnel who inspected the maintenance activity a

cause of the malfunction which necessitated the maintenance activity *

• description of the corrective action taken

identification of the post maintenance testing performed

identification of personnel performing the post maintenance testing

identification of replacement parts used

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identification of test and measuring equipment used

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a program has been established for reviewing completed correc-tive maintenance records to assess adequacy of the maintenance program and identify repetitive failures

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work control procedures have been established for authorizing special processes and establishing fire watches when needed I

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methods and sponsibilities for equipment control have been defined wh.

requires permission from the operations department to l release equipment or systems for maintenance L

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a requires the operating staff to verify and ascertain that the equipment or system can be released for maintenance, and for how long without violating Technical Specifications

require documentation of testing of redundant systems per

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Technical Specification or 10 CFR 50 requirements

identify the status of equipment and systems a

require independent verification of equipment tagging

establish controls for returning equipment to service

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a preventive maintenance (PM) program for safety related structures, systems and components has been developed which:

divides responsibility for the program amongst the I&C, Electrical, and Machanical maintenance departments

establishes a master schedule for PM activities

provides documentation and review of completion of PM activities

assigns methods and responsibilities for establishing PM frequencies

• provides controls for periodic system or component upgrading based on system or component failures

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administrative controls for special process have been established which:

• assure that only qualified personnel and procedures will be used

• require that documentation be maintained to include qualification records of procedures and personnel

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administrative controls and responsibilities for general housekeeping have been developed which:

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• establish Housekeeping Zones a control housekeeping during work activities

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staffing levels were adequate to support normal plant mainte-nance activities

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the Maintenance Department consists of 3 electricians, 1 lead electrician, 3 mechanics, 1 lead mechanic, 4 welders, 2 lead welders, 1 foreman and I supervisor a

the I&C Department consists of 7 technicians, 2 lead tech-nicians, 1 foreman and 1 supervisor

a Maintenance Manager is in charge of both the I&C and Maintenance Departments

during outages contract personnel are brought in to supplement the maintenance staff

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a 10 year plan was developed identifying items or systems which might have to be replaced. This plan is reviewed annually and updated or modified as needed. As a result of NRC Information Notice #84-20, the licensee was replacing Agastat relays during the 1985 outage 3.3 Program Implementation The licensee had begun the 1985 refueling outage just prior to this inspection. As a result, the NRC inspector witnessed the removal of the ventilation duct in the reactor head cavity area. This work was being done per PORC ap roved procedure OP-1510 by contractor per-sonnel under the direct supervision of the licensee. The supervisor was knowledgeable of the job requirements. A tour of the Vapor Containment confirmed that good housekeeping practices were being implemente During this outage, the licensee was also replacing some thermo-couples in the upper head instrument package as part of the thermo-couple upgrade for the Inadequate Core Cooling (ICC) syste A review of the associated EDCR, procedures and drawings was mad In addition, work associated with sleeving of the Thermocouple (TC)

connectors and installation of the TCs into the instrument package was witnesse It was verified that the licensee's calibration program for technical specification related instrumentation was being implemented on a controlled and timely basis. The following instrument calibration cards were reviewed:

• diesel generator day storage tank level meter, DG-L-J

• fuel storage tank level meter, FOL-1

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> 7 f * temperature differential across Steam Generator Tube sheet-uses 6200 series procedures

Primary water storage tank level meter, DWL-200 The Licensee Event Report (LER) status log and the Plant Information Report (PIR) status log were reviewed to identify recurring or main-

tenance caused problems. For 1984 there were 18 LERs written and 17 PIRs writte ,

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For 1985 there were 2 LERs and 8 PIRs issue No trends or maintenance problems were detecte .4 QA/QC Interface l The licensee is establishing a QC organization. This new organization ,

is to become effective upon completion of the 1985 refueling outage i

! around the first of December. However, the new QC organization has l already begun their program in order to check out and become familiar

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with their new procedures. The organization presently consists of five QC inspectors and one supervisor. Part of QCs new responsibil-ities will be the review of all maintenance requests (MRs) to esta-blish hold points and verify proper classificatio .". The Operations Quality Group (00G) is being reduced in size from five auditors to three auditors and a manager who splits his time between YNPS and Vermont Yankee, With the establishment of the new QC group, OQG is no longer reviewing MRs, and will now only provide limited support for audits at other plants. Their primary function is to perform QA surveillances ard perform close-out of in plant audits. OQG is in the process of establishing a surveillance matrix schedul The Quality Assurance and Engineering Group at Framingham will continue to perform in plant audit In plant audit report #Y-85-06 Maintenance, was reviewed. Two deft-ciencies and one observation were noted. The responses to the deficiencies were timely and appropriate. No major findings were identifie .5 Findings In reviewing the thermocouple upgrade program for the ICC system, it was noted that the replacement thermocouples were ordered to the cal-culated length versus the actual length. Westinghouse drawing 1183F96 indicates that the licensee was to determine the actual length for each thermocouple required. Actual length data was not available from the licensee. As a result, the following questions were raised by the resident and region based inspectors;

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8 What is the original design basis for requiring the actual dimensions? Are there any concerna associated with purchasing TCs to the calculated versus actual lengths? What basis does the licensee have for assuring that the TCs are properly seated in their wells?

! What is the allowable tolerance for the length of TC which must protrude through the well? If the TC fails to protrude through the well, is this accept-able? If the TC fails to protrude through the well, how far into the sleeving can it sit and still be acceptable, and what is the basis for determining how far the TC is located up into the sleeve?

Prior to the inspector's exit the licensee had initiated action to get answers to these questions. This is an unresolved item awaiti the licensee's response to these question:. and NRC's review of them (029/85-20-01).

4.0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncom-pliance, or deviations. One unresolved item was identified during the inspection. It is discussed in section .0 Exit Meeting The inspector met with Yankee Rowe staff on October 25, 1985, to discuss the scope and findings as detailed in this report. The licensee repre-sentatives acknowledged the inspector's finding At no time during this inspection was written material provided to the licensee by the inspector.