ML20205G287

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-029/86-17

ML20205G287
Person / Time
Site:	Yankee Rowe
Issue date:	03/25/1987
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Heider L YANKEE ATOMIC ELECTRIC CO.
References
NUDOCS 8703310418
Download: ML20205G287 (2)

See also: IR 05000029/1986017

Text

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! MAR 2 5 1987

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Docket No. 50-29

Yankee Atomic Electric Company

l ATTN: Mr. L. H. Heider

Vice President of Operations

i 1671 Worcester Road

2

Framingham, Massachusetts 01701

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l Gentlemen:

Subject: Inspection No. 50-29/86-17

This refers to your letter dated February 18, 1987, in response to our letter

dated December 3, 1986.

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Thank you for informing us of the corrective and preventive actions documented

, in your letter. We found these actions to be responsive and consistent with

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your previous discussions with our staff. The effectiveness of the

implementation of these actions will be reviewed during future routine NRC

inspections.

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. Your cooperation with us is appreciated.

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Sincerely,

j OM%1 g gn,4 gy ,

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JCn11. Johnaon

l William V. Johnston, Acting Director

Division of Reactor Safety

Enclosure:

cc:

N. N. St. Laurent, Plant Superintendent

J. E. Tribble, President

G. J. Papanic, Jr., Senior Project Engineer - Licensing

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Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Massachusetts (2)

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8703310418 870325

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FYR 87-017  !

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United States Nuclear Regulatory Commission

Document Control Desk

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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.

d

Subject: Response to Inspection 50-029/86-17

Dear Sir:

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Reference is made to I&E Inspection No. 50-029/86-17 conducted by Mr. Robert l

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, each of which is discussed below. It was agreed that

. the written response could be deferred, pending a discussion of these items. l

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 Federal Regulations,

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we hereby submit the following information:

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Apparent Violation

Technical Specification 6.8.1 states 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.

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As of October 3, 1986, the implementation of procedures affecting safety-related (

caintenance, test and inspection activities were inadequate as evidenced by i

the following examples: l

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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),

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FYR 87-017

b. A description of the actual maintenance performed includ-

ing procedurc number if applicable,

c. A description of the retest 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.

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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 th. 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 detaile 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. Follow-

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 written

procedures, which set forth the requirements and acceptance limits

and specify the inspection responsibilities ...".

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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

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personnel were provided retraining with regard to procedure 0QA-X-5,

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" 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

specific to the activity being performed. Procedure OQA-X-5 will also

be resised 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, 1

1987 This revision will address internally generated QA audit deficien-

cies as well as add clarifying statements regarding this NRC inspection.

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Item 3: Procedure 0QA-X-5 states in part "... OQC 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 licensee's QC group did not establish ho3d l

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 OQA-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 0QA-1-5 will be revised to clarify the use of " Hold

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

j- 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.

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Item 4: Procedure OQA-I-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:

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Inspection checklists will be developed for use in final reviews of

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completed maintenance requests in order to improve the depth and con-

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sistency of this portion of the inspection program. Quality control

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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

actions 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-

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: ,

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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

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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

Attachment

ec: USNRC Region 1

USNRC Resident Inspector, YNPS

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