ML20214V573

Notice of Violation from Insp on 860929-1003

ML20214V573
Person / Time
Site:	Yankee Rowe
Issue date:	12/03/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214V556	List: IR 05000029/1986017 ML20214V553 ML20214V573
References
50-029-86-17, 50-29-86-17, NUDOCS 8612090743
Download: ML20214V573 (3)

Text

, s APPENDIX A Notice of Violation Yankee Atomic Electric Company Docket No.50-029 1671 Worcester Road License No. DPR3 Framingham, Massachusetts 01701 As a result of the inspection conducted on September 29 - October 3, 1986 and in accordance with the " General Statement of policy and Procedure for NRC

' Enforcement actions", 10CFR2, Appendix C, the following violation was identified:

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 maintenance, 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:

(1) AP-0205, " Maintenance Request", requires:

a. That any maintenance performed on systems, components or structures that require quality assurance utilizing materials, parts, replacement components or documentation shall necessitate the use of a Maintenance Request (MR),

b. A description of the actual maintenance performed including procedure 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.

Contrary to the above:

a. Water addition to the diesel fire pump battery, a safety related maintenance activity documented in QCIR 86-28 dated January 29, 1986, was conducted without the use of a Maintenance Request.

8612090743 861203 PDR ADOCK 05000029 G PDR OFFICIAL RECORD COPY IR YR 86 0002.0.0 11/28/86

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b. A description of the actual work performed was not documented in MR 86-717 and the manufacturer's work instruction used to perform maintenance was not documented in OP-5103 for MR 86-772A,

c. The retest procedure used was not documented in MR 86-259 and no retest was performed in MR 86-561,

d. A description of the material used or a Q/A or MI number was not documented in MR 86-801,

e. Items 8 and 9 were not completed on form APF-0205.2 for QA required MR 86-770.

(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 ...".

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 requirements, acceptance limits, and inspection responsibilities.

(3) Procedure 00A-X-5 states in part ". . . OQC personnel will review all Maintenance Requests (MR) to determine / establish the following: ...

l. hold points have been invoked as deemed necessary for inspection,

based upon a review of repair plans or procedures; Notification j

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 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. (listed in attachment 1)

(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 I above) on the inspection form.

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(5) The licensee's Equipment Classification Manual section 3.5 states:

The requirements of the Yankee Atomic Operational Quality Assurance Manual (YOQAP1-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 responsible 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.

The above collectively constitute a Severity Level IV violation.

(Supplement I)

Pursuant to the provisions of 10 CFR 2.201, Yankee Atomic Electric Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the ccrrective steps which have been taken and the results achieved; (2) corrective steps that will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response

time.

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