IR 05000309/1985034

Performance Appraisal Team Insp Rept 50-309/85-34 on 851105-1231.Violations Noted:Calibr Procedures for Outside Micrometers & Torque Wrenches Inadequate & Load Capabilities of Anchor Bolt Installation Incorrectly Calculated

ML20151T782
Person / Time
Site:	Maine Yankee
Issue date:	02/03/1986
From:	Elsasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151T748	List: IR 05000309/1985034 ML20151T745 ML20151T762
References
50-309-85-34, NUDOCS 8602100362
Download: ML20151T782 (7)

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U.S. NUCLEAR REGULATORY COMISSION

' REGION I Docket / Report: 50-309/85-34 License:

DPR-36 Licensee:

Maine Yankee Atomic Power Company 83 Edison Drive Augusta, Maine 04336 Facility Name: Maine Yankee Nuclear Power Station Inspection At: Wiscasset, Maine Dates:

November 5 - December 31, 1985 Inspectors:

C. Holden, Senior Resident Inspector J. Robertson, Resident Inspector Approved by:

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d.fr A-h-N C. Elsasser, Ctfief, Reactor Projects-Section 3C Date Summary: November 5 - December 31, 1985:

Inspection Report 50-309/85-34 Areas Inspected:

Follow up inspection of management controls in eight functional areas including Plant Operations, Surveillance, Maintenance, Design Changes and

' Modifications, Quality Programs, Procurement, and Radiological Controls.

Inspec-tion' hours totalled 74.

Results: Of the thirteen Unresolved Items noted in the Performance Appraisal Team Inspection Report (85-15), five resulted in four violations (two similar Unresolved Items are issued as one violation). As noted in this report, corrective action has been initiated on each of the Unresolved Items.

Although initiation of cor-rective actions was sufficient to resolve two of the violations, the inspector will continue to follow the remaining items '(Sections 2.b and 2.f) until all corrective actions are complete.

In addition to the four violations, two inspector follow items have been assigned.

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DETAILS S

1.

Persons Contacted Within this report period, interviews and discussions were conducted with various licensee personnel, including reactor operators, maintenance and surveillance technicians and the licensee's management staff.

2.

Licensee Action on PAT Inspection Findings a.

(Closed) Unresolved Item (UNR 309/85-15-01) Surveillance procedures performed by the Operations Department did not always require the re-cording of as found data.

This was consistent with Procedure 0-10-2, Surveillance Tests and Records, but is contrary to the requirements of ANSI N18.7-1976.

In response to this item the licensee reviewed all the surveillance procedures required by Technical Specifications and deter-mined that the Maintenance and I & C Departments were in compliance with the requirement to record as found data.

However, the Operations and Plant Engineering Departments (PED) were inconsistent in their recording of as-found data, e.g., rather than recording a specific reading, an in-dividual may have only initialled the item as meaning the reading was acceptable, or an individual may have written "Unsat" for a reading that did not meet acceptance criteria, and then followed up on that condition with a Deficiency Report to correct the unsatisfactory condition and re-test to determine acceptability.

Both departments are currently review-ing procedures and making the necessary revisions to include the record-ing of as found data. The Operations and PED reviews are expected to be completed by December 31, 1985 and July 1, 1986, respectively.

Re-solution of this item is complete.

Followup action will be reviewed in a future inspection after the completion of the procedural revisions.

(IFI 85-34-01)

b.

(Closed) Unresolved Item (UNR 309/85-15-02) Failure to adequately im-plement a Measuring and Test Equipment (M&TE) Program.

Four. examples

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of inadequate control of M&TE were identified as follows:

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(1) Calibration procedures for outside micrometers and torque wrenches and calibration cross-check procedures for dead weight testers did not designate the calibration points to be checked.

The inspector reviewed revised calibration and calibration cross-check procedures and verified that calibration points are now specified.

Corrective action has been reviewed and found to be sufficient.

This item is closed.

(2) Evaluations were not conducted to verify the validity of tests made with M&TE that was later discovered to be out of tolerance.

The inspector reviewed Controlled M&TE Evaluation Sheets that were com-pleted subsequent to the PAT inspection and determined that the acceptance of test validity for the M&TE found out of tolerance was adequately addressed and documented.

This item is closed.

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(3) I&C M&TE usage log sheets did not' always identify where the test equipment was.used.

The usage sheets for the specific items iden-tified by the PAT inspection were corrected.

Additionally, I&C now attaches-an M&TE cover sheet to calibration forms applicable _to other departments' test equipment.

This cover sheet requires supervisory review and update of the usage sheets.

This activity was reinspected on October 7-11, 1985 (Inspection Report 309/85-29)

and although precedural controls were considered adequate, cases of incompleteness and inaccuracies in M&TE document control were noted.

Collectively,. items 1 through 3 constitute one violation (NC5 50-309/85-34-02) as set forth in Appendix A, item A.

No response to items 1 and 2 is necessary since corrective actions were reviewed and considered adequate.

(4) Evaluations were not conducted, as required by the QA Plan, to document the basis of acceptance when using calibration devices having accuracies less than four times the accuracy of the equipment being calibrated.

Requirements were added to Procedure 0-06-5, Measuring and Test Equipment, to require justification when.the 4:1 criterion is-not-met. This item is not a violation. This item is closed.

c.

(Closed) Unresolved Item (UNR 309/85-15-03) Inadequate control of design inputs and design information flow.

In response to this ites the Plant Engineering Department provided training on June 13, 1985 on design input control. This training emphasized adherence to FSAR design basis, proper documentation of design inputs and adherence to design requirements

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through all phases of design implementation.

Revision 2 of Procedure 17-21-2, Engineering Design Change Request - Maine Yankee, was issued October =24, 1985, and was reviewed by the inspector.

Additional guidance-was-provided to adequately control the coordination of design change information and to specify responsibilities for releasing design change information. Qualifications of personnel releasing design information were also specified. This item is not a violation and is now closed.

d.

(Closed) Unresolved Item (UNR 309/85-15-04) Failure to make an adequate design calculation for a feedwater line support.

This item involved the derating of an anchor bolt due to its close proximity to a similar, but unloaded, anchor bolt.

The vendor's recommendations were misinterpreted by the preparer, reviewer and approver to apply a derating factor only for loaded anchor bolts in close proximity, and as such did not represent a programmatic breakdown.

As stated in Inspection Report' 309/85-15, the calculation was reperformed taking into account a 20% derating for the anchor bolt (due to the close proximity of a similar sheared off bolt)

as recommended by the vendor and eliminating some of the conservatisms used in the original analysis.

The installation was found to be satis-factory. To ensure that proper derating factors are considered in the design process, the licensee distributed a copy of the vendor's Test

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Report to Maine Yankee' mechanical engineers and engineering managers.

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This is a violation (NC5 50-309/85-34-03) as set forth in Appendix A, Item B.

No response to this item is necessary since corrective actions were reviewed and considered adequate.

e.

(Closed) Unresolved Item (UNR 309/85-15-05) There were no administra-tive controls to ensure testing was performed on the non-return valve (NRV) vacuum assist system before releasing it for operation. The system, although released for operation, was scheduled to be tested at the first opportunity which occurred during the plant cooldown in August, 1985.

t Satisfactory completion of the NRV vacuum assist system testing was verified by the inspector.

Design Control System procedures 17-23-1 and 17-23-2 have been revised to improve the control of functional tests and test documentation.

These procedures adequately define the responsibili-

. ties and requirements for functional testing subsequent to design changes.

This item was not a violation and is now closed.

f.

(Closed) Unresolved Item (UNR 309/85-15-06) Failure to follow proce-dures for the control of drawings.

The PAT inspection identified the following three deficiencies in the drawing control program:

(1) Two sets of uncontrolled drawings located in the Control Room that had been in use for a prolonged period of time had not been re-verified as required by Procedure 0-01-2, Drawing Control.

These drawings were removed from the Control Room at the time of the in-spection.

However, during this followup inspection one of the same sets of uncontrolled drawings was found in the Control Room with the controlled drawings; this set had not been reverified. Addi-tionally, an uncontrolled electrical drawing (FE-IV) was taped to the back of the door leading to the rear of the Main Control Board.

This drawing had been changed by correction tape and pen and ink with no documentation or reverification.

These drawings were re -

moved from the Control Room.

(2) Controlled drawings at various. locations did not reflect the same status of EDCRs.

Followup inspection of various controlled drawings at three locations found no inconsistencies with revision numbers or EDCR status.

The licensee is planning to include a routine assessment of the drawing control program as part of the PE0 Per-formance Assessment Program.. Implementation is expected early in 1986.

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Items 1 and 2 constitute one violation (NC5 50-309/85-34-04) as set forth in Appendix A, Item C.

No response to item'2 is necessary since corrective actions were reviewed and considered adequate.

(3) The PAT inspection identified three examples in which the same per-son had identified, field-verified, and changed a Control Room drawing as allowed by Procedure 0-01-2.

Procedure 0-01-2 has been revised to require independent field supervision-of drawing discre-

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pancies, and Procedure 17-22-3, Drawing Update, has been revised to provide an independent check of revised drawings.

The inspector determined that these additional administrative contrels are ade-quate to minimize the potential for one person't mistake to go un-checked through the drawing change process.

This item was not a violation and is closed.

g.

(Closed) Unresolved Item (UNR 309/85-15-07) Failure to adequately store and control design quality documents.

The storage facility in use was adequate, however, procedures were not establisted to control sign out and return of design packages.

As stated in the PAT Inspection Report, the licensee recalled all outstanding EDCRs and developed Procedure 17-208, Storage and Maintenance of Original Design Change Packages and Original Drawings.

This procedure specifies the practices for storing Design Change Packages and original drawings.

The inspector reviewed Procedure 17-208, Revision 1, dated October 2, 1985, and found that it adequately specified responsibilities, methods of storage, accountability and maintenance for quality assurance records.

The signout log indicated that all records were returned to the drafting file room at the end of each working day.

Individuals' names with access to the files were posted on the door.

It was also determined that the drafting file room meets the requirements of ANSI N45.2.9-1974, Section 5.6 for single facility storage.

This item was not a violation and is now closed.

h.

(Closed) Unresolved Item (UNR 309/85-15-08) Failure to perform adequate audits.

(1) Deficiencies identified in audit checklists were not always identi-fied as deficiencies in the report.

A discussion with the licensee has indicated that only those items not in compliance with regula-tory requirements or procedures are considered deficiencies.

Other items of concern, are addressed as recommendations.

These recom-mendations were reviewed and received adequate management attention.

This item is closed.

(2) The depth and sample size of the 1983 and 1984 audits were con-sidered insufficient to provide a vJ id basis for determining ac-ceptability.

The PAT inspection ident.Nied the Technical Specifi-cation Audits of the surveillance prograi, as a particularly weak area because the audit checked only two suiveillance tests by re-viewing the control room log.

A review of the eni.!re '"dt ; rogram for 1983 and 1984 shows that additional Technical Specification surveillances were reviewed in each applicable audit area, such as, Chemistry and Fire Protection.

The 1985 Technical Specification Audit was expanded to examine approximately twenty-five surveillance requirements to determine if tests were performed in accordance with approved procedures and within the required time period, and that test records were properly maintained.

This item is close r

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6 (3) The checklists' for Audits 83-7B and 84-7 did not include all ~ attri-butes' required by ANSI N45.2.11-1974.

Specifically, the require-ments to audit test procedure development and design interface con-trol were not included.. The licensee's response to this item.indi-cates that Audit 83-78 was conducted to verify implementation of the new design change program, and was not an attempt to determine whether procedures had been established and derived from ANSI N45.2.11.

Audit 83-7A focused on the administrative controls and-responsibilities for, design control activities and evaluated test procedure development.. The inspector reviewed Audit 83-7A and found it adequately addressed these areas. The 1985 Audit (85-7) of Plant Changes was performed to determine the program's adequacy, compli-ance, and effectiveness of implementation.

The documents were evaluated using the appropriate requirements and standards. The inspector reviewed Audit 85-7 and found that it was effective in identifying specific deficiencies and programmatic weaknesses.

This item is closed.

In general the PAT inspection' identified several areas that were ineffective in the 1983 and 1984 audits.

Actions were taken by the licensee to improve its audit program for 1985 prior to the PAT inspection.

Additionally, improvements were made as a result of the PAT inspection. These items were closed with no violations.

i.

(Closed) Unresolved Item (UNR 309/85-15-09) The use of chemicals with expired shelf lives.

Procedure 7-02-1, Quality Assurance / Quality Control Program for Chemistry Technical Specifications Tests, Revision 1, was issued on September 12, 1985. This revision expanded the section on the shelf-life program and incorporated a new requirement to uniquely iden-tify shelf-life sensitive reagents and standards. This was done by marking reagent bottles with a bright orange dot to remind the laboratory staff to check the expiration date prior to use.

Several checks by the inspector verified that shelf lives of the reagents and standards in use were not expired.

This item is a violation (NC5 50-309/85-34-05) as set forth in Appendix A, Item D.

Since corrective action was judged adequate, no response is required.

This item is closed.

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(Closed) Unresolved Item (UNR 309/85-15-10) Special storage and pre-servation requirements were not specified as required in the Maine Yankee Operational QA Program and Procedures 0-02-1, Material Equipment and Service Purchases, and 0-02-2, Maine Yankee Purchase Specifications.

A computerized Preventive Maintenance System program is currently under development to specify the detailed requirements for the handling and storage of components.

This item will be reviewed pending full imple-mentation of this program which is expected by February 1986 (IFI 50-309/85-34-06).

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(Closed) Unresolved Item (UNR 309/85-15-11) Engineering services for the analysis of safety class system design changes were not always pro-cured from qualified contractors.

This is allowed by Procedure 0-02-1,

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Material Equipment and Service Purchases, Section 6.3 as long as the contractor is under direct supervisicn by Maine Yankee personnel.

This requirement was met as the Maine Yankee Project Engineer directly super-

' vised the contractor before and during the design process. The inspector verified that the Engineering Design Package received from the off-site contractor was reviewed by the Project Engineer and then by Yankee Nuclear Services Division for independent reviews.

The Design Change Package was reviewed, controlled and approved in accordance with Maine Yankee Design Control Procedures and the Maine Yankee Quality Assurance Program.

This item is closed.

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(Closed) Unresolved Item (UNR 309/85-15-12) Limited scope of the rou-tine airborne survey program.

The routine airborne sampling program has been expanded and the following surveys have been added to the survey schedule:

Spray Building continuous air sample during RHR Operation

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Primary Auxiliary Building continuous air samples taken at the

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operating ~ charging pump Primary Auxiliary Building continuous air samples taken during

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liquid waste processing system operation Service Building 4-hour air sample taken daily

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Turbine Building 24-hour air sample taken weekly

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The addition of these air samples to the survey program adequately ad-dresses the concern of Item 309/85-15-12. This item is closed.

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(Closed) Unresolved Item (UNR 309/85-15-13) No calibration procedure was available for the Nuclear Measurements Corporation gas flow propor-tional counter used in the radiochemistry laboratory to establish the allowable flow rate for liquid effluent releases.

Procedures 7-05-03, Operation and Calibration of the NMC-5 Proportional Counter and 7-05-05, Operation and Calibration of the Canberra Model 2200 Low Level Alpha-Beta Counting System, were revised to include calibration instructions.

Both of these revisions were PORC approved and issued August 29, 1985, com-pleting the corrective action for this item.

This item is a violation (NCS 50-309/85-34-05) as set forth in Appendix A, Item D.

No response is required as the corrective action is considered adequate.

3.

Exit Interview Meetings were periodically held with senior facility management to dicuss the inspection scope and findings.

A summary of findings was presented to the licensee at the end of the inspection.