IR 05000309/1986007

Insp Rept 50-309/86-07 on 860512-16.Violation Noted: Failure to Control Measuring & Test Equipment.Unresolved Item Re Analysis of Equipment Maint Needs Also Identified

ML20206R652
Person / Time
Site:	Maine Yankee
Issue date:	06/24/1986
From:	Eapen P, Holden C, Meils E, Napuda G, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206R596	List: IR 05000309/1986007 ML20206R590 ML20206R609
References
50-309-86-07, 50-309-86-7, GL-83-28, NUDOCS 8607070197
Download: ML20206R652 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-309/86-07 Docket N License No. DPR-36 Licensee: Maine Yankee Atomic Power Company 83 Edison Drive Augusta, Maine 04336 Facility Name: Maine Yankee Nuclear Power Station Inspection At: Wiscasset, Maine Inspection Conducted: May 12 - 16, 1986 Inspectors: h GsorgeNapuda,LeadReactorEngineer

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4 0x Corrf611us Holde'n, Senior Resident Inspector dite /

'5 kb lf g'/ djhdh William Oliveira, Reactor Engineer date

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Eric Meils, NRC Consultant d,/L3/86 date- '

Approved by: h. K - [MlfA G /J // M(,

Dr.P.K. Eapen, Chief, f Quality Assurance dat4

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Section, OB, DRS Inspection Summary: Announced Inspection conducted on May 12 - 16, 1986 (Inspection Report No. 50-309/86-07)

Areas Inspected: Licensee's actions to address the concerns identified in NRC'

Generic Letter 83-28 in the area of Equipment Classification, Vendor Interface, Post Maintenance Testing, Surveillance, and QA/QC Overvie Results: One violation (failure to control measuring and test equipment, paragraph 5.2.1) and one unresolved item (paragraph 3.2.1) were identifie BSU 26 bi PDR ADOCK 05000309 9 G -

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DETAILS

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1.0 Persons Contacted l

Maine Yankee Atomic Power Company J. Atkinson, Material Control

• E. Boulette, Assistant Plant Manager

• R. Chase, Quality Assurance (QA) Project Engineer

• R. Crosby, Assistant to Maintenance Department Manager D. Curtis, Mechanical Maintenance Supervisor M. Dover, Instrument and Control (I&C) Supervisor

• S. Evans, Licensing Engineer J. Garrity, Plant Manager

• R. Grant, Electrical Engineering Supervisor

• A. Jordan, Quality Control (QC) Supervisor i L. Lawson, QA Coordinator II

• R. Lawton Jr. , QA Manager A. Proctor, Stores Supervisor

• R. Prouty, Maintenance Department Head

• C, Shaw, Mechanical Engineering Supervisor

• K. Vachon, Electrical Maintenance Supervisor

• Whittier, Nuclear Engineering and Licensing Manager V. Withee, Document Control Supervisor United States Nuclear Regulatory Commission

• J. Robertson, Resident Inspector

• Dr. P.K. Eapen, Chief, QA Section, OB, DRS ,

• Indicates those who attended the exit meeting on May 16, 1986.

[ The inspectors also interviewed other site personnel during the in-spection.

I 2.0 Inspection Summary

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2.1 Background The reactor trip system, as part of the reacter protection system, is fundamental to reactor safety for all nuclear power reactor

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assumption that the reactor trip system will automatically initiate reactivity control systems on der.and to assure that fuel design '

limits are not exceeded. The design and regulatory philosophies for attaining the high reliability required of the reactor trip system have been based primarily on the use of redundancy, periodic testing, and quality assuranc !

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In February 1983 the Salem Nuclear Power Station experienced 2 failures of the reactor trip s-ystem on demand. Regulatory and in-dustry task forces we.re formed to determine the safety significance and generic implications of the events. Based on these findings, certain actions were required of all licensees. These actions, transmitted in Generic Letter 33-28, fell into 4 areas: (1) post-trip review, (2) equipment classification and vendor interface, (3) post-maintenance testing, and (4) reacwr trip system reliability improve-ment MYAPCo submitted their response to Generic Letter 83-28 in letters listed in Attachment A. This inspection included the areas'of equipment classification and vendnr interface, post-maintenance testing, and QA/QC interface 2.2 Inspection Results One violation and one unresolved item were identified. These findings are discussed in paragraphs 5.R.1 and 3.2.1, respectively. Except for these items, the irispectors found the licensee's actions to be consistent with the NRC positions of generic Letter 83-28 and the licensee's letters referenc.ed in Attachment .0 Equipment Classification 3.1 Program Review The documents in Attschment A were reviewed and it was determined that the Equipment Classification Program adtreised f or included the i following: i

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Safety related components are identified as such in written procedures for procurement, maintenance, and modificatio Management oversight of source documentation for the designation of safety related systems and component Corporate level procedurec for safety related component procurement, maintenance, and modificatio Periodic Quality Assurance au~dits of activities impacting safety a related equipmen ' -

Corrective action program for safety related equipmen .2 Program Implementation ,

Mechanical drawings for the Emergency Feed Water system. and the Emergency Diesel Fuel Oil and Starting Air systems were reviewed and found to accurately designate safety classification of components and proper safety related/non-safety related system boundaries. The I

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safety related systems list in the Maine Yankee Operational Quality Assurance Program, Appendix C, was reviewed and found to be accurat A sampling of equipment in four computerized equipment lists, still under development, showed no incorrect classification A field comparison of system mechenical drawings vs. installed equipment was performed and components were selected to assess the adequacy of the licensee's Equipment Classification Program Implementation from the following system:

Emergency Feed Water Primary Sampling Containment Spray Charging Emergency Diesel Generator Boric Acid Primary Water From the original selection, items were chosen for followup of the procurement process, receipt, storage, and handling. The procurement request, purchase order (P0), and receiving documentation included the safety classification, special requirements (shelf life), and certificate of conformance. Maintenance requests 1284-83, 2955-84, 2968-85, and 0294-86; design change request 83-29; and, purchase orders 33320, 33491, 42300, 36123, 43075, 41034, 40604, 37661 and 28353 were reviewed to determine proper safety classifi-cation, siesmic catagory, environmental qualification, and shelf life requirements. The "0" rings for the repair of the containment spray pump P-51A requested through P.O. 43075 were placed in a " hold area" of the ware house awaiting receipt of required documentatio The Stores Supervisor, in response to a question by the inspector, stated that a special request would be necessary to release the "0" rings without this documentation. The special request would be accompanied by an engineering evaluation as well as top management signatures. The classifications of the subject components were reviewed with cognizant engineers and determined to be accurat The inspector observed a Storeroom clerk entering information into the computerized Maine Yankee Atomic Power Company (MYAPCo) Stores Shelf Life Program. This program is used only by the Stores personnel. The clerk explained how the' program is continuously updated. The inspector walked through several items being added to the program. For components with limited shelf life, the expiration date of the component or specific component parts is clearly indicated on the stores tag attached to the component. Selected plant personnel, responsible for the determination of safety class-ification, were interviewed to determine if they were trained and knowledgable in tne area of safety classification. Those individuals interviewed had received training in safety classification procedures and demeastrated knowledge in their areas of responsibilit .

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The Maintenance and Instrumentation and Controls departments'

corrective action programs were reviewed to determine if component failure data is accumulated and trended. The programs require log-ging of all corrective maintenance performed on a system. At three month intervals, the maintenance histories are formally reviewed for impact on component preventive maintenance schedules. The corrective maintenance histories for selected systems were found to accurately describe the type of failure, and corrective maintenance performe Several non-safety related components in the Control Rod Drive and

Rod Position Indication Systems were selected to verify proper safety classification of maintenance activitie In all cases, the work was properly classified as non-safety relate No violations were identified. However, one unresolved item was identified and is discussed below:

3. In a letter to the NRC dated January 15, 1986, the licensee

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stated that preventive maintenance requirements for all stock items received prior to December 31, 1985 would be established and implemented by June 30, 1986. The details of this effort and its status was discussed with the Head of the Material Control Department. The analysis of equipment maintenance needs was thorough and well researched but did not clearly address the engineering evaluations for adverse effects on items that a lack of maintenance may have cause The head of the department

, stated that this evaluation wiuld be clearly incorporated into the preventive maintenance program for stored items. This item is unresolved pending NRC review that the licensee does assure such stored items have not suffered adverse effects due to a-lack of preventive maintenance. (50-309/86-07-01).

4.0 Vendor Interface 4.1 Program Review A NRC Performance Appraisal Inspection conducted in May and June of 1985 recommended that MYAPCo develop a procedure for their Vendor Interface Program. This procedure is in the initial review cycl The Document Control Supervisor is responsible for the procedure and the computerized Vendor Equipment Technical Information Program (VETIP) receipt of the manuals, distribution of the copies, and changes and revisions thereto. The procedure defines vendor manuals to include: installation manuals; operating manuals; and maintenance manuals. According to MYAPCo-letter MN 85-150 of August 20, 1985, addressed to the NRC, the program will be implemented six months after approval by NRC of the Nuclear Utility Task Action Committee (NUTAC) Vendor Equipsent Technical Information Program (VETIP).

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The licensee's program for interim control of vendor information was reviewed and determined to include and or address the following:

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Vendor information for Reactor Protection System components is curren Vendor information for safety related equipment is controlled throughout the life of the plan '

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Vendor information for Reactor Protection System components is complet .2 Program Implementation Safety related components were selected to assess vendor interface program implementation from the following systems:

Emergency Feed Water Emergency Diesel Generator Reactor Protection Information in the vendor furnished technical manuals for the selected components did not conflict with test procedures or preventive main-tenance activities. Maintenance procedures for the selected components referred directly to the vendor manual for detailed instruction The Reactor Trip Breakers have been modified per vendor recommendatio Periodic maintenance and surveillance is performed on the Reactor Trip Breakers per vendor recommendations and a maintenance history is maintaine Work order (DR/RO) 2208-86, Perform checks on Reactor Trip Breaker j SP-10 per Procedure 5-38-2, Routine Corrective Maintenance, was '

issued by the licensee to demonstrate the periodic surveillance /

maintenance performed on Reactor Protection System breakers supplied by General Electric Company (GE). Independent monitoring was provided by Quality Control (QC) using pre-established QC Notifica-tion Points (see paragraph 6). The_ technician was exceptionally knowledgeable about these breakers and work procedures associated with them and executed selected steps in a confident ahd dexterous manner. The QC individual also displayed a high degree of knowledge throughout the work cycle. The work and QC overview were performed in accordance with established technical and QA Program requirement .

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5.0 Post Maintenance Testing 5.1 Program Review Procedures in Attachment A were reviewed and it was determined that, during the performance of maintenance, the following were addressed or included:

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Written procedures provided for initiating requests for post maintenance testin Criteria and responsibilities for review and approval of maintenance.

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Criteria and responsibilities for the basis of safety related and non-safety related activity designatio Criteria and responsibilities for inspection of post maintenance testing.

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Methods for performing functional testing following maintenanc Administrative controls for documentation of maintenance activitie .2 Program Implementation Safety related components were selected to assess the implementation of post maintenance activities from the following systems:

Emergency Feed Water Reactor Protection Containment Spray Emergency Diesel Generator Post Maintenance Testing for the repair of the containment spray pump P-61A will be conducted by Plant Engineering Department (PED)/and j Operations Department (0ps) in accordance with the procedures cited '

in the DR/R0 6184-85. The cognizant engineer of the R0 and the test engineer have continued dialogue to insure that all the tests will be performed as required in the DR/R0 and on schedule. The inspector

" walked down" DR/R0 6184-85 from the time it was receive, by the Main-tenance Department; through preparation for a DR/R0 and the attached package of documentation to Plant Engineering for their review and j analysis and preparation of the DR/R0; to QA review and work authori-zation to Mechnical Maintenance. The DR/R0 was processed in accord-ance with Procedures 0-07-1, 0-07-3, 0-07-4 and 17-20 Work packages for other selected components were reviewed and deter-mined t'o be in compliance with written procedures governing mainten-ance activitie .

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One violation (50-309/86-07-02) was identified and is discussed belo . The alignment of the pump shaft to the motor shaft following pump seal replacement, of Containment Spray Pump P-61A, was observed. Repair Order (RO) number 6184, method 7, specified the final pump shaft to motor shaft alignment and total run out readings. In this step, a total run out of less than 0.002" was recommended to ensure maximum life of the pump mechanical sea The two dial indicators used for the run out had no identifi-cation number. There was no evidence that the dial indicators

.were properly controlled, calibrated, or adjusted at specified periods to maintain accuracy within the necessary limits. The licensee's procedure for measuring and test equipment calibra-tion and control (0-06-5) does not include dial indicator This is a violation (50-309/86-07-02).

6.0 QA/QC Interface Procedures have QC Notification Points included in their' step-by-step de- i tails. The required in-line review of work orders by QC provides the me-chanism for the assignment and planning of QA/QC overview of activitie Independent inspection is documented on en Independent Inspection Check-list in addition to a QC signoff step in the procedure. Also, the inspec-tion number is recorded on the affected procedur The largest QA/QC over-view effort is monitoring / surveillance of ongoing activities that the li-censee has defined as Evaluation Each such Evaluation is documented and the specific observations are recorde Whenever a DR (Deficiency Report) relating to safety classification items is generated, an R0 (Repair Order)-is also prepared 4nd receives a QA re-view. Any inspection or other QA/QC activities are noted by the Operation-al QA Department (0QAD), during this revie The 0QAD also conducts inde-pendent inspections that differ from roving inspections in that they are scoped, planned and scheduled for particular activities that 0QAD may deem to require independent inspection. While this type of inspection uses checklists, the 0QAD inspector has the latitude to adjust his inspection effort to the activity. This was demonstrated during the repair of con-tainment spray pump P-61A. The bellows installation was changed to re--

flect the manufacturer's recommendations. As a precaution the licensee had ordered a spare in case the orignial bellows was damaged during re-installatio During this activity, the 0QAD inspector, in the absence of the cognizant engineer, contacted the manufacturer for advice regarding maximum allowable total runout toleranc .

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An annual survey of Reactor Protection System component vendors is conduct-ed by QA to secure any update technical information such as for Vendor Technical Manuals. This information is reviewed and disseminated as appro-priate to manual holders and the survey is documented as an Evaluatio Similar surveys are planned to be conducted on other vendors. The exact methodology of technical information control is dependent on a forthcoming decision by the NRC of a proposal for such a program made by the Combustion Engineering Owners' Group.

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, Specific aspects of the above are discussed in the other paragraphs of this repor No violations were identifie .0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violation An unresolved item is discussed in Paragraph 3. .0 Management Meetings '

Licensee management was informed of the scope and purpose of the inspection at'an entrance meeting conducted May 12, 1986. The findings of the inspec-tion were discussed with licensee representatives during the course of the inspection. An exit meeting was conducted Many 16, 1986 at the conclusion of the inspection to present the finding to licensee management. (see Paragraph I for attendees)

At no time during this inspection was written material provided to the licensee.

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Ai7ACHMENT A 1.0 Requirements /Raferences (1) NRC Generic Letter 83-28, " Generic Implications of Salem ATWS Events" (2) 10 CFR50 Appendix B (3) Maine Yankee Technical Specifications (TS)

(4) Maine Yankee FSAR (5) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (6) ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (7) ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants (8) MYAPCo letter MN-83-232 of November 10, 1983, Subj: Initial response to Generic Letter 83-28 (9) MYAPCo letter MN-85-14 of January 25, 1985, Subj: Additional in-formation regarding Generic Letter 83-28 (10) NRC letter of April 24, 1985, Subj: Safety Evaluation for Maine Yankee Generic Letter 83-28, Item 1.1 (Post-Trip Review)

(11) MYAPCo letter MN-85-151 of August 20, 1985, Subj: Vendor Interface Program for Safety Related Components-Generic Letter, Item 2. (12) MYAPCo letter MN-86-07 of January 15, 1986, Subj: Preventive Main-tenance (PM) Progra (13) MYAPCo letter of January 15, 1986, Subj: Preventive Maintneance (PM)

(14) NRC letter of August 6, 1985, Subj: Performance Appraisal Inspection Report 50-309/85-15 (15) NRC letter of January 24, 1986, Subj: Systematic Assessment of Licensee Performance (SALP) Report No. 50-309/85-15 (16) General Electric (GE) Service AJvice TAB 175 No. 9.21 AK-25 Reactor Trip Breakers-Shund Trip Paddle

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Attachment A 2 2.0 Documents Reviewed 2.1 Procedures 0-00-4 Classification of Nuclear Systems, Components, and Structures, Re Measuring and Test Equipment, Re Installation and Maintenance of Safety Classified. Systems, Components, and Structures, Re Discrepancy Reporting Procedure, Re Repair Orders, Re Processing Repair Orders Within the Plant Engineering Department, Re Operational Assessment System, Re MY Commitment Management System, Re Reactor Trip System Components, Re Routine Corrective Maintenance, Re Assembly of a Containment Spray Pump, Re Administration of the Preventive Maintenance Program, Re . Emergency Diesel Generator-Monthly Surveillance Testing, Rev.2 .2 Programs (1) Maine Yankee Operational Quality Assurance Progra .3 Drawings

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4r 11550-FM-70A rev.23 Main Steam Piping -

11550-FM-72A rev.24 Auxiliary Steam Piping 11550-FM-73A rev.25 Steam Generator Feed Water Piping 11550-FM-80A rev.13 Lubricating & Fuel Oil Piping 11550-FM-88A rev.11 Diesel Generator Starting Air Piping

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Attachment A 3 2.4 Vendor Manuals (1) Byron Jackson Ir.sta11ation & Operation Instructions, Re (2) General Motors Electromotive Division 1st Edition (3) Terry Steam Turbine (4) Controlotron Clamp-on Flow sensor 2.5 Maintenance Requests (DR/RO)

3997, WD-122 valve leaking 6184-85, Excessive Packing Leakage 1294-86, Add Lube Oil to 1A DG Governor 2955-84, Turbo 011 Pump Makes Noisr; 0294-86, Replace Turbo 011 Pump & Motor 1284-83, Replace Lovejoy Coupling in Speed Control & Fuel Pumps 2707-84, Defective BFD Relay 1932-83, Governor Manual Speed Control 0489-85, Modify Spare Upper Gripper Modules 0213-85, Control Element Drive System 0218-86, Limit Switch Ground 0480-86, Control Element Assembly #52 Dual Indication on MCB Mimic 1052-86, Control Rod SD Group C #51 Will Not Withdraw 2.6 Miscellaneous (1) MYAPCo Lists (2) Valve List (3) Instrument Schedule (4) Equipment List (5) Relay List (6) Stores Shelf Life Program Purchase Orders 4103400 Thermostats 028353 Snap Lock Limit Switches 36267 Reactor Trip Gear 33491 Pump & Motor Assembly 42300 Delco Pump & Motor Assembly 33320 Viton Couplings Non-Conformance Reports (NCR)

84N-201 86N-023 86N-021

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e Attachment A 4 Corrective Action Requests-(1) Surveillance No. 845-491 Reactor Trip Components (2) Operational Assessment Action Request DE83-90, Reactor Trip Breaker Maintenance TAB 175 No. 9.20 Maintenance and Upgrade of AK-25 Circuit Breaker with UV Trip Device .

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