IR 05000309/1985028

Insp Rept 50-309/85-28 on 850920-1021.Violation Noted: Procedural Deficiencies Resulting in Failure to Perform Tech Spec Required Surveillance Testing.Licensee Corrective Actions Acceptable

ML20137K669
Person / Time
Site:	Maine Yankee
Issue date:	11/26/1985
From:	Eichenholz H, Elsasser T, Holden C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137K651	List: IR 05000309/1985028 ML20137K647
References
50-309-85-28, NUDOCS 8512030255
Download: ML20137K669 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket / Report: 50-309/85-28 License: DPR-36 Licensee: Maine Yankee Atomic Power Company 83 Edison Drive Augusta, Maine 04366 Inspection at: Maine Yankee Nuclear Power Plant, Wiscasset, Maine Dates: September 20 - October 21, 1985 Inspectors: h # M

d H. Eichenh ,' ior Resident Inspector Date

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1. ~C. Hold ,S or Resident Inspector Date

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Approved by: -.

// 85 T. C. Elshfi6r, Chief, Reactor Projects Section 3 C Dats Summary: Inspection Report 50-309/85-28 (September 20-October 21, 1985)

Areas Inspected: Special announced reactive inspection of licensee activity related to their corrective action program that was developed in response to two unrelated events which resulted in the inoperability of the low steam generator pressure trip functions. The inspection involved 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> on site by two senior resident inspector Conclusion: Licensee corrective actions were acceptable. The licensee was informed that no outstanding issues associated with this inspection existed which would prevent the plant from returning to power operatio Results: One licensee identified violation was determined to exist and involved procedural deficiencies which resulted in failure to perform Technical Specifications required surveillance testin Ogo%h eG

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DETAILS 1. Persons Contacted The below listed technical and supervisory personnel were among those contacted:

Maine Yankee Atomic Power Company E. T. Boulette, Assistant Plant Manager J. H. Garrity, Plant Manager J. R. Hebert, Director, Plant Engineering Department R. Nelson, Nuclear Safety Section Leader R. L. Radasch, Instrument and Controls Section Leader G. D. Whittier, Manager Nuclear Engineering and Licensing E. C. Wood, Assistant to Executive Vice President Yankee Atomic Electric Company W. H. Reed, Instrument and Control Lead Engineer Stone and Webster Engineering Corporation C. F. Bergeron, Consultant - Nuclear Technology and Licensing Division The inspector also interviewed and held discussion with other licensee employees during the inspection, including members at the Operations, Maintenance, Nuclear Safety, and Plant Engineering Departments:

2. Background and Scope 2.1 Background On August 7, 1985, the licensee discovered that nine of the twelve root valves for the steam generator pressure transmitters were mispositioned. This resulted in the inoperability for all of cycle 8 operations of the low steam generator pressure trip function in three of the four channels (i.e. , Channels B, C, and D) of the Reactor Protective and Feedwater Trip Systems. In response to this event, the NRC conducted a special safety inspection on August 8-16, 1985 and issued Inspection Report 50-309/85-19 on August 28, 198 An Enforcement Conference to be conducted with the licensee on September 9, 1985 to discuss this even During the performance of a routine refueling surveillance test on September 3, 1985, the licensee discovered that the Channel A low steam generator pressure trip of the Reactor Protection System was inoperable for all of cycle 8 operations. This was attributed to a

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design error in the modification that installed a subcooling margin monitor for the steam generators. It was also determined that the licensee did not conduct adequate post modification testing to ensure that the Reactor Protection System was operable. In response to this event, the NRC conducted a special safety inspection on September 3-4, 1985 and issued Inspection Report 50-309/85-27 on September 4, 1985. The licansee included a discussion of this event in the Enforcement Conference which was held on September 9, 198 At the Enforcement Conference in the NRC Region I office, the licensee discussed the circumstances surrounding the discovery of the two events and the corrective action to prevent recurrence were outlined by the licensee. The corrective actions included.an in-depth plan for control of all root valves as well as a review of post plant modifications,and a functional test program to evaluate proper in-stallation of these modifications. The licensee's proposed correc-tive actions were presented during this meetin Following an NRC request made at the Enforcement Conference, the licensee transmitted letter MN-85-164 to the Region I office on September 13, 1985 as it's formal documentation of a program to correct and prevent recurrence of the events described in NRC Inspection Nos. 50-309/85-19 and 50-309/85-2 .2 Scope The purpose of this special NRC inspection was to provide an onsite independent safety assessment of the adequacy of the licensee's implementation of it's corrective action The NRC assessment included:

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Frequently held discussions with station and corporate management representatives.for the purpose of obtaining

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licensee clarifications of their written commitments, and provide immediate feedback of inspector identified concern Observe the activities and conduct interviews with personnel of the various working groups and committee's assigned responsibilities-for implementing corrective action program element '

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Perform reviews of documentation associated with the program elements (e.g., new functional test procedures).

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Conduct field observations of selected functional tests b$ing implemented as part of the corrective action program to determine if expected performance was achieve A determinations that all licensee commitments were or would be complete prior to achieving power operation In addition to the above, the inspection was utilized to verify the licensee's immediate and long term corrective action commitments associated with Violations 50-309/85-19-01 and 50-309/85-27-0 . Reactive Inspection in Response to Licensee's Implementation of a Corrective Action Program 3.1 Documents Reviewed The documents reviewed during this inspection are listed in Attachment "A" to this repor .2 Inspection Findings and Conclusions The items described below correlate on a one-to-one basis with the elements of the licensee's corrective action program described in their letter to NRC Region I dated September 13, 198 During the inspection, the inspector held discussions with licensee representatives pertaining to the status of the program elements and the manner in which the licensee would document the corrective measures that were to be implemented. Inspector observations that certain program elements appeared to be implemented in a fashion different than that described in the licensee's commitments were discussed with them. On October 15, 1985, the licensee transmitted letter MN-85-177 to the NRC Region I Office, which contained the status of each element and assurance that the corrective action program objectives would be met prior to returning the plant to power operation. This letter also stipulated that in several in-stances the corrective actions changed from what was originally contemplated. No unacceptable findings were made as a result of the licensee redirecting it's corrective action efforts due to an evolu-tionary proces .

5 Items Reviewed: Verify as open, all root valves associated with instrumentation identification in Technical Specifications Tables 4.1-1, 2 and On August 7, 1985, when nine of the twelve root stop valves for Steam Generator (S/G) Pressure transducers were found shut, all S/G root valves were opened / checked open and tagged ope Technical Specifications (TS) were reviewed and a list of all Reactor Protective System (RPS), Engineered Safeguards System and other miscellaneous safety system instrumentation was developed from tables 4.1-1, 2 ar.d 3. Using this list, the licensee verified the root valves open either through physical check of the valve, procedure review which showed the valve had been opened or a review of the instrument performance which in-dicated the instrument was operable. Additionally, transients which had occurred during the cycle were reviewed to verify proper instrument respons The valves that were inaccessible during power operations were checked shortly after the plant shutdown for a refueling outage on August 17, 1985. All root valves, except the 9 mentioned above, were found in their required open positio . Incorporate all root valves identified in TS tables 4.1-1, 2 and 3 into appropriate operating procedures to ensure that they are opened and verified opened prior to startup from each refueling outag The licensee reviewed plant startup procedures and incor-porated all root valves for TS Tables 4.1-1, 2 and 3 into these procedures, if required. This was accomplished prior to October 21, 198 . Verify that appropriate administrative controls (procedures)

exist on all isolation valves associated with instrumentation identified in (1) abov A review was conducted by the licensee of procedures that govern the positioning of instrument isolation valves. The licensee determined that the existing controls are adequat The inspector noted during the licensee's review process associ-ated with the development of special functional testing pro-cedures that they are implementing enhanced administrative con-trols of instrument root valve and independent verification practices associated with instrument valve . .-

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6 Review all special tests and temporary procedures prior to use to ensure that each valve position is individually specified

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when realigning system Special tests and temporary procedures were reviewed. Those procedures which were not active were terminated. This accounted ,for the majority of the temporary procedures. The remaining procedures were reviewed to ensure individual valves were specified when realigning the syste . Revise the generic procedures governing the preparation and review of procedures to ensure valve positions are individually specified when realigning system Maine Yankee procedure 0-06-1 " Procedure Preparation, Classification and Format" has been modified to require that procedures, which involve the repositioning of valves, specify the correct final or "as left" position of each valv . Redesign the Subcooled Margin Monitor (SMM) circuitry to eliminate common connectio The licensee reviewed, approved, and installed a modification to SMM that eliminated the common connection associated with the selector switch. A review was conducted by the inspector of modification, installation and testing documentation. Special Functional Test No. 4-6-01-14, Steam Generator Pressure, was utilized for post modification testing. The review resulted in identifying one item of concern. The item deals with the adequacy of documentation associated with the Safety Evaluation of Engineering Change Notice (ECN) No. 5 to EDCR No. 83-32, Saturation Monitor Upgrade. The ECN incorporated 0-06-4-1, Form 10 CFR 50.59 Safety Evaluation, which was completed by the assigned Yankee Nuclear Services Division (YNSD) Enginee Although the forms was used minimal information existed that provided a written basis as to why the change does not involve an unreviewed safety question. A written basis is required by 10 CFR 50.59. The licensee's Procedure 17-21-2, Engineering Design Change Request-Maine Yankee, indicates that Safety Evaluation are done in accordance with Procedure 17-21-7 (Safety Analysis) with the conclusions in the safety evaluatien being fully supported by adequate discussion in the text. In addition, a 10 CFR 50.59 Safety Evaluation per Procedure 0-06-4 is to be performed. The format of a Major Change ECN, which is the type in question, requires both the Safety Evaluation and the 10 CFR 50.59 Safety Evaluation, which are respectively done by procedures 17-21-7 and 0-06-4. The inspector noted that only the evaluation utilizing Procedure 0-06-4 was included in the EC .

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As a result of inspector concerns on this matter, discussion were held with the Plant Director and the Director of Plant Engineering. Following a request by the inspector for improved documentation, the licensee added a Safety Evaluation section to ECN No. 5 of EDCR 83-32. This document was reviewed by the PORC on October 10, 198 The Plant Manager agreed to review the use of Form 0-06-4-1, 10 CFR 50.59 Safety Evaluation, to ensure that appropriate guidance exists for a required Safety Evaluatio . Review all previous design changes which involve or could interact with the safety instrumentation systems listed in TS Tables 4.1-1, 2, and The licensee, in consultation with the Maine Yankee Project Department of YNSD developed a Design Change Review Action Plan to implement its commitment to the NRC. Implementation of the action plan was assigned to YNSD, who developed Procedure MYP Special -1, Rev. O, Design Change Review to control the activity. Additionally, the procedure identified the specific objectives of the design change review and identified the screening methods and selection criteria. The essential aspects of the review consisted of determining if commoning or any other

interaction problems existed. The licensee utilized the combined expertise of individuals in the YNSD Engineering and Stone &

Webster Engineering Corporation to perform the reviews. The com-position of the review group was controlled by Procedure MYP Special - The inspector reviewed YNSD Memorandum from R. P. Shone to

. P. L. Anderson, dated October 7, 1985, which documented the completion of the design review. Furthermore, the inspector

. reviewed the eight enclosures to this memorandum which docu-mented the review activity. The inspector noted, that, as a result of the licensee's review, sixty-five design changes were actually determined to have interacted with TS 4.1 instrumenta-tion. The licensee's design review determined that no instances of improper design existe . Provide an independent design review of all of the design changes identified in item 7 abov As required by their action plan and implementing procedures, the licensee contracted with Combustion Engineering and Stone &

Webster Engineering Corporation to perform the independent review of the sixty-five changes which were identified as interacting with TS 4.1 instrumentation during the YNSD review in item 7 above. In addition, eight other design changes, which

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had been determined to have no interaction with TS 4.1 instru-mentation, were also independently reviewed. This review resulted in an determinntion that all interface requirements were met and no instances of improper design existed. Combustion Engineering was specifically assigned the responsibility of reviewing those design changes that involved the Reactor Pro-tection Syste The inspector identified no inadequacies in the licensees in-dependent review activitie . Develop functional test requirements that are more comprehensive for all systems identified in item 7 above that have been significantly modified since the issuance of the facility operating license (1972), including those undergoing modifica-tion during the current outag The licensee developed functional test criteria for use in item 10. This activity was performed by the Functional Test Criteria Group, and included input derived from the design change review process conducted.by YNSD, Combustion Engineering, and Stone &

Webster Engineering. The Functional Test Criteria, which were reviewed by the inspector, specified test requirements that ensure safety analysis assumptions are satisfied. Although not included in TS Table 4.1, the group specified functional testing for the turbine trip on a reactor trip, and a position verifi-cation on the Safety Injection Tank outlet valve As a result of the licensee's efforts on this item, a more comprehensive set of functional testing requirements have been compile . Provide documented assurance that the functional test requirements identified in item 9 above have been previously satisfied, and no further modifications have been performed, or perform new comprehensive functional tests to satisfy the applicable requirement Utilizing the functional test requirements developed above, the licensee's initial efforts in providing the assurance that the functional test requirements have been previously satisfied, were assigned to an I&C Procedure Subcommittee. The subcommittee was to ensure that existing calibration procedures adequately address the functional test requirements or developed new functional test procedures. This subcommittee was only a part of the Special Functional Testing Program developed by the license ,

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Early in the inspection, it was noted that the licensee did not appear to have an independent assessment of the adequacy of existing functional testing procedures. This concern was brought to the licensee for resolution by the inspector at a meeting with licensee management representatives on September 24, 1985, On September 25, 1985, an Interface Review Subcommittee, was established to ensure that the interface between the Functional Test Criteria Group and the I&C Procedure Subcommittee is comprehensive. This interface group of licensee and contractor personnel were independent of the development of existing functional testing procedures, and were to verify that every functional test requirement is explicitly addressed by either an existing calibration procedure or by a new functional test procedur Another aspect of the Special Functional Testing Program was the establishment of a Functional Test Special Review Subcom-mittee of the PORC, to review new test program procedures for the purpose of ensuring that the functional test requirements were comprehensive and that the test program procedures were adequate. Subcommittee reviews were presented to the full PORC Committee. The inspector verified that the subcommittee was operated in accordance with a Charter that was endorsed by the plant and corporate managers. Based upon the comprehensive nature of the subcommittee reviews, as well as the manner in which its members carried out their assigned review functions, the inspector has concluded that the licensee's utilization of a PORC Subcommittee is an example of a licensee management strengt The Special Functional Test Procedures, of which their were approximately 23, were developed by the licensee to provide single value instrument loop integrity checks. These checks were verified to be performed following the completion of all modification activity done during the current refueling outage, and included the performance of the detailed refueling calibration procedures as a prerequisite. The licensee considered these Special Functional Tests to be added assurance that modifications to instrumentation loops did not result in any undesirable interactions between circuit Following the completion of each Special Functional Test, they are being reviewed by the Fuctional Test Program Manager and the I&C Section Head. The performance of selected tests were reviewed by the inspector at both containment and control room location Regarding the identification of discrepancies during the performance of the Special Functional Test Pregram, the licensee has identified one minor wiring error that has been resolved. As a result of the Interface Review Subcommittee

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effort, the licensee informed the inspector of identified procedural discrepancies associated with surveillances required by TS Table 4.1-1, 2, and 3. The instrumentation channels involved were 1) Containment High Pressure, 2) RWST Level Calibration, 3) the High Pressure Setpoint Relief Mode of the PORV Actuation Circuit, and 4) the Variable Pressure Setpoint Relief Mode of the PORV Actuation Circuit. The inspector verified that the licensee had established appropriate short term corrective actions that would ensure that the TS surveillance testing requirements would be performed prior to the equipment being declared operable. The above noted procedural descrepancies resulted in failure to perform TS required surveillance testing for the specified functions of Table 4.1-1, 2 and 3. However, this item meets the criteria of NRC Enforcement Policy,10 CFR 2, Appendix C, 49 FR 8587 (March 8, 1984), Section V.A. for a licensee identified item and a notice of violation will not be issued, in that: the item was identified by the licensee, reported pursuant to 10 CFR 50.73, if appropriate, it constitutes a violation at Level IV (Supplement I.D.) it was not an item that the licensee could resonably be expected to prevent by corrective action from a previous violation, and the item will be corrected including measures to prevent reoccurrence within a reasonable length of tim Regarding this last point, the licensee will develop resolutions for the discrepencies affecting existing surveillance procedures and submit them in writing to the NRC Region I office within a month following plant startup. The licensee identified item remains unresolved pending completten of corrective actions (50-309/85-18-01).

11. Revise the EDCR procedures to specifically identify instrumentation lead "commoning" as requiring special design review emphasi The licensee submitted for inspector review and comment proposed revisions to Procedures 17-21-2. Engineering Design Change Request-Maine Yankee, and 17-21-6, Design Verificatio The licensee acknowledged inspector comments and concerns relative to their proposed procedural directives, and modified the documents accordingl The revised procedures direct the designer and design reviewer to address whether the change electrically connects any two or more instrument or control circuits such that common points of connection could degrade the operation of the circuit (s) or system (s). Additionally, YNSD engineering Instructions WE-100, Engineering Design Change Request and WE-101, Plant Design Change Request, have been revised to require the appropriate

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i design review emphasis. The inspector reviewad tM YNSD document revisions and determined that they were appropriate design control measure . Revise the QA procedures to require that a comprehensive l functional test be performed on modified circuits including any

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associated circuits that may be affecte The licensee has revised their Procedure 0-06-3, Preoperational, Operational, and Special Test and Experiments to require a com-prehensive functional test to be performed on modified electrical circuits, including instrument and control loops and any associ-ated loops or circuits that may be affected, to verify that the installed system meets the intent of the design change require-ment YNSD Procedures WE-100 and WE-101 have been revised to incorporate as design input and design review considerations the specifying of appropriate system functional testing requirement . Revise the EOCR procedures to require a second independent design review of all EDCR's associated with instrumentation identified in item 7 above, with particular emphasis to detecting sneak or interactive circuit The licensee has specified, that, Procedures 17-21-2 and 17-21-3 already require an independent review of all EDCRs and a second independent review of Design Grade 1 changes. The licensee has included all TS Table 4.1 instrumentation within the definition of Design Grade 1. Since the existing definition implies a safety class system, the inspector noted that this would be appropriate only if all the instrumentation in TS Table 4.1 are part of safety class systems. This observation was related to licensee representatives for their review and action, if require Regarding the EDCR procedures having a requirement that places particular emphasis for detecting sneak or interactive circuits, the inspector verified that appropriate instructions were added to Procedure 17-21-6, Design Verificatio . Revise the procedures governing design change implementation instructions to provide an independent review to ensure that the functional test requirements are appropriately comprehensiv . . _ - . . ., -_- - _ . _. _ _ - _ _ _ _ _ _ _ _ - -

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. The licensee has revised Procedure 17-23-1, Design Change Implementation Instructions, to have the independent reviewer to ensure that the functional test requirements are appropriately comprehensive. This procedure requires that the functional tests be developed in accordance with Procedure 0-06-3, which in item 12 above was revised to require comprehensive functional testing be. performed on modified elec~tric circuits. Inspector comments and concerns were resolved by the licensee prior to final release of Procedure 17-23- In addition, the YNSD design procedures have been revised to ensure that appropriate functional testing requirements are considered during design review . Exit Interview l Meetings were periodically held with senior facility management to discuss the inspection scope and findings. Between September 23-25, 1985, these meeting included the participation of the Chief, Projects Branch No. 3, Division of Reactor Projects.

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ATTACHMENT "A" TO INSPECTION REPORT 50-309/85-28

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Documents Reviewed during Inspection 50-309/85-28:

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Letter to NRC Region I, MN-85-164, dated September 13, 1985

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Letter to NRC Region I, MN-85-177, dated October 15, 1985

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Licensee Procedure No. 0-06-4, Rev. O, 10 CFR 50.59 Safety Evaluations

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Licensee Procedure No. 17-21-3, Rev. 1, Engineering Design Change

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Request Yankee Nuclear Services Division (YNS0)

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Licensee Procedure No.17-21-7, Rev.1, Safety Analysis

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Licensee Procedure No. 0-06-3, Rev. 1, Preoperational, Operational, and Special Tests and Experiments

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Licensee Procedure No. 17-21-6, Rev. 1, Design Verification

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Licensee Procedure No. 17-23-1, Rev. 1, Design Change Implementation Instructions

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Licensee Procedure No. 17-21-2, Rev. 1 Engineering Design Change Request-Maine Yankee

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Licensee Procedure No. 17-22-1, Rev. 2, Document Revision Procedure

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YNSD Procedure WE-100, Rev. 13, Engineering Design Change Request

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YNSD Procedure WE-101, Rev. 7, Plant Design Change Request

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Special Functional Test Procedure 4-6-01-1, Rev. O, High Pressurizer Pressure

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Special Functional Test Procedure 4-6-01-2, Rev. O, Interlocks -

Isolation Valves on Residual Heat Removal Line; and Pressurizer Power Operated Relief-Variable Pressure Setpoint

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Special Function Test Procedure 4-6-01-3, Rev. O, High Pressure Safety Injection Header Pressure

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Special Function Test Procedure 4-6-01-4, Rev. O, Low Pressure Safety Injection Header Pressure

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Special Function Test Procedure 4-6-01-5, Rev. O, Containment Spray Header Pressure

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Special Function Test Procedure 4-6-01-6, Rev. O, RHR HX Outlet Temperature

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Special Functional Test Procedure 4-6-01-7, Rev. O, Containment Water Level

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Special Function Test Procedure 4-6-01-9, Rev. O, Wide Range Logarithemic Neutron Channels

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Special Functional Test Procedure 4-6-01-10, Rev. O, Reactor Coolant Flow

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Special Functional Test Procedure 4-6-01-13, Rev. O, Stean Generator Level

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Special Functional Test Procedure 4-6-01-14, Rev. O, Steam Generator Pressure

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Special Functional Test Procedure 4-6-01-15, Rev. O, Safety Injection Tanks Level and Pressure i

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Special Functional Test Procedure 4-6-01-18, Rev. O, Containment Pressure

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Special Functional Test Procedure 4-6-01-20, Rev. O, ECCS Light Box

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Engineering Design Change Request 83-32, ECN, Saturation Monitor Upgrade i

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Implementing Instruction 83-32-7, Saturation Monitor Upgrade Selector Switch Re-wiring

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Functional Test Criteria Summary Output from the Nuclear Safety Engineering Requirements Subcommittee

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Design Change Review Summary

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YNSD Action Plan - Design Change Review, documents dated September 5

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YNSD Memorandum R. P. Shane to P. L. Anderson dated October 7,1985, Design Review

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Multi-Disciplinary Committee Review - Summary Document

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Licensee Memorandum E. Wood /T. Boulette to Distribution, dated September 24, 1985, Special Functional Testing Program

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Licensee Memorandum J. H. Garrity to Distribution, dated September-18, 1985 Special Functional Test PORC Subcommittee Charter

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Minutes of the Special Functional Test PORC Subcommittee - Various

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Minutes of the PORC - Various

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Memorandum from Interface Review Subcommittee to E. C. Wood, dated October 2, 1985

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-Technical Specifications for the Maine Yankee Nuclear Power Plant

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Summary Document - TS Table 4.1-1, 2 & 3 Items vs. Most Recent Modification and Date

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Memorandum E. C. Wood to Distribution, dated September 6, 1985, Action Plan

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Listing of All Previously Installed Modifications At Plant

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Listing of Applicable Modifications from First Screening of Design Change Review

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List of Modifications Receiving Independent Design Review

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Documentation of Design Change Review of Independent Design Change Review

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