IR 05000029/1975010
| ML20002A455 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 08/29/1975 |
| From: | Davis A, Hurd R, Steeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20002A451 | List: |
| References | |
| 50-029-75-10, 50-29-75-10, NUDOCS 8011170236 | |
| Download: ML20002A455 (17) | |
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SI fcrm 12
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ca 75), (Rev)
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U. S. NUCLEAR REGULtTORY COMMISSION 3FFICE OF INSPECTION AND ENFORCEME'TT
REGION I
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. Inspection Report No:
50-29/75-10 Docket No:
50-29 Yankee Atomic Electric Company License No:
DPR-3 ccusee:
2DTurnpikeRo'ad Priority:
Westborousth. Massachusetts 01581 Category:
C Safeguards Group:
ca tion:
Rowe. Massachusetts Tc of Licensee:
PWR, 600 MWt (W)
pc. of Inspection-Routine.I[nannounced
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ttes of Inspection:
August 11-15, 1975
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tres.of Previous Inspection:
Julv 29-31. 1975 sporting Inspector,:
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( J. F. Streeter, Reactor Inspector D/JE 8j'3,1l"If O 0-
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- companying Inspectors:
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R. O. Hurd, Reactor Inspector DATE_
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DATE
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DATE ther Accompanying Personnel:
None DATE tviewed By:
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[ 2-7/7 J'
A. B. Davis, Senior Reactor Inspector, PWR Section DATE Reactor Operations Branch
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SUMMARY OF FINDINGS Enforcement Action
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Items of Noncompliance
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None B.
Deviations
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None Licensee' Action on previousiv Identified Enforcement Items t
The licensee's corrective actions with respect to Ite=s of Noncompliance identified in Region I Inspection Report 50-29/74-14, Details 2.c(2) and
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2.c(3), were. reviewed by the inspector and were found to be acceptable.
(Details 8 and 9)
Design Changes The licensee is in the process of =odifying his ventilation system to enable him to maintain all radioactive gaseous releases as low as prac-ticable,.
(Detail 13)
Unusual Occurrences 1.
The plant was tripped on May 13, 1975, from low steam generator water level as a result of losing a boiler feed pump when an elec-trical fault occurred on the distribution line.
The plant was re-turned to power and phased on the grid 2-1/2 hours later af ter an
investigation of the occut ance revealed that no trouble existed with plant equipment.
2.
The plant was tripped on May 16, 1975, from low steam generator water level as a resuit of losing the boiler feed pumps en low suc-tion pres ure.
The plant was returned to power and phased on the grid 5-1/2 hours later af ter an investigation of the occurrence revealed that no abnormalities existed ~in the condensate system.
3.
During a controlled plant shutdown, the plant was inadvertently tripped on May 31, 1975, from 10% power during a nuclear instrumen-tation surveillance check.
4.
The Vapor Container developed a leakage rate in excess of that al-lowed by the. Technical Specifications.
(De tr* 1 18)
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Other Significant Findings 1.
Acceptable Areas Plant Operations except for Switching Log and Special Orders a.
Log.
(Detail 3)
b.
Surveillance.
(Detail 4)
c.
Maintenance.
(Detail 7)
d.' Ventilation System Modification.
(Detail 13)
Prevention of Flooding Due to Non-Safety-Related Equipment e.
Failure.
(Detail 14)
f.
New Fuel Receipt.
(Detail 15)
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2.
New Unresolved Ite=s a.
Switching Log.
(Detail 3.c(1)-)
b.
Special Orders Log.
(Detail 3.c(2))
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Corrections to Reactor Containment Building Integrated Leak
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Rate Test.
(Detail 5.b)
d.
Method of Conducting Type 3 Tests.
(Detail 5.c)
e.
Abnormal occurrence'75-7.
(Detail 6.b)
f.
Use of the Term NA in Procedures.
(Detail 17)
3.
Licensee Identified Items of Noncomoliance
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Contrary to Technical Specification D.2.e(8), contain=ent isolation valve TV-209 would not so fully closed. This item is an Infraction.
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(Detail 6.a)
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4.
Status of Previousiv Identified Unresolved Items The following items have been resolved:
a.
ECCS Circuit Breaker Inspection Procedure.
(Detail 11)
b.
Approved Vendors List.
(Detail 12)
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c.
In-Plant Audit Procedures.
(Detail 16)
More information is needed to resolve the following item:
Pressuriser Surge Line and ECCS Ring Header Hangers.
Management Interview At the conclusion of the inspection, the inspector held a meeting at the site with the following licensee personnel:
Mr. W. G. Jones, Assistant Plant Superintendent Mr. J. H. Shippee, Instrument and Control Supervisor Mr. J. L. Staub, Technical Assistant Mr. N. N. St. Laurent, Technical Assistant to the Plant Superintendent The following summarizes the ite=s discussed:
A.
Purpose of the Inspec* ion.
(Detail 2.b)
3.
Previously Identified Unresolved Ite'es as Identified in " Status of Previously Identified Unresolved Items" Section of This Report.
C.
Previously Identified Enforcement Items as Identified in " Licensee Action on Previously Identified Enforcement Ite=s" Section of This Report.
D.
New Unresolved Items as Identified in "New Unresolved Items" Section
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of This Report.
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E.
Licensee Identified Items of Nonco=pliance as Identified in " Licensee Ident.fied Items of Noncompliance" Section of This Report.
F.
Plant Operations.
(Detail 3)
G.
Surveillance.
(Detail 4)
H.
Maintenance.
(Detail 7)
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Ventilation System Modificatien.
(Detail 13)
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Prevention of Flooding Due to Not.-Jafety-Related Equipment Failure.
(Detail 14)
K.
New Fuel Receipt.
(Detail 15)
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DETAILS
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1.
Persons Contacted-Yankee Atomic Electric Comoany Mr. D. Army, Engineering Assistant Mr. H. A. Autio, Plant Superintendent Mr. E. D. Barry, Control Room Operator
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Mr. R. L. Berry, Technical Assistant Mr. W. D. Billings, Chemistry and Health Physics Supervisor Mr. R. L. Boutwell, Engineering Assistant Mr. T. P. Danek, Operations Supervisor Mr. W. M. Ebert, Plant Reactor Engineer Mr. J. A. Flanigan, Plant Health Physicist Mr. W. G. Jores, Assistant Plant Superintendent Mr. B. L. Kirk, Shif t Supervisor Mr. P. E. Laird, Maintenance Supervisor Mr. L. L. Reed, Quality Control and Audit Coordinator Mr. I. Seybold, Technical Assistant Mr. J. H. Shippee, Instrument and Control Supervisor Mr. J. L. Staub, Technical Assistant Mr. N. N. S t.
Laurent, Technical Assistant to the Plant Superintendent Mr,. M. J. Thayer, Engineering Assistant Mr. M. D. Vassar, Assistant Operations Supervisor
2.
General
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a.
Plant Status
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The plant was operating at approxidately 98% power during the inspection.
b.
Inspection Purpose The inspector stated that the purpose of the inspection was to review the areas of plant operations, abnormal occurrences, maintenance, surveillance, local leak rate testing, and out-standing items.
3.
Plant Operations a.
The inspector reviewed the following logs and operating records:
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-5-Shift Supervisor Log, 6/13/75-6/25/75.
Rowe Station Log 1, 6/15/75-6/25/75.
Rowe Station Log 2, 6/15//5-6/25/75.
Primary Plant Log Sheets, 6/15/75-6/25/75.
Secondary Plant Log Sheets, 6/15/75-6/25/75.
. Operating tkmos 20-1; 2R-1; 2R-21; 2R-22; 2R-23.
Special Orders 254; 269; 271; 272; 273; 275; 278.
Bypass of Safety Function Jumper Control Requests 74-18; 75-24; 75-23 and Jumper Control Log.
Plant Information Reports 29; 30; 31; 32.
Switching Log Switching Orders T-3147; T-1532; T-26.
The inspector determined from his review of the above records that:
(1) Log sheets were filled out and initialed.
(2) Logs were being maintained and reviewed in accordance with plant procedures.
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(3) Jumpers or bypasses did not result in operations contrary
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to the Technical Specifications.
(4) Plant Information Reports confirmed that problems addressed
did not result in Technical Specifications being exceeded.
(5) Operating Memos and Special Orders did not conflict with the Technical Specificati ons.
b.
The inspector toured selected areas of the plant on August 11, 12, and 13 and toured the reactor containment with the Shift Supervisor on duty on August 12.
During the tours he deter-mined that:
(1) Operator crew composition and Control Room manning were in accordance with the Technical Specifications and 10 CFR 50.54(k).
(2) Radiation controls were established in accordance with plant procedures.
(3) Selected monitoring instrumentation was monitoring Primary Coolant System parameters as required.
(4) No unusual fluid leaks or piping vibrations were observed.
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(5) Seismic restraints in the pressurizer compartment were observed to have adequate oil levels in their reservoirs.
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(6) Switch positions of selected valves in the Switchgear Cooling System were in agreement with the physical posi-i tions of the valves.
(7) _ Selected equipment t'ags were observed to be properly
authorized and logged.
(8) The control room operators were aware of the reasons for
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lighted annunciators and had taken action specified in applicable alarm procedures.
(9) Plant housekeeping conditions were acceptable.
c.
The inspector had the following comments in the area of plant
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operations:
(1) The format of the Switching Log is such that an individual
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j cannot. easily determine all of the outstanding equipment tags in the plant. The licensee had recognized this prob-lem and had drafted a revision to procedure AP-0017,
" Switching and Tagging Rules for plant Equipment," to
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correct the problem.
This is an Unresolved Item pending
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i completion of the licensee's corrective action.
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The format of the Special Orders Log is such that an individ-ual cannot easily determine all of'the outstanding Special j
Orders.
The licensee had recognized this problem and in-
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tends to correct the problem.
This is an Unresolved Item pending completion of the licensee's corrective action.
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(3) Entries made in the Shif t Supervisor's Leg concerning
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i Abnormal occurrences 75-6 and 75-7 were brief.
The in-spector stated that entries involving abnormal conditions
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such as these and subsequent corrective action should be
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more descriptive.
The licensee stated that more descrip-
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tive entries would be made for abnormal conditions.
The inspector had no further questions concerning this matter.
4.
Surveillance
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a.
The inspector reviewed surveillance data and witnessed portions of selected surveillance tests to verify that testing was being accomplished in accordance with Technical Specification require-ments and that test results were being reviewed for acceptability
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by someone other than the individual performing the test.
Results of the following tests were reviewed:
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Pressurizer Circulation and Surge Spray Valve Operation OP-4219
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Pressurizer Solenoid Relief Valve Set Pressure OP-4219 Power Range Channel Adjustment OP-4201 Control Rod Position Check OP-7103 Reactor Coolant Flow Trip System OP-4606 Nuclear, Heat Flux Hot Channel Factor OP-4704
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Steam Generator Trip System OP-4604
Emergency Boiler Feed Pump OP-4211 Fire Pump OP-4210 Diesel Fuel Inventory OP-4207 Charging Pu=p and Fire Pump Breakers OP-5755 Station Batteries OP-4501 Emergency Diesel Generators OP-4209 LPSI and HPSI Valves OP-4203 LPSI and HPSI Pumps OP-4204 VC Recirculation System Valves OP-4212 VC Recirculation System Pump OP-4213 VC Recirculation System Suction Header Strainer OP-2100
' Process Radiological Monitoring System OP-4600 Accident Emergency Level Radiation Monitor OP-4602
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Accident E=ergency Environmental Monitors OP-4800 Inspection and Maintenance of Hydraulic Suppressors DP-5106 The inspector' verified that the test frequencies and results satisfied the applicable Technical Specifications and the test results were being independently reviewed.
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b.
The inspector reviewed the procedures associated with the above listed surveillance tests to determine if the procedures were approved in accordance with plant administrative requirements and to determine if the procedures specified prerequisites and test preparations, instrumentation calibration information, acceptance criteria, and appropriate operational checks prior
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to returning equipment to service.-
The inspector had the following comment in the area of sur-veillance procedures:
The inspector stated that procedure DP-5106, "In'spection and Maintenance of Hydraulic Suppressors," should provide i
quan,titative information on fluid additions and mechanical
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adjustments in order that trends of degradation could be detected.
The licensee stated that the procedure data sheet would be revised to include quantitative information.
The inspector had no further questions in the above listed sur-veillance areas.
5.
Type B and C Testing-The inspector reviewed the licensee's method of logging the a.
results of Type B and Type C tests.
The inspector found the licensee's practice of keeping a running. total of Type B and C tests results to be effective in deter =ining at any time how the plant stands relative to the 10 CFR 50, Appendix J, requirement of.6 La for the su=mation of Type B and C test results, b.
The inspector reviewed selected Type B and C test result cal-
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culation sheets.
The inspector found that the result from one test he reviewed was not included in the local leak rate sum-mation listed in Su= mary Technical Report No. 1074, " Reactor Containment Building Integrated Leak Rate Test," dated May 1974.. This report was submitted to the Directorate of Licens-ing on August 29, 1974.
The change is only.00037 wt %/ day and the corrected sum =ary test results still easily meet Appendix J requirements.
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The licensee pointed out two other errors in the report to the inspector.
One report error was the results of the instrument error analysis for the 16 psig reduced pressure test:
the re-port stated that the instrument error was + 0.597% whereas the figure should have been i 0.0597%.
The other report error was that the report states that a Table II and Table III are at-tached which break the local leak rate data down by test class, year and component:
the licensee is not required by Appendix J to report the detailed data and he chose not to.
l The licensee stated that corrections to Summary Technical Report No.1074 would be submitted to the Division of Reactor Licensing.
This is an Unresolved Item pending the licensee's submission of the corrections, c.
The inspector reviewed the licensee's method of conducting and calculating the results of Type B electrical penetration leakage tests.
Summary Technical Report No. 1074 states:
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" Type B electrical penetrations are constructed as closed cylinders penetrating perpendicularly through the vapor container.
They are tested by pressurizing the cylinder and therefore they can leak either into or out of the vapor container.
Leak te'sts with a halide (freon) detec-tor, bubble solutions, and sonic detectors were used to determine the direction of the leaks for these penetra-tions.
For purposes of calculations, leaks from the electrical penetrations which only went into the vapor container were discounted. Leaks which either went only out of the vapor cdntainer or went both ways were calcu-
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lated at full leakage value as leaks through the penetrations."
The inspector stated that the plugs (% 1/2" OD with rubber 0 ring seal) removed from penetrations to allow attachment of the testing rig were never tested.
For penetrations determined to be leaking into containment, the plugs would be subjected to containment pressure during an accident.
The inspector stated that the licensee's practice of discount-ing the leakage of electrical penetrations which only leak into containment and the licensee's assumption that penetration test plugs do not leak will be reviewed further by Region 1.
This is an Unresolved Item pending completion of the Region I review.
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Abnormal Occurrence Review Abnormal occurrences 50-29/75-6 and 50-29/75-7 were reviewed to verify that:
--the cause was identified and details clearly reported;
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--the corrective action described was taken to prevent recurrences;
--each event was reviewed and evaluated by the licensee; and
--safety limits, limiting safety settings, and limiting conditions for operations were not exceeded.
a.
Abnormal Occurrence 50-29/75-6
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References: Licensee letters to Region 1 dated July 25 and August 4, 1975 The following documents related to A0 75-6 were reviewed by the inspector:
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--Licensee letters to Region I dated July 25 and August 4,1975.
--Maintenance Requests75-390 and 75-400.
--Job Orders75-137 and 75-139.
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--QC Inspections75-137 and 75-139.
--PORC Meeting Minutes 75-41 (7/25/75) and 75-44 (8/7/75).
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--Type C leakage test data.
--Procedure OP 6450, " Inspection, Repair and Stroke Calibration of V. C. Isolation S0V's and/or Trip Valve No. TV-209."
Abnormal Occurrence 75-6 concerned a containment drain line automatic containment isolation valve (TV-209) that failed to go fully closed during preparations to conduct a Type C leak-age test due to corrosion buildup on the valve linkage.
The inspector's review of f acility records related to A0 75-6 re-vealed that the occurrence had been satisfactorily evaluated and corrected by the licensce.
The licensee stated in the referenced correspondence that fail-
ure of the valve to go fully closed was not significant because the drain line discharges into a normally closed systen (Vapor Container Drain Tank) which is considered an extension of the Vapor Container.
The inspector stated that the Vapor Centainer Drain Tank cannot be considered an extension of the vapor Con-tainer since the Type A containment test was not conducted with the VCDT being exposed to accident pressure.
The licenste acknowledged the inspector's comment.
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The inspector stated that the inability of valve ";V-209 to go fully closed automatically would have prevented it from respond-ing in accordance with the requirements of Technical Specifica-tion D.2.c(8).
This specification, which is considered to be a limiting condition for operation, requires that " valves in outgoing lines from the vapor container shall close automatic-ally if at any time vapor container pressure increases above 5 psig."
The inspector stated that exceeding this limiting condition for operation constituted an Item of Noncompliance and is considered to be an Infraction.
Since this event has
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been adequately identified and addressed by the licensee, no response to this item is required.
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Abnormal Occurrence 50-29/75-7 References:
Licensee letters to Region I dated August 8 and 15, 1975
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The following documents related to A0 75-7 were reviewed by the inspector:
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--Licensee letters to Region I dated August 8 and 15,1975.
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--Maihtenance Request 75-413.
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--Job Order 75-144.
--QC Inspection 75-144-1.
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--Procedure OP-5100, " Valve, Fitting or Pipe Section Replacement
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and/or Rep '.r."
--Procedure OP-5261, " Testing of Charging Pump Relief Valves on the Test Stand."
--Procedure OP-5254, " Maintenance of Charging Pump Relief Valves."
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-PORC Meeting Minutes 75-45 (8/11/75).
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Abnormal Occurrence 75-7 concerned a nozzle to flange veld crack which resulted in a slight weeping of charging water.
The in-spectors review of facility records revealed that the occurrence had been satisf actorily corrected by the licensee; however, the licensee's evaluation of the occurrence to prevent recurrence
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is not yet complete. The licensee has concluded that the crack was caused by vibration and he is conducting an evaluation to
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determine a remedy for the vibration problem.
This is an Unresolved Item pending completion of the licensee's evalua-tion and associated corrective action.
The inspector reviewed maintenance activities on the following c.
components to determine if the circumstances should have been reported as abnormal occurrences:
No. 4 Loop Fill Valve (MOV-539) - Job order 74-127.
No. 2 MCP Vent Valve - Job Order 74-111.
The inspector determined that these items were not reportable as abnormal occurrences.
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Maintenance Maintenance activities on safety-related systems were reviewed to verify that:
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--limiting conditions for operation were met while the system or
component was removed f rom service;
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--administrative approval was obtained prior to initiating the
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--maintenance was accomplished with approved procedures;
--required inspections or hold points were included;
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--necessary functional testing and calibration was performed; I
--quality control records were available; and
--maintenance was performed by qualified personnel.
The maintenance review included review of Maintenance Requests, Job Orders, plant procedures, and Technical Specifications. Maintenance work reviewed is tabulated below.
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Component Job Order
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Pressurizer Level Indicator 74-128 No. 3 and 4 Main Coolant Loops Flow Detector i
DP Cell 74-250
Nuclear Instruuentation Channel 8 74-30 Intermediate Channel 4 74-31 Pressurizer Vent Valve 75-41 Steam Generator Blowdown Line Trip Valve 74-110 No. 2 Diesel Generator 74-161 No. 3 Diesel Generator 74-179 and 75-50 Waste Disposal Valva VD-V-933 74-145 Safety Injection Accumulator
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74-123 The inspector's review of the above maintenance activities revealed that they were accomplished satisfactorily and the above inspection items were satisfied.
The inspector stated that he detected a sig-nificant improvement in the documentation of maintenance evolutions since this area was last inspected.
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Unauthorized Procedure Changes
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The licensee issued Revision 1 of procedure OP-5204, " Main Coolant Pump Inspection and Repair," on June 13, 1975.
This rev'<ed pro-i cedure incorporates revised torque and clearance values.
This docu-ment resolves the Item of Noncompliance identified in Region I Inspection Report 50-29/74-14, Detail 2.c(2),
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Main Coolant Check Valve Modification - Acceptance Criteria The. licensee issued Revision 2 of procedure OP-5200, " Main Coolant
Check Valve Repair," on June 13, 1975.
This revised procedure in-corporates acceptance criteria and resolves the Item of Noncompliance identified in Region 1 Inspection Report 50-29/74-14, Detail 2.c(3).
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Pressurizer Surge Line and ECCS Ring Header Hangers i
During the tour of'the Vapor Container, the inspector observed that the licensee had made hot setting adjustments to one spring hanger on the pressuricer surge line.
The licensee is continuing to eval-unte the positioning of the ECCS Ridg Header Hangers and will adjust the cold setting of the Pressurizer Surge Line Hangers during the upcoming refueling shutdown. These remain as Unresolved Ite=s pend-ing completion of the licensee's actions.
11.
ECCS Circuit Breaker Inspection Procedure
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The licensee issued Revision 2 of procedure OP-4506, " Inspection l
of ECCS Circuit Breakers," on May 30, 1975.
This revised procedure incorporates acceptance criteria and provisions for recording test
equipment information.
This document resolves the Unresolved Item identified in Region I Inspection Report 50-29/74-16, Detail 13.b(8).
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12.
Approved vendors List Revision 1 of Cuideline No. 1, " Policy for Material Purchases, Design Changes, Repairs and Modifications," was issued in March 1975 and Revision 3 of procedure AP-0211. " Material and Service
Purchase," was issued on May 16, 1975.
These documents both re-
quire material to be purchased from vendors on the Approved Ven-dors List or from suppliers specifically approved by the Operational Quality Control and Audit Department.
(The " Yankee' Atomic Electric r
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Company Operating Plants Approved Vendors List" was issued in May 1975.) These revised documents are consistent in the approach t procurement and resolve the Unresolved Item identified in Region Inspection Report 50-29/74-16, Detail 14.b.
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13. Ventilation System Modification The licensee is in the process of modifying his plant ventilation system in accordance with Engineering Design Request 74-3 to enable him to maintain all radioactive gaseous releases as low as practi-cable. This effort is expected to be completed during the refuel-ing outage beginning in October 1975.
The inspector had no further questions concerning this matect at this ti=e.
146 Prevention of Flooding Due to Non-Safety-Related Equipment Failure _
The inspector determined from record review and visual observations that the licensee had taken the actions specified in a letter to the Office of Nuclear Reactor Regulation dated February 14, 1975.
The actions taken were to make modifications in the Primary Auxiliary Building and the Diesel Generator Building to provide protection of Motor Control Centers 1, 2, 3, and 4 aCainst the postulated failure of a service water line.
The inspector had no furcher questions concerning this matter.
15.
New Fuel Receipt The licensee has received all 40 new fuel assemblies he intends to install during the refueling outage scheduled to ecmaence October 18.
All assemblics have been inspected by the licensee and placed in the New Fuel Storage Vault.
The inspector had no further questions con-c,crning this mat te r.
16.
In-Plant Audit Procedures The in-plant audit program is now covered in two documents:
Proce-
dure OQA, SVIII-2, "In-Plant Audit Program," and Procedure AP-0208,
"In-Plant Audits."
These procedures resolve the Unresolved Items identified in Region I Inspection Report 50-29/74-16, Detail 5.b(3),
as follows:
a.
OQA, XVIII-2 requires that the auditor review the most current discre: ancy report for inclusion of outstanding items in the area to be audited.
b.
AP-0208 requires that a time 'rame for resolution of audit discrepancies be included in the Plant Position Report.
c.
OQA, XVIII-2 requires that the Manager of Operational Quality Control and Audit document his approval on audit checklists.
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The inspector reviewed the latest In-Plant Audit Summary to deter-mine if the plant was issuing Plant Position Reports in a ti=cly manner after the audit reports are received.
For audits conducted over the past year, most PPR's were issued in 15 days or less f rom the audit report issuance date and the longest time was 36 days.
The licensee stated that he would revise his procedure AP-0208
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to require PPR's to be issuad within 30 days f rom the audit report issuance date.
The inspector hcd to further questions concerning this matter.
Use of the Te rm "NA" in Procedures g
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Use of the term "NA" (not applicable) has been observed by Region I at this and other facilities.
It has been found, at another facility, that reviewers who had recently signed off a completed reactor start-up procedure as acceptable were unable to describe to the NRC inspec-tor why specific steps were "NA."
This situation has made it obvious that blanket use of the term "NA" by procedure perforcers can lead to inade:uacies in review, in addition to providing a ecchanism by which safety-related procedures can be inadvertently modified with-out the required reviews and approvals.
Region I evaluation of the use of the term "NA" is that such usage neither requires nor provides a determination that required proce-dure steps have been satisfactorily accomplished.
It is a require-ment of Criterion V, Appendix 3,10 CFR 50 that safety-related activities be accomplished in accordance with prescribed proce-dures. Disregard of or deviatica frc= procedural steps is not authorized for normal evolutions.
This decs not =can that unnec-essary evolutions cust be accomplished.
For example, if a specific valvc lineup is required, a recent establishment of that lineup incident to another procedure can be an acceptable reference for
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proper accomplishment of that lineup, provided that it has been determined that other evolutions which could have changed the lineup have not occurred in the meantime, and provided that such acceptance does not allow improper changing of the required lineup by performance of other evolutions. Administrative procedures should prescribe the conditions for, and limits over, acceptability of such procedure step accomplishment.
If, however, procedure steps are to be modified, then the appropriate procedure change mechanism must be implemented.
In cases where only one portion of a procedure is to be performed, the reason for such limitation can be noted on the procedure.
Steps which are not to be performed can be crossed out, with a reference to the reason placed in the margin. But it should be emphasized
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j that the reference for not accomplishing a step or series of steps
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needs to be cicarly referenced on the procedure.
Otherwise, con-formance to one or more of the following Appendix B, 10 CFR 50 requirements may not be achieved.
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The' Criterion II requirement for a documented program which a.
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assures that all prerequisites for safety-related activities
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are accomplished.
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a b.
The Criterion XIV requirement for identification of items which
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have satisfactorily passed required inspections and tests in
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order't'o preclude inadvertent bypatsing of such inspections
and tests.
The Criterion XVII requirement that records shall include the i
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results of reviews, tests, audits, and monitoring of work per-formance; with such records to be identifiable and retrievable, r
Conformance to the above identified regulatory requirements will be l
examined during a subsequent inspection.
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18.
Excessive Operational Containeent Leakage Rate The licensse informed the inspector on August 15 that the Vapor
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l Co,ntainer Continuous Leak Rate Monitoring system indicated that the containment had developed a leakage rate in excess of the operational
limits in the Technical Specifications. Preliminary data indicated l
that the leakage rate experienced at 1.4 psig was roughly equivalent to.69 weight %/ day whereas the allowable operational leakage rate is.4 weight %/ day.
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1 After the leak was detected, a controlled plant shutdown was com-
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menced at about 10:30 a.m. in accordance with emergency procedure OP-3007, " Loss of Vapor Contain=ent Integrity." The leak was lo-cated about 1:00 p.m. on a vent header flange and isolated.
The shutdown was terminated and the plant was returned to 98% power.
Preliminary evaluation by the licensee of local samples, environmen-
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tal monitors, and Vapor Containment environment indicates that the
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event represented no significant threat to the public. There was no indication of a release of radioactive material.
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This event was subsequently reported to Region I as Abnormal Occur-rence 75-08.
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