ML20133B425

Ack Receipt of Forwarding Myap Response to Rept Issued by NRC Independent Safety Assessment Team

ML20133B425
Person / Time
Site:	Maine Yankee
Issue date:	12/31/1996
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Frizzle C Maine Yankee
References
NUDOCS 9701030173
Download: ML20133B425 (4)

Text

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December 31, 1996 l Mr. Charles D. Frizzle President and Chief Executive Officer Maine Yankee Atomic Power Company 329 Bath Road Brunswick, Maine 04011

Dear Mr. Frizzle:

This letter is to acknowledge the receipt of your letter of December 10, 1996, forwarding Maine Yankee Atomic Power Company's response to the report issued by the U.S. Nuclear Regulatory Commission's Independent Safety Assessment (ISA) Team. The NRC staff will be reviewing the details and conclusions presented regarding each of the inspection findings along with the evaluation of your proposed corrective actions.

The NRC staff also looks forward to your participation in the briefing of the Commission on January 9, 1997, on Maine Yankee's corrective actions in response to the ISA findings.

Sincerely, 1

originalaloned by i James M. Taylor James M. Taylor Executive Director for Operations DISTRIBUTION:

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DOCUMENT: G:\DORMAN\GT96958.GRN *See Previous Concurrence j To receive e copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = -

Copy with attachment / enclosure "N" a No copy 0FFICE PM:DRPE PD4-2:LA l DD:DRPE D:DRPE l ADPR I NAME DDorman:* EPeyton* JZwolinski* SVarga* RZimmerman* I DATE 12/23/96 12/23/96 12/23/p6 12/23/96 12/27/96 0FFICE OGC D:NRR EDO X l NAME JGoldberg FMiraglia* JTay lbr DATE 12/ /96 12/30/96 12/ M /96 0FFICIAL RECORD COPY 030017 9701030173 961231 PDR ADOCK 05000309 m m COPY (J P PDR

Mr. Charles D. Frizzle -

President and Chief Executive Officer Maine Yankee Atomic Power Company /

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329 Bath Road /  !

Brunswick, Maine 04011 /

Dear Mr. Frizzle:

This letter is to acknowledge the receipt of your-letter of December 10, 1996,

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forwarding Maine Yankee Atomic Power Company's respon'se to the report issued by the U.S. Nuclear Regulatory Commission's Inde 'ndent Safety Assessment (ISA) Team. The NRC staff will be reviewing th f details and conclusions presented regarding each of the inspection find ngs along with the evaluation of your proposed corrective actions. N The NRC staff also looks forward a to your p/'rticipation in the briefing Commission on January 9,1997, regardin jNaine Yankee's corrective actions in response to the ISA findings. /

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/ Sincerely,

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,' James M. Taylor I

/ Executive Director for Operations j DISTRIBUTION:

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l EDO Principal. Correspondence Control FROM' DUE: 01/02/97'- EDO CONTROL': 'G960958 DOC-DT: 12/10/96 FINAL REPLY:

.Chcrles D.' Frizzle '

Mains Yankee

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Chairman Jackson l FOR' SIGNATURE' OF : ** GRN **

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Executive Director DESC: ROUTING:

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" i INDEPENDENT SAFETY ASSESSMENT Ltr only:

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_DATE 12/19/96 ,

ASSIGNED TO:. CONTACT:

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j SPECIAL INSTRUCTIONS OR REMARKS: .

NRR RECEIVED:- DECEMBER 19, 1996 .

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OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-96-1239 LOGGING DATE: Dec 16 96 ACTION OFFICE: EDO AUTHOR: CHARLES FRIZZLE . l AFFILIATION: MAINE ADDRESSEE: CHAIRMAN JACKSON LETTER.DATE: Dec 10 96 FILE CODE: IDR-5 MAINE YANKEE

SUBJECT:

INDEPENDENT SAFETY ASSESSMENT 1 ACTION: Signature of EDO DISTRIBUTION: CHAIRMAN, COMRS, OGC, SECY l SPECIAL HANDLING: SECY TO ACK CONSTITUENT:

NOTES: PREPARATION OF RESPONSE FOR COMMISSION MEETING OCM  !

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i MaineYankee REll ABL E E LE CT RICilY SINCE 1972 h#7  !

i Charles D Frizzle 329 Bath Road Brunswick, Maine 04011

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' President and Chief Executive Officer

, (207) 798-4100

). December 10,1996 l j- MN-96-183 CDF-96-192 j L l j- i i  ;

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UNITED STATES NUCLEAR REGULATORY COMMISSION  !

! Chairman Shirley A. Jackson .;

- Mail Stop O-16 G15 l One White Flint North i

. I1555 Rockville Pike  !

j. Rockville MD 20852-2738 l i

References:

(a) License No. DPR-36 (Docket No. 50-309)  ;

. (b) Letter, S. A. Jackson (USNRC) to C. D. Frizzle (Maine Yankee), dated  !

] October 7,1996 - Independent Safety Assessment

SUBJECT:

Independent Safety Assessment '

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Dear Chairman Jackson:

' i j This letter and enclosures comprise Maine Yankee's response to the report of the l Independent Safety Assessment Team (ISA).

As you asked in your letter of October 7,1996, we are presenting Maine Yankee's plans l l for resolving the concerns identified in the ISA report, and for addressing the root causes the [

l team described. We appreciate the opportunity to respond directly to the Commission.  !

I At the outset let me state that the ISA was a significant learning experience for me and l

[ for the organization as a whole. We appreciate the thoroughness, rigor and faimess of the l i

inspection. Although the report confirmed that Maine Yankee is operating safely, the report's j . conclusions that performance is average or slightly below average and declining, and its  !

documentation of significant deficiencies indicate that we need to make substantial r improvements.

l l Root Cause Assessment l- Shortly after receiving and individually reviewing the ISA the senior officers of Mame ,

Yankee met in a day long session to review, as a team, the ISA. The purpose was to make sure  ;

L we fully understood the report, especially the root causes. - In that session we conducted an assessment of the report in light of other known performance evaluations. As a result, let me say r

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MaineYankee UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183

' Attn: Chairman Shirley A. Jackson Page 2 l

plainly: Maine Yankee agrees with the ISA report, and agrees with the root-causes of 1) l- economic pressures and 2) weaknesses in problem identification and correction resulting from

complacency and a lack of a questioning attitude. The ISA report confirms our own analyses on l a number ofissues that were under study shortly before the ISA team began its work and for which we were in the process of developing improvement initiatives and underscores the need for major changes.

While safety has always been our first priority, a close s.econd has been our gongern for economical energy production. As the ISA report observes, the close focus on cost and competitive standing fostered an attitude of complacency in the sense of tolerance for non-urgent conditions that eroded our standing in the industry. That decline ultimately degraded the public and regulatory confidence upon which this industry depends, and must be reversed.

Maine Yankee is committed to liecoming an industry-leader in safety, design integrity, and equipment performance. Now, and in the months ahead, actions will support the words of this letter.

Part of our response will be to address the specific concerns of the ISA report. But the ISA team identified broad, corporate-culture issues that require more than a laundry list of ~

specific remedial actions. They require a basic rethinking of Maine Yankee's operating philosophy.

Corrective Actions The following corrective actions, which are described more fully in the formal response attached, have been developed in response to the root causes identified.

We have developed an Excellence Action Plan to address the root causes described in the ISA report and in our self-assessments. That program includes creating a Nuclear Oversight Committee at board level staffed by an independent expert advisory committee; appointing _

fgrmer.NRC Director of_ Nuclear Reactor. Regulation, Dr. Thomas E. Murley, to the Boar d_of _

Directors; adding high-level expert staff, including a new Vice President of Licensing and Regulatory Compliance; a third party review to assess the ability of each officer and manager, and plans to make personnel changes as appropriate; and reevaluating and retraining supervisors.

We are also increasing staffing in Engineering and Maintenance.

With respect to financial resources, Maine Yankee began development of an integrated Business Plan, with budgeted initiatives in August 1996. The proposed 1997 budget has been l developed in parallel with the development of the Business Plan, and represents a fundamental l departure from past budget development practices. In particular, the proposed 1997 budget has been developed by identifying and prioritizing activities, including corrective actions and

MaineYankee j UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183 Attn: Chairman Shirley A. Jackson Page 3 l l

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improvements, deciding which activities should be implemented, and then pros iding the I necessary funding, rather than starting with budget targets and then identifying and prioritizmg  ;

activities. . As a result of this new process, which has been endorsed by the Board of Directors, Maine Yankee's budget for 1997 is $27 million more than would have been the case had we followed past practices. ]

l Additionally, in 1995, Maine Yankee initiated a major reengineering ofits existing  !

problem identification, task tracking, and corrective action processes. As a result the " Learning  !

Process" was developed to improve problem identification and the corrective action programs for l Maine Yankee. The Learning Process was recently completed, with implementation scheduled for January 1997, and as a result, Maine Yankee is consolidating its corrective action programs into a single system for identification and tracking of problems, screening of problems for operability and reportability, prioritizing problems for corrective actions and assigning responsibility and accountability. We believe that this will enhance problem identification given its availability to all workers and ease of use, and improve the quality of corrective actions.

Maine Yankee is also making improvements in each of the principal areas of weakness identified by the ISA. For example:

• MggigImorovement Program - Maine Yankee is developing a design and operating margin review program to identify existing margins on important issues.

Where margin improvements are determined to be warranted, appropriate plant upgrades will be provided. Plant upgrades to the containment spray and service water systems have already begun. In light of the ISA findings regarding margins, Maine Yankee will not seek approval to return to 100percentpower operation until this margin improvementprogram has been completed.

• Hacklog Reduction - Maine Yankee is developing a program to reduce engineering and maintenance backlogs to minimal levels within the next two cycles of operation. This program will necessarily rely on contracted resources.

Permanent staffing increases in engineering and maintenance will be authorized to prevent the buildup of excessive backlogs in the future.

• Licensing and Desien Basis - In May 1996, Maine Yankee initiated a Configuration Management Improvement Initiative to verify conformance with the licensing basis, enhance configuration management controls, and improve 50.59 safety evaluations. Additionally, Maine Yankee has initiated a Safety Analysis Information Document (SAID) Program to identify the bases for operator-controlled plant parameters in a single set of documents. Although begun prior to the ISA Maine Yankee believes these efforts will address issues raised by the ISA.

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MaineYankee UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183 Attn: Chairman Shirley A. Jackson Page 4 1

= Operations - Maine Yankee has reassessed each of the operator workarounds'

' individual and collective impact on operators during emergency conditions. At i this time there is not a single or collective workaround interaction that would significantly challenge operators under postulated accident conditions. Of the 13 workarounds identified by the ISA, eight have been addressed to remove the burdens on the operator and five are being addressed and will be resolved no later than the 1997 refueling outage. In the future Maine Yankee will seek to keep operator workarounds to a minimum and will routinely evaluate the single and collected effects of necessary workarounds.

• Maintenance and Testing - Maine Yankee is taking actions to improve its testing program, including reviewing existing test procedures to ensure that they are sufficient to verify the safety functions of systems, structures, and components, and prcviding training in evaluation of test results. Maine Yankee is also taking steps to improve material condition, such as issuing guidelines for identification of material condition problems and establishing teams to reduce maintenance backlogs to minimallevels.

• Engineering - We are creating, and by December 1997 will have established, a system engineering group to increase engineering ownership and accountability and to improve resolution of problems.

We are also integrating this corrective program within the broader Maine Yankee Business Plan now being dralled. Both the Excellence Action Plan and the Business Plan will be  !

driven by this thought: From this point forward, Maine Yankee's management focus will be on excellence which we believe is best defined as a SALP 1. We will focus on assuring that these plans are well implemented such that obvious improvement in performance is demonstrated to regain the trust and respect of the public and the regulators. .;

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We are designing systematic protocols to measure progress and the effectiveness of our corrective actions and to identify necessary refinements as this work progresses. We are  !

committed to open communication on these points with our regulators and other constituencies, ,

and welcome the opportunity to hold periodic management meetings with NRC staff to review l our progress.

l The Board of Directors recognizes that implementing an excellence strategy will, in the  ;

near term, increase budget requests submitted to them. But they have also expressed their firm commitment to support the actions necessary to fully address the root causes. The Board shares the view that focusing on excellence is the best long-term strategy to secure safety and cost l efficiency.

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'l UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183' i Attn: Chairman Shirley A. Jackson Page 5 L

Maine Yankee is taking the ISA report very seriously, not simply because it is a f l regulatory document, but because it is an accurate assessment of conditions we recognize must  ;

be addressed. Our past performance demonstrates that Maine Yankee employees are capable of.  !

world-class achievements. The findings of the ISA report and our self-assessments are sobering i

reminders that we have slipped below that potential. We will not let that happen again. We will not settle for being " adequate." We will strive to improve performance. SALP "1" is our goal.

The enclosed response provides a discussion of the root cause analysis, corrective actions  !

for root causes and Maine Yankee's actions to remedy specific ISA deficiencies. The response i also includes 1) the Excellence Action Plan; 2) a summary of the Business Plan; 3) Yankee  !

Atomic's plan to corret deficiencies; 4) Maine Yankee's actions to address specific ISA findings; l and 5) clarifications of statements in the report.  !

We look fonvard to the opportunity to brief the Commission and its staff on our response and to answer any questions you may have. We also hope to provide regular progress reports on our plans for improvement to the Region and NRC staff, as appropriate.  :

Yours truly, u 6y Charles D. Frizzle ,

President and Chief Executive Officer CDF/ dip  !

Enclosures

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MaineYankee  !

i UNITED STATES NUCLEAR REGULATORY COMMISSION MN-96-183 )

. Attn: Chairman Shirley A. Jackson Page 6 l

c: Commissioner Kenneth C. Rogers  !

Commissioner Greta J.Dicus  !

Commissioner Nils J. Diaz  ;

Commissioner Edward McGaffigan, Jr.  !

Mr. Edward L. Jordan, Director, Office for Analysis & Evaluation of Operational Data Mr. James M. Taylor, Executive Director for Operations Mr. Leonard J. Callan, Regional Administration, Region IV

< Mr. Frank J. Miraglia, Acting Director of NRR Mr. Hugh L. Thompson, Jr., Deputy Executive Director for Nuclear Material Safety / Safeguards and Operations Supports Mr. Hubert J. Miller, Administrator, Region I Mr. Ellis Mershoff, Region II, Deputy Director, Divieion of Reactor Projects Mr. Samuel L. Collins, Deputy Regional Adminise stion, Region IV Mr. John A. Zwolinski, Deputy Director of Reactor Projects Mr. J. T. Yerokun, NRC Resident Inspector Mr. D. H. Dorman, NRC Project Manager Mr. Uldis Vanags, State Nuclear Safety Advisor Mr. Patrick J. Dostie, State Nuclear Safety Inspector Honorable Angus King, Governor, State of Maine  !

Thomas M. Allen, Congressman-elect John E. Baldacci, Congressman William S. Cohen, Senator Susan Collins, Senator-elect James B. Longley, Congressman Olympia J. Snowe, Senator I i

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i RESPONSE TO THE i

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ASSESS MENT ,

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~ TABLE OF CONTENTS l l t Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i l L  :

1 Section 1 - Root Cause Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1  ;

Section 2 - Corrective Actions for Root Causes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 }

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. Section 3 - Corrective Actions for Specific Major ISA Deficiencies . . . . . . . . . . . . . . . . . . 3-1  ;

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Section 4 - Corrective Actions Required to Assure l

. Long-Term Resolutions of the Deficiencies . . . . . . . . . .. . . . . . . . . . . . . . . . . . . 4-1 l I

Enclosure 1. . . . . . Maine Yankee Excellence Action Plan 1 Enclosure 2 . . . . . . Maine Yankee Business Plan Summary 1 i Enclosure 3 . . . . . . Closcout Plan for Yankee Atomic Electric Company q l

i Enclosure 4 . . . . . . Actions Associated with ISA Requests for Information Enclosure 5 . . . . . . Actions Associated with ISA Report Statements j i

j Enclosure 6. . . . . . Actions in Response to Safety Assessment Observations i i

Enclosure 7. . . . . . Clarification of Statements in the ISA Report

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J INTRODUCTION i

1 Maine Yankee has considered the ISA's root-cause analysis in the context of third-party evaluations, j internal and external oversight activities, and self-assessment initiatives.  !

Maine Yankee fundamentally agrees with the two root causes presented in the ISA. The ISA Report accurately portrayed Maine Yankee's performance in the areas examined, and was consistent with the results of our own assessment conducted by the senior officer group after receiving the report.

Maine Yankee believes that if corrective actions are to be meaningful and lasting they must treat the i two ISA root causes together, and link them with other perfonnance issues.

The corrective actions presented here represent a fundamental change in Maine Yankee's approach  !

to conducting business. The comerstone for that transformation is the Maine Yankee Excellence l Action Plan, which aims to restore excellence in five areas: resource allocation, organizational i improvements, Board of Director oversight and involvement, program enhancements, and management performance and workplace culture. ,

Complementing the Excellence Action Plan, the Business Plan will define the specific goals on  ;

which the organization must focus to attain the vision established by the Excellence Action Plan and i this response. The Business Plan has been structured to provide for the development, l

- implementation, and monitoring ofinitiatives and actions needed to achieve those goals. That ,

structuring includes the corrective actions associated with resolution ofISA issues. As the single management tool for defining and communicating management's priorities and directing resources,  !

the Business Plan is closely linked to the budget development and approval process to ensure adequate resources are committed. The Excellence Action Plan was m. veiled October 9,1996, and ,

is presented in Enclosure 1. The Business Plan is in the final stages of reiincanent for I

implementation in 1997; the Plan summary is presented in Enclosure 2. The 1997 budget ensures that adequate resources are available for the actions and initiatives prescribed by the Business Plan.

The Business Plan and 1997 budget are available for review in their entirety at Maine Yankee's offices.

Maine Yankee's assessment has found that as the nuclear industry has matured over Maine Yankee's  :

l 24 years of operation, standards of performance and professionalism have risen steadily, and performance once considered exemplary is only adequate now. In some respects Maine Yankee has failed to stay abreast of advances in the industry, and our performance has fallen short of the current standards of excellence. Mere adherence to the requirements of the license basis or adoption of an

" acceptable" standard is unacceptable. We recognize that by standing still, we have fallen behind.

Hence, Maine Yankee's actions to address performance issues and their underlying causes, including those presented in the ISA Report, reflect our commitment to excellence and to restore margins of safety, design integrity, and equipment performance. We intend to monitor the 3 effectiveness of our plans for improvement and adjust accordingly. In this manner, Maine Yankee intends to reestablish full confidence among employees, regulators, and the public. '

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This response is organized as follows. Section 1 summarizes Maine Yankee's assessment of the root causes of the issues identified by the ISA, its own evaluations and oversight activities, and third- i party assessments, and concludes that the root causes identified by the ISA are consistent with the results.of Maine Yankee's own assessment. Section 2 describes Maine Yankee's corrective actions  ;

for each of the root causes discussed in Section 1. Section 3 describes additional actions that Maine  !

' Yankee is taking to resolve the principal deficiencies identified by the ISA. Section 4 describes the - 'l corrective actions for the long-term resolution of the deficiencies.

I This response also includes seven enclosures. Enclosure 1 provides the Maine Yankee Excellence

• o ment the clos pl forthe ec a an proc ss bserv t on s r I t to c es d analyses made by the ISA team. Enclosure 4 is a report from the ISA RFI database that links the long-term  !

action items from the RFIs with the Maine Yankee Task Tracking System (MYTTS). Enclosure 5 l provides a road map that interconnects statements, issues, concerns, and acknowledged follow-up  ;

actions from the ISA Report with tracking or closure documentation. Enclosure 6 provides a road  ;

map to allow tracking of the action statements made by Maine Yankee in the SAO summaries. l Finally, Enclosure 7 provides Maine Yankee's clarification of certain statements made in the ISA i Report.  :

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I SECTION 1 - ROOT CAUSE ANALYSIS

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l FIRST ROOT CAUSE: ECONOMIC PRESSURE The ISA Report stated:

" Economic pressure to be a low-cost energy producer has limited available resources to address  !

corrective actions and some plant improvement upgrades. Management has effectively prioritized l available resources, butfinancialpressures have caused thepostponement ofsome neededprogram improvement and actions. " i Discussion: ,

1 Maine Yankee identified four distinct, but closely related, factors constituting this root cause.

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1. Internal nressures to contain costs Pressures within Maine Yankee to contain costs played a larger role than external pressures. Among workers and managers, cost containment has been viewed as an indicator of sound resource management, and has been a source of pride. A traditional emphasis on self-reliance, and a reluctance to seek outside expertise, reinforced this cultural characteristic.

The cost-containment attribute of Maine Yankee's workplace culture had led to complacency in this sense: a reluctance to raise problems that an individual or group considered to be oflittle safety significance and too costly for a perceived marginal contribution to safety. This informal screening of problems led to a build-up ofissues considered to be oflow safety significance which did not receive formal evaluation, prioritization, or corrective measures. Other problems had received formal evaluation for corrective action, but were considered non-critical for safety and were characterized by implementation delays, extensions, or cancellations.

2. External economic nressures Emerging energy alternatives and deregulation of the electric generation industry in the U.S. have led to a competitive energy market affecting all producers, including Maine Yankee. In recent years management established priorities and made decisions that reflected external economic pressures.

3. Perceived inadeouacy of resources Those who self-screened problems and never raised them acted on two perceptions: low safety significance, and perceived unavailability of funds to address the problem. Those who canceled, deferred, or extended initiatives or corrective actions based their decisions, in part, on the same perceptions.

The Board of Directors has a consistent history of approving both routine and special budget requests without modification. However, officers routinely established budget targets based on their I-1

assumptions as to what the Board would find acceptable and what competitive pressures would permit. As a result, budgets submitted to the Board did not support all the work necessary to achieve excellence.

4. Resource utilization Overly conservative resource utilization is a product of the cost-contaimnent culture. Departments have routinely underrun both capital and O&M budgets to finish the year under budget.

With respect to the issue of ownership structure we respectfully suggest that Maine Yankee's non-traditional ownership structure and practice of not retaining earnings is not a contributor to the ISA's first root cause. Maine Yankee's FERC approved cost-of-service rate making formula allows current recovery of costs without a formal rate hearing. Under the FERC approved power contracts Maine Yankee bills all actual costs of operating the company monthly. The Company's approved rate consists, in addition to certain fixed costs, the actual cost of providing service each month, regardless of the production level of the plant. Moreover, other agreements require the owners to contribute capital as necessary. The ability to draw on the resources of ten owners provides a depth of available funds and fiscal flexibility; the actual limiting factor has been management's funding requests. See for more details.

SECOND ROOT CAUSE: PROBLEM IDENTIFICATION The ISA Report stated:

"There is a lack ofa questioning culture which has resulted in thefailure to identify orpromptly correct i sigmficantproblems in areasperceived by management to be oflow safety sigmficance. Management l appears complacent with the current level ofsafetyperformance and there does not appear to be a clear l

incentivefor improvement. " '

Discussion:

Maine Yankee identified six distinct contributing factors, many of which are linked to factors in the first root cause.

1. Resource shortfalls Resource shortfalls driven by economic pressures and cost contaimnent fostered a form of corporate complacency in the sense of a willingness to live with problems considered to be oflow safety significance. While there arc examples of complacency there are also areas where Maine Yankee has not been complacent, such as conducting the cultural assessment and steam generator inspections.

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2. Comolacency '

l Worker complacency reflected standards and expectations established by management. While there was organizational complacency, Maine Yankee's assessment confirmed the ISA's portrayal of a motivated and dedicated work force who base their safety ethic and operating philosophy on management's demonstrated threshold for action in response to problems.

. Insularity Insularity existed in certain functions, but did not pervade the organization. Our assessment found a history ofinteraction with industry leaders in important areas such as: steam geneetor testing, I reactor vessel management, plant operation, and use of probabilistic risk assessmer t (PRA) during operation and a risk management program during shutdown periods. Overall, however, Maine Yankee has not been sufficiently engaged in participating in INPO exchanges, industry panels and forums and benchmarking visits, and this situation contributed to a failure to keep pace with the industry's evolving standard of excellence.

4. Worker anprehension l

l Maine Yankee conducted a cultural assessment of the w orkplace which was completed in June 1996.

The cultural assessment found workers throughout the organization have become increasingly l

l concerned about the future of the facility. Apprehensive over the perceived threat of premature plant ,

shutdown, employees place undue emphasis on cost containment.

5. Accountability ,

l 1 Although accountability is evident in high priority, high-visibility projects, like the steam generator i sleeving, the executive assessment identified a marked reduction in accountability for items which

fell below the perceived safety / cost justification threshold. l l

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! 6. Administrative Obstacles  !

l Prior to the IS A, Maine Yankee identified a myriad of reporting and corrective action systems that were diminishing our ability to implement effective corrective actions. Like the ISA, we found evidence that individuals were confused or ineffective in their efforts to drive a problem to closure j using the existing administrative machinery.

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RELATIONSHIP OF THE TWO ROOT CAUSES We have determined that the two ISA root causes are inextricably linked and cannot be successfully ,

resolved if treated in isolation. There was always more work to do and problems to resolve than

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could be accomplished with the available resources. As a result, the organization placed great  ;

emphasis on resolution of high visibility, high consequence problems. When available resources  !

were exhausted, we allowed work regarded as not significant to remain undone. The situation was exacerbated by a workplace culture which emphasized prudent resource utilization and cost containment as necessary to remain competitive in the energy market. When workers saw backlogs I build up they saw little value in reporting additional problems perceived as insignificant, thereby ;

further exacerbating the appearance ofinertia and complacency. That backlog of unresolved l

problems reflected an organizational complacency marked by lack of a questioning attitude and )

resulted in the diminished operating margins observed by the ISA.

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7 SECTION 2 - CORRECTIVE ACTIONS FOR TIIE ROOT CAUSES Following receipt of the ISA and our assessment of the root causes, Maine Yankee determined the j need for significant and meaningful corrective measures to restore margins and establish Maine i Yankee as an excellent performer. Some of the initiatives were commenced after receipt of the ISA, others before, but we believe all are responsive to the root causes.

ECONOMIC PRESSURE Maine Yankee is addressing the pressures to contain costs, the perceived inadequacy of resources and resource utilization concerns by providing additional resources and staffing, by fundamentally changing the budget preparation process, and by improving communication of management's position on the budget and pursuit of excellence. Each of these actions except communication, is discussed in more detail below. Communication is discussed on page 2-5.

1. Resourec 3deauacy Resource inadequacy and lack of a questioning attitude was evidenced by a declining material condition and an understaffed organization. Therefore, providing adequate resources is the prerequisite for all other actions. In a special meeting held on November 19,1996, the Board of Directors affirmed its commitment to provide the resources necessary to restore Maine Yankee's position as an industry leader. The Board has endorsed an increase of $27 million in the budget, over inflation for 1997. This represents an increase of 20 percent in non-fuel O&M for an outage year. The Board has conceptually endorsed further future outlays.

2. Budget Preparation The proposed 1997 budget, developed in parallel with the Business Plan and response to the ISA, represents a fundamental departure from past practices. Managers, working individually and r.s a management council, established appropriate corrective actions for known performance issues, including those derived from the ISA. The resulting comprehensive list of actions was prioritized with emphasis on safety and reestablishing performance margins in key areas. Thus, officers were able to demonstrate to the management group a willingness to review and to provide funding to lower the threshold for taking action on problems which, under past standards, would have remained ,

unresolved because of perceived low safety significance. At a meeting on November 19,1996, the Board endorsed this approach.

3. Staffing Maine Yankee initiated a staffing study in August 1996 in response to the findings of the Cultural Assessment, which indicated that inadequate staffing was contributing to performance erosion, particularly with respect to problem identification and corrective action. Maine Yankee established criteria for comparison based on three key measures of performance among industry leaders: SALP score, capacity factor, and non-fuel O&M costs. The study was performed by a nationally recognized consulting firm specializing in nuclear utility staffing, and was completed on December 2-1 J

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! 2,1996. The consultant's report indicated staffing, particularly in the Engineering and Maintenance 1

organizations, was below that of the industry's leaders. Maine Yankee is completing officer and ~

manager review of the consultant's findings, and will prepare a comprehensive resource reallocation

{ plan for 1997. Staffing needs will be addressed in 1997.  !

i Ma ine Yankee will provide the appropriate employee and contractor staffing to perform the work .

needed to regain and maintain the excellent performance previously achieved. We have determined . -

. the need for two categories of additional staff

contracted individuals with select skills or expertise i  !

deployed promptly on deferred or extended projects and permanent employee positions to the extent  ;

necessary to maintain excellence and prevent backlog growth and margin erosion.' Most additional resources will be deployed in engineering and maintenance assignments. Although the exact number l of additional positions has not been finalized, the projected increase represents a substantial merease i j in total staffing.  ;

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[ PROBLEM IDENTIFICATION i i

l Maine Yankee is addressing the root.cause involving problem identification and corrective action by

improving personnel performance and organizational and programmatic effectiveness in identifying l l and resolving problems. Each of these is discussed in more detail below.  ;

i 1. Manacement Assessment i 1- t

.. Maine Yankee has recognized the need for effective leadership and management competence as '

i' . prerequisites for restoring the utility to a leadership position in the industry. Toward this end, by i i April 1997, the Maine Yankee Board of Directors will complete an assessment of each officer's  !

j ability to contribute to a successful transformation of the company, including problem identification j i and resolution. Each manager will likewise be evaluated by a third party screen reporting to senior l management by April of 1997. This effort will be expanded to include all management personnel by

January 1998. Maine Yankee will also use a third-party assessment to screen new supervisors and l l managers. Following this series of assessments the Board is prepared to take the appropriate actions  !

to ensure confidence that a management team and structure is in place which will function at the required high level during this important phase in the life of the plant. ,  !

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2. Supervisorv Effectiveness

! Maine Yankee began a series ofleadership development workshops in August 1996. To date,35

supervisors have participated. Sessions are introduced by an officer who communicates the

significance of the supervisor's contribution to a successful recovery of our leadership position.

i Each workshop has as its underlying theme effective situational leadership and development of an l

approach to supervision which emphasizes coaching and teamwork. We believe this will enhance

problem identification by improving their ability to respond to workers. All supervisory personnel are scheduled to complete the training by June 1997. A continuing supervisory education program i i will be developed by June 1997.

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3. Team Development Maine Yankee expects to continue to rely heavily on multi-discipline, cross-organizational teams to tackle specific issues. (However, to increase accountability, every effort at Maine Yankee will have an individual assigned as responsible.) Maine Yankee began in August 1996 to implement a series of two day workshops designed to transform groups ofindividuals into a highly effective focused 1 work group. To da:e 30 employees have been through the training. The workshops are scheduled to continue in 1997.

4. Individual Development  ;

To promote more effective individual performance. Maine Yankee has begun a series of three-day workshops based on Stephen Covey's Seven Habits of Highly Effective People, conducted by experts from the Stephen Covey firm and available to all Maine Yankee employees. This training will be strongly encouraged for all supervisory and management positions and available to the balance of the employee population. Maine Yankee's goal is to have 50 percent ofits employees complete this training by December 31,1997.

5. Worker Anxiety Maine Yankee is developing an aggressive communications campaign to address what has become known among workers as "end-of-life" concerns. Sponsored by Maine Yankee's Human Resources Department, the effort will begin in January,1997 to communicate the company's plans in areas of employee interest, such as retention programs, severance packages, retirement and benefit options, out placement services, and projected staffing during decommissioning. As applicable, programs will be incorporated in Company Manuals and Handbooks by January 1998. This is intended to l address end oflicensed life as well as a premature shutdown. i

6. Worker Performance Evaluation Maine Yankee will make substantive changes in the employee performance-appraisal process for all  !

employees to ensure that the organization's new values, higher standards, and expectations of a questioning attitude are reinforced and personal accountability is emphasized. The appraisal forms will be tailored to craft, non-union / administrative and professional / exempt. In 1997 supervisors will be evaluated on their performance in the area of" employee relations" and encouraging an open and questioning environment, with emphasis on the application of skills leamed in the supervisory development workshops described above. The full scope of revisions will be announced in January 1997 following completion of a review by an employee team.

7. Margin Imorovements Program Maine Yankee will develop and complete a design and operating margin review to identify any areas j where the margins, although adequate, do not satJsfy today's standards of excellence. Where margin improvements are determined to be warranted, appropriate plant upgrades will be provided. Mainc Yankee will not seek approval to return to 100 percent power operation until this margin improvement program has been completed. We believe that this effort will address the problem of a i

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lack of a questioning attitude by forcing ourselves to ask questions about the adequacy of margins. It is also a resource issue in that it will likely cause improvements where none were previously planned.

8. Worker Compensation Maine Yankee has revised its middle-management compensation program to significantly reduce reliance on incentive-based compensation. Implemented in 1996, the incentive-based program replaced traditional overtime compensation for middle managers with an annual bonus tied to predefined performance goals. The effect created tensions which distracted from the efficient and effective completion of work. Maine Yankee recognized that to meet the challenge of restoring our leadership position we must have the full support and committed involvement of n iddle management and first-line supervision. On November 3,1996, Maine Yankee reduced the incentive-based compensation program and restored overtime compensation for 225 non-exempt employees.

In addition, on November 14,1996 there was an early distribution ofincentive-based bonuses earned in 1996. By January 1997, Maine Yankee will refine the remaining incentive programs to ensure the appropriate focus on pursuit of excellence.

9. Board of Directors Initiatives The Board established a vision and priorities for Maine Yankee when it published the Excellence Action Plan on October 9,1996. The Plan, with which management is in full agreement, expanded the Board's membership by adding Dr. Thomas E. Murley as a Director and member of the Nuclear Committee of the Board. The Board also strengthened its oversight ability by expanding the role of the Nuclear Oversight Committee. These improvements should make the Board more effective in identifying and resolving problems. The Plan also approved creating new officer and manager positions. The search for these individuals is under way. The role of Human Resources has been expanded and that function now reports directly to the president. The Excellence Plan provides for added resources and enhanced programs in maintenance, engineering, and safety analysis. The Plan' also emphasized the role of the Business Plan, restructured the Worker Concern Program, and stressed the importance of supervisory development. See Enclosure 1.

10. Learning Process The Learning Process, described in more detail in Section 4, has been developed over two years to address the fragmentation and duplication found in earlier corrective action programs. It is scheduled to begin in January 1997. The Learning Process is a corporate-wide, comprehensive, software-driven process that incorporates all aspects of corrective action including problem entry, risk / priority screening, graduated evaluation response, task tracking, reporting and trending. The process emphasizes ease of use, universal access, traceability of tasks to issues, clear ownership and accountability and a mechanism for communicating lessons learned throughout the organization.

The system is expected to contribute to increased accountability and ownership, casier problem identification, a structured and consistent approach to evaluation and prioritizatior of problems, and enhanced tracking and trending. Properly applied, the process will contribute to deelopment of a questioning attitude. Maine Yankee plans to conduct an assessment of the Learning Process implementation by a third-party expert during the second quarter of 1997.

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11. Business Planning The Business Plan has been developed on a parallel path with the ISA response and the 1997 proposed budget and is scheduled to be fully functional as a management tool for 1997. The Business Plan provides for integrated planning, and serves as the single vehicle to establish and communicate the vision, goals, and priorities of the organization. The initiatives featured in the Business Plan, and the tasks specified to make those initiatives a reality, include identified performance issues. Issues from the ISA have been integrated into the attached Business Plan summary.

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12. Communication Clear, consistent communication is necessary to change the culture throughout the company from one of cost constrained, but safe operation, to one which emphasizes pursuit of excellence. Maine ,

Yankee has developed an internal communications plan to provide the model and structure for '

communicating the fundamental change of direction and provide timely and relevant information to

, workers. The plan calls for expanded officer visibility and accessibility, increased use of supervisors as communicators, periodic briefings, and expanded use ofinternal media.

13. Yankee Atomic Interface As more fully discussed in July 1996 in a meeting with the NRC staff, Maine Yankee has s strengthened certain processes and refined aspects of the working relationship between the two companies. Improvements are underway to strengthen accountability and coordination between the two companies. Maine Yankee believes that strengthening accountability and coordination will enhance problem identifications and corrective actions.

14. Benchmarking To ensure a clear understanding of the standards of today's industry leaders. Maine Yankee envisions an ongoing program of visits to other plants which we have already begun and will continue throughout 1997. To enhance our skills in financial management, Maine Yankee has also joined the Electric Utility Cost Group in January 1996 and exchanges information with other utilities in the area of budgeting. l

15. Worker Concern Program The President commissioned an evaluation of the prognun by a group of employees in August 1996 I to establish a standard of excellence. That evaluation has been completed and the recommended )

improvements in the area of problem identification and program utilization will be adopted. The program administrator will be upgraded to a full time position responsible for promoting the use of the program among employees and contractors no later than March of 1997. The part time administrator will continue in his role until the full time administrator is hired. Performance measures intended to communicate information on the nature and extent of concerns have been developed. The revised program emphasizes supervisory training and awareness and the use of performance indicators as an important means to provide early notification to management of 25

emerging problems and trends. All supervisory workers will receive training on encouraging and evaluating worker concems. The training will be concluded by June 1997.

16. Resnonse to the Cultural Assessment In 1995, senior management at Maine Yankee initiated a third-party Cultural Assessment to I determine whether and to what extent Maine Yankee may have a culture that discourages employees ,

from raising concerns. The Cultural Assessment Team issued its report in 1996, which identified a number of findings. As a result, Maine Yankee established a Cultural Assessment Response Team to address these findings.

The Cultural Assessment Response Team was comprised of ten members which included employees from the craft, staff, management, and external consultant experts. Their charter was to validate, provide oversight, and effectively integrate initiatives in the implementation of the Cultural . l Assessment team corrective actions to ensure maximum organizational effectiveness and efficiency. 1 The team's recommendations, which have been approved for implementation and have been factored I into the Business Plan, are described throughout the ISA response and include such things as the worker concem program changes, the compensation changes, end oflife committee, and the  ;

supervisory effectiveness training described above. l CORRECTIVE ACTION ASSESSMENT The Business Plan and the Learning Process will facilitate detailed tracking of the commitments outlined above and those provided in the remainder of this response. As part of the Business Plan development, specific performance indicators are being developed to permit monitoring of our i progress in pursuit of excellence and our commitment to follow through. Finally, the Maine Yankee l Quality Programs Department, working with the Maine Yankee Nuclear Safety and Audit Review Committee and the newly formed Nuclear Oversight Committee of the Board, has been tasked to develop an integrated audit and review program to periodically assess the effectiveness of these corrective actions and suggest improvements as appropriate. We intend to develop performance measures which will assure that the plans under development result in lasting improvement. If we do not see lasting improvement then the corrective actions will be adjusted accordingly.

SUMMARY

Maine Yankee agrees with the two root causes discussed in the ISA. Maine Yankee recognizes that l its willingness to forego the pursuit of excellence in order to maintain its economic position has led to the acceptance of conditions that are inconsistent with striving for excellence. Recognizing the potential for eroded operational margins, Maine Yankee is committed to giving priority to achieving excellence in all phases of our operations, while continuing our responsibility to the people of New England to operate as efficiently as possible. Toward that end Maine Yankee has constructed a comprehensive plan of corrective measures in the key areas of maintenance and testing, engineering, licensing and design basis, operations and self assessments and corrective action. Additional resources will be aggressively managed to obtain the desired changes, an approach that is consistent with our public commitment to the citizens of Maine to operate the plant safely or not at all.

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We will identify the industry standard of excellence and hold management and workers accountable for achieving that standard. We will ensure that a qualified management team and a functional organizational structure is in place, and will clearly and consistently communicate management's standards and expectations. We will develop and support a supervisory group which understands and endorses senior management's vision for the company and translates that vision into improved performance in our shops, plant, and offices. We will revise the threshold for taking action on problems, thereby ensuring that problems with the potential to erode safety will receive prompt, effective resolution without undue concern for costs.

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1 SECTION 3 - CORRECTIVE ACTIONS FOR SPECIFIC MAJOR ISA  !

DEFICIENCIES l l

Introduction l J

On October 10,1996, the ISA held a public exit at Maine Yankee regarding its inspection j findings. The NRC further reviewed these findings at an October 18,1996, Commissioner's meeting and discussed the issues they viewed as being the most significant. Maine Yankee has ,

addressed or is addressing each issue raised in the ISA Report. For purposes of this section, we j i have focused on the significant issues raised during the Commission meeting. This section l presents the specific near-term, compensatory, interim, and/or long-term actions to resolve the specific performance issues identified by the ISA. These items are grouped in the categories of material condition, equipment performance, and design / licensing and operability issues. We believe the actions described in Section 2 of this response will prevent recurrence of the deficiencies noted herein.

All remaining issues identified by the ISA Report are being addressed and records of specific actions taken or planned are available on-site for NRC review. A matrix which identifies the ISA Report issues and provides corresponding follow-up tracking system numbers is provided as Enclosure 5.

Material Condition Items Corroded CCW Pining Inside Containment The ISA noted external corrosion on carbon steel PCCW piping inside containment, a condition which was identified and periodically monitored by Maine Yankee before ISA. Although piping integrity is not at issue, Maine Yankee had developed a multiphase project to replace the PCCW piping inside containment with stainless steel. The first phase replaces that pipe with the most extemal corrosion, and the pipe associated with the reactor coolant pump (RCP) scheduled for replacement in 1997. This pipe represents about 30 percent of the effort, and specifically includes replacement of the following during the 1997 refueling outage:

- PCCW inlet and outlet piping for penetration coolers 32,45,47,55,64,54,65, 53,66,29,30,31,46,62, and 9.

i . PCCW inlet and outlet piping for containment air recirculation fan coolers 1 and '

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• Flanged PCCW piping from valves PCC-421 and PCC-422 up to their flanged connections to the various RCP #2 coolers. In addition, a drain valve will be added to the PCC piping.

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• The second phase includes the PCCW inlet and outlet piping to air recirculation fan coolers 3,4, 5, and 6 and is scheduled for completion during the 1999 refueling outage. The balance of the affected piping will be replaced during subsequent outages.

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Maine Yankee will continue monitoring PCC pipe condition until completion of PCC piping replacement.

Service Water Bav/ Circulating Water Pumn House Material Condition In response to initial ISA walkdown concerns, Maine Yankee conducted an expanded inspection to comprehensively assess material condition elsewhere in this building. Maine Yankee has completed a number of corrective measures including:

. The bearing lubrication systems (primary and backup) for all four SW pumps have been evaluated. The results showed that the as-found piping and supports met code allowables for all loading conditions including a design basis seismic event.

• Six degraded supports have been completely removed (including concrete anchors) and replaced with a more rugged design. The modified hangers have been coated with epoxy suitable for protection in the pump house's environment.

. One new support has been added on P-29C's bearing lubrication system to enhance that system's seismic performance.

• The accessible SW pump anchor bolts have been torque tested and the heads cleaned and sealed to prevent water intrusion. A preventative maintenance (PM) instruction has been initiated to ensure the seals' integrity and effectiveness are maintained.

. The circulating water pump house has been painted. An epoxy coating has been applied to the floor and component bases for protection against salt water.

. Personnel safety improvements are being implemented. The catwalk handrails buween the SW and cire water bays have been enhanced. j 1

The analysis performed to verify the adequacy of the SW bearing lubrication systems also indicated that enhancements could be made to increase the systems' design margin. Based on the results of the analysis, walkdown inspections, and SW system modifications planned prior to IS A, Maine Yankee plans to implement the following during 1997:

. Three existing supports on P-29A and two additional supports on P-29D will be removed and replaced with new material.

. One new support will be added on each of the SW pump bearing lubrication system to increase the design margin.

. The bearing lubrication system for P-29B and P-29C will be reconfigured and simplified under EDCR 95-31.

. Flange bolts on the SW system will be evaluated and will be replaced as required 3-2

with material better suited to incidental contact with salt water.

Containment Housekeeping '

ISA observations inside the containment indicated that housekeeping required greater attention to eliminate foreign material or items left over from maintenance activities. Specific issues were items wrapped in unqualified plastic and the presence of discarded tape. During follow-up inspections, Maine ' Yankee also found uncontrolled tools in the containment. Although Maine Yankee had protected against any significant safety impact of these materials (such as sump clogging), these findings were not acceptable from a commitment to excellence perspective.

The items identified by the ISA were removed or evaluated and determined to be acceptable before the plant returned to power from the August 1996 shutdown. Additionally, Maine Yankee conducted an expanded containment cleanliness inspection and resolved identified issues, including removal of an uncontrolled operator aid in the containment stairwell. Maine Yankee has implemented an initiative to replace the plastic contamination-control material utilized on large, non-standard equipment with high-temperature plastic. Our goal is to ultimately eliminate the plastic wherever possible. Where contamination levels cannot be reduced to acceptable levels, only high iemperature plastic will be used in configurations evaluated to ensure that a safety concern does not exist. This effort will be completed by the end of 1997 refueling outage.

The plastic cmrently used in containment has been evaluated and found not to constitute a safety concern. Additionally, the containment inspection procedure (Procedure 1-200-11) has been upgraded. Applicable maintenance work practices will be revised to maintain appropriate cleanliness as emergent work is performed after containment closcout inspections are completed.

Revisions and training will be conducted by June 1997.

Small Leaks in Lines Covered by the Erosk n/Corrosien Program Notwithstanding Maine Yankee's adherence to its Erosion / Corrosion Program, the ISA team noted that there had been six small leaks since 1981 in high energy piping. After the identification of the leaks, repairs were made and inspection procedures were revised to enhance visual inspections.

Additionally, the ISA noted several small leaks in swondary high pressure drain system lines to the main condenser. These lines are under vacuum and the leaks posed no personnel or nuclear safety concerns. Nonetheless, these occurrences are considered unacceptable from an industry excellence perspective. Maine Yankee has been replacing these lines during refueling omages .

and several of these lines were replaced during 1995. Maine Yankee plans to continue te replace these lines based on their safety significance and impact on plant performance. Also, the ISA Report noted that components related to the high pressure drain trap TR-15 in the main steam system had not been replaced even though a work order to accomplish the work had been i prepared. In fact, TR-15 and the piping downstream ofTR-15 had been replaced with improved  !

maerials under Work Orders 91-7202 and 94-2568 during the 1992 and 1995 refueling outages.

Enhancements to the Maine Yankee Erosion / Corrosion Program are discussed in Section 4 of this response.

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1 Equipment Performance Issues l Ooerator Workarounds Maine Yankee assessed the impact of operator workamunds individually upon identification or creation. The management team also assessed the most significant items periodically at morning I management meetings to ensure appropriate priority and timeliness of resolution. The manner in ,

which these items were managed and resolved, however, was not consistent with achieving l performance excellence and suggested a management process that was willing to live with the

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situation that created the workaround. Maine Yankee has reassessed each of the operator workaround's individual and collective impact on operators during accident conditions. At this time, based on our review, we conclude there is no single or collective workaround interaction j that would unreasonably impede the operator's ability to perform under accident conditions. -

Maine Yankee recognizes the importance of promptly resolving identified operator workarounds, and additional programmatic measures will be taken to incorporate industry guidance relative to definition of workarounds and standards for timeliness of resolution, and to implement a formal ,

process for reviewing the aggregate affect of workarounds by March 1997.

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Maine Yankee has made or is planning to make design or equipment changes to correct each of the thirteen most significant workarounds identified by the ISA.

l The following provides the current status of these changes:

1. Motor-driven main feedwater pump trip i

The operator would have to attempt a second start if P-2B tripped on low lube oil pressure during l

an attempted start. Such a trip occurred three times in the last 21 start attempts during the past j five years. The apparent cause was loose lube oil pump suction flange nuts and deteriorated saction flange gaskets that allowed air to be drawn into the lube oil suction piping when a feedwater pump start was attempted. These specific deficiencies have been corrected (WO 96-2622) and the same work is being performed on P-2A during the ongoing pump overhaul.

2. RH-4 leakage This item was resolved on August 22,1996 when the valve was replaced (on WO 96-2879).

3. Slow response of main feedwater pump P-2B recirculation valve The apparent cause of the slow response was resolved when the valve positioner was replaced on August 1,1996 (WO 96-256) with a positioner having high temperature components to increase longevity (TE 130-96). Additionally, to optimize performance, work orders have been prepare /

to install low friction valve packing and to replace FIC-1302A&B recirculation controllers with a new type of controller with enhanced response. This work is scheduled to be completed no later than the 1997 refueling.

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4. Leakage past . main feedwater regulating valve bypass valves  ;

i This item was resolved on August 9,1996, when the bypass valves' bench set was changed from  !

40-60 psi to 52-72 psi as supported by Technical Evaluation 141-96. [

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5. Inability to control CEAs in manual sequential mode due to computer overload problems. l t

During the controlled plant shutdown ofJuly 20,1996, the plant computer overloaded when ,

operators attempted to drive rods in manual sequential mode. It is important to note that operators responded to the overload consistent with their training, and at no time was plant safety compromised. This overload was caused by two unrelated events occurring simultaneously. The i first was ongoing chattering of a single sequence of events (SOE) point which caused the plant process computer to' process many erroneous transition messages in a short time. This  ;

phenomenon has overloaded the plant computer system in the past. This capacity deficiency I I

presents a commitment-to-excellence issue (rather than a regulatory requirement issue), and requires correction.

l The long-term corrective action for this problem is to upgrade the hardware and software which handle the point processing. This upgrade was designed prior to ISA. as a phased project calling for incremental upgrades across several cycles, with completion scheduled for Cycle 16 (1999).

As an interim measure, a software modification was installed on September 9,1996 to suppress the erroneous messages when chattering was detected. This modification has been tested with eight simultaneous chattering SOE points, which were adequately suppressed. Maine Yankee has not experienced more than two simultaneous chattering SOEs in the past, and therefore, the software modification has resolved the impact of chattering on the plant computer. The work tracking document for this change was Computer Services Problem Report Form 2-96-030, Work Order 96-2927.

The second contributing factor was processing of the rod motion indications for multiple groups when the operators were moving CEAs in manual sequential mode. The effect of sixteen input points all signaling rod motion at the rate of one state change (each step) for each rod each second taxed the already burdened computer. This phenomenon has typically slowed the response time of the computer, forcing the operators to pause during periods of continuous rod motion. The permanent fix to this problem is part of the phased upgrade described above, specifically to install redundant CPUs connected to the computer's front end system to receive inputs such as CEA rod steps. This portion of the computer upgrade will be completed in 1997.

Until that effort is completed, operators will continue to manually control rod movement (manual l

- group or individual mode), as required.

6. Protected switchgear room ventilation l

Before the ISA, Maine Yankee's IPEEE review identified ventilation design concerns m a i number of plant compartments including the protected switchgear room. The ventilation systems j were not required to be safety related plant systems in Maine Yankee's original design and i licensing, but through regulatorv evolution, have risen in importance in the drive to improve margin. For the switchgear room ventilation system, once the design vulnerabilities were identified, Maine Yank:e instituted compensatory measures. These included improved 3-5

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y monitoring instrumentation for control room operators, improved procedures and administrative -

. controls in the event of system failures. Based upon further evaluation, additional compensatory  :

. measures were adopted in 1996, which included blocking inlet and outlet dampers open, and the  !

recire damper shut, to maximize cool air flow into the room. These measures minimize the

i potential impact on ambient temperatures in the switchgear room due to a postulated high energy i line break in the adjacent turbine building. This matter has been documented in letters to the ~ i l Staff dated August 14,1996 (MN-96-114) and November 18,1996 (MN-96-154).  !

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Design work for permanent modifications is now under way which will include installing of a ,

! dedicated independent and redundant ventilation system outside the turbine hall to support the  ;

j protected switchgear room and the battery room. The new system will be powered from l

!~ independent, safety-related buses. This design upgrade is scheduled for completion during 1997.

l 7. Battery room ventilation i '

- Battery room ventilation is supplied via the protected switchgear room ventilation system.

! Battery room ventilation upgrades will be completed as described immediately above.  !

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8. Emergency diesel room ventilation .j 4 l

Before the ISA, Maine Yankee determined that the emergency diesel room ventilation supply i j and exhaust dampers were not capable of operating against the high differential pressure that -

would be generated by a tornado. Similar to the protected switchgear room ventilation system,

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original design of this ventilation was not required to be safety related and tornadoes in the )

vicinity of the diesel rooms were not considered credible. The dampers were not, therefore, i i designed to operate against the differential pressure conditions of a tomado Recently, Maine )

Yankee identified this potential vulnerability and decided that, regardless of the low likelihood of tomados in the area, it ought to be corrected. As a result, the dampers were blocked open during summer months. A justification for removing the blocking device based on the low probability of a tornado occurring in the winter has been prepared.. This is consistent with the current version of the Standard Review Plan. During the period when tomados do not occur in this region (i.e., winter and fall) the system has been returned to its normal configuration. The dampers will again be blocked open during periods of higher tornado probability. A design modification to replace the existing damper system with one qualified to operate against differential pressures which could be experienced during a tornado will be completed in Maine

. Yankee's subsequent operating cycle (cycle 16). At this time, this workaround has been resolved.

9. Containment spray building ventilation (exhaust fans FN-44A/B) i This operator workaround has been resolved by installation of mechanical stops and by l disconnecting the damper actuators to eliminate the risk of unintentional closure of the inlet dampers. Permanent resolution of this matter will be completed in 1997.

10. Turbine building flooding i

Before the ISA, Maine Yankee's IPEEE review had identified potential turbine building internal 3-6

flood mitigation concems. Compensatory measures were instituted, such as blocking the roll up i doors open five inches from the floor. Permanent modifications include increasing the berm height to the cable vault (complete) and to the control room, installation of turbine building flood relief panels, and installation of a flood channel to carry intemal flood water away from the i turbine building. Additionally, a circulating water pump trip circuit with turbine building flood level switches is planned to be installed during the 1997 refueling outage. The increased height berm for the control room, the new flood relief panels and installation of the flood water channel are currently under way with completion scheduled for early 1997. Upon completion of this effort, this workaround will be removed.

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11. Remote isolation of a ruptured steam generator i

Under the current design, operators in bunker gear must manually close the appropriate stop '

check valve to isolate a steam generator that has a ruptured tube (SGTR). A design change is i under way for implementation during the 1997 refueling outage which will replace the existing valves with new motor-operated valves, thus allowing isolation of the affected steam generator from the control room. Maine Yankee's plans for resolution of this matter were previously j

provided to the Staff by letter dated October 3,1996 (MN-96-142). <

12. Steam generator atmospheric steam dump valve capacity i

As reported to the NRC in a letter dated October 3,1996, (MN-96-142), Maine Yankee is now l

engineering physical modifications to the atmospheric dump valve (ADV) system. These l modifications include the installation of an ADV with a steam relief capacity of approximately l 560,000 lb/hr at 900 psig main steam pressure in parallel with the existing ADV with a capacity of approximately 280,000 lb/hr. The new ADV system will have excess capability to mitigate an I inadequate core cooling event with loss of offsite power. The design change is now under way I and installation is scheduled for completion during the 1997 refueling outage. At that time, this  !

workaround will be resolved. j l

13. Offsite power supply capability As stated in the ISA Report, during a periodic grid voltage study, Maine Yankee identified a more limiting offsite power transient than had previously been considered. Specifically, Maine Yankee found that should a plant trip occur with a safety injection actuation signal (SIAS) and l with an automatic initiation of a motor-driven main feedwater pump, load studies concluded that power being supplied fiom one of the two offsite 115kV lines would not be sufficient to prevent offsite reserve power from being disconnected and loads being automatically transferred to the two diesel generators under limiting conditions. Upon identification in early 1996, administrative controls were established to address the potential event sequence. To address the long-term issue, Maine Yankee has initiated a design change to the start circuitry for the motor-driven feed pumps (P-2A, B) to prevent automatic start with an SIAS present. This modification is scheduled for completion during the 1997 refueling outage. At that time, this workaround will be resolved.

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AFW Pump Reliability The ISA reported that the conditional probability for the steam driven auxiliary feedwater pump (P-25B) completing its demand mission was low. Maine Yankee, through its Maintenance Rule equipment performance monitoring program, had previously concluded that the pump's reliability was low and unacceptable. As a result, a multi-disciplinary team comprising Operations, Maintenance, and Engineering personnel was established to develop short-term and  :

. long-term reliability improvements for P-25B. Additional tasks for the team include: monitoring an accelerated testing program, identifying currently outstanding corrective actions, and implementing those actions deemed to be essential and achievable in the short term. The short-term improvements are scheduled for completion by the end of 1996; the long-term improvements will be scheduled using the Learning Process prioritization criteria. Short-term improvements include: improving testing instrumentation to improve performance monitoring, upgrading the existing controller, correcting lube oil leaks, repairing a lube oil pressure gauge and a lube oil temperature gauge, and developing preventive maintenance enhancements for govemor oil and turbine oil. The above actions, although not under way prior to the ISA, would have been performed as P-25B was categorized by Maine Yankee as an A(1) component under Maintenance Rule.

Component walkdowns have been conducted by the Maine Yankee multi-disciplinary team and ,

by an INPO Assist Team. The results of the walkdown have been incorporated into the short/long-term improvement lists.

Design / License Basis and Operability Issues Raised The ISA Report stated that Maine Yankee's licensing basis was understood by the licensee but lacked specificity, contained inconsistencies, and had not been well maintained. Maine Yankee has embarked on a continuing improvement program to correct the deficiencies noted in the ISA ,

Report and to improve Maine Yankee's overall performance in this area. Actions under way i relative to licensing basis improvements are discussed later in Section 4 of this response. Maine Yankee will be responding to the October 9,1996,10CFRQ50.54(f) letter, which will provide, among other things, Maine Yankee's action plan for ensuring design basis adequacy. Operability i related issues raised during the ISA Commission meeting are discussed below.

I Ventilation Systems i

I Maine Yankee acknowledges that the overall design and material condition of the ventilation systems need continued management attention to enhance margin. Also, the Maine Yankee PRA l supports the need for added attention in this area. Accordingly, Maine Yankee has implemented i a number of actions since 1992. The background research for the Ventilation Design Basis Summary Document (DBSD) is nearly complete and the DBSD is scheduled for completion in August 1997. A vertical audit of ventilation systems will be completed in December 1996, including those systems reviewed by the ISA, as well as others associated with safety-related equipment. ,

Recent activities completed for ventilation systems include upgrading of the design basis for the i protected switchgear room, turbine hall, diesel generator room, containment spray building, and 3-8

the emergency feedwater pump room. Temporary improvements have been completed in the turbine building and protected switchgear room as compensatory measures to support the upgraded design basis. Permanent modifications were completed in the emergency feedwater pump room in early 1996. M;ine Yar.kee has begun a modification to provide a redundant and independent protected switchgear room ventilation system outside the turbine building. This system is scheduled to be installed in 1997. Design and replacement of the containment spray building heating and ventilation unit (HV-7) were under way during the ISA and are scheduled for completion by December 1996.

As stated earlier, procedure changes have been completed to ensure that the diesel generator room dampers remain capable of providing ventilation under tornado atmospheric conditions consistent with methodology prescribed by the Standard Review Plan; and long-term modifications are planned.

1 Logic Circuit Testing  ;

i At the time of tha ISA, Maine Yankee had begun evaluation of the adequacy of system logic l circuit testing in accordance with Generic Letter 96-01. As a result of a deficiency noted by the l ISA, Maine Yankee expedited portions of that review which identified similar concerns in other circuits including a wire cut and removed from the A-train safety injection actuation signal (SIAS) circuit. Maine Yankee then undertook an effort to validate the logic circuit testing procedures to demonstrate that logic circuits required to be tested by the Technical Specifications were adequately tested, and to ensure circuit safety functions were demonstrated satisfactorily. .

The details of this testing program were communicated to the NRC by letter dated August 23, 1996 (MN-96-123). Specifically, Maine Yankee reviewed procedures for circuits identified in I Generic Letter 96-01, which included nine circuits, each with multiple activation paths.

Appropriate logic circuit tests were performed and, as described in the ISA Report, three additional equipment deficiencies were identified. These deficiencies were corrected prior to plant startup.

In order to address long-term issues associated with this matter, Maine Yankee convened an Event Review Board which completed its review in September 1996 to investigate the SIAS cut wire. The Board concluded the most likely cause of the event was accidental cutting and partial removal of an incorrect wire during planned removal of spare wires from the main control board during the 1990 or 1992 refueling outage. A root cause evaluation to determine why existing surveillance procedures did not provide adequate functional testing to uncover the existence of the missing wire is under way with completien planned for January 1997. Additionally, Maine Yankee plans to reevaluate the adequacy oflogic system testing and resolve any outstanding issues in conjunction with our response to GL 96-01. This was communicated to the Staff by letter dated August 24,1996 (MN-96-130).

RWST Level Transmitters As discussed in the ISA Report, Maine Yankee identified a service life concern with the level transmitters for the RWST due to an incorrect heat trace setting. The transmitters were replaced during the ISA to resolve the immediate concern. Maine Yankee reviewed heat tracing circuits 3-9

on safety-related equipment and found that no similar conditions existed. A long-term action to develop a calibration program for temperature controls in heated enclosures containing safety-related instrumentation is scheduled for completion by June 1997.

Sorav Pump NPSH The ISA Report stated that the ability of the containment spray system to provide a reliable supply of water during the recirculation phase of a LOCA was not adequately demonstrated for operation at power levels above 2440 MWt due to concerns about inadequate net positive suction head (NPSH) for the containment spray pumps.

Maine Yankee was licensed with permission to credit containment intemal accident pressures in spray pump NPSH calculations and Maine ' Yankee has done so to demonstrate adequate NPSH I availability. But, the margins available, even when crediting intemal pressure, are low, and Maine Yankee had begun steps before the ISA to address this condition. The pump's ,

manufacturer has been consulted and has concluded that the low NPSH conditions would not be l detrimental to the pump or its continued reliability. Maine Yankee has decided to increase  ;

containment spray pump NPSH margin by lowering the impeller elevation. This project will be j completed prior to Maine Yankee seeking approval for return to 100 percent power.

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Eauinment Oualification-Submergence l As reported to the NRC on September 30,1996 (MN-96-120), Maine Yankee identified 30 components that were not qualified for submergence, but were installed below the potential flood level inside containment. While most of the components satisfied their 10CFR50.49 function prior to becoming submerged, all of the components were Regulatory Guide 1.97 components required for post-accident indication. Maine Yankee has relocated twelve items above the

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containment flood line and has provided justification for operation of the remaining items. The  ;

balance of the remaining items will be evaluated and corrected as necessary during the 1997 refueling. I I

l A departmental root cause evaluation has been completed and a supplemental plant root cause i evaluation to confirm the departmental findings has been perfonned and is in final review. I Corrective actions to prevent recurrence are being developed and Maine Yankee will notify the i NRC regarding these actions. Additionally, an independent assessment of the EQ Program using I recognized industry experts is under way and will be completed by December 31,1996. l SWOPI Recommendations The 1994 Service Water Operational Performance Inspection (SWOPI), conducted by Maine Yankee and observed by the NRC, identified more than 155 issues and made nine recommendations related to the SW, PCCW and SCCW systems. Following the SWOPI, Maine Yankee committed to resolving all follow up actions by the end of the next cycle, expected to occur in mid-1996. Due to the extended shutdown in 1995, that same cycle (Maine Yankee's current) is now expected to end in 1997 and all remaining items are scheduled to be completed.

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1 3-10

Control Room Positive Pressure Test The October 31,1995, control room ventilation test results showed a slight negative differential pressure (d/p) between the control room and adjoining rooms or buildings, which suggests a test failure. Maine Yankee performed further analyses and calculations at that time to verify operability based on estimated in-leakage and subsequent radiological dose limits. Based on these analyses, the system was determined to be operable.

l Further review of the October 31,1995 test results and suppoding engineering analytical documentation during the ISA raised additional questions about the operability determination.

Maine Yankee re-performed the test on August 17,1996, with the control room ventilation system in the emergency mode as it would be in the applicable design accident conditions. The test results indicated positive pressure and demonstrated operability.

It appears that the most likely cause of the October 31,1995 negative d/p test result was that the ventilation lineup did not coincide with the appropriate emergency mode lineup. A root cause investigation is ongoing to determine the cause of the test failure. The root cause corrective actions and the necessary procedure revisions, as appropriate, will be completed before the next scheduled control room ventilation test. The test is currently planned for the 1997 refueling shutdown.

Service Water and Comnonent Cooling Water Margin The ISA expressed concern with available margins for the service water, component cooling, and RHR systems. Maine Yankee's calculations for these systems are performed using methods and assumptions that maximize the heat input to the component cooling water system (CCW) from RHR and minimize the heat rejection to the service water system. Operational limits are then derived for the service water system to ensure the systems are operated within the calculation model. These limits are, therefore, established to maintain CCW temperatures within acceptable limits. Maine Yankee continues to believe that system capacity is acceptable at full power.

Nonetheless, we agree that the calculation model does not explicitly account for all instrument uncertainties and that performance testing to date is inconclusive due to the low heat loads and low temperature differentials available for testing as compared to the design conditions. Maine  !

Yankee has evaluated the issues from the ISA and self-assessments, and has developed initiativas aimed at improving and verifying system margins. The following improvements are completed j now or are scheduled for completion during 1997. i l

• Modify testing instruments and improve test methods and instrument calibration processes to reduce uncertainty.

• Install a CCW heat exchanger bypass valve automatic trip to assure full heat I exchanger flow during postulated accident conditions.

+ Improve ultimate heat sink calculations to more clearly document conservative assumptions.

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. Completed a technical evaluation for the CCW flow tests and confirmed the 3-11

i systems operated within analysis / calculation assumptions.

l i Develop a preventive maintenance work instruction to provide for periodic  ;

calibration of heat exchanger temperature control valves, positioners, and i associated temperature controllers to assure reliable operation.

t In addition, an integrated evaluation of the existing heat exchanger testing program and associated instrumentation will be performed with specific focus on instrumentation adequacy  !

I and location; instrument uncertainty determination; correlation of assumed / calculated fouling factors to actual conditions; test methodology and trending of results; and inputs and i assumptions related to heat loads, flow rates, etc. Upon completion of the integrated evaluation, j necessary actions will be implemented to improve the testing and evaluation program as well as making equipment changes, if applicable, to gain additional design margins. This work will be l completed during 1997.  ;

i The initial phase of the integrated evaluation was an independent assessment by EPRI of heat  ;

exchanger models for the limiting heat exchangers (inboard SW). 'With this review, EPRI i validated Maine Yankee's models used for testing and safety analysis in that they produced i essentially identical results to EPRI hand calculations. Some minor changes to Maine Yankee's models will be made, and a similar evaluation of the remaining heat exchanger models and {

requisite changes if any will be completed during 1997. l Overall, Maine Yankee plans to demonstrate adequate margin for this system prior to seeking l NRC approval for return to full power.  ;

i Turbine Building HELB  !

! l l The ISA reiiewed Maine Yankee's ongoing activities to address turbine building high energy l line break (MELB) issues identified in early 1996 as part of Maine Yankee's IPEEE review. To l date, Maine Yankee has conducted analyses for the summer and the winter turbine building ventilation ccnfigurations. For the present winter configuration, temporary modifications and ,

compensatory actions are in place to adequately mitigate the affects of a postulated HELB in the turbine building. This matter is discussed further in a Maine Yankee letter dated November 18,  ;

i 1996 (MN-96-211). i Permanent modifications being designed and implemented in the turbine hall include: ,

a New protected switchgear room ventilation outside of the turbine hall ,

• New remotely-operated valves to allow remote actuation of fire main cooling to EDGs F

= Installation of turbine hall siding pressure relief panels  ;

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I . Reinforcement of unprotected switchgear room masonry wall to withstand HELB

. pressures s 3-12

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e Remotely-actuated or automatic dampers for post-HELB turbine hall ventilation [

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. Upgraded motors for CCW systems l

. Install qualified solenoids to trip CCW HX temperature control valves l The above actions are scheduled to be completed during 1997 or as equipment can be procured.

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4 l-1 3-13

l SECTION 4 - CORRECTIVE ACTIONS TO ASSURE LONG-TERM RESOLUTION OF  !

THE MAJOR ISA DEFICIENCIES l

Introduction i Maine Yankee examined possible trends ind!cated by the problems identified by the ISA and l those known from other sources. We identified five key dimensions of our performance which (

warranted aggressive, comprehensive steps to achieve improved performance. When fully l implemented, the actions specified below are expected to ensure long-term resolution of problems in these key performance areas. These improvements relate to the areas of l maintenance and testing, engineering, licensing and design basis, operations, and self-assessments and corrective actions. Maine Yankee's principal actions to achieve improvements  ;

in each of these areas is discussed below. j 4.1 Maintenance and Testing  !

The ISA identified weaknesses in testing, including inadequate scope, lack of rigor in the content of the tests, weak evaluations of test results, and the lack of an Air Operated Valve (AOV) testing l program. The ISA also identified weaknesses in Maintenance, including declining material conditions and inconsistent equipment material reliability. Maine Yankee's improvements i l

related to each of these weaknesses is discussed below.

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i Testing Improvement Program J Maine Yankee is committed to significantly improving the overall scope, technical adequacy, -l and methodology ofits testing program. This improvement effort will be implemented in I

conjunction with ongoing efforts such as the GL 96-01 logic testing review and the EPRI heat exchanger testing program evaluation discussed in Section 3 of this response.

The first objective of the program is to review the present scope of testing for completeness. The intent is to determine where the present scope of testing does not periodically verify or othenvise provide reasonable assurance that a system, structure, or component important to safety will perform its intended safety function as assumed in the safety analyses. This review will extend beyond the surveillance testing required by the Technical Specifications.

The second objective is to verify that the tests and surveillances presently used and any new test or surveillance developed as a result of the review of the first objective, are technically adequate and comprehensive. The effort will include, but not be limited to:

. Verification that appropriate design features are tested

• Verification of applicable license conditions

. Verification of appropriate plant conditions

. Appropriate QC involvement

. Adequacy of data collection requirements  ;

. Clarity of acceptance criteria and the resultant pass / fail criteria for test results

• Identification oflinks to other programs, such as ISI/IST, EQ, fire protection 4-I

A

' t the outset, a " Writer's Guide" for test procedures will be developed which captures the guidance established in the INPO " Good Practice" document on post-maintenance testing, MA-305; and the EPRI Testing Standard NP-72135, " Post-Maintenance Testing: A Reference Guide," and desirable characteristics from the industry based on benchmarking. The Writer's Guide would then be used as the standard against which Maine Yankee procedures are evaluated and revised.

Specific focus will be placed on ensuring timely review and resolution of test data, full evaluation of test results on component, system, and plant operations, and appropriate trending evaluations. Maine Yankee intends to utilize system engineers to maintain and oversee the testing program after the improvement phase is complete. The system engineers will be responsible for ensuring that procedures remain updated, post-maintenance tests are adequate, functional test instructions for design changes are adequate, as well as monitoring and trending test results as appropriate. A complete description of the system engineering program is provided later in this Section.

The first and second objectives above are scheduled to be completed in 1997 for Technical Specification and the Inservice Testing Program Components. The balance of the components will be scheduled consistent with completion of the implementation of the SAID, and tracked via the Business Plan.

AOV Program A program to ensure air operated valves receive adequate testing will be developed beginning in January 1997 and will incorporate the industry's best practices. Following program development, Maine Yankee will assemble or develop the necessary design information and expects to perform pilot testing during the 1997 refueling outage. This pilot is intended to verify and validate the program. Maine Yankee intends to perform periodic testing ofprogram valves during subsequent outages.

Backlog Reductinn Maine Yankee will develop a program by April 1997 to substantially reduce the backlogs in Maintenance and Engineering to minimal levels within two operating cycles. Maine Yankee currently does a good job working off high priority actions. The focus of this additional program is to reduce the outstanding low-priority maintenance work orders, outstanding engineering temporary modifications and " task tracking system" open items.

Plant Insnection Activities In November 1995, Maine Yankee re-introduced a program of Management Area Inspections (Procedure 22-100-01). This program requires monthly inspections by management personnel in specific assigned areas of the station. Every six months, the areas are rotated to provide for a fresh perspective. Discrepancies are assigned to responsible sections and are trended as a performance indicator.

The previously mentioned management inspections were largely housekeeping in nature, thus l

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additional action was warranted. Maine Yankee is evaluating lessons learned from recent benclunarking activities including the use of a dedicated plant housekeeping workforce. This concept as well as the results of other recent benchmarking efforts are being evaluated for implementation in 1997.

Many of the problems noted during the ISA were technical material condition-related problems.

On October 1,1996, Maine Yankee instituted a pilot program of system engineering inspections where plant engineers conducted detailed material condition inspections in a manner consistent with EPRI TR-104514,"How to Conduct Material Condition Inspections". The first round of system engineering inspections was effective in identifying conditions requiring ruolution and the follow-up actions have been collected for resolution. The process utilized dming this pilot will be transferred to the system engineering initiative in 1997 for selected systems. In the meantime, additional similar inspections will be conducted on a periodic basis by Plant Engineering and any identified discrepancies will be tracked through resolution.

Preventive Maintenance Imnrovements As part of the enhancements to improve material conditions, preventive maintenance (PM) implementation procedures for the Mechanical, Electrical, and I&C Maintenance sections will be revised to include definitions of accountability and expectations for PM updates. The centralized planning activities being implemented by the Maintenance Department will address coordination of PM among Maintenance sections. Maintenance and Engineering will develop a PM improvement plan for technical review of the Maintenance PM programs for critical equipment by the end of 1997. Engineering will take an active roll in the PM program review and implementation.

Predictive Maintenance Procram j Another facet ofimproving material condition is the formal establishment of a predictive maintenance program. One objective of the program is to improve plant safety and reliability by  ;

preventing equipment failures through early identification and diagnosis of equipment problems l or deterioration. Another is to reschedule major preventive maintenance tasks whenjustified by l state-of-the-art condition monitoring techniques. Maine Yankee began developing the program in March 1996 with the creation of the Predictive Maintenance Group in Plant Engineering i utilizing EPRI guidance and industry benclunarking. The group has determined which ,

technologies will be used and what hardware, software, human resources, and training will be )

required. Job functions, scopes, and responsibilities have been defined and five draft '

implementing procedures have been prepared. The program is scheduled to be fully implemented during 1997.

1 Erosion / Corrosion Control Program The ISA Report stated that the Maine Yankee erosion / corrosion program was adequate, but was difficult to assess because the common industry practice of using a computer-based program to determine inspection points was not being used.

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Development of an enhanced flow accelerated corrosion (FAC ) program began in April 1996. ,

The program is scheduled to be in place prior to the 1997 refueling. The enhanced program will provide a predictive approach to FAC instead of the inspection / trending approach now used.

When oompletely implemented, the new program will meet the guidelines of NSAC-202L, "Recommedations for an Effective FAC Program," published by EPRI and will utilize the EPRI CHECWORKS code, both of which are industry-accepted practices. The new program is being developed by an engineering consultant having industry experience with FAC. EPRI services have also been contracted to assist in the program development. INPO will perform an assist visit once the new program is in place.

The goal of the FAC Program is to prevent ruptures or leaks due to FAC that could cause personal injury, a plant trip, a safety actuation, or a plant shutdown. The program applies to the detection of pipe wall thinning due to FAC of safety-related and non-safety-related carbon and low alloy steel piping systems. Wear in vessels, pumps, valves, and other in-line components is included where plant and industry experience indicates a specific FAC problem.

4.2 Engineering The ISA identified some weaknesses related to Engineering, including inconsistent problem identification, inconsistent problem resolution, and limited ownership of programs. Maine Yankee is addressing these weaknesses in part by establishing a system engineering program.

This program is discussed below, together with Yankee Atomic's improvements in the Engineering Deficiency Report process. Additionally, the ISA identified weaknesses related to j environmental qualification. Maine Yankee's programmatic improvements in this area are also discussed below.

System Eneineering Grouo Maine Yankee is developing a System Engineering Group using guidance from INPO and from nuclear power plants with similar programs that are recognized as exceptionally effective. The system engineers will assess system performance to focus attention on problematic areas. <

System health reports will be submitted directly to upper management.

The basic concept is single point responsibility and accountability. Systems deemed " risk significant" by the Maintenance Rule will be assigned to system engineers. The system engineer will be responsible for a high degree of understanding on the system's design basis, design and specific component functional requirements. From this knowledge base, the system engineer will function as a technical resource and will have responsibility for ensuring high system reliability and performance.

The system engineer responsibilities are still under development, but tentatively include the following:

a Review and evaluate PM results, changes to the system (DBSD, operability determinations, technical evaluations, etc.), test results, changes in procedures associated with the system, and industry operating experience reviews 4-4

Track and trend corrective maintenance (evaluate combined effects of outstanding work), system performance, and performance monitoring as a part of the Maintenance Rule l

Establish, compile, track, and interpret performance indicators

• Conduct regularly scheduled, in-depth system walkdowns a Report to management regularly on system health Specify post-maintenance test requirementa and assist in planning /prioritization of maintenance Staff additions are being made to form the group. A Section Head and approximately ten

engineers will make up the group and are scheduled to be fully functional no later than the end of l 1997. The system engineering program will help improve problem identification an' resoluthn by engineering, and will enhance system ownership by engineering.

Yankee Atomic Engineering Deficiency Report (EDR) Process The EDR process at YAEC is defined and implemented through the existing procedure WE-109.

This process was established as a mechanism for the intemal reporting of errors associated with l the generation of the safety analysis calculations. Yankee Atomic self-identified in late 1995 that i the reportability threshold was too high for the results to serve as a performance or precursor l indicator management tool. Steps have been taken since early 1996 to informally lower the j reportability threshold. WE-109 was revised to reflect a formal lowering of the threshold; i appropriate training of personnel will be implemented by the end of December 1996. The impact of this lowered threshold has been seen in increased EDR generation since early 1996 and the l

l subsequent usage of the EDR reportability results as an appropriate management tool.

l t

l Environmental Oualification Program l

l A self-assessment (with assistance from industry recognized experts) of the environmental J j qualification (EQ) progrun is currently being conducted by a review team to evaluate the l continued effectiveness of Maine Yankee's implementation of the requirements of 10 CFR50.49, l and to identify any significant problem areas. Review team selection was based on both EQ j l experience and plant experience in the specific review focus areas. The primary focus areas of  !

this review are the design process, incorporation of EQ requirements in the operating plant, l i

maintenance of EQ equipment, and quality assurance. Each of the primary focus areas will be l l reviewed relative to EQ installations selected by the review team as representative of critical l equipment installed in the plant and the spectrum of EQ challenges known in the industry. l Examples include Limitorque operators, Rosemount transmitters, ASCO solenoid valves, l CONAX conduit seals, and NAMCO limit switches. A representation sample of several l equipment items reviewed in detail will be sufficient to evaluate the key aspects of the EQ j Program and provide insight into areas for improvement. Management will be notified about j areas ofimmediate concern identified by the team, along with recommendations for correction.  ;

Tracking the resolution of each open item will be the responsibility of the EQ Coordinator. l 4

In addition, the Master Equipment List will be revalidated by December 1998 to include all 4-5

relevant EQ information. A full-time engineer in the Plant Engineering Department will be designated as the EQ Program manager in 1997. This individual will be responsible and accountable for program maintenance.

4.3 Licensing and Design Basis The ISA identified some weaknesses related to the Licensing and Design Basis, including findings that the licensing basis lacks specificity, contains inconsistencies, and is not well maintained. Additionally, the ISA identified various deficiencies in design calculations and analyses. Maine Yankee's improvements related to these weaknesses are discussed below.

Marcin Evaluation and Recoverv ,

As indicated in the ISA Report, the operational and design margins have been found inadequate i for the NRC to conclude that plant operation at 100 percent power was warranted. In particular, the ISA noted that the power upgrades did not include adequate margin and design assessments.

Maine Yankee recognizes that the type of system operating margin associated with a small power level increase is difficult to quantify and inherently contains substantial uncertainties.

Maine Yankee also recognizes that the cumulative impact of power level increases on the design compliance and operability margins needs to be assured. We, therefore, are undertaking a comprehensive review and assessment of the Maine Yankee plant to both assure design compliance with the design basis and qualitatively evaluate available operating margins. This effort will be completed, and the results shared with the NRC staff, prior to Maine Yankee seeking approval for return to 100 percent power.

Adeauacy and Availability of Design Bases Informati20 Maine Yankee is currently in the process of responding to the 10 CFR 50.54(f) request from the NRC, dated October 9,1996, related to design bases information. The Maine Yankee descriptions and evaluations associated with this request will be comprehensive in defining and assessing the programs, processes, and procedures associated with the design bases development, design bases control, configuration control, and corrective actions in the event of design ,

discrepancies identified at Maine Yankee. l 1

As part of this response, Maine Yankee will be committing to the completion of our ongoing design bases recovery program.

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Configuration Management Imorovement Program In May 1996, Maine Yankee initiated a comprehensive reassessment ofits configuration management program to ensure it is current with industry standards. This initiative, called the Configuration Management Improvement Initiatives Plan, ensures the license and design bases  ;

documents are reestablished; and administrative controls are enhanced to maintain plant configuration current with license and design bases documents. Guidelines or checklists are being established to assist personnel in reviewing the license / design bases to assure completeness and consistency. The improvements to be made in the configuration management processes at 4-6

both Maine Yankee and Yankee Atomic Electric Company (YAEC) will also provide enhancements in the management of NRC commitments and in the safety evaluation /50.59 process.

One initiative is upgrading the Updated Final Safety Analysis Report (UFSAR)'to reflect current plant configuration, license bases, and design bases. An Engineering Division " expert team" has reviewed the UFSAR against guidelines, design bases, license bases (including license amendments), and engineering analyses. A " compliance expert team" is reviewing the UFSAR upgrade packages submitted by Engineering to assess changes for operability /reportability considerations and 10CFR50.59 compliance. The UFSAR was also reviewed to assure conformance with the Technical Specifications and the Tecimical Specification bases. The review of the UFSAR commenced in April,1996, and resulted in approximately 160 potential changes being generated to date, most of which will be resolved or incorporated by June,1997.

This will include those discrepancies identified as part of the ISA process. The review of the safety analysis section of the UFSAR continues and will be completed by the end of 1997.

Additional training in licensing and regulatory requirements will be provided to responsible personnel.

A second initiative is designed to maintain the UFSAR current through continued reviews of proposed changes by the " expert teams" and maintenance of the UFSAR in an electronic filing

. system to facilitate electronic scarching and network distribution. Administrative controls and procedures have been revised to assure that safety evaluations are submitted with all proposed changes and that operability /reportability is assessed as changes are submitted. Guidelines have been established to assist personnel in UFSAR reviews to assure consistency and completeness.

Improvements in the commitment management system have been initiated through a series of steps to re-identify commitments and assure continued confonnance with them. Currently, j docketed license and SER communications and correspondence are reviewed to identify commitments. SER's and related docketed information from 1982 through the present have been reviewed to ensure commitments to the NRC are being addressed by procedure or other active i control mechanism. The remaining SER correspondence from commercial operation date through 1982 is currently being reviewed. The review will also reassess compliance with NRC commitments for major license basis programs such as fire protection, Reg. Guide 1.97, the EQ  ;

program, HELB, etc. An NRC commitment change process based on NEI guidelines endorsed by the NRC has been developed to control changes to commitments.

Another facet of these initiatives has made enhancements to the safety evaluation /10CFR50.59 process. Improved 50.59 evaluations are expected through the use of enhanced inputs and assumptions processes, such as the SAID document discussed elsewhere in this report. A centralized and serialized file for 50.59 evaluations has been established, separate from the parent documents, to improve accountability and retrievability and to ensure annual reporting requirements are met. Appropriate distribution of completed 50.59's will be provided to ensure cognizant individuals are aware of changes that affect their areas of responsibility. Periodic training will be conducted to increase and maintain awareness of the conditions for performing l 50.59 evaluations with appropriate Maintenance and Operations personnel as well as with the  !

Engineering Dmsion. q l

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Additionally, configuration management initiatives at YAEC are being implemented to improve the control process for safety analyses by ensuring their compatibility with the design / license bases and ensuring compliance with regulatory requirements such as 10CFR50.46.

Administrative controls are being established to ensure YAEC personnel are aware of the regulatory requirements conceming the license / design bases analyses and that Maine Yankee is promptly informed of changes or discrepancies affecting the analyses.

The completion date for the configuration management initiatives is currently planned for the end of1998.

Methods Overview Manual In order to assemble and manage effectively the information, processes, commitments, and

. methodologies defining and controlling the performance of the FSAR Chapter 14 Safety Analyses, Maine Yankee will develop and implement a Methods Overview Manual (MOM). -

This manual, represented by a new set ofliving documents, will provide a cohesive reference resource for analysts in the cyclic assessment of the safety analysis transients. The MOM includes identification of key safety analysis inputs and parameters, methodology descriptions, references and overviews, identification and discussion of key phenomena and important assumptions for each safety analysis, code assessments ofimportant parameters, sensitivity studies, code SER limitations and methods of compliance, code benchmarking studies from YAEC and industry sources, and the results of peer reviews and assessments. All information currently being considered for consolidation into the MOM already exists in other formats and references. Completion of the initial issuance of the MOM as a living document is scheduled for the start of Cycle 16.

Safety Analysis Information Document (SAID)

When completed, the SAID will be the principal source document for the information necessary to ensure conformance to the safety analyses. It will serve as a reference for both plant personnel and safety analysts. Operating limitations will be provided for safety significant parameters that are cross referenced to applicable analyses. Information will be provided for each analysis that includes analysis assumptions for applicable parameters. The SAID is designed to accomplish the following in a single document:

• Provide a means for directly comparing plant operations and equipment performance to safety analysis assumptions,

. Allow comprehensive evaluation of the margin of operational flexibility within the safety analysis envelope, and

. Serve as a common reference source for operating procedure review and development, safety analysis inputs and assumptions, and engineering design changes.

Phase I of the SAID development was completed in September 1995. The SAID development is scheduled to continue in phases with each phase implemented as it is completed. Highest 48

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i priority is assigned to the FSAR Chapter 14 safety analysis transients; non-Chapter 14 transients l' and operating practices will follow later. Complete development of the SAID is scheduled for December 1997.

I Maine Yankee Process for Reviewine Safety Analysis Inputs The oversight of safety analysis by Maine Yankee has historically been founded on the  !

continuous review and direct involvement of Maine Yankee personnel with the YAEC engineers i and analysts in the development and generation of the safety analysis. Included as a part of this j l

effort is the assessment of the cycle-specific inputs to the safety analysis. On a consistent basis, j l this review is composed of a series of cycle-specific meetings between Maine Yankee and YAEC ]

technical personnel, assessment of the continued applicability of past safety analysis inputs,  ;

generation and use ofinternal data and informational transmittals within YAEC, and  !

implementation of design controls associated with fuel design and fabrication. Additionally, -)

! safety-related design changes implemented at the Maine Yankee plant are, by procedure, i l reviewed by the safety analysts for identification ofimpact'on safety analysis inputs. )

l Concurrent with the Maine Yankee efforts to oversee the safety analysis and the YAEC reviews regarding safety-related changes to the plant, YAEC personnel in the Maine Yankee Project office provide internal oversight to the generation of the safety analysis.  ;

! l i In 1994, Maine Yankee initiated a plan to enhance the existing process. The plan involves usmg -l the SAID to assure that analysis assumptions continue to support operating limitations when j l either is changed. Completion of this effort is scheduled concurrent with the completion of the i L SAID in December 1997. l i

Snfety Analysis Oversight Imorovement Program Self assessments of safety analysis oversight have resulted in observa+ ions regarding reliance by YAEC on individuals rather than on documented processes. This has generally worked well due to the high quality of personnel involved. However, continued reliance on individuals is not optimal for the long term. Therefore, the following plans have been developed and are being implemented with completion scheduled to be concurrent with the completion of the SAID in December 1997.

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= The existing safety evaluation process will be supplemented with an evaluation based on safety functions such as: reactivity, cooling, and radiation barrier integrity.

. A training program for preparing and reviewing safety evaluations will be developed and implemented.

• A written process for performing safety analysis calculations will be developed to ensure that all associated activities are completed appropriately.

• The responsibility for safety analysis oversight will be consolidated in Nuclear Engineering. Oversight of the process would include the SAID, the written safety

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analysis process, and all NED work. An individual in Licensing will be designated to follow safety analysis licensing requirements and assure the NRC is informed of safety analysis issut Calculation Standard The ISA also noted calculation control discrepancies primarily in the mechanical calculations.

The specific discrepancies noted in Section 3.3.4 of the report will be corrected by March 1997.

Long-term resolution of the programmatic issue will be addressed by the creation of a calculation standards document governing the use of approved calculations, when calculation revisions are required, and when new calculations are required in lieu of Technical Evaluations. Once these standards are created, engineering personnel will receive training and follow-up audits of implementation will be conducted. Development, training and implementation of the calculation standard will be completed by July,1997.

4.4 Operations The ISA identified weaknas in Operations, including a large number of workarounds and compensatory measures, and weaknesses in log-keeping and post-trip reviews. Maine Yankee's improvements for each of these weaknesses are discussed below.

Operator Workarounds Maine Yankee's actions to incorporate industry guidance and assess the aggregate affect of operator workarounds is discussed in Section 3 of this response.  ;

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Log-Keening Management reemphasized existing guidance on log-keeping to all control room operators with j an Operations memo dated August 29,1996 (SPS-96-023).

Post-Trio Reviews i

Maine Yankee improved the post-trip review process by utilizing INPO guidance during the October 1996 unplanned shutdown. That guidance is being incorporated into the Post-Trip Review procedure (1-2-1) to enhance the depth of the review and the detail recorded following plant trips. Procedure changes will be completed by March 1997.

4.5 Self Assessments and Corrective Action The ISA identified several weaknesses associated with self assessments and corrective action, including fragmented problem identification and corrective action processes, weak implementation of the processes and occasionally ineffective corrective actions, and many individualimprovement plans that had limited effectiveness and mixed results. Maine Yankee's Learning Process (LP) addresses the weaknesses related to problem identification and correction.

Maine Yankee's Business Plan addresses the weaknesses related to the improvement plans.

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Leaming Process The LP design team was formed in 1995 to consolidate the many existing Maine Yankee corrective action processes. In addition to the LP, only three other corporate problem identification and resolution processes will remain in place following LP implementation. These include our Work Order Process to control equipment hardware work, the Employee Sugestion Program to stimulate employee suggestions for non-safety improvements, and the Worker ,

Concerns Program to provide a secure and confidential route for employees to address l unresolved safety concems. The LP will include procedural controls to manage the interface and redistribution ofissues among these remaining processes.

In addition to consolidating processes, the LP will provide a readily available entry point for all issues through an on-line open-access computer system, common screening and coding criteria, an expe t screening panel, improved evaluator qualification, a single responsible issue owner, a single consolidated task tracking system, and a common task and issue prioritization method. As a result, Maine Yankee personnel will be able to focus resources on higher priority items, i c conduct more consistent searching and trending, reduce task duplication, reduce the number of redundant corrective actions to a few more productive actions, and streamline the processing of issues and tasks with a minimum of paperwork. In addition, the LP will lower the threshold for reporting problems because a single point of entry will simplify documenting an issue and all workers, including contractors, will have access to the system. Furthermore, workers will also be allowed to enter issues anonymously if they desire.

The LP also includes provisions to avoid problem recurrence which we are confident, will address the ISA concem relative to occasional ineffective corrective actions. These include qualification requirements for root cause evaluators, single issue owner responsibility for integrated problem solution, risk level and task priorities influenced by prior experience, post implementation effectiveness evaluations for high-risk issues, inclusion of external operating experience in prior experience searches, and a searchable leamable lessons database that can be used when preparing for work, procedure modifications; or training. These features help assure that our LP and root cause procedures align with the guidance provided in NRC Information Notice 96-28, Suggested Guidance Relating to Development and Implementation of Corrective Action.

The Leaming Process will begin its phased implementation in January 1997. Actions completed in support of the new process include an interim task prioritization process, integrated tark backlog monthly performance reporting, revised corporate expectations for the evaluation and timeliness of responses to external operating experience, initiation of pre-implementation training, and the start of a process pilot within our Technical Support Department to demonstrate and test the process computer software. Shortly after full implementation of the new process, Maine Yankee has scheduled a third-party expert assesstnent of the Learning Process using NRC module 40500 to assure the new process meets or exceeds required objectives. Maine Yankee is developing systematic performance measurements to determine the effectiveness of the J

corrective actions. Furthermore, the Company's implementation of the maintenance rule is intended to significantly improve the Company's knowledge and management of equipment included in that program. Finally, our emphasis on self assessment is intended to establish a stronger cultural value on effectiveness of corrective action.

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41 e

ENCLOSURE 1 MAINE YANKEE EXCELLENCE ACTION PLAN 4

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MaineYankee RELI ABLE ELECTRICITY $1NCE 1972 329 BATH ROAD + BRUNSWICK, MAINE 04011 * (207) 798 4100 EXCELLENCE ACTION PLAN INTRODUCTION-During much of 1996, Maine Yankee has been in a period ofintense examination - both internally and extemally. Intemally, we have looked closely at issues such as employee culture, design basis documentation, corrective action procedures and business plan enhancements.

Extemally, the U.S. Nuclear Regulatory Commission (NRC) conducted the most thorough inspection of Maine Yankee ever in the plant's long history. A 25 person team of experts logged over 4,500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> of time inspecting both plant equipment and plant procedures, documentation and work processes.

' Now, the results of these examinations are known. The NRC inspection team concluded that Maine Yankee is operating safely, and yet there are important areas where improvements and changes are indicated.

The following is an outline of Maine Yankee's current road map for addressing the issues that have been raised during the course of these examinations and investigations. This plan builds on our strengths, many of which were identified by the NRC's Independent Safety Assessment Team and includes immediate actions that are already underway. It also includes long-term actions that will continue during the next several years.

The plan also includes changes at the Board of Directors level. Technical advisors in specific areas like employee / cultural issues, regulatory compliance and plant operations will be integrated into the Board structure to provide additional oversite of Maine Yankee.

As Maine Yankee reviews the ISA report and develops its formal response to the NRC, changes and improvements will be reflected in this plan. Maine Yankee will also be working closely with State of Maine officials, who had a significant role in the ISA inspection process, as Maine Yankee responds to the ISA report.

EXCELLENCE ACTION PLAN Maine Yankee's Action Plan has five primary elements:

1. Resource Allocation

2. Organization Changes u=ve me m

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3. Board of Directors Increases Oversight ,

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4. Program enhancements

5. People & Cultural Changes  !

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'1. Researces a) Budget: The Excellence Plan is consistent with actions necessary to ensure adequate resources are available at Maine Yankee. For example, $10 million  !

already has been authorized to address the ISA process and the Action Plan.  !

Maine Yankee is committed to providing whatever resources are necessary to j continue to operate safely. -

b) Perennnah Maine Yankee has retained the professional firm of Tirn Martin and l Associates to benchmark company staffing leveh as compared to the best in the l industry. l l

2. Organizational Changes l

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a) Sanaratian of f icanning & Fnginaaring Dents to provide incrancad rignr: To' l provide more focus on both regulatory compliance and engineering, the current l position of Vice President of Licensing & Engineering is being divided into a )

Vice President of Licensing & Regulatory Compliance and a Vice President of .

Engineering. The VP of Licensing & Regulatory Compliance will directly l address the issue of commitment tracking and meeting regulatory requirements.  !

The position will also be responsible for licensing issues, staying abreast of and i anticipating evolving industry standards. This dedicated focus will further  :

support a culture ofexcellence within the company. We are launching a )

nationwide search to identify and recruit the most experienced and respected j manager available for this new position.

The Vice President of Engineering position will bring increased focus on  !

technical issues and implementation of regulatory requirements and will provide additional oversight ofYankee Atomic Electric Company.

b) Human Rannurces given graatar reenannihility; vimihility: As of today, Maine Yankee's Human Resources function is being detached from the Finance &

Administration Department. Under a new Manager ofHuman Resources, this department will now report directly to the president of Maine Yankee. This is not a symbolic move, but a practical way of ensuring that human and corporate-culture issues receive the direct, top-level attention they demand.

c) Senior Ontage Manngar nneition creata* As part of Maine Yankee's pursuit of excellence in outage operations, Maine Yankee has created the position of Senior Outage Manager. A national search to identify an experienced outage manager is now underway.

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d) Maine Yankecldankee Atomicanarclarmally_ separated:_We have taken action to formalize the organizational separation of Maine Yankee from Yankee Atomic Electric Company (YAEC). YAEC is Maine Yankee's principle engineering contractor. This action already has resulted in the removal of the president of YAEC from the dual role of Maine Yankee officer.

(1) YAEC has earned the highest respect for its engineering skills. But as the RELAP computer code investigation demonstrated, ambiguous responsibilities and overlapping jurisdiction invite operational confusion.

(2) With these changes, it will be made even more clear that Maine Yankee is unequivocally responsible for its own engineering, licensing, and regulatory decisions, and for maintaining the interface with regulators.

3. Board of Directors Oversight a) Nuclear Committee of the Board estnblished: The new Nuclear Committee of the Board of Directors will provide increased oversight of the initiatives Maine Yankee is undertaking pursuant to this plan, and will monitor compliance with regulatory requirements. The committee is pursuing the appointment of several highly respected technical and employee /workforce culture experts who will serve as advisors to the committee.

b) Former NRC senior _ manager to join MY Roard of Directors: We are proud to announce that Dr. Thomas Murley, retired Director of the NRC's Nuclear Reactor Regulation program, and a part-time resident of Maine, has agreed to join the Maine Yankee Board of Directors and serve on the Board's Nuclear Committee.

Dr. Murley's professional expertise and immense practical experience will help  !

the Board in its oversight of Maine Yankee. A copy of Mr. Murley's vita is '

attached for your reference.

4. Program Enhancements a) Business plan integrated _ta_ improve pinnning A resource nlinention: Maine j Yankee is now integrating several existing planning processes into one central I document, called the Maine Yankee business plan. This will ensure that consistent, coordinated priorities are developed for overall operations and l adequate resources are provided to meet both short term and long term goals. The i business plan will also provide a document to systematize improvement projects  ;

under way at Maine Yankee, including the response to the ISA report. l l

i b) Cen'enlized Conective Action Trncking: Last year Maine Yankee began a l reengineering process to completely revise its corrective action process. That process, called the Learning Bank, is now being implemented. It will centralize the corrective action tracking system and pmvide increased management oversight to ensure that improvements are prioritized and on schedule.

I Maima Yankee 10/09/96

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c) 100-percent-power _ goal: We believe the plant can operate safely at 100% power and we will work to fully address the concems ofour regulators. Our current {

limitation of ope

ating at only 90-percent power deprives Maine and the rest of j New England of some 13 million kilowatt-hours of very economical energy every l i week. ' Retuming the plant to full power would benefit the economy for the entire 1 l j' region. 1 i

d) Other pmgrama craatad to strenothan Maine Yankee. Additional significant j performance improvement programs at Maine Yankee include the Maintenance p Improvement Program, the Engineering Quality Impmvement Program and the -  !

j Safety Analyses Improvement Plan. Also being addressed by other program  !

j changes are reducing backlogs, bench marking plant operations to the best in the  !

!. industry and involvement in a variety of national industry groups which share

' l leaming experiences and opportunities.

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L 5. People  ;

a) Maina Yankee management cammitment- In order to enhance the effectiveness .

of every employee, and to instill an attitude of reaching for the highest standards  !

while questioning the status quo, Maine Yankee management, through this plan,  !

is renewing its commitment to be leaders who care about their employees, who '

respond to employees in a timely way, who seek and value employee input, who l encourage employees to bring forward safety concems and who reward  !

employees forinnovation.  ;

i b) Culture initiatives A variety ofinitiatives are underway which will enhance the j effectiveness of our organization as a whole and our management and employees: '

l' (1) Vision: A team of employees drawn from every department in the plant has been working on a forward-looking vision statement to guide our operations. It will be presented to the Board of Directors in December. -

'(2) Industry awareness: Alert to the dangers ofinsularity, Maine Yankee has - )

committed itself to continuous familiarity with industry best practices, to  ;

providing members for industry-group committees, and to assigning staff I in support ofINPO missions. ,

(3) Accountability: Maine Yankee is committed to ensuring that full personal l I

accountability for meeting the highest industry standards is an integral part of our way of doing business. This includes demonstrating the highest standards of personal integrity, ethics and fairness.

(4) Worker Concern Program: Management understands that it must be genuinely open to workers' concems on safety, operations, and other issues - and that workers must feel confident in the integrity of the process for communicating concems. To that end, the Workers Concem Program is being revised to strengthen the program and to heighten worker awareness ofits capabilities.

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-(5) SupervisoryDevelopment: Maine Yankee has renewed its efforts in supervisory training. Leadership and communication training is being  :'

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. provided to supervisors to ensure that our supervisors have the skills necessary to enhance employee effectiveness.

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i CONCLUSION l

This comprehensive, focused Excellence Action Plan will help Maine Yankee meet the i challenges raised by the ISA Report and challenges raised by the evolving standards of the  ;

industry, and by the proper expectations of Maine's people for safe, reliable, and competitive .'  !

i electricity from nuclear energy.  !

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o C. '7,0 ENCLOSURE 2 MAINE YANKEE BUSINESS PLAN

SUMMARY

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BUSINESS PLAN

SUMMARY

Introduction The following Business Plan Summary contains selected portions of the Maine Yankee Business Plan. The summary includes Company background information as well as task descriptions, schedules and responsibilities for the various tasks associated wi'h and aligned to the Company's Vision, Goals and improvement Initiatives.

The detailed Business Plan, which is in the final stages of completion, will include additional information such as:

• A detailed Market Analysis

• A Company Situation Analysis Performance Indicators for Company Goals

• Detailed budget and labor information associated with the Business Plan tasks I

• Key financialinformation l

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tIfSLll 0 Maine Yankee AEllABL E Et ECTAICITY FOR MAINE SINCE 9972 l

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j Maine Yankee Business Plan Integration Team 3

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Table of Contents The co m pany . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 M arket Analys i s . . . -. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . H com pany v i s ion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . n

. Company Goals in Pursuit of Excellence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . H .

Performance Indicators for Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

M anagement Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Organizational Chart . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 Board o f Direc tors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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, m Business Plan 1

The Company l 1

Below is a summary of Maine Yankee's background and current issues as stated in the 1995 Annual Report and updated through the 1996 quarterly reports. For i further detail, reference the specific documeats.

1 Overview l

Maine Yankee Atomic Power Company (the " Company" or " Maine Yankee"),

incorporated under the laws of Maine on January 3,1966. owns and operates a pressurized-water nuclear-powered electric generating plant at Wisetsset.

Maine, with a current net capacity of approximately 860 megawatts electric (the

" Plant"). The Plant was declared commercial on December 28,1972. The Company sells its capacity and output to its ten sponsoring stockholder utilities (the -Sponsors" or the " Stockholders").

The Sponsors are each committed under a Power Contract with the Company to purchase a specified percentage of the capacity and output of the Plant and to pay therefor a like percentage of amounts sufficient to pay the Company's fuel costs, operating expenses, interest on its debt and a return on its equity. The Company and its Sponsors have also executed Additional Power Contracts for the purpose of extending the term of the Power Contracts, as amended, from 2003 to the end of the useful life of the Plant and the completion ofits decommissioning and financial obligations. Each Sponsor has also agreed, under a Capital Funds Agreement with the Company, to provide a like percentage of the Company's capital requirements not obtained from other sources, subject to obtaining necessary authorizations of regulatory bodies in each instance. All such obligations are subject to the continuingjurisdiction of various federal and state regulatory bodies.

l The following New England electric utilities own all of the common stock of the Company:

l New England Power Company l 20 l

l The Connecticut Light and Power Company l 12 l

l Bangor Hydro-Electric Compan) l 7 l

l Maine Public Service Company l 5 l

l Public service Company of New Hampshire l $

December 9.1996 (9:46am) Page1

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l Montaup Electric Company l 4 l

l Western Mnsachusetts Electric Company l 3 l I l centras vennont rubiic service Corporation l 2 l l Total l 100 %

1 The obligations of the Sponsors to make payments under the Power Contracts are unconditional, subject only to each Sponsor's right to cancel its Power

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Contract if deliveries cannot be made to the Sponsor because either (i) the Plant  ;

is damaged to the extent of being completely or substantially completely )

destroyed. or (ii) the Plant is taken by exercise of the right of eminent domam or  !

a similar right or power. or (iii)(a) the Plant cannot be used because of l

contamination or because a necessary license or authorization cannot be obtained or is revoked or the utilization thereofis made subject to specified conditions which are not met, and (b) the situation cannot be rectified to an extent which will permit the Company to make deliveries to the Sponsor from  !

the Plant. Notwithstanding the right to cancel, the obligation to pay l decommissioning costs continues until the Plant has been fully decommissioned. j A default by a Sponsor of the Company in making payments under the Power Contract or Capital Funds Agreement could have a material adverse effect on the Company. depending on the magnitude of the default, and would constitute a default under the Company's First Mortgage Indenture and two other major credit agreements unless cured within applicable grace periods by the defaulting Sponsor or other Sponsors.

The Plant i The Plant is located on tidewater on Bailey Point in Wiscasset, Maine, on an 820-acre site that is owned in fee by the Company and is adequate for the Plant and for all associated facilities, including the associated switchyard facilities which are owned in part and operated by CMP.

The Plant is a nuclear-powered electric generating plant, utilizing a pressurized-water reactor, fueled with slightly enriched uranium oxide. The nuclear steam supply system and certain other equipment were designed and fabricated by Combustion Engineering. Inc. The turbine generator was supplied by Westinghouse Electric Corporation. Stone & Webster Engineering Corporation, as engineer and constructor, designed and constructed the Plant. Construction of December 9.1996 (9:46am) Page 2

Business Plan the Plant, w hich began in 1967, was completed in 1972 except for certain discharge temperature control facilities designed to meet the requirements of the ,

Maine Board of Environmental Protection, which were completed in 1975.

Since the Plant commenced operation, the Company has sought to improve its safety and reliability, while increasing its output, through periodic upgrading of. >

equipment and facilities, along with regular training programs for Plant personnel, in furtherance of those goals, the Company replaced the Plant's two low-pressure turbines and its high-pressure turbine in 1988 and 1990, respectively, with new units provided by Asea Brown Boveri ("ABB"), which ,

resulted in an increase of approximately 20 megawatts in the Plant's output. In addition, the Company is retaining a new ABB main electrical generator as an emergency spare component. Since the original construction cost of approximately $231 million the Company has made, through December 31.

1995, approximately $218 million in additional capital improvements.

, Regulation and Environmental Matters The Plant is subject to extensive regulation by the NRC, which is empowered to authorize the siting. construction and operation of nuclear reactors after consideration of public health, safety, environmental and antitrust matters.

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The Company and several ofits Sponsors are subsidiaries of registered holding i companies and, as such, are subject to regulation by the Securities and Exchange l

. Commission ("SEC") under the Public Utility Holding Company Act of 1935 )

with respect to various matters, including the issuance of certain securities. The Company is also subject to regulation by the SEC under other federal securities i laws.

l In addition, the Company is subject to regulation by the Federal Energy '

Regulatory Commission ("FERC") as to its rates (including the Power Contracts and Additional Power Contracts) and various other matters. and is subject to l regulation by the Maine Public Utilities Commission ("MPUC") as to some l aspects ofits business, including the issuance of securities. I i

The United States Environmental Protection Agency (" EPA") administers l programs established under the Federal Water Pollution Control Act and the

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Clean Air Act, as amended in 1990, which affect the Plant.

l In addition, pursuant to the Federal Resource Conservation and Recovery Act of 1976, the EPA regulates the generation, transportation, treatment, storage and i disposal of hazardous wastes. The EPA has broad authority in administering  ;

these programs, including the ability to require installation of pollution control and mitigation devices.

l December 9. I996 (9:46am) Page 3

e Business &n The National Environmental Policy Act of 1969 ("NEPA") requires that detaN statements of the environmental effects of major federal actions be prepared 'oy federal agencies. Major federal actions can include licenses or pennits issued to the Company by the NRC and other federal agencies for construction or operation of generation and transmission facilities. NEPA requires that federal licensing agencies make n independent evaluation of the environmental impact of, and alternatives to. the proposed action. Future construction modifications or other activities at the Plant could require federal licenses or approvals that in-s olve NEPA requirements.

The Company is also subject to regulation as to environmental matters and land use by various state and local authorities in Maine. ,

Under their continuingjurisdiction, the NRC and one or more of the EPA and the state authorities havingjurisdiction over the Company's facilities may modify permits or licenses that have already been issued, or impose new conditions on such permits or licenses, and may require additional capital expenditures or require that the level ofoperation of a unit be temporarily or permanently reduced. The Sponsors of the Company have agreed, however, subject to certain exceptions including regulatory approval. (i) to provide the required capital not othenvise available. (ii) to take the total output of the Plant, and (iii) to pay all costs of the Plant, including capital and decommissioning )

costs.

Operating Results Plant Operations The Plant is generally operated on a planned eighteen-month operating cycle and must be taken offline at the end of a cycle for approximately eight to ten weeks l for scheduled refueling. maintenance and planned construction activities. The Company is currently planning and scheduling the next refueling-and-maintenance outage, w hich is now expected to begin in the early fall of 1997, and will seek to shorten the outage period with no compromising of safety or quality of work. Maine Yankee continues to evaluate and implement options to increase operating flexibility and minimize costs.

Steam Generators The Maine Yankee unit. like other pressurized-water reactors, had been l experiencing degradation ofits steam generator tubes, principally in the form of circumferential cracking. which, until early 1995, was believed to be limited to a relatively small number of steam generator tubes. In the past. the detection of defects had resulted in the plugging of those tubes to prevent their subsequent December 9.1996 (9:.86am) Page 4 l

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Business Plan use. During the refueling-and-maintenance shutdown that commenced in early February of 1995, the Company detected through new inspection methods substantially increased degradation of the Plant's steam generator tubes to the extent that approximately 60% of the Plant's 17,000 steam generator tubes appeared to have defects to some degree, which eliminated mitigating the problem by plugging the tubes with indicated defects.

Following a detailed analysis of the safety, technical and Gnancial considerations associated with repair of the degraded steam generator tubes. Maine Yankee elected to repair the tubes by inserting and welding short reinforcing sleeves of an improved material in substantially all of the Plant's steam generator tubes.

Similar repairs had been completed at other nuclear plants in the United States and abroad. but not on the scale of the Maine Yankee project. With Westinghouse Electric Corporation as the general contractor. the sleeving project started in early June of 1995, after approval of the Westinghouse sleeving process by the Nuclear Regulatory Commission ("NRC") and was ,

essentially complete in early December. The project caused Maine Yankee to l

incur additional costs of approximately $27 million during 1995. l Power Output Limitation l I

On December 4,1995, when the sleeving project was substantially complete, Maine Yankee obtained a copy of a letter from the Union of Concerned Scientists, an organization with a history of opposing nuclear power, to a State of Maine nuclear safety ofGeial based on documentation from an anonymous employee or former employee of Yankee Atomic Electric Company (" Yankee"),

an affiliate of the Company that has regularly performed nuclear engineering and related services for the Company and other nuclear plant operators. The letter contained allegations that Yankee knowingly performed inadequate analyses to support two license amendments to increase the rated thermal power at which the Maine Yankee Plant could operate. It was further alleged in the letter that Maine Yankee deliberately misrepresented the analyses to the NRC in seeking the license amendments. The allegedly inadequate analyses related to the operation of the Plant's emergency core cooling system ("ECCS") and the calculation of the Plant containment's peak postulated accident pressure, both under certain assumed accident conditions. The analyses uere used in support oflicense amendments that authorized Plant power uprates from 2440 megawatts thermal, a level equal to approximately 90 percent of the maximum electrical capability of the Plant. to its current 100-percent rated level of 2700 megawatts thermal.

In response to technical issues raised by the allegations, the NRC initiated a special technical review of the safety analyses performed by Yankee relating to Maine Yankee's license amendment applications for the power uprates. At the December 9.1996 (9A6am) Page 5 l

Business Man same time, Maine Yankee and Yankee initiated intensive internal investigations of the allegations and provided responsive information and documentation to the NRC. Subsequently, the NRC informed Maine Yankee that the allegations would be the subject ofinvestigations by the NRC's Office ofInvestigations and the Office of the Inspector General.

On January 3.1996. the NRC issued a " Confirmatory Order Suspending Authority For And Limiting Power Operation And Containment Pressure (Effective immediately) And Demand For Information"(the " Order"). The Order limited the power output of the Maine Yankee Plant to approximately 90 percent ofits rated maximum until the NRC had reviewed and approved a Plant-specific ECCS analysis and ordered that internal containment pressure be limited until the NRC had reviewed the design-basis analysis ofcontainment pressure.

The Order further contained a request for information prior to restart. which the Company satisfied.

On January 10,1996, Maine Yankee filed with the NRC information specified in the Order that it believes supported operation of the Plant at up to 90 percent of the Plant's capability. In its submittal Maine Yankee also notified the NRC that it expected to proceed with initial operation of the Plant on January 11,1996, and the Plant commenced operation on that day. The Plant began normal operation at a 90-percent level on January 24,1996. On April 25,1996, Maine Yankee submitted an analysis to the NRC which Maine Yankee believes meets all federal regulatory requirements for operating the Plant at 100 percent level.

As previously reported, in December 1995 the NRC's Of6ce Ofinspector General ("OlG") and its Office ofinvestigations ("Ol") initiated separate investigations of certain anonymous allegations of wrongdoing by Maine Yankee and Yankee Atomic in 1988 and 1989 in connection with Maine Yankee Plant operating-license amendments. On May 9,1996, the OlG, which was responsible for investigating only the actions of the NRC Staffissued its report

, on its investigation. The report found deficiencies in the NRC Staff's review, documentation, and communications practices in connection with the license amendments, as well as "significant indications of possible licensee violations of NRC requirements and regulations." Any such violations by Maine Yankee or Yankee would be within the purview of the 01 investigation. Maine Yankee was advised on September 19,1996, that the NRC had asked the U.S. Department of Justice to review the Of investigation report before final release. An internal assessment by Maine Yankee and Yankee noted several areas that could have been improved, inclu.fing regulatory communications, definition of-responsibilities between Maine Yankee and Yankee, and documentation and tracking of regulatory compliance. A separate internal investigation commissioned by the boards of directors of Maine Yankee and Yankee and conducted by an independent law firm found no wrongdoing by Maine Yankee, Yankee or any of their employees.

December 9.1996 (3:26pm) Page 6

l L  ;

Business Plan 1

l Independent Safety Assessment i i

On June 7,1996, the NRC formally notified Maine Yankee that it planned to ,

conduct an " Independent Safety Assessment"("lSA") of the Maine Yankee  !

Plant in conjunction with the State of Maine to provide an independent evaluation of the safety performance of Maine Yankee and as a " follow-on" to the O!G report. The NRC stated that the os erall goals and objectives of the ISA  !

were: "(a) provide an independent assessment of conformance to the design and  !

licensing basis: (b) provide and independent assessment of operational safetv l

performance; (c) evaluate the effectiveness oflicensee self-assessments, corrective actions and improvement plans and

(d) determine root cause(s) of  !

safety significant findings and conclusions." The NRC further informed Maine Yankee that the ISA would be carried out by a team of NRC personnel and

)

I contractors who were " independent of any recent or significant involvement with the licensing, regulation or inspection of Maine Yankee."

l On October 7,1996 the NRC released the ISA report, which dealt with each of  ;

its stated goals. The report concluded that overall performance at Maine Yankee l was adequate for operation of the Plant, and that the deficiencies noted in the  ;

report stemmed from two closely related root causes. The report indicated that l j the root causes were: (!) that economic pressure to be a low-cost energy j i

provider had limited available resources to address corrective actions and some l improvements; and (2) that a questioning culture was lacking, which had resulted in a failure to identify or promptly correct significant problems in areas perceived by Maine Yankee to be oflow safety significance, i

The ISA report also identified certain deficiencies and stated that they would be  !

addressed as part of a separate NRC follow up to clarify NRC expectations for -

the nuclear power industry.

The Plant's current allowed operating level may be limited to 90% of capacity

! until completion of the Plant's next planned refueling outage, which is now  !

scheduled for September 1997. The Company cannot predict, however, whether t or when the Plant will attain a 100-percent operating level, or the results of the ongoing NRC and U.S. Department ofJustice investigations and reviews.

Capital Resources

! The Company currently has capital resources available from secured and unsecured lines of credit totaling $106 million.

' Notes Payable To Banks

The Company had bank lines of credit totaling $21 million as of December 31, December 9.1996 (9A6am) Page 7

. .. . - __ ~ . -

4 i I

i Business Man l 1995.

i l

Secured Credit Agreement In 1989, the Company entered into a secured credit agreement with a group of l banks including the Bank of New York ("BNY"), which is also acting as the l

agent bank, under which the Company may borrow amounts up to $50 million to finance corporate expenditures. Borrowings are secured by the Company's nuclear fuel inventory, as defined, and cenain rights under the Power Contracts and Capital Funds Agreements.

Eurodollar Revolving Credit Agreement in January 1990, the Company entered into a Eurodollar Revolving Credit Agreement with a group of major international banks including Union Bank of Switzerland, which is also acting as agent bank, under which the Company may borrow up to $35 million.

i First Mortgage Bonds The Company had First Mortgage Bonds, Series D, E and F, of approximately

$96.6 million outstanding on December 31,1995 with an annual sinking fund requirement of $6.7 million. .

Under the terms of the indenture securing the First Mortgage Bonds, substantially all electric plant of the Company is subject to a first mortgage lien.

Redeemable Preferred Stock 7A8% Series. On December 31,1995, the outstanding balance was approximately $4.2 million.

0 00% Series. On December 31,1995, the outstanding balance was approximately $15.0 million.

Retained Earnings Under the terms of the most restrictive test in the Company's First Mortgage indenture and the Company's Articles ofincorporation, no dividend may be paid on any class ofits stock unless the Company is in compliance with specific .i.

equity ratio requirements. Through December 31,1995, the Company was in compliance with these requirements.

December 9.1996 (9:46am) Page 8

I e Baainess Plan Credit Rating

• I In January,1996, Standard and Poors Corporation ("S&P") reaffirmed its rating of the Company's senior debt at "BBB" and its "BBB " rating on preferred stock. l The negative outlook rating reflects concern over the ability to reestablish .

reasonable operating performance consistent with past plant performance, as  !

well as continued downward pressure on the overall weighted average rating of  !

the ten utility owners of Maine Yankee.  !

The Company, as well as the nuclear electric industry in general, has been challenged by common problems in recent years including those of controlling i

operating costs and expenditures for plant modifications attributable to more  ;

I stringent regulatory requirements and uncertainties caused by political  !

involvement in nuclear utility regulation, it is not possible at this time to predict what impact these uncertainties will have on the future financial operation of the Company.

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December 9,1996 (9:46am) Page 9 I i

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l Business Plan l l

Market Analysis  !

overview This section provides an overview of the major factors driving the electric utility industry. The focus of the market analysis is within the New England Region, but riso covers national interests. The Federal Energy Regulatory Commission (FERC) issued orders 888 and 889 in April of 1996, which took a major step to bring competition to the electric utility industry. The New England states have higher than average prices for residential, commercial and industrial users, and i

are therefore on an aggressive track to open their markets to competition.

The New England market currently has enough generating capacity to continue to meet peak demands beyond 2005, but the existing generating units are fairly old and expensive to operate. This will bring opportunities for other power resources to meet regional demands. These new opportunities could come in the form of new plant construction, plant upgrades, power imports or " tolling,"

which is a conversion of natural gas into electricity. There are two proposed natural gas pipelines through the state of Maine which will make gas-Gred capacity more attractive. As a result of these driving factors and the fundamental restructuring of the U.S. power industry, Maine Yankee can expect a very competitive market in the near future. -

The historic structure of the power industry is a vertically integrated monopoly with regulated returns. The industry's future is expected to be an unregulated competitive market with performance based proSts. It is also expected that tnere will be a generation sector and a power marketing sector as the two major components of the electricity supply business. By the year 2000, the generation sector may become consolidated while the power marketing sector may offer  ;

aggregate energy services by integrating gas and electricity services to consumers. Ownership and control of generation assets may be a key to future value creation.

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1 December 9.1996 (9:46am) Page 10 i

Business Plan l-Company Vision

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DCCCmbCr 9.1996 (9-46am)

Page 11

Business Plan Company Goals in Pursuit of Excellence A goal is a general description of the directions the organization will take to fulfill the vision.

Sustain high nuclear and industrial safety standards.

• Achieve optimal plant material condition.

• Provide cost competitive, reliable electricity.

Foster a challenging and rewarding environment that provides growth opportunities for employees. l

• Improve planning and prioritization .

l processes to effectively utilize resources.

- Enhance credibility and respect with the regulators, peers and the public.

• Prepare for and adapt to an uncertain future. I l

December 9,1996 (9:46am) Page 12 I I

7 i

Business Plan Performance Indicators for Goals l Company Goals A. Sustain high nuclear and industrial safety standards.

l B. Achieve optimal plant material condition.

1 C. Provide cost competitive reliable electricity.

l D. Foster a challenging and rewarding environment that provides growth opportunities for employees.

E. Improve planning and prioritization processes to effectively utilize resources.

F. Enhance credibility and respect with the regulators, peers and the public.

O. Prepare for and adapt to an uncertain future.

1997 Coinpany Performance Indicators This section will include at least one company performance indicator for each goal.

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December 9.1996 (9:46am) Page 13 i

Business Plan Management Plan Goals and initiatives in Pursuit of Excellence GOAL A: Sustain high nuclear and industrial safety standards.

A-1 Continue to reinforce safety as a paramount organizational value.

A-2 Improve radiation safety programs.

A-3 Implement Margin Improvements Program GOAL B: Achieve optimal plant material condition.

B-1 Evaluate steam generator options.

B-2 Improve and maintain excellent physical condition of the i

plant.

B-3 Improve equipment and system testing and reliability.

B-4 Reduce critical work backlogs.

GOAL C: Provide cost competitive, reliable electricity.  !

l C-1 Return to 100% power. I I

C-2 Optimize fmancial resources.

C-3 Explore cost sharing or reduction through industry alliances.

GOAL D: Foster a challenging and rewarding environment that provides growth opportunities for employees.

D-1 Improve employee empowerment and accountability. I l

D-2 Strengthen employee development.

D-3 Improve internal communication.

1 December 9,1996 (9:46am) Page 14 l

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1 Business Plan GOAL E: Improve planning and prioritization processes to effectively utilize resources. l E-1 Optimize work control / planning process. ,

t E-2 Continue Business Plan integration.

E-3 Create a proactive vs. reactive environment.  !

E-4 Evaluate human resource adequacy (quantity and allocation),

t E-S Optimize outage duration.

E-6 Improve performance indicators and how they are used. I GOAL F: Enhance credibility and respect with the regulators, peers and the public.

F-1 Enhance Specialty Training Program. I F-2 Improve configuration management programs.  :

F-3 Enhance industry awareness. -

GOAL G: Prepare for and adapt to an uncertain future.

G-1 Address uncertainty of future and employee EOL concerns.

G-2 Evaluate Maine Yankee's value in a de-regulated utility environment. ,

G-3 Pursue strategic business opportunities.

Abbreviated Task Summaries The following section contains a listing of the initiatives required to move toward realization of the Company goals. More detailed information is available in the Business Plan source document. Each of the twenty five (25) initiatives is aligned to a goal and contains a summary of the tasks necessary to accomplish the initiative. Each initiative has been resourced, both from a financial and human resource perspective. A description of column content of the tables is as follows:

December 9,1996 (9:46am) Page 15

Business Plan i t

BP Task No.: A unique sequential identifier for the task. For example, the first task for the A-1 initiative is A-t-1. ,

LB Task No.: The task number in the Learning Bank that has been assigned to the task.

LB Task: A short description of the task to be accomplished. The description is identical to that contained in the Learning Bank. '

Start: The month and year that the task is scheduled to start.

Finish: The month and year that the task is scheduled to be complete.

Task Manager: A Learning Bank term used to describe the single individual responsible for managing the task to completion.

Current 1997 O&M; identifies if the task is funded in the 1997  !

Costs: baseline, special costs or contingency budget.

Cycle 15 Capital; identifies if the task is included in the cycle 15 capital budget.

Additional Identifies if there are additional costs, both O&M and capital, '

Lifetime for all of the budget lines associated with the task.

' 3 Costs:

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Business Plan Financial Planning This Business Plan is organized in a manner which resources current year tasks and activities as budgeted. In this manner, the Budget itselfis in large measure, an output of the Business Planning Process based on the need for work and project activities. The aggregation of all current year expected costs serves as the basis for the Budget.

The current year Budget, in turn, serves as the basis of the first year of the Company's Five Year Financial Plan, Future year's costs estimates are based on a review of the Business Plan, including identified multi-year work tasks or projects. The Five Year Forecast serves as the Company's financial planning tool to assess the Company's future financial position.

December 9,1996 (9:46am) Page 42

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} Business Plan i

Tracking of Business Plan Tasks j The Maine Yankee Business Plan will be the governing document for all initiatives and I

their tasks. The Learning Bank will be the vehicle for tracking the status of each task and 4

-( sub-task associated with the initiatives. Refer to Learnine

' Process Procedure 0-16-1 for

guidance.

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1 Figure 28 Tracking of Business Plan Tasks

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December 9,1996 (9:46am) Page 44

J Business Man I

Board of Directors i i.

(AS of 11/96) i e

3 l Arthur W. Adelberg Vice President. Law and Power Supply Central Maine Power Company i Robert S. Briggs Chairman of the Board. President and Bangor fly dro-Electric Co.

Chief Executise Omcer l

Kent R. Brown Vice President. Engineering & Centrai Vermont Public Service  ;

i Operations Paul Cariani l President and Chief Executive Omcer l Maine Public Service Company Lillian Cuoco Senior Nuclear Counsel Northeast Utilities l l

] Ted C. Feigenbaum Esecutis e Vice President and Chief Northeast Utilities d

Nuclear Omcer Dasid T. Flanagan r.entral Maine Power Company l President and Chief Esecutive Omcer Charles D. Frizzle President and Chief Executisc Ome-: Maine Yankee Atomic Power Company

~

Frederic E. Greenman Retired New England Power Company i'

l '

John B. Keane Vice President and Treasuner I l Northeast Utilities Service Carroll R. Lee Vice President. Operations Bangor Hydro-Electric Company l

, David E. Marsh Vice President. Corporate Services. Central Maine Power Company Treasurer and Chief Financial Omccr I

] Dr. Thomas Murley Retired Nuclear Regulatory Commission j Donald G. Pardus l President and Chief Executive Eastern Utilities Associates Omcer )

I l Gerald C. Poulin Vice President.Genciatien and Central Maine Power Company 1 Technical Support I James S. Robinson Manager. Nuclear Insestments and New England Power Company

Administration John W. Rowe New England Power Company j l President and Chief Executive Omcer F. Allen Wiley Managing Director of Generation Central Maine Power Company l

Russell D. Wright President and Chicf Operating Omccr Commonwealth Electric i

Company December 9.1996 (9.46am) Page 45 i

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i 95 y &

ENCLOSURE 3 CLOSEOUT PLAN FOR YANKEE ATOMIC ELECTRIC COMPANY l

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1 PURPOSE OF ENCLOSURE 3 I i

Enclosure 3 documents the closcout plan for the technical and process observations related to j codes and analyses made by the ISA team. The attached plan identifies actions, responsible j individuals, and scheduled dates. i t

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Date: December 6,1996 Rev. No.: 4 Page 1 of 2 ISSUE OR QUESTION PLANS COMMENTS / STATUS

1. YNSD does not have specific documentation of A. List SER conditions as pan of Methods Overview A and B l the disposition of SER conditions in their files. Manuals (MOMS) Completion before start of

1. List SER conditions and compliance by code Cycle 16 operation. SER

2. List SER conditions and compliance by conditions will be part of transient methodology and topical report MOMS.

B. Develop guidelines, part of which mandates checking SER conditions to ensure they are met.

2. The NRC was not able to find the level of A. Identify benchmark cases supporting methods and A. Completion by start of Cycle validation they would like for some of the codes from YNSD and industry available data. Will 16, computer codes used by YNSD. be part of MOMS.

B. Develop a data base of benchmark cases for each B, C, and D code, which may include: Scope and schedule under integral tests development. .

separate effects tests C. Define standard benchmark data sets to be used to set up and maintain methodologies through changes in the codes .

D. Perform standard benchmarking to baseline methodologies,if required

e.-

YNSD/NRC ISA CODES & ANALYSIS CLOSEOLTT PLAN Date: December 6,1996 Rev. No.: 4 Page 2 of 2 t

ISSUE OR QUESTION PLANS COMMENTS / STATUS .

3. De safety analysis process relies on individuals A. Create MOMS, describing methodologies for each A. Completion before start of instead of documented processes. Too much transient. Cycle 16 reliance on individuals can leave the process vulnerable. B. Write general guidelines to define ar alysis process. B. Completion by 12GIS6 l i

C. Defin ,6e giidance (baseline) calculation for each C. Completion before start of transitat Cycle 16 D. Define 2-3 cycle review of A, B, C to ensure D. Completion before start of conformance with appropriate methodology Cycle 16 E. QA Technical Specialists to dca mua the review E. Completion by 12GIB6 content and the results for inclusion into QA reports ,

4. He EDR threshold is too high for performance A. Lower threshold via procedure WE-109 changes A. Pic. cede complete. Training indication. personnel training, conununications with plant, etc. by 12G186.  ;

5 Control ofinputs to safety analysis needs to be A. Finish SAID A. Phase I completed 90065 ,

PhaseIIby 40067 strengthened PhaseIIIby 10f3167 PhaseIV by IG187 Phase V by 18168 B. Provide systems training to analysts B. Completion by 12GIS7

6. He ability of the CS system to provide a reliable A. Perform additional sensitivities to address break A. Completion by 12GIB6 supply of water during recirculation phase of a spectrum effects at 2440 MWt.

LOCA was not adequately demonstrated for power levels above 2440 MWt due to CS pump cavitational concerns.

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eg ENCLOSURE 4 ACTIONS ASSOCIATED WITH ISA REQUESTS FOR INFORMATION 4

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l PURPOSE OF ENCLOSURE 4 A database was generated during the ISA to manage the ISAT requests for information (RFI).

Enclosure 4 is a report from the ISA RFI database that links the long-term action items from the  !

RFIs with the Maine Yankee Task Tracking System (MYTTS). Expected completion dates for long- l term actions are being tracked via the MYTTS. The RFI database is no longer maintained current j to reflect schedule changes for the RFI action items.

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NRC RFI's Req iring Followtp Acti:ns 'A Sortet! By Functional Area And Request Naseher Report 30 FunctionalArea: OPSITRNG Req # NRC ltem/ Request Responsstde ST Date Due : MYTTS Person Short Tm h Date Compg 1.ong Tem h Numbers 1049 RWP issues DALTON, J. Brief NRC on PoRey. 7/23SS None None Completed On: l 7fw"96 l 1050 SAO - Tech. Spec. Interpretation DALTON, J.

Pm wrRten feedback. See 7/16S6 None None RFI 4041 Completed On: l em96 l 1058 SAO - Discrepancies on E-1 Entry Conditions HATHAWAY, R- E-1 pages 1 and 2 have been 7/3086 ES-02 will be updated during the bienrwel review. None reference given to document control to be reissued.

Completed On: l 8/9/96 l 1063 SAO - Discrepancy between FSAR and OP 1-2 DALTON. J. Discuss issue with NRC 7/2496 Maine Yankee will initiate a change to the FSAR to % 39-112 Dilution Paths provide esanRcation to enst7e consistency with Completed On: l 7/24.96 l 1064 SAO - Explain Difference in HPSI Flow Setpoints HATHAWAY, R. None Setpoints asa appropriate. None in FR-C.1 steps 2 & 15 1067 Ouestions concerning diesel generator. WELOUGHBY,P. Dtscuss issue wiwth NRC 7/2396 None None Completed On: l 7/25/96 l 1072 SAO - Noted that EOP Setpoint Basis Documents snsTH, S. P. None- AB setpoents in data base updated by 12/31/96 3 6 113 refer to the Maine Yankee Training Manual 1073 SAO - is one CET reading greater than 1200* F HATHAWAY, R. EOP Steering Conmttee 7/26 S6 Have Training Department We lesson plans 30-39-114 sufficent to enter FR-C.17 Meehng on locahon of CETs. wRh information suppimi by Operates. Update to F-0.2 background document.

Completed On: l 7/23/96 l 1079 What are vibratien set points of Reactor Coolant wtLOUGHBY, P. Prmide copy of vibration EmRs to 7/1896 None None Pumps? Inspector Completed On: l 7/19S6 l 1080 SAO - HSI-M-50/51 valve indication. VOGEL, T. Evaluate indicators locany. 7/25/96 None None Completed On: l 7/25/96 l 10-Dec-96

.c NRC RFI's Requirirg Follswcp Acti:ns 2 Ser1ed By Functional Area And Request Number Report 30 FunctionalArea: OPSITRNG Req # NRC tiem/ Request R,. w ^ ST Date Due l MYTTS Person Short Term Action Date Compi Long Term Action Numbers 1105 SAO - Program to track thermal cycles of the RCS paCHOLS, S. E. Providecopiesof above 7/2496 Develop procedure to kglernent thermal cycle 30 39-115 documents to kispector, traciong. (PED)

Completed On: l 7f5/96 = l

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1107 Status of CEDM problems during plant shutdown. DALTON, J. CMer Section wW provide SW9Q WO 96-2625 thmugh 96-2631 were created to 30-39-116 e to operations investigate and resolve seven chattering SOES.

management regarding manual sequermat operabons Completed On: l 8/1/96 l 1118 SAO - REPLACES ORIGINAL REQUEST MOULTON, B. None Work order previously iniheted for issue traciang 30-39-117 NUMBER 2156. and, 6 a.a.

CH-M-1 valve position indication. Evaluate local posshon indicahon configuratim change (gear ratio change) and/or redesign posibon indicahon method to interface directly with valve stem. Note: long term target date-1998 refueing 1119 REPLACES ORIGINAL REQUEST NUMBER MEtXELL, R- Work order scheduled, ready to 7/3096 Based on inspechon results of WO 96-1934, a 30-39-118 2155. work Work Order may be developed for pennanent Boron buildup on casing of P-14A "P"'

g 1124 SAO - T.S. 3.12 inte' pretation net properly NILES, J. Bring the Tech Spec 9/3096 Nme M 119 documented. Interpretation back to PORC for review and c.acumentation in PORC minutes.

Comphed On: l l 1125 SAO - Control Room Staffing DALTON, J. None Transfer Fire Brigade duties from the SOS to 30-39-120 another indMdual as a supplemental action to improve staffing.  !

1128 Time line for PCC issue. WILLOUGHBY, P, Declan! PCC Inoperable, enter 7/21/96 Install safety watves in containment PCC piping remedial action to technical wh, plant to cold shutdown.

Completed On: l 7/21/96 l 10-Dec-96

- e-NRC RFI's Rcquiring Follswup Acti:ns ~;

Sorted By Functional Area And Request Number Report 34 Functional Area: OPSITRNG Req #

NRC ltem/ Request R+. ST Date Due l MYTTS Person Short Term Action Date Cornpi Long Term Action Numbers 1132 Need assessment document for HPSI pump. En4TH,S.P. 1. Perform 3.17.6.6 evalumhon of W 1) % Op. Memo and Operatum Procedure 1- 30-34121,3009-P-14B when placedin serwce 11-6 to comply with the engmeenng directive. - 215 dunng the next scheduled ECCS Long Term Targt Date 12/31/96 Quarterly Survetence to ensure 2) Initisk a Performance improvement conhnued operabiuty of P-148. Opportur4 at the mammg meetmg Long Term .

Target Date 2/1/97

2. Initiets a Performance improvement OpporturW at the moming mutmg Completed On: l 8/16/96 l 1133 Status of shutdown items conceming MFRV's v0 GEL.T. 1). Complete WO 96-2560 to 96- 8696 None None 2564 to verify problem is not present on other valves.

2) Complete WO's 96-2567. 96-2568. 96-2536, and WO 96-2566.

Completed On: l 8/a96 l 1134 Status of shutdown items Conceming P-2B *AElXEti, R. None 1). Repair FW-F-8 postioner WO 96-256. 30 39-122 2). Complete MRFA #96-223. 30-39-123 1155 Training on Definition of Steam Generator Overfilt HAYWARD,R.M. None Operabons trarung to evaluate and upgrade 30-39-124 Licensed operator course rnatertal to ensure j inclus6on of concems associated with NRC Generic Letter 81-28.

1159 Adminstrative Controls of Service Water Pump DALTON, J. None Revise OP 1-15-3 to ensure that ECCS one 30-39-125 Combinations service water pump must be operable and operahng in each ECCS train to consider that .

ECCS train operable 1160 Provide correlation between FSAR and Procedure HEBERT.J R. None 1) Evaluate the fogranng wordmg on page 9-50 of 30-39-126 1-15-3 regarding Service Water the FSAR and detemune if R is appropriate 30-39-127 ,

" tfm occurence of an inesdent would find the Service Water System in the Normal Mode. "

2) Rev6ew other sections of the FSAR for similar wording and evaktate for appropnoteness.

i 10-Ikc-96

NRC RFI's R quiring Folinwup Actirs

' ~

Sorted Ey Functional Area And Request Nussber Report 38 -

FunctionalArea: OPSITRNG .

Req # NRC ltem/ Request ^; -

^

ST DWe Due )

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REYTTS Person Short Term Action Date Campi Long Term Action Numbers 1176 What evaluation was performed on HV-7 plywood? PORTHA, Fs. Complete HV-7 replacement 9r3096 Recewe new equipment Remove and repsace 30.G9-123 design documention Purchase easting HV-7. 30 39-129 New HV-7 equipment completed on: l l 1177 RH-4 Leakage Problems PORTELA B. Replace RH.4 8396 None None completed on: l ar29/96 l 1178 During the shutdown on 7/20/96 (mid-shift), while SMITH, S. P- None Evaluate 1 13-1 with regards to Step 6.3.14.  % 39-130 placing RHR in service, Step 6.3.12 in Procedure Modify this step to include a temperature range 1-13-1 (for piping warm up) directs that RHR heat rather than be"appraammeh equal?

exchanger inlet and outlet temperatures be approximately equal before preceeding. The delta T was approximately 35' F and the Operators continued in the procedure.

Please explain regarding management's expectations regarding procedural adherence, procedural clarity / accuracy and need, if any, for a TPC, etc. -

1180 SAO-Post Trip Reviews lack ' detail & rigor'. EBERT, P- None Compare procedure 1-2-1 against industry 30 39-131 standards and initiate any needed changes.

1181 SAO-Control Room Logbook entries are not made WHITE, T. Operations Management wg 9/1/96 Develop a PAP to review the Control Room Log 3009-132 for significant events. develop a reminder for against Sunellences, UOR's, Equipment  !

management expectabons to log Failures, etc., to check for cornistency in Logging entries. sigraficant evokshorm ,

campseted on:l araa96 l 1185 SAO - Procedural adherence. WHITE, T. None Operahans management review of samulator 30-39-133 feedback informahon concemeng throtmng feed flow to a ruptured steam generator during E-0.

1188 Timeliness of identification of penetration seal ARNOLD, J. None Close out plan 96 013 COP-96 013 problems.

10-ikc-96

-e.

NRC RFI's Reqriring Fcilzwcp Actir:s ' #

Sorted By Functional Area And Request Noseher Report 30 Functional Area: OPSITRNG Req # NRC item / Request Responsible ST Date Due l MYTTS Person Short Term Action Date Compg Long Tenn Actum Numbers 1190 FSAR differs from plant configuration HEBERT, JR. None  % the statement on page 9.8 to refied 30 39-134 operabons practice 1208 Reed Switch Discrepancies not simulated. HAYWARD, R. M- Incorporate control room fidekly NI'M more M padance on MwW M 135 check off sheet into procedure 18- wak order W to sMw remw M M 136 344-1. Generated Simulator .--mymee guedance into the Srnulator Fidelity Work Order 96-124 to invesbgate Report.

reed switch problems expenenced in the piart Compteted on: l l 1209 RC Trends HEATH,E. None Evaluate re<achon of primary side contamination 30 39-137 in reducir s personnel contemnaborn 1210 SAO - Would like to see total number of percons. HEATH.E. None Recommendsbons 30 39-138

• Review procedural guidance goveming the selection of survey technique and survey frequency of areas mentained as contamination free within the Restricted Area. This review must include the process by which surface contamnation is profited such as on wans, on equipment and other drnensens other than just the floor. Ensure this guidance generate data to alert Radiabon Protecbon to potenbal co'taminaban problems so that appropnate preventative action may be taken.

• Review controls govemng work in non-contaminated areas of the Restricted Area.

Ensure suney data as generated in the above recommendation can be reliably used to ensure that the radelogical consequences of this type of work are determined and appropnate c( viWory measures are taken.

• Conhnue improvement inRiative in the area of i-Ti...- indcator c.J.,,  ; and

...p. ...._a. in the self assessment actnees by Radiaten Protection.

IO-Ikc-96

e.

NRC RFI's Requiring Fell:wup Acti:ns Sorted By Functional Area And Request Museber Report 39 FunchonalArea: OPSITRNG Req # NRC ltem/ Request Responende ST Date Due J MYTTS Person Short Tm m Date cor gd I 8"!I Tenn Action Nienimars 1219 Results of Review of NRC IN's 88-83,91-13,92- SOULE. E. D. None Maine Yankee to develop a comprehensive acton 2847-11 40,93-15 & 93-38. plan h response to NRC generic letter 9641.

1227 SAO-Tech Spec 3.11 Interpretation WROUGHBY,P Evaluate RW 9/15S6 None 30 @ 139 Completed on: l 9/17/96 l 1229 SAO - Waikdown of critical manual action steps. WROUGHBY,P. Evaluate hsta8abon of 12r31/96 Imdallabon of rmdor operated wdves in senes wth M 140 emergency lights in the MS-59, MS59,79,99 area. -12/31/97 79,99 area - 12/31/96 con,ded on: l s/2ss6 l 1238 Provide written follow up on Safeguard pump test WEAST. J. 1. Evaluate P-61S operabMty 1M None 30 39 141 problems. with regards to as electricallogic 30 39 142 setup. 30-22-125

2. Maintain P-61S out of sennee until determination completed.

Completed on: l l 1240 The quality of communications used by operators DALTON, J- None 1. Enhance and grade operator comr9unicahons 30 39-216,30 39-during plant activities was good; however, the use during simulator sessions - Training. 217 of repeat-backs was inconsistent. In addition, 2. Dmcuss Management expectations on control room alarms were seldo.n announced to communicahons weh opendors during trairung the entire crew. The team observed similar weaknesses during simulator training sessions.

Number of Requests for OPSITRNG: 39 10-Dec-96

~ ~

NRC RFI's Requiring Fcliswup Actirns -

Sorted By Functional Area And Request Number Repor136 FunctionalArea: MAiNTITEST Req # NRC ltem/ Request RG ST Date Due j MYTTS Person Short Term Action Date Comp Long Term Action Numbers 2125 SAO - Assess condition of SW pump brg cooling HENRES.W. 1) Declared P-290 W - 8/2/96 1) Sagnificantly tygradannodify the cookng 5 39-75, 5 39-water from pump discharge. Complete system as part of the EDCR 95-31 effort. Date: 212

2) RN the degraded 1997 RFO - Long Term Target Date 10/1/97 rwn water line support to retum P. 2) CED to evaluate NNS seismic supph Long 298 to operable status. 7/20/96 is Term Target Date Gr3G97 target date. - Complete

3) Perform a formal analyss of the SW coohng piping in irs as-found condshon to determine LER reporting requirements. Date:

8/02/96-Complete. Per Bill Henries, this analysts was resolved via memo MYP 96-0496-Issued 85'96.

Completed On: l 8/15/96 l 2127 SAO - Provide history for temp. mod for mussel SOULE, E. D. None Masne Yankee has made a commRment to INPO 3 N 76 control sampling to reduce long standing yellow tags by December 1996.

2129 Pipe clamp missing by SA-136. DESROCHE 1.M. We work order to instar pipe 7/18/96 Schedule / Wort the above WO 96-2501-00, once % 39-77 Closed to WO 96-2501 ciamp *"Wed, planned and approved WO is READY WO 96-2501-00 initiated to to w rw has M been schedM as of WM address pipe clar'ys Completed On: l an5/96 l 2130 Has the base plate mat on P-14S been evaluated HENRES.W. a) Grout degradation evaluated 7/16/96 Repair degraded grott in accordance with priorty 30-39-78 for deterioration? b) WO initiated 2496 WO scheduled for 9/1tV96.

Closed to WO 96-2496 c) Evaluation attached 9/4: In PED for review.

COMPLETED Comptered On: l 7/1696 l 2138 Identify any temp. repairs (which still exist) which JOHNSON, D. None Repair AS-P-99. WO 96,2571. Completed None are included in RFI 2060 7/23/96.

10-Dec-96 t

NRC RFI's Requiring FcII wtp Acti:ns ~;

Sorted By Functional Area And Regnest Number Repet130 FunctionalArea: MAINTITEST Req # NRC ltem/ Request Respons tde ST Date Due j EWlVTTS Person Short Term Action Date Comps t ong Tenn Action NumIms 2140 P-25C has oilleak on front end of pump and is JOHNSON. D. Initiate WO # to insped inboard 8/16/96 Work to be scheduled 30-39-79 work ordered. What are plans to work? beanng. drain plug. 9/4: P status, Level 1 review.

Closed to WO 96-2504 WO # 96-2504 00 has been originated. As of 8/15/96 work orderis in OWCC files,no scheduled work date.

Develop and schedule an approved work order to correct iesk.

Work order priarty process will determine date.

Completed On: l 8/1596 l 2146 Explain deficiency on BD-T-12,22. DEE,R. None WO"s for BD-T-12/22 will be evaluated for work in None the next scheduled outage. Work orders 95-2143 and 95-2144 issued.

9/4. Completed 6/30/96 2152 Missing Clamp on RW-52 JOHNSON D- Work order #96-2516 was MW This work will be scheduled and -.WJ per the m Closed to WO 96-2516 originated to replace the missing normalscheduhng process. 9/4: Scheduled for U-bot. 10/28.96.

Completed On: l 8/15/96 l 2157 Explain discrepancy betyeen indicating lights on WHmE. T. Initiated Work Orders to correct 7/1S96 9/4: In planning, not scheduled. WO is nonnal 30 39-81 DG-1A/B deficiency. DG-1 A -WO 96 ops Prt 6.

2510; DG-1 B -WO 96-2511.

Completed On: l 8/15/96 l 2158 Ouestion on seeens for SW pump motors DEE.R. Electncal maintenance is 8/16 % None None evaluating the personal safety requirements for the screen and if appropnatewigpursueremoval of the screen on P-29C.

Complete.

Completed On: l 8/15,96 l 2162 SAO - Follow-up on failure to synchronize SMITH, S. P. None Reviewof Procedtre 3.1.14A/B to ensure 30 5 82 adequate controls are in place om operat:or of the lccal sync-selector control switeit 10-Dec-96

NRC RFI's Req: iring Foll;wup Actions ~;

Scrted By Functional Area And Request Neanber Report 30 Functional Area: MAINTITEST Req # NRC item / Request Ra ST Date Due ; MYTTS Person Short Term Action Date Compg Long Term Action Nienbors 2163 SAO - Long and short term plans for AOV. MORRISON, S. None Mene Yankee is C.J4 y an Ar Operated Vane 30 3943 Progrant Plant Engineering Department, Mechanical Maintenance, instrumerwahon &

Controls, and Corporate Ergneenng Department wig assess the foRomng Rems for inchJsson in a Program.

C- .Jy.e-a of a design summary documert for targeted air operated vanes.

Seled poptJahon of air operated vanes to be included in scope.

Develop an Air Operated Vane Program desenption Evaluate Fredictrve versus preventrve maintenance prognmt C;.J,. a of an integrated Air Operated Vane Team, including Coordinator, Mechanical Mairtenance, Instrumentation & Controls, and Engineenng 2168 Valve packing leaks in HPSI valve room. MCALUSTER, S. None Clean up Baron txmidup idenhfsed in Level 3 30-3944 maintenance boost 2175 IST Equipment in accelerated test frequency. SPRINGER, T. MOV-6013-WO96-2586 to 8/30/96 MOV-6013-WO 95-016931997 Refuehng 30-39-85 Troubleshoot and Adjustlimits. BD-T-146 change next Refueling Complete 8/6/96. FunctionaBy tested 8/9/96.

Completed on:l 8.9/96 l 2180 SAO -What caused the Rotor Seizure on P-25A in FLUET,D. NONE Complete Root Cause determinahort Per Dana 30-39-86 Jan.967 Fluet, still wortang the root cause determinshon as of 9/4/96.

2181 SAO - Steam generator blow down Isolation PACKER, J. Conhnue to test BD-T-146 8/16/96 WO 96-2611 htiated to install new actuator on 3W7 valves (6) have had their test frequency changed monthly BD-T-146. (During Refueling Outage 1997) from quarterly to monthly.

Closed to WO 96-2611 Completed on: l 8/16/96 l 10-Dec-96

e NRC RFI's Requiring Fcilowup Acti:ns ~h Sorted By Functional Area And Request Number Report 30 FunctionalArea: MAINTITEST Req # NRC item / Request Responsible ST Date Due i MYTTS Person Short Term Achon Date Compi Long Tenn Action Numbers 2195 REPLACES ORIGINAL REQUEST NUMBER SCHUBERT,B. Provide response as N 7/22S6 None None 3194. atxwe. Per BE Schubert, further 15 see auto start requirements and load time rweshgaban is regaired (8/1496).

sequencing info.

Completed On: l 7/22.96 l 2196 REPLACES ORIGINAL REQUEST NUMBER usCOMB. R. None inspecthelubricate gearbox during 1997 refusang 30 39-88 3265. W.O?s 96-2579-00 and 96-258040 have been SW-A-103 and SW-A-104 leaking oil from gear N box.

Close to WOs 96-2579 & 96-2580 2198 REPLACES ORIGINAL REQUEST NUMBER HENRES W. Complete WO 96-1532. g/12SQ Clamp is on but loose. 30-39-210 3196. Completed on 8/12/96.

Missing clamp downstream of SCC-414 Completed On: l 8/12/96 l 2202 REPLACES ORIGINAL REQUEST NUMBER BARRY,B. Inspect hhtaN hx. 8/26/96 9/4: Planned WO 96-2502 as Priority 7, 30-39-89 3209. WO 96-2502 was issued to Scheduled week of ms6 Elec. insulation appears to be broken to valve SW- replace the flex condut A-103 Closed to WO 96-2502 Completed on: l 8/19G6 l 10-Ikc-96

NRC RFI's Requiring Follswup Acti ns Sorted By Functional Area And Request Number Report 30 FunctionalArea: MAINTITEST Req # NRC ltem/ Request R; ; -_

ST Date Due : MYTTS Person Short Term AcMon Date CompI Long Tem Achon Numbers 2219 SAO - EFW surveillance per 3-1-22 failed. DALTON, J.

1). Calibrate PL1205A under M None None WO 96-2601). Work order 96-2607 was VOIDED -done via level 3. Calibrated satisfactordy 7/25/96 - Complete.

2). PED and Operations to detemme best method for detemunng reverse flow-Temporary Procedure Change (TPC) #96-257 issuer! by OPS 8/8/96. Tech EM 142-96 being prepared by PED (8/17/9S).

3). Incorporate procedure changes to perform reverse flow tests prior to startup- Temporary Procedure Change (TPC) #96-257 issued by OPS 8/8/96. Tech Eval 142-96 being prepared by PED (8/17/96).

Completed on: l 8/17/96 l 2228 REPLACES ORIGINAL REQUEST NUMBER MCCANN J. None Change FSAR Page 8-9 to reflect the correct start 3G49-145 3351. time of 15 seconds SAO - Please provide all correspondence from M.Y. to the NRC regarding licensing analysis for diesel start time of 15 sec. Also, any correspondence from NRC to M.Y. regarding the same issue. Also, provide documentation which justified changing surveillance criteria.

2231 REPLACES ORIGINAL REQUEST NUMBER HENRES.W. Move W12's and Macro FW 7/25/96 Mark new storage locahons 30-39-211 3292. Component (complete)

Evaluate capability of LS-1602B and C to Mark acceptable storage withstand consequences of CW pipe failure and locabons - Complete per Bill mussel sampling equipment failure. Hennes (8/17/96).

Completed on: l 8/15/96 l 10-Dec-96 '

NRC RFI's Req iring Fcilswup Acti::s ~;

Seried By Functional Aura And Regnest Number Report 3#

FunctionalArea: MAINTITEST Req # NRC ltem/ Request Responsible ST Date Due l 94YTTS Person short Term Action Date Compg Long Term Action Numbers 2236 The OEM's recommended NDE for the EFW pump mEIXELL,R- 1)tnitiate work order to replace P- 7130/9Q Replace pump intemals with new upgraded 30 39-90 P-25A was not performed during the last minute 25A pump intemals -WO 96- h pump overhaulin January 1996. 2683. Bemg remwed f r 1997 Refueling Outage.

2) Shipped new damaged P-25A intemale to IDP for repair on Req.

34816. PO 96-2384.

Completed On: l 8/15/96 l 2239 Provide justification for P-25 discharge pressure WHITE, T- 1. TPC #96 213 initiated to use !L@26 NONE None guage. suchon pressure gauge -

Complete

2. PED and Operabons to determine best method for determinsng reverse flow -

Complete.

3. Incorporate procedure chanpes to perform reverse flow tests prior to startup - Complete.

Completed On: l 8/19f96 l 2240 Provide info on how EFW Test 3.1.22 was DEE R. 1.) TPC 96-213 was written to 8.%96 NONE None dispositioned. anow use of suchon pressure gauges - Complete.

2.) PED and operations to determine best method for determenmg reverse flow-Complete.

3.) Incorporate procedure changes to perform reverse flow tests prior to startup - Complete.

Completed On: l 8/1996 l 2242 Containment walkdown observations DEE,R. Work Order 96-2655-00 written 7/2996 None None to correct paciong leak (RC-26 boron buski-up). Done 8/4/96 and functiona#y tes A 8/11/96 -

Complete.

Completed On: l 8/11/96 l 2243 Flange botting on PCC piping to all 3 RCP's is NICHOLS, S. E. None Upgrade PCC piping in containment 30-39-91 corroded.

10-Dec-96

NRC RFI's Requiring Fehowtp Acti:ns ~;

Sorted By Functional Area And Request Namiber Ry e 30 FunctionalArea: MAlNTITEST Req #

^

NRC item / Request R %- ST Date Due l MYTTS Person Short Tenn Achon Date Compg Long Term Action Numbers 2244 Corroded bolts on PCC valves in containment taCHOLS, S. E- None Upgrade PCC piping m contamment 3 M 91 2246 SAO - Explain why the lock wire is missing on five MORRISON, S- W.Ols 96-2671 thru 96-2675, BW Mod @ procedure 602-2, feed mcore detector M 92 (5) nuts on the in-core in:trumentation sleeves on inclusive, have been generated to inserten, to include a specdc requrement to verify the seal table. provide for lockwire remstaRabon. hh Completed On- l 8M/96 l 2269 Elaborate on responses to RFrs 2219,2239 and PELZER,P. Test aR effected valves prior to M None None 2240. 210"F/400psig of current start-up - Complete.

Completed On: l 8/19/96 l 2271 SAO - Missing lockwire on MOV-32 loop 3 stop MOULTON, B. None Complete 'e[.ew md pmcedural changes as valve and an apparently " skewed" valve stem on necessary to usnure cap screw pre load is valve RC-26. mamtaewd 2230 1) Why arent valves EFW-A-101, 201, 301, 338, PE12ER, P. None Complete COP-94-015, item 814 COP-94-015 339 and 340 identified as category "A" in the IST program?

2) Provide latest revision of closeout plan CDP 04-015 associated with SIC 94-006.

2288 SAO - FSAR Sect. 8.3.2, page 8-11, states HEBP (r,J.R. None- Clarify FSAR to better describe integral and day 30-39-93 "together the integral and day tanks are capable of tarts operatog capabaibes a minimum of six hours operation at fullload".

10-Dec-96

NRC RFI's R'; quiring Fcliswcp Acti:ns ~:

Sorted By Functional Area And Request Nuneber Report 30 FunctionalArca: MAlNTITEST Req # NRC ltem/ Request Responsible ST Date Due ) MYTTS Person Short Term Achon Date Comps  % Term Achon Numbers 2289 As discussed during an 8/12 meeting regarding HEBERT, JR. None incorporate FSAR change for revesed contammert 30-39-94 EDG Ioading, CS, etc. please provide the following: spary delivery times h FSAR Revision 13.

1) Explanation of containment pressure response curve with respect to CS actuation.

2) Timeline of changes made in EDG start time acceptability evaluations, containment spray effectiveness (press & iodine) evaluations, valve stroke time evaluations, and any associated testing changes and 50.59's.

3) Accident scenario time line.

4) EDG vender spec, for starting time.

5) Information on EDG failures-to-start and failures-to-run since 1987.

2312 What controls the length of time a tempora;y SOULE. E. D. Hone Engineenng to reduce number of open 30-39-95 modification may stay installed and what are the Ergneenng Temporary Mods by one half.

limitations?

2331 Provide info on P-29C bearing water support MEDTLL. R- Complete Root Cause 9/16/96 None 30-39-96 removal.

Completed on: l l 2333 SAO M49-Some EFW and AFW piping does not HENRIES.W. Issue DCR(s)to correct 8/31/96 None None match the isometric drawings. drscrepancies.

(Note: DCR 96155 issued 0905/96) comple*ed on: l 9/5/96 l 2342 Provide info on FM-918 discrepancies on pipe SOULE, E. D. None Revrse 1 550-F M-918 30-39-97 sizing.

2354 EDG Testing Procedures DALTON, J. None 1.) Consider a procedure enhancement on 30-39-58 3.1 A.A/B to speedy where the dieselis phased at.

2.) Step 5.2.6 which verifles P-25 block removed should occur prior stopping the visicorder 10-Dec-96

NRC RFI's Req: iring Foll:wtp Acti:ns ' ;

Sorted By Functional Area And Request Number Report 30 Functional Area: MAINTITEST Req # NRC ltem/ Request Rs;-:- "" ST Date Due MYTTS Person Short Term Action Date Camps Long Term Achon h 2364 MKW Memo, dated 6-9-92, from Don Galeazzi GRANT, R. None Evaluate DG derating assumphons as part of the 3M9-09 provides guidelines for derating engine load output next revision to MYC-107 *Ernergency Diesel for air intake temperatures above 90*F and for Generator Loa &wj" less than 190*F, JW outlet temperature with separate derating curves for Jacket water outlet

. temperatures above 190*F. Based upon air inlet temperatures of 110*F (MYP-94-0225) and DG-18 Loading of 2849KW, it appears that the derated load limit is exceeded by 2% during the first hour of a LOCA event.

2377 Control Room Ventilation issue. GIGGEY. C. 1- Complete root cause h 12/31/96 Revise procedure 3.17.5 & 31.18 before next use. 30 39-99 2- Complete cateusabons for 30-39-100 operatetytepartabety 30-39 101 determinahon.

Completed On: l l 2380 Request that NRC watch a PT inspection of welds LECLERC, s. Remove defect and re-examine. SQQ.90 None None during the moming of 8/22/96 (Thursday) 9/4: Rework completed 8/26/M.

Completed on: l 8/26/96 l 2382 During the Exit Meeting, Maine Yankee indicated MCCANN, J. None Submit FSAR Revision 13 30 39-102 that many, if not all, the inaccuracies in the FSAR/TS were previously identified and documented.

1. Provide the detailed listing of FSAR/TS inaccuracies you have discovered.

2. Provide the date of discovery of the discrepancies.

3. Provide corrective action dates for each.

4. If no corrective action taken, indicate when the changes will occur.

l 10-Ikc-96

NRC RFI's Requiring Fcilswcp Acti::ns Sorted By Fnectional Area And Request Nuniber Report Je FunctionalArea: MAINTITEST Req # NRC ltem/ Request Re% - ST Date Due ; MYTTS Person Short Tenn Action Date Compt t.ong Tenn Action Numbers 2384 Provide an update on maintenance performed on MASON. A- 8/27s 6 Evaluate stroiang these valves aner evohmons BD-T-12 from valve disassembly last week to heressed W 30-39-103 frequency as outlined in attached such as plant start tes or changes in slowdoim restoration. Please identify root cause of memo ARM 96-013. h, sm these dynamic evolutions may condrtion, if known. d'st dge debr4 fmm the steam generators.

(PED / OPS) completed on: l 8/27/96 l 2386 Response to RFI T 3 implies that the volume of HEBERT, J.R. None Revbe FSAR 30 39 104 fuel oil in the day took plus integral tank for an EDG is not sufficient for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of diesel run time. Explain why this is acceptable and whether or not the wording in the FSAR is appropriate regarding this run time.

2387 Was the reportability determination " identified in BRAfD Submit LER if requred W1 N None M 105 UOR 96-073 for BD-T-12 reviewed following review of the as-found condition (assumed "as found" leakage beyond recordable range)? This appears reportable per 50.73 (a) (2) (ii) as a loss of containment isolation function.

Completed on: l 8/2&96 l 2395 NRC ISAT Report, dated 10/7/96, pg. 44, para. 4 RADASCH,R. None Evaluate downward trend h DG-1B condRional 30-39-171 states the latest conditional probability trend for probability and " ntify action being taken or DG-1B is downward due to increased planned and planned to irr, e avaitatety.

unplanned maintenance.

2396 NRC ISAT Report, dated 10/7/96, pg. 45, 3.2.1.3, RADASCH,R. None identdy action being taken or planned to address 3009-172 para. 2 discusses failures in Centainment sump protWems with Containment Sump discharge vane isolation valves caused by debris in sump. testing tailures. Include status of mv ;.for trench screens and sump / trench cleaning.

10-Ikc-96

NRC RFI's Reqcirirg Fcilzwcp Acti:ns ~ ;

Sorted By Functional Area And Request Number Report 30 FunctionalArea: MAINTITEST Req #. NRC ltem/ Request Responsstde ST Date Due MYTTS Person Short Term Actkm Date Compi Long Term Action Numbers 2397 NRC ISAT Report, dated 10/7/96, pg. 47, para.1 RADASCH, R. None identify echan to be taken to address 30 39-173 of 3.2.2 and pg. 49, 3.2.4 (1) thru (11) states culturavattitude assues.

testing was not an effective tool in identifying problems. A lack of questioning attitude during test performance and evaulation was not conducive to discovering equipment problems, but rather to accepting equipment pesformance.

2398 NRC ISAT Report, dated 10/7/96, pg. 47,3.2.2, RADASCH. R. None Identify achon to be taken to address 30 3 174 para. 2 states some deficient conditions were not cuturaL'atteude issues.

being identified by either of the three main groups

- (Maintenance, Engineering, Operations).

2399 NRC ISAT Report, dated 10/7/96, pg 47,3.2.2, RADASCH,R. None Pmde status and sched* of LPRE efforts to 30-39-175 para 3, last sentence states Maine Yankee was in close ttWs specific issue.

the process of integrating existing fragmented corrective action programs with the intent of being more effective in identifying, resolving, tracking deficiencies and minimizing failure.

2400 NRC ISAT Report, dated 10/7/96, pg. 48, 3.2.3, RADASCH,R. None Evaluate equiprnent rnolfuncbon issue for any 30-39-176 para 1 discusses several instances of equipment mbstandard mawial condinon trends. Identify, malfunctions which occurred during recent plant as appscable, any correceve action piermd or shutdown and startup attempts indicated a akady W to address issa declining trend in material condition.

2401 NRC ISAT Report, dated 10/7/96, pg. 49 (3) states RADASCH R. None Evaluate controls in use to assure proper FME 30-39-177 poor FME work practices resulted in a failure of practices for maintenance actMbes in general is t BD-T-12. Weld rod found in seat. there a FME problem or does tfWs relate to an isolated case? Provide resuRs of evaluabon and plans to enchance FME cordrois as warranted 10-Dec-96

~;

NRC RFI's Requiring Fcil:wcp Acti:Es Sorted By Functional Area And Request Number Report Je FunctionalArea: MAINTITEST Req # NRC ltem/ Request R-- ;_ _ _ . - ST Date Due j MYTTS Person Short Term Action Date cornpi 1.ong Term Action Nanbors 2402 - NRC ISAT Report, Dated 10/7/96, pg. A9, 3.2.4 RADASCH. R- None Impemert cormetswe acten as rwcessary to 34 39-180 states despite many inconsistencies be; ween prevent future discrepencies between test information contained in the FSAR and the as built procedures and FSARMessgn requrements condition of the plant, the licensee did not recognize a need to review and reconcile test procedures with design requirements and to correct these errors.

2403 NRC ISAT Repost, dated 10/7/96, pg. 51 (4) states RADASCH,R. None ldertify close out schon addressed in ERB-13 01 76-14,01 emergency actuation activity currently not 15,01-76-16 adequately tested.

2404 NRC ISAT Report, dated 10/7/96, pg. 53, para. 3 RADASCH, R. None Evaluate scope of AOVs included in IST program 30-39-186 states approximate!y 10% of the station AOVs that perform safety reisted funchons. E gland were included in the IST program. Many of the program as appmpnote to include afety related valves not included in the IST program performed AOVs not rpesently covered. For thos valves which perform safdy retwed funcbons the we nd safety related functions such as the TCVs for PCC be w try IST m m appmprute and SCC systems (PCC-T-19,20 and SCC-T-23 &

24). Despite a history of actuator problems, these valves were not in the IST program.

2405 NRC ISAT Report, date 10/7/96, pg. 53,3.2.5 RADASCH,R. None Evaluate process used to factor WO information 30 39-191 states the basis for some of the risk information into C.Mi PRA stabsbes. Modify the may not be as conservative as previously process as twee sary to ensure as vand WO Wormehon (completer! WO) is included.

assumed because equipment failure data had not been updated. There was a large backlog of WO (some back to 1991) where work had been completed but close out of the work package was not yet performed.

2406 NRC ISAT Report, dated 10/7/96, pg. 54, 3.5.2.2, RADASCH,R. gh Idertify status and scope of WO efficiency 30-39-192 para.1 states some weaknesses were found in the improvement efforts. Inckxte schedule for work control process, however, the licensee was - A of plan.

assessing how to improve WO efficiency.

/O-Dec-96

_ - -. _ _ _ . . . . . . - -_ _ ~ _ _ ___ . _. _ ._ - . . -

NRC RFl's Req iring FcH wcp Acti:ns- 'd sorted my Functional Area And Reaguest Neanber Report 3e FunchonalArea: HADNTITEST i

Req # NRC Mem/ Request Responsede ST Deen Due ofYTT4 Person Short Tenn Action Date cg Long Tenn Action founters ,

2407 NRC ISAT Report, dated 10/7/96, pg. 43, para.1 RADASCH R. None Update IPE os requeed 30 39-195 -

states the AFW system (P-250) performed poorly for the time penod analyzed and was worse that the performance values assumed in the IPE. The e licensee was not fully aware of the poor condition [

of P-258 and had not updated the assumptions made in their IPE. '

I 2408 NRC ISAT Report, dated 10/7/96, pg. 53 (11) RADASCH,R. None implement a perkate cakrahon or othermee lE39-190 i states RWST transmitter enclosures heated above describe the process to be used h the hdure to transmitter design temperature. soeure heated anciosures contaning safety i relmied hatrumentreon are maintamed at a 1emperature that we not vietate the quellReshon of Instrumerdation. Reference SAO-E-14.

~'

2409 NRC ISAT Report, dated 10/7/96, pg.14, 2.2.1.2, RADASCH,R. None Perform How testing on HPSI pumps neal RFO. 30 3 194 para. 5 states the licensee plans a future test of conduct tests and record data so as to reache the HPSI pumps in a technically rigorous manner questions regardirig inck of mergm, operating to fully demonstrated the availablo margin. pumps beyond values prowded in vendor curve, and pump covention concems as empressed in ISAT Report, pg.14, para.1,2 & 4.

2410 NRC ISAT Report, dated 10/7/96, pg. 56, para. 4 RADAsCH,R. None issue is cultural and s'inude related and suggestr 30 39-197 states the team noted the lack of a " conservative our testing phsosophy is non-conservative testing philosophy" that resulted in the Provide a process and schedule to resolve tNs identificahon of numerous safety related issue.

components that were not being periodically tested or calibrated.

i 2411 NRC ISAT Report, dated 10/7/96, pg. 65,4.2.2, RADASCH,R. None idenIWy piens to be dev or attedy in piece ;E39-196 para. 3 discusses the continuing problem with P- to hdy resolve ins protdem. Include schedule for 2B tripping on low lube oil pressure. implementuhon.

10-Dec-96

- . - . - - - . - . - . - . - . - . . . - . . - - . . .. .. . _ . . . . -- . . - . - . . . . . . . ~ - . - . . - ...-._ - .. - - . . . - - . .

NRC RFI's Req; iring Fcilswup Acticas '-

Seded By Functional Area And Request Numiher Report Je ,

FunctionalArea: MAINTITEST Req # NRC item / Request Responidee ST Dah! Due , MYTTS Person Short Temi Achon Date Comps Long Term Action Neunbers 2412 NRC ISAT Report, dated 10n/96, pg. 21, para. 3 RADASCH,R. None Pnmde for penode PM and cabbrahon of velves, 30 39-196 under Tiow Dtversion" states that no calibration posinoners, and associated temperature procedures for CCW hear exchanger bypass cortopers as reg *ed to assise reliable opershon valves, (PCC-T-19/20 & SCC-T-23/24), the controllers were not of the fail safe design, and maintenance history showed 11 completed WOs for these valves in the last 5 years.

2413 Response to NRC ISAT Report, dated October 7 RADASCH,R. None Develop and implement a plan to greattw improve 30-39 199 1996, pg. 46,3.2.1.5, para 2, last sentence. the material candlhon of the SW pump boy area.

Commitment noted in report The licensee ProWie a descriphon of work scope and a indicated that resources would be made available schedule for c@ of prnyet to greatly improve the material condition of the SW pump.

2414 NRC ISAT Report, dated 10R/96, pg. 39, para. DALTON,J- None inspect containmerd and remove any unconroNed h;m3 3.1.3.2. merkings or information Number of Requests for MAINT/ TEST: 67 10-Dec-96

NRC RFI's Rcq iring Fcilowcp Actists d Ser1ed By Functional Area And Request Number Report 38 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request Re.im. . ~' ST Date Due l MYTTS Person Short Term Action Date Compi Long Term Acuan W

~

3128 Stroke time for HSI-M-50 & 51 upon SIAS. SHELDON. P. p 7/17/96 None None Completed On: l 7/17/9E l 3133 Data indicates 2 Worthington & 2 Bingham SW SHELDON, P. Provide h to correct P-29 7/16/96 None None  !

Pumps 4.. - curves.

Completed On: l 7/16/96 l 3136 SFP Cooling Questions JONES, H. None MYTTS 8 20-22-71 AND 20-22-72 as 20 22-71 summanzed in attached rnemo HFJ-96 035 20-22-72 3144 AFW/EFW Pump Suction from PWST. SOULE. E. D. None Procedure revision to incorporate proposed 30-39-30 changes 3153 Basis for location of FT 1201 A, B, C tranducer MATHIEU. J. A COP will be developed, 8/1/95 Perform grade 2 uncertainty calculation. 30 39-40 location. specifying need for a EFW flow test.

Completed On: l 8/7/96 l 3154 SAO - HPSI Time-line for SIAS SHELDON, P. pad, gg, 7/22/96 None None Completed on: ] 7/22/96 l 3157 High Energy Piping in DG Cubes LOZANO, L Complete 7/16/96 None None completed on: l 7/16/96 l 3162 Verify I-line Drawings in SWGR Room are current. LOZANO. L. Complete 7/16/96 None None Completed On: l 7/16/96 l 3164 SAO - Past commitment to NRC for cross-tying GRANT. R. Detennine N Meu Yh wM 7/2496 None None DC buses. conhnue to cross-tie DC buses at power. This will be answered under Req 8 3352. TPC 96-228 Completed On: l 8/6,96 l

10-Dec-96

NRC RFI's Req iring Fcil2wup Acti:ns '

Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGINEERING Req # NRC ltem/ Request Responsstne ST Date Due ! MYTTS Person Short Term Action Date Compt Long Tenn Action N e tsers 3167 SAO - E14 Justify use of nominal yard BARRY,B. Complete DBS96-042. Review 7/22!96 Complete TE-012-96 Design Basas Recovery of 20-22-111 temperature in Setpoint Cales. setpoint program calculations for Heat Tracing System 01-13-20 (32,88,3293,3296,3350) similar problems (Heat Traced Enclosures).

Completed On: l &20,96 l 3168 SAO - Questions from Review of MYC-104 BABIN ltem 1 Refened to MY Licensing !Z2G_9ll None None for Disposibon Reference Request # 3214 Completed On: l 7/2496 l 3173 FIT-6015 Design Requirements KULP,D. None 1. Recover Design Basis and instaRahon 30 39-29 documents

2. Upgrade installation to meet MY standa. tis, as reqtared 3174 Prordetary. Provide HPSI system instrumentation LOZANO,L Provide procedures for P-301, P. 7/26/96 None None datt 303, P-354W, L-307K, L-308K, A-1001Y Short term action complete with Rev.1 procedure submittal.

Completed On: l 7/2G96 l 3176 When do the EFW Room fans have to run? SMITH. S. P. TPC 96-160 complete 7/16/96 Proc. No.1-12-3 to upgrade at next revisson 30-39-45 interval.

Completed On: l 7/16/96 l 3182 Why is the heat tracing system NNS? BOURGOIN. D. None 1 Update FSAR Sechon 30-3947

2. Update applicable drawings 3184 Proprietary - P-61 A,B.S NPSH during injection SHELDON, P. Provide requested info. 7/17/96 None None and recirculation Completed On: l 7/17/96 l 3189 What is cable size of P-25A and P-25C motor BOURGOIN. D. Process Drawing Change 8/11/96 None None cable? Request 96-120.

Completed On: l 8/26/96 l 3197 Provide Fuse evaluation process info BARRY,B. Complete. 7/17/96 None None Completed On: l 7/17/96 l, 10-Dec-96

NRC RFI's Requiring Fcilswup Acti:ns 4!

Sorted By Fur- tional Area And Request Number Report 30 Functional Area: ENGINEERING Req # NRC item / Request Responsible ST Date Due l MYTTS Person Short Term N Date Comps Long Term Action Numbers 3201 Task summary / schedule for Fuse Program FREWIN, W- None See FUSE Data Base- Action 06-19-15 References / Schedule Projectcompletion7/26/97 3203 SAO - Answer HVAC questions on swgr. room MCCONATY None Finanzatxan of MYC-1570 30 39 @

ventilation design basis 3205 Describe MTE identification control. CARD, J. Provide informahon 7/19/96 None None Completed on: l 7/22,96 l

'3221 MYC-1734 Comments / Questions BRADLEY,G. None Correct MYC-1734 with respect to pump 30-39-39 hWW Bingham vs Worthington on p.10.

3225 SAO - E24 Cat. data for R.G.1.97 standby power KulP.D- Create MYTTS Rems to ass %n 7/26/90 - Cahbrate Reg Guide 1.97 Standby Power 30-32-1133 instruments. (More data: 3395) Tag Numbers to all Reg Guide Wors N2m 1.97 Standby Power instruments - Enter standby power instruments in MtPPS 30-32-1135 and to include these indicators in equipment data base the Electrical Prh - Update RG 1.97 source document Maintenance Program for calibration.

Completed On: l 7/26.96 l 3226 List RG 1.97 instruments marked "EQ". KULP,D. Add EQ Label for PR-1012,- 9/996 None None 1022,-1032 i RI-6113 A & B Light Box indicahon for CI Valves Completed On: l 9/8/96 l t

10-Ike-96

NRC RFI's R2 quiring Fcil;wup Acti:ns ~

Sorted By Functional Area And Request Number Report 38 P

FunctionalArea: ENGlNEERING i

Req # NRC ltem/ Request Responsible ST Date Due J MYTTS Person Short Tenn Action Date Compi Long Term Actiort Numbers 3228 SAO - Acceptab4 sty of Atmos. Steam Dump tacHoLS, S. E. The orupnal short term action 8/12/96 Complete actions in COP 96004 and MN-9644. 30-39-46 System- was to pmvide a pesentation to ,

NRC on results of upcomog I meeting between Maine Yankee and Stone & Webster on ASDV modrficahon.

Update: Stone & Webster presented a draft Conceptual Project Authorizabon (CPA)to Maine Yankee on August 22, in response to Maine Yar*ee comments in a meeting on July

29. Stone & Webster is recommending that a "5%"

atmospheric steam dump valve (instead of another"21/2%"

valve) be added in parallet to the existing dump valve . Also, Stone

& Webster recommends replacing the common 6" decay heat release header with 8" piping which wiR increase the capacityof the existing i atmospheric steam dump valve.

This project is stir in the conceptual design phase and this information may change before finaldesign is completed and approved Completed on: l N22/96 l 3239 SAO - E17 EQ Instrument / Cable Submergance PAPKEN,R. Complete EQ submergence 8a96 Evaluate impact to EQ program and make COP-96421, No walkdowns. necessary rev% ions and/or plans for physical plant MYTTS Complete DBS96-044 changes Completed on: l as96 l 3245. Provide an update on the HX test program. MARSTALLER.T. Provide draft of" POP" revision 7/26/96 Implement " POP" revisions that have the new heat 3439-47 and schedule for complebon exchanger accettance criteria.

Completed on: l 7/26/96 l 10-Dec-96

NRC RFI's Requiring Fcll;wcp Acti:ns

'i Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request Responsable l ST Date Due l MYTTS Person Short Term Action j Date Cg Long Term Action Numbers 3258 Provide discussion for RWST temperature BERGERON. P. Provide requested information in 7/2496 None None assumptions rnemo TAG-MY-96-069 Completed On: l 7/31/96 l 3260 SWOPl closure mechanism for updating DBSD. MCCABE,L None Update service water DBSD to renect screen 30-39-48 wash pump change.

3261 Provide basis for 20 min. flood time. SHONE, R- None Perform Service Water Calculahon WE-103 30-39-49 3274 Evaluate combined effects of FN-32 Mat 1 MEfXELL. R. 1. Added % latch to 7/22'96 1. Replacelatch. 30-39-50 condition. mechanical maintenance 2. Repairheplace FN-31 discha ge boot,if descrepancy Est. required.

2. Initiated Work Order to 3. Temporary Modification to provide adequate evaluate FN-31 discharge boat. venhiahon to protected switchgear room per Tech Evat.128-96. Work Order 96-2584 initiated.

Completed On: l 7/21/96 l 3275 SAO - Do FN-44A/B dampers fail open? JENNtNGs, K. Design Basis Screen 9tMy51 7/3066 To be driven by the DBS process 30-39-51 written to evaluate poterfst loss of air flow Completed On: l 8/2/96 l 3278 SAO - Observation: Cable losses not considered GRANT, R. None Evaluate the addition of cable losses into the 30-39-09 in DG loading calc. calculation.

3280 SAO - Provide commitment to resolve HV-7 issues. DROTTER,F. S. Complete HV-7 replacement S/30/90 Receive new equipment and associated project 30 39-128 design documents Purchase new matenals Remctal of existing HV-7 and 30-39-129 HV-7 equipment and associated associated rnatenais, Mc. Installabon of new HV materials reviews and approvals unit, tw duct work, piping control valves, etc.

of vendor summittals, develop Functional test (s) and w . Med to late field work packages for review S*Pt ember through October 1996. Final and spprovals,WO's etc. Target  %-w 11/1596 date: Present through September 1996.

Completed on: l l 10-Dec-96

NRC RFI's Requiring Fcil wup Acti:ns Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGINEERING Req # NRC ltem/ Request Responsible ST Date Due l MYTTS Person Short Tenn Action Date compi Long Tem Action Numbers 3290 SAO - P-25B reliability is low PELZER,P. None Cause Memmatm for 2 recent failures of P-25B 30-39-52 (Equipment Root Cause).

This has been prepared and is in Engineering Management Review.

Maintenance Rule cause determinahon and (a)(2) to (a)(1) package for exceeding criteria.

This is scheduled for w@u,. 30 days after the Equipment Root Cause.

(a)(2)to (a)(1) disposiboning To be presented to Maintenance Rule Oversight CommRtee within 30 days of competim of MR Cause determination and (a)(2)'3 (a)(1) Package 3293 Provide Operability Determination information For JORDAN, T. To be re<:alibrated prior to start. 7/30/96 None None LIA-303AK up via Proc. No.3-6.2.1.41 Completed On: { 7/23/96 l 3298 ls there a hard-piped spent fuel pool make-up MASON, A. Complete evaluation of DBS 7/30/96 K1ne 2422-93 049 and iake appropriate action.

MYTTS 20-22-99 20-22-102 MYTTS 20-22-100 MYTTS 20-22-101 MYTTS 20-22-102 Completed On: l 8/20/96 l 3299 Is SFP levelindication EQ? HEBERT, J.R- None AOP-2-52 upgrade upon s/d rule issuance. 30-39-53 3312 SAO - Ot,servations on MYC-1559 (electrical DONNER, J. None Determine accuracy of Westinghouse DWS 30-39-10 coordination). #267C172 Revise MYC-1559 and at other affected calculahons and documents if necessary.

3314 SAO - Calculated diesel generator step loading BONNER, J. None Revise and Reissue MYC-107 30-3!)09 not in accordance with design basis.

10-fke-96

NRC RFI's Requiring Fellcwc:p Actirns ':

Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request a-- - -

sT Date Due l MYTTs Person Short Tenn Acnon Date Compi 1.ong Term Action Numbers 3315 Cable damage curves not in MYC-1063 BONNER, J. None incorporate cable damage data into next revisson 30-39-11 of MYC-1063 3323 SAO - Basis for operability of SW pumps at low MCCABE, L None See request 3342 5 39-55 low tides.

3324 SAO - In Calculation MYC-107, what was BERKLAND. D. None Revise MYC-107 to incorporate data sheet from 30-3SO9

assumed motor efficiency for P-12A and P-61 A. MYS-601.

3326 Outdoor instruments and weather protection BARRY, B. None Write Tech. Evaluation for setpoint on Fuel 04 30-29-28 Level Instrument.

3334 SAO - Power for emergency fans used in loss of GRANT, R. Instal an extension cord in the 8/7/96 InstaE permanent welding outlets from MCC-7A 30-39-12 swgr room ventilation. Appendix R cabinet. and MCC-8A. t Completed On: l &5i/96 l 3338 Provide information supporting memo WES JENNINGS. K. None ped should resound the intake channel no tater 30-39-54 009 than summer 1998. This should be tracked via MYTTS.

- 3339 SAO - Provide evaluation / justification for P-12A & BERKLAND. D. None Complete revision of MYC-107 30-39-09 P25C D/G loading.

3342 SAO - Provide operability determination for tides <- MCCABE, L None Process appropnate FSAR change and 30-39-55 7ft. corresponding 10CFR50.59 evaluation for extreme low service water bay levels.

3352 REPLACF.S ORIGINAL REQUEST NUMBER GRANT, R. Provide info response to NRC 7/17/96 DC Bus Operaton Procedure Change 30-39-13 1048.

Time restrictions on operating with battery buses tied?

Completed on: l 7/17/96 l 10-Dec-96

• 6 NRC RFI's Requiring Fcilzwup Acti:ns '

Sorted By Functional Area And Request Nuniher Report 30 FunctionalArea: ENGINEERING

" Req # NRC ltem/ Request Responsitste ST Date Due i MYTTS Person Short Term Acnon Date Compg Long Tems Actmi Numbers 3353 REPLACES ORIGINAL REQUEST NUMBER DRAKE. B. Provide info 7/17/96 None None 2123.

Provide priority on WO's.

Completed On: l 7/17/96 l 3354 REPLACES ORIGINAL REQUEST NUMBER MEtXELt., R. None implement WO 96-1722 and WO 96-1724 30-39-56 2124.

HPSI valve WO status 3356 REPLACES ORIGINAL REQUEST NUMBER ERK:KSON, D. WO 96-2457 is being 7/15/96 Complete Work Order 96-2452 2139. processed - make WO ready P-298 gland drain is plugged. when approved.

Completed On: [ 7/2496 l t 3360 SAO - REPLACES ORIGINAL REQUEST HEBERT. J.R. None implement safety analysk information document 30-39-57 NUMBER 1071. (SAID) and SAID control process.

Why is the IASD incomplete?

3366 SAO - E15 TS 2.1, 3.9 & FS/P c.*fpass Condition HEBERT. J R. Submit suggested changes to the 9/1/96 Incorporate changes into Tecincal Spec 6fications 30-39-41 Discrepancies FSAR and technical and FSAR by Cycle 16.

4+T- % m to clarify bypass conditions Completed On: l 8/22/96 l 3369 SAO - Reference Response # 3074, HSI-M-11 GRANT, R. 1. Review MOV Program data 7/3G96 1. Verify al MOV Program sizes in MYC-107 are 1)30-39-09 MIPPS data disagrees with FE's MYC-107 (D/G against FE one line diagrams and correct as part of the calculation revision. 2)30-39-14 Loading)' issue a DCR to correct as 2. Perform a root cause to determine how this deficiencies. This PCtion is e sight occM complete.

2. Examine MYC-1542, MYC-979, MYC-1615 to verhiht the MOV HP sizes are accurate.

This action is complete Completed On: l 7/30/96 l 10-Dec-96

4

~

NRC RFI's Requiring Fcliswup Acti:ns Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request Responsitde ST Date Due l MYTTS Person Short Term Actiot Date Comp Long Term Action Numbers 3379 Identify Pipe L at could have affected safety sOULE, E. D. None DBS96-006 Rev. 2 is tracking corrective actions 20-22-59 functions. and interim measures COP-96-014 3384 Ref. response 3312. Assuming the new LRA is HYYRYNEN,K. None Revise MYC-1559 with new P-14A,B,S data 30-39-10 correct (571 A, vs 649 A), will the overcurrent relay -

be changed?

3385 SAO -Was a 10CFR50.59 Safety Evaluation done DALTON, J. None Mame Yankee will institute a procedure change to 30-39-13 on the DC bus cross-tie procedure change? alicw the cross-being of DC buses only in condibons 5 or lower for maintenance actMties (per Request #3352) 3390 REPLACES ORIGINAL REQUEST NUMBER MEtXELL, R. WO 96-2514 inihated 7/19/96 Evaluate need for PM to penoditcally clean Drain 30-39 58 2137. To be completed based on Collechon System P-25A pan drain is plugged. priority and system work Completed On: l 7/19S6 l

~

3391 REPLACES ORIGINAL REQUEST NUMBER Mute 4, v. WO 96-2500; Priority 8. 9/2G96 Complete WO 96-2500 30-39-59 2141, Temperature switch mounting.

Completed On: l l 3392 SAO - REPLACES ORIGINAL REQUEST JOHNSON, D. WO 96-2518-Clean boning 8/2/96 1. PM for annualinspection of s& cone 30-39-60 i NUMBER 2142. recess and seal with smcone PMC Request 96-151 initiated.

SW pump base plate bolting. Will be determined based on priority.

Completed On: l l 3392-1 SAO - REPLACES ORIGINAL REQUEST MEtXELL, R- WO 96-2518-Clean bolting 8/2/96 1. PM for annualinspechon of silicone. 30-39-60 NUMBER 2142. recess and sealwith silicone PMC Request 96-151 initiated.

SW pump base plate botting. Will be determined based on. [REV 1: 2. Implement a suitable fix prior to startup priority. from the 1997 Refueling.

PMC 96-151 to be closed by 08/02/96]

Completed On: l l 10-Dec-96

.A t-NRC RFI's Rcquiring Fcliswup Acti:ns '

Sorted By Functional Area And Request Number Report 30 Functional Area: ENGINEERING Reqit NRC ltem/ Request Responsitde ST Date Due MYTTS Person Short Tm Action Date Compi Long Te Action Numbers 3393 REPLACES ORIGINAL REQUEST NUMBER MElXELL, R. InRiate WO to clean cogection 7/24/96 Schedule / work an approved work order usang the 30 39-61 2143. system for P 25A leak offlines. work crder priorty process for scheduling Excessive gland leakage on P-25A WO 96-251440 originated to address housekeeping issue.

Completed on: l 7/24/96 l 3396 Provide basis for Auto-start time of P-2A/2B on GRANT, R. 1) Review post plant trip data for 8 S*96 Incorporate resuRs of short term achons into MYC- 30-39-15 low FW header pressure after P-2C trip. motor driven feed pump auto 430 " Auxiliary Power System Votage Study".

starts. This is complete.

Completed on: ] BS'96 l 3399 SAO - Provide heat rise and time required for a MCCONATY None Finalize Calculabon MYC-1570 30-39-08 loss of FN-31 or FN-32.

3413 Temporary Equipment chained to floor grating ME!XELL. R. None Secure Rems to r,tr a:tural steel. 30-39-213 which is not secured.

3416 Rg 1.97 pressurizer heater operation SOULE, E. D. None 1) Ensure computer point # 286 is included in the 30-39-26 calibrahon program.

2) Change REG Guide 1.97 Data Sheet to be in agreement with attached memo to M. Marston from D. Bourgoen 3429 Provide plans to address containment PCC pipe NCHOLS S. E- None Replace Carbon Steel PCCW Piping. 30-39-62 corosion.

3433 How was " Equivalent Total Fouling" Derived in BRADLEY,G. Revise memo MYP-9S4380, 8Q0@tli None 30-39-38 MYP-96-0380, Rev.17 Rev.1 (MYP-96-0466/LOCA-MY.96-031. Rev.1)

Completed on:l 9E*D6 l 3438 Provide an evaluation, or explain why one isnl HENR:ES. W. None incorposte this analysis into the RHR Hx design 30-39-37 required for the RHR Hx transients shown in RFI # documentation.

3305.

>!O-Dec-96

NRC RFI's Requiring Fcilswup Acti:ns Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGINEERING Req # NRC ltem/ Request Responsitne ST Date Due MYTTS i Person Short Tenn Action Date Compt I eng Tem Action Numbers 3451 SAO - Follow up questions on the FE one line not GRANT, R. Complete. DCR 96-129 written. M None Ne matching the HSI-M-11 horsepower size.

Completed On: l 8/2/96 l 3468 SAO - What is the Turbine Building HELB effect MccONATY None Finanze Calculation MYC-1570, Rev.1 30-39-08 on swgr. room ventilation?

3478 'SAO - E39 RWST Hi-Level Alarm Setpoint does 1.OZANO,L None COP 96-021 Containment Flood Evaluation. COP-96-021 not match MYC-1173 value. -

3485 SAO - Provide heat load references in Calc.1570 BOURGOtN. D. None Rev.1 - Update MYC-1570 30-39-08 on switchgear room ventilation 3489 What controls heat trace setpoints? BARRY, B- None Heat tracing design basis recomy MYTTS 01 01-13-20 20 3494 SAO - Question on 115KV Voltage Study MYC-430 URBANOWSKI.S. None issue revised calculation MYC-430 30-39-15 -

3518 Provide DBS & evaluation of FN.31 intet damper NICHOLS, S. E. CEDNNSD to determins the 12/1/96 Conect FSAR section 7.7.2 wording 30-39-63 failure mode. function and required faGure N mode for this damper. Damper should stay blocked open until this work is completed. Note:

This is a cold weather issue.

Yellow Tag Request #96 027 has a required clearance date of 10/1/96.

a Completed On:l l 3520 Provide DBS on FN-44A/B inlet dampers racHOLS. S. E. 1) FN-44A & B inlet dampers 8/19/96 Evaluate making FN-44A/B inlet blocking devE 30-39-65 blocked open per Yellow Tag 96- a permanent modificebon. (Evaluate cold weather

28. Operation).

2) Develop matrix to be used for ventilation system Design Basis Documents Completed On: l 8/19/96 l 10-Dec-96

. _ - - _ - _ , - - _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ - _ - _ _ _ _ _ _ _ _ - . . - _ _ _ _ _ ~ _- .- - . - . . - . . . , .. _

=

NRC RFI's Requiring Fcil;wup Acti:ns '

Seried By Functional Area And Reaguest Number Report 36 FunctionalArea: ENGlNEERING Req # NRC ltem/Re:e.m. Responsable ST Date Due l MYTTS Person Short Term h Date Compg Long Ten N Numtws 3527 Containment piping thermal over pressurization SHELDON, P. None Pmde comg*ted Docmetahon of Contammt N 26 Penetrabon Review, MYP 96-584 3530 PCC Pump Degradation SPRINGER, T. None Evaluate -i,; ;nirs the fut flow test and IST test 3CL39-35 for the SCC and PCC pumps into one test and evaluate the lower flow IST limit.

3539 SAO - What are Maine Yankee's plans for MCCABE, L Present Conceptual Designs 8/22/96 Formulate Long Term HVAC ;. yw i.-its 30-39-16 Protected Switchgear Room Ventilation Mods. in the winter.

Completed On: l 9/1/96 l 3541 Provide Information on BUL-79-14 Pipe Support HENRIES.W. None 1. Evaluate ISl-DCR process to update dwgs. 30-39-66 Verification Processes. 2. Verify support geometry / adequacy of H-21 on MKS-104A1.

3545 Provide documentation that the HPSI suction MElXELL, R.

DCR 96-145 and 96-146 issued 8/31/96 WO 96-3037 OPEN. 30-39-67 strainers are removed. to remove temporary strainer references and WO 96 3037 issued to verify the P-7 strainer has been removed.

Completed On: l 8/26/96 l 3547 SAO - E42 Procedure 3-1.15.2, Manual RAS LOZANO,L None COP-96 022 and GL 96-01 Project 28-07-11 Circuit, does not adequately test the manuai circuit.

3548 SAO - E40 Safeguards annunciator circuits are KULP.D. None The procedural review to be conducted to satisfy 28-07-11 not tested by surveillance procedures Generic Letter 96-01 wW include recommendations to add venfication of annuncetor window activabon in the refueling outage survemance procedures.

I 10-Dec-96

. _ - _ . , _ _ _ . _ _ - - . . _ - . . - . _ - - _ - . - _ . - _ _ _ . - _ . - - . - - _ _ . _ _ _ . . - _ - - - - _ _ _ _ . - _ - _ - - _ . - - . _ _ - - - - _ - - _ _ - --- -.-_--_- - --- . a -,<.-__.,-_.--_._-~---.-..__e - - _ - - - _ - . - - _ - - - - --

NRC RFI's Requiring Fcilcwup Actians ~'

Sened By Phnctional Aura And Reaguest Needier Report 38 Functoonal Area: ENGlNEERING Req # . NRC ltessi/ Request W ST Deee Due MYTTS Person Short Term Acelen Deee Cornpg Long Tenn Action Numiners 3554 Why were some of the plant MSKs superseded or mCHARDS None The"C . -.Centnr issue remed ty this 30-39-68 voided? . request,is addressed ty the followhg action.

1. AB of the"supersedesr* MSK-series drawings should in revised to remow the"-_l _ ^ ~ or

" voided" stamps and they should have the foBowing note added.

"This MSK summentes the original Stone and Webster strees analyses resuRs for the sutgoct piping system. The Intest analysis of record for this piping is identilled in Attachment A2 of the Guideline for Seisnuc Symiens Siructures and Components

• C4YMEG-G01)."

The intent of this change is to restore those MSKs which suR reGect our current

• analysis of record" to nor - , _ ^ ' asetus and to direct engineers to the proper location for verifying that changes how not sigereeded this enginal informenon 3558 SAO - Provide Temporary Modification for FN- t#CHOLS, S. E. See ISA Request #3520 8/19f96 See ISA Request 3520 30 394i5 44A/B Inlet Dampers.

- Completed On: l 8/19f96 l 3564 Explain MKS discrepancies and corrective actions HENRIES. W. Issue memo to Engineering dept. 8/31/96  % BZ and MKS drenings for supports whose N personnel- MYP 96 !ssued. function was modified by lEB 79-14.

Idenkned DCRs wel be issued-DCR 96-147 issued.

Completed On: l 8/26/96 l 3565 Are manual loads considered in the diesel loading BERKLAND. D. Screen analysis perfonvied 8/15/96 Revise MYC-107 to address Service Air 30-39-09 calculation? Compressors being load on Diesel Generator early Completed On: l 8/15/96 l 3572 2 Questions on the lack of calibration procedures GRANT. R. None 1) Revise OPS Procedure 3.1.14A and 3.1.148 to 1) 30-39-17 for D/G load sequence timers 62-5 and 62-P25A. include time deley acceptance cetterie. (12/31/96) 2)30-39 18

2) Evoluete adding a seperate rouune cembranon P.M. (06/30/97) 10-Dec-96

NRC RFI's Requiring Fcil;wup Acti:ns '"

Sorted By Functional Area And Request Number Repott 30 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request Responsable ST Date Due . MYTTS Person Short Term Acnon Date Compi Long Tenn Action Numbers Go74'VerW software control SHELDON. P. Obtain vendor C of C and 9/1)@6 None 30-3944 complete 50.59 determination.

Completed On: l l 3575 Provide PCC Operability Determination GeFFORD T. Complete technical evaluebon 9/1M None 30-39-33 and evaluate reportabilty Completed On: l l 3581 Provide test instrument accuracy. GIGGEY, C. None Close out open item R8 of the SWOPI Matrbt. 23-21-52 3582 Generic question on inadequate testing of critical GRANT, R- None 1.) See #3572 1-4)30-39-19 time delay relays. 2.) Develop Calibration P.M. for 62-P4 for every 5)30-39-20 other refuehng interval.

3.) Research Maine Yankee history, industry expenence, and vendor recommendation for Agastat relay calitrabon interval. Set up every 4th refuel calibration #W Interval unless a shorter interval, down to every other refuel minemum,is determined to be mere prudent. ,

4.) Research Maine Yankee history, industry expenence, and OEM for DG 1 A/B time delay -

cahbrahon interval. Determine appropriate intervat, down to every other refuel minimum, for these time delay relays. -

5.) Revise OPS. Proc. 3.1.15.2 to verify the trip  ;

block function of the 62-RAS timeru.

3583 For 115KV System: 2 Questions on MYC-430 " BONNER, J. None Contact CMP to request add Donac statultty study 1)30-39-15 Auxiliary Power System Voltage Study" for system loading at 1300MW and incorporate 2) 30-39-21 into MYC-430.

Contact CMP and relay importance of Maine Yankee Capcitor and Suromec LTC Transformer Auto Boost; and need to inform Maine Yankee on i either being out of service 09/30/ES 1

l t

10-Dec-96

• k NRC RFI's Requiring Fcilzwup Acti ns. 'C Sortes By Functional Area And Request Number Report 3G '

FunctionalArea: ENGlNEERlNG Req # NRC ltem/ Request Responsitde ST Date Due l MYTIS Person Short Term Action Date Compg Long Term Action Numbers 3584 SAO - Provide HPSI throttle valve flow vs . position NICHCL.S, S. E. Estathsh an acten plan for 12/31/96 Carry out achons from above plan by end of 1997 30-39-69 data. evaluebon of HPSI throttle valve refuehng outage. 30-39-70 improvements including possitde trim replacement, different tolerances on stem stops, and/or ,

wne,; Jen of these i

throttling /balancmg ophons completed on: l l 3587 Ref. Proc. 3.1.14A ' Loss of AC Test" Step 5.2.6- GRANT. R None Revise Ops. Proc. 3.1.14 A and B to change 30-39-22 Explain the referer,ce to the 30 sec. time delay for 5.2.6.a from 30 seconds reference to 20 secor.ds.

P-25C start difference.

3590 Provide information on broken MOV keys. NICHOt.S. S. E. Replace support keys or perform 8/26/96 Perform root cause on overalt issue and cany out 30-39-71 DBS on issue. approval .~,u..aations.

Completed On: l 8/28/96 l 3595 Provide containment electrical penetration BONNER, J. None Perform a formal study documenhng the electncal 30-39-23 electrical coordina* ion. penetration short circuit protection.

3609 Provide GL-89-13 Commitments. SOULE. E. D. None 1- Evaluate the influence of instrument 30-39-71~

uncertainhes 2- Re-evaluate the acceptance criteria or fouling factors that are currently used.

3- Evaluate and/or incorporate a worst case CCW-HX test.

4- Re-ev duate monitoring methods and frequencies to assure compliance with GL 13/ ENC-2 gunfelines 5 -idenhfy and schedule necessary changes to our GL-89-13 programs and procedures.

6- Determine and documerd the need to provide an update to our current GL-89-13 response.

' 10-Dec-96

.e 2

NRC RFI's Requiring Fcilowup Acti:ns Sorted By Functional Area And Request Number Report 30 Functional Area: ENGlNEERING Req # NRC item / Request Responsitne ST Date Due l MYTTS Person Short Term Action Date Compi Long Term Act6on Numbers 3610 6 Questions on FN-20Af20B D/G Room Exhaust GRANT, R- None a. Review thermal overload protection for ad a) 30-39-24 Fans. safety-related MCC motor loads and document b) 30-39-25 this review via YNSD calculation with target date of 12/31/97.

b. Evaluate the FN-20A/B thermostats to determine an appropriate calibrahon uiterval 3616 Provide additional info. on CS Pump NPSH. SHELDON, P. None Evaluate methods to increase Containment Spray 30-39-32 Pump NPSH Margin 3626 Please verify CS Pump Suction Line Losses. BENSON None Revise MYC-272 30-39-31 3629 Was G. Bradley 1991 Recommendation to isolate NORTON,S. Re-evaluate MYTTS 10-13-09 for 10/1W None WM HV-7 Steam implemented? iw A. of the recommendation into EDCR 96-33 HV-7 Modificabons Completed on: l l 3631 SAO: E19 Miscellaneous Drawing and Calculation LOZANO,L inmate DCRs 8/22/96 Revise RWST level calc aner heat trace eval 01-13-20 Discrepancies. complete.

Completed On: l 8/30/96 l 3642 SAO: E50 EFW Flow Transmitters LOZANO,L None. Perform detailed radiahon exposure calculation. 30-39-27 3643 Provide clarification on E/C responses and SCHUBERT, B. None Upgrade EC sonware program with 30-39-73 checkmate application concems. CHECKWORKS 3651 Provide info on control of calculations of record. MCCABE,L Resolve requirement to submit 9/26/96 None 30-39-74 list of cales submRted during ISAT (Rem 3).

Completed on: l l Number of Requests for ENGINEERING: 108 10-Dec-96

NRC RFI's Requiring Followup Actions

Sorted By Lunctional Area And Request Number Report 30 /

FunctionalArea: MGT & ORG Req # NRC ltem/ Request Respons4tde ST Date Due l MYTTS Person Short Term Action Date Compg Long Term Achon Numtws 4041 SAO - M&O - 003 PORC has made non DALTON. J. Terrrmate T. S. Interpretation &W 1.) Perform a review of existing T. S. 30-39-106 conservative decisions 5.5.B.9 and provide fotow-up WW W existing Wdions, M 107 review for LER. other , and the FSAR. Resp. Ops 30-39-108

2. Provkle the review to PORC for a review of the Completed On: l 10/2/96 lqu)ality of the assessment.

3.) Evaluate Proc.1-26-2 agaenst industry standards for this type of procedure to ensure consistent approach to ttis type of clariracation l (i e., use of 10CFR50.59).

4.) Licensing should evaluate the number of outstanding interpretations and initiate the Tech Spec Change process where warranted.

4046 SAO - Proprietary - M & O -001 Integrated ARNOLD, J. None Develcp enhanced Business Plan. 30-39-109 business plan 4102 PRCE # 182 - Corrective Action Status MEtXER, R. Select vendor to provide expertise 11/1/96 Upgrade Crane Maintenance Program. 30-39-110 for upgrading the crane 30-39-111 irea,e program.

Completed On: l l 4114 Background information EDCR 94-54. KULP O., Determine Reportability 9/15/96 None None Completed On: l 9/17/96 l Number of Requests for MGT & ORG: 4 10-Dec-96

. -. - .- . . . -. . . . . ~_-. ..- .-. . -- . . . . .

.?

t

i l

l ENCLOSURE 5 I i

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1 ACTIONS ASSOCIATED WITH l l

ISA REPORT STATEMENTS l

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PURPOSE OF ENCLOSURE 5 Enclosure 5 provides a road map that interconnects staten:ents, issues, concerns, and acknowledged follow-up actions from the ISA report with tracking or clo:ure documentation. As applicable, it cross-references the ISA report section, ISA request for infonnation (RFI'; number, ISA safety assessment observation (SAO) number, Maine Yankee Task Tr>cking System (MYTTS) number, and the Business Plan initiative number.

l The ISA report made repeated references to various deficiencies noted during the ISA. An entry was

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not necessarily made in the Enclosure 5 table to track each instance that a specific deficiency was l cited in the ISA report. However, sufficient information is provided to allow confirmation that each deficiency is being tracked.

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ACTIONS ASSOCIATED WrrH ISA REFORT STATEMENTS Business Seedse Seasement RFI ' SAO MYTT5 Pimm Comenrunamme to Design and Laesosing Basis-Transtemt and AceMems Sassey Assaynes 2.1.2 YAEC did not have a wnmem process to docianssa how sesety analyses cadonmed to SER aandma== 3360. C-13 3039157 F-2-3

p. s 3039I58 3039163 2.1.4 Ahhough weaknemass were foemed, the mass sesam line egenre smalysis was femmd to he =aa=g==ld= due to W On the hemis of MYP '

p.10,11 summemay samties personned by YAEC sad W in the MSlJt described below the ISA temum cameluded that these h

, 0638 had been .", addressesL [Maime Yankee h are desenbed in summo MYP 964638]

2.1.5 YAEC ihd not have aw process in place to idemnfy sad reek key phenomens for encli of the tr- and

• in the sedwy analyses C-7 3039159 F.2-8 p.13 report andin turn idensify wcode N and perumeeric samly efforts. During the ISA, YAEC h he wnsing t of a "Meehads Overview C-9 thru Manust" which was insended to seiress these issues. C-17 3039163' Comforumance as Design and I % Basis - Design Review of selsread Systemen 2.2.1.2 .-.the bosamme plans a lbsure tem of the ifSI puseps in a M ngorous manner to fidly desmosterase the available margiiL 2409 E-25 3039194 B-3-6

p. I4 E-48 2.2.1.3 The plemand ifSI flow tesmag to veri $ pump M- et high Bow will also enable the licensee to reset the & ef diese [ IPSI Ilow comaral 3354 303956 B-3-6 p.15 thromie] valves using a imore precise tolerance to ename that required flow is smet and rimont condihons are mot exceedet The licemmee plans to inchade 3584 303969 the r==ehme of these valves to a menre precise toleramce as put aflhet flow testing 303970 2.2.1.4 The almiity of the CS syseem to provide a reliable supply of weser duing the recuculabam phase af a LOCA was not M A====* meed for 3616 C-18 303932 A-3-3 p.15 opersesom at power levels above 2440 MWt due to CS pump carnational concerns. E-27 E-51 2.2.1.4 (2) As a sesult of the ISA esum's concesa. the t==== perfanned an evalumnom that com6nmed an increase of[CS pump] ==reiam pipe fricsson losses 3626 E-27 30393I A-3-3 p.17 tout 4.5 feet to x ^ '; 5.3 feet E-51 2.2.1.4 .-.Fouesnes the . the h ea=^=+=8 addsmonal [CS pump] analysis to support plant operanon at up to 2440 M1ML Enct3 A-3-3 p.17 Issue 6 2.2.2.6 The ISA team was unable to raarh=le and the lacessee did not demomsense, that these [PCCW/SCCW] heat resmoval sysians would performs " , ' , A-3-4 p.20 under " _ accident comenoms ensimmung team a power level of 2700 Mwt.

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Busimons Sereise h RFI SAO DEYTT5 Fine 2.2.2.6 . an emymmanus abrecesse had been pravuled to ensure the SW sysaem would be aperuand widum certaan h=ina Housever, die opename h 3404 Campa 5 p 20 psevided m ehe emymourung duecerse were not bemuled by the licassums On the bens of she E ===ds smalyms,the CCW symems would met support plum apennan up to te SW tamparamure values in the FSAR. [Camplese: TE 121-%; MFU 96-172]

2.216 Fouhme discours used for the CCW and RHR heat --- _ .were mot apprapnmeely - yven the lack of rehable tesmag dame to com6ra the 3609 E-28 J03972 B-3-5 .

p.20 maammed values.. The ISA tessa had the follounns 9=en ca-r**ms wahibe licensse's heat *=hager sessums programa.

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(a) Inserument umastammy was cat a ====a=4 for mi _" .the fouhmg values. .;

(b) The asemiled lar*=== for the Bow sumamunng devices were less than opemman to ammme uccency, and the Sour sneenmang devices were not .

enkbruned for esir ep-Ae ,, or a4maand for the acommi pipe wmE 'h=*===

(c) Heat enchanger esbes were clemmed en a periodic beas; however, there was no regerumment to do performance tesmag just before the best -i muchamper a.==== thus ibe - fouhmg veine was not besag =r=*=ed.

(d) The lack of surface h W smede the measured temperammes smanspeNe to pesammal seremmmag 2_216 TheISAteaun , " the basis for the 10 heemk value [in MYC-1742, Rll, suce in the case of the PCCW symmun, the heat land inchmied the 3529 3039209-

p. 21 spent fed pool (SFP) best exch=yr, which had a denen load af 9 beauk (pner to re-racking), ami cach esmergency diesel heat ==h=ger, which had 3039214 aland h at 5 heent 2.2.2.6 Im 1995 es Ecassee discovered that the CCW best --h=g r bypass valve, PCC-T-20, was apua about 11' followsms en anempt to siipi it to its safety 3575 303933 i

p. 21 seisand pommon, clammL At the amme. Maine Yankee was in en omsage and am usus-a=a aparabihty W was not seguired; hosoever, the

.r , determummason had not yet besa ==pa=ed at the imme of the ISA.

2.216 The ISA team found am cabbrumma. 34 these [CCW HX bypens] valven, the commaRers were not of she "fmit safe

• desiyt, mer " _ were 2404 3039186 B-3-10 .

p. 21 famed shut named stulily af these valves to pe ~.wm eher sainy ruimmed thaceien, and the hissary af theos outwas iemmedad li campissed 2412 3039196 work erders (WOs) for %se velves in the last Sve years. _the i====== personmed a test an the PCCW teumperamme comaral valve mAer the esmua let to see. This test was reparted as

• 1 % the opersman ef this valve. _

Cemeer===== em Bemism and IJemesing Basis - Elmeerleal and Inser====* med Camersh 2.3_2 As a sumult afrecumsly yd=aas Che voltage ==a=, the hcensee was a the process ofsuvuung the electical sysseus emelyses in % MYC-430, 3396 E-23 303915 A-3-10

p. 23 It.3. 3494 212 Maine Yamine would again manfy Che to bnes she Maine Yankee capar*- beak and Swainec Transsanner Amno Baast isso service at yid landag 3583 E-23 303921' A-3-10 p.23 yemaer esa 1,300 MW. ]

2.3.2 Che would be asked to perfann a syssam ammiysis based en a pid loading af 1.300 MW and die mesults would be used to venfy er adegasse sysema ~ '

3583 E-23 303915 A-3-10 p.24 vahngetoremetthedayaded yid - ' . relay. 301921

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2.32 The thE syneem bene came waaid be h ham e=Ir=i=hr= MYC-430 and repieced widt a new case which is bened an the yid at a 1.300 MW loei 3583 E-23 303915 A-3-10

p. 24 2 i 3

._ . - . . - . .m_m_ . . _ - .m_ _ _ ____.____..._._._.___._____._m____m._____m_m__'_-._m..__m____._____._._m___-_ __ m- m__ _ _ _ __. ___m m_ _m_._m__._ _ _ . _ _ . ,e-

b Busimmes Seedne h RH SAO MYYT5 Pima 2.3.2 The celeramon solarums bent of the deyeded pid _ . ' . reimy would be mlucent 3494- E-23 303915 A-3-10 p.24 2.3.5 The ISA team moemd the following probisses wish the eh of EDG W in e=hdannam MYC-107; 3278 E4 303909

p. 24 (1) Cable power lasses in die 4-kV and 480 Voit ac synnans were not incorparssed imeo the Adma=

2.3.5 (2) Theloadingpro61ewas' -widi FSAR and design reaper ====se 3314 E-8 303909 p.25 2.3.5 (3) There was a lack ofW in the calculamen to support minear loads. 3324 E4 303909 p.25 2.3.5 (4) Pimmyanotarloadingwas= - . IPSI pump lamens in calcidman MYC-107 was id-aded as 336 kW; however, the laadian value at 3339 E4 303909 p.25 runous would be 364 kW. The EFW pump lameng was also bened an a monumal value of 378 kW rusher them on the rumout value of 441 kW.

2.3.5 (5) Cameral air conspressor manami stat, requued by procedure ECA42 was not imaarporated imeo the +dma- 3565 E4 303909 p_25 2.3.5 (6) MOV. were anth for in the EDG laadine h in tot opersoors and miosars for 14 MOVs were nylaced under the 3369 E4 303909 ~

p.25 MOV Uppade Pteyen,but the anosor' esages were mot included in the elecencal ame-line drawungs and traded E-31 303914 2.3.5 ha rv to the ISA teesn's concerns in diis men, the lir==== prepared a prelisnimary revusam to eW MYC-107 which showed that the loadmg E4 303909 p.25 cm EDG-IB (warst. case) increased tema 2,629 kW to 2,842 kW (a 213 kW increase), stdl below the 2,000 hans/ pear rumme immit of 2,850 kW.

2.36 (I) lamrrect einear data were usal for seems the IPSI pump moonor prosecine relsys in e=hd=*m MYC-1559, in that the incorrecs locked rosor 3312 E-16 303910 p.25 current was used. 3384 2.3.6 (2) Incerece cable date were used in the coordmanon curve for the EFW piump P-25C moeor la calculatum MYC-1559. 3312 E-16 303910 p.26 3384 2.3.6 (3) Cable dans sad ceNe damage carves were ammeed Gesa e="d a- MYC-1063. RS, where curves dul not idemmfy the feeder cabis sine and did mot 3315 E-16 303911 p.26 macarparese the cable damage plot om die coord=ma= curve to W that the cable was protoceed h wish industy procace.

2.3.7.1 Dh- were sneed in the design of die protected switchgear roase W systemt The h was aware c( and actively currecums, samme of COP 9614 A-3-5 p.26 these dsW As a result of the ISA team's inqunes h vulnerabakenes were idemm6ed. The est effect of diese recemly id-adad probleums could be mendicant, pasmNy-_7 . frees I percent to up to 10 penxam addan==8 probababey ofcare damage.

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Busimase Saeolum - h RFI SAO MYTTS Pima 2.3.7.1 The ISA tessa found that the lice === bad no c=trid*=a or analyssa wiuch evalueesd the consequences of a [ protected switchgear rensa] supply or 3203 303908 A-3-5 p.27 an=== fan fuihme coincident wak a LOCA or HELB seuler worst <:ase elecencal lontag. 3399. A-3-9 3468 3485 2.3.7.1 _the ISA tamma found that the [MYC-1570. R0] e=arad*= dul not address various [protoceed swachgear rooms] fan imihme mumlest 3203 303908 A-3-5

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p.27 . 3399 3468 2.3.7.1 (5) Along-tenu,pennesseth was im=M to instaD s9=,a in the pr===*d switchgear rooms which would be powwed tomi EDG- 3334 E-6 303912 A-3-5 p.28 backed esmergency buses MCC-7A ami MCC-8A.

2.3.7.1 (6) The current HELB cvaluation covered ====ar canditions only;ilme licensee was for=adanne plans to resolve this issue for wuser ca=An=== 3539 202259 A-3-9 p.28 303916(c)

COP 9614 2.3.7.2 The tv-ae was in f yn --ss of' ,  ; a design change to. ~ ; the HV-7 supply unit to solve the existing desip probiumns.

1876 E-10 3039128 p.28 3289 3039129 2.3.7.2 lhe ISA tsaan fousul no evulen e abat this issue [VP-A-56 & VP-A-57 problena found 2/20f91] had bens emnered imeo a correserve action syseese or was 3520 101309 E-3-4 p.29 bang tracked by the lir===== 1his was an exasaple of the h*: fadure to take appropnene action to address a plume proldemL {see Eact 7 3039575 Ciarde*==]

2.3.7.2 _the ISA tears ca==hred the I 'sr- ' weak in regard to the lack of fonowup of the ide=edr*= of the d==g=r concerns fromi 1991 and 3269 E-10 303951 p.29 also week in that the recame focus on the probleses whh this v==smania= system dul not result in idenedying a .L ' ' ; whh damquers VP-A-56 and 3275 VP-A-57.

2.38 1he licenses stated that thisr .--

- [1-22-2] was inan=M to be used only en lismiend h with due rav=&eamos given to overall plant nak- 3352 E-4 303913 p.29 However, as a result af draa==sa== widi the ISA tensm, Proceitare 1 22-2 would be revised to Immit crosa-ames of de buses to Ca=an== 5 or lower (i e., 3385 plant met at power)for acemmes.

2.3.9 The ISA temen also moeed that there was no ammped seescugineer wah prunary. , *;inthis[EQ] aren. B-3-8 p.30 2.39.1 As a result of the ISA teami's inquiry, the licassee ia-aded 30 e belour die submergssce lewel Several of these w such as HCV- 3239- E-17 COP 9621 E-3-8 p.30 257. HCV-271, and TV-3501, were the same ,

that were idsmedied as below the ' - level is the tir===='s 1900 subanetal and the NRC's SER- -

2.3.9.2 1he hommese sessed that ev=h== af this issue [EQ of FIT-1201 A.B.C] was immhr way as part of a revusan to DBS 96-41. This revision would add an 3153 E-50 B-3-4 p.31 action iemma to provide a deemiled review of the r=dissia= done at the insenannut t ar min = [See Enct 7. Clarde===l 3642 4

____m________m _ _ _ _ _ - _ _ _ _ -__--_im__re-e.,-..c_

. - ,_-_ -- w , _ e.- - - - r.m__ .- _ m v__2 -___.s _- r- _ ._m _-m_m _ _ _ _ - --v.'_-_ ___.__.__-.r- ____,,__e- _ _ .-w -

Besimese Section Staeussent RFI SAO MYTTS Flam 2.3.9.2 In addenua, the licensee's RG l.97 sutumnal and Regulatory Gumle Source Document. "Demgn and Q=Idicema Cateria kr Post Accident Mannonns 3225 30321133 B-3-L

p. 31 Inse-wmmma

• ident 6ed these transnutters as beeg appropnately EQ queh6ed with no denanons from NRC gundance. 30301134 30321135 2.3.92 The hcensee did not adequately categorue and nientify the excepuans taken on the RG 1.97 data sheets. 3416 030942 B-3-8

p. 31 303946 13.9.3 The licensee had recently ident:6ed an expanded HEIB concern in the timbine building that had the potential to impact safety related comp-we in the 3414 202259 A-3-9 p.31 turbine buikhng. 3539 303916(c)

COP 9614 Confersmence to Design and IJesesing Basis - FSAR W 2.4 Prior to the ISA team amval on mee, the licensee intiated a FSAR armt Techescal E, - --- review to hfy escrepancies with the 8% basis. 3039102 F-2-1

p. 31 The licensee placed prionry on revieweg those systems bems reviewed by the ISA team. Over 100 issues were idamnei The ISA team idenu6ed adenonal discrepancies which are A i hroughout t the report. Many of these issues will require changes to the FSAR and 10 CFR 50.59 renews since eqmpment and proceares at MYAPS have changed fnun that desenbed in the FSAtt.

2.4.1 The-reung on the spent Ibel pool (SFP) heat exchanger was not canasient with the design values in the FSAR. The licensee claimed a 3136 E-9 202271

p. 31 reasonable eywr**w= that this IDC could be used to restore summal coohng follomag bulk bodmg and was trackmg an action item to analyze by 202272 January I,1997, the capabihty of tius IIX to go to 225F.

2.4.2 In a lener deced July 1,1996, to the NRC, the licensee comnutted to make phyncal changes to the .;,4 steam dump system to improve relieving 3228 E-12 303946 A-3-8 p.32 capacay and reesce the isolation tune of the afecial SG.

Assessawat of Cr.. alSafety-Opereelema Assessament 3.1.1 The team found that Operanons was efective in identifymg problems, but nosed weaknesses with problem resoluhan. 3039175 E-3 4 p.33 31.1.1 During the g' _.-4 of a plant shusdown on July 19 and 20,1996, the team observed that the operances expenenced several equipment problems 2411 3039198 p.33 winch complicased the shundowit These problems evolved the inp of a moeor<$ riven main feedweect (MDFW) pump following an attenipted start._

_the slow response of the main feedwater pump recirculation valve when the pump was started 1134 3039123 3039202

_ leakage past a main feedwater regulating valve bypass valve wluch required additional opersior attennon and actions Complete

_.and the inabdity to operale the control element assembhes (CEAr , a the manual sequennal node due to a plant compuser which was camly 1107 3039116 B-2-3 overloadei 5

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Bedeses Smetime Se=a===e RFI SAO MYTT5 Plus 3.1.1.1 e , - -j h were taken as a result ofdesip vuhiersinhees ===ac==a d widivenalaman systems for the safety-reissed banery roomms, swischgear 3520 E4 303965 A-3-5 p.34 rooms, emergmacy desel gamerasar (EDO) ramas, ami the - ^ spray buahag E-10 COP 9614 B-2-4 COP 9617 turbasebushhas a nahm,n=r.,as COP 9607 A-3-9

_the immbihty to resmosely isoisse a rupamed steam guesrasar COP 9604 A-34 a single,underinzed, sessa gamerusar ==a=ph ne snesse dump (ASD) valve 3228 E-12 303946 A-34 COP 9604

_and a deyaded a8 mise poner supply. A-3-10 3.1.1.2 The teamm was camcased that the licassee had wh aa=Aar*=g proasdural requmessenes that would be , " to comply widiin the event of 1125 Compleen

p. 34 fare commendent wide a mem6 cal esmargumcy Dunne ibis possulesed event, the summmum stadling requeaments respured in the Th ?,- ?- RFII125 would not be sensdied if the semiar reecent operanars " as desenbod in the licensee's admnessaramve preceduren.

3.1.1.2 The teman famed that Maine Yankee has previously developed e - . action plan to address the shiA *ning inumes which included- (1) using 4044 O-16 3039120 p.34 securuy peren==e8 rusher sham the PSS as - he=1 first r@,(2) using a second CRO as the fire tuigade leader rasier them the SOS. (3) providing an dwsecunty guard for the fire bngede to suplace am amehery operanar,(4) amhancing the dose prW procm and (5) % STA eSecammess. However,the sense desenmined that Mame Yankee's schedule for ' - . these conective ar*a== by the and of 1996 was not tumsty.

3.I.1.2 The team also doesnummed that the licensee missed am apparammty to M and anvect this . _-. , dunas its review of!N 91-77."ShsA Stamms '

II47 ca pi **

p.34 at Nuclear Power Planes,* which w McSe Yamkee's r==pa== to a Ere RFI1147 31.1.2 Mhnia==my, the licensee planned to add a thisd iM reactor operator to the commel room staff and ==ap=at he t duties of the fire brigade leader to I125 p.34 the reecear aparasar. (see Enci 7, Cien6camens) 3.1.2.1 The quehty of- used by agerseers dunng plemt acemises was good, homever, the use of repost-backs was - Imnahmos, 1240 3039216 D-2-9 p.35 comaral roosa slanms were =hh- a=r===I t o else emmre crew. The team observed simular W dunag

• training - 3039217 3.111 Commul roman logs tarias detal and did not meet the y=d==r* provuhd in Maine Yankee's =&===seramve procedures. 1181 0-36 3039132 D-2-9

p. 35 3.1.2.5 _the tensa moeed ehnt the lia=== made am iscorrect opersinhty h h wah the perfanmance ofengsmeared ' . . _ fessee [P-14A O-28 p.36 & P-14B] relay testing. [see Enct 7,Clanfr aa==1 3.1.2.6 Maine Yankee =he a d hus t it piammed to cancel the [ Tech Spec 51B.9]imeerpretamast 404I camepleie p.37 6

Basimasa

• a-a===e RFI SAO MYTT5 Plan Saetism The team W that inchahms a daily a=a=====a grab sample in this imeerpressman [Tedi Spec 3.14] was a change to the TSs because tims did not 1883 3.1.2.6 4041 p.37 represamt a ,operuang systemL The lacensee disayend unch the teamL At the conclusion of the assessment,the NRC was revieweg the e of this TS interpr=*m==

De PTRs [ post-enp reviews), in general, lacked risar and casapien-a== The reviews & not have deensled event n==hmee ==pa.ee desenpesans of I180 0-14 3039131 J.I .2.7 p.38 the event, and operator:==l-== could not be detenmined temaihe docie====a== The PIRs dal not ==a== a ca pl=== list afresymred and a-pla al short-ears conecuve accians and piammad lams-tenn curreceve acmana. In =Ah8=, mulmdmal opermear ma=====aa ==am-d a the reviews gamerady dui mot a=ami= sudicient detad m add value to the review.

PRCE 209 A-3-8 313.1 Am=9 the h licammae pisamed to correct the [ADV] problem, these plans were defered and alesmanely canceled in 1992. De I-=== M mot ynmde p.38 en - , as to why the plans to increase the relief em were e===8ad

. event ruiMaine 3228 E-12 303946 A-3-8 3.13.1 In the Plant Root Cause Evaluaman Report a= plan =8 in July 1996, the li~== a=ch da8 that the ICC evuut was not a " .

COP 9604 p.38 Yankee was not respured, nur dulit a to have the capabsiny to ammesse an ICC event. Nonetheless, the twaa- did infans the team it imeemds to

" ^; the plant to increase [ADVI sneem relief capacey 3228 ra-pa e 3.13.1 To casure that the hmmes of 10 CFR Part 100 would not be eve- i-8 in the event that an aver 611 candinan dut occur [as a resuk of am SG1R with a p.39 ea-c a=a loss of-L Maine Yamkee

.J, lumined rescear eaal==a s ystema asemey to 10-peseest af the -- value aRawat by TS.

1229 Casuplete 3.13.1 Alag the h-was evalemang theu maa= of emergency bahting in this area [ upper levels of the smain steam valve areal. -

RFI1229 p.39 2242 3039203 3.13.2 Dwing tours of the - the tesem faimul handunmen marknes as the war that incialed safanmel synessa drawmies. P seemedle=a=*

and a scale used in detenmsung reactor vessel wiser level when in reduced enemoary. De licensee =&e=aa8 that these were old m% were not 2414 p.39 used, and woukt be resmoved.

' Plan (FPIP) in 1995. The essen famed that Maine Yankee had smede progress in impn=====""t 1153 072860 A-t-6 3.I.4.1 Mmme Yankee insmeused a Fue Pr***= 4

p. 40 the FPIP. Plammad acemmes sucIwled W.the desipi bens for the FP sysica,inspacang peneerenan seals, and uppaang the puncedures for commeums ==a- ales and iy=a== seemeest Caumplete 3.1.4.1 Mame Yankee added a Fire Pr* *= F=g-a ,plassed to hire a new Fire Prunacman Caoreham , sad creased a Fire Pr* *= Training insencear P.40 pa=e-Maine Yankee was not e5acave in idemedying and comamiling - in areas of the plant considered to be cleast 1210 0-40 3039138 A-2 3.1.43

p. 41 7

--..n - . --.._- - - . _ _ . - - _ -n- . _ _ _ . - - . . _ , . . - - - _ _ _ . . - - . . - . . - - . _ . . - - - - . . - . _ . _ _ _ _ _ _ . . _ - . . . - . _ _ - - . - . . - - . - - - - - . __ , , _ , - _ _ - - - - . . - - - - _ _ . _ - - - - . - - - - - - - . - - - - - . - . . _ . _

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r Busimmee Sessima en - RFI SAO MYT13 Plan 3.l.4.3 The rh & program het been effecove in id-mihag areas where improvanent was needed, but had been less esseteve at reaching timese 3029190 A-2

{i

p. 4I problemas. 302919s I

3029199 3029200 30W3 1209 O-40 A-2 i 3.I.4.3 _Sp ne=uy secumag psoblems had been aceed in iba ereas cWwexpomme, the comarol of per=====4 - use dproceeses, and ,3039137 i

p. 41 ansparvisory overacht 1210 l3039138 a======e of C m "Sassey-M% medTaselas A ^

3.2.1 Comenomel,, _" " " which incorpersee compenset avalabihees and reliabihties were poor for the AFW sysaema 3290 M-13 303952 B-3-3 p.42 B-3-12  ;

3.2.1.1 (1) Baand on the results of testing, the AFW system performed poorly for the tune pmod analyzed and was worse than the perfor==c- values =====as 2182 M-13 303952 B-3-3 p.43 in the licensee's IPE. 3290 .

i The h was not aware of the poor condstnam of AFW pusep P-258 and had act =pd=aai assumpuans inade in their !PE. 2407 3039195 B-3-3 [

3.2.1.1 (3) A specialtest of P-14A rw in a failure to snart. T.-. . metmees to determee the cause of the falure i=Ae a-f that a wire has been COP 9622 2

p.44 inadvenemdy resnowed in the SIAS stat circust for P-14A-3.2.1.1 (4) The IB diesel had besa slowly impremns hona a weak N probabihty of m ', 80% frosa Deceumber 1993, to Anne 1996, when it 2395 3039171  ;

p.44 reached 90%. The laaest tmed for the IB diesel was downward due to increased plumed and - ;*-

i In =das== the h had estabbshed a close out plan [ COP 95-06) to idennfy and track ismses with [- ) purge valves im general [RFI til8 1818 3039117 i 3.2.l.3 p.45 addresses CH-M-1 only] COP 9506 3.21.3 AW repensive testing Imhmes involved the contair aent sump isolenon valves caused by debris in the sump such as tie-wrses, weld rod and safety 23 % 3039172 A-24 p.45 wue.

3.2.1.3 Prapa==le had bene suggested to provide ad&tional trench screens and to clean the sump and -- trenches during the 1997 refachng ware 23 % 3039172 A-2-8 i p.45 3.2.1.4 During the [7/20/96] ainage, nahtsanal egapment problems were identified that needed to be addressed prior to startup,includsag operabilty problems 3290 M-13 Complete B-3-3 i p.46 wnh AFW pump P-258.

. excessive leakage of a residual heat removal valve (RH-4L. [ cia-d by WO %2879] 1177 Complete P

e i i

I

-. . - . - ,  % -,. , . -_--_4 . - - . . - ,.-- _.m _ _ _ _ _ _ - . m4___ m_ _ _ _ _ _. - - _s

Businese seesium Semessent RFI SAO - MYTT5 Plum ant W of safeguards eqmpment scansinon logic tesang deH and assoramed eqmpawat problems. E-42 3039152 B-3-9 E-44 3039185 E-49 311.5 line be=== 4 a thes portons of the corroded PCCW pipimC ocased l inside - -wouldbereplacedwakan a.a=sessipipesemingthe 2243 E-36 303 % 2 B-2-2 p# 1997 renmehmg ausage. 2244 M-25 303991 3429 311.5 _the tir===== foamul .aema==l pmbleums, which N a desengaged support (caused by the lack of weld penseremon) imr the raw weser line leading 2125 M-4 303975 B-2-9

p. E to SW pump P-298.

311.5 The hr===== ==armaae that resoamas waald be made avadable to yemely improve the anseenal condanom of the SW pump bay. 2413 M-5 303960 B-2-9

' p. # 3392 303975 3392-1 3039199 3.2. l.5 1helicammeshadnoteSesavely p athe - for h aAer the [7/2066] cimage. Teema obesvamans inside the 2238 M-26 3029206 A-2-8

p. # h hat:t , , rapered gresear asa=*a= to chamasse mappropnsee foreipi material or ineses let over foran acemmes isees M-39 3029207 wrapped in -- - ~ ' passac, and discarded tape.. uncontrolled tools in the 3029219 3029147 3.2.1.5 The licumsee , " an immaeve to replea plaec covennes unhand inside the ^ with lugh-eamperature ag==haat masenmL 2238 M-26 3039147 p.47 312 The t'- Deperumsat samtwas efecove in Andes and ? . misannel condition h wahin the plans However, the 239g 3029231 E-t-5 p 47 efechwaness of k prabhan ihme*=e== sad reaakaan prease was '-seest 3029232 E-3-4 3039174 ,

3039175 312 In annay insammessL testing was mat an asemerve tool in idemm@ess peh A lack of a apnesmomag saimede dunes test , ^ and eveksamen was 2397 3029210 B-3-10 --

p.47 mot caudaceve to dianovenug ar T===== prnblems, but rusher to sacepeng egepeant . - 3039173 312 The snain oorrecane acesos pseyame [Procedsre 67-300-1] used by the h Department to ieview rework was not AsBy e5 scene and, in sanne M-22 303914 E-1-I p.47 cases, failed toidemm@ PA=a==sive problems or treado. For example, nework and repenene falures ===-aal wah the AFW and EFW pumps were not idsmaned by the program as issues.

4 3.2.2 Fvm=ples that wue Iomed i=heenal that the program was not always efecave and in some cases the orgn== at Ms Yankee were not 3039175 D-3 p.47 -m=g med coopermag wish each coher top idamfy and prevent repeat probians. E-3-4 I

t

,L t

I t

f Business 1 Seesten h RFI SAO MYTI3 Plan 3.2.2 Maine Yamhee had ie=ad=a gas de6cesecy and was in the pmecas ofinsegrahng =sk=g tagmented corrective action propuns with the imeest of 2399 MO4 3039175. E-3-4 p.47 beses meme efectne a idenednes. resolving. tracking, ade==c-a and m repeatne fadures. MO-7 {

r 313 In general, procedure use and mEnerence were approprisee, bin there were some irm ance* ofpoor - - work prar*= (1) Faihet to implesment 2180 M-14 3039e6 E-t-1 2236 303990 t p.48 vendor rea=====misnoms for EFW pummy P-25A.

3.2.3 (2) Work esder instuchoms not followed, service weier sysans declared __ , a Licensee weakness resultedin a degraded 2125 M-4 303975 D-l

p. 48 A of the SWsyneesa eming - en a M piping support [P-29C]. 2331 M-50 303996 D-3-2 i E-t-1 ,

32.3 (3) Poor foreign massnel ach=a= work prachces r* in a funkme of stessa generstar blowdown vehe BD-T-12. - 2384 3029206 A-2-8 i

p. 49 3029207 3029219 I

3029254 3039103 3039477 3.2.3 (4) Lack ofpsocedurut deneil for imannamos med coment offastemer lockwee [lCI seal h====ge and RC-M-32] The licensee esmerased WO's to iussell 2246 M 35 303992 I

' I p.49 the misens lockwee. The be==== also took actions to review and revisep involves lockwwe === lama == 2271 M-47 3039178 3.2.4 The team fomul' ---- in the scope of temag proyama, a;ei wenimesses in the rigor in which testing was perfonned, and in the evaluaman of COP 9622 B-3-10 p.49 acene resuhs to d==a=*ese " ", ofsafetyeqmpment 3.2.4 Despise the many ' ' - between mufur-ma= -e===d in the FSAR and the as-buik coudnaan of the piset, the licensee did not reirag=ae the 2402 3039179 B-3-10 p.49 meed to review and r=ra-rene test procednes wnh desiga reqaremments, and to correct these errors. 3039130 F-2-1 F-2 2 3.2.4 A lack of a quesanomag sesmule resulted in the use of poor survedlance procedures, sad in the inefective evalumnon of muse Esece test dass to B-3-10 p.49 duememune we y ,

3.2.4 Of the test r " _ ihet were reviewed, the sessa fomul several examples of tests that had been developed, perforened, and evnimuned ammy times 2354 E-37 303917 B-3-10 p.49 wahois & the validity of the test results. (1) Poor EDG teneng ,, - --, The teamm that the 10 and 20 secamd EDG load 3572 M-52 303918 7==rs== relays had not be en cabbrused unce iusselleman, the taleremos band and =a"T'"""* cntene had not been **eanad, and these relays were 3587 303922 mot in the Maine Yankee Cabbranon Psogrant 3.2.4 the ?- =4==a#=I several other relays that were not teseed or included in their calibramon propunt These relays included, the suonor &iven fue 3572 303918 B-3-le p.50 piump start penussave relay and the penussne relays to amose the Imr pressee safety i=p=+a= (LPSI) pump inp to seconds aAar the recarcuaman 3582 303919 act man sigui to allour =====1 rensart of the pump. The kr==== shaad hat ten apprepnene calibration inserval would be ammemed to these relays. 303920 t.

- _ _ _ - - _ - - _ _ _ _ _ - _ _ _ - - _ - - ... - __ - ~ . _ ~ - - , -- . . . - - - - . , - - - - - . . . . . - . - . -

.. - - . . . , . . m-_. . . . . - _ . . . .- .. _ ._m. _ -_... . . .

. = ?

I 4

i i

Businese Soestem es - RM SAO MYTTS Flma 3.2.4 (2) Cameral ruas v=ad*= test resuhs not prtyerly ev=hmand Fwther review of the October 31.1995 faled test amt ilm YAEC calcul*= 2377 M-51 303999 B-3-10 p.50 ammmmpeiams by the licensee M shat the CR v==a=8*= synten was inoperable temi the failed test im October 1995, used the successibt recent im 3039100 August 1996. 3039101 3039153

_ for [sefety-reisted piump discharge] check valve testing ' 2219 M-30 3039181 B-3-2 3.2.4 (3)* ^ maarvice test r. _

p.50 2239 M-42 B-3-10 2240 r 2269 2329 3.24 (4) Esurgency equpunema - cucunry nos M teseed and IPSI peup P-14A disarvered P of seertug am SIAS when in saammy 3546 COP 9622 B-3-9 .

p. 51 anode 2403 017614 B-3-10 f thru i 017621 314 (5) addaa==I =.=pa of W logic tesmag idsmaned and egapumus h= discoveret, la reyomme em the samm's & comoerumms 1219 E-42 200711 B-3-9 .

p. 51 the adequacy aflogic tasang sad as part ofins 1. f plan im response to 14tC Gemaric Imer (GL) 96-01,

• Testing of Safety-Reissed Logic 3155 E-49 3039182 3

Ch* the h initioned a sim,.n.=r, tesmas closeous piam to idemeify and correct other potential sessing discrepancies- 3593 COP 9622 4621  ;

314 Several h exameples afinsuinesent logic cucuit testing were idamand evolving the SIAS, CS actum= RAS,e==e=====s =Ja= feedweser 1219 E-42 303917 B-3-9 '

p. 51 trip, EFWi-mm= ruecear pre *= EDO ace ===, and minim steams i=d== syseeams. 3547 E-49 303918 B-3-10 303919 '

3572 3582 303920 [

3593 3039182 i 1

3039185 ,

314 a bresher for CS pump P4tS cycled whom ihe- . - device was reset. 1238 COP 9622

p. 51 2022125 )

3039140 3039141 ,

314 (6) Commelboard - fanit alarm cucmies not perm teseed 3548 E-44 3039183 B-3-10 .

p. 51 [

t t

i i

)

i I

- t

. -i Basema.

sneesen - art sAO IWYTF5 Flan 3.24 (7) SemmEpy power meters supured by Reguissary Guide 1.97 mot caidsruned and , _ _ " , tesemi.-. The hcensee semand ilmt die volt senters med 3225 E-24 30321133 B-3-10 p.52 ammmenes for the inverters, beamy chargers, DC buses, EDGs and esmorgumey buses wees denenamend to be out of the sonye despapumma ilus impured 3395 3039184 cabbruaun io suppast operstmhty desenam*== Funber h weh she luxeume M that the addanmal amners would be sided to hs 3039193 cabbramam program 3.2.4 (8) 1.mt of cahbraman for EDG reasm & fem thenmaatst 3610 E-47 303925 B-3-10

p. 51 303902 314 (9) Itscuculassam ==== siymd musmal trip swindi eve

• met esmeervely tenned 3547 E-42 3039185 B-3-10 p.52 3.2.4 (10) The seksame on AOVs em perfona sainty W should have M emeier P support for a , a AOVtesang B-3-1 p.52 pseyes that would summe reliable opennis C-2-1 3.2.4 1he Musammuace Departmeus had recomely @ the need for a - , .. AOV testing proyam sud was in the process debesumag Ibadug 2163 M-9 303983 B-3-1 p.53 M procue itse respered W and sesens e and proyaum numming. 2404 3039186 314 (11) Itencent-Weser sa urage tank level;. -overbessed 2408 E-14 011320 p.53 3167 2022III i 3287 303907 3293 3039187 ,

3296 ilms 3489 3039190 -

COP 9619 3.2.5 1he bens tr samme of the nsk indmummen memy not be as . , as prevemmuly h as was the case for AFW peup P-258 utumb had a 2405 3039191 B-3-3 j

p. 53 h probainhty (overug rebebihty p for smesses; miless een that spec: Sed in ese liosmoses IPE because egepassa faihme dass had mot team B-3-12 updated l 315 und h wah ihm WO premena, and share was a lege backlog of apam WO*s Bush the Isomisse and the sessa had M samme ~ --- 2405 3039191 B-4-4

p. 53 (same deems back in 1991) where the scenal work had been emugniseed, sideaugh +=== ef the wask package was met yet personned E-1 3.2.52 Samme % were fausul in the work commel pnxess, however, the h was amesame how to isuprove WO edicsency 2405 3029190 E-t l p.54 2406 3029191 E-t-4 3029235 3029236 3029237 3039192 l n

[

l I

____.____._._.._.._.___.._-,_.t ..-

4 Besieres Sectise Staseuseet RFI SAO MYITS pima 3.25.2 The capelnhoes of the WO tracLmg symem were under-utihzed as a tool to ami managensent in undermandag ilw natus WWOs. 2405 3039192 E-1-1 p.54 E-1 -2 E-t-4 32.52 .a review of the 1995 mese generance cinage WO **en indscened there was a high percentage of WOs that were canceled, deferred or wnded aper 2036 M-37 3039149 E-t-1 p 54 the WO's were entered and pnonnaed. 2406 3039192 E-1-4 3.2.5.2 This practice proJumd adnumerseve inelliciencies whidi were largely caused by duplicane WOs, lack ofinitial de6ciency tagging of components, or a 3039192 E-t-1 p.54 deternunstion that a WO was not requered eAer ame had been ianstei E-14 32.52 A review ofopen WOs showed that there was a backlog of 185 WOs (many greater than one year with the oldest bemg 1991), where the work had been 3039192 B4-4 p.54 completed, inchehng funcuanal testag, but the work package was not yet closed one.

3.2.52 The processes used en perform work wnhm the Mannienance Departmera differed between the mechanical, elecincal, and insann-mem4n and casrol 3039192 E-t-1 p.54 groups which caused some emnor work catrol inconessencies in trackmg and trendag of wak. These work corarol ddeences also afecned the E-t -4 repostme of monthly WO ***n m that preventrve -or surveillance testeg actmees may or sney not have been inchaled in WO st%

^

Assesoament of Operatismal Safety - Engineering A_ _

3.3.1 _the team also found. 3039175 A-3-8 p.55 - dencient hen conditions that had not been entered in a correctne achan symem or were dropped [1991 spray bidg deepers; ADV capacity] E-3-4

. correcove ecuan for problems that was not appropnetely expanded to look for similar issues [venulation probhms in prat swer, spray bldg. control 3039175 E-3-4 room, and EDO rootel

- other long-standmg deficient condamms (EQ prograrn, equipment testing] COP 9622 B 3-8 B-3-10 E-3-4 3.3.1 The team noted the lack of a conservative tecing phdomiphy that resuhed in the hadirmian of numerous safery related compensees that were not 2410 3039197 B-3-10 p.56 beeg periodically tested or calibrme L 3.3 I The tease also found speca5c testag weaknesses with recuculatum actumuon signal (RAS) unanuel actuatwn, 3547 E-42 30391as B-3-to p.56

_.Agastet relays used for timing safetyclased _ = ,--- --- 3582 E-37 303919 B-3-10

. the P-615 CS pump, 1238 E-49 3039140 B-3-10 3039142 11

__m__ _ _ _ _ __ . _ . _ _ . __ _ _ _ _ _ _ _ . _ _ _ _ _ _ _________.a..______m +,_ - * -m-- - ~ -

a.

4 Bestmese Bereise P=a=====* RFI SAO BtYf75 Plum

_casarat room imuk =====e==aws, 3548 E44 3039183 B-3-10

_the EDO room entdanen ther-ammar 3610 E47 303902. B-3-10 303925 mul venous safety-ruissed wel es (CCW bypens, check valves). B-3-10 B-3-12 33.1 As a Esuonny to the tessufs comoerms, haemose tesmag sevealed det IFSI pump P-14A would eat have seurend W en a " , ,

sipal COP 9622 B-3-9 p.56 wide oSmise power availside, alemuda the pemmy conde have been sesried mamusRy B-3-10 33 2.1 samme temparury maadir= san == bad been installed for a lang imme (w '; 10 years). The Inceusse was awue dh ==ms- and had recemely 2127 303976 B-4-2 p.57 minde some W in this ares to reduce the member ef e==ra ary h 2312 303995 E-4-1 33.2.2 The licensee's EressamCarreman Progrant was ddEcidt to assess e,ae=== the - medustry prucace of using a .y based preyama to 3643 303973 B-2-5 p.57 deserumme ==r=r*= pouns was r.1 beeg used The L==== also seated det it was W plems to use the EPRI GECWORKS saAware but dal mot commut to am _ , ' - dese.

33.2.2 The plant had six smaall Isaks in inglweergy piping h a the proyama, four of these were P leaks, aunt two of which were in Sitings that had 3420 ce p.57 beam mapacted and had _ , lembed 33.22 Thee had been segural smaR leaks im secundary drein lines to the main h. and denug the last euenge, the hcensee fuied to repiece P 3420 3039102

p. 58 am WO 9442568-00 reisand to hida presume eraim trap 15 wlmch had beam idamentied as havns E/C. [see Emcl 7. Wl 3323 At the amme of this =======*=r 18 SWOPl linhags were mot eaa-I These 18 Esubmes ervalved the adequacy ofcunhas of the EDGs,tesung and 3363 E-20 232145 A-3-4 p.58 trenamis of heat ed==yar edEcuacies (fouhng) respured fw safeey smalyses, and the absence of *a funmal set af====== hans trumsfer regimrummmes 3581 thna B-4-2 reissed to - -heu remiovel" to sigiport - -smicey analysis. 3609 232153 C-2-1 303972 33 2.3 For *===ple even though work had been scened, am efective proyum was not a piene to ensure that die heat *=W fouhas did not exceal the 23214$ A-34 p.58 bousmhng vehses ammumed in calculsesans. 232148 B-3-5 tlwu 232153 303972 333 Samme h h were emely ,

--I becomme diere were portums of various revusams to IIne sanne h comundmed 3039218

p. 53 apphc=ha. The earher --n--a aa= revemos were mot mumissed to idemai@ that they were *_ , _ _ " er " void

• 33.3 There were no DBSDs as yet for mee seems M in dus proyama, mehuhms the sumergency desel yearesars (EDGs), ciscarical sheard-ma= F-2-7 p.58 verhl a== (pertal), rescear preeechai, and J.., spels(SAS).

e4 -

_. _. _ _ _ _ _ _ _ . _ ._.__.____._m_ . . . _ -_ z___. _ . . _ _ _ _ _ _ ___._______.m________m____- z__ -_ -_-__e _ ___ _ . _ _ _ . _ - . . - -.2-___ ._m_w._______ _._w -

-+.---.s, n,.e-_ w_..r..ew

- _ - . . . - - . - . . - - - . - _ - . - - . _ - , ~ - . - . - - - . . _ . . . - . - . -

i

~r j

r i

me hma ,

sereins - api s4o - MvTTs plus t

333 _the tesen fand that tlwy [DBSDs] could not be casupletely rehed upon widnaut h in that there weee samme muss shocrepamcses. 3260 303948 F-2-7  !

p. 58 333 There was no ===lar document [hke Ibe IASD] to provide - '. commel of the sammerous asher safesy-relseed parameters resymrod in desip and 3360 C-14 303957 F-2-3 I N med plume procednes. The licasse had W h in the IASD and was worksms to replane it wah a more E-30 3039169 I p.59 i-

.. doe ==== called the Safety Analyas Isdanamesan Docuummet (SAID), which had a proyected dise of1997.

r 333 Other drawings [besides the IEB 79-14 safery-relaned piping drawngs] had been verined am en as-meeded basis, mad, as a rendt, asher syseesus such as 3541 303966 I p_ 59 SW, lacked a complete set of as-budt drewmst i

.?

3.3.4 there were eummples of apdicant N denesencies e4=4=9 time EDO landmig + (, _ ^ "i200 KW afland was mot anr-*=d 303909 r p.59 fw),

_the NPSH calc =lan= for the r=sa==== spray pumps (incorrect suction piping head lasses and other inapprapnsee ===== tea ==), 3626 C-18 303931 A-3-3 [

E-27 E-51  ;

f and die heat load ceW for the CCW syneemis (muspyropnsee =====g====). 3529 3039209 A-3-4 3039214 t

33 4 The quakey of 10 CFR 50.59 emelyses was ====d==ed pad, however the tuuma found several 'N h of these smalyses,such as,for a 3478 E-39 Cop 9621 F,-2-9

+

p. 59 change to the RWST hsgh-level alarum, camsuhroman was not gross to the poemmel Sur the v of ed&ms maare water to imilaeug 3515 E-40 en ancedsat diereby ponemmally mapaceses envm===ama - ' ofL 3516 l 3517 i e

3.3.4 Before the tasma arrived ammee, the b==aae menased a seriew of.=a==*d FSAR ==*a= to innme that the W bens of the plant was exerectly 3039102 F-2-1 i ^ '; 50 F-2-2 i

p. 59 seseect At the imme of the ISA, this elfort was partselly P but resuhed in over 100 Apparess Ducrepeacy Reports, of which w wiB requee FSAR changes and accxumpanying 10 CFR 50.59 rewwwt .

t 33.4 A ==d== in the cameral ofh was monest For example share were two active revunams ofcalch MYC-272 2039218  !

p.60 i 33 4 Cele =tas=a= MYC 1731 Revusat 0, ceiculseed the post-LOCA summy temperumme at 263F. Inns h should have been ayerseded 3039218 f 4 p.60 mmce the ammp temperumme ofrecord was 255F, developed hans h MYC 1740, hveman 1. l

, i j Sa5 Assessument  ?

4I the sessa mated that supervisors " ;smissed almans pr=dd=== weten the plant such as deGeseum summenal ==aaa== in the service weenr pump A-2-8 f

p. 61 bay and foresp sesennel that r~a==d inside the sAur clasman. D-2 l  !

i i

15  !

i 1

i

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _____...-.m _ _ . _ _ _ . _ _ . - - . - _ ~ _ _ _ _ -

Busheses Sortium Sassammet RFI SAO MYTT5 Plan 4.1 The h was devekying an acnon plan ta adeems der oncerns and recausammuishaus of the CAT suport. Punpa==d sceuws insteded ;- _ , 4105- MO-9 D 1-1 p.62 of a new vision =s=s-it,incremens the Human Resources Secmon's presence au mas, '_ , of the Supervissry improvemuut Proymm and D-2-1 review of the End of Ufe Comunsmes's recomune-ima== E-4-4 G-t-2 4I the Chersamm of the NSARC was also the Manager of QA for YAEC. Imihe immer pommam,he psovedad audit resouress for Maire Yankae. As the 4063 MO-5 Complete

p.63 Chasrumma of die NSARC, he was in charge of e===== overadit ofhis deparemmad's work. This resuhsd in e'ie appearance of a lack of -

RFI4063 4.1 Tsacking med reparang fmismy performinace mAm was ihming the 1995 auense. r'a===r==any, same ammagers sessed that they saw 3039175 E-6 p.63 hette ===arennent benefit fross mesmy perfonmence undscasars and they were car *====p e adjust ther ea a==a and presentaman to aid in use mal uleerpreenham.

4.1 Performonace =Ae=a-s for -- work orders inchaded only ,, , 29 percuss of the toesi ===d=e of% warm.L were 3039175 E-6-3 p.63 hseed in the h Infor-ma= seul Parts Procusesment Syssemi(B4PPS) Cauespusely the sneal werkload in te backing was not accurneely samareceenrodbythe, ' . subcasar ahbough due overall tresul in the work of ruse was repr===amve.

4.1 1he lar===== _ , ^ 2 the Laanung Process "_m Proyaum to penvide a plannende  ; so inseysse the separase trucking symmes. 3039175- E-3-4 p.63 4.1 . Ahhough the thrd=Id far raising proidsmus had decreased since the begnumag of the year, the seasm found scene ====pa== where cuisural bemars to 3039175 A-1-1 i

p. 64 probiumma-mae a-mseRemissed foremmaple,thepoorforuipsauseenalcameralsinr ^and die paar ea-ama= af die survice water bud &ms.. A-2-8 B-2-9 C-2-1 .

D-I-3 E-3-4 Carteselve Aseless 4.2.1 Thelack of4 " root cause mesuhas cesabanal wigh the infrequent [Funcmanal Area A- Repcut] FAAR mend duas did not yve MO-20 3039175 E-3-4 p.64 ====p===* the infarummon it assend to essess adverse trends. Timmely tending could have id===A=d casasumes probleses in the muss of foreigs immeenal esclamos commel, sad auxdear *sedweier (AFW) synessa ,=a;=ha=y. The air====='s new bianung Process was W to address this immse.

42.2 The teens deternumed that the liceusse's coneceve acman r==4*== process was week The sisr==-s tracking syssum was W wati 4103 MO4 3039175 E-3-4 p.65 x ^ 7 21 indm&amt systemis. The backlog ofconecove scuoms was relsovely large ami was W The average age of the ineses was 8 to MO-7 9 smanshs, and samme inesas were as old as to yeart MO-8 to

.__________.___-._u.__m______._____.__._______._____m.-.-_____________m._. m_______________.___e-.__mm.m___- _ . _ _ m u__-__ _ -_ _ ._ __ , - -v-m-.ua.-_+*-_%. _ . - _ _ _ - - - - -yw = _ wm

Busteses Seetism ** - RFI SAO MY113 Fimm 42.2 The immasse's 1995 correcew scesom audit also W the ^ desmangement to tienely preldan r==ahmam [umiernaud ADV; SWOPE B-4

p. 65 secomumendmeans, turtnme hall 9aaama- 1991 spray bids dumpers) C-2-I E-1 -5 E-2-1 E-4-1 422 Somme dthe licensee's enriscove accians have been imedbreve and have ceased repsense problemas. 24II MO-15 3039175 E-3-4

p. 65 4629 303919s 42.2 An examuple of W correcave assion was how the L=r=+ addressed the mesmew commel rease pressure =A=nA=d durnas e surv==33- 2377 M-51 303999 B-3-10 p.65 conduceedin October 1995. 3039100 3039101 3039153 4.2.2 km e to selfh conceums, the b==== developed sa mieyssed Carre:tive Assion Pioyne, the Imnums Process, which was - for M O-6 3039175 E-3-4 p.66 _ _ , _

in the fab af 1996. At the close ofdie ========= the lia=== was developing s'.e imyleammang c - _ sadusammenrytumsms. MO-7 han)-8 Flummhsg and Resources 4.3 I The E==== M mot have an inneyssed overall plummag h While sesmy ensumanas dan inseyssed plus exissed, meme of these elmsmemas 4046 MO-l 3039109 E-2 p.66 h inden nam which W reapared nesaness in achseve W gemis and abgacervest W,specdc r '

to desenmmm thele elof ,

^ was out M The L==== bad W id=.a-a sie lack of an inssynond overuE plan and was in j the process ofincari wrsang the frag =====8 elements inao a single docuument as part of the Bemmess Plan houserve mM h=rinive W butimuves improvem ut plans.

4.3.1 1he tensa also famed oss samme previous impsem plums wese out esscew. Far emergle, begumung in 1990, the In~=== nummeed several 3029190 A-2

p. 67 ,__- - plass to wrect problems in the Rahasion Pr===*a= Deparument. M2919s D-I-2  !

3029199 E-6-5 t 3029200 3029238 Somme inuprovemen g* as had out beam becomme afinsk af fumhms For W ese immysovemmes unamsves ===ne,=s=d wah B-3-1 [

4.3.1 ,

p.67  ; a ca-Aw mir-operueed valve (AOV) tennias preyasm had not baum M for the past 3 years.-. C-2-1 and the Erosia Commet Prayan was not Adly Amuled for 1995. B-2-5 C-2-1 I

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E Businese Seselma W RFI SAO MYTT5 Plan 43.1 Also, same proyases had received Amuhms, but du hcemsee had w dem dens immes ofresmuce sment For =+ tim supervisory C-2-1 p.67 lepro esmentProywr.was deng the 1995 rudimelmas cuence. D-2-1 43.2 Stading levels and budget expendswes have been conseressed to sist m to genersee power efeciesely C-2-1 p,67 E-4-1 433 .,_the hea== en remances have delayed and defened piast igynden, maprowessame, and lower pnanty conectrue acuiams whsch del met samut the C-2-3

p. 63 thredmid int safety,reguisanry . er reliable prh Pagaces v.4ich would himly have prevesmed prabisans were umAmuled becomme af F-2-3 budget immstet One ilhauersaive ~9 was the W delay of the - .af die Safety Analyses imputs Documnasi(SAID) whidi could have re-W the probless web the umimured ASD sumer.

433 Amesher example ofdefemag needed protects h of a lack af Amadung is the heimme of the suechanical/elecenceWi&C specialty training prayan C-2-1 p.69 dens the 1995 stessa yearusar sleevues aimage. This waimme prepareJ - workers as jaumeyinem and prm;ded enemmuing . " -y F-1 tremums All specialty treiming was kahed in an eBart to increase the svasimbshey of - workers to surPort aimage work.

^" C-2-1 433 "-i funds were mot approved in the 1995 OAM budget to respond to % ren@*a= issues.

p.69 F-1 433 A* example of the impact afisamed resources te empestemt prepeces was that the demgm-boms m program was behad danmg the 1995 snesen C-2-1 p.69 generusar sleevang amonge h of - 4 em samtresourass. If this preyama had amamumed,thee would have beam h apparamuses F-2-7 dunasthe 1. - of design-basis de to idemary some of die older Jesipi problemas that were laser idemaiSed by time team.

- 433 in h arroxmmenely 100 high pnanny work orders were deferred Reum the 1995 cuange schedule at the end af te cimage becomme of erhah B-4-4 p.69 conseramas. C-2-1 E-I 433 With _ work order med correcave acteam tracking sysseum backlogs nece=ames, senior pinut v has recemely decided to add muse B-4 p.69 staE E-4-1 IS e

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ENCLOSURE 6 i

l ACTIONS IN RESPONSE TO

SAFETY ASSESSMENT OBSERVATIONS 1 1 l

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j PURPOSE OF ENCLOSURE 6 i i

• Near the close of the ISA onsite assessment period, Maine Yankee pmpared summaries of the NRC i 2

safety assessment observations (SAOs) as an intemal management tool to suppon a shared i understanding of the issues and to control commitments between the NRC ISA team and Maine Yankee's ISA suppon team. The compilation of SAO summaries, sometimes referred to as the i

" green book," was useful during that phase of the ISA, but has not been maintained. Apparent or i- root causes provided in the SAO summaries had relevance at the time, but no longer necessarily j represent Maine Yankee's position on the issues. Enclosure 6 provides a road map to allow tracking  ;

of the action statements made by Maine Yankee in the SAO summaries. This Enclosure also  !

supersedes and cancels the SAO Summary document.

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ACTIONS IN RESPONSE TO SAFETY ASSESSMENT OBSERVATIONS SAO # ISAT Issee Semanary Key Respamalve Actions ISA Key RFI MYTTS WO/Beeinass Plan C-1 The FSAR descnpuce of the SGTR event does not accuranely Clanfy FSAR to address apparentL- - -- b 3039200 F-2-1 descnbe the EOP analysis basis.

C-7 The YAEC method ofperfornung the Mene Yankee safety YAEC is developing a process for the fannal Anrwaamat= and 2.1.5 3039158 F-2-8 analyms rebes cm the histcmicci basis indmdual personnel transfer dthe hastancel basis for the calculanons. thru drecten in controlling the i.4w of safety analyset 3039166 C-8 The Techmcal Specinhsis perucipaans in the QA audsts of the Revise the QA seda a*= for those audits unas Tedancel 3039167 NED group at YAEC are not defunng the extent of their Specinhsis to include duect wnties ieput from the Specialists de6ning reviews and fmamgs in the QA reports. the scope and fuahngs of their wtut.

C-13 The SER conditzns of the codes and -- ? '- " @ associated Develop and implemers a process irr h"= and codifymg SER 2.1.2 3039157 F-2-3 with the MY safety analyms have been reviewed sat found to compliance for all safety analysis ML 43 and codes. 3039158 be 3.dAQ met D-- -- ---- of the SER compliance 3039163 needs to be coddied.

C-14 The control of the safety analysis impens does not follow a well Finish the SAID. 333 3039157 F-2-3 Maat procest 43.3 thru Fonnahze the MY inserface process in reviewmg the safety analysis 3039170 meint C-15 The EDR reportability threshold is too high to be an effecove Maddy the contrathng EDR procedure to ensure that the requued 3039168 mw toolin =+===ng problem arent Addinonally, the threshold is lowered. -

plant has not been made aware of mR EDRs potentially adfecung the safety analyst Provide training tw the YAEC engmeers and inanagers provahng impia to the EDR systeni.

tower the threshold for MY notificanoat E-3 Some plus controlled drawags are original Men drawmss As-beldmg drawags contmues via the DCR process as discrepancies 3107 303968 mal have not been thoroughly venfied agemst the as-built are identified. 3554 condition of the plant E-4 MY procedures have penmued cross-tyng de buses winch Procedure 1-22-2 has been revised to remove the option to cross-ne 23 8 3352 303913 renounts to eBowng the system to operate without adequate DC vaal buses while at power (modes 6 and 7). 3385 separanon and with a segle failwe potential.

t

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b 5AO 8 ISAT lasse Samunary Key " . .Aceless RSA Key RFI MYT13 W OtSusinessPima E4 Adequacy dpreseceed switchy:ar races w=mim- systent A t'h evaluanton of vanilmaan syseem appades an necessary 2.3.7.1 303912 A-3-5 potential generic syseem wed=*= any exist. 31.1.I Upgrade amiabiley DEDO-backed power supphes for swnchgear roosa temporary w=him-V = ham == evalunha samen has been developed and follour-g actions are beung ' ' as apprepname.

E-8 EDO loadmg calcialas== (MYC-107) did nos = ara ==e for some IA=ms-I changes wdl be incorporated isso the ongong h 23.5 303909 appmprinseloedt revemost E-9 SFP HX a==rplate ; A . not censueent wnh FSAR Reanalyze the HX for operateam at the FSAR seraperanse. 2.41 202271 (nameplase=2007,FSAR=225B 202272 Perfann 50.59 screen as reapared Veew coher SFP == ling P for ein=Isr e==ama== Revise FSAR as sospured E-10 The v-mid== sysean for the - -spray buibhagis Replace HV unit prior to onset of cold wendeer 23.7.2 303951 A-3-5 vulnerable to temans and potent.at single fashnes ofdamper .

31.1.1 303 % 5 pasa==mers thes could result in loss of w=it=e== Deemame whether inlet vases need to be r*t-h for winner 3039128 operamon. 3039129 E-Il MY ide=hEnt a Eugeber ofimplV4eUReEl opporh=**= dunas MY had already commmuned to- ,

,,IPEEEh nder i 3269 230154 the IPFJIPEEE evalumnons that have not been thi!y resolved a pleased appreads whida ====d= to the 1999 reinehag outaget [sumes thru 196-026 MAW includes a table ofevery MYTTS number asaped to 230I69 IPEEEismet)

E-12 Ass ==pheric steam dump valve capacay is less than anhcapated Abn=aeseve liants established for RCS iodime. 2.4_2 303946 A-34 decay best loads. This could adversely adIect the EOP 3.I.I.I execision of SGTR andi@ care coohng Operseer training and EOP revenons for SOTR, as apprapnene. 3.13.1 analysentecoveey tunes. 43 3 Hardware h wiB be ' , "ezug the 1997 reibehms outage.

E-I3 RHR HX thennel cycle fatisee anacapated in current CCW  % &evaluamosperfortned MYwillWthe 3438 303937 accident ammivues not bounded by current ratigue smalysa evalumnost 2

_ _ . . _ _ _ . _ _ . _ . _ _ . _ ___.______.__...__m._.-.____m_ _ _ _ . _._._s___._am_.m_ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ -

• _ _ _ _ - - - _ - -

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SAO # ISAT lesse Samunary Key % Acelses ISA Key RFI MYTf5 Wotteshness Plan E 14 RWST level; wansnumers e---a-a iber t=Wd ide due to em O -'ve heat wacing sysicia analysis. 3.2.4 011320  % 2525 i incorrect temperature set point on an associated heat wacing 2022111  % 2526  ;

cucus. Revise RWST level set point calculation to inciale new best wace 3039157 settinga. 3039189 i 3039190 I COP 9619 l t

E-13 Minor discrepancies between Tech Specs and FSAR wonhas. Descr=p==~= will be correcssd widi _ - 3366 303941 F-2-1 ,

E-16 Emrs and enussions l' ave been Mamaal in elecencal h escr=p==~= will be reviewed and incorporased inno the 23 6 303910 counknamon studies (MYC-1063 and MYC-1559). aunt revisena of the Coonhnation W as appngnese. 303911 i E-17 Dunns plant walkamas, usinaments and elecincel 1rTa -* appropnase correceve actions froni root cause inwarar= 23.9.1 COP 9621 B-3-8 compr===st were found bekm the - - flood elevation when casupleted. ,

and were not qualdied fw subanergence by the EQ progrant .  ;

Detaned Dood smalysis review. L Fully quehfy Ci valve h and arrow range 50 level w-m E-19 Cale=a=*= references ce seuralICI. drawings are Review k ICL series ofdrawags and initiene DCRs to resmove sonsce 3631 011320 DCR%143 secopeent docusheet 3Riormer= Bo longer a=*=0aed to be useAd or CurTess. TE12% DCR96l44 (ICl 303.-403;MYC-1016)

E-20 Timehness of follow-upkta=at SWOP 1 follow-up items. r-n-- to casuplete folkm-ty iteins e =e*== widi Cycle 15 3.32.3 3363 23214I B-3 5 r (endhund 1997) piens. [5WOPI action ammenx included with RFI 3363 thna has aanglese hst of MYTTS numbers.] 232153

• i E-23 ne 115 kV syseessioed study" Base Case" suggests that bus Revise MYC-430 to return UV relay calibration band to de 38%. 23.2 303915 A-3-10 voltage does not recover to I 16 4 kV required to reset the 303921 .

degraded gnd relays. Revise

• Base Case yid load m to amore r==har=By represuma and operamag ~_ ie., use one or more ==d-a= of volenge m'PPort in acconimum wudi CMP proceemet E-24 Reg Guide 1.97 standry power insenenents are noe in the Cahbrase the instinnenes at next refuehng outage. 3.2.4 30321133 cahbrutnam progrant 3039184 3039193  ;

E-25 Atar=ry of HPSI NPSH under design basis LOCA a-ht== Conduct HPSI runout test ment outage and record piamp vibramon and 2.2.1.2 3337 3039194 B-3-6 current resdnes. 2.2.13 3364 8 i i

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_ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _._,__.._______..______________..m__ - . _ _ _ _ . _ _ _ _ _ _ _ m__ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ ___m_________._______ _ _ _ . . . _ _ _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ . _.m.

m . . . . . _ . , m _ m _ . _ ,_ m . __ m_ _ . . . . _ _m . .. _ . . .

SAO8 ISAT issue Samunary by" . Actimes ISA Key RFI ' MYITS WO/Ba=8- as Plan E-27 Adequacy of Contamment Spray Pump NPSH under deman Mame Yankee already had ongoms a marga 4..-.- evalumuon 2.2.1.4 303932 A-3-3 bass LOCA followmg .-. L actunuort which will be continued later this year 3.34 303931 E-28 Foules factors tened as uipe parameters no the CCW analyses Recaluaic heat exchanger performance testag for incorporanon of 2.2.2.6 303972 B-3-5 may not be conservauve and testing of heat exchangers to estnanent uncertamey and imptuved methodologies valmiste the analysis - - . - = = does not adequately canader estnanent uncertainry Re< valuate the acceptance criteria and fouling factors currently used Re-evaluate programs used to satisfy Generic Letter 89-13.

CcessJer updaung Generic Imener 89-I 3 response no the NRC.

E-30 The inputs and Assumpuans Source Documret (IASD) was Complete and implement SAID. 3.3.3 303957 F-2-3 established in response to a 1982 Confirmauxy Action Izeter, 4.3.3 3039169 but the issue of control and use of design and licenang bass 3039170 parameters in safety analyses remams unresolved.

E-31 Founeen amear-operated valve moeors were replaced with Incorporsee changes into the EDG loadmg calculatuam 2.3.5 303909 anosars ofdifIerent sizes. The changes in motor loads were not 303914 reflected in the associated electncalloadmg concot-E-35 Apparent dtscrepancy between seapone calculahon and Revise seapoint calculanun [MYC-Il73]. 3478 COP 9621 associated calibratitui procedure for RWST lush and alarm TE21593 seipoet and head ccrrecuan. Incorporaie caich resuks inio lac procedure [34.2.1.411 TE19994 E-36 Loose paint and scale frone corroded primary component 100% of- -PCC piping has been as-built and analysis in 3.2.1.5 303 % 2 B-2-2 coohng waner pipes in- -could result a cloggag of underway to suppon replacement of the pipeg with stainless steel i the safeguards sump screens in the event of an accalent requinns the nunation of contansnent spray. followed by Approxanately 20-25% of the piping will be replaceJ dunng the 1997

. .m actuanan. omage.

The r=== vier of the impacted PCC piping wal be replaced ering the followns two in three opersung cycles.

E-37 Emergency eesel generator load sequencmg tune delay relsys Procedural enhancements to identify test acceptance creerist 3.2.4 303917 B-3-10 are not rouunely cahbrated 3.3.1 303918 Estabhshment of a routme calibrauen frequency.where approprimie.

E-39 RWST high level alann setpome raised without fbli evaluauon Upgrade infonneuan cara==-i in floodmg DBSD. 3.3.4 3478 F-2-7 ofimpact.

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__ , ___.__2._c____ _ _ __ . . . - _ .___ . . - _ _ _ _ _ _ _ - _ _ . _ . _ _ _ _ _ - _ _ . _ _ - _ _ _ _ _ . __- m__ - _ _ _ - _ _ _ . _ . + _ = --. - - - w-_ ---r w m- -- -w&w

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SAO8 ISAT Imame Samunary Key Bampanalve Acelsea BA Key RFI MYTTS WO(Budmass Plan l E-40 Demgn Basis Screen 96444 dal not ====s for 2 Coseplete root comme currective items for close-out plam COP 96-021. 33 4 3633 COP 962I r level increase -=a,.euntin Tecimucal  ;

Evh 215-93.

E-42 Racmeulanon acnastum signal (RAS) mammal casacts are not Compiene logic system testing upgrades as part of GL 96-01 process.

3.24 3039185 B-3-9 5 teenal as part ofeseablislud surveillance procedures. 3.3.1 B-3-10 E-44 Canal roomicueust fault e are mot teseed as part of Incorporuse tesame afkey -- . as procedue h 3.2.4 3039183 B-3-9 i N serveillance prar ames. during the GL 9641 review. 33.1 B-3-10 E-47 Emergency diesel generseer (EDG) roosa vesadan== fan An appropnase PM interval wie be establadud aml ' , - -- 3.2.4 303902 B-3-9 dierunoments are not routmely cahbrasad 33.1 303925 B-3-10 E-48 High premure safeiy inpacason (HPSI) pump NPSH testing dut HPSI pump rumout W will be perfonned and doc =====J during 22.1.2 3337 3039194 B-3-6 mot ex:ument sufEcient ansonnahaa to conclusively desnomsiruse the 1997 refLelag omage. [See E-25] 3364 long-term relialuhry dunng and follounns anticipased runout condmosa E-49 Survedance procedures duinot W " , of n==rl== logic syseems tesang upgrades as part of Gemaric Lemur 96- 3.2.4 1238 3039142 B-3-IO swing pennp P-615 circuits 5 and 6. 01 processt 33.I 3039182 E-50 Emergency feedwater(EFW) Sow ^. . are not A deemiled evaluamom ofstue ,

redishon _._ welbe 23 9.2 B-3-4 parfanned and M. [see Enct 7. Clar=Aras===]

~

_ , quah6ed (EQ) for the post-LOCA rea=hr=

envw ====sansicipated by the EQ progran in the EFW penp roont E-51 The spare- spray pimap (P-61 S) -rai== pipes head Revised head loss h will be fannahred and : ,_ Jinna 2.2.l .4 303931 A-3-3 lose appears to be penser than the head lame =====d in the the funnel consammment spray pumap NPSH calc =I==== 33.4 pump NPSH calculataans. j M-2 FSAR hen == 3 4.1 stases maxmnuni tuman concemaratum Review FSAR hesir= 3.4.1 for poemble clanncanout 2057 3039143 F-2-1 +

during rensehng is 1720 ppet M-3 IST prograni report to NRC was aus tunely. Traciung system improvemenes ongoeng as result ofearly 1996 Maine 2223 3039144  ;

Yankee h of need forimprovesment.

M-4 Service water bearing waier ime support appears to be Uppade couhng sysessa under EDCR 95-31 dunng 1997 reesehng 32.15 2125 303975 B-2-9 degraded. ' outage. 3.23 S . ,

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SAO # BAT lasse somemory Key Raspuesive Acelsmo BA Key RFI MYT13 WOSusimass Plas  ;

M-5 Service weser pump baseplace belang is corvaded. PM to be generseed to ===.ny inspect alicone seelt 3.2.1.5 3392 30396 B-2-9 Repiscanent ofmens will be evalussed and replaced as necessary i dunns next pump rebuid pnar to startup frosa nesd reAmeleng ausage.

M-9 Denne long and short-terni plans for AOV propant Furtherprogramade% set-igofa area, and 3.2.4 2163 303983 B-3 pechase ofvalve angenec equipment ==aarq=ced praer to 1997 3039186 +

refuehag og Developing a desipi m Aw===s esembhshag an AOV teman, and Mi-=g scope af programa efIerts W guier to 1997 +

reinehas awage.

M-10 DG1 A faled to synchrunare dunng the 07/16/96 savedlance. Review of aiher sumach use to ensure proper ponnosung wiB verify 2162 303982 P85per ownch & as part of% framung M-13 P-25B rehabihtyislour. Rehabihty unprovament sessa being developed. 3.2.1.1 2182 230169 B-3-3 3.2.1.4 3290 303952 +

Perfornienceunpnmunentstobe _'_ , " and = rap-I as part of .

micreased amennen as requend by theu- Rule.

M-14 P-25A rosor seized in January 1996. Complese root cause evalusaan sad address corrective action 3.2.3 2180 303986  ;

W by root cause. 303990 j M-15 Maine Yankee changed steam genersaar blowdown HELB Five of ax valves have had ther actusman synngs suplaced, one 2181 303937  ;

valve tesang tuas quenerly to meeddy m N for 1997 estage.  ?

M-16 Provide copies of cor.w from Maine Yankee to the Finahm any FSAR changes as requred. 2228 3039145 F-2-1 I NRC regardag EDG start tune change from 10 to 15 seands. l

['

M-22 Proyasa to idmhff [gwgrk ggd repeneve fadures appears to be Review proceshme 67-300-1 and coher processes thatid-seFy and track 3.2.2 3039146 E-t-1 I-+=g (Repensiveprobeems on P-25B is a good example.) rework and repeenve failures.

l 3=re --= changes, as apprepname,to impeove esacemmess. j

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5AO# ISATiseen Summanary Key Respenstre Aegimme ISA Key RFI MY1TS WOftumbase Finn M.25 Maesnel cmedienen of mesamament PCC piping. C=s- unroman inspecnoms and pipe pi---=a during next 3.2.1.5 2243 303962 B-2-2_ ,

three cuteges. 2244 3429 Piping is monitored each cycle for sinicaral misegnty via SERP-100% da=*=====a PCC piping has been as-buik sad analyas is i

underway to support repiecessent of the piping with stamiless sneel.

A r. - 720-25% of the piping wdl be sepieced during the 1997 outage. ,

The resammader dahe impacted PCC piping will be re;dmaad Aming the t

fono nagswoioihr eeperinageycies.

M-26 cana=== = clemm! mess Mr==d=rd plassic being rept -d wnh high temperamme plassic. 32.1.5 2238 3039147 A-2-8  !

MY wiB evalunee insee folloinns containsmens cla- =e when emergest i work occurs. y M-30 EFW discharge check vehe seveiRance procedue used PED and Opennems evalumsed test msad P cnsens for 3.2.4 2219 3039181 B-3-10 pressure smuge with too high of a range to read 15 psi syssess dieci vehe survan==-. (tims P and edier M 2239

• W==r* cnsena. NRC concerned that proldess was mot W a==paa-a=). SurvetBaece proemdwes maMad to 2269 sdemaned eerber. maarpormie new sest enesiuses and P creerm Tests completed 2329 ssandaceanly l

M-32 CH-50 has loose capscrew muss Review wnh vendar, meal for post - chest (hetverspiean 2217 3039148 r pressure semi valves) ,

M-35 ICI seal b===g lockwee um Wdichange appbcable pocahmes to perammy venfy lockwwe 3.22 2246 303992 i

M-37 1995 re6sehmekemi generstar outage perfonmence maare Will perfona e rewww of the "froma end* of the work order process to 3.2.5.2 2036 3039149 E-t-4 ,

appear to intre poor pismsung due so time larse ammber of samunuze the museber of unnecessary work orders emaned imeo the 3039192 work orders that were voided. PreM work orders not desabase.

worked y 36% and 18% of work orders wnnem eming ausage were moe worked.

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SAO # ISAT Issue Summasary Key " . M Aestema BA Key RFI MYTTS WOensiones Flam M-39 Duct tape Aussion SFP well Employee awarenans heightened on ME issues seul & 3.2.1.5 2062 3039151 A-2-8 3039177 FhE Pohey Oversight Comenteee fonned.

Imbag for amadur way to mest posn=ns.

M-42 EFWcheck valve precedure @ Surveillana procaeses -Mn=1 to redect P test -shad 3.24 2219 3039181 B-3-2 B-3-10 M-43 HPSI Sow beyond pump cuve 2173 3039194 B-34 M 46 Contanument spray header valves CS-M-1,2 siroke tunes are Appnynsee FSAR change rv wiu be subsumed to conect 2270 303994 F-2-1 not -** wnh the FSAR. Costanument presmee vs. tune FSAR. 2289

- spray.

cwve shows no c5cca frase-M-47 Loop 3 stop valu RC-M-32 is aussing actuator ==g lastaBedlockwee 3.2.3 2271 3039178 lockwire M-48 Does aut appear to be P feel oil ===== d in the chesel Change FSAR as approprisee. 2288 303993 F-2-1 generseur imeagral and day snarage tanks to meet a sex knur run tune.

M-49 Sosne EFW and AFW piping does as match the i===*w lasse DCRs for W which do not fall wnhia die P 2333 3039154 i drawingst crieuna for the es. built venncanon. 3039155 3039156 M-50 Pipe suppost removed frcan P-29C bearing water supply. Utshze resuks as appropnsee anm root cause analysis. 32.3 2125 303975 B-2-9 2331 303996 M-51 Comuniroom ventdesionissues- Compiene a root cause caluamon of past test by 12-31-96 3.2.4 2377 303999 B-3-10

- Poecnnel imedequase aparalnhty and .pC ;, evalumnon 4.2.2 3039100' regarchng 10/95 survedlance Address 50.59 issue under RFI 2377 3039101

- Opus almley sessus frnun 10/95 to 8/967 3039153

- Concems regardag cheessag meeral rooms in 1 ahar Yenow tag issue to be addressed by 12-31-%.

assumpeans taas 10 (1993) to I (1989) to 10 (1995) and associated 50.59 ch Reviewhevise test procedures pnar to next une (9/97).

- Yellow tag on damper since 1988.

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- - - - - - - _ _ _ - - . - _ - - - .a.--_.-- a-_- ,v - - - - . - - - - - - - - - - - - - - - -_-__-- __a n---n-w_--ww--- a---u--- ---- -,,e,rv. -_m - r -_--- www m e-,&

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SAO # ISAT Issue h===*y Key " , _ ' ; Aseimme ISA Key RFI MYtTS Woeusammes Plum M-52 EDO procedure 3.1.14A refers to 30 ===I start block (P- Revenfy vendor's cabbrusma recamur==dmumm 3.2.4 2354- 303917 25C) and tuneris set at 20 seconds. 3587. 303918-Research --

hissary asui mulusty expenence to detenumme 303919 EDG tiew delays are mot cahbrased. appropname cohbranaa imervals. 303998 MO-l MY has not yet developed an imegrased bummess plan Mismon/Viman revision 4.3.1 4046 3039109 E-2

- _ - - the busumens plan MO-3 PORC has made man-conservaarse h bened an ihe TSI 5.5B.9 was tenrumseed and will be evalueemd for LER - 4041 3039106' review of x ' ,64 Tech Specin:erpnannoms approved 3039107 by PORC. Of the 64 innerpresseiams, seven specific Have PORC persons a review afexisting T5It 3039108 interpretenues were ciend.

MG4 Commaussiest tracksas at MY has been weak. _ _ ,

- of the Issnung Process 3.2.2 4083 3039175 E-3-4 412 4640 MO-7 Fr=W correctrve action process - The current carrocerve WiheImanums Process.- 312 4083 3039175 E-3-4 acesas psoness appears W and frapnessed at the 4.2.2 4103 Corporane Level NRC asked MY to explaim ar*a== to (1) Review a-se=v issues in seminple h using LP screenes 4640 esaure no acnoms *fmR through the crack" and (2) treadmg is cneene(RF14083).

sudficient Heighesmed sesumervey to new ia==

MO-8 Samme issues dul not receive tumely reschenom. Venf fwheiherissues involved =-aaan, safety concern. 4.2.2 4083 3039175 C-2-1 4104 E-3-4 Evalusse generic '- - ofspecificexamplet Utahre pnuntmaan fessures of the LP.

MO-9 Soune piam stadfhave last trust im semiar ====punemt's abiiny Review sad revise carparsee =i == and visiast 4.1 4105 D-I-I tolack om for their welGe.

• Emd ofIEe" Comnumee will receive increased menossam and prianty. O-1-2 Broeder amployee imput on policy 1- - D-I-3 Revise Worker Cancerm PropamL A t-4 Higher prinney as puencerve 3029251 D-3-2 9

_m_____._ _ _ __ _ . _ _ _ ___ . _ . . _ . _ _ _ _ _ _ _ _ _ _m.__ ___ _ _ _ _ _ _ _ _ _-_.______ ._ mm- _ _ . _ _ . _ _ - -- -.- - _ _ _ _ . -_-r --.m_ m -

m_m=--.--=.-_we- - - - ___~s -e-4 _ r___. m_w_--___.a

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i SAO # ISATIssus % Key Raspensive Anemos I5A Key RM MYTT5 Weemsimons Ptmm '

MO-10 Some correcew m how been innseceve samt how namhed W abeIAanung Process. 4.23 4629 ~ 3039175 E-3-4 in npe=== problemo MO-20 Departmentalroot c== mos trendent '__, afihe Imanmar Process wiB imiprove trackms and 411 4631 3039175 E-l tremdag. 4636 E-3-4 As part of the %h Rule. PED wiB mack and treimi apparums commes for a=r==s imihees. -

O Mummmann sumaber of CETs respured for enwamim imeo FR-C.!

. - diences to FO.2 and bodyomed h to ensee 1073 Ig2303 mot specded. Sist five CETs musst be >l2007 to esser FR-C.I. 3039114 06 FSAR does not specify use of BA-A-80 as a ddmuon path FSARwel be clarded. 1063 3039112 F-2-1 during rescear startup.

O-7 Training Manuel lisned as a reference doneses for EOPst Refenmoe is being summoved. 1072 3039113 Reference section updsee is underway 0-13 Operstar A _ y h(vahame). . Uppade espapment h per ple=at and proposed EDCRs or 23 2 1107 3039116 96256 work orders as apprepnene. 23.7.1 1134 3039123 962536  !

23.7.2 1876 230159 962566 j 3.1.1.1 1177 303915 962879 3228 303921 l 32s9 30390s 3494 303912g [

3583 3G39129 303946 r t

0-16 Operamag quew sendEng dunne some imusmaces muiy fut below Trender Fue Bngsde itseins tout the SOS to amadur inhominst as a 3.1.1.2 1125 3039120 ,

the summmmme recymred. This was W ammed at the PSS " sceios to iinprow stadling. [

duty as a Fun Aid Responder dunne a Are.

O-18 MY does not track RCS thenmal cycles. Develop procednes to wiplesment trackms " ' ' _ . 1105 3039115

,. 6 O-19 Tech Spec innapressesom process appears to be nom. Wdi perform bcemens review of eB actin TSis. 4041 3039106

- - . . 3039107 l*

3039108 t

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D SAO # BAT lasse Smemmary Key " , " ; Aceless ISA Key RFI MYTTS WOSesiasse Plan 0-30 11 mere were several espegument gwebleums dunng the recent pism . P-2B inp issues beeg tracked by h Rele. 1107 3039116 924411

=Imm& MIL 1134 3039122(c) 9t223 3039123  % 256

% I864 0-33 HPSI meneer map issue - pusep operated in the " orange" besul Develop peaceese changes to track total imumber of hours a l132 3039121 for aumps- abis requeed PED review. --y====r cum be operated in this h 0-34 Post Trip Review Reports lack "detal and rigor." Review MY procedme against indesary standants (% INPO). 3.1.2.7 1180 3039131 l

-a=mper prabh-s  :

-skip cheris1.ckimmes imisisse maychamen a ---am wish me

- seemedad as a res it of the imemory review.

- no check on opersang espapanent samrts -_ i- l O-36 Cameral scusa lag book del not have emeries telseed to the h new ==r ' """*""*"'

• fe' """"E""""' review 3.I .2.1 1181 3039132

% ofcommel roami lag book aner abmannal plant condman occurs

- =====l rencear anp as part of the plant shundown an 7/20/96

. EDO problems em 7/U96  ;

" W operunas due to piamt computer problem  ;

-g wie RH-4 W _

O-37 Risk-bened wegubmm ofECA40 ATTC had tun. t=a% ofmasar opersears for MS-59.-79. med -99 piammad far 1229 3039140(c) A-3-8 -

n=riings Wakdown of ECA 0.2 had ame W 1997cimage. CPA9632 COP 9604 0-40 Fity percent of all persammel occur ic cleam Review procedwal sh en survey sectumque and tequemey for 3.1.4.3 1209 3039137 A-2 arent  % 1210 3039138 Review camerals goversmag work in h areas ofdie Resniceed Area.

C- mpuovament summeves in the eram of self - I 6

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ENCLOSURE 7 CLARIFICATION OF STATEMENTS IN THE ISA REPORT -

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l PURPOSE OF ENCLOSURE 7 Enclosure 7 provides Maine Yankee's clarifcation of certain statements made in the ISA report and describes the financial stmeture of M 'ne Yankee.  ;

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CLARIFICATION OF STATEMENTS MADE IN THE ISA REPORT  ;

b Sorelse Corrent es- Cisseessima Table 1 T:se "SER h" assibuted to the COBRA III-C come me MI==t as beag impa==a by the audur of These h me mot SER-relased resirichaar they are li= ofshe " ' 4== based ca

p. 6 ihe code and not the NRC im na SER. . ' behavior of she tramment or smodelag i== sana == based on ampuwal can-eama-y' ,

-t 2.1.3 De two SER condstsaus on FROSSIEY-2 were C. --. (1) alocalburmuy lumns of 60.000 The SERlumut is aceump y 60,000 MWDMTU on a red averant bans. There is no loca.Inunum Emut for the i

p. 8 MWdNTU and(2)the inrimana of Asel ~ :auncerm sw. FROSSTEY-2 code.

2.2.2.6 (c) [CCW and RIR] Heat = ' . _ tubes were clemmed on a perunhc basi t RHR HX tubes are mot enemmed on a penodec basst 'l

p. 20 2.3.2 Maine Yankee would again moufy CW to bnes the Maine Yankee capacusar beak and Surowiec Maine Yankee does not manfy CW to bnes the capacnor beak imeo service on and lands >l300 MW.

p.23 Transfonner Ause Boost isso service at pid loads penser than 1,300 MW. Operusers use voltage minnes to desermine opersinhty.

2.3.7.2 _the licensee adonned the ISA tessa that the denrubility of bicckmg open these dampers had been raised Revision I to Maine Yankee's :=5-== to RFI 3520 inchid-i the MYTTS ==h= s inst were used tu track p.29 in 1991 by a samspenom Rose YAEC in a ===ar-a= dated February 20,1991 This ===ar-a== the 6 minde in the 2/20/91 - -a- 10-13-04 ihrough 10-13-12.

en=a==asa specific recoup ===d=sion to block open d==pers VP-A-56 and VP-A-57 because. *1f the camisroller fasis,it could cause the inlet vanes for beak fans to close, e====y a rahacaos in the culput of the systemL* De ISA tessa found no evid==re that ilus issue had been emeured imeo a conecerse action system or was beng tracked by the liceusse. This was an exarnple of the th's failure to take appropname action to address a plant problent 2.3.92 The w essed s abat evalumnam ofibis [EFW flow .- ] issue was under way as part of a DBS 96-41 was act revised to require a dame review. Mesme Yankee is ciertasty evalusang the .e ~;

p. 31 revuman to DBS 96-41. This revision would add an action ieem to provide a d=aaila8 review of the or =g===a==== of the flow . -

raaaaaa= done at the instru===8 locanon.

31.1.2 The team fomul ahat Maine Yankee has previously developed a - . 've =*= plea to mibbens the Maine Yankee has arendened Fins Responder ahnies to the Saceney Supervisar. Maine Yambse did not .  !

p.34 stuft saadEng isuses which included (1) using secunty per.-warasheribamilae PSS as smedical Erst commet to sees a thed CRO. Maine Yankee muunneed to iransfer the Fue Brigade beder esens to one of

=9 d= ,(2) using a second CRO as the fire bngade leader ruslier thei the 505 the two en-Aidt CROs and transhr his ahmins to either sa NPO or en adenamel secunty guanL (RFI 1125).

3.1.1.2 r"  ;,ihe ni~a== planned to add aihirdi.--=-arenciar operasar to the commui roma sisarand Mano WFB 96-063, sanched to RFI 4044, included the ***== "I " "; Samur Ma==r===e ,

p.34 -gaas the duties of the fire bngede leader to the rescear operator ayend to the long range hines and traiimag psocess m so achieve an =Aha-==8 Ima===I operanar cn i

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each cuew." Aa =4eini===I N was made in - -a WFB 96 031, also anached to RFI 4044: 1 "Two NPOs should be d==g==a-d as Ese brigade ===hers one ofwhich is despissed the Ese bngade leader

. j This will leave one opeuter (CRO or NPO dependes on the crew ==6at) avalable to perform required  ;

local operamans dunas an =arad-a ==4e=== *

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-._.,ma_.-.. _ mm . . . _ . . . ~ _ _ m -._ . . . ._ m _ . . . . ~ ~ . . - - . .

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Saestes Comme semesment ClartArmelse 31.2.5 she team mesed ihet the Econsee made en immaned operabday deemmmmena " with the Maine Yankee despose with the NRC W Mmme Yankee behews that SIC 96-18 correctly ,

p.36 ,' of . _ safeguards feature relay temung. The team found eut this imeerpretaten of the desanummed the sqmpement to be operable.

Ts rapar=== e.was immorrect.

3.2.3 (2) Work anler insenectnans not followed, savice waser syseesa declared maparable Should read " service water suam P 29C declared smoperable" as is stated in the ment to last - of the .

p.48 pW 3.24 (2) Further miew of the October 31,1995, failed test and the YAEC h ====re a== by the Maine Yankee perfunmed am opersbehty deemummmon and -w that CR haineshibey was in fact p.50 I-==== M that the CR veneilation systems was inoperable been she failed test inr heawr 1995, insananmed. Referto RFI 2393 sad imemo CAO 96 014.  ;

used the ,===4d reeest im August 1996.

3.3.2.2 The licemane also ==aatt hat it was making pleas to use the EPRI CHECWORKS soAwee but did not Our respamme to RFI 3643 included the frJiounns " Mamie Yankee also behrwes that the une of

p. 57 crearmit to an ' __ date. 'CHECKWORKS* v code wenid provide h assurance and has aheady h experts in the use of *0ECKWORKS' to iqiyade our program. This process has beem underway for d=am e year i now sad is to be + in imme for the 1997 rensehag."  !

s 3.3.2.2 dunas the last ausage, the licensee failed to replace compa===e= on WO 94-02568-00 reissed to high This was a - - en the part ofMaine Yaml== bs fact,TR-15 and the piping doussauem of

p. 58 pressure drain trap 15, which had been hA d as having ER TR-15 had been rapinand wink improved masenals under work orders 92-7202 and 94-2568 dens the 1992 and 1995 reibehmg ouanges. ,

App B The orgammma= chart pW in Appendix B ' . A W the Mammyr,Public & Gover====a These managers report directly to the PresmientChsef Enecumve OEicer, ,

Affairs and the Manager, QPD/ Strategic Pl===mg as nyartmg to the Vice Pressdent & Osmaral Counsel.

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FINANCIAL STRUCTURE OF MAINE YANKFF 4

i In Section 1 of the response, Maine Yankee asserts that the non-traditional ownership structure and practice of not retaining earnings is not a contributor to the ISA's first root cause of economic pressure. Our executive assessment concluded that Maine Yankee has always enjoyed ready access

to adequate resources, and the practice of not retaining a large cash reserve in no way contributed -

i to the economic pressures affecting performance. This expanded explanation of the financial aspects )

! of Maine Yankee's ownership structure is provided as clarification in support of that assertion. )

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! Background -!

l l Information provided to the Federal Energy Regulatory Commission (FERC) describes the financial )

[ relationship of Maine Yankee's owners. l i  !

' The Company is sponsored by ten investor-owned New England utilities (the " Sponsors" or the j

" Stockholders"), each of which is committed under a Power Contract with the Company to purchase j

j. a specified percentage of the capacity and output of the Plant and to pay therefor a like percentage  :

l of amounts sufficient to pay the Company's fuel costs, operating expenses (including a depreciation l accrual at a rate sufficient to fully amortize the investment in the Plant over the operating life of the j l Plant and amounts estimated to be sufficient to decommission the Plant), interest on its debt and a l

l retum on its equity. The Company r.nd its Sponsors have also executed Additional Power Contracts i

} for the purpose of extending the tam of the Power Contracts, as amended, from 2003 to the end of l the useful life of the Plant and the completion ofits decommissioning and financial obligations. l

Each Sponsor has also agreeJ, under a Capital Funds Agreement with the Company, to provide a  !

like percentage of the Company's capital requirements not obtained from other sources, subject to

obtaining necessary authorizations of regulatory bodies in each instance. All such obligations are  ;

subject to the continuing jurisdiction of various federal and state regulatory bodies.

I l The obligations of the Sponsors to make payments under the Power Contracts are unconditional, l j subject only to each Sponsor's right to cancel its Power Contract if deliveries cannot be made to the j

Sponsor because either (i) the Plant is damaged to the extent of being completely or substantially  ;

3 completely destroyed, or (ii) the Plant is taken by exercise of the right of eminent domain or a l similar right or power, or (iii) (a) the Plant cannot be used because of contamination or because a j l

necessary license or authorization cannot be obtained or is revoked or the utilization thereofis made l j subject to specified conditions which are not met, and (b) the situation cannot be rectified to an j j extent which will permit the Company to make deliveries to the Sponsor from the Plant. <

Notwithstanding the right to cancel, the obligation to pay decommissioning costs continues until the Plant has been fully decommissioned.

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! Imnlication for Maine Yankee The regulated cost of service formula allows Maine Yankee to pass its actual costs of providing i

service through to its owners monthly, regardless of the production level of the plant. Knowing that

Maine Yankee will be promptly compensated by the ten owners who are its customers eliminates the need for large cash reserves to cover contingencies or disruption in cash flow that other utilities

) may face.

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. i, In fact, Maine Yankee does retain a reasonable and allowable amount of earnings. The Company's -

fmancial statement at the end of 1995 shows a common stock investment of $71.2 million, including -

$3.8 million of retained earnings. In 1995, Maine Yankee actually increased its common stock investment by retaining 50 percent of earnings Just as our FERC regulated cost of service formula f ratemaking provides for immediate recovery of costs regardless of the plant's production level, it ,

similarly provides for the recovery of those costs without regard for the level of retained earnmgs.  :

1 Under its organirational structure and FERC regulated cost of service formula ratemaking, Maine Yankee's profitability is not affected by the costs it incurs, whether those costs are planned or unanticipated. Maine Yankee considers this a competitive advantage over other plants operating under traditional fmancing arrangements. Despite the steam generator sleeving expenses incurred in 1995, Maine Yankee earned its allowed 10.65% return on equity before deducting non- .

recoverable costs such as charitable donations and certain advertising costs. )

Maine Yankee common equity investment exceeds all of the equity requirements established in its  :

fmancial agreements. The Company's common equity ratio is cost effective, closely monitored, and respected by the external fmancial markets. Maine Yankee maintains an implied investment grade j credit rating under Standard & Poors Corp.

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l Considered from the financial perspective, Maine Yankee's ratio of equity to total capitalization is ,

efficient. Because it exceeds the requirements of the Company's fmancial agreements and the j conditions of the current financial markets, there is no current fmancialjustification for increasing j the level of retained eamings. With its current financial arrangement, Maine Yankee is considered  :

credit-worthy and capable of meeting all financial obligations.

Imnlications for Maine Yankee's Owners Maine Yankee's ten owners feel the impact of costs passed through monthly under the FERC cost of service arrangement. Collectively, the owners carry a substantial common equity investment, including sizable retained earnings. Maine Yankee is sensitive to the need to manage resources efficiently to contribute to the continued financial condition of the owners. Indeed, Maine Yankee's ,

implied investment grade rating from Standard & Poors relies in part on the fmancial condition of 1 the owner utilitiesc y l

Conclusion j

Maine Yankee's ownership structure and FERC cost of service formula assures an adequate reserve  !

of funds to address contingencies, and access to money is not a contributor to the ISA's first root cause By drawing on the resources ofits ten owners, Maine Yankee avoids the need for large cash reserves held in its own accounts. This efficient use of funds contributes to Maine Yankee's creditworthiness and respectability within the fmancial community.