ML20154H615
| ML20154H615 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/08/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154H589 | List: |
| References | |
| EA-96-299, EA-96-320, EA-97-034, EA-97-147, EA-97-34, NUDOCS 9810140270 | |
| Download: ML20154H615 (11) | |
Text
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I (NOTICE 1)
Maine Yankee Atomic Power Company Docket No.
50-309 Maine Yankee Atomic Power Station License No. DPR-36 i
97-034;97-147 During NRC inspections conducted between July 15,1996 and August 26,1996, and between December 8,1996 and March 15,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC i
Enforcement Actions," NUREG-1600,the violations are listed below:
1.
VIOLATIONS RELATED TO INADEQUATE TESTING A.
Technical Specification (TS) 3.9.B, " Engineered Safeguards Features l
Actuation System," Table 3.9-2 No.1, " Safety injection," requires, in part, a l
minimum of 3 operable channels for both high containment pressure and low l
pressurizer pressure per safety injection actuation system (SIAS) subsystem l
to be operable whenever automatic initiation of Engineered Safeguards Feature (ESF) systems is required to be operable. TS 3.6.C requires, in part, l
two operable and redundant emergency core cooling system (ECCS) trains l
including one in cach high pressure safety injection (HPSI) pump subsystem, l
an ESF system, to be operable whenever the reactor is in a power operation condition.
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Contrary _to the above, during periods of power operation from December 1991 until August 17,1996, there were no operable channels of high containment pressure or low pressurizer pressure in the 'A' subsystem of the SIAS. Specifically, the 'A' HPSI pump would not have automatically started in response to a SIAS signal (high containment pressure or low pressurizer pressure) due to a missing wire in the HPSI pump circuit. (01013)
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B.
TS 4.0, " Surveillance Requirements," requires that each surveillance l
requirement in Section 4 be performed within the specified surveillance interval.
l 1.
TS 4.1, " Instrumentation and Control," requires, in part, that testing l
of engineered safeguards system logic channels be performed as I
specified in Table 4.1-2. TS Table 4.1.2, requires, in part, that Channel 3, SIAS actuation relays; Channel 10, refueling water tank level recirculation actuation signal (RAS) initiation; Channel 20, feedwater trip system; and Channel 21, emergency feedwater (EFW) initiation, be tested at least once every 18 months.
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2 Contrary to the above, prior to August 18,1996, surveillance tests required by TS 4.1, Table 4.1-2, were not performed at least once every 18 months. Specifically:
a.
Channel 3 - HPSI pump start signals for SIAS and undervoltage (UV) conditions were not tested independently; and the dual function swing pump (P-61S) was not tested as a low pressure safety injection (LPSI) and containment spray pump for UV and SIAS actuation; b.
Channel 10 - Manual initiation of RAS was not tested; and the automatic trip of swing pump (P-61S), when used as a LPSI pump, was not tested; c.
Channel 20 - The SIAS permissive was not adequately tested in that the main feedwater pump, condensate pump, and heater drain pump trip systems were not tested with a SIAS coincident with a steam generator low pressure signal; and d.
Channel 21 - Emergency feed water pump circuit breaker closure was not tested. (01023) 2.
TS 4.5, " Emergency Power System Periodic Testing," A.2, " Diesel Generators," requires, in part, testing of the diesel generators (DGs) during each refueling interval that demonstrates their readiness to start automatically and restore power to vital equipment on loss of all normal a-c station service power supplies.
Contrary to the above, during each refueling interval prior to August 18,1996, tests required by TS 4.5.A.2 were not being performed in that emergency bus loading and load shedding, necessary to demonstrate the DGs readiness to start automatically and restore power to vita' equipment on loss of all normal a-c station service power supplies, was not adequately tested. Specifically, for the following vital equipment:
a.
Service water (SW) pumps P-29B and P-29C were not verified to remain operating on the bus if they were the only available pumps in the train.
b.
Primary component cooling (PCC) pump P-98 was not tested as the preferred pump.
c.
Secondary component cooling (SCC) pump P-10B was not tested as the preferred pump. (01033) 3.
TS 4.6, " Periodic Testing," D.1.a, "Feedwater Trip System, Main Feedwater Pumps," requires that each main feedwater pump, l
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condensate pump, and heater drain pump trip system shall be tested during each refueling interval by tripping the actuation circuitry with a safety injection signal coincident with a steam generator low pressure signal.
Contrary to the above, during each refueling interval prior to August 18,1996, the testing required by TS 4.6.D.1.a was not performed to verify tripping of each main feedwater pump, condensate pump and heater drain pump circuit breaker with a safety injection signal coincident with a steam generator low pressure signal. (01043)
C.
TS 4.7.A, " Inservice inspection and Testing of Safety Class Components,"
requires, in part, the establishment of an " Inservice inspection Program" that meets the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, " Inservice Testing of Pumps and Valves," for safety class 3 pressure retaining components.
10 CFR 50.55a(f), " Inservice testing requirements," requires, in part, that safety related valves must meet the requirements applicable to components which are classified as ASME Code Class 3 set forth in section XI of the ASME Boiler and Pressure Vessel Code.
ASME Code,Section XI, iWV-3520, " Check Velve Tests," requires that valves normally open during plant operation whose function is to prevent reversed flow, shall be tested in a manner that proves that the disk travels to the seat promptly on cessation or reversal of flow.
Contrary to the above, as of August 18,1996, inservice testing for 15 safety class 3 pressure retaining check valves that were located at the discharge of safety related pumps did not meet the requirements of the ASME Code,Section XI. This inservice testing failed to demonstrate that the standby pump's discharge check valves, which are normally open during
. operation and whose function is to prevent reversed flow, would properly close on the cessation or reversal of flow which would be necessary to prevent short-cycling of the operating pump. Specifically, the following safety class 3 valves were not adequately tested:
1.
Charging /HPSI pump discharge check valves CH-10,19 and 26; 2.
EFW pump discharge check valves EFW-15, and 314; 3.
LPSI pump discharge check valves LPSI-50 and 51; 4.
PCC pump discharge check valves PCC-6 and 13; 5.
SCC pump discharge check valves SCC-7 and 14; and
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4 6.
SW pump discharge check valves SW-1,4,7 and 10. (01053)
These violations in Section I represent a Severity Level 111 problem (Supplement 1).
II.
MOLATIONS RELATED TO ENVIRONMENTAL QUALIFICATQQN_
10 CFR 50.49(d) requires, in part, that the licensee shc3 include in a qualification file the environmental conditions, including temperature, humidity, and submergence, at the location where electrical equipment important to safety covered by 10 CFR 50.49 must perform.
10 CFR 50.49(j) requires that a record of the environmental qualification must be maintained in an auditable form to permit verination that each item of electric equipment important to safety is qualified for its application and meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function.
10 CFR 50.49(f) requires each item of electric equipment important to safety to be environmentally qualified by (1) testing of identical or similar equipment under identical or similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable, (2) experience with identical or similar equipment under similar conditions with a supporting analysis, or (3) analysis in combination with partial type-test data that supports the analytical assumptions and conclusions.
10 CFR 50,49(b) defines electric equipment important to safety within the scope of 10 CFR 50.49 as safety-related electric equipment, non-safety-related electric equipment whose failure under postulated accident conditions could prevent safety related equipment from accomplishing the functions identified in 10 CFR i
50.49(b)(1), and certain post-accident monitoring equipment.
10 CFR 50.49(e) specifies the conditions and other location dependent considerations that the electric equipment qualification program must be based upon. These conditions and considerations include, in part, temperature and pressure, humidity, and submergence, as applicable, during and after the most j
severe accider.t environment for which electrical equipment important to safety must remain functional.
A.
Contrary to the above, as of August 2,1996,the qualification files for 30 items of electric equipment important to safety inside the reactor containment did not permit verification that the items were qualified for their applications and met their specified performance requirements when subjected to submergence, a condition predicted to be present when they must perform their safety functions after a loss of coolant accident (LOCA).
The qualification files for these 30 items of electric equipment did not include j
the correct submergence level at the location where they must meet their j
specified performance requirements. Specifically, safety-related valve limit i
switches and associated pigtails, Rosemount transmitters and associated l
electrical connectors, and certain Rockbestos cables were not qualified for
5 post-LOCA submergence in that there were no documents in Maine Yankee's environmental qualification (EQ) file to demonstrate qualification of the items by testing or a combination of testing, experience, or partial type-test data with analysis. (02013)
B.-
Contrary to the above, as of March 11,1997, the qualification files for two PCC pump motors and two SCC pump motors, safety related components, did not permit verification that they were environmentally qualified to remain functional during and following a high energy line break (HELB) in the turbine building, which is the most severe design basis event at their location during or after which they must remain functional. ~ Specifically, there were no documents in the Maine Yankee EQ file to demonstrate that the PCC and SCC pump motors were qualified for high temperature and high humidity resulting from a HELB. (02023)
These violations in Section ll represent a Severity Level 111 problem (Supplement 1).
Ill.
VIOLATIONS RELATED TO INADEQUATE SAFETY REVIEW A.
10 CFR 50.59, " Changes, tests and experiments," permits the licensee, in part, to make changes in the facility and procedures as described in the safety analysis report without prior Commission approval provided the change does not involve an unreviewed safety question (USQ). A proposed change shall be deemed to involve a USQ, in part, if a possibility for an accident or malfunction of a different type than any evaluated previously in
- the safety analysis report may be created. The licensee shall maintain records of changes in the facility and these records must include a written safety evaluation which provides the bases for the determination that the change does not involve an USO.
I 1.
Contrary to the above, in May 1992, Maine Yankee made a change to procedures as described in the FSAR that involved an USQ without prior Commission approval due to an inadequate safety evaluation.
Specifically, Maine Yankee established procedure 1-22-2, "AC and DC Vital Bus Operation," which allowed cross connecting redundant 125 Vdc vital buses for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> during plant operation. This was a change from FSAR Appendix A, Criterion 39, " Emergency Power for ESFs," which provides, in part, that the alternate power systems be provided and designed with adequate independence and redundancy to permit the functioning required of the ESFs and, as a minimum, that the onsite power system shall independently provide required capacity assuming a single failure. With the 125 Vdc buses cross connected, all 125 Vdc power to the ESFs could have been lost due to a single failure. This created the possibility for an accident or l
malfunction of a different type than any evaluated previously in the safety analysis report and represents an USQ. As of August 30, i
1996, the safety evaluation performed for this procedure change was inadequate in that it f aiied to identify this USQ. (03013)
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1.
6 2.
Contrary to the above, Maine Yankee made the following changes to the facility as described in the FSAR without performing a written safety evaluation for these changes to provide the basis for the determination that the changes did not involve a USO, each of which constitutes an individual violation:
a.
In January 1996, Maine Yankee restricted the maximum SW operating temperatures to 70.2 *F for component cooling water (CCW) heat exchangers E-4B and E-5A, and 78.5 'F for CCW heat exchangers E-4A and E-53 to support design basis post-l LOCA condition heat removal capability. This was a change l
from FSAR Section 9.4.1 which assumed SW inlet l.
temperatures of 80 'F for E-4B and E-5A, and 90 *F for E-4A l'
and E-5B. As of August 30,1996, no safety evaluation had j
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. been performed for the change in SW operating temperatures.
(03023) i b.
On February 21,1997, Maine Yankee changed the layout within the protected area by installing and filling a 1000 gallon propane tank contrary to FSAR, Section 1.3, " Plant Description Summary." This addition had the potential to damage the circulating water (CW) pumphouse if it exploded, and could l
negatively affect both trains of the SW system since'the SW pumps are located in the CW pumphouse. As of March 5, 1997, no safety evaluation had been performed for the
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propane tank. (03033) j c.
On March 11,1997, a drain hose was temporarily installed on a spent fuel pool pump suction pipe which was contrary to the contiguration of the spent fuel pool cooling system as shown in plant drawings and the FSAR, Section 9.8, " Fuel Pool Cooling System.". As of March 15,1997, no safety evaluation had been performed for this change in the configuration of the spent fuel pool cooling system. (03043) d.
As of August 30,1996, no safety evaluation had been performed for approximately 89 equipment and procedure changes that were made to equipment and procedures described in the FSAR. These changes were identified by Maine Yankee as a result of an initiative to upgrade the FSAR and are listed in the " Final Safety Analysis Report (Revision
(03053)
B.
10 CFR 50.71(e) requires the licensee to update the FSAR to assure that the information included in the FSAR contains the latest material developed.
Updates must be filed annually or 6 months after each refueling outage. The updates must reflect all changes made in the facility or procedures as -
7 described in the FSAR up to a maximum of 6 months prior to the date of filing.
l Contrary to the above, as of August 1996, the FSAR was not updated to reflect 27 changes made to the facility as a result of Engineering Design Change Requests and Plant Design Change Requests that were implemented l
between 1980 and August 1996. These changes were identified by Maine Yankee as a result of an initiative to upgrade the FSAR and are listed in the
" Final Safety Analysis Report (Revision 13) Maine Yankee FSAR Update (MFU) Status Report." (03063)
These violations in Section lli represent a Severity Level lli problem (Supplement 1).
1 IV.
VIOLATIONS ASSOCIATED WITH INADEQUATE CORRECTIVE ACTIONS i
l 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires that measures shall be established to assure that conditions adverse to quality are j
promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
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A.
Contrary to the above, from October 31,1995, until August 16,1996, the inability of train 'A' of the control (CR) breathing air system to maintain a positive pressure in the control room during accident conditions was not corrected. Specifically, during testing of the 'A' train of the CR breathing air system on October 31,1995,in accordance with Surveillance Procedure 3.17.5, pressure in the CR was slightly negative. These test results indicated that the 'A' train of control room ventilation system (CRVS) was not operable, a significant condition adverse to quality. Maine Yankee did i
not take measures to assure that the cause of this condition was determined l
and did not take corrective actions to preclude repetition. No action was taken to restore operability of the 'A' train of CRVS prior to making the reactor critical on January 11,1996 contrary to Technical Specifications.(04013) l l
B.
Contrary to the above, as of August 3,1996, a significant condition adverse to quality identified in 1991 had not been corrected. Specifically, a loss of non safety-related instrument air could cause the air operated dampers (VP-A-56 and VP-A-57) in the containment spray building (CSB) fans' ducts to i
fail shut, rendering the fans (FN 44A and 448) incapable of performing their safety function of providing ventilation to the low pressure safety injection (LPSI) and containment spray pumps and heat exchangers area (i.e., by removing more than 10,000 cfm of air as specified in the Maine Yankee FSAR, Section 9.13.2.3)in the CSB. Without adequate ventilation, the LPSI l
and containment spray pump motors could fail due to overheating. This potential to lose CSB safety-related fans was identified during a ventilation system review by engineering in'1991 and was not corrected until August 3, 1996. (04023)
8 C.
Contrary to the above, between 1994 and 1996, actions to determine the cause and preclude repetition of icing and clogging of the CSB heating, ventilating, and air conditioning (HVAC) unit, HV-7, a significant condition adverse to quality, were inadequate. Specifically, the clogging occurred at least three times during that period, and even though corrective actions were taken, they were not effective in precluding repetition of the adverse.
condition. The clogging of the HVAC unit caused the CSB ventilation system (a support system for the LPSI and containment spray systems) to be inopersble, thereby potentially rendering both trains of LPSI and containment spray systems inoperable. (04033)
D.
Contrary to the above, as of August 30,1996, actions to determine the l
cause and preclude repetition of Auxiliary Feedwater (AFW) control system l
failures, a significant condition adverse to quality, were inadequate.
Specifically, repetitive problems between 1992 and 1996 resulted in.
degraded reliability for the AFW pump to respond to a start /run demand.
I Even though corrective actions were taken, they did not preclude repetition of the control system problems. (04043)
E.
Contrary to the above, as of April 1996, a design deficiency, which was a condition adverse to quality, involving the plant being outside of its design basis for a turbine hall flood, had not been promptly corrected. Specifically, during the Service Water System Operational Performance Inspection in 1994, Maine Yankee identified that the plant was outside of the design basis for a turbine hall flood in that during a design basis flood in the turbine l
building, safety-related equipment in the control room, the DG room, and the turbine building would be rendered inoperable. (04053) l F.
Contrary to the above, from December 20,1996 until February 21,1997, l
Maine Yankee did not promptly establish compensatory corrective actions i
regarding an identified condition adverse to quality that would challenge the l
operability of the SW system. Specifically, in a ventilation system assessment report, dated December 20,1996, Maine Yankee identified that a loss of ventilation in the circulating water pumphouse during periods of extreme cold temperatures, could create potentially freezing conditions for SW system components. Frozen water in stagnant lines could restrict flow to the SW pump bearings and gland cooling or create the potential for a line break, Compensatory actions to prevent freezing in the circulating water pump house were not taken until February 21,1997. (04063)
These violations in Section IV represent a Severity Level lli problem (Supplement 1).
V.
SEVERITY LEVEL IV VIOLATIONS TS (TS) 5.8.2.a requires, in part, that written procedures, as recommended in Appendix A of Regulatory Guide 1.33, (Rev. 2), February 1978, shall be established and implemented.
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A.
Regulatory Guide 1.33, Appendix A, section 1, " Administrative Procedures,"
l states, in part, that the maintenance of minimum shift complement; log l
entries; and authorities and responsibilities for safe operation and shutdown should be covered by written procedures.
l 1.
Contrary to the above, as of August 30,1996, Maine Yankee had not l
established procedural requirements, such that, in the event of a fire coincident with a medical emergency, the minimum control room staffing required by TS Section 5.2.2/ Table 5.2-1, would be satisfied.
Specifically, only two Senior Reactor Operators (SROs) were required i
to be on duty. As a result, there would be no SRO in the control room, as required, if the two SROs on duty had to respond to a fire and a medical emergency concurrently. (05014)
I This is a Severity Level IV violation (Supplement 1).
2.
Maine ' Yankee administrative procedure No. 1-200-10, " Conduct of Operations", section 4.13, " Operability Assessment," specifies that if there is not a reasonable expectation that the equipment is operable, then the equipment shall be declared inoperable. Section 4.13 also specifies that an operability determination must assess the ability of the equipment to perform its intended safety action in the accident environment it would be subjected to when it would be called upon to i
do so and that tests or partial tests should be used for completing operability assessments.
Contrary to the above, on August 17,1996, administrative procedure No.1-200-10 was not implemented in that the Operations Manager issued a memorandum that stated that TS testing disprepancies did not render the HPSI and containment spray swing pumps inoperable.
This was contrary to the requirements of procedure-1-200-10in that without performance of the testing that verifies that the pumps would perform their intended safety action when called upon, there was no reasonable assurance that the pumps were operable. (06014)
This is a Severity Level IV violation (Supplement 1).
B.
Regulatory Guide 1.33, Appendix A, section 9, " Procedures for Performing l
Maintenance," states, in part, that maintenance that can affect the l
performance of safety-related equipment should be performed in accordance l
with written procedures or documented instructions; that preventive maintenance schedules should be developed to specify inspection or replacement of parts that have a specific lifetime; and that general procedures for the control of maintenance should include the method for obtaining permission and clearance for work.
1.
Maine Yankee maintenance procedure 5-9-3, " Maintenance of f
Emergency and Auxiliary Feedwater Pumps," Rev. 4, section 6.3.11 i
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L 10 specifies the inspection of parts to determine if they are suitable for reuse. Maintenance procedure 5 9-3, section 6.3.12 and preventive maintenance (PM) card, M-18-3X-J, "P-25A Emergency Feedwater (EFW) Pump and Motor," specify performance of a liquid penetrant or magnetic particle examination of the cast iron diffuser assembly.
Contrary to the above, during the 1995 overhaul of the EFW pump P-25A, maintenance procedure 5-9-3 and PM card M-18 3X-J were not implemented in that no liquid penetrant or magnetic particle examinations were performed prior to reuse of the cast iron diffuser assembly. (07014) l-L This is a Severity Level IV violation (Supplement 1).
2.
Maine Yankee maintenance procedure 0-16-3, " Work Order Process,"
i Rev.10, Attachment A, section I.A specifies that work performed on l
safety class equipment must be performed in accordance with procedures that provide specific information for the intended actions.
Contrary to the above, as of August 7,1900 Maine Yankee failed to establish procedures that provided specific instructions to reinstall fastener lock wire as intended and, as a result, lock wire was not reinstalled after maintenance was performed on the following safety class equipment: Reactor coolant system loop No. 3 stop valve's motor operated valve actuator mounting fasteners and in-core instrumentation seal housings F-11, V-11, N-17, D-11, and T-16.
(08014)
This is a Severity Level IV violation (Supplement 1).
i
.3.
Maintenance procedure 0-16-3, sections 6.5 and 6.6 specify that, if l
necessary, equipment shall be tagged out prior to commencing work and that maintenance governed by this procedure shall not commence until the Work Order has received all required reviews and approvals.
Work Order No. 94-02278-01 for replacement of a pipe support specified that a white tagging order was required for SW pump P-29C to be out of service.
Contrary to the above, on August 13,1996, procedure 0-16-3 was l
not implemented in that maintenance personnel removed a seismically qualified pipe support on a seal water line for SW pump P-29C without a white tagging order being issued to tag the pump out of service. Removal of the existing pipe support caused the pump to be inoperable and; therefore, out of service. (09014)
This is a Severity Level IV violation (Supplement 1).
i.
11 Pursuant to the provisions of 10 CFR 2.201, Maine Yankee Atomic Power Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a
" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence,if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
j Because your response wit be placed in the NRC Public Document Room (PDR), to the j
extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or i
proprietary information is necessary to provide an acceptable response, then please provide I
a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at King of Prussia, Pennsylvania this 8th Day of October 1998