IR 05000029/1988002

Insp Rept 50-029/88-02 on 880110-15.Violation Noted.Major Areas Inspected:Licensee Mgt,General Plant Operations, Control Room Operations,Surveillance Testing,Plant Maint Activities,Design Changes & Engineering Support

ML20153E087
Person / Time
Site:	Yankee Rowe
Issue date:	04/21/1988
From:	Blumberg N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20153E057	List: IR 05000029/1988002 ML20153E054 ML20153E075
References
50-029-88-02, 50-29-88-2, NUDOCS 8805090390
Download: ML20153E087 (37)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 88-02 Docket.N !

License N DPR-3 Licensee: Yankee Atomic Electric Company 1671 Worcester Road .

. Framingham, Massachusetts 01701 l Facility Name: Yankee Nuclear Power' Station and l

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Yankee Atomic Electric Company l Corporate Offices .

Inspection At: Rowe and Framingham, Massachusetts

Inspection Conducted: January 10-15, 1988 Team Inspectors:

J. Kaucher, Project Engineer T. Rebelowski, Senior Reactor Engineer G. Grant, Senior Resident Inspector, Vermont Yankee D. Limroth, Project Engineer D. Ruscitto, Resident Inspector, Seabrook l

Support Inspectors:

l Harold Eicheholtz, Senior Resident Inspector i Cynthia Carpenter, Resident Inspector

OtherNRCPersonneh I naldHa.rkamp,ghief,ReactorProjectsSection3C Approved by: , , / &

N. ~Blumbekg, Chief, Operatyonal Programs M2

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date ;

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Section, Operations Branch, Division of Reactor Safety, Team Leader i

i Inspection Summary: Special, Announced Team Inspection on January 10-15, 1988, l Report No. 50-29/88-02

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Areas Inspected: Special, announced inspection of licensee management, general j

plant userations, control room operations, surveillance testing, plant j maintenance activities, design changes, and engineering suppor Results: One violation was identified which is detailed in paragraph 5. Commercial grade fuses were installed in safety related vapor containment alarm without proper procurement, quality assurance, or configuration I

Controls.

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Strengths and weaknesses are summarized in paragraph 1. of the details section of this repor {DR ADOCK 05000029 DCD

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TABLE OF CONTENTS Page i I

l Introduction and Executive Summary 2

! Plant Management 4 i Plant Operations 6 1 Surveillance Activities 12 Maintenance Activities 13 Design Change / Engineering Support 22 i Main Steam Line Pressure Switch Failure 27 Management Meetings 30

Attachment 1 - Persons Contacted Al i i

Attachment 2 - Documents Reviewed A2 I Attachment 3 - Tests Witnessed A3 Attachment 4 - Maintenance Witnessed A4

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f DETAILS

' Introduction and Executive Summary A NRC Region I Team. Inspection was performed at Yankee Nuclear Power Station-from January 10-15, 198 This-team consisted of_three region based inspectors, two resident inspectors based at other nuclear plants, and a team leade The team reviewed the following areas of plant operations:

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Plant Management

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Plant Operations

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Surveillance Activities

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Maintenance Activities

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Design Changes / Engineering Support In each of the above areas emphasis was placed on the following critaria: -

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Management and sta'f attitudes

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Adequacy of staffing '

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Adequacy of training

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Effectiveness in implementation of program and procedures !

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Management and staff attitudes

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Organizational interfaces

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Management involvement in work activities

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Control room operations .

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Interfaces with other organizations  !

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Management involvement in day to. day activities l Configuration control

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Work control

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Quality assurance and quality control oversight Inspectors held discussions with plant management, plant operators,

maintenance and test personnel, and staff engineers as well as other

personnel as appropriate. One team member and the team leader. spent one day at the Yankee Atomic corporate engineering offices, located at Framingham, Massachusetts. The inspection also involved extensive witnessing of control room activities, surveillance testing, and maintenance activities. Plant tours were conducted to determine the condition of plant equipment, general plant operations, and overall-housekeeping. Each area was given an in-depth review and activity interrelationships we*e evaluated.

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General Conclusion and Summary of Findings At the beginning of the inspection the licensee was informed that inspection was to be evaluative in nature and not strictly compliance oriented. However, the licensee was also informed,_that any violations identified would be noticed in the inspection repor Based on the i extensive review by the inspectors and discussions with licensee representatives the inspectors were able to form conclusions as to significant strengths and weaknesse These are summarized below and further detailed in later sections of'this report. .Each strength or weakness is based on perceptions by the inspector and specifically observed conditions in the plant. In addition one apparent violation of NRC regulatory requirements is also summarized belo Strengths ,

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The plant has a small, stable staff which facilitates ease of I cperation (Paragraph 2.2)

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The plant appears to be well maintained with excellent housekeepin (Paragraph 3.3.1)

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The plant staff is committed to safe, conservative operation (Paragraph 2.4.1)

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Control room operations and shift turnovers were excellent, and the operators displayed positive attitudes. (Paragraph 3.3.2) '

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Control room annunciators operated in an almost "black board" condition. (Paragraph 3.4)

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The maintenance craftsman exhibited a pride in performance and a knowledge of maintenance. (Paragraph 5.4.1)

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Maintenance backlogs were minima (Paragraph 5.3.4)

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Corporate engineering support in the area of design $

modifications appeared to be excellent. (Paragraph 6.3.3) '

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There was a strong interface between corporate engineering and the plant staf (Paragraph 6.3.3) Weaknesses l

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Administrative procedures, while promulgating requirements, did not appear to adequately detail how functions were to be performe (Paragraph 2.1)

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There appeared to be an occasional lack of aggressiveness resolving ~ problems identified during plant operations and a lack ,

of a questioning attitude. Personnel were not attentive to -'

certain problems. (Paragraph 3.3.1)

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Use of the Shift Supervisor to process switching.and tagging ~

orders appears to be detract from his overall management of the shif (Paragraph 3.3.3)

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Trending of maintenance problems needs improvemen (Paragraph 5.3.6) ,

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Vendor manual control is not well develope (Paragraph.5.3.7)

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The Maintenance Suppert Department concentrates on design !

changes rather than on plant maintenance problems. (Paragraph 6.3.4) l

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Slow corrective action take by the licensee regarding complementation of design changes for the main steam line pressure sensing switche (Paragraph 7.4) Violations

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A blown fuse located in a vapor container high pressure alarm was replaced in kind with a commercial grade fuse located in the stock room. No engineering evaluation had been accomplished to j assure adequacy of the fuse for this safety related use. In i

addition. there was a lack of configuration control in that

! there were no drawings which indicated the kind or size of fuse which actually belong in the alarm circuitry. (Paragraph 5.3.9)

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2.0 Plant Management l

2.1 Management Effectiveness Plant inanagement effectiveness was assessed through interviews with !

key licensee personnel, review of administrative controls and observation of performance of plant activities and discussions with plant supervisory and technical personnel. The inspectors reviewed

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management's cermitment to reactor safety and quality, to. assess if the goals and objectives of management were effectively communicated to personnel responsible for performing the task, and to assess the

, licensee's action to modify and upgrade the program and associated d

controls as dictated by the licensee's own assessment of their

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The overall assessment of management effectiveness is reflected in the material condition of the plant. The plant appears well maintained and plant cleanliness was excellent. Leaks were almost non-existent, equipments / systems out of service were minimal,-and no persistent alarm conditions were noted in the control room

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Management direction was adequately communicated to those assigned responsibility for performing the function through a system of administrative controls. The inspector reviewed several procedures in various categories, such as plant operations, maintenance,:and surveillance. These procedures were generally excellent.and provided the depth of detail in orderly form to permit verbatim complianc On the other hand, procedures dealing with. administrative matters were usJally a summary .of requirements extracted from applicable- ,

guides and standards to which the plant was committed. The I procedures, however, did not appear to adequately detail how ]

functions were to be performed. While uniformity was noted in the I execution of these administrative tasks (e.g., swite..ing and tagging, l control of lifted braces and jumpers, etc.),;it would appear that I such uniformity is more attributable to training and staff stability than to the adequacy of administrative procedures. Accountability is '

well-defined for outstanding tasks and recurring functions. Open items and committrents are tracked by means of a computer based

"Project Commitment Tracking and Responsibility System." An inspector J reviewed a recent printout of :he system and noted several overdue item A concern was noted in the conduct of removing equipment from service. The component realignment is relayed orally to the appropriate operators involved who report back, again orally, when the operation has been completed. The Shift Supervisor records the  ;

name of the person (s) performing the lineup (s). Use of the  ;

Switching / Tagging Order (APF-0017.1) by the appropriate operator and signing that the action has been performed is more usual in industr No discrepancies in component lineup were identified; however, the i system appeared to be an informal control mechanis l

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2.2 Plant Staffing The staffing of the site was reviewed. Staffing is unusually stabl i Functional responsibilities detailed in position descriptions and

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specifications were compared with other administrative controls in  !

order to assess the adequacy of staffing. Backlogs of maintenance and technical support efforts were similarly reviewed. These reviews  !

indicated a relatively constant backlog which leads to a conclusion j that the station staff is adequate to maintain the status quo. Some current initiatives to turn over more modification work to Yankee

Nuclear Services should permit the station staff's Maintenance Support organization to reduce its backlog.

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2.3 On-site and Safety Review Corrmittee The composition of the Plant Operations Review Committee (PORC) was compared against the requirements of Technical Specifications and was determined to be in compliance. The PORC is comprised of the l

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majority of the station's middle and upper. level management. The

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responsibilities of the PORC are well-defined and a review of PORC meeting minutes indicates that these responsibilities are being-satisfie The inspector attended one regularly scheduled weekly meeting. _The

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meeting was used as a mechanism to brief plant management regarding status, operations and potential problems. One procedure' revision was reviewed in detail; considerable management effort was expended in that review which might have been precluded through a more effectively conducted pre-meeting revie .4 Summary of Findings and Conclusions 2. S_trengths  ;

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A stable plant staff which permits facility operation with a minimum of administrative procedure An effective corrective maintenance and housekeeping program evidenced by excellent material condition and overall !

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A staff committed to safe, conservative operation who have '

sustained an exceptional plant availability recor '

2.4.2 Weaknesses

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Administrative procedures do not appear to adequately communicate how functions are to be performed but serve more to prescribe requirements and promulgate forms to be employed.

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The system used to remove and restore equipment from service is informa ;

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3.0 Plant Operations 3.1 Operations Overview - Scope of Inspection Licensee performance was assessed in the area of plant operations as it related to nuclear safety, regulatory conformance, management control and involvement, administrative control and overall plant

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conditions. Assessments were based upon interviews, discussions, document reviews and direct observation of facility activitie Specific assessment criteria included:

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Overall quality of operations related procedures and policies including control, dissemination, explicitness and l applicabilit ;

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Adherence to procedures and policie Degree of management involvement in routine plant operations and activitie Effectiveness of established corrective action systems including recognition, promptness, threshold and lack of repetitio Overall quality of plant operations related record Conservatism and soundness of approach to tecanical issues of safety significanc Adequacy of staffing including experience, vacancy rate, depth and minimization of overtim Evidence of training effectivent, Staff attitude as demonstrated by inquisitiveness ir problem identification, thoroughness of problem resolution, attentiveness, attention to detail and regulatory interfac I These criteria were applied, as appropriate, throughout the inspection and in the specific areas reviewed as discussed belo Findings and conclusions were based upon data available d; ring the inspection effort and the degree of attainment of the ass!ssment criteria demonstrated during the inspection perio .2 Inspection Criteria / Elements Reviewed A comprehensive plant inspection was performed to ascertatn overall material conditions. Assessment items included equipment condition, operability of standby equipment, maintenance and surveil',ance activities, radiation protection control including instruments and practices, fire hazards, missile hazards, plant secteity tnd general housekeeping. Additionally, a detailed review of control room activities was performed on numerous occasions. Control room instruments were observed for correlation between channels, proper functioning, and conformance with plant technical specification Alarm conditions in effect and alarms received in the control room were reviewed and discussed with operators. Operator awareness and response to these conditions were reviewed. Control room and shift manning were compared with technical specification requirement .-- . _ . . - . - - _

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3.3 Areas Reviewed 3. Plant Tours The plant was found to be in generally good condition. Absence )

of fluid and air. leaks, accessibility in radiological rintrol areas and quietness of equipment operation were noteworth ;

Overall plant cleanliness was. excellent. Control room !

conditions and operator attentiveness were generally good with the below noted exceptions. During a detailed control room review on January 11, at approximately 3:00 p.m., an inspector noted that No. 4 Steam Generator Steam Flow had been increasing continuously for-the previous four hours as evidenced by an increasing ramp on No. 4 Steam Generator chart recorder ,

(MS-FLR-4000). The other steam generator steam flows were constant. Additionally, No. 4 Steam Generator feedwater flow and level showed no change. Comparison with front panel indications showed that the meter indication for No. 4 Steam -

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Generator Steam Flow also exhibited an abnormal value. When questioned by the inspector, operators were unaware of this anomalous indication and could not immediately determine the probable cause. Subsequent licensee actions included issuance of Maintenance Request 88-76 for I&C investigation. The cause :

was eventually determined to be freezing of the No. 4 Steam -

Generator pressure sensing line. A similar freezing of the N Steam Generator pressure sensing line subsequently occurred on '

January 11. This incident appeared to demonstrate less than i fully effective control room status review by the operator ^

During a control room observation period, the inspector noted a failure of the safety parameter display system (SPDS). The SPDS computer was off line for approximately one-half hour. During !

that time the inspector discussed the requirements of Technical '

Specification 3.3.3.5, "Accident Monitoring Instrumentation,"

with the on-shif t operators in the control roo This discussion revealed that there was no generally accepted criteria for determining the operability of the incore and .

reactor head thermocouples. Both sets of instruments are composed of a primary and secondary display. The primary display is the SPDS and the secondary display is the main '

ccntrol board indicators. Surveillance procedure OP-4272,

"Accident Monitoring Instrumentation Channel Check," is performed monthly. This procedure is used to meet the :

acceptance criteria of T.S. 3.3.3.5 monthly surveillance, and i requires one thermocouple in at least 3 core quadrants to be operable at either the primary or secondary display. Addition-ally, the total number of operable channels must be eight, but no display is specified for these eight channel i i

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9 I The channel check requirement for the primary display indicates that one of the two reactor vessel head thermocouples must be operable at the primary or secondary display. The channel check requirement for the secondary display has identical wording but also indicates that the total number of channels required to be operable is tw It is unclear what channels or portions of channels are allowed to be out of. service in order to meet the requirements of :

3.3.3.5. The Operations Department managers were unable to provide any basis for the confusing wording of either require- t ment. A review of the licensing correspondence between YAEC and the NRC provided no further clarification on the intent of .3.3.5 with respect to the licensing basis for the Yankee Nuclear power Statio l Definitive written guidelines are needed for the operating

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staff to use in making operability determinations using SPD This item remains unresolved pending completion of licensee action and NRC review (50-29/88-02-01), i 3. Shift Turnovers l

Several control room shift turnovers were observed. Adequacy of  :

information exchange, formality, checklist completion, control board walkdowns and log reviews were assesse The inspectors i uniformly found shift turnovers to be_ disciplined, well controlled and quiet evolutions. Althot.gh maintenance, I&C and i other non-operations personnel quietly waited for shif t turnover l to be completed, their presence unnecessarily adds to the 1 control room activity leve Decreasing the number of personnel )

in the control area of the control room during shift turnover would increase the effectiveness and efficiency of the proces l Traffic patterns in the control room occasionally create excessive extraneous distractions in the control area. The noise level of conversations in the area of the Secondary Alarm Station (SAS) are also distracting at times. Operator-

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tions. However, more effective isolation of the control areas would reduce extraneous activity and improve the control room ,

atmosphere, j 2.3.3 Operatine Documents During control room tours, logs and records were reviewed to j ensure compliance with station procedures, to determine if i entries were correctly made, and to verify correct communication i j of equipment status. These documents included: Station Logs l l

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Nos.1 and 2, Primary and Secondary Log sheets, Special Orders, Temporary Change Request (TCR) log, Switching and Tagging log, Shift Supervisor's log, Maintenance Request log and Shift Relief Checklist All logs were maintained in accordance with applicable procedures and appeared to adequately communicate plant and equipment status. The TCR log appeared to have an excessive number of entries, indicating overuse of the TCR syste Although Procedure AP-0018, "Temporary Change Control," allows exclusion from this procedure if temporary changes are positively identified and controlled by other types of approved procedures, TCR's were being written anyway possibly cluttering up the TCR system with unneccesary change Observation of switching and tagging evolutions identified two potential weaknesses. Use of the Shift Supervisor to process Switching and Tagging Orders appears to detract from his overall management of the shift. The practice of the Shift Supervisor verbally transmitting multiple valve and switch position changes over the phone system to an auxiliary operator increases the potential for component mispositionin .3.4 1 raining Effectiveness Interviews and conversations with plant personnel regarding various training programs indicated positive attitudes pertaining to training effectiveness and qualit Inspection during the control room day shift identified several Reactor Operator (RO) and Senior Reactor Operator (SR0) candidates involved in control room activities. Their level of knowledge appeared good and their involvement in plant activities was extensive. Performance of OP-4207, "Surveillance of the Station Power DC and AC Distribution Systems and the Emergency Diesel I Generators," was observed by an inspector and included l appropriate R0 trainee involvement. Trainee supervision was excellent. Time spent by the R0 discussing the procedure, equipment and system interrelationships demonstrated a commitment to increasing training effectiveness. This same attitude was apparent during the performance of OP-4623, "VC Post Accident H2 Analyzer HV-GA-1 Calibration," which involved an I&C traine ,

3. Procedures Procedure reviews were performed for the documents listed in Attachment 2 to this repor Overall, procedures appeared to effectively control plant processes, operations, surveillances and administration (except as noted in paragraph 2.1). A satisfactory balance between necessary detail and over proteouralization appeared to have been accomplished in most procedures. Observed procedural compliance was excellent. The Special Orders notebook contained good amplification of plant

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abnormalities but it was unclear as to what csnstituted a "long term" versus a "short term" condition. Special Orders were prepared to be used in place of temporary modifications to procedures, such + hit the requirement for review and approval are bypasse If a plant abnormality requires modification of normal activities, then either a temporary procedure or a temporary change to an existing procedure is appropriat .4 Summary of Findings The licensee conducts plant operations in a professional, safe and conservative manner. Shift turnovers were thorough and log keeping was adequate. Activities were generally well understood and were conducted with care and formality. Operators responded effectively to equipment failures and contro? room alarms. Except as noted in paragraph 3.3.1 operator alertness and attentiveness was eviden During the inspection, at any given time, only one or two alarms were activated in the control room cad the causes were being pursued. The lack of alarming main control board annunciators minimizes operator distraction. Operators exhibited positive attitudes, a keen interest in operations excellence, and their plant knowledge was judged to be very good. This same observation of positive attitudes was evident in nearly all plant personnel contacted during the course of the inspectio A weakness identified during the inspection was a general lack of skepticism pertaining to plant operations and related activitie Discussions with plant staff consistently demonstrated an occasional lack of aggressiveness and a lack of a questioning approach to problem resolution. Years of excellent plant performance may be the cause of the above complacent attitude. Some examples of not being sufficiently aware of problem areas include the following: ;

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Control room operators did not note an increasing trend in No. 4 Steam Generator Steam flow over a four hour perio I&C personnel did not question the possibility of a malfunctioning No. 4 Steam Generater feedwater control system as evidenced by an increasing steam flow signal without attendant control system reactio Effective corrective action was not taken to prevent recurring problems with steam generator pressure sensing line freezin Past freezing problems were not fully accumented in machinery history record Management attention is required in this area to develop an atmosphere of active questioning of the status quo and aggressive pursuit of root cause determination .

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J 4.0 Surveillance Activities '

4.1 Surveillance Activity Overview - Scope of Inspaction i The team evaluated licensee performance in th ruoctional area of surveillance by witnessing surveillance tests in progress and

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reviewing past test dat .2 Inspection Criteria Surveillance activities were assessed in three areas. The following attributes were evaluated:

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4. Surveillance ~est Program

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Master surveillance schedule

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Approvals for maintenance and tagouts 4.3 Areas Reviewed I 4. Surveillance Test Program Administrative procedure AP-0041, ii ant Surveillanca Schedule" includes two relevant attachments. Attachment A of AP-0041 details each 5pecific T.S. requirement and its 1 associated surveillance procedure, applicable mode and t frequency as specified in ANSI N18.7-1976. Administrative i Controls and Quality Assurance for the Operational '" ,: 9 of Nuclear Power Plants, section 5.2.8. Attachment B ludes I other YAEC surveillancas such as those required by 3dREC-0737,

"Clarification of TMI Action Plan Requirements", and the YAEC Physical Security plan. Administrative procedure AP-0220,

"Surveillance Tests and Records" provides specific guidance on the responsibilities, for and implementation of the surveillance progrgm.

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Operations and maintenance department schedules, administrative procedures AP-2005, "Operations Department Surveillance Schedules" and AP-5000, "Maintenance Department Surveillance Schedules" respectively, are promulgated using AP-0041, "Plant Surveillance Schedule" as a basis. These schedules provide specific day by day requirements in a four week cycle as well as other specific requirements of varying periodicity. T inspector reviewed the weekly operations surveillance schedul .3.2 Surveillance Procedures The inspector reviewed administrative procedure AP-0001, "Plant Precedures" for conformance to Regulatory Guide 1.33," Quality Assurance Program Requirements," with respect to surveillance procedures. Various 4000 series surveillance procedures covering operations, maintenance and instrumentation were verified on a sampling basis. A specific review of several proceduras was conducted in the course of the inspection. The procedures were technically accurate and included appropriate acceptance criteria with one exception concerning the testing of SPDS which is addressed in paragraph 3.3.1 of this report. The procedures were determined to reflect the requirements of the technical specification .3.3 Test Witnessing and Results Review The inspector observed performance of surveillance procedure OP-4217, "Charging System Operability Test" for the running charging pum The inspe.ctor reviewed the surveillance data associated with the recent main steam 'ine pressure switch failures. Surveillance ;

procedure OP-4656, "Function Test of the NRV Main Steam Line '

Pressure Channels", as completed on December 3, 1987, provides e.omprehensive information on "as-found" and "as-left" conditions including accurate amplifying informatio .4 Findings / Conclusions l

l The licensee is conducting its surveillance program in accordance with regulatory requirements. No strengths or weaknesses were noted and no violations were ident,fie .0 Maintenance Activities 5.1 Maintenance Activity Overview - Scope of the Inspection I

The inspection team assessed the licensee's performance in the functional area of maintenance. Included in the asessment of naintenance in progress were observations, disscussion with maintenance management, atte dance at scheduling meetings and review of peripheral areas that support maintenance activitie O

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The following areas of maintenance were assesse Maintenance Organization and Management Oversight:

Elements included the organizational structure, scheduling of safety related correction and preventive maintenance and Maintenance Support function Adequacy of Maintenance Department Staffing:

Element included the need for additional staffing, quality of staff and tradesmen and attitudes of the staff:.

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Training and Qualifications Elements included formal tra?ning and On-The Job Training (0JT).

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Planning and Work Control Including Maintenance Backlog Elements included maintenance manager contribution to planning and the conduct of maintenance request progra Witness Preventive and Corrective Maintenance In Progress:

Elements included observation of craftsmen in the performance of both corrective and preventive maintenance activitie Failure Trending Elements included contriFution of surtrvision versus the l Mair.tenance Support Department inputs to trend component !

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Element included a vendor manual program revie ,

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Quality Assurance / Quality Control (QA/QC) Oversight of the Maintenance Program Elements included QA surveillance of maintenance and audits of departmental records and corporata assessment The individual areas assessed are described in the following ;

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15 5.3 Areas Reviewed 5.3.1 Maintenance Organization and Management Oversight The Maintenance Organization as structured at this facility consists of a Plant Maintenance Manager (PMM) who reports to the Assistant Plant Superintendent. The supervisors of the Instrument and Control, Maintenance and Maintenanct Support departments report to the PMM. Under each department a core of permanent trades;..an are augmented by personnel from a contractor, New England Power Services. As an example, the makeup of the Maintenance Department consists of two supervisors with sixteen permanent tradesman supplemented with fif teen additional tradesman from New England Power Services. Three additional foreman are scheduled to report in early 1988; one of which is to be assigned as permanent planne The maintenance sversight function consists of daily meetings of the PMM with his staff and meetings with the Assistant Operations Superintendent and the routine site committee meetings. In addition numerous audits by the Quality Assurance corporate auditors and site staff auditors, assess the performance of the maintenance department on a scheduled frequency. The corporate quality assurance audits review maintenance areas on a scheduled basi The Maintenance Support Department is considering an adjustment to ref'cus its efforts on the support of maintenan;e and the retraction from its previous role of plant design change reviews and modification support. This item was discussed with PKM and he restated his goals to extend the maintenance support function to these area No violaticas or deficiencies were identifie .3.2 Adequacy of Maintenance Department Staffing The Maintenance Department staffing is presently changing 1 in that a new maintenance manager has recently been '

appointed. A posicive attitude in the maintenance function is evident from discussions with 'irst line supervisors and l tradesmen. Management has suppo- >1 the Maintenance Departmen goals by providing additional supm visors, a maintenance planner I and an iacrease in tradesmen to support all program areas. The l staffing is presently adequate with its sights set at using the ,

increasing staff to address needs of on sitt supervision and '

increased planning functicc I The stable core of tradesmen with their added degree of !

experience has translated into a attitude of "du the job right l the first time." I I

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5.3.3 ~ Training and Qualification

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The licensee's maintenance training program has historically i been conducted by the department supervisors. The qualification ,

of tradesmen is followed by ~the recording of areas of studies on  ;

1 the individual personnel records. Due to one annual review '

t of personnel- records, the early recognition of the need for -

further training is not pinpointed on a timely basi !

A new formal training program under the training manager for l

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maintenance, IC tradesmen and technicians'has been formulate OPS 14, '! Balance of Plant Training Program," and AP0226,

"Qualification and Training of Personnel" have been designed to i complement each othe Since issuance of the latter procedures, a needs assessment is in progress to identify requirements for -

aew training programs and improving the programs already in force. As a result of the assessment, a task inventory has been

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conducte In addition, the training personnel staff has been i i increased for balance of plant cnd safety equipment training, i

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Specialists in job analysis have been assigned to this review of '

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trsdesmen f.eed l The formal training program is still in the early stages of (

formulation. During this changeover period the on-the iob- l training (0JT) combined with the supervision by department heads 1 is to continue. Because of the experience level and long tenure

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, training programs does not indicate inadequate training of personnel. The contractor personnel training could not be ascertained from training department. It was noted that quality l lesson pians had been written and are implemented during the new -

personnel indoctrination to plant systems. No violations or -

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' s 5.3.4 Planning and Work Control Including Maintenance Backlog  ;

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The Maintenance Managers Plan of Day is the major element in planning maintenance. The discussions among department '

supervisors determines priorities and manpower availabilit '

' The work is controlled by the "Maintenance P,equest" (AP 0205) *

packages. The packages contain all necessary documents l i

ir.cluding retest requirements. A review of these packages  ;

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indicated that personnel are adhering to the requirements of the j cpecified retests, Operations Quality Assurance hold points and  :

a required department review In addition criteria and '

responsibilities have been established for review and approval l

' of maint.enance requests, designations of safety related systems, inspection and functional testing.

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i The_ licensee tracks the backlog of maintenance requests and

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designates the "window of opportunity" to accomplish these

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tasks. The present backlog of maintenance requests _is less than 200 with the majority of items scheduled to be accomplished p during an unscheduled unit shutdown or'during the'next refueling outag The inspector reviewed several completed maintenance requests and no deficiencies were-identified. The licensee has

!- vigorously pursued the-various maintenance problems during the

, 1987 period, completing 1008 Maintenance Requests. The

maintenance request program which includes weekly reports and monthly updates of. the backlog, is considered a management- -

strength. Na violations or deficiences were identifie ;

5.3.5 Witnessing Preventive and Corrective Maintenance In P,togress l

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During the inspection the following preventive and co'recthe !

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maintenance activities were witnessed:

] NOTE: See also paragraph 5.3.9 concerning witnessing of ,

Maintenance on Vapor Container Pressure Instrumen '

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Control Room Emergency Air Control Suony j

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Observation of the calibration of a flow instrument No.

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AD-0P1-3, which measures air AP across the charcoal filters was monitored. This component of the Air Disposal System >

had four instruments that were calibrated using a Dywer Red ,

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' 011 Manometer No. 3528. During the initial application of -

test pressure, fluctuations in pressure were experienced, i

The technician determined that a accumulation of moisture !

in test tubing was cause of malfunction. Test lines were :

cleared and calibration continued. Test resilts satisfied '

test criteria and no adjustments were required to complete l l the calibratio :

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Diesel Fire pump Batteries *

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To ensure the reliability of the Diesel Fire Pump Batteries ;

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the licensee conducts a preventive maintenance inspection of the 24 volt battery bank. The inspector witnessed j technician performance of:

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- #1 and #2 Battery Bank overall voltage check l

- Pilot Cell specific gravity readings with correction

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factor to specific gravity applicd

- Battery temperature readings j - Check of battery electrolyte levels All acceptance criteria were met. It wts noted that the I

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procedure sequential steps require recording specific

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gravity prior to mea urement of electrolyte levels. If

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additional water was introduced to a cell, a dilution of e- the specific gravity levels occurs. A check of .  ;

the specific gravity (S.G.) af ter the addition of water. was

discussed with the licensee and is under licensee's procedural enhancement revie During the tours of.the plant and during test observations, '

the housekeepino was.found to ba excellent. The

technician and 4C personnel were knowledgeablo of calibration and surveillance procedures and expressed a positive sttitude in completing procedures satisfactorily

or pursuiig causes of test anom.slie ,

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No violation or deficiencies were identifie ,

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5.3.6 Failure Trending

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The program of failure trending of components is minimal. Each individual department performs a review of anomalies. Manually documented machinery history cards are the aids in determining a

trend in the condition of components. The trending reviews are '

{ not done by the maintenance support section because of 'other ;

designated priorities. The reason for the minimal trending i program appears to be a concentration in the review of plant :

design changes causing little support to the maintenance  !

i program. DiscJssions with management indicated tha {

refocusing of maintenance support function has been defined and '

additional attention to trending is one of the present Support q Support Department goal .3.7 Vendor Equipment T,echnical Information Program

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Procedure AP-0075 the "Vendor Equipment Technical Information j 3 Program" has recently been issued. This program calls for

control of technical information for equipment requiring qutlity

, assurance but has not been implemented on-site. The decision by ,

' the licensee not to include vendor m:nual Balance-of-Plant i equipment was discussed during a review of this item at the

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Corporate Headquarters. The licensee stated that such a program would be implemented in 198 .

5. "/QC Oversight of Maintenance i

The Quality Assurance and Quality Control oversight of the

! maintenence program contains elements that monitor surveillance

{ and job onsite observation with additional audits of the

operations of maintenance departments adherence to the administration and departmental procedures. Procedure OQA-X-1, Quality Assurance Surveillance addresses administrative i

controls for planning implementation, reporting and resolving ,

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The onsite Quality Assurance Supervisor (CAS) maintains, together with Quality Assurance Engineer (QAE), the planning of surveillance and observation and scheduling of activities. The 1988 audit schedule addresses in plant audits of 19 areas, with teams of QA/QC corporate and onsite personnel with specific maintenance audits scheduled. The onsite staff requires additional technical expertise in some areas. These areas are supplemented by the corporate and/or contractor personnel. The QA section is functioning satisfactoril In addition the Quality Services Group addressed maintenance conduct in performing vibration monitoring, surveillance testing and corrective maintenance program surveillances during the first quarter of 1988. Only a minimum number of items appear on the Plant Audit Discrepancy Report (PADSR).

No violation or deficiencies were identifie .3.9 Repair of Vapor Container Pressure Instrument During this inspection, maintenance was required on one channel ;

of the wide range vapor container (VC) pressure instrumentatio This instrument loop senses VC pressure and consis,ts of a power supply, bistable, and indicator, all in a control room cabinet along with the pressure transmitter located in the primary auxiliary building. The inspector reviewed control room indications and local hardware. The pressure indicator, VC-PI-243, in the control room read one to two psig, a normal condition for the VC. The SPDS readout was 2.1 psig. The high pr.ssure alarm annunciator window was lit and would not reset (setpoint 3.0 psig). Maintenance request MR 88-67 was initiated for I& 3epartment troubleshooting and repair. The inspector observed initial I&C activities and discussed the work with the lead !&C technician and the I&C Superviso The failure was I determined to be a blown fuse in the line to the bistable high pressure alarm (VC-HPA-243). The fuse was replaced "in kind" from stock in the control room. The channel was then checked, l the bistable reset and the channel returned to service. No root l cause evaluation was performed to determine the cause of the '

blown fus A violation involving the improper use of commercial grade components and lack of design control was identified. NRC 3 Information Notice 87-62, "Mechanical Failure of Indicating Type Fuses" and NRC Information Notice 87-66, "!nappropriate Application of Commercial Grade Components," describe industry events which relate to this issue. Administrative procedure !

AP-0204, "Safety Classification of Systems, Components and Structures," states that safety class instrumentation systems require quality assurance measures in accordance with the Yankee l

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Operational. Quality Assurance Program (YOQAP). Additionally, it-states that small spare parts having no traceability, such as !

commercial off-the-shelf items, may be purchased as nonsafety-related and then qualificd'for use in equipment requiring a quality assurance. 10 CFR 50, Appendix B, Criterion VII, q

"Control of Purchased Matarial, Equipment and Services," the Yankee Operational Quality Assurance Program Manual and Administrative Procedure AP-0211, "Material and Service Procurement Program" requires that measures be taken to assure that purchased material conforms to procurement documents and *

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that records of such conformance be available for inspection and

. be retained. These requirements were violated in that no '

l program has ever existed at Yankee Nuclear Power. Station to establish controls to ensure that commercial grade fuses possess the required measures of assurance to allow use in safety related applications Since no program exists, no documentation has been retained to ensure that all purchased material conforms to the procurement documents. In addition to the above i violation, a second concern was identified during this repai CFR 50, Appencix B, Criterion III, and the Yankee "Design Control" Operational Atsurance Program Manual state that s measures shall be established to assure that applicable e regulatory requirements and the design bases are currently i

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translated into specifications, drawings, procedures and instructions. Inese requirements were violated in that no design document contains information on what size fuse is to be ;

installed in the VC pressure instrument channel. Inspector

, discussion with Yankee QA and I&C personnel indicated that this deficiency is indicative of a past less stringent configuration ;

control for this plant. This is probably the result of the fact i that Yankee Nuclear Power Station was designed and constructed :

prior to the implementation of 10 CFR 50 Appendix B. This particular design change, however, was initiated in 1979 as a result of the TMI Action Plan long after 10 CFR 50, Appendix B

! became a regulatory requirement. Inspector discussion with an

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i I&C Technical Support Engineer indicated that this deficiency l l has been known for some time and fuse sizes are presently j incorporated in new design changes. Because Yankee Rowe was ;

built before certain current QA requirements were in place, a l

I number of instruments channels and possible electrical control '

circuits are installed where no designs bases exists with respect to fuse size a d type. When notified of this specific j deficiency, licensee engineers performed a calculation to verify

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that the installed fuse was, in fact, adequate for continued j

use. Although current program are in place for the design change process (see paragraph 6.3.1) to assure design basis and j configuration control documentation, the licensee presently has

no program to establish a design basis or configuration for plant equipment installed before the current control program was implemente <

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21 The above two examples of non-compliance with 10 CFR 50, Appendix B constitute a single violation of NRC requirements (50-29/88-02-02). The safety significance of this deficiency is that improperly sizeii or time-delayed fuses may not provide adequate circuit protection resulting in the possible loss of safety related indication and/or control feature .4 Findings / Conclusion 5. Strengths

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The following strengths in maintenance programs were noted:

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A pride in performance of maintenance and housekeeping thus exhibiting loyalty to licensc A stability in tradesmen with its accompanying knowledge of maintenance requirement Minimal maintenance request backlog with early response to identified problem Excellent housekeeping in many area .4.2 Weaknesses The tollowing maintenance areas appear to be weaknesses and require more licensee attention:

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The Maintenance Support Department concentrates on design changes rather than maintenance problee The licensee planning function needs improvemen The l

proposed additional planner should hel Trending of maintenance problems needs improvemen Commercial grade certification program has not been l

! develope Drawinc updates of electrical protection devices requires

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licensee revie The Vendor Technical Manual Information Program has not been fully implemented and does not apply to balance of plant equipmen l

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6.0 Design Change / Engineering Support 6.1 Design Activity Overview - Scope of the Inspection The objective of the inspection in the area of design change /

engineering support was to gage the performance of the plant staff and Yankee Nuclear Services Department (YhS0) in routine activities t such as procedure development, solving day-to-day plant engineering problems, modification design work, training, safety reviews, engineering problems, modification design work, training, safety reviews, QA monitoring of engineering activities and configuration contro .2 Inspection Criteria /Eleme.1ts Reviewed Engineering and related activities were evaluated during the process of the inspection, and are categorized as follows with attributes assesse .2.1 Configuration control,

- Procedural control

. - Program elements

- Design traceability

- Program upgrades 6.2.2 10 CFR 50.59 Safety Review P,rocess

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- Procedural guidance

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- Qualifications of reviewers

- Adequacy of reviews 6.2.3 Modification Design Process

- Procedural Control

- Design Verification

- Engineering Interface

- Control of modification process

- Personnel qualifications

- Drawing Control

- Engineering calculations .

- Post modification testing l

- Closure of modification packages

- Training of engineering staff '

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6.2.4 Engineering Involvement in Plant Activities

! - Maintenance process involvement

--Root cause analysis I - Performance trend analysis

- Procedural guidance .

6.2.5 QA/QC Oversight-

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- Procedural control

- Personnel qualifications

- Involvement in engineering process

6.3 Areas Reviewed

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6.3.1 Configuration Control -

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Yankee Atomic has a configuration control program for the Rowe- ;

project for recent and current design changes. This program '

consists of several elements, namely; engineering manual  ;

procedural guidance, a controlled document system, design basis ;

index, updated technical manuals, setpoint study, plant life i

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extension program, MOVATS, and seismic classification  !

documentation. Progress has been made in several areas and  ;

goals have been established for completion of all element ,

i The completed Design Basis Index is an a detailed document  !

which contains a data base listing of design basis documents by i

FSAR sectio The design basis index is a tool which is be  !

used to verify and maintain the design basis of plant system '

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The inspectors reviewed the implementing procedures for all of  ;

l the configuration control element '

j The implementing instructions are sufficiently detailed to  ;

provide adequate definition, guidance and performance standard !

However, as dicussed in paragraph 5.3.9, the licensee has no i

, program to establish a design basis for. plant equipment l i installed before the current confirguation control program was i implemented.

a 6.3.2 10 CFR 50.59 Sa/ety Review Process ,

i i The guidance far performing safety reviews for determining '

unreviewed safety questions at the Yankee Rowe Site is i

contained in two procedures; AP-0018, "Temporary Change j Control," and AP-0200, "Plant Modifications." The guidance '

provided in these procedures has been updated within the last

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four months in an effort to improve the quality of safety i evaluations. No single procedure is dedicated specifically for  ;

, performing safety evaluations and determinations of unreviewed i safety question '

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The team reviewed several 10 CFR 50.59 evaluations contained in i Plant Design Change Requests in order to determine their completeness, validity and consistency. The safety evaluations ,

were discussed with the Maintenance Manager and the Maintenance ;

Support Supervisor. The safety evaluations reviewed by the 1 inspection team although adequate, were not alvvays as detailed i'

as needed to clearly evaluate the criteria ccntained in 10 CFR 50.59(a)(2). Additionally, the depth of review was not consistent. The recent revisions to AD-0018 and AD-0200 appear :

] to give better guidance and should aid in improving the quality of safety evaluations and determinations of unreviewed safety

question .3.3 Modification Design process The procedures which govern the design process, both at the Yankee plant and at YNSD, are clear and detailed. Design interface, design process and corrective action requirements are ,

adequately addressed in the procedures with appropriate control !

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forms and instructions provided. YNSD is considered the primary design agent for all modifica+,1ons and has review and approval authority on both plant design change requests (PDCR) and  ;

engineering design change requests (EDCR). l The team reviewed a total of tan design change requests, listed !

in Attachment 2. The level of licensee review, approval and ;

verification were in all cases appropriate for the complexity of

the chang Review ccmments were found to be substantive and '

l were resolved with sound technical justificatio In all cases '

l appro,nriate cross discipline review was performed and documente The design ch.1ge packages were complete and detaile There was evidence of a strong interface between the Yankee Maintenance Support Department and YNSD. Calculations ;

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. contained in the design change packages were technically correct :

and performed in accordance with applicable procedures. The ;

closure of the EDCR's and PDCR's was performed in a timely i fashion and made a part of the permanent plant records.

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The team interviewed several members of both the Maintenance Support Department and YNSD staff and found them to be i knowledgeable and motivatsd. The training program for the j Maintenance Support Department was found to be adequate and is

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conducted in accc.d .1ce with the governing procedure. The level

] of experience / education of personnel exceeds the procedural requirements.

! The team reviewed the post modification testing requirements j specified in both the EDCR's and PDCR's and found them to be 4 adequate to determine both the static and dynamic i

characteristics of the systems. Various types of tests are specified, including: surveillance tests, pre-operational tests

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The control of drawings aff?ctad by the modification process is procedurally controlled and adhered to. Drawings were found to be accurate and to receive an appropriate level of review and approval. The master of a crawing in the process of change is annotated such that the user is made aware of the change in progress. At the completion of the modification and prior to the final revision of drawings, a verified "red line" drawing is provided to the control room to ensure that they have accurate drawings. Final revisions of drawings are required to be completed within 90 day The design process within YNSD and the Maintenance Support Department (MSD) appears to be well controlled and contains the appropriate checks and balances. There is an awareness of nuclear safety as evidenced by discussions with personnel, and the effort to upgrade procedures and institute new programs such as configuration contro The procedures that control the plant design change request process does not limit what design activities that the MSD can take en. However, the team found that the MSO does not appear to take on projects beyond its capabilit The MSD does not use the "system engineer" concept, where one or more individuais are responsible for areas such as maintenance plannin n maintaining system status and trending performance for a given syste .3.4 Engineering Involvement in Mant Activities The onsite engineering organization is ',he MSD. Inis group has ,

evolved from within the I&C and maintenance groups, and '

subsequent to its formation has become mere involved in the design process and less involved in day-to-day maintenance )

activitie Presently the MSD utilizes the majority of their j resources on design related activities, and involvement in I day-to-day piant activities seems to be only upon request by I other piant personnel. The MSD supervisor and the maintenance 1 manager both stated that the goal is to shift emphasis from !

design to a more active role in plant maintenance activitie As a result of the MSO being heavily involved in design related activities, this group of plant engineers is not readily available to plant personnel for routine activities such as engineering review and evaluations of maintenance tasks, root l cause analysis and equipment performance trend analysi Additionally, the MSD supervisor is not in the review cycle for maintenance requests and consequently this engineering perspective is not provided for routine maintenance activitie .

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6.3.5 QA/QC Oversight The Quality Assurance Department (QAD) on site is composed of a stiff of seven, and one of these positions is presently vacan This group appears to function mainly as a QC organization and is not normally involved in the routine activities of the MS The QAD does not have a staff member with engineering experience and utilizes I'NSD QA engineers to supplement their staff when required. Organizationally the QAD supervisor is one management level below sther department managers. The QA supervisor reports to the Quality Services managar off site. With the exception of QA procedures, the QAD had no review and approval authority for plant procedures including installation and test procedure .4 Findings / Conclusions 6.4.1 Strengths Both the MSD and YNSD appear to have good morale with qualified personnel and e stable work forc The quality of work performed by bath organizations is good. There seems to be an emphasis on mainta'ning a strong interface between MSD and YNS .4.2 Weaknesses / Deficiencies 6.4. Weaknesses The MSD involvement in the desig process is such that sufficient time is not available to get involved in the day-to-day maintenance activitie This non-involvement reduces effectiveness in the following areas:

developement of predictive maintenance activities engineering review and evaluation of naintenance tasks

- root cause analysis equipment performance trend analysis

- determination of maintenance requirements, replacement schedules and life extension requirements The MSD supervisor is not responsible for reviewing maintenance request This engineering perspective is valuable in determining areas in need of additional engineering resources and independent appraisal of ongoing maintenance activitie CFR 50.59 safety reviews performed by plant personnel are not always as detailed as needed to evaluate the crittria and the depth of review is not consistent. A recent revision to AD-0200 (plant modifications) appears to give better guidance and may aid in improving the quality of 50.59 review .

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Several plant procedures do not reflect t.ie current QA organization. AD-0001 (plant procedures) refers to 0Q0 and 00A on APF-0001.7, AP-6007 (I&C department corrective maintenance)

refers to OQC on APF-6007.1 and AP-5010 (maintenance department corrective maintenance) refers to OQ The effectiveness of the QAD may be limited because they have no engineering capability, the QA supervisor is at .

management level below other department managers at the plant, and the lack of review of plant procedure .0 Main Steam Line Pressure Switch Failures 7.1 Background Each of the four main steam (MS) lines has three pressure switches (PS). Low steam pressure sensed on any two out of three switches on any one line will scram the reactor and close the MS line non-return valves (NRV). This Engineered Safety Feature (ESF) is provided to limit the cooldown of the main coolant system following a M$ line break accident. YNPS Technical Specification (TS) J.3.2 requires that in Mode 1 all three channels be operable on each steam line. In order to be operable, the trip setpoint must be greater than or equal to 262.5 psig. The action statement of TS 2<2.1, "Limiting Safety >

System Settings" indicates that when a crip setpoint is less conservative then 262.5 psig that the action statement of TS 3. must be applied. The action statement of TS 3.3.2 requires that the inoperable channel be tripped within one hour for power operation to continue. If the channel cannot be tripped within the required one hour time frame, TS 3.0.3 requires that the plant te in Mode 3, hot standby within one hou .2 Problem History The MS line pressure switches at Yankee have a history of problems '

dating back to mid 1985. These prcblems were documented in NRC Region I Inspection Report (IR) 50-29/85-15 and followed-up in IR 50-29/85-2 The NRC resident inspectors have maintained cognizance of licensee activities in this area and additional information concerning this issue is contained in IR $0-29/87-16. A brief chronology of the PS preolem follows.

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Date Event July 18, 1985 MS-PS-11 Fails and is replaced Augur.t 16, 1985 MS-PS-31 Fails and is replaced August 23, 1985 Failed MS-PS-31 returned to the vendor (ASCO) for failure analysis September 12, 1985 MS-PS-33 Fails and is replaced Octobe.e 1,1985 ASCO provides evaluation of PS failures November, 1985 Nine remaining PS rep'iaced (Refueling Outage)

June 12, 1986 YAEC 10 CFR 21 evaluation completed and recommendations accepted September 9, 1986 PORC review of the above report. Service request developed for redesigned sensing lines September 10, 1987 New design change to sensing lines is proposed December 3, 1987 Two MS FS fail, three others outside of TS allowable band 7.3 Recent Failures On December 3, 1987 following the failure of MS-PS-13, all 12 PS were checked with the following results:

MS Line Switch As Found Setpoint (Note)

Loop 1 PS 11 278 psig (1)

PS 21 295 psig PS 31 Failed (2) ,

Loop 2 PS 12 288.5 psig (1)

PS 22 294 psig  :

PS 32 273 psig (1) l Loop 3 PS 13 Failed (2)

PS 23 293 psig (1) l DS 33 240 psig (2)

l Loop 4 PS 14 296.5 psig PS 24 260 psig (2) ;

PS 34 240 psig (2) l NOTES: (1) Below procedural allowable of 300 +/-6 psi (2) Below TS Limiting Safety System Setting of 262.5 psi I l

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A summary of the as-found conditions on December 3, 1987 indicated the following:

(1) Two pressure switches faile (2) A total of five pressure switches below TS Limiting Safety Setting (3) A total of nine pressure switches below prucedural allowable ban (4) Two loops (3 and 4) with two of three pressure switches below the TS Limiting Safety System Setting such that during a main steam line break on either steam line, the engineered safety features of reactor scram and MS line isolation would not have activated within their design band The NRC analysis of this situation determined that this multiple common mode failure condition left the YNPS in a degraded condition for an undetermined period of time. Furthermore, the licensee was aware of the historical probler and was trending the as-found settings from the monthly surveillance >. NRC review of this data indicates a consistent downward trend of the as-found setpoint on all twelve instruments each month and that in the majority of cases the instruments had to be reset within the procedural control band each month and on numerous instances setpoints were found just above the TS allowabl A review of the chronology of events surrounding the YAEC corrective action and discussion with the Yankee plant superintendent revealed the following:

(1) Eleven months passed between the time of the initial failures in 1985 until a root cause analysis was complete (2) An additional fifteen months passed before a revised design change was recommende (3) Two and one-half years af ter the initial failures, no design changes have been made, and none are planned until the next refueling outag (4) The position of Yankee management is that they have approached the problem in a methodical manner and that certain conditions beyond their control such as delay in parts delivery and inaccurate technical evaluations made bv contractors have been the cause for the delay. No explanation was given as to why the most recent switches which failed were not yet evaluated for root caus The switches were sent out for evaluation in late February 1988, nearly three months after failur . _ _ _ _

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7.4 Conclusions The team evaluated corrective actions taken on this licensee identified event in the context of maintenance,. surveillance, operations and engineering control since all four elements of the inspection charter were associated with this problem. Licensee activities in reporting the event and actions taken under the TS are the subject of IR 50-29/87-1 With respect to licensee corrective actions in accordance with existing YAEC procedures, the team is concerned that corrective action has not been timely or adequate. The Yankee Operational QA Program (YOQAP) requires that, in the case of significant conditions adverse to quality, the cause of the condition be determined and that corrective action be taken to preclude repetitio The YAEC staff appears to have not taken an aggressive attitude toward the correction of this deficiency and although evaluation of the problem is underway, the process appears to be sluggish as evidenced by the fact that the licensee has yet to complete a failure analysis on the most recently replaced switches. Increased priority on resolution of this problem is needed. As indicated in IR 50-29/87-16, the NRC will follow to resolution concerns regarding (1) the potential reportability of the pressure switch failure mode upon completion of failure analysis of the switch; (2) corrective actions to be taken by the licensee to preclude exceeding Technical Specification limiting conditions for operation in the future; (3) actions to ensure that the pressure switch problems are corrected; and, (4) promptness of corrective actions taken for this problem. The actions are collectively considered an ucesolved item pending licensee action -

and subsequent NRC:RI review (50-29/88-01-03). In addition, completion of these items will be tracked under open Licensee Event Report 50-29/87-1 .0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at an entrance intereiew conducted on January 7, 1988. The findings of the inspection were periodically discussed with licensee

' representatives during the course of the inspection. An exit interview was conducted on January 15, 1988 (see Attachment for attendees) at which '

time the findings of the inspection were presente At no time during this inspection was written material concerning j inspection findings provided to the licensee by the inspectors. The '

licensee did not indicate that any material discussed during the inspection contained proprietary informatio l l

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ATTACHMENT 1 - PERSONNEL CONTACTED:

• R. Mitchell - Maintenance Manager

• D. King - Maintenance Support Supervisor

• Kay - Technical Services Manager W. Loomis - Senior Engineer N. Fetherston - Engineer D. Fogarty - Engineer

• W. Jones - Engineering Manager (YNSD)

S. Rosenberg - Lead Electrical Engineer (YNSD)

S. Fournier - Lead System Engineer (YNSD)

D. Visco - I&C Engineer (YNSD)

D. Hansen - Licensing Engineer (YNSD)

• L. Bozek - Quality Assurance Suoervisor

• B. Darcy - I&C Supervisor B. Holmgren - Lead Mechanical Engineer

• B. L. Drawbridge - Assistant Plant Superintendent

• N. St. Laurent - Plant Superintendent

• E. Jurentkuff - Plant Jperations Manager R. A. Jodoin - Assistant Plant Operations Manager C. A. Johnson - I&C Foreman G. Grove - I&C Lead Technician C. Johnson - As:istant I&C Supervisor G. Barry - Shift Supervisor

• E. Begiebing - Maintenance Supervisor C. Keating - Senior Maintenance Foreman E May - Senior Engineer J. Spitulnik - Training Supervisor

• Present at Exit Meeting i

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ATTACHMENT 2 - DOCUMENTS REVIEWED

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DRAWINGS: ,

9699-FM-8A, Flow Diagram - Charging, Bleed and Chemical Shutdown Systems 9699-FM-9A, Flow Diagram - Main Coolant Component Shutdown Fuel Pit Cooling Lines 9699- FM-6A, Flow Diagram - Main Coolant S. V. Blw, Drain and Vent Lines YM-H-8 Flow Diagram - Sampling System 9699-FE-36G, Control Bay Conduit Details 9699-HE-48MG, Cable Schedule 9699-FM-83A, LPSI and HPSI Flow Diagram 9699-FE-4L, Main Coolant Flow and Pressure, Trip Relays i 508F311A, Turbine Section of Main Control Board, Connection Diagram, L Panels 6R and 7R YR-E-40-171 VC Pressure Instrumentation t YR-E-40-172, VC Pressure Instrumentation

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DESIGN CHANGE REQUESTS:

PDCR 86-001, Safety Injection Accumulator Venting Equalization Line PDCR 86-003, Reconfiguration of PICS Building Electrical Loads PDCR 86-006, HPSI Flow Readout

, PDCR 87-001, Heater Drain Tank and No. 3 Feedwater Heater Level Controllers Power Supply Change i

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PDCR 87-003, Steam Generator Narrow Range Level Trip Channel Relays Status Lights EDCR 86-307, SI Relief Valve Replacement EDCR 86-318, PASS Modification /CH-MDV-527 Motor Operator Replacement EDCR 86-322, Turbine Trip Logic Upgrade EDCR 87-302, Battery No. 3 Installation EDCR 79-40, VC Pressure Level Instrumentation

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PRDCEDURES:

AP-0001, Plant Procedures AP-0017, Switching and Tagging of Plant Equipment i AP-0228, Quality Assurance Program AP-0227, Corrective Action AP-0226, Qualification and training of Personnel AP-0214 Maintenance and Change of Safety Classified Systems, Components and Structures l AP-0207, Equipment Control l AP-0205, Maintenance Request AP-0204, Safety Classification of Systems, Components and Structures l AP-0200, Plant Modifications a DQA-X-1, Quality Control Inspections OQA-X-1, Quality Assurance Surveillances

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Attachment 2 AP-0018, Temporary Change Control AP-6007, I&C Department Corrective Maintenance AP-2007, Maintenance of Operations Departmental Logs AP-2006, Special Orders AP-0018, Temporary Change Control AP-0003, Plant Operation leview Committee, Revision 10, November, 1986 AP-0222, Job Orders, Revision 9, June, 1987 AP-0223, Document Control, Revision 8, July,1986 AP-0020, Operating Information Review, Revision 5, October, 1987 AP-0021, Operating Memos, Revision 8, November, 1986 AP-0040, General Plant Housekeeping and Cleanliness Control Survey, Revision 8, July,1986 AP-0041, Plant Surveillance Schedule, Revision 8, May, 1986 AP-0042, Housekeeping for Maintenance Control, Revision 4, February,1987 AP-0075, Vendor Equipment Technical Implementation Information Program, August, 1987 AP-0208, In-Plant Audits AP-0215, Control of Measurement and Test Equipment AP-0216, Plant Housekeeping Program, Revision 4, May, 1987 AP-0218, Test Control, Revision 10, February,1987 AP-0220, Surveillance Tests and Records, Revision 15, February, 1987 AP-2001, Responsibilities and Authorities of Operations Department Personnel, Revision 17 February,1986 AP-2002, Operations Department Personnel Shift Relief, Revision 16, November, 1987 AP-2005, Operations Department Surveillance Schedule, Revision 36, J September, 1987

AP-5000, Maintenance Department Surveillance Schedule, Revision 13, July, 1986 AP-5002, Maintenance Depcrtment Corrective and Preventive Maintenance ;

Program, Revision 10, November, 1987 '

AP-5006, Maintenance Mechanic / Electrician Training Program, Revision 8, May, 1987 AP-5010, Maintenance Department Corrective Maintenance, Revision 6, July, 1986 AP-7005, Operational Experience Assessment, Revision 1, December,1985 i AP-0508, Maintenance of Training Records  !

AP-0514, Balance of Plant Training Program Development l DP-0900, Maintenance Support Department Training i WE-002, Design Document Control i WE-100, Engineering Design Change Request WE-101, Plant Design Change Request

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WE-103, Engineering Calculations and Analyses WE-105, Drawings OP-3300, Classification of Emergency OP-4656, Functional Test of NRV Main Steam Line Pressure Channels OP-4271, Accident Monitoring Instrument Channel Check i 00-4217, Charging Pump Surveillance l 00-4623, VC Post Accident Hydrogen Analyzer HV-GA-1 Calibration !

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OP-4207, Surveillance of the Station Power de and ac Distribution l Systems and the Emergency Diesel Generators A2-2

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A2-3 OTHER DOCUMENTS Material Issue Ticket 360S6 Material Issue Ticket 35332 Material Issue Ticket 35824 Material Issue Ticket 35121 Material Issue Ticket 36067 Material Issue Ticket 35133 Yankee Service Request 87-020 Yankee Service Request 86-039 Yankee Service Request 86-098 Operational QC Inspection Report 00C-YR-87-115 Supply Requisition 6247 Design Basis Index Maintenance Request 88-67, Maintenance Request 87-1980, Maintenance Request 87-1984, Maintenance Request 88-67 Maintenance Request 88-76 Maintenance Request 88-81 Maintenance Request 88-97 Maintenance Request 88-98 LER 50-29/87-15, Main Steam Line Pressure Switches Inoperable TCR 87-442, MS-PS-13 TCR 87-444, MS-PS-31 Letter FYR 83-69 dated July 28, 1983 from YAEC to NRC Letter FYR 85-108 dated October 15, 1985 from YAEC to NRC YAEC Operational Quality Assurance manual OP Memo Notebook Temporary Change Notebook Plant Information Report 87-01 Plant Information Report 87-02 Plant Information Report 87-03 Plant Information Report 87-05 Plant Information Report 87-06 Switching and Tagging Log I

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ATTACHMENT 3 - Tests Witnessed OP-4623, VC Post Accident Hydrogen Analyzer HV-6a-1 Calibration OP-4207, Surveillance of the Station Power dc and ac Distribution Systems and the Emergency Diesel Generator OP-4565, Weekly Check of the Diesel Fire Pump Batteries OP-4580, Weekly Check of the Diesel Generator Batteries OP-4500, Weekly Check of the Station Batteries OP-4217 Changing System Operability Tests

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ATTACHMENT 4 - Maintenance Witnessed MR-88-67, VC Wide Range Pressure Bistable (VC-HPA-243) Troubleshooting MR-88-76, No. 4 Steam Generator Steam Flow Indication MR-88-97/98, No. 3 and No. 4 Steam Generator Pressure / Steam Flow Indication MR-87-245, Control Rod Drive Coil Stack MR-87-552, No. 2 Non Return Valve Team A MR-87-1461, Repair of Pump P-23 LPSI Cooling Pump HR-87-517, No. 3 FW Flow Line Nozzle MR-87-226, Check Valve CSV-632 Repair MR-87-650, Post Accident H2 Analyzer

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