IR 05000309/1990080
| ML20012D354 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/06/1990 |
| From: | Kelley G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012D346 | List: |
| References | |
| 50-309-90-80, NUDOCS 9003270221 | |
| Download: ML20012D354 (38) | |
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NUCLEAR REGULATORY COMMISSION Realon I
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Report No.:
50-309/90-80
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LiCJnsee:
Maine Yankee Atomic Power Company 83 Edison Drive Augusta, Maine 04336 Facility Name:
Maine Yankee Nuclear Power Station
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Inspection At:
Wiscasset, Maine and Bolton, MA Inspection Conducted:
January 14 through January 19, 1990 Inspection Team Members:
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Team Leader:
E.
Conner, Project Engineer, Region I
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Mechanical:
T. White, ERC Environmental and Energy i
Services Company
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E. Leeds, NRR Project Manager Electrical:
G. Morris, ERC Environmental and Energy Services Company Operational:
J. Stair, Susquehanna Resident Inspector Special Programs:
T. Koshy, Yankee Rowe Resident Inspector l
Approved By;
Gen 6 Kelly, Chief I Date l
Technical Support taff
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Division of React r Projects Ok
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SUMMARY A team of NRC inspectors and contractor personnel reviewed Maine i
Yankee's progress in resolving findings from the Safety System
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Functional Inspection of the component Cooling Water system originally conducted in January 1989 detailed in the NRC Region I Inspection Report 50-309/89-80.
This report identified about 60 individual findings, i.e., items where corrective action should be taken, and five assessed weaknesses.
Follow-up of these findings found that the majority of items correctable by simple calculations, analyses or safety evaluations, by procedure changes, or by minor plant system modifications have been completed.
In addition, for more complicated items, the licensee (Maine Yankee) has embarked on comprehensive programs for correcting the original team's findings.
The SSFI Follow-Up (SSFIFU) team evaluated the status for the five major issues as follows:
(1)
Inconsistent Safety Perspective Exemplified by Maine Yankee's Approach to Resolving Several Longstanding Problems Maine
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Yankee has attended to the specific concerns of the SSFI team and has taken steps to emphasize quality assurance in the electrical and instrument and control areas.
The team recommends that issues found during the plant design bases recovery program, as well as from other sources, receive prompt analyses to identify all safety concerns, and that corrective actions are taken as appropriate.
(2)
Technical Specifications and/or other Administrative Controls Allow DC Buses Operation in a Non-Conservative Mode Maine
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Yankee is planning to install a spare inverter and battery charger to eliminate the need for ties between redundant buses.
This installation, when complete, will resolve NRC's concern on this subject.
However, administrative control allowing cross-tie of the DC buses for seven days is excessive and needs to be justified.
(3)
Generally Inadequate Short circuit Protection for the DC Buses and Motor Thermal Protection Although comprehensive
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planning has occurred, questions remain regarding the protection of plant electrical equipment, i.e., omissions from the DC short circuit calculation and basis for the selection of large AC motor thermal protection.
(4)
Concerns with the Component Cooling Water System Capability to Perform its Intended Safety Function Maine Yankee has
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satisfactorily documented, through conservative assumptions and analyses, that the component Cooling Water system can perform its safety function.
The substantiation of residual heat removal (RHR) and component cooling water (CCW) heat exchanger design by performance testing remains to be completed.
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l Maine (5)
Component Replacement Verses Design Change Process
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Yankee has taken a number of actions to strengthen their programmatic controls for design changes and componen; j
substitutions.
In addition, the licensee has initiated a minor modification process which will become a part of an Integrated Plant Component Control System.
The SSFIFU team noted two Maine Yankee initiatives as part of the conduct of the current follow-up effort.
First was the implemen-
tation of Probabilistic Risk Assessment (PRA) insights even before the full analysis was completed such as establishment of an Equipment Importance Ranking Table for prioritization of maintenance activities, implementation of on-chift review of Discrepancy Reports and Failed Surveillance, PRA-based training scenarios for simulator use, and the guidelines for use of PRA results for 10 CFR 50.59 determinations.
Another initiative noted by the team was the use of a sophisticated vibration monitoring reliability program for all plant rotating equipment.
A demonstration of this equipment, including review of the Charging Pump bearing failure prediction chart, was provided to the team.
Use of this type of equipment is aimed toward increased plant reliability and reduced safety system challenges.
Of the approximate 60 items which the original SSFI team identi-fled, the SSFIFU team found all were satisfactorily addressed except the following which will be tracked as NRC unresolved items:
Large Motor overload Protection (Item 9, Page 8);
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l DC Systems Voltage Drop Control (Item 12, Page 9/10);
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AC Short Circuit Protection (Item 13, Page 10);
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Diesel Generator contactor Voltage (Item 15, Page 11);
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DC Safety Bus Cross-Tieing (Item 24, Page 13).
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Overall, the SSFI Follow-Up team found that corrective actions for the original items and issues had been, in all cases, at least i
started by Maine Yankee.
Many of the previous SSFI findings were fully corrected.
Licensee action on the remaining concerns are underway and, for all items and issues identified, appear to be appropriate.
The exception to this conclusion is the timing schedule for certain of the recalculations involving reliability of the DC buses, large AC motors, 4160 switchgear, and the l
potential operability concern for diesel generator multiple starts, Also, the 7-day administrative limit on cross-tie of the DC buses i
was, in the SSFIFU team's estimation, excessive.
Unresolved items were initiated for the remaining concerns listed above.
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2.0 BACKGROUND AND SCOPE In January 1989, NRC Region I performed a Safety System Functional Inspection (SSFI) of the Component Cooling Water (CCW) system at Maine Yankee.
There were an unspecified number of unresolved
" Items" and five weaknesses (Issues) identified in the SSFI Team Report, 50-309/89-80. Maine Yankee's corrective action planned for
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the five weaknesses, and the priority and schedule for commitments
made during the SSFI, were addressed in the licensee's letter of June 13, 1989 (MN-89-80).
The response specifically addressed the 5 NRC identified issues plus another three (3) issues Maine Yankee considered of major importance (Issues 6 through 8 in this report).
In addition, the response provided, in tabular form, descriptions, plans, completion schedules, and status / comments for 61 discrete
" Items" from the inspection report.
During the entrance meeting for this inspection, hereafter known as the SSFI Follow-up or SSFIFU team, the licensee provided a supplemental response, dated January 15, 1990, with additional and/or changed plans, completion schedules, and status / comments.
This report is organized similar to the original SSFI report, and only previously unresolved Items and Issues are addressed. The following details represent the team's evaluation of the licen-see's response to each original item (parenthetically identified by number).
3.0 MECHANICAL SYSTEMS l
l The original SSFI report documented concerns with the Component Cooling Water (CCW) system design with respect to the ability of the system to perform its safety function.
These mechanical concerns were in the areas of CCW design and performance (Items 2, 3,
51A, and 51B), calculation (Items 4 and 7),
operation and surveillance (Items 35, 49, 60, and 61).
The major mechanical system issues raised in NRC Inspection Report 50-309/89-80 were the ability to confirm CCW system capability (Issue 4).
Item 2 CCW System Heat Balance (Section 3.1.2)
The SSFI team was unable to determine the CCW system's ability to l
perform its design function.
Heat balance analyses provided by the licensee as verification of the CCW system's capability were either incomplete or used assumptions or inputs that could not be fully substantiated.
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The licensee has received updated heat balance analyses of the Primary CCW (PCC) and Secondary CCW (SCC) system from Stone &
Webster.
The SSFIFU team reviewed the updated heat balance analyses provided to show that the two CCW systems can perform their safety func-tions.
The computer model used was determined to be valid.
The team found the assumptions and inputs used (e.g., the various heat exchanger heat transfer coefficients) to be reasonable and well documented.
The heat balance study shows peak CCW system tempera-tures to be 117.3 F, given a service water temperature of 80 F.
This temperature is used because it is the highest Ultimate Heat Sink (UHS) temperature that the licensee had on record.
(This is 7 degrees higher than the licensee told the SSFI team and 10 degrees above the previous design basis analysis.)
The UHS is the
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direct source for the service water system.
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Stone & Webster is conducting an analysis evaluating the maximum allowable CCW temperature for each affected safety-related component.
Preliminary indications are that all safety-related components are adequately cooled up to a 122 F CCW system tempera-ture under all conditions.
At a122 F CCW system temperature, piping modifications would be required so that the emergency diesel generators can be adequately cooled under all conditions.
Maine Yankee has committed to testing during the April 1990 refueling outage to determine whether modifications are necessary.
Item 3 Residual Heat Removal (RNR) Heat Exchanger Performance (Section 3.1.2)
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The SSFI team could not find viable heat transfer coefficient data for the RHR heat exchangers.
The licensee has never verified RHR heat exchanger performance by direct testing.
The licensee is planning to investigate methods of monitoring and testing RHR and CCW heat exchanger performance during the April 1990 refueling outage.
No final resolution date was proposed.
The SSFIFU team requested that the licensee commit to properly testing the R:IR heat exchanger performance as noted in the original report, possibly as part of their response to NRC Generic Letter 89-13.
Upon completion of this testing, the results should be reviewed for possible effects on the overall CCW system heat transfer capability which in turn could affect the design capability of the CCW system.
Based of the licensee's commitment to perform this testing, and future inspection activity to confirm Generic Letter 89-13 implementation, this item is resolved.
Item 4 Trip Valve Air Accumulator capacity (Section 13.1.3)
The SSFI team found two of the assumptions used in the sizing of the backup air supply accumulator (Tank No. 110) for trip valves
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SCC-A-460 and SCC-A-461 were invalid.
The team was concerned that the accumulator capability was inadequate to perform its safety function (close valve and keep closed when required).
The trip valve accumulator design basis has been updated by the licensee and has incorporated revised assumptions.
The revised calculation shows that the accumulator system was capable of performing its function.
In addition, procedure AOP 2-36 was revised to manually close the SCC trip valves within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a valid automatic closure, and the accumulator low pressure alarm was reset to 92 psig.
The SSFIFU team reviewed the accumulator sizing calculation provided by the licensee and found it to be acceptable.
The analysis was thorough and logical in its methodology, assumptions, inputs, and conclusions.
In addition, the team agrees with the resetting of the accumulator low pressure alarm from 80 psig to a more conservative 92 psig.
The licensee reviewed the calculations and confirmed that setpoint tolerances were taken into account.
This item is, therefore, resolved.
Item 7 Isolation Valves calculations (Section 3.1.6)
The SSFI team learned that the intent of calculation EDCR 80-45-CAL-1 was to prove that the SCC isolation valves close in time to prevent a loss of cooling water inventory, leading to system failure, if there is a break in the non-safety-related portion of the SCC system.
This calculation did not consider the effects of thermal shrink and swell due to system heatup and cooldown during a design basis LOCA.
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The licensee received an updated calculation from Stone & Webster that does consider the effects of thermal shrink and swell in the SCC system during a LOCA.
The SSFIFU team reviewed the updated calculation and found that it does adequately show that the SCC valves' closure time adequately protects against a system failure due to a loss of cooling water inventory through a non-safety-related break in the SCC system.
The methodology and assumptions used were reasonable and logical, therefore, this item is resolved.
Item 35 Operating with One Service Water Train (Section 4.2.3)
The SSFI team found that during periods of high heat load and high service water temperatures, all four CCW heat exchangers may be in service.
Since the service water system divisions are normally cross-tied, it is possible that during a LOCA with a loss of off-site power, only one service water train would supply flow to all the CCW heat exchangers.
There is no analysis showing that the CCW system can perform its safety function during this situation.
This item is closely related to Item 8.
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The licensee changed the emergency procedures to isolate the idle train's CCW heat exchangers prior to a recirculation actuation signal (RAS).
The licensee performed an analysis of operating the CCW system with one service water train supplying flow to all four CCW heat exchangers.
The SSFITU team found the licensee's response adequate. A rigorous analysis of operating the CCW system with only one service water train operable should be performed.
However, the revision to the emergency procedures should prevent this situation from occurring.
The procedures now isolate the idle train's heat exchangers before RAS causes an increased CCW heat load, thus resolving this item.
Item 49 Flow Monitoring Equipment Training (section 6.2 and 7.6)
The SSFI team encountered a problem with the use of an ultrasonic flow measuring device to conduct a quarterly in-service test of service water pumps. Licensee personnel had incorrectly positioned
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the flow transducers, thus causing an erroneous flow indication.
It was later determined that licensee personnel had not been trained on this equipment.
The licensee utilized the manufacturer's representative to conduct training on the ultrasonic equipment for operators and maintenance workers.
The SSFIFU team found operating and maintenance instructions are now available with the equipment.
Training of all operations and maintenance personnel that use the monitoring equipment has been completed.
Therefore, this item is resolved.
Item 51A Design capability to Maintain 80:7 Tsolation Valves closed (NY Identified)
This issue is formally addressed in Item 4.
The ability of the
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SCC air accumulator (Tank 110) to hold the SCC isolation valves closed for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> could not be substantiated.
l In addition to the actions taken in response to Item 4,
the licensee changed Abnormal Operating Procedure (AOP) 2-36 to require i
the SCC isolation valves to be manually shut within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a valid automatic closure.
The SSFIFU team reviewed AOP 2-36 and found it adequate, in conjunction with the actions previously noted in Item 4, to resolve this item.
Item 51B SCC Trip Valve Design Correction (NY Identified)
Maine Yankee internal review of the SCC accumulator revealed that the accumulator tank does not have a drain valve.
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The licensee's supplemental response commits to installing a drain t
in the accumulator as an added measure to remove moisture from the system.
The instrument air system already uses desiccant dryers to maintain low moisture in the system.
The SSFIFU team found the addition of an accumulator drain valve adequate to resolve this item.
Items 60 and 61 Surveillance Procedure Stroke Time and Acceptance criteria (NY Identified)
The licensee identified problems with surveillance Procedure 3.1.20, Safeguards Valve Testing, in that no stroke time limits and acceptance criteria for the closure of valves SCC-A-460 and SCC-A-461 and for the verification of the system capability to maintain these valves shut for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The SSFI team report does
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not address this issue.
The licensee has changed Surveillance Procedure 3.1.20 to include the missing limits and criteria.
The SSFIFU team found these changes satisfactory and are in accord with the analysis completed in response to Item 4.
Thus, Items 60 and 61 are resolved.
Issue 4 Inability to support CCW system capability (Items 2, 3,
4, 7,
35, 51A, and 51B)
The SSFI team was unable to determine the CCW system's capability to perform its intended safety function because of questions regarding the effects of thermal shrink and swell, air accumulator capacity to isolate non-essential loads, performance testing of the RHR and the new CCW heat exchangers, and the lack of a complete CCW system heat balance.
The licensee performed analyses to verify the CCW system's capability to perform its design safety function.
The specific analyses were addressed in Items 2, 3,
4, and 7 of this report.
The SSFIFU team found that the licensee has satisfactorily documented that the CCW system can perform its safety function.
The analyses are thorough and use verifiable, up-to-date inputs and assumptions.
The team considers the recent analyses to be valid due in part to conservative assumptions of RHR and CCW heat exchanger heat transfer performance.
The manufacturer's design heat transfer coefficient for a clean RHR heat exchanger was used.
The design heat transfer coefficient for the CCW heat exchangers was appropriately degraded by a fouling factor.
The licensee committed to substantiate RHR and CCW heat exchanger design by performance testing.
The results of such testing will be the subject of Generic Letter 89-13 follow-up inspection, therefore this issue is resolve r I*
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ELECTRICAL SYSTEMS The original SSFI report documented concerns in the AC and DC j
system supporting the PCC/ SCC systems.
These concerns were in the
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areas of electrical calculations (Items 11, 13, 14, 15, and 19),
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equipment protection (Items 9,
10, 12), and system operation, maintenance, and testing (Items 17, 18, 23, 24, 30, 37, 38).
Major electrical issues raised in the report were vague Technical Specifications (Issue 2) and the basis for electrical protection (Issue 3).
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Itea 9 Overcurrent Protection for Large Motors (section 3.2.1.1)
f The SSFI team was concerned that motor time-current thermal curves did not exist for the large safety-related motors.
These curves are necessary to verify the correct selection of overcurrent relay settings.
The licensee's initial response stated that the development of an electrical setpoint manual would be scheduled by September 1,1989.
A supplemental response later stated that Maine Yankee has sched-uled development of this manual.
Orally, the licensee stated that the manual has been scheduled for completion by the end of the 1991 refueling outage.
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The SSFIFU team noted that Service Request M-89-135 was issued to YAEC to develop the motor overload protection manual.
This item, although primarily a reliability issue at this stage of understand-ing, will remain unresolved until the proposed setpoint manual confirms the adequacy of the protective devices on safety-related motors.
(UNR 50-309/90-80-01)
Item 10 Overload Relay Heaters Motor Operated Valves (MOVs)
(Section 3.2.1.3)
The SSFI team was concerned that other MOVs may have oversized
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heaters similar to those identified by Maine Yankee when the MOV actuator on PCC-M-219 was replaced.
The licensee's June 1989 response stated that a program was already in progress to recalculate overload heater sizes prior to the SSF1 and committed to have this program completed by the April 1990 j
refueling outage.
1 The SSFIFU team confirmed that selected motor-operated valves (MOVs)
had been previously reviewed in calculation MYC-979 (8/26/87) in response to IEB 85-03.
The results of calculation i
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MYC-979 indicated that all 20 MOVs reviewed had oversized overload heaters, and replacement was recommended.
The team selected a
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sample from those 20 MOVs and confirmed, from existing Maine Yankee walkdown data, that the heaters were replaced.
Expanding the study from the original 20 MOVs, Service Request M-87-149 was issued to YAEC.
This service request will address all remaining MOVs, both safety-related and non-safety-related, using the same methodology of calculation MYC-979.
This work is required to meet NRC Generic Letter 89-10 and is scheduled for completion during the April 1990 refueling outage.
The team agreed with the method used in MYC-979 and was satisfied that the recommendations were implemented, and therefore considers this item resolved.
Iten 11 Calculations for New Battery (Sections 3. 2. 2.1, 3. 2. 3. 2,
and 3.2.4.1.a)
The SSFI team was concerned that the DC short circuit calculation for the battery sizing calculations had not been updated to be consistent with the new battery arrangement.
The licensee's initial response indicated that the short circuit calculation (E-1) and the battery sizing calculation (MYC-104)
would be revised by 12/31/89.
The SSFIFU team confirmed that both calculation E-1 (R5, 8/19/89)
and MYC-104 (R2, 6/29/89) had been updated.
The team confirmed that calculation MYC-104 was updated to include the latest manufacturer's data for the 59-cell battery arrangement.
However, the team questioned assumption 2 to calculation E-1, which gave an empirical relationship between battery short circuit current and 9 times the 1-minute rate to 1.78 volts / cell (1540 A) and sug-
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gested that the rate to 1.75 volts / cell (1800 A) should have been used.
In response, YAEC stated that, if additional cable is added to increase the circuit resistance, margin in the calculated
required length would be included to account for uncertainties in I
the short circuit methodology.
The team found this YAEC response l
acceptable.
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The original SSFI Report (Section 3.2.3.2) questioned the effect of DC voltage on inverter current.
YAEC stated that 25% margin had been added to the inverter load, and that additional voltage studies would be performed if this margin were to be subsequently reduced, resolving the discrepancy of battery sizing calculations.
Item 12 DC Fault Current Breaker Ratings (Section 3.2.2.1)
The SSFI team was concerned that the available fault current at the DC buses was above the interrupting ratings of the DC breakers.
The licensee's initial June 1989 response acknowledged that the problem existed and committed to develop the required calculations and define required (cable)
modifications by the April 1990 refueling outage.
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The revised January 1990 Maine Yankee response changed the j
scheduled completion date to the 1991 refueling outage, with the
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additional time required in order to determine the effect of the additional cable resistance on equipment voltage.
The SSFIFU team expressed concern for available DC voltage margin, in that YAEC documented in calculation MYP-89-808 (August 18, 1989)
that the effect of adding cable resistance between the battery and DC bus would increase the voltage drop from 1.0 to 2.0 volts during the emergency discharge.
It appears that YAEC was not able to evaluate this effect because the voltage margin available at the safety-related DC loads at Maine Yankee is unknown and must be calculated.
The lack of a DC voltage analysis was mentioned in the original SSFI report. Maine Yankee's corrective action (Service Request 89-62) was combined with the response to NRC Information Notice 89-16, " Excessive Voltage Drop in DC Systems."
This item will remain unresolved, pending resolution of DC short circuit concerns.
[UNR 50-309/90-80-02)
Item 13 AC Short Circuit Protection for 4160-kV Voltage System (Section 3.2.2.2)
The SSFI team found the original Maine Yankee minimum voltage switchgear short circuit calculation study, E-5, Revision 2,
indicated that the 4360-volt circuit breakers had marginal interrupting capability.
The team was concerned that calculation
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E-5 assumed that the 345-kV system operated at 1.0 per unit voltage (i.e., 345 1 0 kV).
System voltage affects fault current and the circuit breaker interrupting rating.
The team had confirmed that the system voltage normally operates at 350 kV and could range up
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to 362 kV.
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l The licensee's initial response committed to include system voltage variations in the short circuit study.
The completion date was l
January 1,
1990.
The revised response changed the scheduled l
completion date to June 30, 1990.
This issue remains unresolved, pending resolution of the available AC short circuit currents at the safety-related switchgear.
[UNR 50-309/90-80-03)
l Item 14 Diesel Generator Recovery Voltage (Section 3.2.3.1)
The SSFI team was concerned that the diesel generator (DG) recovery voltage curve (ACD 67-71) was obtained from the manufacturer's proposal data and not supported by any specific test data for the Maine Yankee units.
The licensee's initial response stated that the manufacturer GM's Electro-Motive Division (EMD) would be contacted by 9/30/89 to evaluate the adequacy of the DG recovery voltage curves.
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revised response rescheduled the completion date to January 31, 1990. The SSFIFU team confirmed that the manufacturer's representa-tive, Morrison-Knudsen (MK), was contacted.
MK letter of December 18, 1989 confirmed that the recovery voltage curve being used at Maine Yankee is applicable for all generators / excitors of the 999 EMD diesel generator system at Maine Yankee.
Item 15 Diesel Generator Multiple Starts and Thermal Overload Protection (section 3.2.3.1)
The SSFI team was concerned that the results of calculation MY-107 indicated that the step loading of the diesel generator could result in the motor starter contactors on the MCCs deenergizing and being reenergized with each step. The resultant effect of multiple starts on individual Motor Control Center (MCC) loads and the effect on the selection of thermal overload protection had not been evaluated.
In their responses, Maine Yankee stated that they did not believe that the contactors would respond to the brief voltage dips.
However, they committed to formally review this item during the next calculation revision, which is scheduled for completion by December 31, 1991.
The SSFIFU team remains concerned that Maine Yankee has not pursued this potential operability concern.
If they do not believe the contactors will drop out on a voltage dip to 57.5% at the generator terminal, and therefore below the standard rating for magnetically held contactors, a simple test could confirm the limits for contac-tor minimum voltage.
This will remain an unresolved item, pending resolution of these concerns.
(UNR 50-309/90-80-04)
Item 17 Batteries
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Discharge Rate Testing (Section l
3.2.4.1.c)
l The SSFI team was concerned that when Batteries 2 and 4 were replaced, the acceptance test and the initial performance test used the incorrect (2.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) discharge rate in place of the higher 2-hour rate.
This item is related to Item 53.
The licensee's response stated that the test data obtained from the original manufacturer's and Maine Yankee tests would be L
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reevaluated.
The Maine Yankee response committed to revise the performance test procedures, l
The SSFIFU team confirmed that the manufacturer (C&D Batteries)
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evaluated the previous test data and correctly concluded that, in l
both cases, the tests demonstrated that batteries 2 and 4 had at
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least 100% capacity.
The team also confirmed that the test procedure (procedure 3.5.3, Section 5.2.3.c.2), was in the process of being revised to change the test current from 161 amperes to 187 i
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amperes.
Based on the planned revision of the test procedure, this item is resolved.
j Item 18 Numbering Systems for Maine Yankee Equipment (Section l
3.2.4.2)
The SSFI team noted in the report that the equipment numbering
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system used at Maine Yankee (for valve numbers) was different than that used on the electrical schematics.
In their response, Maine Yankee stated that their review concluded that both systems are beneficial to Maine Yankee and would continue to be used.
The SSFIFU team was unable to identify any examples of problems experienced by Maine Yankee that could be attributed to having two numbering systems.
A cross reference and two sets of P& ids with the two numbering systems exist as an aid for operators.
This item is resolved.
Item 19 Document Control of Calculations (Section 3.2.4.3)
The SSFI team obtained two copies of the same electrical calcula-tion from YAEC and the plant that were different; the plant version being 6 years out of date.
The Maine Yankee document control center did not maintain copies of the "MYC" series calculations, and did not have a index of these calculations.
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The licensee's corrective action was to issue Service Request No.
M-89-40, Maine Yankee Calculation Index.
Arrangements have been made to forward updated copies of this index to the plant on a monthly basis.
The SSFIFU team had no further questions regarding this item, and, therefore, it is resolved.
Item 23 Battery Operability Requirements (Section 3.2.5.1)
The SSFI team's concern was that Technical Specification 3.12 had been interpreted by Maine Yankee to permit both batteries to be taken out of service when the plant was below 210 F and 400 psig.
The Maine Yankee June 1989 response stated that procedures would be revised to ensure that whenever an RHR system was required to be operable, its respective DC system would also be in service.
l The SSFIFU team confirmed that procedure 1-7-2 was revised on 10/19/89.
Attachment B,
Cold Shutdown Technical Specification checklist, addresses battery operability whenever there is fuel in the reactor.
The team also confirmed that procedure OP-1-22-2, Revision 10, Section 5.5.2 requires that whenever an RHR system is required, its respective DC bus will be in service.
This item was resoled.
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Item 24 Plant Operation with DC Bus Cross-tied (section 3.2.5.2)
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The SSFI team was concerned that no restrictions were placed on the length of time that the two DC safety-related buses could be tied together.
The licensee committed that they would control the amount of time that the buses could be tied together to 7 days based on the Technical Specification for loss of a DC bus.
The SSFIFU team confirmed that Procedure 1-22-2, Revision 10, was revised to limit cross-connecting buses 1 and 3 for a maximum of 7 days whenever the plant is in condition 6 or above.
However, when the cross-tie is closed, both redundant buses are tied together and redundancy of all safety systems requiring DC power is lost.
The team took the position that these buses never be cross-tied, and stated that 7 days is excessive considering the loss of redundancy.
(NRC Standard Technical Specifications permit operation following loss of a DC bus for only 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.)
At the end of the inspection, Maine Yankee informed the team that a spare inverter and a spare battery charger would be installed and wired to eliminate the need to tie two redundant buses together.
Preliminary work is expected to be in place during the 1990 outage, permitting completion of this modification prior to the 1991 outage.
Upon completion of this modification, Procedure 1-22-2 will again be revised to eliminate the option of operating the plant with redundant buses cross-tied.
This item will remain unresolved, pending completion of the modification and procedure revision.
(UNR 50-309/90-80-05)
Item 30 Motor-operated Valve Wiring (Section 3.3.6)
The SSFI team found that Maine Yankee has the generic industry MOV problems similar to those of older plants.
One of the main MOV failure modes is caused by a design inadequacy of the older two-rotor control assembly MOVs.
There are at least three critical switch settings needed for each MOV.
When only two switches are available, the closed limit switch function is set on one rotor and the opening torque bypass and open limit switch functions are set on the other rotor.
While this is acceptable for valves where the safe position is closed, valves which open on a safety signal will indicate open when the torque bypass switch operates, typically only 15% open.
Thus a valve needed to be open for safety may torque out above 15% and not indicate its position in the control room.
The torque and limit switch issue has been covered in vendor, industry, and NRC notices and is one of the issues ad-dressed in Generic Letter 89-10.
The above issue was the concern with PCC-M-219, PCC flow isolation to containment loads.
The MOV for this valve had been replaced
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with a four-rotor control assembly, but wired as a two-rotor control assembly.
The SSFIFU team discussed the Maine Yankee detailed MOV improvement project with the lead engineer and reviewed this program.
There are 119 MOVs in the plant, about 63 of which are important to a
safety.
The licensee plans to complete the Generic Letter requirements by the November 15, 1991 due date.
They are scheduled to inspect, modify, and test 26 MOVs during the April 1990 outage.
The work will be done using Procedures 5-18-1 through 6.
The inspector noted that these procedures are being reviewed / revised at this time.
Since the required MOV program is ongoing and has
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received other NRC inspection (IR 50-309/88-04 on Bulletin 85-03 MOV Common Mode Failure), Item 30 is resolved.
Item 37 Preventive Maintenance (PM)
for Batteries
and
(Sections 5.1.b and 5.1.c)
The SSFI team was concerned that the preventive maintenance (PM)
program did not appear to have been updated for the new battery requirenents in that no torque check for terminal connections was required.
Torque requirements for the new batteries are found in PM E-5-Q-D.
The SSFIFU team reviewed Preventive Maintenance Card E-5-Q-D and confirmed that it included a 125 in/lb torque requirements for all the safety-related batteries. The team also confirmed that the post-design was the same for the terminals of both types of cells.
Item 38 Battery Equalisation Time Requirement (Section 5.1.c)
The SSFI team was concerned that the PM program had not been updated to include the changes in equalizing charge requirements for the new lead-calcium batteries.
Procedure Change Request 88-256 was issued December 55, 1980 to revise Surveillance Procedure 3.5.14 and Battery PM E-5-A-A had been revised to correct the equalizing charge for batteries 2 and 4.
The SSFIFU team confirmed that Revision 4 of Procedure 3.5.14 (March 7, 1989) includes the correct equalizing times.
The team also confirmed that PM card E-5-A-A refers to Procedure 3.5.14 for the correct equalizing charge.
Issue 2 Vague Technical Specifications (Items 15, 23, and 24)
The SSFI team found the Maine Yankee Technical Specifications (TS)
for the DC system did not address the ability to cross-tie direct current buses 1 and 3, allowing a common mode failure to render both diesel generators inoperable.
The TS also permitted removal of all DC buses from service when the plant was in cold shutdown.
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i The licensee stated that the capability to tie the redundant buses together was necessary for those times when immediate maintenance was required on a battery or battery charger.
The licensee revised the appropriate normal and abnormal operating procedures to limit the existence of this condition to 7 days.
The licensee also stated that it has not been their practice to remove all DC buses i
from service, but they would nevertheless revise their operating procedures to require that a DC bus be operable whenever its associated RHR system was required to be operable.
i At the end of the SSFIFU team inspection, plans were underway to
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install a spare inverter and battery charger, and eliminate the need for ties between redundant buses.
The team agreed with the proposed design modifications and temporary procedure changes, although the 7 day limit was judged to be excessive.
Closure of this concern will be tracked along with Item 24.
Issue 3 Electrical Short Circuit Protection (Items 12 and 13)
The SSFI team questioned the short circuit protection on the DC buses after the DC short circuit calculation was found not to address the new batteries, battery temperature, or the maximum interrupting capability of the DC circuit breakers.
The team also questioned the basis for the selection of AC motor thermal protection for the larger safety-related 4000-volt motors.
The licensee confirmed-the errors in the DC short circuit calcula-tion and revised that calculation, considering this a reliability problem, not an operability problem.
The licensee also believes that the 4000-volt motor protection philosophy used at Maine Yankee is based on industry standards and good judgment, and that the original setpoints were selected by the original ar4hitect engineer after consideration was given to motor thermal damage curven.
The SSFIFU team agrees that, in all probability, the overload relay setpoints selected for the CCW pump motors will adequately protect the motor, but this conclusion is only based on the team's exper-ience and engineering judgment.
The motor thermal damage curves referred to in the original response were never found by the t
licensee.
To correct this, Maine Yankee plans to establish a motor overload protection setpoint manual.
These concerns remain, pending resolution of Items 9 (Page 8) and 12 (Page 9/10), and will be tracked by UNRs 50-309/90-80-01 and 02.
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5.0 OPERATIONAL AND NAINTENANCE ISSUES The original SSFI report documented concerns in the operations and maintenance areas supporting the PCC/ SCC systems.
These concerns were in the areas of procedural adequacy (Items 21, 22, 34, 43, 56, and 57) and operation and equipment maintenance (Items 6, 40, 41, 42, and 58).
The major operational and maintenance issue raised in the report
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were the critical valve preventive maintenance in support CCW system capability (Issue 7) and check valve surveillance testing (Issue 8).
Item 6 Performance Testing of Primary CCW Valves (Section 3.1.5)
The SSFI team was concerned about the operability of CCW system
check valves, such as PCC 445, 446, 508, and 509, that do not routinely operate (close), but must close during accident condi-tions.
In order to confirm operability of this type of check valve, functional testing is necessary.
The licensee's supplemental response states that the IST program is being reviewed and is currently scheduled to be revised by the 1990 refueling outage.
The valves in question (PCC 445, 446, 508, and 509) as well as the valves addressed in Item 43 (PCC 72 and SCC 4) will be included in this revision.
l The SSFIFU team found that the valves in question have been incor-porated into the In-Service Testing (IST) program.
Only valves PCC-72 and SCC-4 however, can be tested during operation and have been scheduled for quarterly terting, the first of which should take place prior to January 31, 1990.
PCC-445, 446, 508, and 509 i
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cannot be tested during operation without plant modification and are scheduled for disassembly and inspection during the April 1990 refueling outage and for testing upon return to service.
PCC-445 and 446 will be tested in conjunction with system operability verification.
PCC-508 and 509 cannot be operability tested and are, therefore, scheduled for disassembly and inspection, only.
The team also reviewed the licensee's response to NRC Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs, in order to determine that the licensee had reviewed their IST program to assure that components which perform safety functions were included in the program.
Changes to the program, l
procedures, and physical plant backfits necessary to conform with L
GL 89-04 were identified and plant modifications are being evaluat-e d.-
Determination that the subject valves are in the IST program is adequate to assure that they are tested for their ability to function.
Based on the licensee's response to GL 89-04, adequate assurance exists that the evaluation of required plant modifica-tions and their implementation will be completed.
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Item 21 Low Voltage Alarm Procedures (Section 3.2.4.5.a)
The SSFI team identified a minor discrepancy existed between the Electrical Training Document PGS-18 and the Abnormal Operating Alarm Response Procedure (AOP), in that the DC low voltage alarms at 120 volts according to AOP 2-36, while PGS-18 states 115 volts.
The licensee stated that the AOPs govern plant operation. Training manuals are updated periodically but a disclaimer in the manual states that the manuals are not to be used to operate the plant.
Comparison of PGS-18 and AOP 2-36 by the SSFIFU team found that the licensee had revised PGS-18 to indicate the proper low voltage alarm setpoint of 120 volt DC, therefore making AOP and PGS-18 consistent.
Additionally, Maine Yankee updates the training manuals periodically, thus assuring that the smount of incorrect information relayed to the students is kept to a minimum.
Item 22 CCW Motor Overloads Alarm Response (Section 3.2.4.5.b)
The SSFI team determined that a minor discrepancy existed in that the Stone and Webster 4000-volt motor protective device setpoint guidance explicitly identifies the need to manually shut down the component cooling pumps on motor overload as soon as possible, but the alarm response procedures that address 4000-volt motor overloads fail to identify any specific action applicable to the component cooling pump motors, nor do they indicate any special concern without overloads on these motors.
The licensee stated that Panalarm AOP 2-37 was reviewed and found that while there is not a specific response unique to each of the 23 4160 V motors, there is a specific response to a motor trip, overcurrent, or thermal overload condition for any 4160 V motor.
Maine Yankee believes this is appropriate and does not plan any further action on this item.
The SSFIFU team determined that AOP 2-37 addresses motor thermal overloads and initial operator actions for 4160 volt motors which includes PCC and SCC pump motors.
However, these actions only result in a reduction of load on the affected motors and do not require an immediate trip of the motors.
The team noted that the licensee has not determined whether or not the PCC and SCC pump motors require a different response than the other 4-kv motors due to the Stone and Webster guidance.
The team stated that the licensee should evaluate whether or not these motors require a different response, and, if so, a subsequent alarm response procedure change should be acccmplished to reflect this.
The licensee committed to perform this evaluation, therefore, reasonable assurance exists that this evaluation and any required action will be performed, and therefore, this item is resolved.
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Item 34 surge Tank High Level operator Guidance (section 4.2.2)
Weaknesses were noted by the SSFI team in panalarm responses and subsequent Abnormal Operating Procedure (AOP)
direction with respect to the identification and isolation of a PCC or SCC high surge tank level alarm resultant from in-leakage.
The PCC and SCC surge tank high level panalarm response procedures failed to develop specific instructions to identify sources of system in-leakage.
Alarm response procedures should provide instruction to promptly identify PCC system in-leakage from the Reactor Coolant Pump (RCP).
The licensee revised AOP 2-10, 2-25, and 2-36 to provide more specific guidance for radiation monitor response and Reactor Coolant System (RCS) in-leakage.
The SSFIFU team determined that changes made to AOPs 2-10, and 2-25 provide specific guidance to identify sources of in-leakage to PCC which includes leakage from the reactor coolant pump based on a return flow alarm and increasing PCC surge tank level.
AOP 2-36 also specifies that individual components should be isolated to determine in-leakage points for both PCC and SCC.
Supplemental action statements for operator action are included.
Based upon the above procedure changes, this item in resolved.
Item 40 Dusty control Room Panels (section 5.3)
The SSFI team found a layer of dust in the back of the control room panels.
It was determined that a panel cleaning program doesn't exist and that the panels were cleaned in 1986 because of a maintenance identified dust problem.
The team further determined that the " Low Voltage Electrical Distribution Closecut Plan" action items to develop and implement a control room panel cleaning program has not been done.
The licensee plans to develop a PM activity to clean the inside of the main control board during refueling outages.
The SSFIFU team determined that the licensee has tasked individuals with developing a preventive maintenance cleaning program which includes the back of the main control panels; no cleaning has been performed to date.
Scheduled completion of this program is planned for the April 1990 refueling outage and for subsequent refueling outages.
Visual inspection by the team verified that a layer of dust on the components and dirt / foreign materials on the floor still exists.
However, the team did not consider this a current safety problem.
Based upon the supplemental response commitment to develop a program and periodically clean the main control panels and entering this into the licensee's commitment management system for tracking, this item is resolved.
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Item 41 Control Room Panel Ventilation (Section 5.3)
The SSFI team suggested an evaluation be made to determine the need for inlet air filters on the Main Control Board (MCB) doors.
l The licensee evaluation for placing inlet filters on the MCB doors determined that the filters may not be necessary following place-ment of carpet on the Control Room floor.
The carpet was in-stalled 1989.
The carpet eliminates the need to strip wax from the floor, preventing dust like particles of wax from becoming air-borne.
However, the licensee has committed to monitor the dust buildup following a thorough cleaning during the April 1990 refuel-ing outage to determine if additional modifications will be
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required.
Filters can be designed, fabricated, and installed on the screened access doors into the MCB enclosures if necessary.
The SSFIFU team concluded that the monitoring control room dust commitment is adequate to close Item 41.
Item 42 Control Room Panel Terminated Leads and Unidentified Wires (section 5.3)
The SSFI team found several improperly terminated and unidentified leads in the back of the main control room panels.
Specific discrepancies observed by the team were: Panel
"A" had 4 leads hanging out approximately 8 inches: Panel
"B" has a pull tape hanging loose from overhead and an old audible annunciator alarm wire hanging from the overhead at the rear wall, two wires of a
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FEMCO connection were cut and unidentified; and two wires marked spare ICS 36 and ICS 38 were hanging loose:
Panel
"C" had one loose 1/2 foot wire that was unmarked and improperly terminated.
On the back wall, two wires were improperly terminatedt one was identified the other wasn't. These inappropriate terminations were not in accordance with the Maine Yankee Wire and Cable installa-tion / Removal Standard MYSTD-ELEC-1
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The licensee stated that the specific discrepancies were corrected.
Other similar deficiencies will be detected and corrected during walkdowns of control room electrical circuits previously planned.
A walkdown of the control room back panels by the SSFIFU team determined that the previously identified improper terminations had been corrected. However, the team noted other improperly terminat-ed unmarked wire in Panel
"C" and several loose pull strings in the back panels.
Maine Yankee has generated a field verification procedure to assure that instrument loop / main control board wiring is verified as shown on drawings.
This process should allow the
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proper termination and marking or removal of presently unmarked leads in the MCB during the 1990 refueling outage.
Based upon completion of the above actions, Item 42 is resolved.
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Item 43 Preventative Maintenance (PM) for CCW Isolation Valves (Section 5.4.1)
t The SSFI team determined that there was an inconsistency in the PM Program between gland leakoff collection tank check valves PCC-72 and SCC-4.
Valve PCC-72 is included in the program and has a PM action to disassemble, inspect and repair every 5 years.
Valve SCC-4, a similar valve, does not have a PM requirement.
The licensee agreed to achieve consistency in the maintenance of these valves.
The licensee evaluated PM Program requirements for both check valves, then deleted the PM since no reason for it was found. The PM Program had been revised to provide better tracking of additions and deletions to the programt but both of the subject valves were l
to have been included in the IST Program.
(This item is closely related to Item 6.)
The SSFIFU team discussed the rationale behind the removal of PCC-72 from the PM program with the Plant Engineering Department to ascertain that appropriate action was taken in determining that PCC-72 should be removed.
It appears that the licensee's actions were appropriate and justified based on the valve's previous history of service, size and function.
Additionally, PCC-72 and SCC-4 were added to the IST program and are scheduled for a
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quarterly operational surveillance.
This surveillance should detect any deterioration of these valves and provide the assurance that these valves remain capable of performing their intended function.
This item is, therefore, resolved.
Item 56 Procedures for PCC/ SCC Ph Range (MY Identified)
The licensee identified, during the SSFI team inspection, that the Inputs and Assumptions Source Document (IASD)
and Operatiens Procedure 1-15-1 are inconsistent for the PCC/ SCC normal pH range.
The licensee stated that the PCC/ SCC range stated in the IASD was changed to agree with operations procedure 1-15-1.
The SSFIFU team verified that the appropriate changes to pH were made and the IASD and Ops procedure 1-15-1 are now consistent, and therefore, this item was then resolved.
Item 57 PM Sheets for SCC Heat Exchanger Outlet Temperatures (NY Identified)
The licensee noted, during the SSFI team inspection, that the IASD and the Instrument and Control (I&C) Preventive Maintenance (PM)
sheets are inconsistant for SCC heat exchanger outlet temperature.
The licensee stated that the appropriate correction from 87.5 to 89 F has been made to the IASD.
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The SSFIFU team verified that the high SCC heat exchanger outlet temperature alarm is at 89 degrees Fahrenheit in the IASO, which is consistent with the I&C Preventive Maintenance Activity Form.
This item is resolved.
Item 58 ESF Control Panel Temperature Monitoring (NY Identified)
During the SSFI, the licensee identified the concern that no data is available on the existing temperature inside the Engineering Safeguards Features (ESP) control room panels A and B.
The licensee's corrective action was to embark on an improvement program to replace 12 Sigma outmoded and heat generating indicators and/or controllers. These instruments-cause small temperature rise within each indicator and an overall temperature increase in the A and B panels.
The SSFIFU team reviewed Engineering Design Change Request (EDCR)89-600, Replacement of HELB SIGMA Meters, and a 9-page Design Verification Documentation Sheet that provides for functional testing to be added to EDCR 89-600.
This information was found to be complete, therefore, the item is resolved.
Issue 7 Critical Valve Preventive Maintenance (Item 43)
The SSFI team concern was inconsistencies in the Preventive
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Maintenance (PM)
requirements for certain CCW valves, in that similar valves were not being consistently maintained.
This is the issue reviewed under Item 43.
The licensee responded that investigation into the PM Program and history files did not identify any recurring operational problem with PCC-72 nor any identified problems with SCC-4.
The reason why PCC-72 was placed on a five-year PM could not be identified.
I Consistency was achieved with the two valves by removing PCC-72 l
from the PM program while the NRC team was on-site.
These valves were reviewed for incorporation in Maine Yankee's IST program, as discussed under Issue 8.
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As a result of investigating this issue, Maine Yankee revised l
Procedure 5-207-6, Maintenance Department Administration of The Preventive Maintenance Program, to require formally documenting, approving, and retaining Preventive Maintenance program changes.
As discussed in Item 43, the SSFIFU team discussed the rationale behind the removal of PCC-72 from the PM program, found the licensee's actions to be appropriate and justified, and confirmed that PCC-72 and SCC-4 were added to the IST program scheduled for quarterly operational surveillance.
These actions should detect any deterioration of these valves and provide the assurance that
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these valves remain capable of performing their intended function.
This issue is resolved.
Issue 3 Check Valve surveillance Testing Program (Item 6)
This SSFI team concern was that the surveillance testing program was generally adequate, but several check valves were found that
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should have been included in the In-Service Testing Program.
The licensee response was the Inservice Testing (IST) Program is currently scheduled to be revised by the 1990 refueling outage.
The valves in question (PCC-445, 446, 508, and 509) as well as the valves addressed in the forgoing issue (PCC-72 and SCC-4) will be included in this revision.
This issue parallels Item 6.
The SSFIFU team's review showed that the valves in question have been incorporated into the IST program, the licensee's response to
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NRC Generic Letter 89-04 (Guidance on Developing Acceptable
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Inservice Testing Programs), determined that the licensee had reviewed their IST program to assure that components which perform safety functions were included in the program, and that changes to the program, procedures, and physical plant backfits necessary to l
conform with GL 89-04 were identified and plant modifications are being evaluated.
The team determined that inclusion of these valves in the IST program adequately assure that they are tested for their ability to function.
Based on the licensee's response to GL 89-04, the team closed Item 6 and, therefore, Issue 8 is also resolved.
6.0 special Program Issues The original SSFI report documented concerns of a special program type supporting the PCC/ SCC systems.
These concerns were in the areas of equipment design and control (Items 1, 5, 28, and 55) and special safety programs (Items 20, 25, 26, 27, 29, 46, and 52).
The major special program issue raised in the report was the composite safety perspective in support of CCW system capability (Issue 1).
Item 1 MOVs Equipped with Reach Rod Assemblies (Section 3.1.1, 3.1.4, 3.3.6, and 5.4.3)
This SSFI team concern dealt with MOVs PCC-M-43 and SCC-M-65, equipped with reach rod assemblies, had undergone repetitive failures in the valve opening cycle.
The design deficiencies addressed were: 1) the reach rod exceeding the slenderness ratio; and, 2) questionable operator to valve mismatch due to the omission of accounting for the additional losses in torque transmission.
These valves have a chronic history of failures and do not demon-
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strate consistent motor torque readings during testing.
There are 13 MOVS with reach rods and the above referenced two valves had the most failures.
The licensee's immediate solution to the above problem was to modify the circuit such that the valve will close on the limit switch control rather than the torque switch control.
This approach makes the maximum torque from the motor available for valve closing.
Another modification was to instell mid-span bearing guides to reduce the deflection of the reach rod.
This reduction in reach rod deflection should reduce the torque trans-mission losses.
These modifications were installed through DR 3158-89 and DR 3157-89.
In the forthcoming refueling outage, the licensee plans to perform some additional testing to quantify the torque transmission efficiency and reevaluate the size of the operator.
The SSFIFU team concluded that the above program will further improve the reliability of the MOVs.
Recently, the performance of MOVs have been a subject of NRC attention.
Generic Letter 89-10, addressing this subject requested licensees to respond with a program for improving MOV reliability. Therefore, this activity will be addressed in future inspections as licensee's plans in response to the Generic Letter 89-10 are evaluated.
This item is resolved.
Itsa 5 Control of MOV Reach Rod Assembly Parts (Section 3.2.4.4)
The SSFI team found that the MOVs equipped with reach rod assemblies had a history of repeated failures at the universal coupling roll pins.
The licensee subsequently developed an acceptable pin for the particular use. The SSFI team was concerned about retrieving this information for future procurement and valve modifications.
Based on the above concern, the licensee has generated a new drawing SCC-M-165, PCC-M-43/1150-6.56-13 for the reach rod assembly.
The SSFIFU team found that this drawing specifies the various parts necessary for maintaining the integrity of the assembly. This item is, therefore, resolved.
Item 20 Electrical Load Tracking (Section 3.2.4.4)
l This SSFI team was concerned with the absence of a formal program I
to track the electrical load changes for non safety related equip-l ment.
The Yankee Atomic Engineering Company (YAEC), responsible j
for maintaining the electrical calculations, was not on distribu-l tion for the load changes that were not done through Engineering Document Change Requests (EDOR).
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The licensee's corrective action was to revise Procedure No.17-226, Technical Evaluation, strengthening control of this type of j
change.
The SSFIFU team reviewed this procedure and found it currently has an attachment to notify YAEC of any electrical changes by marking i
electrical system manuals as an affected document. These changes are then forwarded to YAEC for action.
The team considers these changes appropriate, and therefore this item is resolved.
Item 25 Setpoint Bases And Documentation (Section 3.3.1)
The original SSFI team found considerable conflicting information in the bases for setpoints. The team had expressed concerns about:
1) the way certain inputs were addressed; 2) the error effect from input to output; 3) determination of dependant or independent variables; 4) the data base for analyzing the distribution of the sampled variables; and 5) the method of calibrating a loop.
The licensee's response presented the following multi-phase program to address this concern; their supplemental response provided new completion dates.
Develop a setpoint bases document which Phase 1
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address the guidelines for identifying all class 1E setpoints by April 1, 1990.
Implement a setpoint control program for the Phase 2
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basis document by April 1, 1990.
Implement appropriate procedural controls for Phase 3
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change of setpoints: this is completed.
Implement a setpoint control program for Phase 4
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Revise calibration procedures to agree with Phase 5
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loop accuracy calculations by December 31, 1991.
The SSFIFU team reviewed the licensee's progress to date on these programs.
The guidelines for Phases 1 and 2 utilized the recom-mendations of the current version of Regulatory Guide 1.105, Instrument Setpoints for Safety-Related Systems, Revision 2 (to which the licensee is not formally committed) and the Instrument Society of America Standard (ISA) SP.67.15, Methodologies for the Determination of Setpoints of Nuclear Safety Related Instrumenta-tion.
In order to control and better document the changes to the setpoints (Phases 3 and 4) the licensee has implemented changes to Maintenance Procedure No.
6-07-1, Instrumentation and Control Corrective Maintenance, requiring engineering evaluation for setpoint control.
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l The SSFIFU team found that the Phase 1 and 2 calculational programs were in the developmental stage.
The Phase 5 individual calibra-tion procedure revision scheduled have been delayed until December 31,1991.
The team expressed concerns regarding the two-year duration for the final corrective action implementation, however, it endorsed the prompt evaluation based on immediately available data on inaccuracies such as instrument drift and accuracy, test instrument accuracy etc., to address any significant differences in design margin (target setpoints and safety analysis assumptions)
between the newly-calculated setpoints and the current setpoints.
Maine Yankee stated that this program is a voluntary upgrade of their setpoint control methodology and that there are no known deficiencies with the present program.
They provided a Setpoint Open Item Resolution Flowchart that includes a commitment to review calculation results after management approval of the calculations.
This review process appears to alleviate the team's concern, but since no licensee review had been performed ahead of the SSFIFU inspection, no specific evaluation by the team was possible.
The team concluded that, while different numerical values of total instrument channel uncertainty may be subsequently calculated as part of the licensee's ongoing initiative to use Regulatory Guide 1.105 methodology, currently calculated margins between safety analysis assumptions and as-left field settings were still valid (and in fact part of the existing approved design basis for Maine Yankee).
The team was confident that the existing instrument setpoint review process was sufficiently structured so as to evaluate any new substantially different uncertainty margins found via the new methodology.
NRC review of the licensee's revised setpoint control program will be confirmed under the normal ongoing inspection program.
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Item 26 Loop Calibration Technique (Section 3.3.2)
The SSFI team was concerned with the I & C practice of calibrating instrument components serially instead of calibrating it as a loop or overlapping segments. The present licensee practice of calibra-ting isolated segments, renders greater calibration errors, does not test the interfaces, and does not allow for compensating cyclical deviation.
The licensee has developed a multi-phase program to address this concern.
See item 25 for the proposed long term corrective j
actions.
Item 27 As Found Calibration Discrepancies (Section 3.3.3)
This SSFI finding deals with the lack of evaluation of the as found data collected during the Preventive Maintenance work performed by the Instrumentation & Control (I & C) department.
The NRC review
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of the I & C activities in 1989 revealed repetitive deviations that were not attended to for corrective action.
In response to the above concern, the licensee developed Procedure No.
6-03-4.2, Instrumentation & Controls Preventive Maintenance Activity.
This procedure, currently in draft, requires the I & C supervisor to review the as found data in accordance with Instru-mentation & Controls Department Performance Assessment Program, PAM-8.
Although this procedure specifies the criteria for evalua-tion, it does not address the need for evaluating the data for operability /reportability for the deficient condition.
The SSFIFU team interviewed one of the I & C supervisor and he stated that any as found condition outside the acceptance criteria is discussed with the shift supervisor for operability determina-tions. The team had no further questions; this item ic resolved.
Item 28 Containment Pressure Transmitter Range (Section 3.3.4)
The SSFI team found that the containment pressure instrumentation did not fully comply with Regulatory Guide (RG) 1.97 requirements.
This team found that YA calculation MYC 948 (approved September 26, 1988) suggested that the present control room indicator for pres-sure transmitter channel PT-2012 could be inaccurate by as much as 18.11 psi under normal operating conditions, and by as much as 111.37 psi under LOCA conditions.
This team concluded that the use of a single instrument with an extended range contributes, in large part, to the unacceptable loss of sensitivity and accuracy where the instrument is most needed.
A more recent draft YA calculation, MYC-1168, reported: " Based on a calculated NCU (normal channel uncertainty) of +3.08 psia, -3.58 psia, the Containment Pressure Channel P-2012 should not be used to ensure containment pressure remains below 3 psig."
The licensee stated that their Containment Weight of Air Monitoring (CWAM) system is used to ensure the 3 psig TS (LCO 3.11.C) is met.
This was confirmed by reviewing containment leak rate procedures (Proc. No. series 3.17.9). However, other documentation, such as Procedure NO. 3-6.2.2.24 (Indication Channel Calibration Contain-ment Pressure) and the above calculation (MYC-1168), indicate that P-2012 is the instrument used.
In addition, control room personnel indicated that the TS requirement was met by P-2012.
The licensee stated that they will correct the procedure and calculation reference to P-2012 and make sure control room person-nel use CWAM as primary indication of normal containment pressure.
Based on this commitment, this item is resolved.
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Item 29 Low SCC Pressure Alarm and Trip settings (Section 3.3.5)
The SSFI team found that Pressure Switch 1706 provides an alarm at 80 psig when SCC water accumulator TK110 reaches low pressure. This is the minimum pressure required to operate both SCC water trip valves if the plant air was unavailable.
Providing an alarm and a trip at the same value does not allow sufficient time for the operator action to rectify the situation.
This item is closely related to Item 4 in Section 4 of this report.
In the light of the above concern, tne licensee performed a calcu-lation to review the adequacy of the air system for SCC trip valves.
The SSFITU team reviewed the study that concluded the tank pressure should be maintained above 87 psig to assure closure of the valves under worst case differential pressure conditions.
In order to i
meet this system demand,the licensee has changed the setpoint to 92 psig.
This new setpoint provides a reasonable time for the operator to respond.
This item is resolved.
Item 46 Procedure for Commitment Tracking (Section 7.1 and 7.4)
This SSFI team concern addressed the lack of a procedure to track the commitments made to the NRC and in response to industry information.
The licensee responded that they have revised Procedure No.20-3-1, Commitment Management System, and established a formal program to track all commitments made.
The SSFIFU team reviewed Procedure No. 20-3-1, noting the Manager, Safety Engineering
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Operational Support is responsible for commitment tracking. This item will continue to receive NRC review as a normal part of the inspection process, therefore, Item 46 is resolved.
Item 52 Quality Assurance (QA) Audit Program (Section 1.0.1)
This SSFI team concern deals with the failure of the licensee QA l
program to identify concerns similar to the NRC SSFI.
l This subject is discussed under Issue 1, below.
Item 55 Plow Diagram Vacuum Breaker Labeling (NY Identified)
l During the SSFI, Maine Yankee identified mislabeled PCC and SCC vacuum breakers on Flow Diagrams 17A, 34A, 70A, and 94A.
The SSFIFU team reviewed DCR 89-013, January 11, 1989, and found l
marked-up sketches for the first three flow diagrams attached to j
the DCR.
No mark-up was attached for Flow Diagram 94A, and a
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drawing check revealed that this drawing had not been changed.
Prior to the end of the inspection, the licensee provided a copy
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of DCR No.90-025, which included a marked-up sketch showing correct labeling of the PCC vacuum breaker.
The team found no
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other indication of missed drawing changes, cautioned the licensee regarding DCRs, and recommended closing this issue.
This item is resolved.
Issue 1 Composite Safety Perspective (Itecs 1, 5, 2 5, 2 6, 27, and
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52)
The SSFI team identified an inconsistent safety perspective exemplified by Maine Yankee's approach to resolving several
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longstanding problems such as; the root cause of the failures associated with the valves PCC-43 and SCC-165; the lack of control on instrument satpoints and a formal program to address instruments found out of calibration; and the role of Maine Yankee's QA audit
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program in identifying certain of those programmatic findings identified by the SSFI team.
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The licensee has attended to most of the specific concerns addressed in the SSFI inspection.
The licensee has made some design improvements to eliminate the root cause of the failures
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associated with the valves PCC-43 and SCC-165.
See further discussion on this item under Items 1 and 5 (Pages 23 and 24).
In the past, Maine Yankee's QA audit program did not have suffi-cient emphasis on electrical and I & C area due to the absence of audit personnel with training in these areas. Subsequent to the SSFI, the licensee has allocated resources to include a full time Electrical and I & C person into the Q A organization. Moreover, during December 1989, the Yankee Atomic-Bolton conducted an audit with an I & C member in the team. The NRC team reviewed the licensee report 89-07 dated December 12,1989. This report had several findings in I & C, Equipment qualification and Electrical area.
In the engineering area, more resources are being committed to form an I & C group with a supervisor and four engineers.
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The SSFIFU team was initially concerned with the licensee's approach to upgrading the instrument setpoint bases and documen-tation to Regulatory Guide 1.105 guidance.
The concern related to the prcgram length (it started in March 1989 and lasts through the-refueling outage beyond December 1991), and prompt review of any n=
identified safety findings.
During this inspection the criteria for the development of setpoints and some calculations were made.
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Implementation remained in the preliminary stage. The licensee has
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proposed a committee review of the new setpoint calculations, after approval, to resolve any safety issues and develop implementation
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plans.
The team acknowledged that the instrument setpoint upgrade program was being done as a licensee initiative and, therefore, the scheduling should be under licensee control.
The implementation
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of instrument setpoint bases and documentation, discussed under Item 25, will receive NRC review at a later time.
7.0 TECHNICAL SPECIFICATIONS AND ADMINISTRATIVE CONTROL ISSUES The original SSFI report documented concerns related to the Technical Specification and administrative controls supporting the PCC/ SCC systems.
These concerns were from Items 8, 16, 31, 32, 33, 36, 39, 44, 45, 47, 48, 50, 53, 54, and 59.
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The major Technical Specification and administrative control issues raised in the report were the control of component replacement (Issue 5) and component labeling (Issue 6) in support CCW system capability.
Item 8 Service Water Cross-Tie Line-Up Guidance (Section 3.1.7)
The SSFI team determined that the current post-LOCA CCW system emergency operating procedures (EOPs) would not have prevented a system configuration which could result in inadequate service of safety-related heat loads. The potential existed that a post-LOCA system line-up could result in one service water pump trying to supply all four CCW heat exchangers.
This item is related to Item 35.
In response to the team's concern, the licensee revised step 15 of procedure EOP E-0 to require isolation of both service water heat exchangers in the inoperable CCW system if only one service water pump was operating.
The SSFIFU team found the revision to the EOP procedure adequately
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However, the revised procedure l
instructed the operators to, "close the service water heat exchang-l er outlet valves on the service water heat exchangers in the inoperable train" but did not specify the applicable valve numbers for clarification.
The licensee committed to a procedure revision to include the applicable valve numbers for each failure condition, therefore this item is resolved.
Item 16 Batteries 2 & 4 Replacement (Section 3.2.4.1.b, 5.1.b, 7.1, 7.2, and 7.5)
The SSFI team determined that Batteries 2 and 4 were replaced by component substitution rather than through the design change process.
The team questioned the supporting safety analysis, installation testing, and preventive maintenance actions.
These problems may have been avoided if the design change process had been used.
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The licensee developed new Procedure No.17-226, Technical Evalua-tions, to strengthen the design change / component replacement interface.
The SSFIFU team reviewed Procedure No.17-226 and found it followed industry guidelines for replacement of power plant equipment.
The licensee is 914o committed to develop a minor modification process which wouM suctMr $1fferentiate between component substitutions, design chugash end minor modifications.
Based on these planned improvciaens, this item is resolved.
Itam 31 Plant Radiation Monit0 ring System Modifications (Section 3.3.7, 7.2)
The SSFI team found that the plant radiation monitoring system had been modified without a design change package.
The concerns of this item are closely related to Items 48 and 50, and parallel Item 16.
The licensee's corrective actions and the teams review are as stated above.
Therefore, this item is resolved.
Item 32 control Room Deficiency Report Log (Section 4.1)
The SSFI team determined that an informal Deficiency Report (DR)
log was maintained in the plant control room for operator refer-ence. 'The log was found to be incomplete and not wholly accurate.
The licensee expressed a desire to retain this informal log as an operator aid.
The log is updated weekly from the outage Department master DR list.
The SSFIFU team found the subject log provides, the operators with an easily accessible reference list of all deficiencies involving control room instrumentation & controls.
If needed between the I
weekly list updates, the operators have access to a computer L
terminal in the control room to check the status of any instrumen-tation in question. The team considered this log a useful operator
aid, found the weekly updates sufficient for operator reference, and, therefore this item is resolved.
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Item 33 Control of Valve Tags (Section 3.1.7, 4.1, and 4.5)
An assessment of the PCC and SCC component labeling by the SSFI team determined that although all inspected valves were correctly identified with metal tags, the tags minimally complied with the licensee's procedure for system and component labeling.
Many of the metal tags were physically deformed, painted over or located in an awkward position and, thus, difficult to read.
The licensee has replaced the CCW system specific valve tags identified with new color-coded tags which are easy to read and include a description of the valve as well as its alpha-numeric
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designation.
The tags were replaced as part of the plant-wide component labeling upgrade program currently in progress at the
site.
The SSFIFU team noted a detailed assessment of the licensee's new component labeling program for the service water system was
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described in Inspection Report 50-309/89-22.
To summarize, this inspection found the licensee's new labeling system a significant improvement over the metal tag labels used in the past.
Therefore, this item is resolved.
Item 36 Alternate Fire Main Flow for Diesel Generators (Section 4.3.1)
The SSFI team determined that although the PCC and SCC normal operating -procedures identified the proper sequence to manually establish alternate fire main cooling to the affected EDG upon loss of a CCW train, this information was not included in the applicable system Auxiliary Operating Procedures (AOPs).
In response to the team's finding, the licensee revised procedures AOP 2-32, " Loss of SCC" and AOP 2-33, " Loss of PCC" to include the procedural steps necessary to establish the alternate fire main flowpath to the affected EDG.
The SSFIFU team reviewed the revised procedures and walked through the procedures with a qualified operator.
The revisions satisfac-torily established an alternate fire main flowpath to the affected EDG in both procedures.
However, one step in both procedures had the operator verify that EDG jacket cooling temperature was decreasing but did not specify the designated instrument for verification.
The operator was momentarily confused as to which of two indicators to use to monitor jacket cooling temperature.
The licensee committed to revise both procedures to include the l
proper instrument designation to alleviate the possibility of confusion.
Based on the licensee's corrective actions, this item is resolved.
Item 39 Technical Requirement Elimination by Maintenance (Section 5.2.1)
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During the SSFI, the team observed a Secondary Component Cooling (SCC) pump repair being performed with a Maintenance Department issued Procedure' Change Report (PCR) to reassemble the pump end housing without a 0.010 inch gasket.
This elimination of the l
gasket circumvented:
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the technical intent of the repair procedure 5-9-S; (2) vendor requirements to maintain a small axial clearance of the outer shaft bearing race; and (3) the procedure change instructions (Proc. 0-62-2), which requires PED approval of all PCR ]
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32 The licensee cancelled the inappropriate PCR, counseled the supervisor involved, looked for similar cases of non-PED approved PCRs, and provided maintenance crew training on this subject.
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SSFIFU team review indicated no further problems; therefore, the item is resolved.
Item 44 Accumulator Check valve Testing Records (Section 6.5.2)
The SSFI team found the record keeping for accumulator check valve testing to be disorderly. In addition, there was little or no indication of test result evaluation.
The licensee's response stated that the records were reorganized and will be maintain in an orderly fashion.
The SSFIFU team reviewed the subject record books and found them
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in good order, thus, Item 44 is resolved.
Item 45 Safety Evaluations Standard Content and Format (Section 7.1, 7.4)
The SSFI team found that the Plant Engineering Department (PED)
procedure for preparing Safety Evaluations does not establish l
requirements for a standard content and format for documentation of safety evaluations.
The licensee indicated that the PED procedure for preparing Safety Evaluations, No.
17-21-7, provides a content checklist for the safety analysis and leaves the format to the discretion of the writer.
The licensee also indicated that past experience has justified that the procedure is adequate.
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l The SSFIFU team's review of PED Procedure No. 17-21-7 found the checklist for the analyst considered items such as failure mode analysis, conforms to system / component design basis, and many other significant design considerations.
In addition, the resultant safety analysis is.used in the Engineering Design Change Request (EDCR) process which results in multiple reviews of the safety analysis by other plant disciplines.
The inspector also reviewed several completed safety evaluations and found no deficiencies.
Although further review of the adequacy of the licensee's safety evaluations will be conducted in accordance with the routine NRC inspection program, based on the team's review, this item is resolved.
Item 47 FSAR Updated Process (Section 7.1)
At the time of the SSFI, the team found that the FSAR had not yet been updated to reflect the installation of the new PCC and SCC heat exchangers.
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The licensee submitted an FSAR update to reflect the new heat exchangers in their last FSAR update.
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The SSFIFU team reviewed the current up-dated FSAR and found it now
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reflects the new E-4A (PCC) and E-5B (SCC) heat exchangers includ-ing a discussion of the heat exchanger materials.
In addition, the licensee has begun preparing an update of all the CCW heat loads for the FSAR.
This item is resolved.
Item 48 Component substitution Control (section 7.2, 7.5)
The SSFI team found several cases of component substitution without a design change package.
The concerns of this item are closely related to Items 16, 31, and 50.
The licensee's corrective actions and the teams review are as stated for Item 16, therefore, this item is resolved.
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Item 50 Quality Assurance (QA)
statement on Replacement of Batteries 1 & 3 (section 7.5)
The SSFI team, during review of plant Quality Assurance (QA) audit reports, noted that Audit Report MY-88-07 stated that Station
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Batteries 1 and 2 could have been replaced under the Discrepancy
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Report / Repair Order (DR/RO) system. This statement did not reflect knowledge of regulatory requirements for the design change process beyond those of the plant procedures.
L As mentioned earlier in this report under Item 16, the licensee has improved their design change / component replacement interface.
These improvements encompass the QA audits.
The SSFIFU team found the procedural control improvements, addressed in the Item 16 write-up, resolves this-item.
Item 53 Batteries 2 & 4 Discharge Rate (Section 3.2.4.1.c).
The SSFI team found that the acceptance test for the cells of Batteries 2 and 4 at both the manufacturer's facility and following installation at Maine Yankee used the wrong discharge rate for the stated test length.
This was considered a failure of Quality Control (QC) to verify the correct test requirements.
This item is closely related to Item 17.
In response to this finding, the licensee initiated a new element in the QC review to verify that the correct test requirements are specified for acceptance tests.
The SSFIFU team reviewed the new element in the QC program and found the licensee's corrective action adequate.
Therefore, Item 53 is resolved.
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Item 54 CCW Heat Load Accuracy in FSAR'(NY Identified)
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The licensee determined that all CCW heat loads listed in the FSAR should be updated for accuracy including checking the " safeguards"
loads and verification of control room HVAC loads.
The licensee completed this review prior to the SSFIFU inspection.
The team reviewed the FSAR update package and had no further questione,-therefore, Item 54 is resolved.
Item 59 Commitment Management System Control (NY Identified)
The SSFI team identified this minor concern without highlighting it in any manner.
The licensee identified the issue and revised Procedure No. 20-3-1, Commitment Management System.
The SSFIFU team's reviewed of the procedure identified no remaining concerns, thus, Item 59 is resolved.
Issue 5 Control of Component Replacement (Items 16, 31, 48, and 50)
The SSFI team was concerned that the licenseee's programmatic controls did not adequately limit actions performed as component substitutions such that unauthorized plant modifications were prevented.
Examples of modifications performed as component substitutions rather than through the design change process included the replacement of station batteries and the replacement-of plant radiation monitoring system detectors.
Problems iden-tified with these modifications included the adequacy of the safety.
analysis performed to support these changes, installation testing deficiencies, and preventive maintenance actions.
The team con-cluded that these problems may have been prevented if the changes had been made using the design change process rather than through component substitution.
In response to the team's findings, the licensee took a number of actions to strengthen their programmatic controls for design changes and component substitutions.
The licensee developed a new procedure to provide improved design control and technical evalua-tion of replacement items.
This procedure requires documented approval from the Plant Engineering Department (PED)
for all component substitutions. The procedure was developed following the intent of an industry guideline on te chnical evaluation of replace-ment items.
In addition, the licensee strengthened the procedural definition of a component substitution and is in the process of clarifying the definition of a design change.
Finally, the licensee is also developing a new minor modification process which
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also amplifies the differences between component substitutions, i
design changes and minor modifications.
The SSFIFU team reviewed the licensee's new procedure, " Technical-Evaluations", No.17-226, which provides guidance for conducting
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L and documenting technical evaluations to assess the technical suitability of a component substitution as well as other plant issues.
The technical evaluation is performed by a PED reviewer and provides a specific format for the reviewer to follow.
The completed evaluation is then required to be reviewed by a PED supervisor.
The team reviewed several technical evaluations completed to support component substitutions and had no questions.
In addition, other plant procedures involving design changes, discrepancy reports and maintenance requests were reviewed.
The team found that the licensee's procedure governing plant modifica-i I
tions, " Permanent Plant Modifications", No. 17-21-1, specifically differentiated between design changes and component substitutions and referenced the new technical evaluation procedure for component substitutions.
Procedure No.
0-16-3, Discrepancy Reporting Procedure, also discussed compone:nt substitutions and indicated that documented approval by PED was required for all component substitutions.
The inspector also reviewed a draft copy of Procedure No.
17-21-8, Minor Modifications, and noted that the licensee's definition of a minor modification was congruent with the definitions and governing documents for design changes and component substitutions.
In regard to the QA audit report which incorrectly indicated that the replacement of Batteries 1 & 3 could have been performed as a component substitution, the licensee committed to provide training-to all Quality Programs personnel on the programmatic and proced-ural improvements governing design changes, component substitu-tions and minor modifications.
Based on the procedural and programmatic improvements made and those in progress for Items 16, 31, 48, and 50, this issue is resolved.
Issue 6 Component Labeling (Item 33)
The SSFI team was concerned with a minimally acceptable component labeling program. Many of the labels were difficult to read making the possibility of valving errors increase as the plant ages.
The licensee has replaced the CCW component labels with profes-sional looking tags.
The SSFIFU team observed a number of the new labels for the CCW components and found them of high quality.
However, other plant system components have generally not been covered by this relabeling program.
The licensee has internally committed to
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continue component relabeling, but no specific schedule has been established.
The team encouraged the licensee to continue this plant improvement.
The issue is resolved.
8.0 MANAGEMENT MEETINGS Regular meetings were held with both corporate and station manage-ment throughout the course of the inspection to clarify and discuss findings and concerns.
An exit meeting was conducted on January j
19, 1990.
Attendance at the exit is listed below.
Preliminary findings, assessment of strengths and weaknesses, and conclusions were presented at the exit and are summarized in Section 1.0 of this report.
Maine Yankee Attendees R.
Arsenault, Maine Yankee, Asst. Maintenance Manager B.
Blackmore, Maine Yankee, Plant Manager i
A.
Cayla, Maine Yankee, Operations Manager R.
Crosby, Maine Yankee, Sr. Licensing Engineer P.
Dostie, State Nuclear Safety Inspector i
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Frizzle, Maine Yankee, President J.
Frothingham, MY, Quality Programs Dept. Manager J. Garrity, Maine Yankee, VP, Licensing and Engineering J. Herbert, Maine Yankee, Plant Engineering Manager L. McCabe, Maine Yankee, Senior Mechanical Engineer
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Nichols, Licensing Section Head R. Radasch, Maine Yankee, I&C Section Head i
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Smith, Nuclear Safety Section Head D. Whittior, Nuclear Engineering & Licensing Manager NRC Attendees E.
Conner, NRC, Team Leader C. Holden, NRC, Senior Resident Inspector T.
Koshy, NRC, Senior Reactor Engineer
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Leeds, NRC-NRR, Project Manager l
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Morris, ERCE, Consultant J.
Stair, NRC, RI Susquehanna T. White, ERCE, Senior Engineer
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