ML20058K297
| ML20058K297 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/06/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058K288 | List: |
| References | |
| 50-309-90-19, EA-90-192, NUDOCS 9012170127 | |
| Download: ML20058K297 (42) | |
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FNCLOSURE 1 NOTICE OF VIOLATION Maine Yankee Atomic Pov er Company Docke No.;50-309 Maine Yankee Atomic Pos er Station License IM. DPR-36 EA 00-192 During an NRC inspection from September 19 to October 30.1990, violations of NRC '
I requirements were identified. In accordance with the " General Statement of Policy and.
Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1990), thes j
violations are listed below:
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A.
An NRC Order dated Junt. 14,1984 required, in part,' the installation of
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environmentally qualified limit switches providing position indication for the containment isolation valves which are required to be environmentally qualified by 10 -
i CFR 50.49.
Contrary to the above, as of October 30,'1990,. Maine Yankee had not provided environmentally qualified limit switches for containment isolation valves required to' be environmentally qualified by 10 CFR 50.49. Specifically, inadequate' sealing of the conduit connection to multiple limit switches allowed moisture intrusion which:
rendered limit switch PS-A-20 inoperable during normal operation and invalidated environmental qualification of the other such switches providing required ' position -
indication for containment isolation valves, j
This is a Severity Level IV violation (Supplement I).
B.
An NRC Order dated June 14,1984 required, in part, that the post-TMI items set forth in NUREG 0737 be implemented by October 1,1985, including implementing the guidance in Regulatory Guide-1.97. Regulatory Guide 1.97,~ Revision 3, Table 1, Section 2, specifies that, for the Engineered Safety Feature (FSF) lightboxes which indicate valve position status in the control room, indepen&nt channels be provided to preclude single failures.
Contrary to the above, as of October 19,1990, the Engineered Safety Features i
(ESF) valve position status light lip,htboxes which indicate valve position status l
l in the control room were not supplied by independent channels to preclude single failures.
l This is a Severity Level IV violation (Supplement I).
Pursuant to 10 CFR 2.201, Maine Yankee'is hereby required to submit a written statement.or explanation in reply to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to-the Regional Administrator, Region I, 475 9012170jp7 901206 gDR ADOCK 05000309 PDR 3
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Allendale Road, King of Prussia, Pennsylvania,19406. and~the NRC Resident Inspector, within 30 days of the date of the letter transmitting this Notice of Violation (NOV)., This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: 1) the reason for the violation, or, if contested, the basis for disputing the violation, 2) the corrective steps that have been taken and the results achieved, 3) the' corrective steps that will be taken to avoid further violations, and 4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in -
this NOV, an order may be issued to show cause why the license should not be modified,.
suspended, or revoked, or why such other action as may be proper should'not be taken. -
Where good cause is shown, cocsideration will be given to extending the response time.
Dated at King of Prussia, PA this day of December,1990 l
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I-ENCLOSURE 2 i
ATTENDANCE LIST FOR NOVEMBER 15.1990 ENFORCEMENT CONFERENCE l
IN NRC REGION I' '
i Maine Yankee Attendees C. Frizzle President, Maine Yankee Atomic Power Company G. Whittier Vice President, Licensing and Engineering, Maine Yankee (MY)
J. Hebert Manager, Plant Engineering, MY P. Anderson-YNSD Project Manager, MY Group B. Wilkens YNSD EQ Coordinator S. Nichols Manager,. Nuclear Engineering and Licensing,-MY J. Bonner YNSD Special Prql6 cts Coordinator T. Gifford Project Engineering,- Caction Head, MY NRC Attendees J. Wiggins Deputy Division Director, Divison of Reactor Projects (DRF)
J, Durr Chief, Engineering Branch, Division of Reactor Safety (DRS)
C. Anderson Chief, Plant Systems Section, DRS J. Johnson Chief, DRP Branch 3'-
R. Freudenberger Resident Inspector,-MY P. Sena Reactor Engineer, DRP Section 3B E. Trottier Project Manager, Project Directorate'l-3, Office of Nuclear Reactor Regulation (NRR)
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W. Troskoski Senior Enforcement Specialist, OE -
(By Telecon)
K. Smith Regional Counsel, RI.
R. Christopher Enforcement Specialist, RI ~
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1 ENCLOSURE 3 l
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Maine Yankee Handouts at the November 15.1990 1
Enforcement conference l
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L AGENDA NRC INSPECTION 9019 ENFORCEMENT CONFERENCE:
, November 15,11990
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INTRODUCTION-C. D. FRIZZLE ENVIRONMENTAL QUALIFICATION PROGRAM S. E. NICHOLS EQ ALLEGED. VIOLATIONS '
B.- J. WILLKENS:
REGULATORY GUIDE 1.97 PROGRAM S. E. NICHOLS REGULATORY GUIDE 1.97 ALLEGED VIOLATIONS J.R.HEBERT
SUMMARY
G. D. WHITTIER CLOSURE
'C'. D. FRIZZLE l
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EQUlPMENT.QU.ALIFICATION TIMELINE i
1980 - BEGAN EQ UPGRADES e DOR GUIDELINES, NUREG-0588 and IEB 79-01B 1985 - COMPLETED INITIAL UPGRADES e EQUIPMENT WALKDOWNS.
e DEVELOPED MAINTENANCE GUIDELINES e INDUSTRY GROUP PARTICIPATION
- NRC EQ RULE DEADLINE g
q 1986/1987 - COMPREHENSIVE INTERNAL' AUDIT-e UPGRADED QUALIFICATION DOCUMENTATION FILES-e EQ TRAINING PROGRAMS e REPLACED LIMITORQUE SIS WIRING (IEN 86-03)-
1987 - NRC EQ AUDIT (IR 87-16) l e TWO LEVEL IV CITATIONS, ONE.EQ LEVEL-C CITATION WITH FULL MITIGATION e "PROMPTLY. CORRECTED" e " DOCUMENTATION OF EQ AT MAINE YANKEE HAS IN GENERAL BEEN GOOD" l
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I EQUIEMENT_QUAllELCATION TIMELINE (continued).
iI 1987/1988 - RESPONSE TO INDUSTRY INITIATIVES e REPLACED RAYCHEM SPLICES '(IEN 86-53) e AMBIENT TEMPERATURE MONITORING PROGRAM '(IEN 89-30)L e PRESSURE TESTED AND REPLACED' GAMMA-METRICS CABLES-(PART 21)
H e INSPECTED. ROSEMOUNT. TRANSMITTER HbOSINGS FOR:
J TWISTED NECK SEALS (PART 21)
H q
H 1989 - NRC EQ FOLLOWUP AUDIT (IR 89-16)-
.e NO ITEMS OF NON-COMPLIANCE o VERIFIED CLOSURE OF ALL BUT ONE IR=87-16 OPEN ITEMS 1990 - EQUIPMENT UPGRADES e UPGRADED CTMT ELECTRICAL PENETRATIONS -
e UPGRADED SCOTCHCAST SEALS.WITH NAMCO SEALS -
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e INSTALLED NEW AMBIENT JAIR TEMPERATURE MONITORS (IEN.89-30)
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SUMMARY
- MAINE YANKEE HAS BEEN PRO-ACTIVE IN RESOLUTION OF TECHNICAL MATTERS.
e WILLING TO UPGRADE TO IMPROVED EQUIPMENT. -
e DEMONSTRATED GOOD PERFORMANCE..
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i EQ REQUIREMENTS AND lNSTALLATIONS l
- 33 OF THE 80 LIMIT SWITCHES - ARE REQUIRED TO BE SEALED AGAINST MOISTURE INTRUSION RESULTING FROM A DBE-I q
- REMAINING n47 SWITCHES ARE. NOT EXPOSED TO A 4
STEAM ENVIRONMENT WHENnREQUIRED TO OPERATE
' LIMIT ' SWITCHES ARE MOUNTED ON-VALVES-THROUGHOUT THE PLANT.
THE. -LIMIT SWITCHES PROVIDE INDICATION' l
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~OF -- VALVE E ACTIONS IMMEDIATELY ' AFTER-ISOLATION
.OR VALVEJ CHANGE. OF STATE.
ADDITIONALLY, THESE o
i SWITCHES PROVIDE CONTAINMENT ISOLATION VALVE POSITION zlNDICATION IN ACCORDANCE' WITH j
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-REGULATORY: GUIDE' 1.97--
I THE NAMCO1 LIMIT 1 SWITCHES AND SCOTCHCAST : SEALS ARE e-L_.
QUALIFIED IN ACCORDANCE WITH '10CFR50.49 L --
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i ALLEGED VIOLATION NO.1 t
FAILURE TO MAINTAIN ENVIRONMENTALLY QUALIFIED LIMIT SWITCHES IN ACCORDANCE WITH 10CFR50.49 LACK OF DRAIN HOLE INLSCOTCHCAST SEAL
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FAILURE TO PROPERLY RESTORE THE EQ ENCLOSURE : AFTER SWITCH MODIFICATIONS l
INVALIDATION OF.QUALIFICATIONLDUE TO ELBOW FITTING MODIFICATIONS
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SCOTCHCAST SEAL lhSTALLATIONS THE SCOTCHCAST SEALS WERE INSTALLED DURING THE o
1982 AND 1984 REFUELING-OUTAGES WITHOUT A DRAIN I
HOLE PER THE DESIGN CHANGE INSTRUCTIONS l
THE ORIGINAL QUALIFICATION FILE QUALIFIED--
1 THE -SEALS WITHOUT AL DRAIN HOLE l
LATER REVISION TO THE EQ FILE lNCORPORATED
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ADDITIONAL TESTING WHICH :lNCLUDED A. DRAIN HOLE u
l DISCREPANCY BETWEEN THE. TESTED CONFIGURATION-i L
AND THE. INSTALLED-CONFIGURATION WAS NOTED 'BY j_
.THE NRC DbRC4G THE 1987.- EQ. AUDIT AS REPORTED IN-q NRC INSPECTION ^ REPORT :50-309/87-l16
-* DRILLING -DRAINLHOLES'-WASLNOTE RECOMMENDEDTDUE TO
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' THEL POSSIBILITYROF DAMAGING THE CONDUCTORS ~ ~
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lNSTALLATIONS (CON'T) t i
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- PREPARED 'A CALCULATION TO DEMONSTRATE THAT THE AMOUNT OF CONDENSATE WHICH WOULD ACCUMULATE IN
.THE SWITCH HOUSING DURING AND FOLLOWING A 'DBE' 3
WOULD NOT. ADVERSELY AFFECT LIMIT SWITCH OPERATION E
- THIS CALCULATION WAS REVIEWED. BY THE 'NRC AND
- l THE OPEN ITEM -CLOSED AS DOCUMENTED IN INSPECTION
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REPORT '50-309/89 16 1
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THE FOCUS OF 10CFR50.49 IS THE TIME PERIOD DURING AND-AFTER THE DBE; THE INDUSTRY AS A :WHOLE IS ON A.
LEARNING. CURVE IN^ REGARD TO MOISTURE ' BUILD-UP l
DURING lUED lEIN, 89-63 IN-SEPT.1989
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NORMAL PLANT OPERATIONS; AS A1 RESULT THE
.NRC-ISS a
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MAINE YANKEE'S ACTIONS SATISFIED REGULATORY l
REQUIREMENTS-
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i REVERSAL OF CAM DIRECTION o
NAMCO REQUIRES THAT THE END USER MAINTAIN LIMIT 1
v-SWITCH ENCLOSURE-INTEGRITY I
DURING SCOTCHCAST SEAL REPLACEMENT IN OCTOBER-1990 j
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IT WAS DISCOVERED THAT THE DIRECTION OF THE LIMIT SWITCH ' CAM OPERATION HAD BEEN REVERSED ON 39 LIMIT SWITCHES,17 OF' WHICH REQUIRED AN ENVIRONMENTAL SEAL; THE CAM REVERSAL WAS DONE DURING_ ORIGINALLINSTALLATION
. THE LIMIT SWITCHES WITH ROTATED CAMS WERE REPLACED WITH NEW LIMIT SWITCHES FOR THE FOLLOWING REASONS:-
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- 1) SPEEDOF INSTALLATION :(ALARA)
- 2) COMMUNICATIONS WITH NAMCO 3)~ INDETERMINABLE INSTALLATION DOCUMENTATION
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REVERSAL OF CAM DIRECTION (CON'T)
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r SUBSEQUENT.TO THE NRC INSPECTION, ADDITIONAL INFORMATION WAS OBTAINED DOCUMENTING THAT THE LIMIT SWITCH ENCLOSURE HAD BEEN MAINTAINED DURING INSTALLATION ORIGINAL PURCHASE SPECIFICATION' INDICATED POTENTIAL CAM ROTATION; ORIGINAL INSTALLATION lNSTRUCTIONS PROVIDED DIRECTIONS FOR CAM: ROTATION, ' AND TORQUING OF.-
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COVER SCREWS GASKETS DID-NOT REQUIRE REPLACEMENT BECAUSE -LIMIT SWITCH HAD NOT BEEN PLACED -lN SERVICE i
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PIPE THREAD SEALANT j
QUALIFICATION TEST ' REPORTS FOR THE LIMIT SWITCHES
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REQUIRE THE lNTEGRITY OF THE ENCLOSURE TO BE MAINTAINED BY THE END USER IT IS NOTED -THAT ~ NAMCO DID NOT ' ORIGINALLY ' QUALIFY
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l A THREAD: SEALANT-PIPE FITTINGS WERE lNSTALLED BETWEEN THE EYS.
FITTINGS AND THE -LIMIT iSWITCH HOUSINGS.
THE INTERFACES WERE SEALED USING EITHER NOALOX OR KEY ' GRAPHITE -PASTE:
IT IS -QUESTIONABL WHETHER -THEL FAILURE OF THE. PIPE
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THREAD' SEALANT COULD HAVE RESULTED IN -THE.. LOSS:.OF ~
. INDICATION;_ IF1 LIMIT SWITCH FAILURE-OCCURRED.
OPERATION -OF THE VALVE WOULD NOT BE-AFFECTED FITTINGS USED IN? CONJUNCTION WITH THE. NAMCO : SEAL INSTALLATION ARE SEALED WITH QUALIFIED-RTV SEALANT l
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i MAINE -YANKEE -PROCEDURE NO. 6.-09
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- INSTALLATION l
e OF SCOTCHCAST NO. 9 IN CONDUIT EXPLOSION-PROOF
-SEALING F1TTINGS;" INCLUDED INSTALLATION OF DRAIN HOLE AND VERIFICATION THAT SCOTCHCAST BEEN l
PROPERLY RETAINED BY THE DAM MATERIAL i
i MAINE YANKEE PROCEDURE NO. 6-10-1, "NAMCO LIMIT j
SWITCH INSTALLATION AND MAINTENANCE REQUIREMENTS;"
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-WRITTEN TO ENSURE INTEGRITY OF ENCLOSURE. IS NOT
~ COMPROMISED -DURING MAINTENANCE t ACTIVITIES; -INCLUDED 1
- CAUTION OF FOLDED / TORN: GASKETS t
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- j c ' y" FIGURE.1 SCOTCHCAST NO.'9
. SEAL CONFIGURATION:
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CRDUSE-HINDS TYS* TYPE
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L ALLEGED VIOLATION NO. 2
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r FAILURE TO..TAKE PROMPT CORRECTIVE;
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ACTION FOR THE. LIMIT SWITCH FAILURE a
OF PS-A-20.
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1987 - INSPECTION OF j
H SCOTCHCAST SEALS 1
4 e-OPERATIONAL -CONCERNS WITH FIVE LIMIT SWITCHES; DETERMINED DAMMING MATERIAL USED IN CONJUNCTION
'WITH SEALS MAY :HAVE FAILED. DURING ORIGINAL
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INSTALLATION; VALVE OPERATION WAS NOT AFFECTED FAILURE OF DAM WAS NOT-NOTED DURING ORIGINAL.
i INSTALLATION; SEAL WAS ' INSTALLED WITH TOP COVER GASKET IN PLACE; HOUSING INTERNAL WAS NOT lNSPECTED 1
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INSPECTED.ALL EQ LIMIT SWITCH HOUSINGS FOR SIGNS OF i
MOISTURE AND/OR SCOTCHCAST L
REWORKED 16 SCOTCHCAST.: SEALS BY RE-DAMMING AT THE L
i ENTRANCE TO THE LIMIT SWITCH AND POURING ADDITIONAL SCOTCHCAST.INTO :THE EYS FITTINGS J
DETERMINED THIS REWORK' PROVIDED AN ADEQUATE
-l SEAL INSTALLATION. -QUALIFIEDolN ACCORDANCE WITH j
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1 1987: MOISTURE IN BD-T-32 DURING 1987 EQ: AUDIT A MAINElYANKEE TECHNICIAN-FOUND-MOISTURE IN: BD-T-32 DETERMINED' MOISTURE-ENTERED THROUGH -A FOLDED / TORN TOP COVER GASKET
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NRC INSPECTED TWO -OTHER' SWITCHES IN THE AREA
~'AND NO MOISTURE WAS FOUND; NRC CONCURRED MOISTURE BD-T-32 TO BE' AN ~' ISOLATED CASE AS DOCUMENTED IN INSPECTION REPORT 50-309/87-16
+ - INSPECTED ALL LIMIT SWITCH TOP COVER GASKETS; REPLACED:8 DAMAGED GASKETS REVISED. QUALIFICATION FILES - AND PROCEDURE 6-10-1 TO CAUTION TECHNICIANS OF POSSIBLE FOLDED / TORN GASKETS DURING INSTALLATION / MAINTENANCE ACTIVITIES
- - DETERMINED THE NEW GASKETS PROVIDED AN
-ADEQUATE INSTALLATION j
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FEBRUARY 1990: P8-A-20 OPEN LIMIT SWITCH LIMIT. SWITCH PROVIDES MCB INDICATION FOR THE PRIMARY SAMPLING SYSTEM, A TRAIN ISOLATION VALVE MOISTURE FOUND IN OPEN SWITCH OF PS-A-20 DUE a
TO INADEQUATE REWORK OF SEAL 11N 1987; SEAL REPLACED 'IN: ACCORDANCE-3WITH. PROC. 6-09-1 36 SCOTCHCAST SEALS REPLACED LW/ NAMCO CONNECTORS
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~ DURING '1990 REFUELING OUTAGE; 15uREQUIRED A. SEAL-REMAINING LIMIT SWITCHES INSPECTED ~ FORi SIGNS OF'
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MOISTURE; RESULTS TWERE 100%DSATISFACTORY
-* REMAINING -SCOTCHCAST SEALS' WERE SCHEDULED TO BE REPLACED :DURING. CYCLE --12nNORMAL OPERATION AND CYCLE 12 -REFUELING. OUTAGE DETERMINED NEW CONNECTORS PROV!DED1 ADDITIONAL e
MARGIN OF SAFETY AND REMAINING SCOTCHCAST' SEALS-WERE - ADEQUATELY DESIGNED
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APRIL 1990: DR-A-6 1.
HIGH PRESSURE DRAIN COOLER ISOLATION VALVE MCB INDICATION DURING REPLACEMENT OF SCOTCHCAST SEAL WITH NAMCO CONNECTOR, THE EYS FITTING WAS FOUND WITHOUT SCOTCHCAST; THERE WERE NO SIGNS OF MOISTURE OR CORROSION IN LIMIT SWITCH HOUSING-NO OTHER EYS FITTINGS WERE FOUND WITHOUT SCOTCHCAST DETERMINED _ THAT THIS WAS AN ISOLATED CASE
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.i APRIL 1990: PCC-A-270 CONTROL ELEMENT DRIVE MECHANISM COOLER ISOLATION VALVE LIMIT SWITCH FOUND WITH SIGNS OF CORROSION DURING
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REPLACEMENT OF SCOTCHCAST SEAL WITH NAMCO CONNECTOR DETERMINED MOISTURE DUE TO INADEQUATE : SEAL REWORK e
IN 1987 ROOT CAUSE OF FAILURE IDENTIFIED AND-CORRECTED:
e SIMILAR ' SEAL CONFIGURATIONS REPLACED WITH NAMCO CONNECTORS
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I OCTOBER 1990: PD-A-122 1
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CONTAINMENT SUMP PUMP DISCHARGE ISOLATION-VALVE MOISTURE FOUND IN PD-A-122 DUE TO FAILURE OF SCOTCHCAST SEAL VALVE OPERATED PROPERLY EVEN THOUGH POSITION INDICATION MS LOST LIMIT SWITCH HAD BEEN INSPECTED IN 1987 AND 1990 WITH SATISFACTORY RESULTS; PD-A-122 WA6 THE FIRST l,
FAILURE WITH A SEAL THAT HAD NO-PREVIOUS EVIDENCE OF= INADEQUATE SEALING METHODS i
UPGRADED REMAINING SCOTCHCAST SEALS WITH NAMCO CONNECTORS; QUALIFIED IN ACCORDANCE WITH 10CFR50.49; FILE WAS REVIEWED BY THE NRC AS NOTED l
lN INSPECTION REPORT 50-309/90-19 i
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SUMMARY
VALVE NO.
ROOT CAUSE CORRECTIVE ACTION BD-T-32 FOLDED GASKET COMPLETE INSPECTION PS-A-20 INADEQUATE SEAL NEW SCOTCHCAST SEAL; REWORK IN 1987 36-SEALS UPGRADED; REMAINING SEALS INSPECTED DR-A-6 NO SCOTCHCAST ISOLATED CASE i
PCC-A-270 INADEQUATE SEAL SIMILAR SEALS REWORKED REWORK IN.1987 IN 1987 UPGRADED I
PD-A'-122 INADEQUATE SEALING UPGRADED REMAINING i
METHOD SCOTCHCAST SEALS i
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SUMMARY
OF ALLEGED VIOLATIONS
- i L-ALLEGED VIOLATION NO.1
- MAINE YANKEE-QUALIFIED THE LIMIT SWITCHES WITHOUT I
DRAIN HOLES l
10CFR50.49 FOCUSES ON DBE CONDITIONS, WHICH I
WERE NOT THE CAUSE OF THE MOISTURE BUILD-UP
- MOISTURE BUILD-UP DURING NORMAL OPERATION IS i
l CURRENTLY BEING EVALUATED BY THE INDUSTRY ON A-GENERIC BASIS
- THIS ISSUE DOES NOT AFFECT ENVIRONMENTAL j
QUALIFICATION OF THE LIMIT SWITCHES PURSUANT TO j
10CFR50.49 REQUIREMENTS l
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- LATER EVALUATION OF DOCUMENTATION PROVIDED ADEQUATE ASSURANCE.OF THAT THE LIMIT SWITCH ENCLOSURE WAS MAINTAINED t
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SUMMARY
OF ALLEGED VIOLATIONS i
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ALLEGED VIOLATION NO. 2 j
- FAILURE OF PD-A-122 WAS THE FIRST FAILURE OF A SEAL THAT HAD NO PREVIOUS EVIDENCE OF INADEQUATE 1
i SEALING METHODS i
- THE LIMIT SWITCH FAILURE IN OCTOBER 1990 WAS NOT SAFETY SiGNIFICANT l
- THE LIMIT SWITCHES REWORKED IN OCTOBER 1990 HAD i
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NO SIGNS OF MOISTURE AND/OR CORROSION
- MAINE YANKEE DEMONSTRATED PROMPT CORRECTIVE
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1 REGULATORY GUIDE 1.97 TIMELINE
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1982 - NUREG 0737, SUPPLEMENT 1 ISSUED i
l 1984 NRC ORDER CONFIRMING POST-TMl COMMITMENTS 1985 MAINE YAh"(EE RG 1.97
SUMMARY
. REPORT 1
I 19811990 EXTENSIVE RG 1.97 DESIGN UPGRADES
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- WR LOG CHANNEL INDICATION
- PRESSURIZER PRESSURE & LEVEL
- S/G PRESSURE & LEVEL l
- PCC/ SCC FLOW i
- OTHERG 1990 - NRC RG 1.07 AUDIT (IR 90-15)
- NO ITEMS OF NON-COMPLIANCE
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- INSPECTOR REVIEWED ~ SEVERAL TYPE A,
CATEGORY.1 VARIABLES l
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SUMMARY
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e MAINE YANKEE HAS SUCCESSFULLY COORDINATED RESOLUTION OF POST TM1 ACTION ITEMS.
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e SHOWN WILLINGNESS TO UPGRADE PLANT DESIGN.
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- DEMONSTRATED GOOD PERFORMANCE.
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ALLEGED VIOL.ATIONS NO. 3/4 l
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l FAILURE TO INSTALL A QUALIFIED POWER SOURCE
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FOR POSITION INDICATION OF THE CTMT ISOLATION l
4 VALVES AND TO PROVIDE ACCURATE INFORMATION IN THE FEBRUARY 27,1985 LETTER FROM MAINE YANKEE TO THE NRC (90-19-06/07) t I
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F JRH 1 i
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RG 1.97 Cl POSITION INDICATION 1
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CR OPERATORS QUESTIONED DIMMED LIGHT INDICATION l
ENGINEEniNG !NVESTIGATED l
e RESEARCHED 1985 ENGINEERING EVALUATION i
A JRH-2 n..........
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l ROOT CAUSE EVALUATION
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ROOT CAUSE l
e FAILURE TO CONDUCT ADEQUATE REVIEW.
i e NO GUIDELINES WERE ESTABLISHED FOR CONDUCTING j
ENGINEERING EVALUATIONS.
CONTRIBUTING FACTORS:
e NO PROCEDURALIZED PROCESS, e INFORMATION PROVIDED WAS FOR VALVE CONTROL POWER.
e ISSUE DID NOT RESULT IN AN EDCR.
e INDIVIDUAL ENGINEER PERFORMED AN EXTENSIVE ASSESSMENT OF SOURCE DOCUMENTS.
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e INDEPENDENT SECOND VERIFICATION WAS NOT CONDUCTED.
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SAFETY SIGNIFICANCE
- INFORMATION SUPPLIED WAS CORRECT FOR VALVE i
CONTROL CIRCUlTS.
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- CONTAINMENT ISOLATION VALVES REMAIN OPERABLE -
FAILURE OF INDICATION DOES NOT PREVENT VALVE OPERATION.-
- ISOLATED CASE OF INACCURATE INFORMATION
- NO SAFETY ISSUE EXISTS.
DOES NOT IMPACT ON VALVE OPERATION.
DOES NOT IMPACT ON CAPABILITY TO ISOLATE CTMT DURING CIS EVENT.
l JRH-4
CORRECTIVE ACT!ON SUMMAFlY IMMEDIATE CORRECTIVE ACTIONS:
e NOTIFIED CONTROL ROOM PERSONNEL OF SINGLE FAILURE VULNERABILITY.
e REQUIRED ONCE PER SHlFT CHECKS OF LIGHT INDICATION OPERABILITY.
CORRECTIVE ACTIONS TO PREVENT RECURRENCE:
e INDEPENDENT REVIEW OF RG 1.97 IMPLEMENTATION ee CONTRACTED WITH COMBUSTION ENGINEERING eo PROCEDURALIZE THE CE RG 1.97 REVIEW ee SCHEDULED FOR COMPLETION IN EARLY 1991 e ENHANCED TECHNICAL REVIEW OF NRC SUBMITTALS eo PLANNING SESSION CONCEPT INSTITUTED IN EARLY 1989.
l l
ee DEVELOP PROCEDURALIZED PROCESS FOR ASSESSING COMPLEX ISSUES.
- AUDIT OF SIMILAR MAINE YANKEE SUBMITTALS SINCE 1982 l
ee 1,556 SUBMITTALS BETWEEN JANUARY 1982 AND JANUARY 1990 l
ee SIMILAR TECHNICALLY COMPLEX SUBMITTALS WILL BE REVIEWED FOR TECHNICAL ACCURACY JRH 5
, -~ _.
L..
1 i
IMPROVEMENT OPPORTUNITIES i
LESSON LEARNED / IMPROVEMENT OPPORTUNITY i
ee SELF-IDENTIFIED' e
SIMILAR IMPROVEMENT OPPORTUNITIES i
DESIGN BASIS RECOVERY i
es PROCUREMENT PROCESS ENHANCEMENTS ee INTERNAL / EXTERNAL SSFl'S INDUSTRY INITIATIVES -
ee CONFIGURATION MANAGEMENT
)
CHANGES ARE AN ONGOING PROCESS PROACTIVE/R'. ACTIVE CHANGES
/
eo ee CONSTANTL'/ IMPROVING OUR PROCESSES
.l
- l JRH -
)
l I
i i
SUMMARY
i ENVIRONMENTAL QUALIFICATION OF LIMIT SWITCHES (90-19-04):
e DRAIN HOLES IN SCOTCHCAST SEAL e
RESTORATION OF EQ ENCLOSURE
.i e
ELBOW FITTING INSTALLATIONS t
j GDW-1
~
.. ~ - - - -..
t 1
I DRAIN HOLES DRAIN HOLES WERE NOT REQUIRED FOR ORIGINAL QUALIFIED INSTALLATION.
QDR UPGRADE INCLUDED TESTED CONFIGURATION WITH DRAIN-HOLES.
PREVIOUSLY ADDRESSED IN IR 87-16.
EVALUATION PERFORMED AND RESULTS INCLUDED IN QDR.
OPEN ITEM CLOSED IN IR 89-16.
EVALUATION IS CONSISTENT WITH NRC APPROACH REGARDING IN 89-63 ISSUES.
EQUIPMENT IS QUALIFIED IN ACCORDANCE WITH 10 CFR 50.49 l
c GDW 2
i i
l-1 2
j 1
I i
l
\\
1 4
i RESTORATION OF EQ ENCLOSURE l
)
INFORMATION NOT AVAILABLE AT TIME OF NRC INSPECTION.
e DOCUMENTATION AVAILABLE THAT CONFIRMS PROPER INSTALLATION.
e LIMIT SWITCHES MET 10 CFR 50.49 REQUIREMENTS.
l i
I i
l GDW-3
l j
l i
ELBOW FITTING INSTALLATIONS i
NAMCO QUALIFICATION TEST REPORTS REQUIRED ENCLOSURE INTEGRITY TO BE MAINTAINED BY LICENSEE THE SPECIFIC SEALANT WAS NOT SPECIFIED.
FITTING'S WERE SEALED AT INSTALLATION.
i F.QUIPMENT MET VENDOR REQUIREMENTS.
EQ FOR ENCLOSURES MAINTAINED.
4 l
GDW-4 l
j k'
l i
l CORRECTIVE ACTIONS RE: LIMIT SWITCH FAILURE (90-19-05):
l I
e ROOT CAUSE OF PD-A 122 (OCTOBER 1990) FAILURE WAS NOT SAME AS PS A 20 (FEBRUARY 1990).
l e
CORRECTIVE ACTIONS TAKEN FOR PS-A 20 WERE PROMPT AND THOROUGH.
o VOLUNTARY EQUIPMENT UPGRADES WERE COMPLETED DURING
'90 REFUELING AND OTHERS WERE PLANNED FOR '90/'91.
GDW-5
~..
i I
i o
l l
CONCLUSION i
l l
e PROACTIVE IN MEETING EQ REQUIREMENTS.
{
e EQ ISSUES ARE AGGRESSIVELY PURSUE'D AND RESOLVED.
l NORMAL OPERATING ISSUE NOT AN EQ ISSUE.
e LIMIT SWITCHES MET 10 CFR 50.49 REQUIREMENTS.
I CORRECTIVE ACTIONS TAKEN FOR FEBRUARY 7,1990 LIMIT e
SWITCH FAILURE WERE PROMPT AND THOROUGH.
o OCTOBER 17,1990 LIMIT SWITCH FAILURE SELF-IDENTIFIED NOT RELATED TO FEBRUARY 7,1990 FAILURE PROMPTLY CORRECTED ADDITIONAL ACTIONS PROACTIVE AND' CONSERVATIVE e
INDICATION ONLY AFFECTED - VALVE OPERABILITY NOT AFFECTED.
e MINIMAL SAFETY SIGNIFICANCE e
NO ESCALATED ENFORCEMENT ACTION WARRANTED.
i
=. =..
l 1
l I
REGULATORY GUIDE 1.97 IE POWER SUPPLY (90-18-06 AND 07) l ORDER REQUIRED:
1)
SUBMIT A REPORT...
2)
IMPLEMENT UPGRADES...
e BOTH PROVISIONS WERE MET.
e EVALUATION ON WHICH REPORT WAS BASED AND SUBSEQUENT ERRONEOUS SUBMITTAL TO NRC RESULTED FROM PERSONNEL ERROR.
e MINIMAL SAFETY SIGNIFICANCE SINCE INDICATION ONLY WAS AFFECTED AND NOT VALVE OPERABILITY.
i e
SELF-IDENTIFIED e
ERROR WAS PROMPTLY RFPORTED.
e DEVIATION WITH REG GUIDE 1.97 WILL BE CORRECTED.
AGGRESSIVE ACTIONS TO SEARCH FOR ANY SIMILAR OCCURRENCES.
e ACTIONS UNDERWAY TO PREVENT REOCCUFIRENCE.
NO ESCALATED ENFORCEMENT ACTION WARRANTED.
.