IR 05000029/1989011

Insp Rept 50-029/89-11 on 890626-0731.Unresolved Items Noted Re Plant Operations Review Committee Actions to Address Task Force Investigation Results of 890725 Loss of Emergency Bus.Areas Investigated:Security & LERs

ML20246L643
Person / Time
Site:	Yankee Rowe
Issue date:	08/28/1989
From:	Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20246L640	List: IR 05000029/1989011 ML20246L636
References
50-029-89-11, 50-29-89-11, NUDOCS 8909070016
Download: ML20246L643 (17)

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.k 6 i U.S. NUCLEAR REGULATORY, COMMISSIO REGION I

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Report No: '50-29/89-11 Docket No: 50-29 Licensee.No: DPR-3'

. Licensee: Yankee Atomic Electric:Compans 580 Main Street-Bolton, Massachusetts 01740-1398

. Facility.Name: . Yankee Nuclear Power' Station

$ Inspection at: Rowe, Massachusetts

'-Inspection Conducted: . June 15 . July 31,1989 Inspectors: John B. Macdonald,, Senior Resident Inspector

' Michael T., Markley, Resident Inspector

. Carl Woodward, Reactor Engineer Approved By:

A. Ra~ndy Blougfrf Chief, Reactor Projects Section 3A

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'N Date'

Inspection Summary: Inspection on ' June 26 - July 31,1989 (Report No. 50-29/89-11)

Areas' Inspected: Routine inspection on daytime and backshifts Sv two resident

inspectors of

actions on previous inspection' findings;-operati, il safety; security;-plant operations; maintenance and surveillance; engineering support;

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radiological controls; licensee event reports; licensee response.to NRC initi-atives; and,-per odic report ' Results: ' General Coni:1usions on Aiequacy, Strength or Weakness in Licensee Programs Operator response to.the July 25 loss of the No. 1 emergency bus was note-worthy. The operators promptly identified the situation, ensured plant stability and expeditiously recovered power to the bus. However, the event revealed inadequate development and coordination of c:::ergency diesel L generator maintenance activities. Formation of a PORC appointed task H ' force to investigate this event was appropriate (sections 6.3 and 6.4).

c The inspector-identified failure of the licensee to submit a timely TS change request to address main steam line area radiation monitors is in-dicative of an isolated lapse in the commitment prioritization and cor-

-rective action programs (section 7.1).

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'2 The engineering evaluations. conducted in responsefto discharge pressure anomalies during LPSI testing were comprehensive and complete.and reflect a. probing analytical attitude within the engineering staff (section 9.1).

The licensee temporary modification program exhibited sev'eral weaknesses-regarding the pre-implementation review process (section'9.2). ' Unresolved Items Four unresolved items were ident'ified during this inspection period:

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Review of PORC actions.to address task force investigation-results of the July 25 loss of emergency bus event (section 6.3).

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Review of licensee actions to address the uncontrolled modification of.a plant system (section 7.4).

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Review of licensee evaluation of emergency diesel generator loading and. low pressure safety injection pumps discharge pressure anomalies (section 9.1).

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Review of licensee resolution of weaknesses in the procedural' car. trol of temporary modifications (section 9.2).

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TABLE OF CONTENTS PAGE l

l Persons Contacted...................................................... 1-

, ' Summary of Facility Activities....................................... 1 l Status of Previous Findings (IP 92701)................................ 2 3.1 (0 pen) Violation 50-29/88-22-02, Failure to Establish Effective Measures for Conditions Adverse to Quality Involving Design Deficiencies.................................................. 2 Operational Safety (IP 71707,71710)................................. 2 4.1 Plant Operations Review.................. ...................... 2 4.2 Safety System Rev1ew............................................ 3 4.3 Inoperable Equipment............................................ 4 4.4 Review of Temporary Change Requests and Mechanical Bypasses..... 4 4.5 Review of Switching and Tagging Operations...................... 5 4.6 Operational Safety Findings...................................... 5 Security (IP 71707)........................... ...................... 5 5.1 Observations of Physical Security............................... 5 Plant Operations (IP 71707,93702,82201)............................ 5 6.1 Load Reduction to Replace Condenser Tube Plugs.................. 5 6.2 Containment and Heat Sink Temperatures.......................... 6 6.3 Inadvertent Loss of the No. 1 480 V Emergency Bus............... 6 6.4 Notification of Unusual Event................................... 8 Maintenance / Surveillance (IP 61726,62703)........................... 9 7.1 Main Steam Line Radiation Monitor Inoperability................. 9 7.2 Component Cooling Pump Seal Package Replacement................. 10 7.3 Spent Fuel Pit Rerack Maintenance............................... 10 7.4 Safety Injection Accumulator Drain Va1ve........................ 10 Radiological Controls (IP 71707)..................................... 11 8.1 Observation of Radiological Protection and Controls............. 11 8.2 Spent Fuel Pit (SFP) Activities........................... ..... 11 i

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PAGE Engineering and Technical Support (IP 71707)......................... 12 9.1 Emergency Diesel Generator ( EDG) Loading . . . . . . . . . . . . . . . . . . . . . . . . 12 9.2 Control of Temporary Modifications.............................. 13 10. Review of NRC Initiatives (IP 92703)................................. 14 10.1 Emergency Diesel Generator Fuel Oil (TI 2515/100)............... 14 11. Review of Periodic and Special Reports (IP 90713). . . . . . . . . . . . . . . . . . . 17 12. Management Meetings (IP 30703)....................................... 17

• The NRC Inspection Manual inspection procedure (IP) or temporary instruction (TI) or the Region I temprary instruction (RI TI) that was used as insnection guidance is listed for each applicable report sectio ii

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DETAILS Persons Contacted Yankee Nuclear Power Station N. St. Laurent, Acting Manager of Operations T. Henderson, Acting Plant Superintendent R. Mellor, Technical Director Yankee Atomic Electric Company (YAEC)

B. Drawbridge, Vice President D. Maidrand, Assistant Project Manager NRC M. Fairtile, Project Manager R. Blough, DRP, Section Chief J. Macdonald, Senior Resident Inspector M. Markley, Resident Inspector The inspector also interviewed other licensee employees during the inspec-tion, including members of the operations, radiation protection, chemis-try, instrument and control, maintenance, reactor engineering, security, training, technical services and general office staff . Summary of Facility Activities Yankee Nuclear Power Station (Yankee, YNPS or the plant) operated at 100%

rated power until July 7-8, 1989, when plant load was reduced to replace aging condenser tube plug Following the load reduction, the plant con- '

tinued to operate at full rower through the end of the inspection perio At 11:33 a.m. on July 25, :he licensee declared an unusual Event-Termi-nated when an inadequately reviewed maintenance activity resulted in an unanticipated fourteen minute loss of the No. 1 480V emergency bus and associated equipment (sections 6.3 and 6.4).

Effective July 24, 1989, the licensee initiated several temporary organi-zational staffing changes. Mr. Bruce L. Drawbridge, Vice President and Manager of Operations was reassigned to another facility senior staff position within the Yankee organization. Mr. Norman St. Laurent, Plant Superintendent was assigned the responsibilities previously held by M Drawbridge as the Acting Manager of Operations. Mr. Tim Henderson, As-sistant Plant Superintendent was assigned as Acting Plant Superintendent in addition to his current responsibilities. These temporary assignments, as described, maintain onsite organizational continuity in that the onsite reporting and responsibility structure remain unchanged.

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' Five Region. I specialist ' inspections were conducted during this inspection perio A routine environmental ' radiation and monitoring program specialist in-spection (50-29/89-10) was conducted the week of July 5- A routine effluent, radwaste and transportation specialist inspection (50-29/89-12) was conducted the week of July 10-1 A routine engineering'and design change specialist inspection (50-29/

89-14) was conducted the week of July 17-2 ,

A routine physical security and safeguards specialist inspection.(50-29/

89-13) was conducted the week of July 24-2 A routine emergency preparedness specialist inspection (50-29/89-15) was commenced on July 3 The Institute,of Nuclear Power Operations commenced a one week requalifi-cation assessment of licensee training programs on July 3 . Status of Previous Inspection Findings 3.1 (Open) Violation 50-29/88-22-62, Failure to Establish Effective Measures for Conditions Adverse to Quality Involving Design

' Deficiencies A violation was issued in NRC inspection report 50-29/88-22, which-involved conditions adverse to quality contrary to 10 CFR 50, Appen-

' dix B, Criterion XV In response to the NOV, the licensee imple-mented the initial ' revision of engineering procedure WE-109. The procedure promotes the identification of engineering design defi-ciencies during initial design reviews. Further, the procedure en-sures that deficient conditions are brought to the attention of supervisory personnel in a timely' manner for resolution. The licensee immediate corrective actions to achieve regulatory compliance were accomplished by March 27, 1989, as stated in letter BYR 89-62. How-ever, long term corrective actions, specifically PORC approval of a major revision to engineering procedure WE-100, were not complete at the conclusion of the inspection period. Inspector review of the status of the procedure indicated the revision was complete and presentation to PORC was imminent. This violation will remain open pending approval of the procedur . Operational Safety 4.1 Plant Operations Review The inspector observed plant operations during regular and backshift tours of the following areas:

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Control Room Safe Shutdown System Building Primary Auxiliary Building Fence Line (Protected Area)

Diesel Generator Rooms Intake Structure Vital Switchgear Room Turbine Building Cable Tray House Spent Fuel Pit (SFP) Building Control room instruments were observed for correlation between chan-nels, proper functioning, and conformance with technical specifica-tions. Alarm conditions in effect and alarms received in the control room were reviewed and discussed with the operators. Operator aware-ness and response to these conditions were reviewed. Operators were found cognizant of board and plant conditions. Control room and "

shift manning ~were compared with Technical Specification require-ments. Posting and control of radiation, contaminated and high radi-ation areas were inspected. The use of and compliance with Radiation Work Permits (RWPs) and use of required personnel monitoring devices were checked. Plant housekeeping controls were observed including control of flammable and other hazardous materials. During plant tours, logs and records were reviewed to ensure compliance with sta-tion procedures, to determine if entries were correctly made, and to verify correct communication of equipment status. These records in-cluded various operating logs, turnover sheets, tagout and temporary change request logs, and event deportability evaluation request Inspections of the control room were performed on weekends and back-shifts as follows: June 27, 28, 29; July 3, 6, 7,11,12,15,17,18, 20, 21, 24, 25, 26, 27, 28, and 3 Deep backshift included: July 8, 9:45 a.m. to 11:45 a.m. and July 15, 7:30 a.m. to 5:15 p.m. Opera-tors and shift supervisors were alert, attentive and responded appro-priately to annunciators and plant condition Documentation of shift activities was good. Inspector review of operating logs and turnover sheets indicated good characterization of operating history. Off-normal conditions, surveillance com-pleted, and equipment performance were appropriately documente .2 Safety System Review The emergency diesel generators, EDG fuel oil, containment isolation and high and low pressure safety injection systems were reviewed to verify proper alignment and operational status in the standby mod The review included orification that: (i) accessible major flow path valves were correctly positioned; (ii) power supplies were energized, l (iii) lubrication and component cooling was proper; and (iv) com-ponents were operable based on a visual inspection of equipment for leakage and general conditions. No violations or safety concerns were identified.

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p L .3' Inoperable Equipment Actions taken by plant personnel during periods when equipment was inoperable were reviewed to verify: Technical Specification limits were' met and equipment return-to service upon completion of repairs was proper. This review was completed.for the following items:

-Inclusive Dates Item June'I - Present Main steam line radiation monitor No.1 l (RM-ARM-206) was declared inoperable due to cable and hardware problem It was placed on long-term inoperability

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on June 28 (MR 89-1200)

June 25 - July 11 Main steam line radiation monitor No. 2 (RM-ARM-207) was declared inoperable due to erratic indication (MR 89-1314)

June 26 - July 17 Main steam line radiation mor.itor No. 4 (RM-ARM-209) failed check source test (MR89-1320)

' Main :-teamline area radiation monitor inoperability'is documented in detail in section 'No safety concerns were identifie .4 Review of Temporary Change Requests and Mechanical Bypasses Temporary change requests (TCRs), which were approved in support of implementing lifted leads and jumper requests and mechanical by-passes, were reviewed to verify that: controls established by AP 0018, " Temporary Change Control," were met; no conflicts with the Technical Specifications were created; the requests were properly approved prior to installation; and a safety evaluation in accordance with 10 CFR 50.59 was prepared if required. Implementation of the  !

requests was reviewed on a sampling basis. The following requests were reviewe l

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TCR 89-236: Implemented and restored on July 25, 1989 to support maintenance on control room emergency air cleaning system (CREACS) ventilation damper A (MR 89-1394).

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TCR 89-214: Implemented on June 28 and restored on July 11 to support maintenance on No. 2 main steam line radiation monitor (MR 89-1314).

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-- .TCR 89-223: Implemented on July-11 and restored on July 17 to perform troubleshooting maintenance on No. 4~ main steam line ia radiation monitor (MR 89-1223).

. Review of Switching and Tagging Operations-The switching and tagging-log was reviewed and tagging activities p were inspected to verify plant equipment was controlled in accordance E

with the requirements of AP 0017, "Switt.hing and Tagging of Plant Equipment." The.following switching and tagging orders were re-

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'.-- 89-658 - issued en June 28 and completed on June 29 to replace No. 2 component cooling pump (P-20-2) seal packag '_

-- 89-707 - issued and completed on July 25 to perform maintenance on the No. I emergency diesel generator reverse power rela '

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'-- 89-701 - issued on July 20 to perform restoration of SI-V-50 accumulator drain valve to original design configuratio No unacceptable conditions were identifie .6 Operational Safety Findings Licensse administrative control of off-normal system configurations by the use of TCR and switching and tagging procedures as reviewed

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above, was in compliance with procedural instructions and was con-sistent with plant safety. However, programmatic problems were iden-

. tified with the' control of temporary modifications as described in Section' ' Security 5.1' - Observations of Physical Security Selected aspects of plant physical security were reviewed during regular and backshift hours to verify that controls were in accord-ance with the security plan and approved procedures. This review included the following security measures: guard staffing, vital and protected area barrier integrity, maintenance of isolation zones, and implementation of access controls including authorization, badging, escorting, and searches. No inadequacies were identifie . Plant Operations

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6.1 Load Reduction to Replace Ccudenser Tube Plugs On July 7-8, 1989, the licensee reduced plant load to approximately 50* 4 rated power to replace aging condenser tube plugs. Approximately 80'4 percent of the plugs were replace _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ -

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6- During the ascension to full power, the steam'. jet air' ejector (SJAE)-

radiation monitor indicatec a rapid increase in count rate. Speci-fically, the count rate: spiked from a background 200 cpm to approxi-mately 1200. cpm. . Chemistry sampling was. initiated which indicated the' presence of a primary to secondary. leakage rate of 1.0 - 1.5 gal-lons per day (gpd). Technical Specifications limit primary to secondary leakage to one gallon per minute (l'.0 gpm). Evidence of a

- minor leak'was confirmed by the presence of tritium. No iodines or cesiums were. identified. The steam jet air ejector radiation monitor stabilized and returned to the~ previous backgrcund count rate when full power was achieve Another minor spike to 500 cpm occurred on July 19 during control rod

exercising. Sampling confirmed similar results without the presence of tritium. Operability testing of the=SJAE radiation monitor indi-cated it was functioning properl Licensee response to the observance of a minor primary to secondary leak. reflected a conservative safety perspective. The licensee in-itiated increased sampling and trending of the secondary chemistr Preliminary licensee assessment indicated the minimal leakage ap-peared to be detectable only during reactor power manipulation When detectable, the leak was of. insufficient quantity to allow for radiochemistry analytical techniques to determine the affected steam generato Inspector review indicated no immediate safety concern The inspector will continue to review anomalies in this area.

I 6.2 Containment and Heat Sink Temperatures Review Inspector review of containment bulk temperatures and cooling water inlet and outlet temperatures during high an:bient summer atmospheric conditions indicated no degraded levels c>f performance. During the

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1988 refueling outage, two containment air coolers were replace Currently observed containment ambient temperatures are slightly lower (5-10 degrees Fahrenheit) than those for similar conditions during tne previous summer. Containment temperatures were well within Technical Specification limit Intake and discharge dif-ferential temperatures were noted to be within procedural guidanc The inspectors had no further concern .3 Inadvertent loss of the No. 1 480 V Emergency Bus On July 25, the No. I emergency diesel generator (EDG) was removed from service to facilitate a lube oil change and to replace an engine mounted temperature gauge. Concurrent with this mechanical mainten-ance activity and within the existing equipment clearance (TCR),

maintenance personnel proposed to investigate previously observed

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erratic operation of the No. 1 EDG kilowatt (KW) meter and reverse power relay (RPR). However, because the existing TCR was issued to

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l support non-invasive mechanical maintenance, the shift supervisor (SS) requested maintenance personnel to evaluate the necessity to establish a new electrical clearance boundary to perform the KW meter and RPR inspections, to ensure the No.1480V emergency bus would not'

be impacted. The existing clearance was verified'to be adequate to perform the KW meter inspection, which was_ conducted without inci-t- dent. However, following review of applicable ' drawings, maintenance L

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personnel identified a 10A fuse in a potential transformer (PT) of the RPR circuitry, which they believed when pulled would ensure de-energization of the relay without impact on the No. 1 emergency. bu Maintenance personnel subsequently presented a reviewed and Approved TCR (89-234) to remove the fuse which the SS authorize At 11:19 a.m. the TCR was implemented by maintenance personnel. Upon removal of the PT fuse associated with the RPR, the BT-1A and BT-1B breakers opened de energizing the No. 1 480 V emergency bus and its associated equipment. Equipment lost included the No. I emergency motor control center (EMCC), as well as, the No. I train safety in-jection system, primary control roa position indicating lights, con-trol' rod drive mechanisms, and the in plant gaitronics communications system. The SS immediately concluded removal of the PT fuse had re-

-sulted in the loss of the No. I emergency bus. However, due to the associated loss of the gaitronics system, the SS was unable to estab-lish direct communication with maintenance personnel and, therefore, he dispatched available operations staff personnel to the Safety In-jection (SI) building, where the fuse was located. Remote communica-tions between the control room and the SI building were accomplished via security department two way radios. Loss of primary control rod position indication for 23 control rods placed the plant into TS-3.0.3, which requires the condition be corrected or the plant be in Hot Standby (Mode 3) within one hou At 11:33 a.m., the fuse was re-installed, breakers BT-1A and BT-1B were closed, power was restored to the No. I emergency bus and as-sociated equipment and the plant exited TS 3.0.3. Also, at 11:33 a.m., the SS declared an Unusual Event-Terminated in accordance with plant emergency action levels (see section 6.4).

The response of the operators to this event was noteworthy. Initi-ally, the SS displayed a conservative safety approach by requesting maintenance personnel to initiate a clearance evaluation to speci-fically address the RPR inspection. Although the TCR issued proved to be inadequate, the SS questioned maintenance personnel with re-spect to the TCR to the limitations of required licensed operator knowledge. Pesponse to the loss of the No. I emergency bus was prompt and well coordinated. The SS verified plant conditions were stable, dispatched operators to the location of the maintenance acti-

.vity and established two-way radio communications until power was restored to the affected bus. The inspectors had no further ques-tions with regard to operator response to this event.

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However, the inspectors considered maintenance department performance with respect to this event as generally inadequate. Initially, main-tenance personnel did not provide sufficient technical evaluation to support performance of potentially invasive electrical maintenance within a TCR clearance authorized to perform non-invasive mechanical maintenance. Further, cognizant maintenance personnel failed to for-mally enlist the assistance of more senior management in the develop-ment and review of the ensuing proposed TCR. The inspectors con-sidered the lack of a request for supervisory involvement inappro-priate in light of apparent confusion as to the component designation and in plant location of the PT fuse, as well as, continued SS con-cerns for the potential to impact the emergency bu Ultimately, the maintenance department review of the TCR was incom-plete, in that, all circuitry affected by the removal of the PT fuse was not evaluated prior to submittal to the SS for implementatio Specifically, the review did not consider the status of the emergency restart program undervoltage re',ays and mode switch positio Licensee management immediately formed a task force to conduct an in-depth investigation into this event. The task force was chartered to independently review the activities of the operations department and maintenance department relevant to the event, and also, to review the adequacy of the emergency plan implementation and to perform an integrated esaluation of human performance. The task force was to present a formal report to PORC when the investigation was ccmplete At the conclusion of the inspection period, the task force investi-gation and licensee evaluation of further reporting requirements were ongoing. Final PORC review and approval of corrective actions to this event and recommendations to preclude occurrence of similar l

events will be identified as an unresolved itcm (50-29/89-11-01).

6.4 Notification of Unusual Event Following restoration of power to the No. I emergency bus and associ-ated equipment on July 25 at 11:33 a.m., the licensee declared an unusual Event-Terminated in accordance with facility emergency action levels procedure OP-3300, " Classification of Emergencies."

Procedure OP 3300, Event 22, affords SS discretion to declare an Un-I usual Event when the plant enters a condition in which a plant shut-down is required by TS. Loss of primary control rod position indica-tion placed the plant in TS 3.0.3, which requires the entry condition be corrected or the plant be in hot standby in one hou Therefore, the SS declared an Unusual Event. The NRC Operations Center and the appropriate state notifications were made in a timely fashio The licensee appropriately identified and classified the Unusual Event. On shift personnel performed in a very controlled and profes-sional manner. The inspectors had no further questions.

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7. Maintenance / Surveillance 7.1 Main Steam Line Radiation Monitor Inoperability In NRC Inspection Report 50-29/88-22 Section 10.0, the inspector identified that the licensee commitment to implement NUREG 0737 TMI Action Plant item II.F.1 regarding inclusion of main steam line area radiation mor(tt t s (MSL ARM) into Technical Specifications (TS) dur-ing refueling cycle 18 had not been accomplished. At that time, the licensee detailed plans to submit a TS proposed change in January 198 During the current inspection, the MSL radiation monitors experienced cable and hardware problems which resulted in three out of four moni-tors being declared inoperable, as noted in section 4.3 of this re-port. The monitors prende control room indication used to identify which steam generator experiences gross primary to secondary integ-rity failures under accident or degraded performance conditions. At the conclusion cf this inspection period, all but one monitor had been returned to service. The licensee attributed the inoperability of the equipment to aging related component deterioration. The un-availability of replacement parts was the major factor in repair de-lay Further inspector review of this event revealed that the licensee had not, to date, developed a TS proposed change regarding the MSL ARM Additionally, the MSL ARMS were not being maintained in a manner con-sistent with guidance provided in licensee letter 84-111, dated November 19, 1984 and as indicated as interim corrective actions to inspector concerns raised in inspection report 50-29/88-22. The lic-ensee indic*ted that the TS proposed change had not been developed expeditiously in January because the item had been improperly priori-tized within the commitment tracking program.

L Following inspector identification in this concern, senior station management was responsive in effecting timely resolution of licensing and programmatic issues. The licensee performed a review of current licensing activities and determined all were properly prioritize Standing Order 89-204 was issued and properly implemented July 3 to provide interim guidance consistent with the TS Proposed Change 228 which was approved by PORC on July 7 and submitted to the NRC July 12. In accordance with Action 15 af the Proposed Change, Special Report BYR-114 was submitted to the NRC detailing actions take l causes of inoperability, and the schedule for restoration of the MSL l monitors.

l i,1censee response to the missing guidance noted in NRC Inspection 50-29/88-22 was less than adequate. The TS amendment was not sub-

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mitted in a timely fashion and implementation of interim corrective actions to ensure TS equivalent treatment of MSL ARMS was ineffec-tual. This event appears to be an isolated instance of breakdowns

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1. 10 within the commitment ~ tracking of. licensing issues and the corrective actions program and not indicative of declining programmatic perform-

, ance. Ultimately,. senior management _was effective in resolving the

. issues. :The inspectors will continue to follow progression of the

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- proposed _TS change request and the adherence to interim.administra-tive controls of-the MSL ARM '7.2.' Component Cooling Pump Seal Package Replacemen On June: 26-30,1989, the inspector observed replacement of the number

' two. component cooling pump P-20-2. It.was performed pursuant to

- engineering design change request (EDCR)88-001 and maintenance re-quest MR 89-133 Inspector' review noted the switching and tagging order 89-608 and 7 maintenance to have been properly performed in'accordance with sta-tion procedures. . Quality assurance personnel were observed to review the design change, tagout, and maintenance activitie The inspector had no further question .3 Spent Fuel pit Rereck Maintenance Prior to the core refueling outage which began in November 1988 and concluded Jariuary 1989, the licensee performed a- design change to install new fuel storage racks to accomodate increased storage capa-ci t Upen. installation, the licensee recogr,1 zed that improper d%nsionr1 tolerances exist ad- No fuel was stnred in the racks 41'te they romained in wet storage in the spent fuel pit-(SFp).

L If, June 1939, the licensee ecmmenced removal of the racks to deter-

. mine necessary modifications to achieve the proper installation fit--

Work was observred to be performed in a safe manner unde the guidance L of engheering design change reqaest EOCR 88-304 and station proce-b &Jrew Work is expectrd to take several months to complete the re-

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Insper. tor review neted the technical approach to be consistent with good engineering practice A measuring rig was developed to determine the fitting requirements and necessary modifications. Until the racks are removed and meas-urements are complete, an assessment of initial design problems will not be available. The' inspector will continue to review engineering and maintenance work activities.

L 7.4 Safety Injection Accumulator Drain Valve On July 24, 1989, the licenste observed that plastic tubing and a sarr.ple valve had been atte.ched to the safety injection (SI) accumu-lator drain valve SI-V-50 outlet pipe. The normal configuration i

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would maintain SI-V-50 locked closed with the outlet pipe cappe Although the cap had been removed, SI-V-50 remained locked close Subsequent licensee investigation through maintenance request MR 89-1401' revealed that the uncontrolled modification had been.in-stalled without proper evaluation and documentation. Discussions with' cognizant personnel indicated that the unapproved modification

.had been. accomplished to accommodate ease of chemistry samplin Nonconformance report NCR 89-10 was initiated to determine root causes and corrective actions. The licensee immediately restored SI-V-50 to the original configuration. At the conclusion of.the in-spection period, the NCR had not yet been completed and reviewed by

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the plant operations review committee.(PORC).

Preliminary inspector review indicated that plant modification and engineering design change programs had been circumvented by opera-tions personnel who apparently conducted the uncontrolled activit In reviewing the licensee initial assessment, it was unclear whethe an-unreviewed safety question existed for the as-found' configuratio The. drain line valve SI-V-50 and cap constitute a SI isolation bound-a ry. Additionally, SI-V-50 was found to be leaking apprcrimately twenty ounces per minute. The impact on SI accumulator operabilit was unclear in the event of a safety injection actuation signal (SIAS) and pressurization with a nitrogen blanket. Normal nitrogen blanket pressure is 15 psig. Similarly, the plastic tubino and sample valve were not procu-ed to safety class 2 qualification. This item is unresolved pending Mcensee engineering etaluation of the as found con #itions, resolution of the NCR and the evaluation of the potential for other uncontrolled plant modifications (89-11-M).

8. Radiological Controls 8.1 Observation of Radiological Protection and Controls Radiological controls were reviewed on a routine basis relative to industry radiological standards, administration and radiological con-trol procedures, and regulatory requirements. Selected werk evolu-tions were obreeved to determine the adequacy of Drogram implementa-tion commensurate wit.h the radiological hazards and importance to safety. Independent surveys were performed by the inspector to verify the adequacy of radiological controls and instructions to worker .2 Spent Fuel Pit (SFP) Activities l

Inspector observation of radiological controls to support work acti-vities indicated good performance. Contamination and hot particle controls for spent fuel pool rerack work were consistent with proce-

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dures and-good radiological practices. The inspector had no further question l

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-12 Engineering and Technical Support 9.1 Emergency Diesel Generator Loading On March 2,1989, during TS required surveillance'. testing of the low pressure safety injection (LPSI) pumps, perturbations in the pump discharge pressures and motor currents were observed at essentially steady state operations. Each of the three LPSI pumps experienced an 8 to 10 second, 50 psig increase in discharge pressure and a corres-ponding increase in motor current approximately 8 to 10 minutes-into the 15 minute surveillance ru In response to this observation, the licensee conducted supplemental testing on March 29 and April 27 to obtain and evaluate additional i pump and motor performance data. The additional tests indicated that

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.the LPSI_ pumps.have been operating in cavitation with insufficient net positive e,uction head (NPSH) during all surveillance tests per-formed to date. Pump flow was observed to remain nearly constant at about 1200 gpm between discharge pressures of 0 to 340 psig. How-ever, . comparison of- present pump performance data with original pump performance data obtained ir 1970 prior to initial LPSI installation indicates no measurable pump degradation. Based on the present pump performance data and the many years of reliable and consistent sur-

.ve111ance test results, the licensee concluded an immediate or short term safety concern did not exist. However, the licensee is pre-sently addressing long term solutions to this issue. Following evalu-

.ation of various al:ernatiws, the engineering staff has proposed increasing LPSI discharge f ow resistance by the installation of fixed fl u orificos or manually positionud throttling valves, such that each LPEI pump would deliver 2,100 got at c di eharge pressure j of 350 psig, at run-out conditions. This p oposat nmains under lie ensee rkvie I As a result of tha oM erved LPSI motor current perturbations, the licensee conducted an analysis of emergency diesel generator (EDG)

Ioa:fing assumptions and calcultticas. Etsisting LDG loading calcula-tions assumed maximum LPSI motor currents of 3Z amperes (A). How-ever, the supplemental test data indicated attual maximum LPSI motor currents to be approximately 380 A. Further, reviw of loss of coel-ant accident analjsis indicate that simultaneous maximum '. IPSI (high pressure safety injection) and LPSI saotor currents would be experi-enced if a main coolant system pipe rupture of three to four inches were to occur. Therefore, the revised EDG loading calculations as-sumed these values throughout the injection phase of emergency core cooling. system operation. Inclusion of the actual maximum HPSI and LPSI motor current assumptions, brought all three EDGs to within % of the continuous load rating of 400 KW. Although EDG continuous load ratings are not currently exceeded, it is obvious that the EDG system is essentially fully loaded and, therefore, is intolerant of

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decreased performance of the diesel engine or generator. The licen-see is currently addressing available options to increase EDG capac-ity or reduce existing load requirement Continued engineering review of the new EDG loading assumptions, identified a previously existing overload condition of the No. 3 ED Prior to the 1988 refueling outage the No. 3 battery charger had been powered by the NO. 3 EDG. The battery charger load, in conjunction with the newly calculated maximum assumed HPSI and LPSI motor loads, would have exceeded the No. 3 EDG 400 KW continuous load rating dur-ing a design base accident by 04.5%. The No. 3 battery charger was removed from the No. 3 EDG during the 1988 refueling outage. On July 24, 1989, the licensee reported the identification of the previously existing potential for EDG overload to the NRC Operations Center in accordance with 10 CFR 50.72 reporting criteri Licensee identification and evaluation of these conditions were note-worthy. The engineering analysis performed was comprehensive and complete. All technical aspects, including a historical review to determine prior impact of a new discovery, were considered. The in-spector encouraged the licenser to continue to perfc.. and report the findings of probing system design bcse evaluations. F)..a1 licensee resolution of the LPSI pump discharge pressure perturbations and the existing EDG loading concerns is an unresolved item (50-29/89-11-03).

9.2 Control of Temporary Modifications In response to the July 25 loss of emergency bus event (Sections & 6.4), the inspector reviewed the licensee process for initiating, reviewing, implementing and restorsng temporary modifications via temporary chan.ge request (TCR) procedure DP 0018, " Temporary Change Control." The review ideptified several weaknesses in the licensee program for control of temporary modifications. As currently imple-eented, the procedure allows for a single individual to request a TCR and also perform the initial cognizant department supervisor (CDS)

evaluation to determine TCR impact on operable systems. The inspec-tor expressed concern regarding this practice, since bases documenta-tion associated with the procedure, as well as the instruction of the procedure itself, would imply that the requestor and CDS . functions be performed independently by two individuals. The inspectors concluded that present implementation of the procedure allows the potential for the removal of an initial independent quality check of TCR adequac A second deficiency was noted in the initial TCR technical and operational review, currently performed by the CDS. This review de-termines if the TCR requires a safety evaluation and subsequent PORC review and approval. Technical specification 6.5.1.6.d charges PORC with the responsibility to review all proposed changes or modifica-tions to plant systems or equipment that effect nuclear safet Therefore, the disposition of a technical and operational review of a TCR performed by a CDS essentially dictates the ability of PORC to l

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discharge its TS responsibilities with regard to that temporary change. The inspectors expressed concern that making the sole deter-mination of the need for a TCR to require a PORC approved safety evaluation places an excessive burden on a CDS to have the requisite knowledge of the plant design bases as described in the FSAR, techni-cal specification bases and what activities constitute departures from these document Notwithstanding the temporary change control procedural weakr. esses identified above, the program has generally been administered with no apparent major problems. However, lack of an initial CDS review in-dependent from the requesting individual represents a deficiency and was a potential contributor to the July 25 event. The licensee ac-knowledged the inspector concerns and performed a review of all ac-tive TCRs in which the CDS reviewer was also the requesting indivi-dual. No unreviewed safety concerns were identifie Further, PORC issued temporary actions to ensure future TCRs receive independent initial review. However, at the conclusion of the inspection period, PORC was continuing to evaluate permanent revision to the temporary change control procedure to incorporate independent initial CDS re-view and to determine if the technical and operational review process is presently accomplished at an appropriate supervisory level to fully evaluate license and design bases criteria. Licensee resolu-tion to the inspector identified temporary change control program-matic weaknesses is an unresolved item (50-29/89-11-04).

10. Review of NRC Initiatives 10.1 Egergency Diesel _ Generator (EDG) Fuel Oil (TI 2515/100}

Background For proper operation cf the standby diesel gert rators, it is neces-sary to easure the proper quality of tne fuel oil. Appendix B to 10 CFR 50, as supplemented by Regulatory Guide (RG) 1.137, serves as an acceptable basis for licensees to maintain a program to ensure the quality of EOG fuel oi In response to recent ind.:stry problems, the NRC issued Information Notice 87-04 on January 16, 1987 to alert the licensee to potentially significant probleos, pertaining to t6e Icng-term storage of fuel oi Discussion Assurance of the proper fuel oil requires purchasing the correct fuel oil and a receipt inspection to verify that the fuel oil is proper prior to addition to the storage tank Since fuel oil degrades with time and external sources contribute contamination, periodic inspec-tion is required to assure continued fuel oil quality.

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This inspection was performed.to determine the licensee program for the procurement, receipt, storage, handling and control of EDG fuel oil to ensure adequate quality of the fuel oi Diesel Fuel Oil Receipt / Storage System Description The Number 2 diesel fuel oil system for the site is comprised of a 30,000 gallon oil storage tank which provides a supply of oil to two redundant pumps powered from different safety busses. The pumps sup-ply fuel oil to the auxiliary boilers and the three EDG day tank The day tanks gravity feed fuel oil to the skid mounted EDG fuel pump The licensee estimated annual fuel usage is 72,400 gallons which provides a fuel turnover rate of approximately 3 tank volumes per year (normal tank level is 22,000 gallons). The storage tank fuel pumps and piping provide recirculation of excess fuel from the auxiliary boiler day tanks fuel header back to the storage tan Fuel Oil Requirements Procurement The licensee procures all Number 2 diesel fuel for the site as QA material 19 accordance with their blanket purchase order QA4081 This order requires that the fuel treet the requirements of ASTM-D-975-60 for No. 2-D diesel fuel. This requirement is consistent with the requirements for fuel oil systems for standby diesel generators as established in Regulatory Guide 1.137. The license purchase order further requires that the fuel supplied must be analyzed for viscos-ity, water and sediment prior to unloading the fuel. Licensee TS 4.8.1.1.2.c requires that each diesel generator shall be demonstrated operable at least once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank is within the acceptable limits of table 1 of ASTM-D 975-68 when checked for viscosity, water coa swimen The licensee samples tnd analyzes fuel in accordance with Proced we GP 9208. A review of this procedure and two recent fuel sampling, inspection and analysis including the associated quality assurance surveillance reports, did no; discicse any discrepancies. However, ASTM Specification D-975-68 defines what constitutes No. ? diesel fn1 by significantly more parameters than the viscosity, water and sediment content for which v.he licensee checks. Addit onal chemical i and physical parameters re':ded to qualify n No. 2 diesel foal in-clude cett.no number, flar.n point, cloud poir.t, distillation, carbon j residue, e sh., sulfur, and corrosion. Tne licensee fuel oil supplier -

analysis and certification states that the fuel supplied meets the requirem.nts of ASTM D-975. Further, the licensee fuel receipt and periodic tank analysis only verify three of the characteristics needed to determine that the material received or in the tanks is N diesel fuel. During this inspection the licensee concurred in the need to know that the fuel is of the proper quality to ensure diesel l

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p~ generator. or.erations. As a consequnce, the licensee agreed to evaluate periodically obtaining comp.'ete ASTM D-975 of the fuel by October 1,'198 Fue'l Storage Information Notice 87-04 addresses EDG surveillance failures'as a

!' result of fuel oil system fouling, oxidation, and biological contami-nation. The-inspector reviewed the licensee internal' evaluation and D report relative to this potential- problem. ' The evaluation . included background investigation of the- fuel problems reportcd in the notice with contacts with the affected plants and consultation with stand-ards laboratories. The root causes of the oxidations and biological problems were evaluated, including their relevance to the. fuel oil storageLsystem and fuel program at Yankee. Special samplings and analysis were conducted of the fuel storage and day tanks for fuel oxidation and biological contamination. 'Little evidence of.either-were found with the major finding being a small amount of water and sludge in the bottom one-inch of the storage tank. No evidence of contamination of the day tanks was'noted. The main fuel stcrage tank

.had never been drained and cleaned. Hewever, the fuel turnover rate is approximately three times per year which provides little residence time for fuel breakdown or biological growth. Further, the fuel con-tains additives to control biological growth. Currently, licensee procedures require draiaing any accumulated water in the storage tank on a quarterly basis and from the day tanks on an outage basi EDG Fuel System Operation With the EDG units operating, fuel is gravity fed from the day tanks to the engine fuel pumps which provide fuel pressure through the fuel filter to the engine feel header and injecters. The fuel filter is 9f the unit type wHch does not permit switch user or change durin EDG operation.. The fuel heaoer pressure is instrumented and muni-toted locally by an auxiliary operato . The #uel in the day tank is controlled by levei switchts which provide s ke-up from the storage tank. In addition to the local indication and alarm of fuel tank level and fuel pump pressure, there are alarms in the main control i, room for the nory,e tank Hi/Lo level, dcy tank Hi/Lo level (common for a11 threeh ar.d by tank overflow aise ~

Yhe EDG units and u-E sociated fusi Systems and ccaponents are @alified for operation under seismic event condit'.cn ;

Conclusions The licensee EDG fuel system and maintenance program has provided reliable EDG operation for many years. However, based upon this in-spection, the licensee concurs that potential fuel quality problems could arise with adverse impact on EDG operations. As a consequence,

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licensee commitments were made to evaluate the-implementation of ad-ditional procedures and analyses to ensure the quality of the diesel fuel required to maintain continued reliable operation. The licensee was responsive to the inspector issues raised. The inspector had no further question . Review of Periodic and Special Reports Upon receipt, the inspector reviewed periodic and special reports sub-mitted pursuant to Technical Specifications. This review verified, as applicable: (1) that the reported information was valid and included the NRC-required data; (2) that test results and supporting information were consistent with design predictions and performance specification; and (3) that planned corrective actions were adequate for resolution of the problem. The inspector also ascertained whether any reported information should be classified as an abnormal occurrence. The following report was reviewed:

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Monthly Statistical Report for plant operations for the month of June 198 . Kanagement Meetings At periodic intervals during this inspection, meetings were held with ser.ior plant management to discuss the f.ndings. A summary of findings for the report period was also discussed at the conclusion of the inspec-tion and prior to report issuance. No proprietary information was identi-fied as being included in the repor i i

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