ML20236U845

Safety Evaluation Accepting Rev 14 to Maine Yankee Atomic Power Co Operational QA Program

ML20236U845
Person / Time
Site:	Maine Yankee
Issue date:	07/24/1998
From:	NRC (Affiliation Not Assigned)
To:
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ML20236U840	List: ML20236U838 ML20236U845
References
NUDOCS 9807310109
Download: ML20236U845 (4)

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- SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED REVISION 14 TO THE MAINE YANKEE ATOMIC POWER COMPANY QUALITY ASSURANCE PROGRAM MAINE YANKEE ATOMIC POWER STATION

' DOCKET NO. 50-309 l

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1.0 INTRODUCTION

1 By letter dated January 28,1998, the Maine Yankee Atomic Power Company (licensee) transmitted Revisions 12,13, and 14 of the Maine Yankee (Operational) Quality Assurance L Program (OOAP). Revisions 12 and 13 to the OQAP were submitted as periodic updates l- pursuant to 10 CFR 50.71(e)(4). Revision 14 to the OQAP was submitted in accordance L with the requirements of 10 CFR 50.54(a)(3) as reflecting changes that reduced l .- commitments in the OQAP description previously approved by the NRC. As a result of L . requests for additional information by the NRC staff, the licensee amended its original submittal via correspondence dated April 13,'1998, (Reference 3) and May 26,1998 -

(Reference 4).

2.0 EVALUATION This. evaluation only addresses changes in Revision 14 to the OQAP which the licensee has L deemed to be reductions in commitment pursuant to 1G CFR 50.54(a)(3).

2.1' OQAP, Section ll, "QA Program," Subsection F, " ANSI Standards and Regulatory Guides" l .. .

l Under item 14.d, " Exception," the licensee proposed to take exception to the thirty day 4 requirement for corrective actions in Subsection 4.5.1 of ANSI N45.2.12-1977, l' Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants." As an alternative, the licensee proposed to specify corrective actions and provide management approval in accordance with the time-frames contained in the Corrective Action Program.

l Criterion XVI, " Corrective Action," of Appendix B to 10 CFR Part 50 states, in part, ll

" Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected." The licensee relies, in part, upon its current commitment to ANSI N45.2.12 to satisfy the requirement that conditions i

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' adverse to qua"ty be "promptly identified and corrected." Subsection 4.5.1 states, in part,

!- - that "in the event that corrective action cannot be completed within 30 days the audited l organization's response shall include a scheduled'date for the corrective action." As such, Subsection 4.5.1 on ANSI N45.2.12 already allows for delays in corrective actions that cannot be completed within 30 days.

In its April 13,1998, response to the NRC, the licensee stated that the intention of this l

l change was to control the correction of audit findings under the Corrective Action Program described in OOAP Section >'VI. The licensee added that the timeliness requirements of the Corrective Action Prograrns have been much more clearly defined in recent years in NRC guidance such as Generic Letter (GL) 91-18, Revision ,1 "Information to Licensees Regarding NRC inspection Manual Section on Resolution of Degraded and Nonconforming Conditions." It is more appropriate and much less ambiguous to specify a timeliness requirement based upon the safety significance of the issue, as identified in GL 91-18.

Accordingly, the !!censee modified its exception to Subsection 4.5.1 of ANSI N 45.2.12 to specify that (a) the safety significance of corrective action issues will be based on the f'

guidance in GL 91-18, Revision 1, and (b) in the event that the audited organization

-determines that corrective actions cannot be completed within 30 working days, such organization will establish an alternate schedule based upon the safety significance of the j issue as described in GL 91-18, Revision 1.

The staff finds that this proposed alternative to the timeliness provisions in Subsection 4.5.1 of ANSI N45.2.12 is consistent with the requirements of Criterion XVI of Appendix B L to 10 CFR Part 50 for a decommissioning status facility and is, therefore, acceptable.

2.2 OQAP Section Ill, " Design Control," Subsection B, ." Responsibilities," Deletion of Itams 2.J,3, and 5

, The licensee effected these changes to eliminate references to Yankee Nuclear Services

_ Division (YNSD) and to consolidate responsibility for,the design review of fire protection systems with the organizational entity responsible for establishing and implementing a L system for processing design changes and performing independent design verifications, i.e.,

! the Maine Yankee Engineering Division as described in section Ill.B.2 of the OQAP. The Engineering Support Department at Maine Yankee has been integrated into the Engineering

(' Division under the direction of the Director of Engineering (a position previously referred to as the Vice-President of Engineering).

L - On December 1,1997, the YNSD of The Yankee Atomic Electric Company (a company affiliated to Maine Yankee by' ownership, contractual, and licensing arrangements) ceased

- to exist as a result of being acquired by Duke Engineering & Services Company of

. Charlotte, North Carolina. Therefore, references to documents maintained by YNSD needed to be revised. The design requirements for fire protection at Maine Yankee are governed by paragraph (f) of 10 CFR 50.48?" Fire protection." Engineering personnel performing these activities have in the past and will continue to meet the commitments to ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel," as modified by Regulatory Guide (RG) 1.8, " Personnel Selection and Training," Revision 1, as discussed in section ll.F.1 of the OOAP. . Based on the above, the staff finds that these changes are

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!- 3 consistent with the requirements of Criterion lil of Appendix _B to 10 CFR Part 50 for a decommissioning status ft.cility. Furthermore, Section ill of the OQAP continues to satisfy the licensee's commitments to ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants," as endorsed by RG 1.64, " Quality Assurance ._

! Requirements for the Design of Nuclear Power Plants," Revision 2. On this basis, the. staff

.~ concludes the citanges made to OOAP Section ill, " Design Control," Subsection B-'

L' '" Responsibilities," are acceptable.

l 2.3. OQAP Section Ill, " Design Controls," Subsection B, " Responsibilities," item 5 (Deletion of Engineering Support Activities Associated with YNSD) and item 6 (Replacement of Vice-President Operations with Director, Operations) l The Director of Operations, as iridicated in OOAP Section I.B, " Responsibility," has assumed the responsibilities of the generic title, " Plant Manager", as defined in ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," and meets the qualification of ANSI N18.1 for that position. As stated in Section Ill.B.3 & 4 of the OQAP, the Director of Operation is responsible for evaluation of the recommendations of the Plant Operations Review Committee (now known as the Independent Safety Review)'and for review and approval of proposed design l~ changes. In addition, as the " Plant Manager," the Director of Operations reviews changes to the plant for impact on operations, training, safety, radiological controls, and maintenance and other areas of significance to the operations staff. Ultimately, the

Director of Operations' review of design changes is for approval purposes, t

The Director of Engineering, a position formerly identified as the Vice-President of Engineering, fulfills the responsibilities delineated in OQAP Section Ill.B.2, " Engineering Division." .This review includes ensuring that design changes are properly prepared,

l. reviewed, and verified pursuant to the design control program described in OQAP Section Ill.B.2. The Engineering Division is responsible for the preparation, review, and approval of design documents. The Director of Operations and the Director of Engineering both report directly to the President of Maine Yankee. Since the Director of Operations reports directly to the President, the level of management attention of the review and approval of design changes will be maintained.

. Based on the above, the staff finds that these changes are consistent with the requirements of Criterion ill of Appendix B to 10 CFR Part 50 for a decommissioning status facility. Furthermore, Section til of the OQAP continues to satisfy the licensee's i commitments to ANSI N45.2.11-1974, as endorsed by RG 1.64, Revision 2. On this basis, L the staff concludes the changes made to OOAP Section lil, " Design Control," Subsection B,

" Responsibilities," are acceptable.

'2.4 OQAP L Section IX " Control of Special Processes," Subsection B, " Responsibilities,"

item 3 (Deletion of YNSD activities associated with welding and non-destructive examinations)

. Changes effected to this subsection were limited to the removal of YNSD as the organizational entity responsible for welding and nondestructive examination activities. As

4 discussed above, YNSD no longer exists as an affiliated entity and the responsibility for review and approval for special processes now resides with Maine Yankee Engineering Division as delineated in OOAP Section IX.B.2.d. Engineering Personnel performing these activities have in the past and will continue td meet the commitments to ANSI N18.1 as modified by Regulatory Guide 1.8 as discussed in OOAP section ll.F.1.

Therefore, the staff finds that these organizational changes are administrative in nature and do not affect the licensee's continued compliance with Criterion IX, " Control of Special Processes," of Appendix B to 10 CFR Part 50.

3.0 CONCLUSION

Based on the above, the staff concluded that the reductions in commitments identified by the licensee in Revision 14 to the OQAP are consistent with the requirements of Appendix B to 10 CFR Part 50 for a decommissioning status facility (following submission of 10 CFR 50.82 " Termination of license," certifications) and are, therefore, acceptable.

4.0 REFERENCES

1. G. A. Zinke letter to the NRC, " Maine Yankee (Operational) Quality Assurance Program - Revisions 12,13 and 14," dated January 28,1998

2. USNRC Letter to the Maine Yankee Atomic Power Company, " Review of Revision 14 to Maine Yankee Quality Assurance Description Submittalin Accordance with 10 CFR 50.54(a) Requirements," dated March 26,1998

3. G. A. Zinke letter to the NRC, " Response to Request for Additional Information for Maine Yankee Quality Assurance Program Revisions 14," dated April 13,1998

4. G. A. Zinke letter to the NRC, " Maine Yankee Quality Assurance Program Revi2ns ,

14,Section II - QA Program, Page 16 of 17 Revised," dated May 26,1998 l

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