ML20149M322

Response to Independent Safety Assessment of Myap

ML20149M322
Person / Time
Site:	Maine Yankee
Issue date:	12/10/1996
From:	Maine Yankee
To:
Shared Package
ML20149M320	List: ML20149M317 ML20149M322
References
NUDOCS 9612160150
Download: ML20149M322 (176)

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1 RESPONSE TO THE i I i

i INDEPENDENT SAFETY l ASSESSMENT

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, MAINE YANKEE ATOMIC POWER i

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i December 10,1996 e l l

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i 9612160150 961210 PDR ADOCK 05000309 l p PDR  ;

TABLE OF CONTENTS Introd u cti o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i Section 1 - Root Cause Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 ,

Section 2 - Corrective Actions for Root Causes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 Section 3 - Corrective Actions for Specific Major ISA Deficiencies . . . . . . . . . . . . . . . . . . 3-1 Section 4 - Corrective Actions Required to Assure Long-Tenn Resolutions of the Deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 . . . . . Maine Yankee Excellence Action Plan . . . . . . Maine Yankee Business Plan Summarf . . . . . . Closeout Plan for Yankee Atomic Electric Company . . . . . . Actions Associated with ISA Requests for Information Enclosure 5. . . . . . Actions Associated with ISA Report Statements Enclosure 6. . . . . . Actions in Response to Safety Assessment Observations Enclosure 7 . . . . . . Clarification of Statements in the ISA . Report l

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INTRODUCTION Maine Yankee has considered the ISA's root-cause analysis in the context of third-party evaluations,  !

internal and external oversight activities, and self-assessment initiatives. '

1 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 two ISA root causes together, and link them with other performance issues.

The corrective actions presented here represent a fundamental change in Maine Yankee's approach i to conducting business. The cornerstone for that transformation is the Maine Yankee Excellence Action Plan, which aims to restore excellence in five areas: resource allocation, organizational improvements, Board of Director oversight and involvement, program enhancements, and management performance and workplace culture.

j 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 this response. The Business Plan has been structured to provide for the development, 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 unveiled October 9,1996, and is presented in Enclosure 1. The Business Plan is in the final stages of refinement for 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 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 de license basis or adopti ' d 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 cafety, design integrity, and equipment performance. We intend to monitor the effectiveness of our plans for improvement and adjust accordingly. In this manner, Maine Yankee intends to reestablish full confidence among employc es, regulators, and the public.

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This response is organized as follows.Section I summarizes Maine Yankee's assessment of the root causes of the issues identified by the ISA, its own evaluations and oversight activities, and third-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 corrective actions for the long-tenn resolution of the deficiencies.

This response also includes seven enclosures. Enclosure 1 provides the Maine Yankee Excellence Action Plan. Enclosure 2 provides the Maine Yankee Business Plan Summary. Enclosure 3 documents the closcout plan for the technical and process observations related to codes and 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 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.

Finally, Enclosure 7 provides Maine Yankee's clarification of certain statements made in the ISA Report.

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SECTION 1 - ROOT CAUSE ANALYSIS 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 efectively prioritized available resources, butfinancialpressures have caused thepostponement ofsome neededprogram improvement and actions. "

Discussion:

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

1. Intemal pressures 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 conective action, but were considered non-critical for safety and were cliaracterized by implementation delays, extensions, or cancellations.

2. Extemal economic oressures Emerging energy altematives 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 inadeauncy 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 t-i

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l 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. Esqurce utilization  !

[ 1 Overly conservative resource utilization is a product of the cost-containment culture. Departments l 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 camings is not a contributor to the ISA's first root cause. Maine Yankee's FERC approved cost-of-service rate making formula allows current j recovery of costs without a formal rate hearing. Under the FERC approved power contracts Maine l Yankee bills all actual costs of operating the company monthly. The Company's approved rate ,

l 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 Enclosure 7 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 signtpcantproblems in areasperceived by management to be oflow safety signipcance. Management appears complacent with the current level ofsafetyperformance and there does not appear to be a clear 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 containment fostered a form of corporate complacency in the sense of a willingness to live with problems considered to be oflow safety significance. While there are 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 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.

3. 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 generator testing, reactor vessel management, plant operation, and use of probabilistic risk assessment (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 apprehension ,

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Maine Yankee conducted a cultural assessment of the workplace which was completed in June 1996.

d '"he cultural assessment found workers throughout the organization have become increasingly concerned about the future of the facility. Apprehensive over the perceived threat of premature plant i shutdown, employees place undue emphasis on cost containment.

5. Accountability l

Although accountability is evident in high priority, high-visibility projects, like the steam generator ,

sleeving, the executive assessment identified a marked reduction in accountability for items which j fell below the perceived safety / cost justification threshold.

6. Administrative Obstacles Prior to the ISA, 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 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 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 j 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 i 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 j resulted in the diminished operating margins observed by the ISA.

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i SECTION 2 - CORRECTIVE ACTIONS FOR THE ROOT CAUSES i Following receipt of the ISA and our assessment of the root causes, Maine Yankee determined the need for significant and meaningful corrective measures to restore margins and establish Maine

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.

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! ECONOMIC PRESSURE i

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Maine Yankee is addressing the pressures to contain costs, the perceived inadequacy of resources

and resource utilization concerns by providirig additional resources and staffmg, by fundamentally J i 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 l 4 discussed in more detail below. Communication is discussed on page 2-5.

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I 1. Resouree Adeauacy i

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 i 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 i 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.

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2. Budcet Pret3aration

! The proposed 1997 budget, developed in parallel with the Business Plan and response to the ISA, i

] represents a fundamental departure from past practices. Managers, working individually and as 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 j

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.

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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 j 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-i

2,1996. The consultant's report indicated staffing, particularly in the Engineering and Maintenance 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 i plan for 1997. Staffing needs will be addressed in 1997.

Maine Yankee will provide the appropriate employee and contractor staff'mg to perform the work l 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 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 i of additional positions has not been finalized, the projected increase represents a substantial increase in total staffing.

PROBLEM IDENTIFICATION Maine Yankee is addressing the root cause involving problem identification and corrective action by improving personnel performance and organizational and programmatic effectiveness in identifying .

and resolving problems. Each of these is discussed in more detail below.

1. Management Assessment Maine Yankee has recognized the need for effective leadership and management competence as prerequisites for restoring the utility to a leadership position in the industry. Toward this end, by April 1997, the Maine Yankee Board of Directors will complete an assessment of each officer's ability to contribute to a successful transformation of the company, including problem identification and resolution. Each manager will likewise be evaluated by a third party screen reporting to senior 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 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.

2. Sunervisorv 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.

Each workshop has as its underlying theme effective situational leadership and development of an 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 will be developed by June 1997.

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3. Team Develonment I

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 work group. To date 30 employees have been through the training. The workshops are scheduled to continue in 1997.

4. Individual Develonment 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 goalis 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 stafTmg during decommissioning. As applicable, programs will be incorporated in Company Manuals and Handbooks by January 1998. This is intended to address end oflicensed life as well as a premature shutdown.

6. Worker Performance Evaluation )

l 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 l questioning environment, with emphasis on the application of skills learned in the supervisory  ;

development workshops described above. The full scope of revisions will be announced in January i 1997 following completion of a review by an employee team.

7. Marcin Imnrovements Procram l

Maine Yankee will develop and complete a design and operating margin review to identify any areas j where the margins, although adequate, do not satisfy today's standards of excellence. Where margin l improvements are determined to be warranted, appropriate plant upgrades will be provided. Maine 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 23  ;

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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 vere previously planned.

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8. Worker Comnense+ign  !

Maine Yankee has revised its middle-management compensation program to significantly reduce reliance on incentive-basea 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 middle l 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 camed 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, easier problem identification, a stmetured and consistent approach to evaluation and prioritization of problems, and enhanced tracking and trending. Properly applied, the process will contribute to development 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 i Business Plan provides for integrated planning, and serves as the single vehicle to establish and l l

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 l

performance issues. Issues from the ISA have been integrated into the attached Business Plan summary.

Communication I 12.

Clear, consistent communication is necessary to change the culture throughout the company from I 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 ofintemal media.  ;

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13. Yankee Atomic Interface As more fully discussed in July 1996 in a meeting with the NRC staff, Maine Yankee has 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. Benchmarkine 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 exchar.js information with other utilities in the area of budgeting.

15. Worker Concern Procram The President commissioned an evaluation of the program by a group of employees in August 1996 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 in; ended 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 concerns. The training will be concluded by June 1997.

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

from raising concems. 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 extemal consultant experts. Their charter was to validate, provide oversight, and effectively integrate initiatives in the implementation of the Cultural Assessment team corrective actions to ensure maximum organizational effectiveness and efficiency.

The team's recommendations, which have been approved for implementation and have been factored into the Business Plan, are described throughout the ISA response and include such things as the worker concern program changes, the compensation changes, end oflife committee, and the supervisory effectiveness training described above.

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 i 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 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 perfonnance 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 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 aad 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 i

- 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 l

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 concem for costs.

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SECTION 3 - CORRECTIVE ACTIONS FOR SPECIFIC MAJOR ISA DEFICIENCIES Introduction On October 10,1996, the ISA held a public exit at Maine Yankee regarding its inspection 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 have focused on the significant issues raised during the Commission meeting. This section 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 i

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.

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- PCCW inlet and outlet piping for containment air recirculation fan coolers 1 and 2.

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

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/Circulatine Water Pumo House Material Condition In response to initial ISA walkdown concems, 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 bearinJ lubrication systems (primary and backup) for all four SW pumps have been uvaluated. 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.

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. 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 l maintained. j l

. The circulating water pump house has been painted. An epoxy coating has been )

applied to the floor and component bases for proter. tion against salt water.  ;

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. Personnel safety improvements are being implemented. The catwalk handrails i between the SW and cire water bays have been enhanced. l l

l 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 ISA, 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 Housekeening ISA observations inside the containment indicated that housekeeping required greater attention to l 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 l 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 smnp .

clogging), these findings were not acceptable from a commitment to excellence perspective. l 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 l

the plastic wherever possible. Where contamination levels cannot be reduced to acceptable levels, only high temperature plastic will be used in configurations evaluated to ensure that a l safety concern does not exist. This effort will be completed by the end of 1997 refueling outage.

The plastic currently 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 l 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 Erosion / Corrosion Procram l Notwithstanding Maine Yankee's adherence to its Erosion / Corrosion Program, the ISA team l 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 visualinspections.

Additionally, the ISA noted several small leaks in secondary 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 outages and several of these lines were replaced during 1995. Maine Yankee plans to continue to 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 prepared. In fact, TR-15 and the piping downstream of TR-15 had been replaced with improved materials 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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Equipment Performance Issues

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l Onerator Workarounds 1

Maine Yankee assessed the impact of operator workarounds individually upon identification or

creation. The management team also assessed the most significant items periodically at morning

! 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

! situation that created the workaround. Maine Yankee has reassessed each of the operator

j. workaround's individual and collective impact on operators during accident conditions. At this .

j time, based on our review, we conclude there is no single or collective workaround interaction l that would unreasonably impede the operator's ability to perform under accident conditions.

l Maine Yankee recognizes the importance of promptly resolving identified operator workarounds, l 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 L process for reviewing the aggregate affect of workarounds by March 1997.

l Maine Yankee has made or is planning to make design or equipment changes to correct each of

(- the thineen most significant workarounds identified by the ISA.

3 The following provides the current status of these changes:

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! 1. Motor-driven main feedwater pump trip l

I The operator would have to attempt a second start if P-2B tripped on low lube oil pressure during j an attempted start. Such a trip occurred three times in the last 21 start attempts during the past

! five years. The apparent cause was loose lube oil pump suction flange nuts and deteriorated  ;

I suction flange gaskets that allowed air to be drawn into the lube oil suction piping when a 4 feedwater pump start was attempted. These specific deficiencies have been corrected (WO 96-2 2622) and the same work is baing perfonned on P-2A during the ongoing pump overhaul.

2. RH-4 leakage l

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

1 l 3. Slow response of main feedwater pump P-2B recirculation valve 4 I

The apparent cause of the slow response was resolved when the valve positioner was replaced on l

3 August 1,1996 (WO 96-256) with a positioner having high temperature components to increase i longevity (TE 130-96). Additionally, to optimize performance, work orders have been prepared 2

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 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.

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

During the controlled plant shutdown of July 20,1996, the plant computer overloaded when operators attempted to drive rods in manual sequential mode. It is imrottant 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 ,

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

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 I 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 l 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 pennanent 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

- group or individual mode), as required.

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

1 monitoring instrumentation for control room operators, improved procedures and administrative

. controls in the event of system failures. Based upon funher evaluation, additional compensatory measures were adopted in 1996, which inch.ded blocking inlet and outlet dampers open, and the recire damper shut, to maximize cool air f1 aw into the room. These measures minimize the potential impact on ambient temperatures in the switchgear room due to a postulated high energy line break in the adjacent turbine building. This matter has been documented in letters to the Staff dated August 14,1996 (MN-96-114) and November 18,1996 (MN-96-154).

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 protected switchgear room and the battery rcom. The new system will be powered from independent, safety-related buses. This design upgrade is scheduled for completion during 1997.

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

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

8. Emergency diesel room ventilation Before the ISA, Maine Yankee determined that the emergency diesel room ventilation supply and exhaust dampers were not capable of operating against the high differential pressure that would be generated by a tomado. Similar to the protected switchgear room ventilation system, original design of this ventilation was not required to be safety related and tomadoes in the vicinity of the diesel rooms were not considered credible. The dampers were not, therefore, 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 tomado 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 retumed to its normal configuration. The dampers will again be blocked open during periods of higher tomado probability. A design modification to replace the existing damper system with one qualified to operate against differential pressures which could be experienced during a tomado will be completed in Maine Yankee's subsequent operating cycle (cycle 16). At this time, this workaround has been resolved.

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9. Containment spray building ventilation (exhaust fans FN-44A/B)

This operator workaround has been resolved by installation of mechanical stops and by 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 Before the ISA, Maine Yankee's IPEEE review had identified potential turbine building intemal 36

flood mitigation concems. Compensatory measures were instituted, such as blocking the roll up doors open five inches from the floor. Permanent modifications include increasing the berm l

height to the cable vault (complete) and to the control room, installation of turbine building l flood relief panels, and installation of a flood channel to carry internal flood water away from the i turbine building. Additionally, a circulating water pump trip circuit with turbine building flood l l

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 l are currently under way with completion scheduled for early 1997. Upon completion of this effort, this workaround will be removed. i l

11. Remote isolation of a ruptured steam generator Under the cun ent 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 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 provided to the Staff by letter dated October 3,1996 (MN-96-142).

12. Steam generator atmospheric steam dump valve capacity As reported to the NRC in a letter dated October 3,1996, (MN-96-142), Maine Yankee is now engineering physical modifications to the atmospheric dump valve (ADV) system. These modifications include the installation of an ADV with a steam relief capacity of approximately 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 inadequate core cooling event with loss of offsite power. The design change is now under way and installation is scheduled for completion during the 1997 refueling outage. At that time, this workaround will be resolved.

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 with an automatic initiation of a motor-driven main feedwater pump, load studies concluded that power being supplied from 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 str.rt circuitry for the motor-driven feed pumps (P-2A, B) to prevent automatic stan 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 Pumo Reliability l

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 4 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 l 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-i term improvements are scheduled for completion by the end of 1996; the long-term ,

improvements will be scheduled using the Leaming 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 i governor oil and turbine oil. The above actions, although not under way prior to the ISA, would j have been performed as P-25B was categorized by Maine Yankee as an A(1) component under

. Maintenance Rule.

1' Component walkdowns have been conducted by the Maine Yankee multi-disciplinary team and j by an INPG Assist Team. The results of the walkdown have been incorporated into the j short/long-term improvement lists.

Design / License Basis and Operability Issues Raised  ;

d l 4 i 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 2

has embarked on a continuing improvement program to correct the deficiencies noted in the ISA i Report and to improve Maine Yankee's overall performance in this area. Actions under way

! relative to licensing basis improvements are discussed later in Section 4 of this response. Maine l l

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 Commissien meeting are discussed below. j

' Ventilation Systems

Maine Yankee acknowledges that the overall design and material condition of the ventilation i systems need continued management attention to enhance margin. Also, the Maine Yankee PRA

[ supports the need for added attention in this area. Accordingly, Maine Yankee has implemented

- 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 protected switchgear room, turbine hall, diesel generator room, containment spray building, and 3-8

l the emergency feedwat:r 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. Maine Yankee 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. l 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.

Logic Circuit Testing At the time of the ISA, Maine Yankee had begun evaluation of the adequacy of system logic circuit testing in accordance with Generic Letter 96-01. As a result of a deficiency noted by the 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.

l The details of this testing program were communicated to the NRC by letter dated August 23, 1996 (MN-96-123). Specifically, Maine Yarikee reviewed procedures for circuits identified in 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 conected prior to l plant startup. l 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 j 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 completion 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 Transmitten As discussed in the ISA Report, Maine Yankee identified a service life concem 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 concem. 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.

Sprav Pumn NPSH The ISA Repon 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 pemiission to credit containment internal accident pressures in spray pump NPSH calculations and Maine Yankee has done so to demonstrate adequate NPSH availability. But, the margins available, even when crediting internal 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 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 completed prior to Maine Yankee seeking approval for return to 100 percent power.

Equipment Oualification-Submergence 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 levelinside 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 containment flood line and has providedjustification for operation of the remaining items. The balance of the remaining items will be evaluated and corrected as necessary during the 1997 refueling.

A departmental root cause evaluation has been completed and a supplemental plant root cause evaluation to confirm the depanmental findings has been performed and is in final review.

Corrective actions to prevent recurrence are being developed and Maine Yankee will notify the NRC regarding these actions. Additionally, an independent assessment of the EQ Program using recognized industry experts is under way and will be completed by December 31,1996.

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 l current) is now expected to end in 1997 and all remaining items are scheduled to be completed.

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1 l Control Room Positive Pressure Tcg 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 perfonned 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.

Further review of the October 31,1995 test results and supporting engineering analytical l documentation during the ISA raised additional questions about the operability determination. l 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 conective 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 Comoonent Cooline Water Marcin 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 perfomlance 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 initiatives aimed at improving and verifying system margins. The following improvements are completed now or are scheduled for completion during 1997.

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

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

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

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

systems operated within analysis / calculation assumptions.

. Develop a preventive maintenance work instruction to provide for periodic calibration of heat exchanger temperature control valves, positioners, and associated temperature controllers to assure reliable operation.

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

and location; instrument uncertainty detennination; correlation of assumed / calculated fouling )

factors to actual conditions; test methodology and trending of results; and inputs and assumptions related to heat loads, flow rates, etc. Upon completion of the integrated evaluation, 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 ,

completed during 1997. l The initial phase of the 'ntegrated 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  !

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.

Overall, Maine Yankee plans to demonstrate adequate margin for this system prior to seeking NRC approval for retum to full power.

Turbine Building HELB The IS A reviewed Maine Yankee's ongoing activities to address turbine building high energy line break (HELB) issues identified in early 1996 as part of Maine Yankee's IPEEE review. To date, Maine Yankee has conducted analyses for the summer and the winter turbine building ventilation configurations. 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, 1996 (MN-96-231).

Permanent inodifications being designed and implemented in the turbine hall include:

. New protected switchgear room ventilation outside of the turbine hall

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

. Installation of turbine hall siding pressure relief panels

. Reinforcement of unprotected switchgear room masonry wall to withstand HELB pressures 3-12

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l a' Remotely-actuated or automatic dampers for post-HELB turbine hall ventilation

. Upgraded motors for CCW systems

• Install qualified solenoids to trip CCW HX temperature control valves W

The above actions are scheduled to be completed during 1997 or as equipment can be procured.

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SECTION 4 - CORRECTIVE ACTIONS TO ASSURE LONG-TERM RESOLUTION OF THE MAJORISA DEFICIENCIES Introduction Maine Yankee examined possible trends indicated by the problems identified by the ISA and those known from other sources. We identified five key dimensions of our performance which warranted aggressive, comprehensive steps to achieve improved performance. When fully 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 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.

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 program. The IS A also identified weaknesses in Maintenance, including declining material conditions and inconsistent equipment material reliability. Maine Yankee's improvements related to each of these weaknesses is discussed below.

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_estine Imorovement Program Maine Yankee is committed to significantly improving the overall scope, technical adequacy, and methodology ofits testing program. This improvement effort will be implemented in 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 otherwise 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 4-1

l At 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 revie y 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 l 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.

l 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 Procram j 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 of program valves during subsequent outages.

Backloc Reduction 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 Navember 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. Eve;y 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 42

additional action was warranted. Maine Yankee is evaluating lessons learned from recent benchmarking 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 resolution and the follow-up actions have been collected for resolution. The process utilized during 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 Improvements 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 Procam Another facet ofimproving material condition is the formal establishment of a predictive maintenance program. One ebjective of the program is to improve plant safety and reliability by preventing equipment failures through early identification and diagnosis of equipment problems or deterioration. Another is to reschedule major preventive maintenance tasks when justified by 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 utilizing EPRI guidance and industry benchmarking. 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 ar.d five draft implementing procedures have been prepared. The program is scheduled to be fully implemented during 1997.

Erosion / Corrosion Control Procram The ISA Report t cated that the Maine Yankee erosion / corrosion program was adequate, but was difficult to asser.s because the common industry practice of using a computer-based program to .

determine inspection points was not being used.

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l 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 completely implemented, the new program will meet the guidelines of NSAC-202L, l

" Recommendations for an Effective FAC Program," published by EPRI and will utilize the EPRI l 2 CHECWORKS code, both of which are industry-accepted practices. The new program is being l 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 l 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, l This program is discussed below, together with Yankee Atomic's improvements in the  !

Engineering Deficiency Report process. Additionally, the ISA identified weaknesses related to environmental qualification. Maine Yankee's programmatic improvements in this area are also l discussed below.

System Encineerine Group 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 managemeni.

The basic concept is single point responsibility and accountability. Systems deemed " risk j significant" by the Maintenance Rule will be assigned to system engineers. The system engmeer  ;

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 ftmetion 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:

. 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 44

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

. Establish, compile, track, and interpret performance indicators

. Conduct regularly scheduled,in-depth system walkdowns

. Report to management regularly on system health

. Specify post-maintenance test requirements and assist in planning /prioritization of maintenance Staff additions are being made to fonn the group. A Section Head and approximately ten i engineers will make up the group and are scheduled to be fully functional no later than the end of 1997. The system engineering program will help improve problem identification and resolution by engineering, and will enhance system ownership by engineering.

Yankte Atomic Encineerine Deficiency Reoort (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 the generation of the safety analysis calculations. Yankee Atomic self-identified in late 1995 that the reportability threshold was too high for the results to serve as a performance or precursor indicator management tool. Steps have been taken since early 1996 to informally lower the reportability threshold. WE-109 was revised to reflect a formal lowering of the threshold; 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 subsequent usage of the EDR reportability results as an appropriate management tool.

Environmental Oualification Procrajn A self-assessment (with assistance from industrv recognized experts) of the environmental qualification (EQ) program is currently bung anducted by a review team to evaluate the .

contmued 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 experience and plant experience in the specific review focus areas. The primary focus areas of i this review are the design process, incorporation of EQ requirements in the operating plant, maintenance of EQ equipment, and quality assurance. Each of the primary focus areas will be reviewed relative to EQ installations selected by the review team as representative of critical equipment installed in the plant and the spectrum of EQ challenges known in the industry.

Examples include Limitorque operators, Rosemount transmitters, ASCO solenoid valves, CONAX conduit seals, and NAMCO limit switches. A representation sample of several equipment items reviewed in detail will be sufficient to evaluate the key aspects of the EQ Program and provide insight into areas for improvement. Management will be notified about areas of bmediate concern identified by the team, along with recommendations for correction.

Tracka <he resolution of each open item will be tha esponsibility of the EQ Coordinator.

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

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l 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.

l 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 Recovery As indicated in the ISA Report, the operational and design margins have been found inadequate 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 ,

I 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 Desien Bases Information I 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 infonnation. 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.

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

Conficuration Manacement Imorovement Procram 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 l 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 Technical Specification bases. The l review of the UFSAR commenced in April,1996, and resulted in approximately 160 potential i changes being generated to date, most of which will be resolved or incorporated by June,1997.

'Ihis 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 searching and network distribution. Administrative controls and procedures have been revised to assure that safety evaluations are submitted with all proposed j 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. l Improvements in the commitment management system have been initiated through a series of steps to re-identify commitments and assure continued conformance with them. Currently, l docketed license and SER communications and correspondence are reviewed to identify I 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 j control mechanism. The remaining SER correspondence from commercial operation date l 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  !

i 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 affe ,t their areas of responsibility. Periodic training will be conducted to increase and maintain awareness of the conditions for performing 50.59 evaluations with appropriate Maintenance and Operations personnel as well as with the Engineering Division.

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l Additionallf, configuration management initiatives at YAEC are being implemented to improve l 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 i regulatory requirements conceming the license / design bases analyses and that Maine Yankee is 1 promptly informed of changes or discrepancies affecting the analyses.

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The completion date for the configuration management initiatives is currently planned for the end of 1998.

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 l Analyses, Maine Yankee will develop and implement a Methods Overview Manual (MOM). d This manual, represented by a new set ofliving documents, will provide a cohesive reference l resource for analysts in the cyclic assessment of the safety analysis transients. The MOM l includes identification of key safety analysis inputs and parameters, methodology descriptions,  ;

references and overviews, identification and discussion of key phenomena and important i 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 cource 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 4-8

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

Maine Yankee Process for Reviewing Safety Analysis Innuts 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 and analysts in the development and generation of the safety analysis. Included as a part of this effort is the assessment of the cycle-specific inputs to the safety analysis. On a consistent basis, 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, reviewed by the safety analysts for identification ofimpact on safety analysis inputs.

Concunent 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.

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

Safety Analysis Oversight Imorovement Procram Self assessments of safety analysis oversight have resulted in observations 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.

• 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. ,

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. 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 ofsafety analysis issues.

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.

I 4.4 Operations The ISA identified weakness 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.

Onerator 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.

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

Post-Trin Reviews 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 conective action processes, weak implementation of the processes and occasionally ineffective corrective actions, and many individual improvement 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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Leandng 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 Suggestion Program to stimulate employee suggestions for non-safety improvements, and the Worker Concems Program to provide a secure and confidential route for employees to address unresolved safety concems. The LP will include procedural controls to manage the interface and redistribution ofissues among these remaining processes.

l In addition to consolidating processes, the LP will provide a readily available entry point for all l issues through an on-line open-access computer system, common screening and coding criteria, an expert 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,  !

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 I 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. j The LP also includes provisions to avoid problem recurrence which we are confident, will address the ISA concern 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 l experience in prior experience searches, and a searchable teamable lessons database that can be l I

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 Infonnation 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 task 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 assessment 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 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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4. n

. ENCLOSURE 1

MAIN'E YANKEE EXCELLENCE ACTION PLAN O

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MaineYankee AEllABLE ELECTRICITY $1NCE 1972 4

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, l design basis documentation, corrective action procedures and business plan enhancements.

Externally, the U.S. Nuclear Regulatory Commission (NRC) conducted the most thorough inspection ofMaine 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 l 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 ccurse 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 impmvements 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 Malme Yankee 10/09/96

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, 3. Board of Directors Increases Oversight i i

j ' 4. Program enhancements

5. People & Cultural Changes -

l f- 1. Resources ,

a) Budget: The Excellence Plan is consistent with actions necessary to ensure

adequate resources are available at Maine. Yankee. For example, $10 million ,

j already has been authorized to address the ISA pmcess and the Action Plan. '

! Maine Yankee is committed to providing whatever resources are necessary to i

continue to operate safely.

j b) Perunnneh Maine Yankee has retained the professional firm of Tim Martin and Associates to benchmark company staffing levels as compared to the best in the j industry.

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{ 2. organizational Changes 4

a) Senaration ofI icensing & Engineering Dents to provide incraa<ad rigor: - To-j provide more focus on both regulatory compliance and engineering, the current i 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

address the issue of commitment tracking and meeting regulatory requirements.

i The position will also be responsible for licensing issues, staying abreast of and anticipating evolving industry standards. This dedicated focus will further support a culture of excellence within the company. We are launching a nationwide search to identify and recruit the most experienced and respected 3 manager available for this new position.

The Vice President of Engineering position will bring increased focus on i technical issues and implementation of regulatory requirements and will provide additional oversight of Yankee Atomic Electric Company.

L l b) Human Reenurces given greater rennonsibility visibility: As of today, Maine

!- Yankee's Human Resources function is being detached from the Finance &

l Administration Department. Under a new Manager of Human Resources, this

!- department will now report directly to the president of Maine Yankee. This is not

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a symbolic move, but a practical way of ensuring that human and corporate-culture issues receive the direct, top-level attention they demand.

4 c) Seninr Ontage Mannger nomition craataA: As part of Maine Yankee's pursuit of i 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, s

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. d) Maine _YankeeAXankecAtomic_moreformallymeparatedLWe have taken action to formalize the organizational separation of Maine Yankee from Yankee Atomic i Electric Company (YAEC). YAEC is Maine Yankee's principle engineering i 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 camed the highest respect for its engineering skills. But as the  !

RELAP computer code investigation demonstrated, ambiguous l responsibilities and overlapping jurisdiction invite operational confusion.- l 1

(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 eetahlisheA 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) Eormer NRC seninr manager to join MV Board of N pr ? , 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) Bnainen plan integrated to imnrove pinnning a resource allocatinnt Maine Yankee is now integrating several existing planning processes into one central document, called the Maine Yankee business plan. This will ensure that i consistent, coordinated priorities are developed for overall operations and j adequate resources are provided to meet both short term and long term goals. The  ;

business plan will also provide a document to systematize improvement projects j under way at Maine Yankee, including the response to the ISA report. j b) Centrali7ad Corrective Action Trackingt Last year Maine Yankee began a reengineering process to completely revise its corrective action process. That ,

process, called the Leaming Bank, is now being implemented. It will I centralize the corrective action tracking system and provide increased management oversight to ensure that improvements are prioritized and on schedule.

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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 concerns of our regulators. Our current limitation of operating at only 90-percent power deprives Maine and the rest of New England of some 13 million kilowatt-hours of very economical energy every week. Retuming the plant to full power would benefit the economy for the entire region. ,

d) Other programs created to strengthen Maine Yankee Additional significant performance improvement programs at Maine Yankee include the Maintenance Improvement Program, the Engineering Quality Improvement Program and the Safety Analyses Improvement Plan. Also being addressed by other program 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 learning experiences and opportunities.

5. People a) Maine Yankee manngement comniitment- 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 encourage employees to bring forward safety concerns and who reward employees forinnovation.

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

(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 in support ofINPO missions.

(3) Accountability: Maine Yankee is committed to ensuring that full personal 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) Forker Concern Program: Management understands that it must be genuinely open to workers' concerns on safety, operations, and other issues - and that workers must feel confident in the integrity of the process for communicating concerns. To that end, the Workers Concern Program is being revised to strengthen the program and to heighten worker awareness ofits capabilities.

Maine Yankee 194936

1 (S) Supervisory Development: Maine Yankee has renewed its efforts in l

supervisory training. Leadership and communication training is being {

provided to supervisors to ensure that our supervisors have the skills l

necessary to enhance employee effectiveness.

CONCLUSION This comprehensive, focused Excellence Action Plan will help Maine Yankee meet the challenges raisai 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 electricity from nuclear energy.

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ENCLOSURE 2 1

MAINE YANKEE BUSINESS PLAN

SUMMARY

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i 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 with and aligned to the Company's Vision, Goals and improvement Initiatives.

1 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 wb '

• Key financialinformation

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Maine Yankee REI.lABLE ELECTRfCITY FOR MAINE $1NCE 1972 i

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5 Prepared by Maine Yankee Business Plan Integration Team December 9,1996 l

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ne C o m pany . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . 3.  !

Ma rket Ana lys is . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,1p l Com pany V i s ion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . n Company Goals in Pursuit of Excellence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . n -

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Performance Indicators for Goals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D l'

1 M anagem en t Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Organ izatio na l C hart . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 i

i Board o f D i recto rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 I

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Business Plan The Company 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 further detail, reference the specific documents.

Overview 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 Wiscasset, 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 uith 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

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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, l 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 j 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 De Connecticut Light and Power Company l 12 l

l Bangor Hydro-Electric Company l 7 l

Mame Public service Company s l

Public service Company of New Hampshire l s l

December 9.1996 (9:46am) Page1

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Business &n l Montaup Elcetric Company l 4 l

l l westem Ma:,sachusetts Electric Company l 3 l Central vennont PuNic Senice Corporation l 2 Total l 100 %

The obligations of the Sponsors to make payments under the Power Contracts l

are unconditional, subject only to each Sponsor's right to cancel its Power l Contract if deliveries cannot be made to the Sponsor because either (i) the Plant 1 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 domain or a similar right or power, or (iii)(a) the Plant cannot be used because of contamination or because a necessary license or authorization cannot be  !

obtained or is revoked or the utilization thereofis made subject to specified l conditions which are not met, and (b) the situation cannot be rectified to an j extent which will permit the Company to make deliveries to the Sponsor from l

the Plant. Notwithstanding the right to cancel, the obligation to pay decommissioning costs continues until the Plant has been fully decommissioned.

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 uould constitute a l default under the Company's First Mortgage Indenture and two other major credit agreements unless cured within applicable grace periods by the defaulting

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Sponsor or other Sponsors.

The Plant 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 uhich are owned in part and operated by CMP.

The Plant is a nuclear-pouered electric generating plant, utilizing a presstrized-uater reactor, fueled with slightly enriched uranium oxide. The nuclear steam i supply system and certain other equipment were designed and fabricated by l 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. Ccnstruction of December 9.1996 (9:46am) Page 2 l

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i the Plant, which 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, t 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 i

addition, the Company is retaining a new ABB main electrical generator as an l emergency spare component. Since the original construction cost of approximately 5231 million the Company has made, through December 31.

1995, approximately $218 million in additional capital improvements.

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

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

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 regulation by the Maine Public Utilities Commission ("MPUC") as to some l aspects ofits business, including the issuance of securities.

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The United States Environmental Protection Agency (" EPA") administers programs established under the Federal Water Pollution Control Act and the Clean Air Act, as amended in 1990, which affect the Plant.

In addition, pursuant to the Federal Resource Conservation and Recovery Act of l

1976, the EPA regulates the generation, transportation, treatment, storage and 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.

December 9.1996 (946am) Page 3 l

J Business Plan

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The National Environmental Policy Act of 1969 ("NEPA") requires that detailed statements of the environmental effects of major federal actions be prepared by federal agencies. Major federal actions can include licenses or permits 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 an 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-

, volve NEPA requirements.

4 l The Company is also subject to regulation as to enviionmental 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 i the state authorities havingjurisdiction over the Company's facilities may j modify permits or licenses that have already been issued, or impose new i conditions on such permits or licenses, and may require additional capital expenditures or require that the level of operation 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 otherwise available,(ii) to take the total output of the Plant, l and (iii) to pay all costs of the Plant. including capital and decommissioning l costs.

1 Operating Results .

Plant Operations i

l 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 l Company is currently planning and scheduling the next refueling-and-maintenance outage, which is now expected to begin in the early fall of 1997, j 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. i Steam Generators i

j The Maine Yankee unit. like other pressurized-water reactors, had been 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 l

j December 9.1996 (9:46am) Page 4 1

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 financial 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 incur additional costs of approximately $27 million during 1995.

Power Output Limitation On December 4,1995, when the sleeving project was substantially complete,

.\laine 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 official 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 'or the Company and other nuclear plant operators. The letter contained allegations that Yankee knowingly performed inadequate analyses to suppon two license amendments to increase the rated thermal power at which the Maine Yankee Plant could operate. It was funher alleged in the letter that Alaine Yankee deliberately misrepresented the analyses to the NRC in seeking the license amendments. The allegedly idgiate analyses related to the operation of the Plant's emergency cort cooling cystem ("ECCS") and the calculation of the Plant containment's peak postu ated accident pressure, both under certain assumed accident cond tions. The analyses were used in support oflicense amendments that authorind Plant wwer uprates from 2440 megawatts thermal, a level equal to appro .imately 90 percent of the maximum electrical capability of the Plant. to itwerent 100-percent rated level of 2700 megawatts thermal.

In response to technical issues raised b < the allegations, the NRC initiated a special technical review of the safety ar.alyses performed by Yankee relating to Slaine Yankee's license amendment applications for the power uprates. At the December 9.1996 (9:46am) Page 5

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l 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.

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On January 3.1996, the NRC issued a " Confirmatory Order Suspending l 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 of containment pressure.

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

l 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 4 the Plant's capability. In its submitta! Maine Yankee also notified the NRC that j I

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 l 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 Office OfInspector General ("OlG") and its Office ofinvestigations ("Ol") initiated separate investigations of certain anonymous allegatioas 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 3

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 01 investigation report before final release. An internal assessment by Maine Yankee and Yankee noted several areas that could have been improved including 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

4 Business Plan Independent Safety Assessment

. 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 OIG report. The NRC stated that the overall 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 safety 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 contractors who were " independent of any recent or significant involvement with the licensing, regulation or inspection of Maine Yankee."

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 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 the root causes were:(1) that economic pressure to be a low-cost energy provider had limited available resources to address corrective actions and some improvements; and (2) that a questioning culture was lacking, which had resulted ia a failure to identify or promptly correct significant problems in areas perceived by Maine Yankee to be oflow safety significance.

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 or when the Plant will attain a 100 percent operating level, or the results of the ongoing NRC and U.S. Department of Justice investigations and reviews.

Capital Resources The Company currently has capital resources available from secured and unsecured lines of credit totaling S106 million.

Notes Payable To Banks The Company had bank lines of credit totaling $21 million as of December 31, December 9.1996 (9.46am) Page 7

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Business Plan I

1995.

i Secured Credit Agreement l In 1989, the Company entered into a secured credit agreement with a group of banks including the Bank of New York ("BNY"), which is also acting as the 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 certain 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 w hich the Company may borrow up to $35 million.

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First Mortgage Bonds l 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. l 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 l

7.48% Series. On December 31,1995, the outstanding balance was approximately $4.2 million.

8.00% 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 equity ratio requirements. Through December 31,1995, the Company was in compliance with these requirements.

December 9.1996 (9:46am) Page 8

1 Business Plan Credit Rating 1

). 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.

i The negative outlook rating reflects concern over the ability to reestablish  !

reasonable operating performance consistent with past plant performance, as 4

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

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the ten utility owners of Maine Yankee.  ;

i The Company, as well as the nuclear electric industry in general, has been challenged by common problems in recent years including those of controlling operating cosis and expenditures for plant modifications attributable to more

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stringent regulatory requirements and uncertainties caused by political l 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 i Company, I

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Business Plan Market Analysis overview This section provides an ov:rview of the major factors driving the electric utility industry. The focus of the market analysis is within the New England Region, but also 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 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 pow er 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 naural gas into electricity. There are two proposed natural gas pipelines through the state of Maine which will make gas-fired 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 s ertically integrated monopoly l with regulated returns. The industry's future is expected to be an unregulated i

competitive market with performance based profits. It is also expected that there will be a generation sector and a power marketing sector as the two major l components of the electricity supply business. By the year 2000, the generation l sector may become consolidated while the power marketing sector may offer aggregate energy services by integrating gas and electricity services to

i. consumers. Ownership and control of generation assets may be a key to future value creation.

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December 9.1996 (9:46am) Page 10

i l Business Plan Company Vision A 3artnerslia o' l

3ro essiona s wor <ing i toget,er :o 3 roc uce sa=e, 1

l re iaa e, com 3etit.ive l l energy we into :1e next l -

cen :ury.

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1 December 9,1996 (9.46am) Page1I

T 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.

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Sustain high nuclear and industrial safety standards. l Achieve optimal plant material condition.

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• Provide cost competitive, reliable  !

l electricity.

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

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• 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.

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

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

B. Achieve optimal plant material condition.

C. Provide cost competitive, reliable electricity.

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

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

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

G. Prerare for and adapt to an uncertain future.

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

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

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

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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 plant.

B-3 Improve equipment and system testing and reliability.

B-4 Reduce critical work backlogs.

GOAL C: Provide cost competitive, reliable electricity.

C-1 Return to 100% power.

C-2 Optimite financial 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.

D-2 Strengthen employee development.

D-3 Improve internal communication.

December 9.1996 (9:46am) Page 14

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Business Plan GOAL E: Improve planning and prioritization processes to effectively utilize resources.

4 E-1 Optimize work control / planning process.

1 E-2 Continue Business Plan integration.

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

l j E-4 Evaluate human resource adequacy (quantity and

allocation).

E-5 Optimize outage duration.

E6 Improve performance indicators and how they are used.

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

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

F-3 Enhance industry awareness. l l

GOAL G: Prepare for and adapt to an uncertain future. I G-1 Address uncertainty of future and employee EOL concerns.

i 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

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4 Business Man

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- .I BP Task No.:

4 A unique sequential identifier for the task. For example, the first task for the A-1 initiative is A 1 1.

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LB Task No.: The task number in the Learning Bank that has been assigned l 1 to the task.

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

i 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.

4 Task Manager: A Learning Bank term used to describe the single individual i

responsible for managing the task to completion. '

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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 j cycle 15 capital budget. ~

, Additional identifies if there are additional costs, both O&M and capital, l Lifetime for all of the budget lines associated with the task.

l Costs:

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d 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.

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Decembe'r 9.1996 (9:46am) Page 42

Business Plan i

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Tracking of Business Plan Tasks  !

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, The Maine Yankee Business Plan will be the governing document for all initiatives and their tasks. The Learning Bank will be the vehicle for tracking the status of each task and sub-task associated with the initiatives. Refer to Learning Process Procedure 0-16-1 for guidance.

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o l *To facilitate tracking of Bustiess Plan items to a sub-task level within the Leaming Bank system, each item jl wul be entered as a "non-issue" task. As defined by the Leaming Process. a non-issue task is that which is not Sub-Tasks j tied to a previously idenbfied issue in the system; a task for which no root cause evaluation is required.

'l Figure 28 Tracking of Business Plan Tasks 4

j December 9,1996 (9:46aml Page 43 l

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

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, 4 4

l Business Plan '

4 Board of Directors (As of I1/96)

Arthur W Robert S. Briggs Chairman of the Board. President and Dangor fly dro Electric Co.

Chief Esecutive Omcer Kent R. Brown Vice President. Engineering & Central Vermont Public Service Operations j Paul Cariani l President and Chief Executive Omcer l Maine Public Service Compan L illian Cuoco Ted C. Feigenbaum l Senior Nuclear Counsel l Northeast Utilities l

Executise Vice President and Chief Northeast Utilitics Nuclear Omccr David T. Flanagan l President and Chief Executisc Omcer l Central Maine Power Compan Charles D. Frizzle President and Chief Executis e Omcer Maine Yankee Atomic Power Company ,

Frederic E. Greenman l New England Power Company l Retired John B. Keane Vice President and Treuurer l l Northeast Utilities Service Carroll R. Lee Vice President. Operations l Bangor Hydro-Electric Company l l j David E. Marsh Vice President. Corporate Services. Central Maine Power Company Treasurer and Chicf Financial Omccr Dr. Thomas Murley Retired l Nuclear Regulatory Commission l

Donald G. Pardus l President and Chief Executive Omcer l Eastern Utilities l Gerald C. Poulin Vice PresidenL Generation and Central Maine Power Company Technical Support James S. Robinson Manager. Nuclear Investments and New England Power Company Administration John W. Rowe l President and Chief Executive Omccr l New England Power Company F. Allen Wiley Managing DirectorofGeneration l Central Maine Power Company l

Russell D. Wright President and Chief Operating Omccr Commonwealth Electric Company LMeember 9,1996 (9:46am) Page 45

= .A ._a a __ a Jk _ &, . _ _ .% E ._. J.___a w.-_s E 4 4 .a-..u__JA _..a . .a .- _ _ a h _ ~.a 4 e 1

1 ENCLOSURE 3 1

i j CLOSEOUT PLAN FOR YANKEE ATOMIC ELECTRIC COMPANY

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, PURPOSE OF ENCLOSURE 3 '

2 Enclosure 3 documents the closcout plan for the technical and process observations related to ,

codes and analyses made by the ISA team, The attached plan identifies actions, responsible i individuals, and scheduled dates.

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_YNSD/NRC ISA CODES & ANALYSIS CLOSEQUT PLAN Date: December 6,1996 [

Rev. No.: 4 Page 1 of 2 ISSUE OR QUESTION PLANS COMMENTS /STA"IUS

1. YNSD does not have specific documentation of A. List SER conditions as part of Methods Overview A and B 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.

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

2. "Ihe 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 l C. Define standard benchmark data sets to be used to set I up and maintain methodologies through changes in the codes l

D. Perform standard benchmarking to baseline methodologies,if required I

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YNSIMNRC ISA CODES & ANALYSIS CLDSEOUT PLAN Date: December 6,1996 Rev. No.: 4 ,

Page 2 of 2 P

ISSUE OR QUESTION PLANS COMMEPfrS/ STATUS

3. 'The safety analysis process relies on individuals A. Create MOMS, describing methodologies for each A. Completmn 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 analysis process. B. Completmn by 12S166 1

C. Define the guidance (baseline) calculation for each C. . Completion before start of j transient - Cycle 16 i

D. Define 2-3 cycle review of A, B, C to ensure D. Completen before start of conformance with appropriate methodology Cycle 16 E. QA Technical Specialists to document the review E. Completen by 12B186 -

content and the results for inclusion into QA reports

~

4. "Ihe EDR threshold is too high for performance A. IAwer threshold via procedure WE-109 changes A. Procedure =r're. Training indication. personnel training, communications with plant, etc. by 12/3166.

5 Control ofinputs to safety analysis needs to be A. Finish SAID A. Phase Icompleted 900/95 strengthened Phase II by 400/97 PhaseIIIby 10/3187 PhaseIV by ISIS 7 Phase V by laIS8 B. Provide systems training to analysts B. Completion by 12S187

6. 'the ability of the CS system to provide a reliable A. Perform additional sensitivities to address break A. Completmn by 128166 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.

e ENCLOSURE 4 ACTIONS ASSOCIATED WITH ISA REQUESTS FOR INFORMATION

9 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 (MYTfS). Expected completion dates forlong-term actions are being tracked via the MYTTS. The RFI database is no longer maintained current to reflect schedule changes for the RFI action items.

~

NRC RFI's Requiring Follawup Actirns Sorted By Functional Area And Request Number Report 30 Functional Area: OPSITRNG Req # NRC ltem/ Request Responsible ST Date Due j MYTTS Person Short Term Action Date compg Long Teem Action Numbers 1049 RWP issues DALTON, J.

Brief NRC on Policy. 7_/23Ei None None Completed On: l 7/22/96 l 1050 SAO - Tech. Spec. Interpretation DALTON, J.

Provide written feedback See 7/16/96 None None RFI 4041 Completed On: l 8/7/96 l 1058 SAO - Discrepancies on E-1 Entry Conditions HATHAWAY, R. E-1 pages 1 and 2 have been 7/30/96 ES-02 will be updated during the bienniel review. None reference given to document controlto be reissued.

Completed On: l 8/9/96 l

~

1063 SAO - Discrepancy between FSAR and OP 1-E- DALTON, J. Discuss issue with NRC 7/24/96 Maine Yankee will truttate si cNnge to the FSAR to 30-39-112 Dilution Paths provide clarification to ensure consistency with respect to the dilution paths. ,

1064 SAO - Explain Difference in HPSI Flow Setpoints HATHAWAY, R. None Setpor Js are appropnate. None in FR-C.1 steps 2 & 15 1067 Questions concerning diesel generator. WR.LOUGHBY, P. Discuss issue wiwth NRC 7/23/96 None None Completed On: l 7/25/96 l 1072 SAO - Noted that EOP Setpoint Basis Documents SWTH, S. P. None All setpoints h data base updated by 12/31/96 30-39-113 refer to the Maine Yankee Training Manual 1073 SAO - Is one CET reading greater than 1200* F HATHAWAY, R. EOP Steering Committee 7/26/96 Have Training Department upd&ie lesson plans 30-39-114 sufficent to enter FR4.17 Meeting on location of CETs. with infonnation supplied by Operstms. Update to F-0.2 background document Completed On: l 7/23/96 l 1079 What are vibration set points of Reactor Coolant WILLOUGHBY, P. Provide copy of vibration limits to 7/18/96 None None Pumps? inspector Completed On: l 7/19/96 l 1080 SAO - HSI-M-50/51 valve indication. VOGEL. T. Evaluate indicators locally. 7/25/96 None None Completed On: l 7/25/96 l 10-Dec-96 i

NRC RFI's Requiring Fcliswup Acti:ns -

Seited By Functional Area And Request Number Report 30 Functional Area: OPSITRNG Req # NRC ltem/ Request Responsitne ST Date Due l MYTTS Person Short Term AN Date Compi Long Term Action Numbers 1105 SAO - Program to track thermal cycles of the RCS N QtOLS,S E. Provide copies of h 7/2496 Develop procedure to implement thermal cycle 30-39-115 documents to inspector. tracking. (PED)

Completed On: l 7/25/96 l 1107 Status of CEDM problems during plant shutdown. DALTON, J. Computer Section will prowde BNi/9Q WO 96-2625 through 96-2631 were created to 30-39-116 recommendations to operations invest % ate and resolve seven chattering SOES.

management regarding manual sequential operations Completed On: l 8/1/96 l 1118 SAO - REPLACES ORIGINAL REQUEST MOULTON, B. None Work order prevously iruttated for issue tracking 30-39-117 i NUMBER 2156. and r L u a CH-M-1 valve position indication. Evaluate local posihon indicahnn configuration change (gear ratio change) and/or redesign posthon indicabon method to interface directly with valve stem. Note: long term target dete-1998 refuehng 1119 REPLACES ORIGINAL REQUEST NUMBER MEtXELL, R. Work order scheduled, ready to 7/30/96 Based on inspection results of WO 96-1934, a 30-39-118 2155. work Work Order may be developed for permanent Boron buildup on casing of P-14A '

1124 SAO - T.S. 3.12 interpretation not properly NILES, J. Bring the Tech Spec 9/30/96 None 30-39-119 documented. Interpretabon back to PORC for 1 review at:d documentation in '

PORC minutes.

Completed On: l l 1125 SAO - Control Room Staffing DALTON, J. None Transfer Fire Bngade dubes from the SOS to 30-39-120 another individual as a supplemental action to improve staffing.

1128 Time line for PCC issue. WILLOUGHBY, P. Declare PCC inoperable, enter 7/21/96 Instar safety valves in contamment PCC piping remedial action to technical specifications, plant to cold shutdown.

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

NRC RFI's Requiring Fcilowup Acti:ns Seried By Functional Area And Request Number Report 30 FunctionalArea: OPSITRNG Req # NRC ltem/ Request Responsihie ST Date Due j MYTTS Person ShortTerm Action Date Compg Long Term Action Numbers 1132 Need assessment document for HPSI pump. SMITH. S. P. 1. Perform 3.17.6.6 evaluabon of EMM 1) Modh Op. Memo and Operahans Procedure b 30-39-121;30-39 P-148 when placed in service 11-6 to comply with the engineenng directtve. - 215 during the next scheduled ECCS Long Term Targt Date 12/31/96 Quarterfy Survedhence to ensure 2) Initiate a Performance Irnprovement continued operatnhty of P-148. Opportunity at the momsng meeting. t_ong Term Target Date 2/1/97

2. Initiate a Performance improvement Opportunity at the moming mting Completed On: l 8/16/96 l 1133 Status of shutdown items conceming MFRVs VOGEL T- 1). Complete WO 96-2560 to 96 W6/96 None None 2564 to venfy 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/R96 l 1134 Status of shutdown items Conceming P-28 MEiXELL R. None 1). Repal FW-F-8 posiboner WO 96-256. 30-39-122 2). Complete MRFA #96-223. 30-39-123 1155 Training on Definition of Steam Generator Overfill. HAYWARD R.M. None Operations training to evaluate and upgrade 30-39-124 Licensed operator course material to ensure inclusion 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. JR- None 1) Evaluate the following wording on page 9-50 of 30-39-126 1-15-3 regarding Service Water the FSAR and determine if it is appropriate: 30-39-127

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

2) Review other sections of the FSAR for similar wording and evaluate for appropriateness.

i 10-Dec-96

NRC RFI's Requiring Follswup Actions

~

Sorted By Functional Area And Request Number Report 30 Fur'ctional Area: OPSITRNG Req # NRC ltem/ Request Responsitne ST Date Due l MYTTS

• Person Short Term Action Date Compg 1.ong Term Action Numbers 1176 What evaluation was performed on HV-7 plywood? PORTELA, B. Complete HV-7 replacement SM Recerve new equipment Remove and replace 30-39-128 design documenhon Purchase existing HV-7. 30-39-129 New HV-7 eqtapment Completed On: l l 1177 RH-4 Leakage Problems PORTELA B. Replace RH-4 Brly96 None None Completed On: l 8/29,96 l

1178 During the shutdown on 7/20/96 (mid-shift), while SMTH, S. P. None Evaluate 1-13-1 with regards to Step 6.3.14. 30-39-130 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 "approximately equal."

exchanger inlet and outlet temperatures be approximate!y equal before preceeding The detta 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 MW y*W 9/1/96 Develop a PAP to review the Control Room Log 30-39-132 for significant events. develop a reminder for against Survedances, UOR's, Equipment management expectations to log Failures, etc., to check for consistency in Logging entries. sigrwficant evolutions.

Completed On: ] 8/30/96 l 1185 SAO - Procedural adherence. WHITE T- None Operations management review of simulator 30-39-133 feeenck information conceming throtthng feed flow to a ruptured steem generator during E-0.

1188 Timel; ness of identification of penetration seal ARNOLD, J. None Close out plan 96413 COP-96 013 problems.

10-Dec-96

i NRC RFI's Requiring Follswup Actisns

~

Sorted By Functional Area And Request Number Report 30 FunctionalArea: OPSITRNG Req # NRC item / Request Responsible ST Date Due MYTTS Person Short Term Acuon I ong Term Action Numbers Date Compt 1190 FSAR differs from plant configuration HEBERT, J.R. None Modify the sWement on page 94 to reflect 30-39-134 Operahons practice.

1208 Reed Switch Discrepancies not simulated. HAYWARD. R. M. Incorporate control room fidelity 12f31/96 Present more detaded guwjance on simulator / plant E9-135 '

check off sheet into procedure 18- mrk order fidelity to simulator review board. 30-39-136 344-1. Generated Simulator incorporate guidance into the Simulator Fkielity Work Order 96-124 to investigate Report.

reed switch problems expenenced in the plant.

Completed On: l l 1209 RC Trends HEATH.E. None Evaluate reduction of pnmary side contaminatxin 30-39-137 in reducir\;I personnel contaminations.

1210 SAO - Would like to see total number of percons. HEATH.E- None N""" =' u'* '& 30-39-138

~

• Review procedural guidance goveming the selechan of survey technsque and survey frequency of areas maintained as contamination free within the Restricted Area. TNs review must include the process by which surface contamination is prorded such as on walls, on equipment and other drnensions other than just the floor. Ensure this guidance generate data to alert Radiation Protection to potential contamination problems so that appropnate preventative action may be taken.

• Review controis goveming work in non-contamanated areas of the Restricted Area.

Ensure survey data as generated in the above recommendation can be reliably used to ensure that the radiologica! consequences of this type of work are determined and appropriate compensatory measures are taken.

• Continue improvernent initiatrve in the area of g-Ju,u indicator C.4.-,-4 and improvements in the self assessment activities by Radiabon Protection.

10-Dec-96

NRC RFI's Requiring Fellowup Actions Sorted By Functional Area And Request Number Report 30 FunctionalArea: OPSITRNG Req # NRC ltem/ Request Responsitde ST Date Due i MYTTS Person Short Term Ah Date Compi Long Term Action Nunteers 1219 Results of Review of NRC IN's 88-83,91-13,92- SOULE, E. D. None Maene Yankee to develop a corr 4xehenseve action 28-07-11 40,93-15 & 93-38. plan in response to NRC genene letter 96-01.

1227 SAO-Tech Spec 3.11 Interpretation wuouGHBY,P. Evaluate Reportat2ty 9/15/96 None 30 39-139 Completed On: l 9/17/96 l 1229 SAO - Watkdown of entical manual action steps. WROUGHBY, P. Evaluate instaRahon of 12/31/96 Instatsbon of motw operated vales in series wth B39-140 emergencylights in the MS-59, MS-59,79,99 area. -12/31/97 79,99 area - 12/31/96 Completed On: l 8/28/96 l 1238 Provide written follow up on Safeguard pump test WEAST, J. 1. Evaluate P-61S operat2ty 10M None 30-39-141 problems. with regards so its electricallogic 30-3M 42 setug 30-22-125

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

Cornpleted On: l l 1240 The quality of communications used by operators DALTON, J. None 1. Enhance and grade operator communicahons 30-39-216;30 during plant activities was good; however, the use dunng simulator sessions - Training. 217 of repeat-backs was inconsistent. In addition, 2. Dscuss Management a-+Ms on control room alarms were seldom announced to wth operatws during trumg the entire crew. The team observed similar sesh - Wwanagement weaknesses during simulator training sessions.

Number of Requests for OPS /TRNG: 39 10-Dec-96

I .

NRC RFI's Requiring Followup Acti ns

~

Ser1ed By Functional Area And Request Number Report 30 FunctionalArea: MAINTITEST Req # NRC ltem/ Request Responsitsee ST Date Due l MYTTS Person Short Term Action - Date Compg Long Term Action Numisers 2125 SAO - Assess condition of SW pump brg cooling HENRIES W. 1) Declared P-298 inoperable - 8/2/96 1) Sgruhcantly %y AMy the coohng 30-39-75;30 water from pump discharge. Complete system as part of the EDCR 95-31 efforL Date: 212

2) RW the W 1997 RFO - Long Term Target Date 10/1/97 raw water line support to return P. 2) CED to evaluate NNS seistruc supports. Long 29B to operable status. 7/20/96 is Term Target Date 6/30/97 target date. - Complete

3) Perform a formalanalysis of the SW cooling piping in its as-found condition to determine LER reporting requirements. Date:

8,tE2/96-Complete. Per Bill Hennes,this analysis was resolved via memo MYP 96-0496 -issued 8/5/96.

Completed On: l 8/15/96 l 2127 SAO - Provide history for temp. mod for mussel souLE. E. D. None Mam Yankee has made a commitment to INPO 30-39-76 control sampling to reduce long standing yeRow tags by Decerrber 1996.

2129 Pipe clamp missing by SA-136. DESROCHEs, M- Initiate work order to .; jar pipe Z!L8/2Q Schedule / Work the above WO 96-2501-00, once 30-39-77 Closed to WO 96-2501 clamp '""*d planned and appnnd. WO is READY WO 96-2501-00 initiated to to werW has not h m as of M.

address pipe clamps.

Completed On: l 8/15/96 l 2130 Has the base plate mat on P-14S been evaluated HENMES W. a) Grout degradahon evaluated 7/16!96 Repair degraded grout in ha ~c with priority 30-39-78 for deterioration? b) WO initiated 2496 WO scheduled for 9/16/96.

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

COMPLETED Cornpleted On: l 7/16/96 l 2138 Identify any temp. repairs (which still exist) which JOHNSCW,0. None Repair AS-P-99. WO 96-2571. Completed None are included in RFI 2060 7/23/96.

10-Ike-96 e

NRC RFI's Rcquiring Fcliswup Acti:ns Sor1cd By Functional Area And Request Number Report 30 Functional Area: MAINTITEST Req # NRC ltem/ Request Responsible ST Date Due l MYTTS Person Short Term Acuon Date Compi Long Term Action Numbers 2140 P-25C has oilleak on front end of pump and is JOHNSON, D. Initiate WO # to inspect inboard 6/16/96 Work to be scheduled  % 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 ongmated. As of 8/15/96 work order is in OWCC files, no scheduled work date.

Develop and schedule an approved work order to correct leak.

Work order priorty process will determine date.

Completed On: l 8/15/96 l 2146 Explain deficiency on BD-T-12,22. DEE,R. None WO's for BD-T-12/22 will be evaluated fcr work in None the next scheduled outage. Work orders 95-2143 and 95-2144 issued.

9/4: Completed 8/30/96 2152 Missing Clamp on RW-52 JOHNSON. D. Work order #96-2516 was 7/1W96 This work M be scheduled and completed per the 30-39-80 Closed to WO 96-2516 ongmated to replace the missing rumal schedulmg pmcess. 9/4; Scheduled for U-bot. 10/28,96.

Completed On: l 8/1596 l 2157 Explain discrepancy between indicating lights on WHITE T. Initiated Work Orders to correct 7/18/96 9/4: In pbng, not scheduled. WO is normal 30-39-81 DG-1A/B deficiency. DG-1 A - WO 96 ops Prt 6.

2510; DG-1B -WO 96-2511, Completed On: l 8/1596 l 2158 Question on screens for SW pump motors DEE,R. Electrical rnaintenance is 8/10/9Q None None evaluating the personal safety requirements for the screen and if appropriate will pursue removal 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 Review or Pmcedure 3.1.14A/B to ensure 30-39-82 adequate controls are in place over operation of the local sync-selector control switch.

10-Dec-96

NRC RFI's Requiring Fcliswup Acti:ns ~

Sorted By Functional Area And Reaguest Number Report 30 FunctionalArea: MAINTITEST Req # NRC item / Request Responsable ST Date Due l MYTTS Person Short Tenn Action Date Compi Long Term Action Numbers 2163 SAO - Long and short term plans for AOV. MORRtSON. S. None Masne Yankee is (,c.J4 s an Air Operated Vane 30-39'83 ,

Program. Plant Engineenng Department, ,

Mechanical Maintenance, instrumentabon &

Controls, and Corporate Engineenng Department we assess the following items for inclusion in a i

Cc.J y.ise of a deg summary document for targeted air operated vanes.

Select population of air operated vanes to be included in scope.

Develop an Air Operated Vane Propam description Evaluate predHrve versus preventrve maintenance program C;.J.,,y..s4 of an integrated Air Operated Vane Team, including- Coordinator, Mechanical Maintenance, instrumentauon & Controls, and r Engmeenng 2168 Valve packing leaks in HPSI valve room. MCALI.tSTER.S. None Clean up Boron buddup identified in Level 3 30-39-84 i maintenance book.

I 2175 IST Equipment in accelerated test frequency. SPRINGER, T. MOV-6013-WO96-2586 to 8/30 S 6 MOV-6013-WO 95-016931997 Refueling 30-39-85  !

Troubleshoot and Adjust limits. BD-T-146 change next Refuehng i Complete 8/6/96. Functionally j tested 8/9/96.

Completed On: l 8/9S6 l 1

2180 SAO -What caused the Rotor Seizure on P-25A in rwET, D. NONE Complete Root Cause determinahon. Per Dana 30-39-86

. Jan.967 Fluet, stm wortang the root cause determinahon as of 9/4/96.

2181 SAO - Steam generator blow down isolation PACKER,J. Conhnue to test BD-T-146 8/16SQ WO 96-2611 initiated to install new actuator on 30-39-87 valves (6) have had their test frequency changed monthly BD-T-146. (During Refuenng Outage 1997) from quarterly to monthly. ,

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

NRC RFI's Requiring Follswup Acti:ns -

Sorted By Functional Area And Request Number Repost 30 FunctionalArea: MAINTITEST R;q # NRC ltem/ Request Responsside ST Date Due ) MYTTS Person Short Term Action Date Compt t.ong Term Achon Numbers 2195 REPLACES ORIGINAL REQUEST NUMBER SCHUBERT,B. Provide response as desenbed 7/22/96 ' None None 3194. above. Per BB Schubert, further 15 sec auto start requirements and load time investigation ts required (8/1496).

sequencing info.

Comr wed on:l 7/22/96 l 2196 REPLACES ORIGINAL REQUEST NUMBER USCOMB, R. None inspect /relubncate gearbox during 1997 refueling 30-39-88 3265. W.O?s 96-2579-00 and 96-2580-00 have been SW-A-103 and SW-A-104 leaking oil from gear inmed box.

Close to WOs 96-2579 & 96-2580 2198 REPLACES ORIGINAL REQUEST NUMBER HENRIES.W. Complete WO 961532. p/12/96 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 Wes/ reinstall Rex. BM 9/4. Planned WO 96-2502 as Pnonty 7, 30-39-89 3209. WO 96-2502 was issued to Scheduled wek of E'23/96 Elec. insulation appears to be broken to valve SW- replace the nex conduit A-103 Closed to WO 96-2502 completed on: l 8/19/96 l 10-Dec-96

- . . ... - -. -. . =. .- . -

NRC RFI's Requiring FcIInwup Acti:ns Sorted By Functional Area And Request Number Report 30 FunctionalArea: MAINTITEST R:q # NRC ltem/ Request Responsible ST Date Due l MYTTS Persr.n Short Term Action Long Term Action Numbers Date CW 2219 SAO - EFW surveillance per 3-1-22 failed. on.rON. J. 1). Canbrate PI-1205A under 8/5/9Q None None WO 96-2601). Work order 96-2607 was VOIDED -done via level 3. Cahbrated satisfactority 7/25/96 - Complete 2). PED and Operations to determine best method for determrung reverse flow -

Terrporary Procedure Change (TPC) #96-257 issued by OPS ES/96. Tech Eva!142-96 being prepared by PED (8/17/96).

3). Incorporate procedure changes to perform reverse flow tests prior to startup -Temporary t Procedure Change (TPC) #96-257 issued by OPS 8/8/96. Tech Evar 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 30-39-145 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 HENRtES. W. 7/25/96 Mark new storage locatons. 30-39-211 Move W12's and Macm FW 3292. Component (complete)

Evaluate capabihty of LS-1602B and C to Mark We torage s withstand consequences of CW pipe failure and locations - C@e per Bill mussel sampling equipment failure. Henries (8/17/96).

Completed On: l 8/15/96 l 10-Dec-96

^

NRC RFI's Requiring Followup Actions Sorted By Fnactional Area And Reaguest Naseber Reyest 38 FunctionalArea: MAINTITEST Req # NRC ItemIRequest Responehte ST Date Due J ISYTTS person Steert Term Acnon Lc,sg Tenn Action Date W Nienigers 2236 The OEM's recommended NDE for the EFW pump MEtXELL. R- 7/30S6 Replace pumpYdemets unth new upgraded 30-39-90 1Hneste voork order to W P .

P-25A was not performed during the last minute 25A pump intemals -WO 96- internels pump overhaulin January 1996. 2683. Being revie' ed for 1997 Refusiing Outage

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

34816. PO 96-2384.

Completed On: l W15/96 l 2239 Provide justification for P-25 discharge pressure WHITE. T. 1. TPC #96.213 innisted to use 8690 NONE None guage, suctior pressure gauge-Compiele

2. PED and Operatens to determine best method for determining reverse flow-Complete

. 3. Incorporale procedure changes to perform reverse flow tests prior to startup - Complete Completed On: l W1W96 l 2240 Provide info on how EFW Test 3.1.22 was DEE.R. 1.) TPC 96-213 vues veritten to 8@96 NONE None dispositioned. allow use of suchon pressure gauges- Complete 2.) PED and Operations to determine best method for determining reverse flow-Complete 3.) Incorporate procedure changes to perform reverse flow tests prior to startup- Complete Completed On: l W1W96 l 2242 containment walkdown observations DEE.R. Work Order 96-2655-00 vermen 7/2996 None None to conect pacidng leek (RC-26 baron butd-up). Done W496 and functionsey tested W11/96 -

Compiece Completed On: l W11/96 l 2243 Flange botting on PCC piping to all 3 RCP's is NICHOLS. S. E. None Upgrade PCC piping in contenment 30 39 corroded.

10-Dec-96

NRC RFI's Requiring Follswup Actians Seried By Functional Area And Request Number Report 30 FunctionalArea: MAINTITEST Req # NRC ltem/ Request Responsible ST Date Due l MYTTS Person Short Term Acnon Date Compg Long Term Action Numbers 2244 Corroded bolts on PCC valves in containment NICHOUS, S. E+ None Upgrade PCC piping in contatnment 30-39-91 2246 SAO - Explain why the lock wire is missing on five MORRISON, S-W.Ofs 96-2671 thru 96-2675, &W Modify procedure 642-2, fmed incore Mector N39-92 (5) nuts on the in-core instrumentation sleeves on inclusive, have been generated to inserte, to include a specific rm;uirment to verify the seal table. reovide for loctrwire reinstamation. lockwire instanation.

Completed On: l 8/B/96 l 2269 Elaborate on responses to RFrs 2219,2239 and PELZER P. Test aH effected vatves prior to RM None None 2240. 210*F/400psig of current start-up - Complete.

i Completed On: l 8/19/96 l 2271 SAO - Missing lockwire on MOV-32 loop 3 stop MOULTON, B. None Complete review and procedural changes as valve and an apparently " skewed" valve stem on necessary to esnure cap screw pre load is valve RC-26. N 2280 1) Why aren't valves EFW-A-101, 201, 301, 338, PELZER P. None Complete COP-94415, item #14 COP-94415 +

339 and 340 identified as category"A"in the IST program?

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

2288 SAO - FSAR Sect. 8.3.2, page 8-11, states HEBERT, J.R. None Clarify FSAR to better describe integral and day 30-39-93 "together the integral and day tanks are capable of tanks operating capabeities.

a minimum of six hours operation at fullload".

10-Dec-96

~

NRC RFI's Requiring Followup Actions Sorted By Functional Area And Request Number Reped 30 Functional Area: MAINTITEST ,

Req # NRC ltem/ Request Responsitsee ST Date Due l MYTTS Person Short Tenn Achon Date Compg 1.ong Term Acnon Nwntsers 2289 As discussed during an 8/12 meeting regarding HEBERT, J R. None incorporate FSAR change for revised contamment 30-39-94 1 EDG loading, CS, etc. please provide the following: sPary delivery trnes in 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 temporary soULE, E. D. None Engmeg to reduce number of open 30-39-95 modification may stay installed and what are the Engineenng Temporary Mods by one half.

limitations?

2331 Provide info on P-29C bearing water support MEIXELL, 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 S/'51/9 6 None None  ;

match the isometric drawings. discrepancies.

(Note: DCR 96-155 issued 09/05,96) completed on: l 9/5/96 l 2342 Provide info on FM-91B discrepancies on pipe SOULE. E. D. None Revese 11550-FM-91B 30-39-97 sizing.

2354 EDG Testing Procedures DALTON, J. None 1.) Consider a procedure enhancement on 30-39 58 3.1.4A/B to specify where the diesel is phased at.

2.) Step 526 which verifies P-25 block removed should occur prior stopping the visicorder 10-Dec-96

NRC RFI's Requiring Fcilswup Acti:ns

~

Sorted By Functional Area And Request Number Report 30 FunctionalArea:

MAINTITEST Req # NRC item / Request Responsitde " ST Date Due l MYTTS Person Short Ten Acts" Date compi Leg Term Acum Numters 2364 MKW Memo, dated 6-9-92, from Don Galeazzi GRMT, R. None Evaluate DG deratuig assumptions as part of the 30 39LO9 provides guidelines for derating engine load output next revision to MYC-107 *Ernergency Diesel for air intake temperatures above 90*F and for Generator l_oadingf.

less than 190*F, JW outlet temperature with separate derating cutves for jacket water outlet temperatures above 190*F. Based upon air inlet temperatures of 110*F (MYP-94-0225) and DG-1B 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. caccEY,C- 1-Complete root cause evaluation 12/31/96 Reme procedure 3.17.5 & 3.1.18 before next use. 3M9-99 2- Complete calculations for 30-39 100 operatuleyWabMy 30-39-101 determination.

Completed On: l l 2380 Request that NRC watch a PT inspection of welds LECLERC S. Remove defect and re examne 8/3096 None None during the moming of 8/22/96 (Thursday) 9/4: Rework completed 8/26,96.

Completed on: l 8/2696 l 2382 During the Exit Meeting, Maine Yankee indicated MCCANN. J. None Submit FSAR Revision 13 3CL39-102 that many, if not all, the inaccuracies in the FSARITS 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.

10-ikc-96

NRC RFI's Requiring Fcilzwup Acti ns

~

Sorted By Functional Area And Request Number Report 30 FunctionalArea: MAlNTITEST Req # NRC item / Request Responsitde ST Date Due MYTTS Person Short Term Action Date Compt I ong Term Action Numbers 2384 Provide an update on maintenance performed on MASON, A.

Implement increased W B/27/96 Evaluate stroking these vatves after evohAmns 30-39-103 BD-T-12 from valve disassembly last week to frequency as outlined in attached such as plant start ups or changes in Blowdown restoration. Please identify root cause of memo ARM 96-013. Mes, since these dynarnic evokAons may condition, if known. dislodge debris from the steam generators.

(PED / OPS)

Completed on: l 8/27/96 l '

2386 Response to RFI 2288 implies that the volume of HEBERT, J.R. None Revise FSAR 30-39-104 fuel >4 in the day tank 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 BRAND Sutmt LER if required. 9/16/96 None 30-39-105 UOR 96-073 for BD-T-12 reviewed following review of the as-found condition (assumed "as found'* leakage beyond .ecordable range)? This appears reportable per 50.73 (a)(2) (ii) as a loss of containment isolation function.

Completed On: l 8/28/96 l 2395 NRC ISAT Report, dated 10/7/96, pg. 44, para. 4 RADASCH, R- None Evaluate downward trend in DG-1B condshonal 30-39-171 states the latest conditional probability trend for probability and idenbfy action being taken or DG-1B is downward due to increased planned and planned to improve availatility.

unplanned maintenance.

2396 NRC ISAT Report, dated 10/7/96, pg. 45,3.2.1.3, RADASCH,R. None identify action being taken or planned to address 30-39-172 para. 2 discusses failures in Containment sump problems with containment Sump discharge valve t isolation vattes caused by debris in sump. testing failures include status of proprosals for trench screens and sump / trench clear ing.

10-Dec-96

NRC RFI's Requiring Fallowup Acti=s Sorted By Functional Area And Regnest Number Report 36 FunctionalArea: MAINTITEST Req # NRC ltem/ Request Responsible ST Date Due MYTTS Person Short Term Action Date Compi 1.ong Term Action Numbers 2397 NRC ISAT Report, dated 10/7/96, pg. 47, para.1 RADASCH, R- None identify achon to be taken to address 30-39-173 of 3.2.2 and pg. 49, 3.2.4 (1) thru (11) states cuturairattitude itssues.

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 performance.

2398 NRC ISAT Report, dated 10/7/96, pg. 47,3.2.2, RADASCH, R. None Idenhfy action to be taken to address 30-39-174 para. 2 states some deficient conditions were not culturaitattRude 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 Provide status and schedule of LPRE efforts to 30-39-175 para 3, last sentence states Maine Yankee was in close this 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 equipment malfunction issue for any 30-39-176 para 1 discusses severalinstances of equipment suibstandard material condition trends. Idenhfy, malfunctions which occurred during recent plant as appucat*, any correctrve action planned or shutdown and startup attempts indicated a already Wed to address issue.

declining trend in material condition.

2401 NRC ISAT Report, dated 10/7/06, 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 fai!ure of prachces for maintenance activihes in generat is BD-T-12. Weld rod found in seat. there a FME problem or does this relate to an isolated case? Provide results of evaluehon and plans to enchance FME controis as warranted 10-Dec-96

j .

NRC RFI's Requiring Followup Actions '

Sorted By Functional Area And Request Number Report 30 FunctionalArea: MAINTITEST Req # NRC ltem/ Request Responsitde ST Date Due .

Person MYTTS Short Tenn h Date Compi 1.ong Term Action Numbers 2402 NRC ISAT Report, Dated 10m96, pg. 49,3 2.4 RADASCH,R. None implement correctrve achon as necessary to 30-39-180 states despite many inconsistencies between prevent future drscrepancies between test information contained in the FSAR and the as built procedures and FSAR/ design requrements.

condition of the plant, the licensee did not fecognize a need to review and reconcile test procedures with design requirements and to correct thase errors.

2403 NRC ISAT Report, dated 10/7/96, pg. 51 (4) states RADASCH,R. None idenhfy close out acten 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.  % Evaluate scope of AOVs included in IST program 30-39-106 states approximately 10% of the station AOVs that perform safety related functions. E xpland were included in the IST program. Many of the program as appropriate to include afety related valves not included in the IST program performed AOVs not rposentty covered For thos valves safety related functions such as the TCVs for PCC N perf nn safety mleted funch ns that wN and SCC systems (PCC-T-19,20 and SCC-T-23 & sT pmgnun m we jushfication for not including same.

24). Desp.ter 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 informaton 30-39-191 states the basis for some of the risk information into developing PRA stahshes. Modify the may not be as conservative as previously process as necessary to ensure all valid WO assumed because equipment failure data had not informahon (completed WO) is included been updated. There was a large backlog of WO I (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. None identify status and scope of WO efficiency 30-39-192 para.1 states some weaknesses were found in the improvement efforts. Include schedule for  ;

work control process, however, the licensee was w A, of plan. i assessing how to improve WO efficiency.

10-Dec-96

NRC RFI's Requiring Fcilzwup Actions Sorted By Functional Area And Reaguest Number Report 30 Functional Area: MAINTITEST Req # NRC ltern/ Request Responsitde ST Date Due Person MYTTS Short Term Action DWecompt t.ong Term Action Numbers 2407 NRC ISAT Report, dated 10/7/96, pg. 43, para 1 RADASCH,R. None Update IPE ac requred 30-39-195 states the AFW system (P-258) performed poorly for the time period analyzed and was worse that the performance values assumed in the IPE. The licensee was not fully aware of the poor condition of P-258 and had not updated the assumptions made in their IPE.

2408 NRC ISAT Report, dated 10/7/96, pg. 53 (11) RADAsCH,R. None implement a penodhc cahbraton or othenstse 30-39-190 states RWST transmitter enclosures heated above describe the process to be used in the future to transmitter design temperature. assure heated enclosures containing safety related instrumentation are maintained at a temperature that will not violate the quahfication of mistrumentation. Reference SAO-E-14.

2409 NRC ISAT Report, dated 10/7/96, pg.14, 2.2.1.2, RADASCH,R. None Perform now testing on HPSt pumps next RFO.

para. 5 states the licensee plans a future test of 3M9-194 conduct tests and record data so as to resolve the HPSI pumps in a technically rigorous manner questens regarding lack of margni, operating to fully demonstrated the available margin. pumps beyond vatws praded in vendor cwve, and pump cavitation concems as expressed 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 attitude related and suggests 30-39-197 states the team noted the lack of a " conservative our testing philosophy is non conservatrve testing philosophy" that resulted in the Provide a process and schedule to resolve this identification of numerous safety related isse, components that were not being periodically tested or calibrated.

2411 NRC ISAT Report, dated 10/7/96, pg. 65,4.2.2, RADASCH,R. None identdy plans to be developed or already in place 30 39-198 para. 3 discusses the continuing problem with P. to fuNy resolve this problem include schedule h 2B tripping on low lube oil pressure. implementatiort 10-Dec-96

NRC RFI's Requiring Fcilswup Acti::ns Sorted By Functional Area And Request Number Repcrt 30 Functional Area: MAINTITEST Req # NRC ltem/ Request Responsitne ST Date Due l MYTTS Person Short Term Action Date Compi 1.ong Term Action W ,

2412 NRC ISAT Report, dated 10/7/96, pg. 21, para. 3 RADASCH.R. None Prtvide for penodic PM and cahbration of valves, 30-39-196 under

• Flow Diversion" states that no calibration posthoners, and associated temperature procedures for CCW hear exchanger bypass controllers as required to assure reliable operaton.

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 irnplement a plan to greatly improve '50-39-199 1996, pg. 46,3.2.1.5, para 2, last sentence. the material condRion of the SW pump bay area.

Commitment noted in report The licensee Provide a hi,A., of work scope and a indicated that resources w ::Id be made available sem for compiedon of project.

to greatly improve the material condition of the SW pump.

2414 NRC ISAT Report, dated 10/7/96, pg. 39, para. DALTON, J. None inspect containment and remove any unconroNed 30-39-203 3.1.3.2. markings or informahon Number of Requests for MAINT/ TEST: 67 1

10-Dec-96

NRC RFI's Requiring Fcliswup Actions ~

Seried By Functional Aira And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC item / Request Responsible ST Date Due NYTTS Person Short Term Action Date Comps Long Term m m 3128 Stroke time for HSI-M-50 & 51 upon SlAS. SHELDON. P- Complete 7/17/96 None None Completed on: l 7/17/96 l 3133 Data indicates 2 Worthington & 2 Bingham SW SHELDON. P- Provide reference to correct P-29 7/16/96 None None Pumps du,,e curves.

Completed On: l 7/16/96 l 3136 SFP Cooling Questions JONES, H. None MYTTS # 20-22-71 AND 20-22-72 as 20-22-71 surnmartzed in attached rnemo HFJ-9603S 20-22-72 3144 AFW/EFW Pump Suction from PWST. SOULE, E. D. Procedure revision to incorporate proposed None 3009-30 changes 3153 Basis for location of FT 1201 A, B, C tranducer PAATHIEU. J. A COP wig be developed. BUf90 Perform grade 2 uncertainty calculation. 30-39-40 location. speedying need for a EFW flow test.

Completed On: l 8/7/96 l 3154 SAO - HPSI Time-line for SIAS SHELDON, P. Provide Info 7/22/96 None None Completed On: l 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 l-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. Determine if Maine Yankee wig 7/24/96 None None DC buses. continue to cross-tie oc buses at power. This win be answered under Req # 3352. TPC 96-228 Completed On: l 8/6,93 l

10-Dec-96

- - - - - - - - -- .-,-- - -- -.-- - - -- - u-_---_- - _--_-_-----_ - - - - - - _ _ - - - - - - - - - - - - - _ - - --__ -~-----:__------------_-------------_------- - - - - - - - - - - _ - _ - - - - - - -

NRC RFI's Requiring Fcilswup Acti:ns Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING t

Req # NRC ltem/ Request Responsitde ST Dato Due l MYTTS Person Short Term Action Date Compi Long Term Action Numtes 3167 SAO - E14 Justify use of nominal yard BARRY,B. Complete DBS96-042. Review 7/22/96 Complete TE412-96, Design Bases Recovery of 20-22-111 temperature in Setpoint Cales. setpoint program calculations for Heat Tracing System 01-13-20 (32,88,3293,3296,3350) simitar problems (Heat Traced Enclosures).

Completed On: l 8/20f96 l 3168 SAO - Questions from Review of MYC-104 BABIN ttem 1 Referred to MY Licensing 8f26/96 None None forDisposition Reference Request # 3214 Completed On: l 7/24/96 l 3173 FIT-6015 Design Requirements KULP.D. None 1. Recover Design Basis and installation 30-39-29 documents

2. Upgrade installation to meet MY standards, as reqtared 3174 Proprietary. Provide HPSI system instrumentation LOZANO,L Provide procedures for P-301, P. 7/26S6 None None data. 303, P-354K, L-307K, L-308K, A-1001Y Short term action complete with Rev.1 procedure sutxnsttal.

Completed On: l 7/26S6 l 3176 When do the EFW Room fans have to run? SMTH S. P- TPC 96-160-complete 7/16/96 Proc. No.1-12-3 to upgrade at next revision 30 39-45 interval.

Completed On: l 7/16/96 l 3182 Why is the heat tiacing system NNS? BOURGOllb8, D. None 1. Update FSAR Section 30 39-07

2. Update applicable drawings 3184 Proprietary - P-61 A,B S NPSH during injection SHELDON, P. Provide requested info. 7/17/96 Ne 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 Hm He 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 Foll:wup Acti:ns ~

Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request ResponssMe ST Date Due MYTTS Person Short Term Action Date Compg Long Tenn N Numbers 3201 Task summary / schedule for Fuse Program FREWN, W. None See FUSE Data Base- Action 06-19-15 References / Schedule. Project v pe;o ,7/26/97 3203 SAO - Answer HVAC questions on swgr. room Mccot4ATY None Finakzation of MYC-1570 30-39-08 ventilation design basis 3205 Describe MTE identification Control. CARD, J. Provide information 7,1996 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 Mp;uis. Bingham vs Worthington on p.10.

3225 SAO - E24 Cal. data for R.G.1.97 standby power KULP,D. Create MYTTSitemstoassign 7/26/96 - Calibrate Reg Guide 1.97 Standby Power 3M2-1133 instruments. (More data: 3395) Tag Numbers to all Reg Guide Imors 30 32-1134 1.97 Standby Power Instruments - Enter standby power instruments in MIPPS 30 32-1135 and to include these indicators in W Ma base the Electrical Preventrve - Update RG 1.97 source document Maintenance Program for cahbration.  ;

Completed On: l 7/26/96 l 3226 List RG 1.97 instruments marked "EQ'. KULP,D. Add EQ Label for PR-1012,- 9/9/96 None None 1022,-1032 RI-6113 A & B Light Box indication for Cl Valves Completed On: l 9/8/96 l i

10-Dec-96

NRC RFI's Requiring Followup Acti:ns Sorted By Functional Area And Request Nuniber Report 30

• FunctionalArea: ENGlNEERING i

Req # NRC ltem/ Request Responsible ST Date Due : MYTTS Person Short Tenn Action Date Compi  % Te Action Numbers 3228 SAO - Acceptability of Atmos. Steam Dump MCHOLS. S. E. The original short term action 8/12/96 Complete actions in COP 96-004 and MN-96-84. 30-39-46 System. was to provuse a presentaban to ,

NRC on results of upcommg I meetmg between Maine Yankee and Stone & Webster on ASDV modificahon.

Update: Stone & Webster  !

presented a draft Conceptual Project Authorization (CPA)to Maine Yankee on August 22, in response to Maine Yankee comments in a meeting on July

29. Stone & Webster is recommendmg that a "5%"

atmospheric steam dump valve  :

(instead of another"21/2%*

valve) be added in paratelto the existing dump valve . Also, Stone

& Webster recommends replacing the common 6" decay heat release header with 8" piping which wig increase the capacityof the existing atn-p;mii. steam dump valve.

This project is stillin the conceptual design phase and this information may change before final design is completed and approved Completed On: l 8/22/96 l 3239 SAO - E17 EQ instrument / Cable Submergance PAPKEN. R. Complete EQ submergece BM6 Evaluate impact to EO program and make COP-96-021. No walkdowns. necessary revisions andror plans for physical plant MYTTS Complete DBS96-044 changes Completed On: l 8/8/96 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 30-39-47 and schedule for -@ o exchanger W=oi crReria.

Completed On: l 7/26/96 l 10-Dec-96

NRC RFI's Requiring Followup Actions Sot 1ed By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req #

NRC ltem/ Request Responsitde ST Date Due MYTTS Person Short Term Action Date Compi 1.cng Tem Action Numbers 3258 Provide discussion for RWST temperature BERGERON, P. Provide requested information in 7/24/96 None None assumptions memo TAG-MY-96-069.

Completed On: l 7/31/96 l 3260 SWOPI closure mechanism for updating DBSD. MCCABE, L None Update service water DBSD to reflect screen 30-39 48 wash pump change.

3261 Provide basis for 20 min. flood time. SHONE, R- None Perform Service Water Calculation WE-103 30-39 49 3274 Evaluate combined effects of FN-32 Mat 1 MEtXELL, R. 1. Added missing latch to 7/22/96 1. Replacelatch. 30-39-50 -

condition. ,,Wmh maintenance 2. Repair #eplace FN-31 discharge boot,if diosask,y H.

2. Irdssted Work Order to 3. Temporary Modificahon to provide adequate evakute FN-31 discharge boot. ventilabon to protected switchgear room per Tech Eval.128-96. Work Order 96-2584 initiated.

Completed On: l 7/21/96 l 3275 SAO - Do FN-44A/B dampers fail open? JEN;4iNGS, K. Design Basis Screen 96-051 7/3096 To be driven by the DBS process 30 39-51 written to evaluate potentialloss 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. calculahon 3289 SAO - Provide commitment to resolve HV-7 issues. DROTTER,F.S. Complete HV-7 replacement S/30 % Receive new equipment and associated project 30-39-128 design documents Purchase new materials. Removal of existing HV-7 and 3M9-129 HV-7 equipment and associated associated materials, etc. Installahon of new HV materials reviews and approvals unit, new duct work, piping control vatves, etc.

of vendor summittals, develop Funchonal test (s) and acceptance. Mid to late field work packages for review September through October 1996. Final and approvals, WO's etc. Target acceptance 1915/96 date: Present through September 1996.

Completed On: l l 10-Dec-96

NRC RFI's Requiring Foll:wup Acti:ns Ser1ed By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERiNG Req # NRC ltem/ Request Responsihte ST Date Due i MYTTS Person Short Term Action Date Compg  % Term W Numiners 3290 SAO - P-25B reliability is low PEL7ER. P. None Cause determmation for 2 recent fadures of P-258 30-39-52 (Equipment Root Cause).

This has been prepared and is in Engineenng Management Review.

Maintenance Rule cause determinshon and (a)(2) to (a)(1) package for exceeding criterna.

This is scheduled for complebon 30 days after the Equipment Root Cause.

(a)(2) to (a)(1) GWL 4,v.

To be presented to Maintenance Rule Oversight Committee within 30 days of complehon of MR Cause determination and (s)(2) to (a)(1) Package 3293 Provide Operability Determination Information For JORDAN,T. To be med prior to start- 7fJC/96 None None LIA-303AK up via Proc. No. 3 6.2.1.41 Completed on: l 7/23/96 l 3298 is there a hard-piped spent fuel pool make-up mason. A. We evaluabon of DBS M None 20-22-99 049 and take appropriate action. 20-22-100 20-22-101 MYTT3 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 EQ7 HEBERT. J.R- None AOP-2-52 upgrade upon s/d rule issuance. 30-39-53 3312 GAO - Observations on MYC-1559 (electrical BONNER.J. None D*rmine accuracy of Westinghouse DWS 30-39-10 coordination). #267C172 Revise MYC-1559 and all other affected calculabons and docums.Ms if necessary.

3314 SAO - Calculated diesel generator step loading BONNER, J. None Revise and Reissue MYC-107 30-39-09 not in accordance with design basis.

10-Dec-96

NRC RFI's Requiring Fclinwup Acti ns

• Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request Responsitde ST Date Due J MYTTS Person Short Term AcMon Date CompI Long Term AcHon Numbers 3315 Cable damage curves not in MYC-1063 BONNER, J. None incorporate cable damage data into next revision 30-39-11 of MYC-1063 3323 SAO - Basis for operabihty of SW pump

• at low MCCABE. L None See request 3342 30-39-55 low tides.

3324 SAO - In Calculation MYC-107, what Was BERKLAND. D. None Revise MYC-107 to incorporate data sheet from 30-3909 assumed motor efficiency for P-12A and P-61 A. MYS@1.

3326 Outdoor instruments and weather protection BARRY,B. None Write Tech. Evaluacon for setpont on Fuel Oil 30-29-28 LevelInstrument 3334 SAO - Power for emergency fans used in loss of GRANT, R. Install an extension cord in the 6/7/96 Install permanent weldog outlets from MCC-7A 30-39-12 swgr room ventilation. Appendrx R cabinet. and MCN Completed On: l 8/9/96 l 3338 Provide information supporting memo WES JENNINGS. K. None ped should resouM me intake channel no later 30-39-54 009 than summer 1998 'his should be tracked via MYTTS.

- 3339 SAO - Provide evaluationtjustification for P-12A & BERKLAND.D None Complete revision of MYC-107 30-39G P25C D/G loading.

3342 SAO - Provide operability determination for tides <- MCCABE. L None Process appropnete FSAR change and 30-39-55 7ft. correspondog 10CFR50.59 evaluation for extreme low service water baylevels.

3352 REPLACES ORIGINAL REQUEST NUMBER GRANT R. Provide info response to NRC 7/17/96 DC Bus Operation Procedure Change 30-39-13 1048.

Time restrictions on operating with battery buses tied?

Completed On: l 7/17/96 l 10-Dec-96

NRC RFI's Requiring Fell wup Acti:ns Seried By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request Rew. - ST Date Due l MYTTS Person Short Te Action Date CW Long Te Action 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 W1XELL,R. None implement WO 96-1722 arul WO 96-1724 30-39-56 2124 HPSI valve WO status 3356 REPLACES ORIGINAL REQUEST NUMBER ERICKSON, D.

WO 96-2457 is being 7/15f96 Complete Work Order 96-2452 2139.

processed- make WO ready P-29B gland drain is plugged. when approved.

Completed On: l 7/2496 l 3360 SAO - REPLACES ORIGINAL REQUEST HEBERT, J.R. None Impleret safety em#ysis information document N7 HUMBER 1071. (SAID) and SAID cuntrol process.

Why is the IASD inenmplete? '

3366 SAO - E15 TS 2.1,3.9 & FSAR Bypass Condition HEBERT, J.R- Submit eW changes to the 9/1/96 Incorporate changes into Technical Specifications 30-39-41 Discrepancies FSAR and techrncal and FSAR by Cycle 16.

vi T- -1 = to clarify bypass condftions Completed On: l 8/22/96 l 3369 SAO - Reference Response # 3074, HSI-M-11 GRANT,R. 1. Review MOV Program data 7/30/96 1. Verify as 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 remon 2)30-39-14 Loading). issue a DCR to correct sg 2. Perform a root cause to determine how this deficiencies. This action is omsight occurred complete.

2. Examme MYC-1542, MYC-979, MYC-1615 to verify that the MOV HP sizes are accurate.

This action is complete Completed On: l 7/30/96 l 10-Dec-96 i

NRC RFI's Requiring Followup Acti:ns Sorted By Functional Area And Regnest Number Repoet 30 Functional Area: ENGlNEERING Req # NRC item / Request RG__ _

ST Date Due . MYTTS Person Slut Tevm Acnon Long Tenn Acnon Date Compi Numbers 3379 Identify Pipe E/C that could have affected safety SOULE, E. D.

None DBS96-006 Rev. 2 is traciang corrective achons 20-22-59 functions. ana 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 Maine Yankee we instdute a procedure change to 3439-13 on the DC bus cross-tie procedure change? allow the cross-tieing of DC buses only in condihons 5 or lower for maintenance actmbes (per Request #3352) 3390 REPLACES ORIG!NAL REQUEST NUMBER MElXELL, R-WO 96-2514 initiated 7/19/96 Evaluate need for PM to periodilcaey clean Drain 30-3 %58 2137. To be completed based on Conection system P-25A pan drain is plugged. priormy and system work completed on: l 7/19/96 l 329T REPLACES ORIGINAL REQUEST NUMBER MUNN, V.

WO 96-2500; Pnonty 8. 9/2096 Complete WO 96-2500 30-39-59 2141.

Temperature switch mounting.

Compieted on: l l 3392 SAO - REPLACES ORIGINAL REQUEST JOHNSON, D.

WO 96-2518-Clean briting 6/296 1. PM for annualinspechon of shcone 3439-60 NUMBER 2142. recess and sealwith silicone PMC Request 96-151 initiated.

SW pump base plate botting. WM be determined based on priority.

Completed on: l l 33921 SAO - REPLACES ORIGINAL REQUEST MEIXELL, R- WO 96-2518-Clean bolting 8/7/96 1. PM for annualinspechon of sRicone. 30-39-60 NUMBER 2142. recess and seel wnh smcone PMC Request 9G-151 initiated.

SW pump base plate botting. WiB be determined based on. [REV 1: 2. lenplement a suitable fix prior to startup priorty. frorn the 1997 Refuenng PMC 96-151 to be closed by 0892/96)

Completed on: l l 10-Dec-96

NRC RFI's Req: iring Fcil wup Actims Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC ltem/ Request Responsihte ST Date Due Person MYTTS Short Term Achon Date Comps 1.ong Term AcWon Numbers 3393 REPLACES ORIGINAL REQUEST NUMBER MEDEL1., R. 7/2W 2143. Initiate WO to clean conection N an approms work ader usmg the 3439-61 system for P-25A leak off knes. work order pnority process for scheduhng Excessive gtand leakage on P-25A WO 96-251400 ongmated to address housekeeping issue.

Completed On: l 7/24/96 l 3396 Provide basis for Auto-start time of P-2Al2B on GRANT, R.

1) Review post plant trip data for 8/9/96 incorporate results of short term actons into MYC- 30-39-15 low FW header pressure after P-2C trip. rnotar driven feed pump auto 430 " Auxiliary Power System Voltage Stud /*.

starts. This is complete.

Completed On: l 8/9/96 l 3399 SAO - Provida heat rise and time required for a MCCONATY None Finanze Calculaton MYC-1570 3439-08 loss of FN-31 or FN-32.

3413 Temporary Equipment chained to floor grating MEIKELL, R. None Secure items to structural steel. 30-39-213 which is not secured.

_ 3416

_ _ _ _Rg 1.97 pressurizer heater operation SoulE, E. D. None 1) Ensure computer point # 286 h included in the_ _30-39-26 Cahbration program

2) Change REG Guide 1.97 Data Sheet to be in

,-, a with attached memo to M. Marston from D. Bourgout 3429 Provide plans tri address containment PCC pipe tacHoLS, S. E. None Replace Carbon Steel PCCW Piping.

corosion. 30 39-62 3433 How was " Equivalent Total Fouling" Derived in BRADLEY.G- Revise memo MYP-96-0380, 8/30/96 None MYP-96-0380, Rev.17 30-39-38 Rev.1 (MYP-96-0466/LOCA-MY-96-031, Rev.1)

Completed On:l 9/6/96 l 3438 Provide an evaluation, or explain why one isn1 HENRfES, W. None incorposte this analysis into the RHR Hx design 30-39 37 required for the RHR Hx transients shown in RFI # documentation.

3305.

10-Dec-96

NRC RFI's Req iring Fcil;wcp Acti:ns

~

Sorted By Functional Area And Reaguest Number Report 30 Functional Area: ENGlNEERING Req # NRC item / Request ResponstMe ST Date Due j MYTTS Person Short Term Action Date Compi  % Term Acnon Numbers 3451 SAO - Follow up questions on the FE one line not GRANT, R. Complete. DCR 96-129 written. 8/2/96 None None 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 Calculabon MYC-1570, Rev.1 30-39-08 on swgr. room ventilation?

3478 SAO - E39 RWST Hi-Level Alarm Setpoint doe" LOZANO,L None COP 96-021 Containment Flood Evaluahon. COP-96 021 l

not match MYC-1173 value.

3485 SAO - Provide heat load references in Calc.1570 BOURGOIN, 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 recovery MYTTS 01 01-13-20 20 3494 SAO - Question on 115KV Voltage Study MYC-430 URBANOWSKI.S. None issue revised calculahon MYC-430 30-39-15 3518 Provide DBS & evaluation of FN.31 intet damper NICHOLS, S. E.

CEDIYNSD to determine the 12/1/96 Correct FSAR sechon 7.72 wordmg 30-39-63 failure mode. funcbon and required failure 30-39-64 mode for tNs damper. Damper should stay blocired open until this work is completed. Note:

TNs is a cold weather issue.

Yellow Tag Request #96-027 has a required clearance date of 10/1/96.

Completed On: l l 3520 Provide DBS on FN-44A/B inlet dampers NICHOLS, S. E. 1) FN44A & B inlet dampers 8/19/90 Evaiua'e malang FN-44A/B inlet blocking devices 30-39-65 blocked open per Yellow Tag 96- a permanent modifica* ion. (Evaluate cold weather

28. CPerabon).

2) Develop matrix to be used for ventilshon system Design Basis Documents.

Completed On: l 8/19/96 l 10-Dec-96

NRC RFI's Requiring Followup Acti::ns

~

Sorted By Functional Arca And Request Number Report 30 Functional Area: ENGlNEERING Req # NRC item / Request Responsitne ST Date Due ) MYTTS i Person Short Term Action Date Compg Long Term Action Numbers 3527 Containment piping thermal over pressurization SHELDON. P- None completed DocumerWation of Contaarent % 5 26 Penetration Review. MYP 96-584

[

3530 PCC Pump Degradation SPRW4GER, T. None Evaluate comtxning the fun flow test and IST test 30-39-35 for the SCC and PCC pumps mto 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 Foreate Long Term HVAC Inprovements 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 ISI-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 MEIXELL, 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 manual circuit.

i 3548 SAO - E40 Safeguards annunciator circuits are KULP,D. None The procedural review to be conducted to satrsfy 28-07-11 not tested by surveillance procedures Generic Letter 96-01 wW include recommendations to add verirmation of annunc ator window activation in the refuehng outage survemance procedures 10-Dec-96

NRC RFI's Requiring Followup Acti::ns ~

Sorted By Functional Area And Request Number Report 30 i FunctionalArea: ring lNEERING l-Req # NRC ltem/ Request ResponsiMe .

ST Deen Due - MYTTE Person Short Term Action Long Term Action Date Compi Numbers '

3554 Why were some of the plant MSKs superseded or RICHARDS None The "ConAgurshon Contrar issue remed ty this 30-39-68 I voided? request, is addressed ty the foNomng action.

1. AR of the " superseded" MSK-eeries dramngs should he revised to remove the " superseded" or

" voided" stamps and they should have the ,

fonowing note added.

"This MSK summertres the original Stone and Wh stress analysm reouts for the **iw+

piping system.. The latest analysis of record for this piping is identlRed in Attachment A2 of the

• Guidetne for Smeme Systems, Structures and Components"(MYMEG-G01)." l The intert of this change is tr , we those MSKs which stW reRect our current i+4vais of reconf*

to r= - _ _ j sta8us and to direct engineers to the proper location for verifying kut changes have not - _,: :this ongmeiinformamon.

3558 SAO - Provide Temporary Modification for FN- teCHOt.S. S. E. See ISA Request #3520 8/19/96 See ISA Request 3520 30-39-65 44A/B Inlet Dampers. I Completed On: l 8/19/96 l 3564 Explain MKS discrepancies and corrective actions HENRIES.W. Issue memo to Engineering dept. 8/31/96 Vertfy BZ and MKS drawings for supports whose 30-3948 personnel- MYP 96-0548 issued. function was moddled by lEB 79-14.

IdenhAed DCRs wel be issued-DCR 96-147 issued.

Completed On: j 8/26/96 l t

3565 Are manual loads considered in the diesel loading BERtRAND, D- Scm analyses performed 8/15/96 Revise MYC-107 to address Service Air 30-39-09 calculation? Compressors being load on Diesel Generator earh  ;

-r Completed On: l 8/15/96 lin the event.  !

4 3572 2 Questions on the lack of calibration procedures GRANT, R- None 1) Revloe OPS Procedure 3.1.14A and 3.1.14B to 1)30-39-17 for D/G load sequence timers 62-5 and 62-P25A. include time daley acceptance cr# erie. (12'31/96) 2)30-39-18 r

2) Evaluate adding a seperate routine calibrahon P.M. (06/30/97) ,

I t

10-Dec-96 i

_ _- - _-_ _ _____ - _ _ _- _ _ _ -_ - __ _ - _ ___ ____-___a

9 NRC RFI's Requiring Fcilowup Actions Sorted By Functional Area And Request Number Report 30 FunctionalArea: ENGlNEERING Req # NRC item / Request Responsible ST Date Due l MYTTS Person Short Term Action Long Term Actkm Date Compt Numbers 3574 Verify software control SHEt. DON, P. None Obtain vendor C of C and 9I.L3_5M 30-39-34 complete 50.59 determnation.

Completed On: l l 3575 Provide PCC Operability Determination GIFFORD. T. Complete technical evaluahon 9/15/96 Norm m 9-33 and evaluate reportabihty.

Completed On: l l 3581 Provide test instrument accuracy. GIGGEY, C. None Close out open item R8 of the SWOPI Matrix. 23-21-52 3582 Generic question on inadequate testing of critical GRANT, R. None 1.) See #3572 time delay relays. 1-4)30-39-19 2.) Develop Cahbration P.M. for 62-P4 for every 5)30-39-20 other refueling interval.

3.) Research Maine Yankee history, industry experience, and vendor % .w-stion for Agastat relay calibrabon interval. Set up every 4th refuel calibration / replacement interval unless a shorter interva!, dCwn to every other refuel mmimum, is determined to be more prudent.

4.) Research Maine Yankee history, industry experience, and OEM for DG 1 A/B time delay cabbration interval. Determirw appropriate interval, down to every other refuel rrdnimum, for these time delay relays.

S.) Revtse OPS. Proc. 3.1.15.2 to verify the trip block function of the 62-RAS timers.

3583 For 115KV System: 2 Questions on MYC-430 " soNNER, J. None Contact CMP to request add Donac stabilty study 1)30-39-15 Auxiliary Power System Voltage Study" for system loadmg at 1300MW and incorporate 2)30-39-21 into MYC-430.

Centact CMP and relay importance of Maine Yankee Capcitor and Suromec LTC Transformer Auto Boost; and need to inform Maine Yankee on either being out of service. 09/30/96 10-Dec-96

NRC RFI's Req &ing Folicwup Actisns Sorted By Functional Area And Request Number Report 3#

FunctionalArea: ENGlNEERING Req # NRC ltem/ Request Responsable ST Date Due ; MYTTS Person Short Term AcHon Date Compt t ong Term Acnon Numtet 3584 SAO - Provide HPSI throttle valve flow v5 position NICHOLS. S. E. Establish an action plan for 12f31/96 Carry out actions from above plan by end of 1997 30-3949 data. evaluation of HPSI throttle valve refW miage. W9-70 improvements inckxhng possible trim replacement, differes A tolerances on stem stops, and/or combination of these throtthng/ balancing options.

Compseted 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 reference to the 30 sec. time delay for 5.2.6.a from 30 seconds reference to 20 seconds P-25C start difference.

3590 Provide information on broken MOV keys. NICHOLS, S. E. Replace support keys or perform 8/2696 Perform root cause on overallissue and carry out 30-39-71 DBS on issue. a W .m-n.umu h Completed On: l 8/28/96 l ,

3595 Provide containment electrical penetration BONNER, J. None Perform a formal study documenting the electrical 30-39-23 electrical coordination. penetrahon short circuit protection.

3609 Provide GL-89-13 Commitments. SOULE. E. D. None 1- Evaluate the influence of instrument 30-39-72 uncertainties.

2- Re-evaluate the acceptance criteria er fouling factors that are currently used.

3- Evaluate and/or incorporate a worst case CCW-HX test.

4- Re-evaluate monitoring methods and frequencies to assure comphance with GL 13/ ENC-2 guidehnes 5 -idenbry and schedule necessary c tiges to our GL-8913 programs and procedures 6- Determine and document the need to provide an update to our current GL-89-13 response 10-Ike 96

NRC RFI's Requiring Fcilowup Actions Sorted By Functional Area And Request Number Repott 30 FunctionalArea: ENGINEERING Req # NRC ltem/ Request Responsible ST Date Due Person MYTTS Short Tenn h Date C-.g Long Tem Action Numbers 3610 6 Questions on FN-20A/208 D/G Room Exhaust GRANT R- None a. Review thermal overload protectron for ad Fans. a) 30-39-24 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 cahbration interval.

3616 Provide additional info. on CS Pump NPSH. SHELDON P. None Evaluate methods to increase Cu ta-.m.; 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. RWe MYTTS 10-13-09 for 10/15/99 None 10-1M)9 HV-7 Steam implemented? ncorporation of the i-....h into EDCR 96-33, HV-7 Modifications.

Completed On: l l 3631 SAO: E19 Miscellaneous Drawing and Calculation LOZANO. L Initiate DCRs 0/22/96 Revise RWST level cale after heat trace eva! 01-13-20 Discrepancies. CW'-

Completed On: l 8/30/96 l 3642 SAO: E50 EFW Flow Transmitters LOZANO.L None Perform detailed radiaton exposure calculation. 30 39-27 3643 Provide clarification on E/C responses and SCHUBERT. B. None Upgrade EC software program with 30-39-73 checkmate application concems. CHECKWORKS 3651 Provide info on control of calculations of record. MCCABE. L Resolve requirement to submit 9/20/96 None 30-39-74 rest of cales submitted earing ISAT (item 3).

Completed On: l l Number of Requests for ENGINEERING: 108 10-Ikc-96

_ - - ... . . . .. - _ - . . . . - - . . . _ - ~ .. . ..

NRC RFI's Requiring Follswup Actions '

Sorted By Functional Area And Request Number Report 30 FunctionalArea: MGT & ORG Req # NRC item / Request Responsable ST Date Due ;

Person MYTTS Short Tetm Ah ' Date Compt I ong Tenn m h 4041 SAO - M80 - 003 PORC has made non DALTON, J.

Termmate T. S. Interpretation 6/6/9G 1.) Perfonn a revkw of existing T. S. 30-39-106 conseWa6 3 decisions 5.5.B.9 and provide follow-up IMW agamst Wing specircations, N 107 review for ER. Oth'T 4 #- r '., and the FSAR. Resp. Ops 30-39-108

2. Provute 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 aganst industry standards for this type of procedure to ensure consistent approach to this type of clarification (i.e., use of 10CFR50.59).

4.) Ucensing should evaluate the number of outstandng interpretations and initiate the Tech Spec Change process where warranted.

4046 SAO - Proprietary - M & O -001 Integrated ARNOLD, J. None Develop enhanced Business Plan. 30-39-109 business plan 4102 PRCE # 182 - Corrective Action Status natixttL. R. Select vendor to provide expertise 11/1/96 Upgrade Crane Maintenance Program. 30-39-110 I for upgrading the crane N 111 maintenance program.

Completed On: l l 4114 Background information EDCR 94-54. KULP,D. 9/15/96 None Determine Reportability None Completed On: l 9/17/96 l Number of Requests for MGT & ORG: 4 10-Dec-96

ENCLOSURE 5  !

1 4

ACTIONS ASSOCIATED WITH l ISA REPORT STATEMENTS 1

l l

l 1

1 l

PURPOSE OF ENCLOSURE 5 Enclosure 5 provides a punap that interconnects statements, issues, concems, and acknowledged follow-up actions from the 1SA report with tracking or closure documentation. As applicable, it cross-references the ISA report section, ISA request for information (RFI) number, ISA safety assessment observation (SAO) number, Maine Yankee Task Tracking System (MYTTS) number, and the Business Plan initiative number.

The ISA report made repeated references to various deficiencies noted during the ISA. An entry was not necessarily made in the Enclosure 5 table to track each instance that a specific deficiency was cited in the ISA report. However, sufficient information is provided to allow confirmation that each deficiency is being tracked.

l i

e

4 ACTIONS ASSOCIATED WITH ISA REPORT STATEMENTS , l Business l seiens seassam.ma art sAO MYTTs Flam Cases-se Design and IJzeeming Basis -Yrammimme and Aseedsat saprey Analyses 2.1.2 YAEC dal not have a wresem process to document how safety analyses cesfonned to SER h 3360 C-13 3039157 F-2-3 f

p. 8 3039158 3039163 [

I 2.1.4 A *=yh h were found, the mass steam line ruptwe analysis was foemal to be - dueto w On the basis of MYP 0638  ;

p.10.Il seasservity sendias perforuned by YAEC and % conserv===== in the MSLR desenbad below, the ISA team concluded Gud these h had been .;-, addF===d [ Maine Yankee actions are desmbed in mano MYP 96-0638]

2.1.5 YAEC dul not have a documeented process in place to idesudy and rank key phenomens for each of the tr=====** and

• in the safety analyses C-7 3039159 F-2-8 [

p.13 report and in turs id-edy needed code v= Lim = and parameanc study efferts.-. During the ISA, YAEC insnamed the writing of a W Overview C-9 iluu  ;

Mesmal* whicle was ie= dad to adeess these ie=== C-17 3039163 Camass ==== es Bestem and IJenasens Basis - Dosism Baview of salueemd Syseeims  :

I 2.2.1.2 the I-*===* plans a imure test of the HPSI pumps in a aara=c=ny ngorous misme: to Ibily W ihe available margut 2409 E-25 3039194 B-34

• p.14 E-48 i 2.2.1.3 11me pimamed IPSI now tessing to venty pump h at high Gow wiB sino amable the h to reset the pa=== af these [1953 Sow commel 3354 303956 B-34  !

p.15 tirosse] valves unas a amme precise tolernace to ensure that required Saw is met and runois ==hhnas are got swe= del llge ligggggg plggg 33M j$34 3Q3%9 [

~

the r==esma of these valves to a amore psecise tolerance as part of that Gow a mains. 303970 f

2.2.1.4 The abehty of the CS syseem to provide a rehable supply of weser eums the smarcuB*= phase of a LOCA was not adequesely danaamsteel for 3616 C-18 303932 A-3-3 '

p.15 opernham at power levels abase 2440 MWt due to CS pump cantanomal comraras. E-27 ,

P E-51 2.2. l .4 (2) As a result of the ISA team's comoere, the I- perforused an evaluaman that confinmed an increase of[CS puump] =weinn pipe ticosom leases 3626 E-27 303931 A-3-3 p.17 tam 4.5 feet to. ',5.3 feet E-51 f

2.2.1.4 _.Following the =========r the incensee cwa-*=d addssomai [CS pump] analyms to apport plant operanos at up to 2440 MWt. Enct 3, A-3-3 j p.17 Issue 6  ;

2.2.2.6 The ISA teasm was unable to W sad the lionmae dal not W that these [PCCW/SCCW] heat resmoval systems would perforan =d-p.may A-3-4 p.20 ieder desip-basis =~-i-a a=ia== ongasmag froma a power level of 2700 Mwt i  ;

t

{

~

[

i

_ _ _ . _ _ . _ . _ _ _ _ _ _ _ . _ _ _ . _ . _ . _ _ _ = . _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . . _ _ _ _ _ _ _ _ _ . _ _ . . _ _ . _ _ _ _ _ _ . . _ - . _ _ _ _ _ __ -_m_______

1 l

4 Bushness Seeeeen Stassumet RFI SAO MYTF5 Flam 2.2.2.6 _.am empamenme erecesse had beam provided u ensure the SW syssum would be operskd wedum certain lumies. Ibuever, the apersang Imanaamams 3404 Cr pt a-

p. 20 provided in the empseurung duecove were not bounded by the licemang Om the bans of the licamese's analyas, the CCW syneens would mot support plans opersteam up to the SW tesaparamme vahnes in the FSAR. [Comeplese: TE 121-%; h5U 96172]

2.2.2.6 Fouling factors used for the CCW and RHR heat exchangers were mot appropnseely conservenive pven the lack of rehable tesang &me to counrm the 3609 E-28 303972 B-3-5 p.20 asammed veinesu. The ISA seen had the follounne specinc concerns web the hcensee's heat ewina-ger testing proyuma.

(a) Immanumessimmeertsemiy was noth for in L- .the fouling values.

(b) Thew =u==' laraan== for the flour snessunne devices were less than ag*-- to assure accaracy, and nine Sour smessenmg devices were mot calibrasedfortheirspecinc ,, _ or adysseed for the aceumi pipe well sharWa=

(c) Heatr Nagartubeswerecisamedom apenoshebeas;however,there wasme. , ^ to do perfor===r* testing just before the heat exchagrr,a==.i g thus the - fouhms value was not beses ma===ut (d) The 6 of auface amaumend thennoccupies mude the smeasured tesaperatures == =gane to posennal ser===y 2.2.2.6 The ISA mra --, " the bens for the 10 henuk value [in MYC-1742. Rl]. since in the case of the PCCW syneum, die heat land included the 3529 3039209 p.21 spent Assi pool (SFP) best exchanger, which had a denga load of 9 Mbemer (prior to re-rackmag), and each esmergency diesel heat - . ,which had 3039214 a load esamissed at 5 henuk 2.2.26 la 1995 the tir==== decoveed that the CCW heat - * . - bypass valve, PCC-T-20,was open about 11* following an ====ge to align it to ins safesy 3575 303933

p. 21 suissed pa= man rL=ad At the samme, Maine Ysakee was in an ousage med an imunahnee operabshey determuassaan was not resymred; however, the

.-,~. ' - deessammaemon had mot yet been conspleesd at the imme of the ISA.

2.2.2.6 na ISA tassa Assad no cabbraman promahmes for these [CCW HX bypassi valves, the comerouars were mot of the " fad safe" deman, no c _ were 2404 3039106 B-3-IO p.21 faumd ens teseed absiity of these valves to paions shar safety relseed thW and the - hisecry of these valves M=iA=d 11 e==gea-d 2412 30391 %

work orders (WOs) for these valves in the last Eve years. the hcamsse parfanned a test om the PCCW teesperamme commel valve sAer the team left the sise. His test was reported as -- ~ , demeaantammg the opersman of this valve.

Comsse===== tm Design and IJeensha Basis - Eiseertral and lastromsset and Centrais 2.3.2 As a resuk ofrecemely updseed CMP vohage samties, the hcensee was in the process of revisag the elecencal syneum emelyses in calculeman MYC-430, 33 % E-23 ?O3915 A-3-10 p.23 R.3. 3494 2.3.2 Maine Yankee would again manfy CMP to bnns the Mesme Yankee capacuar bank mut Surowiec Tromsfonmer Aimo Boost isso service at yid noedag 3583 E-23 303921 A-3-10 p.23 yeeser sham I,300 MW.

2.3.2 Che' would be asked to perians a sysessa smalyms based om a yid L=a=, of I 300 MW and the resubs would be used to verify an- P syssam 3583 E-23 303915 A-3-10 p.24 voltage to reset the deyeded and-i ' . relay. 303921 2.3.2 He Adi syssam base case would be hi Buen calculanam MYC-430 and replaced widt a new case which is based on the pad at a 1.300 MW last 3583 E-23 303915 A-3-10 p.24 2

m.-__._.. . - . . _ _ _ _ _ _ _ _. _ _ .. . _ _ .. . _ _ __ .

Basimmes Seeseen h RFI SAO MYTIS Flam 2.3.2 1he celeraman talurance band of the deyeded pul 4. ' . relay would be r=h==d 3494 E-23 303915 A-3-10 p.24 2.3.5 The ISA team moned the following problemas wah the evaluaman ofEDG lasses in calcal=*== MYC-107: 3278 E4 303909 p.24 (l) Cable powerlosses in the 4-kV and 480 Volt ac synesses were not incorporased imeo the e @

2.3.5 (2) The loading profile was W wah FSAR and demy requr==== 3314 E-8 303909 ,

p.25 2.35 (3) There was a lect ofdocumer =s==

e in the cak:idar== to support moeur loads. 3324 E-8 303909 ,

p.25 2.3.5 (4) Pumpmoeurlamenswas= Mwe. LPSI pump la=diae in calcuismen MYC-107 was identified as 336 kW; howewr, the losAng value at 3339 E-8 303909 p.25 numand would be 364 kW. The EFW pusep naaans was also based om a monumet value of 378 kW rusher them as the rumout value of 443 kW. ,

2.35 (5) Commel er arapressor manuel snart, requeed by prneah== ECA-0.2 was not inccupermoed imeo the calculanomu 3565 E-8 303909  ;

p.25 2.3.5 (6) MOV- was eath for in the EDO landmas calculeman in thet opermears and moeurs for 14 MOVs were replaced ieder the 3369 E-8 303909 p 25 MOV Uppade Prayama, but the mentar horsspawer changes were mot included in the elecincel one-hme drawags and tracked E-3I 303914 ,

2.3.5 la r=g-=== to the ISA teaum's concerns in this area, the h preparedr a ' , revissam to casculeman MYC-107 which showed diet the loading E-8 303909 p.25 cm EDO-IB (worst-case) increased hose 2,629 kW to 2.842 kW (a 213 kW immemme), stdl below the 2,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> / year rumme lismit of 2.850 kW.

2.36 (I) becorrect masor deem were used for seques the HPSI pump maior prosecave relays a rah =Ima== MYC-1559,in that the incomctl ar+=8 rosor 3312 E-16 303910  !

p.25 curent was used 3384 2.3.6 (2) Incorrect cable dass were used in the coh cuve for the EFW pump P-25C motor in e=Ir=Im MYC-1559. 3312 E-16 303910 l p.26 3384  ;

2.36 (3) Cable dass and cable desmage cimies were asumed tase e=h=h MYC-1063, R5, winere curves dal not idemmfy the feeder cable mer and dut mot 3315 E-16 303911

p. 26 incorparuse the cable dammage plot om the coord==e== couve to W that the eside was puh ===*=s wish inessay pracace. I 2.3.7.1 Der-- were moeed in the desip ofilme prosseted swischgear recen v=mim syssEmL The IIcEngse was aware a( and actively CarrWCamg, samme of COP 96l4 A-3-5 p.26 these dew As a result of the ISA team's uupunes aM*==al vulnersbehmes were idesafied. The met edFect of these recemly idamned probicans  ;

couldbesamedicant.pomably J ; hose I percent en up to 10 percent =M*===8 probabehry of care damage. E i

r 1

-m

_ _ . _ _ _ _ .__ m_-___mm.. ___.m _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ __ _ _ - . . . - - - - - , - - - v v- ,--

r Bustamos Seceton h RFt 5AO MYTTS Fine 2.3.7.1 The ISA enom found that the hcsasse had no e='a.s.a= or smalyses which evalusand the y of a [ processed swndgear rouse) mapply or 3203 303908 A-3-5 p.27 exhaust fem fadure coecuhat wah e LOCA or HEl.B imeder wona-case electncal laadug 3399 A-3-9 3468 3485 23.7.1 _the ISA team found that the [MYC-1570, It0] h dal not address venous [psosected sanschgear room) fan failurea 3203 303908 A-3-5 p.27 . 3399 3468 2.3.7.1 (5) A long-tena, perinament h was ineended to humall receptacles in the protected swachgear room wiuch would be powered toen EDG- 3334 E-6 303912 A-3-5 p.28 backed esmergency buses MCC-7A and MCC-SA.

23.7.1 (6) He cwremt HELB evaluation covered summmer coadnsons only; the licensee nas Immulating plans to resolve this issue scr winest e==iaa== 3539 202259 A-3-9

p. 28 303916(c)

COP 9614 23.7.2 The h. . was a the process of . a design change to recon 6gwe the HV-7 si9 ply unit to solve the exisung design problema 1176 E-10 3039128 p.28 3289 3039129 2.3.7.2 He ISA team found no evidence est this issue [VP-A-56 A VP-A-57 probleen found 2/20/91] had been essered imes a correcuve action sysseen or was 3520 101309 E-3-4 p 29 being traded by the licensee. His was sa example of the tir====*'s falure to take rypsopnsee acnon to address a plass praW- [see Enct 7, 3039175 CNI 23.7.2 the ISA sessa ca==dared the licumsse's ' week in regard to the lack of $4awup of the idenadle*= of the desaper concerns tasu 1991 and 3269 - E-10 303951 p.29 also week in that the recent focus on the psoblemas wah this vensdation sysse s did not rendt in idemmP f ing a --L * ", wish d=-r s VP-A-56 and 3275 VP-A 2.3.8 The licensee sensed shot this procedere [I-22-2] was imeended to be used only in limsiend corh wilia due ea==d seson given to overat plant nak- 3352 E-4 303913 p.29 However, as a result of A- wndi ths ISA team, Procedue 1-22-2 would be revised to limmt csous-nesag of de buses toch 5 or lower (i.e., 3385 plant mot at power)for actmeses.

23.9 he ISA team also moeed that there was no aragned staKengineer witit ynmary . , ' ' ,inibis (EQ) arest B-3-8 p.30 23.9.1 As a result of the ISA esasn's inquay, the lar==== idaarmi 30 P below the * - levet Several of these a=r-ains, such as HCV- 3239 E-17 COP 9621 B-3-8 p.30 257, HCV-271, and TV-3501, were the sesme - that were idenedied as below the subenergence level in the licensee's 1980 subasaal and the NRC's SER-2.3.9.2 He licensee stated thes evalusuca of & issue [EQ of FIT-1201A,B.C] was under way as part of a revisena to DBS 96-41. His revison would add am 3153 E-50 B-3-4

p. 31 action itsen to provule a desaned review of the radiatian dose et the inserimment l ac. siam [See Enct 7. Clasdr*==1 3642 4

- . - . _ -_- .- _ - . . . - . - . . . - - _ _ - -a.-.w_. z-. - _ . - _ _ _ _ _ - - - _ _ _ _ _ . _ _ - _ - _ _ - - . _ _ _ _ _ - - __._____u-a__ _ w--,-- _ , -w--- w .- m

- . -- ~ . . . - . - . - . .- ------~. - . - - - - . - - . . - . - - . - . _ . . - . - - . - - . .~ ~~

t i .

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4 L

amminam i so time h - RFI SAO MYris plan i 2.39.2 la addman, the hennese's RO l.97 subaustal and Repsleemy Gumle Sou:w h===8 "Denga and C " Cnemia for Post Amd-a Mausorms 3225 30321133 B-3-8  ;

p 31 husm===ama=,* idamned these ;- " e as bang apprepnamely EQ q==Wi=id wiib mo devismans frosa NRC W 30301134 30321135

• 2.392 he lu:emsee dul not adequesely casesonze and idemnfy the excepexas taker on the RO l.97 daea sheets 3416 030942 B-3-8

p. 31 303946  !

e 2.3.9.3 De hcensee had recemely idemained am yM IES concern in the earbme bolding that had the &=1 to imped satsey relmeed P in the 3414 202259 A-3-9

p. 31 turbine behhag. 3539 303916(c)

COP 9614 ,

i Camfaremmee to Danism and 8 % Basia - F5AR W 2.4 Pner to the ISA tessa amval om see, the licensee muussed a FSAR and Tectuucal M=am review to inmh8y with the licersmus basis. 3039102 F-2-1 i 4

p. 31 He licensee placed pnonty om reviewmg those syneans being reviewed by abe ISA teamt Over 100 isuses westid-anas The ISA teams hM

-na a-=1 L , ' wiuch are discumand throughout the suport. Many of these inness wiu require changes to the FSAR sad 10 CFR 50.59 reviews [

since equipesar and procedures at MYAPS have changed han that desenbed in the FSAR.

2.4.1 ne nameplane ramme on the spent Ibel pool (SFP) hast enchanger was not - wish the design values in the FSAIL De lia==== claumed a 3136 E-9' 202271 [

p. 31 ==-==Me , ' that ibis HX could be used to restore norsmal coohng following buk tunhas and was trackmg an action isen to analyze by 202272 Jammary I.1997, the capability of this HX to go to 225F.

4 2.4.2 ha e lesser daned July 1,1996, to the Mtc, the lacemane h to maske phyam.at changes to the ' - - sneen enmip synesma to ilupenve reiseving 3228 E-12 303946 A-3-8  !

p. 32 capacesy ami reduce the isolation tune of the affaceed 50.

a ====-===8 af 4 - "Saseey-Operasisesa ========a ,

i 3.1.1 he team found that Operanome en effective in idemnfpas probieras, but moeed weaknesses web pinbless reschman 3039175 E-3-4 I p.33 3.1.1.I of* P I'at sinadown on July 19 and 20,1996, the team observed that ibe operannrs expenemend several ap=p==8 prh 2411 3039198 Dunne ther- "

p.33 which " the shundown. Dese psoblemas involved the any of a munorwhiven main feedwener (h0FW) pusup following am steampeed snart ,

die slow venpomme of the snaim feedweest pusep recm% valve when the pimap was snarted I134 3039123 f

3039202 i

leakage past a smain feedwater regulamag valve bypass valve which requred =Mha==l opwasor setemnem ami h Complete [

t and the snabahey to operate the comeret element assanbleen (CEAs) in the ====l ==Ta=*==8 meade due to a plant computer whicle was eendy I107 3039116 B-2-3 i over anad,id y s

[

i 1

1

_ _ - , _ . .- .. . . . - _ . . . . _ -- . ~_ . . . _ ~ . ..

-l Bashnese Soesten St=aa-ant RFI SAO MYrI3 Plan 3.1.1.1 Compensatory actions were taken as a result ofdeman vulnerabi',itaes assmanad with ventdaten sysems for the safety-relased banery rooms, snik:hgear 3520 E-6 303 % 5 A-3-5 p.34 rooms, emergency diesel generator (EDG) rooms, and the - spray Innkhns. E-10 COP 9614 B-2-4 COP 9617

.tubineInukhng Goodmg concerns. COP 9607 A-3-9 the inalnhty to remosely isolate a ruptured mean generasor. , COP 9604 A-3-8 a sogle, understred, sneem generasor w sneem dump (ASD) valve 3228 E 12 303946 A-3-8 COP 9604

.and a degraded offste power supply. A-3-10 3.11.2 The team was cmcerned that the licensee had established confhetmg procedural ..,,_- s that would be unpasable to compff with in the event of I125 Complete p.34 fire concalent with a medical emersency. Dunns this postulated event, the - ====

• ding i.,- e required in the Terl=ic. , e._2 - = RFI1125 would not be satisfied if the senior reactor operators responded as descnbed in the licensee's administrative pr-h-es.

3.1.1.2 The team found that Maine Yankee has previously developed a m., J-.ve action plan to address the stuA staffing issues ubich includat (1) using 4044 0 16 3039120 p.34 securny personnel rather than the PSS as mancal first respeder,(2) unng a second CRO as the fire brigade leader rather than the SOS, (3) providUng an adational secunty guard for the fire bngade to replace an mouhary operator (4) enhancmg the esse prosesason process, and (5) enhancing STA edectivenesst However, the seen determined that Mame Yankee's schedule for 1, ' g these corrective actions by the end of1996 was not tunely.

31.1.2 The team also deternuned that the licensee =imed an opportumty to idenufy and correct this vulnerainhty during its review of!N 91-77,"Sluft Staffing 1147 Complete p.34 at Nuclear Power Plants

• which ^-i Mame Yankee's response to a fire. RFIII47 3.1.1.2 Addmonelly, the hcensee planned to add a flurd licensed reacect operator to the control room staff and assigned the duties of the fire luigade leader to 1125 p.34 the reactor operseor. [see Enct 7. Clanficanons]

3.1.2.1 The quahty of--

^

used by operators dunng plea activities was good, however, the use of repemi-backs was =--- ^ In a&hten, 1240 3039216 D-2-9 p.35 canarol roona slanns were seldcen annoimced to the enhre crew. The team observed simular weaknesses dunng sunulasw training sessions. 3019217 3.1.2.1 Control room logs lacked detad and did not meet the guidance provuled in Mame Yankee's adnuaistrative procedures. 1181 0-36 3039132 D-2-9 p.35 "

3.1.2.5 the nessa nosed that the licensee male an incorrect operatnhty determmataan associated with the perfonnance of engmeered sdeguards feanne [P-I4A O-28 p.36 & P-14B] relay testag. [see Enct 7. Clanfications]

3.1.2.6 Maine Yankee =.braned hat t it planned to cancel the [ Tech Spec 5_5 B 9] interpretatuut 404I Compicte p.37 i s

Desimese Secelma h RFI SAO MYTTS Fina 31.26 De smaat m that includsag a daily ar-a=====r yab semple in this e [Ted Spec 3.14] was a dunge to the T5s because ilus did not 1883 p.37 represamt a , opereams spenst The heemsee disayeed with die teamL At the N of the =========r, the NRC was reviewing the 4041 apprepnasemens of this TS inserpretenrat F

31.2.7 The PTRs { post-aip reviews], in general,leded near sad - . The reviews did not have dressled event ===I===, <==paa. - , of 1180 0-34 3039131 the event, sad operusar responses could mot be deemmined tous the doc-=ar= De PIRs did not contain a <== pane list of rapared and ==P""' '

p.38 short-twin corrective assions and pisamed long-tena corrective actions. In =Ahman mulmesel opermear samaesmenes causammed in the neviews genereNy i did sat ===a== sudicient detail to add value to the neview.

3.13.1 A hhr= gin the licensee plumed to arrect the [ADV] probleum, these pleas were deferred and ukumesely canceled in 1992. The 8====ia ed not provide PRCE 209 A-3-8 p.38 an . . as no why the plans na incausse the reliefcapacity were ,=.a.h e 3.1.3.1 la the Plant Root Cause Evalumaan Report <==plaa=I in July 1996, the I- <==chalad hat t the ICC event was not a demp-bans event and Meme 3228 E-12 303946 A-3-8 i p.38 Yankee was not requered, nor did it <====r to have the capab. lay to mungene an ICC event. Nonetheless, the licensee dul inform the temen it ina =d= to COP 9604  ?

moddy the plant to increase [ADV) seems reisefcapocay

(

3. I.3.1 To casure olist abe lusmes a(10 CFR Part 100 would not be exceeded in the event that an over65 con & hon did occur [es a remJt of am SO1R web a 3228 Complete p.39 h loss of vacuusal,hemine Yankee - .J, lismised reacsar coolant synness acemiy to 10-percent of the -= wwlue allowed by TS. }

3.1.3.1 Also, the Ec===ia was evaheating the i==sansa= ofemmergency hghting in this area hqiper levels of the smann sneena velve areal. 1229 Congdese r

p. 39 RFI1229 f 3.1.3.2 Dunne tours of die <==e=====r, ilme team found handunmen earlungs on the well diet included ufenmal synnan drewmies, P -b=ase=ma=* 2242 3039203

p. 39 and a scale used in duournumses rescaer vessel water level when in reduced invemeasy. The licumsee uh hat t these were old markman, wese not 2414 used, and would be summoved ,

3.1.4.1 Mamie Yankes instruned a Fire Pre +== 4 - Plan (FPIP) in 1995. The teams found shst Maine Yankee had made propens in ' 1853 072860 A-t 6 ~j

p. 40 the FPIP. Plammed scambas uncluded % time deep bens for the FP synean, inspecess remeereason seals, and uppedmig the procedures for.  !

I comenthes omahambies and ionian sources. 1 31.4.1 Mame Yankee added a Fire Pr- F=g=== , plammed to hire a new Fire Praeschan Conra ==aar, and creased a Fire Pr====*a= Traines lesenector Complete i P.40 pa===  ;

3.I .4.3 Mame Yankee was not edeceve in idemnfpas and comarotbag in areas of the plant consadaed to be clemL 1210 0-40 3039138 A-2  !

p. 41 ,

_ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___m____ _ _ , _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _

Businasa Secelam Staessamma RFI SAO MYTTS Plan 3.I.43 De reesman preessaan prograin had been elketive in idemnfying areas where 4 - was needed, Inst had been ness edInctive at resolsing these 3029190 A-2

p. 4I problema. 3029198 3029199 3029200 3029238 31.4.3 W. reewnes problemas had beam noted in the areas of W ==pa==u, the exuarol dyersammel- use dproce&s=% and 1209 O-40 3039137 A-2

p. 41 supervisory overwght 1210 3039138 a af C m " satsey - Maa-a==- and Testing .A-311 Condmamal r wench imxzparase cos=g-as evadabshnes and rehabdeos were poor for the AFW syssent.- 3290 M-13 303952 B-3-3 p.42 B-3-12 32.1.1 (1) Based on the resalts of wmf the AFW sysseen perfunned poorly for the tune period analyzed and was worse than the perfonessa values =M 2182 M-13 303952 B-3-3

p. 43 mm the licensee's IPE. 3290 The h was not aware of the poor comkhon of AFW pusep P-25B and had not updated assumpeans made in their IPE. 2407 3039195 B-3-3 3.2.1.1 (3) A special test ofP-14A resehed in a fadure to start T. .  ; activities to deterame the cause of the failure 'M that a wire had been COP 9622 p.44 innsverteady removed in the SIAS start circiut for P-14A.

32.1.1 (4) he IB dienst had been slowly iseproving from a week ra=Ahnma - , O(y- -7 80% froma December 1993, to 3mme 1996, when it 2395 3039171 p.44 rw 909L Thelanest tend for the IB diesel was &maward due to increased plummed and _,'

32.1.3 la h,. ihe l- had established a close ein plan [ COP 95-06] to idemefy and track issues wuh [.- -] purge valvesin generat [RFI Ii18 1118 3039117 p.45 addresses CH-M-1 only] COP 9506 32.1.3 A&htaamel repeneve tr*3 anhees f involved the - sump isolmuan valves caused by debris in the sump ma:h as tie-wraps, weld rod and safety 23 % 3039172 A-2-8 p.45 was.

3.2.1.3 Proposals had been suggeseed to provide adenonal trench screens and to clean the sump and - trenches dunas the 1997 reibehag canage. 23 % 3039172 A-2-8 p.45 3.2. l.4 Dunne the [7/20/96] oute a&btional eqmpment prubleens were ihahfied that t== dad to be addressed pnar to startup, including operabably pr=M - 3290 M-13 Complete B-3-3 p.46 with AFW piump P-258.

_excessve 1-dese of a rendual beat removal valve (RH-41 [ closed by WO %2879] 1877 Compleie s

. ~~ m __-.___. . - - - - = . . - - - -- -----------e - - - - - . - _...~.m._m -- -_..m..m m . - . -

4 Beninasa Sere 6am Staammama RFI 5AO MYITS Plem

_.and id-aneman of safeguards auw logic tesang defumencies and -M egapment problems. E-42 3039182 B-3-9 E-44 3039185 E-49 3.2.1.5 The hcensee **4 that portions of the corroded PCCW piping located inside - would be replaced with *=d*== meet pipeg eming the 2243 E-36 303 % 2 B-2-2 p 46 1997 refuehag omage. 2244 M-25 303991 3429 ,

311.5 the tir==== found h problams, which included a esengaged support (camed by the lack of weld penetrahon) for the raw weser hoe leading 2125 M-4 303975 B-2-9

. p.46 to SW pommy P-29B.

l 311.5 The Er===* mw.re that resources would be made available to greatly improve the maemal cr=Anom of the SW pimap hay. 2413 M-5 303960 B-2-9 p.46 3392 303975 3392-1 3039199 311.5 The Incensee had not *havely impeceed the - - for cle==I==== aAer the [7/20/96] amage. Team observances inside the 2238 M-26 3029206 A.2-8 p.46 =Ae*=I hatt  ! , . regimrod greaser m to ,a===.a. mappropnaae foreign mannel or inasms leR over funn acemmes itsens M-39 3029207  ;

wrapped in unquah6ad plesuc, and discarded tape.-. unconsrolled tools in the e ' 30292I9 1 3039147 I

3.2.1.5 The Er===== ,

" an ismisauve to replace plastic coverings nabwr ingide jbg - with high-seamperasse trahA=8 maesnel. 2238 M-26 3039I47 p.47 312 Theu- Departaset sta5was esechve in Heding and '-- . masenal condition de6ciencies w i thmht elp ant . However,the 2398 3029231 E-t-5 p.47 e5ecommiess of the probless ademu6caban and resolution process was incr==* a. 3029232 E-3-4 3039174 3039175 312 he many i== sam testing was not an efecove tool in idemnfymg problema A lack of a T"""a=""" annende dunas test perfonmence and evaluamon was 2397 3029210 B-3-10 p.47 mot ==Aar*ve to discovenng equipment problems, but rusher to accepang equipment perfun===c* 3039173 3.2.2 The main correceve ecuam propam [Procahme 67-300-l j uaed by the M- Department to review rework was not 6dly esecuve and, in some M-22 3039146 E-t-1 p.47 cases, failed to id-nfy substantive probleums or trends. For erarnple, rework and repamave futures -*4 wah the AFW and EFW pumps were not idenn6ed by the prograse as i-32.2 Examples that were foamd indicated that the program was not always e5ecuve and in some cases the orga-w- at Maine Yankee were not 3039175 D-3 p.47 coeur-aranag and . m wah each onher top idemnfy and prevent repeat problema E-3-4 J

+i ,

4 i I

9 L i

mm 9

- - - --- -- - - - . - - , , - . - - - - - - - -- - - , - - - - - - - - - - - _ . - - - - . - - . - - - _ _ _ _-a_--,----_-_--_,,--,-_-____-__-c

_ .-...m_ m _ . . . ~ . . . - _ . - . - - . _ - . , . . . ~ .. . . - - _ _ - . . _ - - - - - . _-.--.-.--.._m.

- . .__ . . . - - . .~. _ _ .. m . _m.. .

i Bustmeae i Saettaa Sassesmaet RFI SAO MYTTS pine 32.2 Maine Yamtwe had id-eded this de6ciency and was in the process ofimeegretag *==m9 fee corrective action proyams with the intent of 2399 MO-6 3039175 E-3-4 p.47 lusms more e6ecuve an ideatdyms, resuivmg. iratkang, h and n======ig repetshw failures. M7 i 3.2.3 In general, pr=rh-e use and adherence were appropnate, bis there were some instances of poor mantenance work practsces (1) Fahre to impicment 2180 M-14 303986 E-t-1

p. 48 vendor % for EFW pump P-25A. 2236 303990 t

313 (2) Work order han=*r== not followed, servum water syssam declared inoperable. l acensee ' i- wealaess resuhed in a degradui 2125 M-4 303975 D-1 p.48 A of the SW syneen durms = on a seismic paping support [P-29C]. 2331 M-50 303996 D-3-2 E-t-1 32.3 (3) Poor foreign masenal exclumon work practices resuhed in a fashse of steam generstar blowdown valve BD-T-12. 2384 3029206 A-2-8

p. 49 3029207 ,

3029219 l 3029254 3039103  !

3039177 313 '(4) Lack o(proosihraldetail forw=na.==, and comeral of h lockunre [ICI seal W and RC-M-32].. The licassee gamerused WO's to inneau 2246 M-35 303992 p.49 the unisaing lockwue. The heensac also took arviaan to review and revise prnr*A=us involving lockwue == san =*=== 2271 M-47 3039178 6

324 The temen found ' -- -- in the scope of tesung programas, and wealonesses in the rigor in wbsch testing was perfonned, and a the evalunham of COP 9622 B-3-10 p.49 testrig results to dama=*ase functionalsty of safety .

3.2.4 Dasyses the many ' = between mfonnamon ra a==at in the FSAR and the as-bunit condutaan of the plant, the Im did mot recogere the 2402 3039179 B-3-10 i p.49 need to review and reconcile test prr===es with design reqmrements, and to correct these errors. 3039190 F-2-1  ;

F-2-2 3.2.4 A lack of a sp=*r=ums =anamaa resuhed un the use of poor surwiuance procedures, and in the ineSoctiw evaluence of surwillance test data to B-3 10 p.49 deteresse equipunemae' t 3.2.4 Of the test procedures that were reviewed, the team found several examples of tests that had been developed, perfonmed, and evalemned many immes 2354 E-17 303917 B-3-10 7 p.49 withain synesmommig the validity of the test results. (1) Poor EDG tenans piecedures. The tassa id-adat that the 10 and 20 == rand EDO load 3572 M-52 303918 '

sequancang relays had mot been cabbrased since insamaanon, the tolerance band and acceptance cnteria had mui been enabbahd, and these relays were 3587 303922 not in the Maine Yankee Cahbrance Progrant i 32.4 the t--==a sdenuned several other relays that were mot tested or included in their cabbratsas progrant These relays included,the noenr dnica Gre 3572 303918 B-3-10 p.50 pump start pennisave relay and the pennissve relays to remiowe the lour pressure safety iaya*a= (LPSI) pianp trip 10 ===d= aner the recuculataan 3582 303919  ;

actumaan manal to snow manual restart of the pump. The hcensee u*=aai hat t an appropnaec calsbrasion innerval would be ===T=at to these relays. 303920

{

+

6 6

a t

L esse t

'j t

o t

_. _ __ _ _ _____.____________m __.-______._.___._.___.m__.__ _ . _ _ . m__.__.__ _ . _ _ _.__ _ .___.__. _ _ ___ _ _________ _ __ _.__ ______________m

t Business Saettam 4*=a=====* RFI SAO MYTTS Pima 32.4 (2) Cameral masa v==daa== test resuhs not properly evald Further review of the October 31,1995 faled tem and the YAEC c. Lea =*== 2377 M-51 303999 B-3-10 l' p.50 m by te kr==== =Acanal hat the CRt venadasaan syntesa was inoperable frone the failed test in October 1995, untd the ==waand resest in 3039100 August 1996. 3039101 303915) 3.2.4 (3)" , . - sneervice test ---. 3 for [ safety-reisend puunp disdierge] check valve testing 2219 M-30 3039181 B-3-2 p.50 2239 M-42 B-3-10 .

2240 2269 2329 i

3.2.4 (4) Esmergency egepeneet ===i== circunry.sn adaya a=ay teseed and HPSI pump P-14A escovesal sacapable of samting ce SIAS when in saan&y 3546 COP 9622 B-3-9 p.51 anode 2403 017614 B-3-10 thru 017621 +

l 3.2.4 (5) Ah examuples ofi===due===a logic tesang idaaanad and equpment N escoveral in response to the team's & concernmg 1219 E-42 280711 B-3-9  ;

p. 51 the ad==p==y aflagic tesesas and as part ofits ' .' plan in response to Mtc Osannc Imeer (OL) 96-01,

• Testing of Safesy-Reinsed Imgic 3155 E-49 3039182 i

, Cucuns," the lir===== imitassed a survedlance teshag clomeous plan to i&msify and conect other potential tesung discrepamesent 3593 COP 9622 {

~

4621 3.2.4 Several h ===1d== afin=sr==a logic circuit seshag were identdied involving the SIAS, CS acsunnan, RAS, ==d= seam feedweser 1219 E-42 303917 B-3-9

p. 51 trip,EFWi=====ana= reactorprotection,EDO acw-= and main seese isolanon systenut 3547 E-49 303918 B-3-10 3572 303919 .

3582 303920 l 3593 3039182  ;

3039185  ;

3.2.4 a breaker for CS pump P4t S cycled when the undervoltage device was reset. 1238 COP 9622  ;

p. 51 2022125  ;

3039140 -

3039141 3.2.4 (6) Commel board ===e==aar fault aluna cucents not per=Ae=Ny tested 3548- E-44 3039183 B-3-10 {

p. 51 L

ll i f

l I

_ _ . . _ _ . . _ _ _ . . _ _ _ _ _ . _ . . . . _ _ . _ . _ . . . . _ _ . _ _ . _ - _ __...___.___._._.___.____.__.______..__.._m__._____.__.__._.____.__._..1_____._ __._m___...____ __ _ . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _

---

__n.,..._- ~ ~ - - ~ . - . _ _ . ~ . . , .,

l i

Busimmas Seesene Seassement RFI SAO MYTT5 FImm  ;

\

32.4 (7) Senney power smeiers respured by Regulatory Guide 1.97 mot cahbreemd med penahcally tesse L The hcensee stased dust the voit sweers and 3225 E-24 30321133 B-3-10 p.52. ammesurs for the inveners, bemery chargers, DC buses, EDGs and amargency buses were destrummed to be osa of the scope ofeqmpment that requeed 3395- 3039184 a cahbration to support operabsiny determunanons._ Further disc- with the h =Arw that the additsomat meiers would be added to its 3039193 -

calibramon progrant ,

3.2.4 (5) Lack ofcabbration for EDO room ** fan alienmostat 3610 E-47 303925 B-3-10 p.52 303902 .

t 3.2.4 (9) Recuculeman - sipal =====8 mir switch contacts not effectively tested 3547 E-42 3039185 B-3-10 p 52 324 (10) The rh on AOVs to perfonn safety Asocesans should have M earlier ====g -a=r apport for s-  ; AOVtesting B-3-1  !

p.52 proyun that would aumre reliable operation. C-2-1 3.2.4 1he h Department had recendy recoganzed the need for a 've AOV testing progreen sad was in die process ofoboamung fundung 2163 M-9 303983 B-3-1 3039136

{

p. 53 to procure the requesd disposuc and **eas equpement, and proyant trasming. 2404 t

3.2.4 (11) eseactor-Wasersenragetanklevele -- . overheated 2408 E-14 011320 [

p 53 3167 2022III '

3287 303907 3293 3039187 3296 thru 3489 3039190 COP 9619 3.2.5 The basis for some of the nsk infonasmos may not be as conserveerve as previously h, as was the case for AFW puunp P-25B which had a 2405 3039191 B-3-3

p. 53 N probabshty (overall probabihty fw -) much less than that yW in the h's IPE because equipment failure date had not basa B-3-12 vi=*=d [

f 3.25 Bodi the br==== and the team had idenhfied somme and incilicsencass WMh the WO process, and there was a large backlog ofopen WO's 2405 3039191 B-4-4  !

p.53 (some dahms back to 1991) where the actual work had been completed, ahhough clamanut of the work package was not yet perfonamL E-l l t

3.2.5.2 Some weaknesses were found in the work commel process, however, the licensee was m how to improve WO efEcsency 2405 3029190 E-I-l p.54 2406 3029191 E-I-4

• 3029235  !

3029236 t 3029237 {

3039192 i i

12

[

t i

r

?

t I

- - . _ . . . - . . - - . . _ - . - - - . - . . - . - . . - - ._ .-. ._.__.__--..-.._a_.- - - - - - - - . - - - . . - - . _ - - - _ - . - . _ - - _ , - - - - - - - - _ - - - _ _ - _ _ - - - - - . . - - -

_ _ . . . . . _ __m.._.__ ~ . _ _ . ~ . _ _ _ _ . . _ _ _ . . - _ .m_m... - _ _ _ --__ .m . _. _ ..-___m.. __ _ _m . _ . , __ _ mm . .

I t

f I

i m

section Seassansat RH SAO MYTIS Flam l 32.5.2 The- - of die WO tracking system was unierahmt as a tool to aid ====ge-av in - M the stasas dWOs. 2405 3039192 E-I-I p.54 E-t-2 i E-14 i i

3.2.52 -.a renew of the 1995 sneem generosor outage WO *aare =Acan 4 sture was a high peroemsage of WOs that were d, deferred or wndal aner - 2036 M-37 3039149 E-t-1 p.54 the WO's were esaared and pnarmand. 2406 3039192 E-t-4 3.2.5.2 Tims precmos prh =am-manve imelEciescus which wac largely caused by depbcane WOs, lack ofirmaial deficiency tagging of congonents, or a 3039192 E-t-l

p. 54 deter ====== that a WO was not requered aAer one had been immated. E-14 [.

3.2.5.2 A seview ofopen WOs showed that there was a backbg of 185 WOs (snamy penser than one year with the olden bang 1991), where the work had been 3039192 B-4-4 .

p.54 cranpleted, inchuhms ihncenonal temung, but the work pdage was not yet closed ow.

32.52 The pr-a*e used to perfann work wnhin the M- Department ddiered between the muchmascal, elecincal, and L and control 3039192 E-1-1  ;

p.54 groups which commed sonne namor work control : - in trackmg and tradmg of work.11mese work comaral ddlerences also ht he E-I-4 ,

nyasting of-a-ddy WO *hece in that prevemarve - - or swvedlance lessag actmeses unay or saay not have been included a WO itehdce A- af C c. "Sassey-Emaimaoring A-3.3 I the seems also found: 3033175 A-3-8 p.55 - de6 cases deman condmons that had not been emeered in a correcuve action syneent or were dropped [1991 apray bidg demques ADV capacnyj E-3-4 l ,

- correcove action for problemas that was not appropnasely W to look for e-star issues [v==edanae probleums in pset segr, spray bids, commel 3039175 E-3-4 room. and EDO reom]

- osher long-standag de6cient a=Annae [EQ prograra, equpenent testing] COP 9622 B-3-8 B-3-10

• I E-3-4 3.3.1 The team noted the lack of a ca===rvenve testing plulosophy that resulted in the idennArms== of ma--ous safetygelated v that were not 2410 3039197 B-3-10 p.56 bams pa+=ny tested or calibrased.

3.3.1 The team also found =paan tesung weaknemmes wish escuadma= actushan sipal(RAS) ====1 assuasion, 3547 E-42 3039185 B-3-10 p.56

.Agnetet relays used for tuning safety-related conta=== 3582 E-37 303919 B-3-10  ;

.the P-61S CS pump, 1238 E-49 3039140 B-3-10 .

3039142 I

is  ;

- t 5

i

-m.m . . _ . ._..._.m_m_.- . _ . _ . . - -.m. --. .- ---~ - _ . _ = - - -m -- - - - _ , . . - , - .. - - - . _ . - ... . . . _ . . . . . - _ .

i

. c

=

i I

f n==Iman r Soetten h RFI SAO MYlTS Plan [

comerot rooma fmult % 3548 E-44 3039183 B-3-10 ~

_the EDG rainn ve=mlan==s thennostat, 3610 E47 303902 B-3-10 i 303925  !

} i

-_andvanous4,-relseed valves (CCW bypass, check valves) B-3-10 l B-3-12 3.3.1 As a folkmuy to the temn's concenen, ha===== testing revealed that HPSI pump P-14A would not have started 5 on a.l. , e ignal s COP 9622 B-3-9 p.56 widi afsite power available, ahhough the pump ansid have been snarted mismumily B-3-10 ,

3.32.1 .-.sanne tamparary ==hnras- had been installed for a long tune ( - ";10 years). The hcensee was aware of this con & tion, and had recently 2127 303976 B4-2 t p.57 made some ismyrov====s= in this area to reduce the amnber of seinporary sindife=aa= 2312 303995 E4-1 ,

3.3.2.2 The tiraa==='s EromanCorroman Progran was ddlicuk to essess because the comanon unhasary practice of using a ceamputer based pungrase to 3643 Y53973 B-2-5 p.57 deternume =tseha= poemas was aut being usei_ The lacenace also stated that it was making plans to use the EPRI CHECWORKS soitware bem did not connait to an , ' dese, i 3.32.2 The plant had six small leaks in high-energy piping inchaded in the program, four of these wear pinhole leaks, and two of which were in litungs that had 3420 Commplete {

p.57 been nespected and had , leakest {

3.3.2.2 Dere had been several maalliaaks in cae===tay drain lines to the main ca=In==r, and dining the last ainage, the licename fuled to replace ea-g====s= 3420 3039102  :

E p.58 on WO 9442568-00 relased to high presmee drein trap 15, which had been id=hA=8 as beving E/C. (see Enct 7, Clard -l 3.32.3 At the tune of this .18 SWOP! fin &ngs was not cla-.e These 18 lindags involved she =d=T=7 ofW of the EDGs, assung and 3363 E-20 232145 A-34 I

p. 58 treadmg ofim.it exchanger etliciencies (fouhng) requend for safety analyses, and the absence c(*a formal set of====== heat transfer requer== *me 3581 thru B-4-2 ,

related to- - heat removal" to support -- ^ safety analyms. 3609 232153 C-2-1 }

303972 [

i i 33.2.3 For exasnple, even though work had been started, an efective program was not in place to ensure that the heat each==ger fouling did not exceed the 232145 A-34 .

p.58 boun&ng vahses assunned in chan- 232148 B-3-5  !

thru 232I53  ;

303972 t 3.3.3 Sarne M eh were camly - ' .,

h=e- there were partname of various levamans to the same h ======ed 3039218 p.58 The earlier e=1r=I=ma= revisons were noe ==.an=e to medy that they were " superseded" or " void." ,

t nue were no DBSDs as yet for nine mens idensaned in this prograni, including the anergency diesel generators OEDGs), elacencal hi F-2-7 t 3.3.3

p. 58 v ntaha= (partialt reassar protectos, and safety-=enanaa egnels (SAS).  !

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_- _ _ _ _ _ . _ _ ._.__.m __. _ _ . _ . _ _ . .___-.-.m.._m._______. . . . _ _ _ _ _ _ . _ _-__..__.___m. - -. . . - . . - ,, ,,_e-- .

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Saetian Seaseusent RFI SAO MYTT5 Plam

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33.3 the seaan found that they [DBSDs] could not be e==5dmay relied igma without werdicatma in that tiuse wat some umsmar discrepancua 3260 303948 F-2-7 i p.58 333 There was no anular document [like the IASD] to provide = - '. control of the =mneruus other safety-related parammeters regered a deman and 3360 C-14 303957 F-2-3 ,

p.59 i=====g-bases ch*== and plant procedurest The licensee had idenedied we=Ar====e= in the IASD and was workang to replace it wish a enore E-30 3039169  !

docusment called the Safety Analves Informassan Documune (SAID), which had a propected -dase of1997. .

3.3.3 Other drawungs [he=de= the IEB 79-I 4 safety-related piping drawings] had been verined on an as-needed basis, and, as a result, coher sysisens such as 3541 303966 p.59 SW, lacked a counplete set of as-buk drawings. ,

I 33 4 there woe exasnples af assuficant calculanomal deneaearses aaet= tang the EDG ti=nha, e=Ar=Im= (appraam:ssely 200 KW afland was nos accoussed 303909 p.59 for),

[

t the NPSH calc =3*= fur the - sprey pumps (incorrect suction piping head losses and other snapprepname asamnynams), 3626 C-18 303931 A-3-3 t

" E-27 l E-51 i

_and the heat load ehe for the CCW symenus (imappropnase ====pana==). 3529 3039209 A-3-4 ,

3039214 ,

t 3.34 Une qualmy of 10 CFR 50.59 analyses was ana=daad good, hcwever the team found several i=d a-a h of these analyses, asch as, for a 3478 E-39 COP 9621 F-2-9 i p.59 change to the RWST hash-level almnm, e===ri mason was not given to the poeminal for the v of addmag mere weser to - follownis 3515 E-40 -

an.-a==*therebyH Hyimpacangearriramamental *' ' of 6 -

3516 [

3517 i L

3.34 Before the team arnved ansne, the immennec mutissed a review of selected FSAR===*n- to insure that the 1% basis ofthe plass was correcely 3039102 F-2-1 p.59 stated At the time c(the ISA,this esort was partinny , ' but resuhed in over 100 Apparent Discrepancy Repm of which x , 50 F-2-2 ,

wdl sequire FSAR ei===ce= and exampanymes to CFR 50.59 reviews.

33.4 A w =&=a== in the cameral ofcalculanons was nosed For example thus were two active revianons of calculanon MYC-272 3039218 I p.60 33.4 CalculanonMYC-1731.Revisioso,enhd a-aihepost-LOCA- -sump temperanse at 263F. This ,.a,=l*= should have boca superseded 3039218 l

p.60 mince the ammp tanparature ofrecord was 255F, developed tem calculance MYC 1740, Revissaa 1.

Set-Amesoammaet 4,1 _the tessa nosed that supervisors occ==a==Hy sussed Obvtous problesas withm the piset such as deficient menenal copasaa== in the servior waeer pump A-2-8 I p 61 bay and foreign masenal that remaned inside the - aAar cla===8 D-2-1 r i

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_ _ _ _ _ _ . . _ . _ __ _ _ . _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _. _ _ . _ _. . __ ~.!_ _- ,

Busiasse Secelan h RFI SAO MYTT5 Pimm '

4.1 The hcensee was developes an acman plem to adeems the cancerns sad of the CAT nyart Prnpa=-8 acesans N a.. , 4105 MO-9 D-I-I p.62 of a new winam 1==s===r, acreaseg the Humma Resources Socinen's presumae on siae,1_, - of the Sm " Program, and D-2-1 renew of the End oflife Comumsace's recomm-=.a.nna. E-4-4 O-1-2 4.1 the Chesnmem of the NSARC was also the Manager of QA for YAEC. In the lamer pomman, he provided amet resauces for Mesme Yaab As the 4063 MO-5 Comyices p.63 Chaanman of the NSARC, he was in charge d- overudit afhis deparamasa's work. This resulted in the appearamos of a lack af ' RFI4063 4.1 Trackas and reportag ofmany parfanmence =W was Ah eines the 1995 outage. cop =WPr=83 , Sune7sammagers sessed that they saw 3039175 E-6 p.63 timle managesment benefit from many perfonmence =Ar.sars and they were contimung to adjust their content and presamtsanan to and in use and 4.1 Perinnesmos subcseurs for -work orders included only. ',- 25 pennut of the tasal smember of ==A=g work orders that were 3039175 E-6-1 p.63 lessed in h Mesmesmenoe Eminnesman med Pens Proserumsat Sysissa (hEPPS) P ,

^ the tasal workload in the besklog was not assurately chereceanzad by the partinmence subcator shhaude the overall musul in die work ofrene was repressmaatsve, 4.1 The I-==== - , " the Learning Process heprovemust Prograan to psowide a pimenwide mediadology to integreneihe separase tacking systema 3039175 E-3-4 p.63 4.1 Akhaugh the dueshold for reimme probians had demensed since ibe besmuung of the year, the tassa found same === art == where cuhural bemers to 3039175 A-t-1 p.64 problem hm stdl exisaat for example, dw poor famps miseenal camerals Ibr - -and the poor c==Aha= cf the service water busidung. A-2-8 B-2-9 C-2-1 D-I-3 E-3-4 Corneesive Acelsus 4.2.1 He lack of " , ' root cause trendag

• with the im6=stuent [ Functional Area A- Report] FAAR trend daea did not give MO-20 3039175 E-3-4 ,

p.64 ====g====s the infas-san = it useded to samens adverse tremds. T~mmely treuWe,ld have id=hn=8 courammme pr-ha.- in die areas of fannga missenal exclusion commel, and ===aa.=ry feedweenr (AFW) syssam relist &.f. The locussee's new Lesnung Process was d=g-ai to address this issue.

42.2 The sessi decenamed that the licensse's corrective anos r==h=== process was week. The lia===='s traciung syseum was frap==aad widt 4103 MO4 3039175 E-3-4 p.65 w ^ "; 21 individual systems. The backlog of awreente scisans was rulsavely large and was incesamms.-. The everage age of die items was 5 to MO-7 .

9 unamshs, and samme items were as old as 10 years. MO-8 i I

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. - . . . . _ _ . _ . , _ . _ _ . . _ . _ . . . _ _ . . _ . _ . ~ . . _ . , _ ~ - ._m. . . . .- - - - .-_ m . - - . - . . . _ _ . . - . .-.

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n=.am.=a ,

5ereise Seassansas RFI SAO MYTT5 rpum 4.2.2 he locumsee's 1995 correceive acema anda also queen =ad the . - ofmanay===s to tumely problem resoluman. [undermand ADV; SWOPI B-4 i

p. 65 . - . Isabsue hail flaaengr 1991 spray bidg ,a==Tas] C-2-1 E-I-5 E-2-1 E-4-1 412 Samme of the lineesee's correceu actions how basa innsecove sad have ceased repeauve probleses. 2411 M O-15 3039175 E-3-4 p.65 4629 3039198 4.2.2 An a==ple of W correcove acaion was hour the L-==== sddressed die segmew comwel ronsa presume pa-na-a durmg a sur,.m.=,. 2377 M 51 303999 B-3-10 p.65 casubscoalim Oriaber 1991 3039100 3039101  !

3039153 i 4.2.2 ha e to self id-ad=d concess, the t-==== de,aap.een inneyened Canecove Assion Propam, the Imramas Process, which was - for MO-6 3039175 E-3-4 p.66 in the fall of 1996__ At the close of the =======a , the L==== was developsag the ' , , proomhmee and menessary tramung. MO-7  :

M O-8 f

.t Plummhsg and Rosenrees 4.3.1 The Lw=== skd not have en inneyssed overeR 4 1 amsung h Wiele sammy ensemanas of an inesyssed pism exiseul, name of these h 4046 MO-1 3039109 E-2 p.66 comammed infor-ma= whide i&=maad respused resources to achieve apariaat goals sad abjeceves. * ~ ",, speciac perimnmemce to deisnumme ihelevelof . === == i-+=i-s ne i--===- had ' . adameSed the lack of an inseymond overaB pism and was in j the process afincorparaens the fragmsmeed M imeo a sogle docsument as put of the Bummess Plan kunsave and F=armeve ' ' . '

Insaseves impromuna plam 4.3.1 The teams also fasmulihet some preveaus emprovuuset piens were not esecove. For example, begmuung in 1990, the in:amese ===naisseveral 3029190 A-2  ;

p.67 maprow=,= piens to correct probleses in the P=a=maa Protection Depar===a 3029198 D-I-2 3029199 E-6-5 $

3029200 3029238 l 4.3.1 Samme impsevemment pisms had met been mana pa.and becomme oflack ofsuuhms. For.=====rie the immysosuman mutunges h wida B-3-1 l p.67

=. pan =====g e , .. air-aperuend valve (AOV) tesame propen had not besa Amuled for the past 3 years. C-2-I and the Erosion Cameral Propen was not fully funded for 1995. B-2 5 -

C-2-1  !

i tY i

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^

Business Seetlem h RFI SAO MY113 Flam 43.I Also, same preynes had recened haems, but the liosasse had w emus dunne immes ofresauts smess. For summple, ese Supervisory C-2-1 p.67 L._ Preyama was h eming the 1995 retuhmg auenge. D-2-1 4.32 Staginglevels andbudget a _ have been conseramed to that m to gamerste power M C-2-1 p.67 E-4-1 4.33 _the immasaans on resources have delayed and dekrred plear appades, maprovesments, and lower pnanry conectne assions whuh did not mest the C-2 1 W for smisty,reguistory

p. 68 .er reliablec" ' Prepeces which would laely have prevemand prehlemas were unfunded h of F-2-3 budgetlimise One ilhmershve exasug4e was the ing==-e deisy of the completam of the Safety Analyses imputs De (SAID) which could have re.

M he probleum t web the underseed ASD saamer.

4.3.3 Amadur example of desemag moeded proyects becomme of a lack of fleuhmg is itse behing of the M41ecencal/l&C specesky armining proyum C-2-1 p.69 deng the 1995 sessun generator sleevang cusage. This treiming prepared workers esjourneyama and provaled % c , F-1 tramang AE M training was hained in en edart toinszesse the sv=taa=yof werkers to support euenge work.

^"

4.33 "j, thods were mot approved in the 1995 O&M budget to respond to industry reaccreassemon ie=== C-2-1 p.69 F-1 '

433 Amashar =9 of the impact aflimened resources an important prepocas was that the ' .

sumusmary propen was haled emnes the 1995 seman C-2-1 p.69 yearecer slesving amonge h afeemstammes em sentsessuress. Ethis penyene had casemmed, there would have beam adda==d appassumsmes F-2-7 emingthe 1 . ^f" o _ deresumes to idsmady samme of the older design puh Gut were Isaur ia-adied by the same.

4.3.3 In addaman, appW 100 high prieniy work orders wuss esterred hemi the 1995 auenge askedule at the end of the ausage because of sche 6de B-44 p.69 causarama C-2-1 E-l 43.3 Wah - work order and correceve acasan esches synness besklogs escrenums, semier pImma y has seceedy decided to add unuse B-4 p.69 staf E-4-I 1

et i

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._ __ - _ - _ - - - - - _ . . ~ _ _ _ _ _ _ _ - - - - - _ . - _ - _ _ _ . - _ _ _ _ - -

- -- --u-an.-w- . . - , .,-->2 +=.-- a aua,.wu-.. - = . - .=.a.. - --- + . s ux s. . . - . -+.~n_ -u- - -- .x.x ENCLOSURE 6 ACTIONS IN RESPONSE TO SAFETY ASSESSMENT O3SERVATIONS

i 5

i

PURPOSE OF ENCLOSURE 6 1

1 l

Near the close of the ISA onsite assessment period, Maine Yankee prepared summaries of the NRC 3

safety assessment observations (SAOs) as an internal management tool to support a shared i

understanding of the issues and to control commitments between the NRC ISA team and Maine Yankee's ISA support team. The compilation of SAO summaries, sometimes referred to as the

" green book," was useful during that phase of the ISA, but has not been maintained. Apparent or

root causes provided in the SAO summaries had relevance at the time, but no longer necessarily represent Maine Yankee's position on the issues. Enclosure 6 provides a road map to allow tracking l 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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5

ACIlONS IN RESPONSE TO SAFETY ASSESSMENT OBSERVATIONS SAO # ISAT Isses Samunary Key Respumalve Acetsme BA Kay RFI MYTTS WOmmelsens Flma C-l The FSAR desmpaan af tim SGTR event does ad accurenely Clanfy FSARm address appenet 3039200 F-2-1 descnbe the EOP amelyas bans.

C-7 De YAEC w f parfarnung o the Mamme Yankee safety YAEC is developing a process for the fonmal h and 2.1.5 3039158 F-2-8 emelysis sehes on the humancel bees indmdual pensammel transfer of the lustancel basis for the h ilmu direcnam in camarolksg the J.. ^ ofsafety samlynes 3039166 C-8 De Teciumcal W partscapaans in the QA andres of the Revise the QA suda gundsma for those audies using Techsscal 3039167 NED peup at YAEC are not ddumag the exieme afibeir Wde io incinde direct wrimum impia Acum the W %

seviews and fumhngs in the QA reports. ilm scope and 8mmhmes of eneir work.

C-13 The SER commheams of the codes and .. W Develop and W e process for "  ; and omhfhms SER 2.1.2 3039157 3039158 F-2-3 wieb es MY amfeey samlysis have been reviewed and faumd to - for mR safety analyms . and cades.

be 2, sman. Docusa-am of the SER - 3039153 meeds to be cadunal C-14 De camarol of the safety analysis impias does not follow a well Finish the SAID. 3.3.3 3039157 F-2-3 deer. sed proommt 4.3.3 thru Fannales the MY imeerface prwees in revwwung the safety analysis 3039170 impunt C-15 The EDR.s , ihreshold is too high to be se efecove Modify the commolhas EDR proceene to assure that the respured 3039168 etoolinsemesmasproldemaareas. AM the W islawared. -

plant has not beam smede aware of all EDRs pan =h.ny adiscung the safety analyns. Provide training far the YAEC empneers and mismagers provahag input to the EDR systemL Lower the ihresbald far MY h E-3 Samme plass amarelled drawings are original denen drawings &i " drowings camarees via ihe DCR process as "___ , = 3107 303968 and have not bean thoroughly venned against the aWk are id-nr=d 3554 candman of the plant E-4 MYe __ have pensmeed answying oc buses which Proceese I-22-2 has been revised to rumnove the opeion to auss-te 2.38 3352 303913 annammes to allones the synesa to apurane waham adequese DC vnal buses while at poner (unades 6 aut 71 3385 separuman and unh a single failure phd 1

__ _ _ ...m __. _ __ . _ _ . . . . _ _ . _ _ _ __ . . - . . ._. .

• i SAO # 15AT Iuse t=---y by Rampsedve Aetiana ISA byRFI MYTTS WO/Bedman Pine E-6 Adequacy of prh swnchgear rooms w=hinhat systent A Comunued evehwaan of venidanon system uppades as necessary 2.3.7.1 303912 A-3-5 i' ponensial generic syssemi weakness any exist 3.I.1.1 Upgrade avalabday of EDO-backed power supphes for swachgear roomiempormyW ha=

Vennlation evalumnon mamix han been developed sad fonow-up  ;

actions are being 1 *an apprepnene.

E-8 EDG loading e=Lr= 8 ha= (MYC-107) did not ====8 for some hi-hned changes wdl be incorporased into the ongoes cale-lan=a= 2.35 303909 appropnaseloads. revison. .

E-9 SFP HX mameplane temperatwe not -** wnh FSAR Reanalyre die HX for operation at the FSAR temperasure. 2.41 202271 ,

(nameplace=2007, FSAR=225T). 202272 >

Perform 50.59 screen as requre L j View other SFP ==almg e= for similar h Revise FSAR as required.

E-10 The w=hh system for the -- ^ spray buddag is Replace HV mun pnar to anset of cold weseher 2.37.2 303951 A-3-5 ,

vulnerable to freezing and potemnel single falures ofdamper .

3.1.1.1 303 % 5 ,

pneumance that conski resuk in loss of venalanosL Deeenene whesher inist vases maad to be W for wisser 3039128 operasmut 3039129 e E-Il MY amemberofiniprovementopportuminesdanas MY had already a==-se-I to --pam=, IPEEE h under 3269 230154 the IPE/IPEEE ev=hwa== that have not been Fally resolved. a phoned approach whidi esem61s to the 1999 reamhmg asmage. [mmns shru t 196426 MAW inchades a table of every MYTTS ==h - ansped to 230169 .

IPEEE issues]

E-12 As=aghmc seemn dump valve capacey is less than anticipased AAn=*enve heias estabhshed for RCS iodine, . 2.42 303946 A-3-8 decay heat loads.11ms could adversely a5ect the EOP 3.1.1.1 e fSGTRred'o core cooling Operator training and EOP revisions for S01R, as appregnate 3.1.3 I [

analyses / recovery tunes. 4.3.3 Hanhome maMeeh== wC be 1, " dwing the 1997

. reaming w  ;

t E-13 RHR HX thanmal cycle fangue musicipated in currens CCW PreL=.saary, t==ha= ave evalumnos perfanned. MY will formehze the 3438 303937 accident annives mot boundal by current fatigue analyut evaluanon. 6 l

2 ,

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- _ _ . - _ _ _ . = _ _ _ _ _ _ _ - - _ - _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ - _ _ . - _ _ _

. = - . - , - - ,- - - - - .--e~--.--.- - ..,..- . ~ .- - - . . - . , . - - + - - - . . . ~ ~ . . -.

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i SAO # ISAT Issue h=-y Key " . J aan=== ISA ' Key RFI MYTTS WOSemimmes Fine - ,

t E-14 RWST lewl, --- . ===adat their ta-hw ide dee to se Comiprehensin heat tracing syssein analysis. 3.2.4 011320 962525 escusrect temperature set point on an ===arianat heat tracing 2022111  % 2526 cueuse. Pwise RWST level ses point ch= u= to include new heat trace 3039187 setungt 3039189 3039190 .

COP 9619  !

E-15 Minor disceT==a-= butwem Tech Space and FSAR wonhng DE, -- will be correcsad wish my=Ar=== 3366 303941 F-2-1 i E-16 Errors med -- have been id=*Aai in elecencal Id -naat " , '- will be reviewed and incorporased imeo the 2.3.6 303910 coura==a== sendies (MYC-1063 and MYC-1559). next revision of the Coor4==han Sma*= es apprepname. 303911 ,

E-17 Dunne plant wakdowns, instr ====a= sad elecincel layR=====* appropnase correceive art == toma root cause ime 2.3.9.1 COP 9621 B-3-8 consponemas were fumed below the - flood elevenen when -

and were not queb6ed for subenergence by the EQ progrant Detaded Sood analysis review. l i

Fully quehfy CI valve indicasars and nanow range SG level wa====sier ine=siamaa j i

E-19 ch references on several ICI. drawings are Review the ICI. sanas ofdrawings and h DCRs to remoge source 3631 011320 - DCRM143  !

-r==m s docuanent ador==a=m no longer ea==d red to be usefht or current. TEI296 DCR96l44 (KL 303 -403;MYC-1016)

E-20 Tisnelmiess of follow-upklamed SWOPI follow-up ineens. r'anat=- to ca=ya a follow-up inesas ==e -a wish Cycle IS 3.3.2.3 3363 232141 B-3-5 (cadhand 1997) plans. [SWOPI acesca sasarix included wish RFI 3363 thru has cesspiese het ofMYTTS numbers.] 232153  ;

i E-23 The 115 kV sysasun load study " Bene Case

• suggests that bus Revise MYC-430 to retura UV reley calibration band to *0.38% 2.3.2 303915 A-3-10 voltage &ses not recover to i 16.4 LV required to reset the 303921 l degraded put relays. Revise " Base Case" snd load -==g== to unuse reehsuceBy l represent ymioperamag ". ie.,une one or more methods of T voltage support in accmedmace wuk CMP procedures. I t

E-24 Reg Guide 1.97 *=adhy power instrumenes are not in the Calibrase the inser====*= at next renseling outage. 3.2.4 30321133 [

calibration propant 3039184 )

3039193 E-25 Adequacy ofIFSI NPSH under design basis LOCA cosianan conduct HPSI runaut test next outage and record pump vibruaun and 211.2 3337 3039194 B-34  !

courent readings. 2.2.1.3 3364 I

r amus-i

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_ - . . .__m. . _ - . . -. . . . _ . . .. . _ . . _ _ - _. .-

A 5 AO # ISAT Iseem Seammanry Key Raspuesive Acitems ISA Key RFI MYTTS WO/9estamos Plan E-27 Adequacy of Contamment Spesy Pump NPSII un&r design Manne Yankee aheady had ongoing a muge imprwement evaluauen 2.2.1.4 303932 A-3-3 basis LOCA foHowing recuculauen actueuoeL wluch WiE be ConunWed taler llus year. 3.3.4 303931 E-28 Foules factors used as input parameters to the CCW analyses I;ecalumae heat exchanger 4 c testeg for incorporanon of 2.2.26 303972 B-3-5 may not be ounsesvauve and tesung of heat exchangers to estrument incertamty and unpsmed methodologies.

vahdate the analyss _.@ does not adequately consider t mstnanent uncertamry Re-evaluate the acceptance criteria and foulms factors currerely used.

Re-evaluate programs used to satisfy Generic Letter 89-13.

Comm&r updaung Generic letter 89-13 response to the NRC.

E-30 The inputs and Assurryucas Source Dociuneet (IASD) was Complete andinglement SAID. 3.3.3 303957 F-2-3 established in response to a 1982 Confirmasary Action Letaer, 4.3.3 3039169 .

but the issue ofconnut and use of demgn aril licenseg bases 3039170 parameters in safety analyses remanns imresolved E-31 Fourteen menor cyermoed valve sneenrs were replaced wah Incorporsee changes inao the EDO loadmg calculatmas. 2.3.5 303909 nicears of different sizes. The changes in moeor loads were not 303914 reGected in the associated electncal loadmg calculmeians.

E-35 Apparest discrepancy between setpons calculatum and Revise setpoun calculatum (MYC-Il73]. 3478 COPN21 associated cahbretum procedwe for RWST high and alarm TE2i393 seepomt and head correctan incorpweee calculation resuhs into IAC prMwe [34.2.1.411 TE19994 E-36 loose pass and scale freen corroded pnmary compimers 100% of- PCC pipeg has been as-belt and analysis is 32.1.5 303 % 2 B-2-2 coolms waser piping in . -coukt resukin cloggmg of underway to support i@._; of the gnpag wnh stasaless sneet the safeguards sump screens in the event of an acculent requirms the muuation of-- -spray, fuuomed by Am- 25% of the pipeg wdl be replaced dunng ti e 1997 recucidatson actantun outage.

hThe r====tw of the impacted PCC pipes wiu be replaced eming the followns two io ihree cPersung cycles.

E-37 Emergency chesel generseer load sequencmg tune delay relays Procedwal enhancements to ident@ test acceptance crearm 3.2.4 303917 B 3-10 are not rouunely cabbrated 3.3.1 30391g Establishment of a rotame cahbratum frequency,where appropnase.

E-39 RWST high level alarm setpoint raised wnhout fun evaluaaan Upgrade infwinanon <-a- d in Goodmg DBSD. 3,34 3478 F-2-7 ofimpact.

m I

r SAO # BAT Issue Summary Key Rampassive Actimes BA Key RFI MYITS WO/Desimess Plan .

E-40 Denyi Bass Screen 96-044 did not account far e Campiene rain came correceve items for closecut plan COP 96421. 3.3.4 3633 COP 9621 submergence level mcrease assoc ased wah Teciumcal Evalumnon 215-93.

E-42 Recuculeman actuanan menal (RAS) monumi <=hra are not Complete lapc syment testing upgrades as part ofGL 9641 procent 3.2.4 3039185 B-3-9 tested as part ofestablishal survestler z proceduret 3.3.1 B-3-10 E-44 Commel room circut fault -e are not tested as part of incorparuse tesmas ofkey -- . as procedure h 314 3039153 B-3-9 ensamig surveillance procedures. dunes the GL 96-01 review. 311 B-3-10 E-47 Emergency diesel generstor (EDO) raorn vennlance fan An appropnene PM inserval wdl be estabhdied sad ' ,

314 303902 B-3 9 thennessets are not rauhnely cahbrased. 3.3.1 303925 B-3-IO E-48 High pressure safety serectan 0 PSI) pump NPSH tesang dat HPSI pump nmous tesang will be perfunned and w dunng 211.2 3337 3039194 B-3-6 aus document sudicient adonnenen to coachenvely denunsersee the 1997 refuehag ausage. [See E-25] 3364 hag-tena reliebehty during and folkmag anucipated runaut condmans.

E-49 Sauvedlance proceduees dal not deniansernae --- - ' ; of Completelogic syneen tesmag upgrades as part ofGeneric Lauer 96- 314 1238 3039142 B-3-10 4 swing pimnp P415 cucats 5 and 6. 01 procesa 311 3039182 E-50 Emergency feedweser(EFW) Sow. . are not A h 8-I evaluaman of the sanc, seed radiaten _.. -wm be 219.2 B-3-4

-. ", queh6ed (EQ) for the post-LOCA radiahan parfanned and W [see EncI 7, CienEcemans]

envuessnent anucipased by the EQ program in the EFWpump roant E-51 The spare- s pray pump (P-615) e pying head Revised head loss cakh wiB be fM=4 sad incorporated inno 211.4 303931 A-3-3 lama appears to be presar than the head loss assumed a the the fannel- ^ spray pump NPSH eh 314 puny NPSH calculatens.

M-2 FSAR Secuan 3.4.1 sesses meumten baron concentranon Review FSAR Secten 3.4.1 for passble cienScanon. 2057 3039143 F-2-1 during refuehng is 1720 ppra M-? IST progrusa report to NRC was not tumely. Trackas syneen W angoes as result ofearly 1996 Maine 2223 3039144 Yankee W ofneed for unprovement M-e Service weser beenns waser line support appears to be Uppede coalmg sysann ander EDCR 95-31 dunng 1997 refuehag 311.5 2125 303975 B-2-9 degraded ausage. 3.2.3 4

._ . . - - . . . . _ . _ _ _ . - _ . . . ~. . . . . - . - _ . . . - _ _ _ _ . . _ . . _. _._._ _ .- _ _ . _ . . . . __

.i sAO # BAT home Samannery Key Rampmestre Actiums ISA Key RFI MYT13 h Plue

• M-5 Savum weser pump beseplete tolung is corr ** PM to be generused to ammumily inspect silumme seais- 32.1.5 3392 303960 B-2-9 i Replacessent ofmuss will be evalussed and replaced as m dunne ment pommy rebeld prior to startup froms acxt refuehms cuence. -i M-9 De6me long and shast-tena pleas for AOV progrant Further programa developsment, set-up of a area, and 324 2163 3039s3 B-3-1 J pinchase of valveae espapaust W prior to 1997 3039186 refuehms outage.

Devehqueg a design mammary W eh an AOV team, and % soupe ofprogram edExts aM prior to 1997 y refuehag W j M-10 DGI A fasted to --- : dunes the 07/16/96 seveillance. Review ofeeher swinch use to ensue proper possmasses will wsify 2162 303982 i proper switch pommenses as part are trammeg ,

M-13 P-25B reliabilityir low. Rehabehty maprovesment team beses developed. 3.2.1.1 2182 230169 B-3-3 '

311.4 3290 303952 Perfannamme maprev===*= to be i , " and senped as part of museemed smemmen as respured by the ta- Runst M-14 P-25A rotor seized im Jamany 1996. Cammplete toat cause evalueesom sad address carrective action 3.2.3 2I30 3039s6 W by root cause. 303990 M-15 Mesme Yambee chmaged seemm generusar blouews HELB Five ofset valves have had ther % synnes replaced, cae 21si 303987  :

valve teshug tuum quarterly to unamehty m sclanduled for 1997 ousage.

M-16 Provide copies of- m J . fresa Maine Yambee to the Finehze say FSAR chmuges as required. 2228 3039145 F-2-1 NRC regarding EDO start imme % frina 10 to 15 seconda M-22 Program to idmhfy ggwngk ggd ggggggyg (aglgreg appegry to be Review peccahee 67-300-1 and asher'pr- that idamfy and track 3.2.2 3039146 E-t-l I lackms (Repositive problems cm P-25B is a good example.) newest and supemove failures. i t

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5AO # ISATImame Summiery Key Responsive Actimme 15A Mey RFI IETFS Woemsnmess Pine ,

M-25 Masenal

• of- - PCC pipes. c- canassan mispecnons and pipe replacensents ahmag next 32.1.5 2243 303 % 2 B-2-2  :

duee casages. 2244 3429 Piping is maamnared each cycle kr structuralinneyisy via SERP.  ;

100% of- PCC piping has been as-lumit mal amelysis is  !

underway to suppet replacement of the popmg wah h seeet Iw ",- 20-25% of the piping wB be replaced dunng itse 1997 N 7 The W of the impacted PCC piping will be replaced during the falkmmg two to three operuang cyclet l M-26 C- - cleanheess W plastic being replaced wish ingh amupersiure plastic. 3.2.1.5 2238 3039147 A-2-8 MY we evolusseissue folkmme ria==== when esnergemt l work accus.

M-30 EFW abscharge check valve surveillance praamhme used PED and Operamans evalumeed test methods and P cneens for 3.2.4 2219 3039181 B-3-10 preamse gauge wnh too high of a remge to read 15 psi syness check valve sW (dus e and calar p===*.my 2239

• P cnearm NRC concerned that problue was not imp- a P). Serveillance procedures N to 2269 W eerber. sicarpersee new test mand W-csieurm Tesas cumpleesd 2329 J

Review widivendor,amed for past - check (Isot enrupse an 2217 3039148 s M-32 CH-50 has loose capscrew nuts pressure seal cal'est M-35 ICI seal baumnslackwwe umsens. WB champe A procedwestopery=hr.nyvenf flackwwe 32.2 2246 303992 [

M-37 1995 reesehag%esann genersect annage performance w WW perfann a veview of die "frans end* of the work order piecess to 3.2.52 2036 3039149 E-I-4 appear to i=Ar* paar pI===ng &se to the largeef o ===== the member afim work orders essered iman the 3039192 4 work orders that were vaided. Pre-plemned work orders not dueshese.

wanted qs 36% .md is% ofwerk ordes wnmen &ams amage [

were not workedt p s j i

1

m___m .____m-. m.-__ . . _ _ . . . _ _ . . . _ _ . m... _ . _ . _ . . . _ _ _ ._ .

• t i

i SAO # ISAT Issue ? , Key Responsive Aestene 15A Key RFI MYTT3 WOSushuse FIme M-39 Duct tape imsuion SFP well Engdoyee awareness twighsened on ME issues and pre 32.1.5 2062 3039151 A-2-8 3039177 FME Pohey Overnglit Comunnees fiumed Imlung for another way to nark pombons.

M-42 EFWchaivalve procedue @ Survesilanne preasdaresa to reflest adequese test w 3.2.4 2219 3039181 B-3-2 B-3-10 M-43 HPSI flow beyond pump curve 2173 3039194 B-3-6 M-46 rw pray headers valves CS-M-1,2 seroke innes are Apprepnase FSAR change se win be h to correct 2270 303994 F-2-1 not- web the FSAR. r pressere vs. tune FSAR- 2289 .

curve shows no effect tosa- -spray.  !

Installedlackwue 3.2.3 2271 3039178 I M-47 Imy 3 stop valve RC-M-32 is nussing actustar nuountmg lackwire I i

M-48 Does not appear to be adequese fuel osi h in the diesel th=ye FSAR as apprepnant 2288 303993 F-2-1 generesar integret and day snarage tanks to meet a set how run  !

neie.  ;

i M-49 Some EFW and AFW pipes does not masch the isanweic issue DCRs for E , - which do not fell wishin the ennepeans 2333 3039154 drawings. cneena ihr the so-built W= 3039155 l 3039156 r i

M-50 Pipe support removed than P-29C beenna e supply. Unkze results as spyropnmee Rosa root cause emelysis. 313 2125 303975 B-2-9 2331 303996 M-51 Canuel room ventdemanissues- Casmplete a root cause evaluaman ofpast test by 12 31-% 3.2.4 2377 303999 B-3-10  !

- P*nhal , gpaggbgbly ggd reportskMbly ETalustMm 4.2.2 3039100-  !

~

regenhng 1095 surve Dance Address 50.59isuse under RFI 2377 3039101 l

- Operabihty sistas frein 10/95 to 8/967 3039153 l Cancerns regarding changing cas: trol rouse W=pe YeNow tag issue to be addressed by 12-31 96.

ensumphans from 10 (1993) to I (1989) to 10 (1995) and -

[

essociemed 50 59 evel==ma== Reviewhevise test e _ pnar to next use(987). t

- Yellow tag om dumper since 1988.

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SAO # ISAT lasme W Key - . _ Aceimme 15 4 Key RFI MYIT5 WOMa-.a plum M-52 EDO procedure 3.1.14A refers to 30 second start black (P- Reverdy vendor's caltramas W 3.2.4 2354 303917 25C) and teneris set at 20 secamas. 3587 303918'

- Research _ history and medusky expensace to densrumme 303919 EDG tmme delays are mas cahbrasset appropriane cabbranonimeervals 303998 MO-1 MY has not yet developed an innegrened bummess plan bhamonNisio nevisan 4.3.1 4046 3039109 E-2

"_,_ the h plan MO-3 PORC has made mane--eveenve deciseams based on the TSI S.S.B.9 was terummand and wiB be evalussed for LER 4041 3039106 [

seview of. ", 64 Tech Spec e approved 3039107  !

by PORC. Of the 64 inserpreensions, seven speedic Have PORC perfana a review ofexisang TSis. 3039108 interpretancsis were cited.

)

MO-6 Commumment traciung at MY has been week. i, of the Leanmes Process 312 4083 3039175 E-3-4 4.2.2 4640 MO-7 Fragmessed correceive action prosess - The cumse conecave theleanung Process. 312 4083 3039175 E-3-4 i menom process appears uncoer e a.aal and fragmaed at the 4.2.2 4103 Corporate level NRC asked MY to explans accians to (1) Review % issues in maluple dansbases using l} screessag 4640 enume no acuous' Tall thraugh the crack sad (2) tresuhag is cneeria(RFI 4083).

susicient.

Hashamma gammemly to new issues.

MO-8 Sasme issues dut mot recene immely resolunaut Venry wheiher issues involved mummedisse safuey n=== rut 4.2.2 4083 3039175 C-2-1 4104 E-3-4

• Evalumne generic '_ , ofspecific e-+ j i

I Unihas pnar-immeures of the17.

i MO-9 Some plant samthove lost trust in senior management's abiiny Review and revise carperses smisman and visan. 4.1 4105 D-I-I r tolack aim for their welfare. l Tal of14e" Casunuttee wiB receive increased enemason and prianty. G-1-2 i I

- Broeder asuplayee impse on policy L D-I-3  :

t ReviseWorker r ===aPinyant A-t-4 j Higher priorityampmscovee 3029251 D-3-2 i

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_ . _ _ __ _ _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ __ m . _ . . _ . _ . _ _ . _. .m..__ __ _. -_ _ _ _ _ ___m_ ._. _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ . _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ - _ . _ _ . . -

s \

SAO g ISAT Imame Seemmary Key Respuesive Actimes ISA Key RFI MYTTS WOmealswee Plan MO-15 Some corrective actions have been ineNective and have remahad implement the Learmag Process. 42.2 4629 30 9175 E-3-4 in repetitive problems.  ;

MO-20 Departmental root causes not trended. Implementation of the learnmg Process will improve tracking and 42.1 4631 3039175 E-1 trenihns. 4636 E-3-4 As part of the Mameenance Rule, PED will track and trend apparent

- for asupment failures 0-1 Mmunum number of CETs required for entrance inao FR-Cl Incorporsee changes to FO.2 and background doc-navataan to ensee 1073 182303 not specined. that five CETs inust be >l200T to enter FR-C I. 3039114 G.6 FSAR does not specify use of BA-A-80 as a ddution path FSAR will be clarified 1063 3039I12 F-2-1 during reactor startup. ,

0-7 Trammg Manual liseed as a reference axianent for EOPs Reference is beeg removed 1072 3039113 Reference sectica updmee is underway.

O-13 Operstor work __. L'-,-, actions (volume). Upgrade eqmpment 'h per planned and proposed EDCRs or 2.3.2 1107 3039116  % 256 work orders as appropriate. 23.7.1 1134 3039123  % 2536 23.7.2 1176 230159  % 2566 3.1.1.1 1877 303915  % 2879 3228 303921 3289 30390 3494 3039128 3583 3039129 303946 O-16 Operaung crew ..ning danns sane ine- may fall below Transfer Fire Brigade duties froun the SOS to anoelur individual as a 3.1.1.2 1125 3039120 the nununum requred. Tims was spec 6cally anned at the PSS supplemental accon to unprove maning duty as a First Aid Responder during a fire.

O-18 MY does not track RCS thermalcycles Develop procedures to 1_, ^ tracking methodology 1105 3039115 O-19 Tech Spec inserpretatson process appears to be non. Vrdi perform beenseg revww of all active TSis. 4041 3039106

- . , 3039107 3039108 l

no m..._... - _____ _ ____. _ ._._.______.. _ _ _ . _ . _ _ - _ _ . _ _ __ . - _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ . _ _ . _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

SAO# 15ATlesse % Key Responsive Ardams ISA Key RFI MiiTis Weemshness Fina 0-30 nae woe severmi equupeamt problems dunng the recas piam P-2B hip issues being tracked by Massennece Rule. 1107 3039116 9244Ii sinadowat 1134 3039122(c) 96223 3039123 962 %

%1964 0-33 IPSI moeur amp issue - piang operused in the " orange" band Develop proaahme dunges to track total number of hours a 1132 3039121-fur asnps-this requesd PED:= view. campommes can be operuand in this condmont

• j 0-34 Post Trip Review Repons in:k"detaal sad near." Review MY proomhme against indusery senaderds fad-hatINPO). 31.2.7 1180 3039131 compeer probians j

-sdp chanslack tunes Immisse any changes deemed ==~~=y _. wish the i ia check on gersang egapment seerts _

-- odemhned as a result of the % review.  !

O-36 Commel rarse log book dal not have amenes retsaat to the Iminissenewpafor===r*-Mre managannatseview 31.2.1 1181 3039132  ?

following: ofcomerot room log book aAer abnonnel plant condman occurs.

j

- manual reactor inp as part of the plant shundown on 7/2066 ,

-EDG problemas on 7/1/96 t

- manumi P=8 opernham due to plus compeer problem  !

- problems wnh RH-4 w =e*

[

O-37 Rask-bened wakdown of ECA-0.0 ATTC had two h ofmoeur opersaurs for MS-59 -79, and -99 pt===as for 1229 A-3-8 I 3039140(c) m-h=ge Wakdown of ECA-0.2 bad one findmg 1997omage. CPA9632 I cop 9604 0-40 Finy percent of au persammel occw in cleam Review procedural gh om survey techasque and tequency for 3.1.4.3 1209 3039137 A-2  !

areas. WM 1210 3039138

• Review comerois govermag work in aa=~=====a-amens of the Resenceed Area.  ;

f Cosimme improvemment mehstives in gae area of suf I

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9 4 ENCLOSURE 7 i

CLARIFICATION OF STATEMENTS f IN THE ISA REPORT 1

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PURPOSE OF ENCLOSURE 7 Enclosure 7 provides Maine Yankee's clarification of certam statements made in the ISA report and i

describes the financial structure ofMaine Yankee. l 4

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t I

CLARIFICATION OF STATEMENTS MADE IN THE ISA REPORT Samtima Corrumt h Claseessium Table I He "SER comannes* serbined to se COBRA III4 code are Mi-f as being impamed by tem maker of These condmamm me met SEReimand summistamm; tiny are h of the asemedaar bened as t

p. 6 the code and not the NRC in am SER. . behaviar af te trummans or ==M=q i========= bened an empancel conuinamum 2.1.3 ThetwoSERhamRtOSSTEY-2wereC ' 2(1)alocalburnuplumitof60.000 He SER limit is acemmuy 60,000 MWDNTU en a nul avernme benes. There is no locallammme lumit for the

p. 8 MWded1U and (2) the incluman af Asel W c FROSSTEY-2 codit l

t 2.2.2.6 (c) [CCW med RHR] Heat ~4-y- tubes were ,a==.=d an a periodse bens. RHR HX tubes are not enemmed an a penadsc bens.  !

p 20 3

2.3.2 Maine Yankee would assim manly Che to bnes the Maine Ysubee capacisar bank asul Surowiec Maine Yankee does not moedy Che to bnes the - r"**"" beak isso service as ynd lands >l300 Mw. l

p. 23 Trennfanmar Auto Boost inna service at yid lands penser than 1,300 MW. Opersears uma voltage minnes to dananmime operuhehty 2.312 .the becanee amformand the ISA tesem that the desirability ofblacktag sysm these dumpers had beam raised Revinson I to Maine Yambee's e to RFI 3520 included the MYTTS members shut were used to track  !

p. 29 in 1991 by a samspersom ensa YAEC in a masonr-h== dened February 20,1991 Den h the W mande in the 2/20s1 13-04 threech 10-13-12.

h a specisc % to block open d-p==s VP-A-56 and VP-A-57 h====== "If te [

camareller imits,it could comme the inlet wumme int bat (mus to clame, ceuming a ruhusene in the ausput of .I the systemL* 1he ISA teaua faumd no evademne that ilms inmue had beam ausred inao a carrastree maica synessa er was bang tracked by the licasame.1his was am summple of the L====='s faihme to take  !

apprepnase assina to adeems a plume penhimmt 2.3.9.2 The licemens samend that evoluumma of tis [EFW flour - lissue was under way as part of a DBS 96-41 was not sevised to sopire a dame revieur. Mame Yankse is courumsly evalumang es . , --- i

p. 31 revenas to DBS 96-41. His revimon would add an acainm isess to provide a deemiled resieur of she er ==g=-m= man of te Soir trammminers.

r=% dose at the insenumess tar ha= +

3.1.12 The nessa inmed thus Maine Yankee has previously developed e . aceian plus to addrums the Manne Yamhme has trumsfened First P==r-a , emes to the Socieur Suprrvuur. Maine Yankee did act  !

p.34 sinA == ales issues which included- (1) using security persammel re6er them the PSS as medical ant commait to samt a thini CRO. Maine Yankee <====sa d to trammler tim Fue Brigade Lander esses to one of [

responder,(2) umag a sacand CRO as the Are brigade leader ruher them the 505 the two on-shiA CROs and remafer his dusies to echar am NPO or am udemiamat saanemy smant (RFI II25). .t

^"

3.1.1.2 "j, the hcemmee piammad to add a third licensed rescent eparaent to the ammel recem samtand Muno WFB 96463, manched to RFI 4044, included the an=a===e "Addriemany,Sammar kW ,

p.34 emagued the essies of the Hre bngade leader to the rencear operseer myeed to the long reage hiring mut training pencess necemmary to achieve um adesimmat hommmed operaar en  !

each aew. An admeismal W was made in memo WFB 96431, sino anoched to RFI 4044: I

'Two NPOs should be demgessed as due bngade sesehers, one of which is dempsmand en Ere bngede leader.

This wiu leave ama aymuner (CRO ar leo '=r== hme em he crew mehmsp) avalable to perfana IWquired local openssoms durung an accidamt -ama= " +

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Sectise Curvest seasement Clarisemelma 3.115 _she tessa noemd that the I- made an inconoce operalniny deser==*r= h widi the Mene Yankee esagress web the NRC *a===s Mame Yankee beheves that Sic 96-18 anectly p.36 pertanacce of engineered safeguards fessure relay tesung. The tessa found that dus W of the deem ====I t he egapment to be operable.

TS reque== =** was incorrect l

313 (2) W:wk order mstructions not folkmed, service weser system declaral unoperable Should read "_ service water nuen P 29C declared moperable" as is stated in the next to las semeence of the p.48 paragraplL j 314 (2) Fwther seriew of the October 31,1995, failed test and the YAEC h =====rs=== by the Maine Yankee perimmed a operabday determansanon and concluded that CR habambibry was in fact p.50 I===-- -br*J het thei CR vessilation system was inoperable tasa the fueled test in October 1995, mesmesmed. Refer to RFI 2393 and sma=a CAO 96-014. ,

used the W retest in August 1996.

3.32.2 The lh also sessed that it was making plans to use the EPRI CHECWORKS soAware but did not Our r==pa=== to RFI 3643 mcluded ibe folkmag "Memie Yankee mise beheves shut the use of 7

p.57 comune to an ' , -- dese. 'CHECKWORKS' computer code would provide h assurance and has already ev=sare=d experts in  :

the use of *CHECKNS* en upgrade our progreat This process bas beca underway for ahmost a year  !

mow and is adumbded to be commplete in tune Er the 1997 reAsehag.*

3.3.2.2 dunna the last ausage, the I-- e failed to replace congamemas en WO 94-0256840 reissed to high Thn was a - as the part of Maine Yankee. la fact. TR-15 and the piping downsaeam or i

p. 58 pressure dress trap 15, which had been idenedied as having E/C. TR-15 had been replaced wie improved materials under work orders 92-7202 and 94-2568 dunas the 1992 i med 1995 reemehug ausages.

App B The art =="*a= chart prM in Appendut B inconectly Ay ce=d het Manager, Public & Gover===r Dese managers repet directly to die Pr==d=aCluefExecwave 08icer.  ;

ANairs and the Manager. QPD/ Strategic Planung as reportmg to the Vice Presadam & General Counset ,

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FINANCIAL STRUCTURE OF MAINE YANKFF

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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 3 pressure. Our executive assessment concluded that Maine Yankee has always enjoyed ready access i

to adequate resources, and the practice of not retaining a large cash reserve in no way contributed to the economic pressures affecting performance. This expanded explanation of the financial aspects

of Maine Yankee's ownership structure is provided as clarification in suppon of that assenion.

i 4 Baclearound Information provided to the Federal Energy Regulatory Commission (FERC) describes the financial

- relationship of Maine Yankee's owners.

The Company is sponsored by ten investor-owned New England utilities (the " Sponsors" or the

" Stockholders"), each of which is 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 j of amounts sufficient to pay the Company's fuel costs, operating expenses (including a depreciation i accrual at a rate sufficient to fully amortize the investment in the Plant over the operating life of the Plant and amounts estimated to be sufficient to decommission the Plant), 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 l the useful life of the Plant and the completion ofits decommissioning and financial obligations. i 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 nbject to the continuing jurisdiction of various federal and state regulatory bodies.

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 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 domain or a similar right or power, or (iii) (a) the Plant cannot be used because of contamination or because a

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necessary license or authorization cannot be obtained or is revoked or the utilization thereof is made i 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 decommissioning costs continues until the Plant has been fully decommissioned.

Imnlication for Maine Yanicee The regulated cost of service formula allows Maine Yankee to pass its actual costs of providing 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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In fact, Maine Yankee does retain a reasonable and allowable amount of earnings. The Company's l 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 1 investment by retaining 50 percent of earnings. ' Just as our FERC regulated cost of service formula 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 earnings.

3 Under its organizational 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 j unanticipated. Maine Yankee considers this a competitive advantage over other plants operating

under traditional fmancing arrangements. Despite the steam generator sleeving expenses incurred i 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.

i i Maine Yankee common equity investment exceeds all of the equity requirements established in its

j. 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

( credit rating under Standard & Poors Corp.

l' Considered from the financial perspective, Maine Yankee's ratio of equity to total capitalization is j efficient. Because it exceeds the requirements of the Company's fmancial agreements and the conditions of the current financial markets, there is no current financialjustification for increasing

. the level of retained eamings. With its current financial arrangement, Maine Yankee is considered credit-worthy and capable of meeting all fmancial obligations. 1 l

hnnlications for Main. Yaniene'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 fmancial condition of the owners. Indeed, Maine Yankee's ,

implied investment grade rating from Standard & Poors relies in part on the financial condition of  !

the owner utilities.-

Conclusion i 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.

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