ML20209H278
| ML20209H278 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/15/1985 |
| From: | Whittier G Maine Yankee |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 6512L-GDW, GDW-85-259, MN-85-177, NUDOCS 8511110060 | |
| Download: ML20209H278 (9) | |
Text
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4 MAmE HARHEE AMMICPOWERCOMPARSe nuousrlT'a0o"Esl kh (20D 623c21 October 15, 1985 MN-85-177 GDW-85-259 g
Region I United States Nuclear Regulatory Commission Office of Inspection and Enforcement 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention:
Dr. Thomas E. Murley, Regional Administrator
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) MYAPCo Letter to USNRC dated September 13, 1985 (MN-85-164)
Subject:
Inspection Reports 85-19 and 85-27 Gentlemen:
In response to the events described in IE Inspection Reports 85-19 and 85-27, Maine Yankee determined that a comprehensive corrective action program was warranted. The essential elements of this program were outlined in Reference (b). As we developed the details of our program we found that, in several instances, the exact nature of the corrective actions which we felt were appropriate changed from what was originally contemplated.
The actions taken or planned as a result of each of the program elements of Reference (b) are attached.
These actions meet our original objectives to correct the problems identified in the subject reports, ensure similar prot'lems do not exist and ensure similar problems do not occur in the future.
Our completed program will be reviewed by the Plant Operations Review Committee to ensure that the corrective action program objectives have been met and the plant can be safely returned to power operation.
We have discussed our program in some detail with representatives of your staff. We understand that they do not have any outstanding questions regarding this matter.
Very truly yours, MAINE YANKEE ATOMIC POWER COPANY bhW G. D. Whittier, Manager Nuclear Engineering & Licensing GDW/bjp
Attachment:
8511110060 851015 cc: Mr. Edward J. Butcher, Jr.
PDR ADOCK 05000309 G
Mr. Cornelius F. Holden 1
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y MAINE YANKEE ATOMIC POWER COMPANY 4-IE INSPECTION REPORT 85-19 STATUS
/1.
Commitment:
- Verify as open, all root valves (202) associated with instrumentation identified in T.S. Tables 4.1-1,
-2, and -3.
Status:
All root valves associated with instrumentation identified in Technical-Specification Tables 4.1-1, 4.1-2, and 4.1-3 have been physically verified
.to be open. No other valves were found to be improperly positioned. All root stop' valves will again be verified to be open prior to plant startup. Documentation of root valve position is available on site for review.
2.--Commitment:
Incorporate all root valves identified in (1) above into appropriate operating procedures to ensure that they are open and verified to be open prior to startup from each refueling outage.
Status:
All root valves have been verified to have been covered by plant startup procedures or they have been added to such procedures.
3.
Commitment:
Verify that appropriate administrative controls (procedures) exist on all isolation valves associated with instrumentation identified in (1) above.
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Status:
Procedures governing the positioning of instrument isolation valves have
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been reviewed. These procedures have been determined to adequately control the positioning of isolation valves associated with Technical Specification 4.1 instrumentation.
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. 4.
Commitment:
Review all special tests and temporary procedures prior to use to ensure that each valve' position is individually.specified when realigning systems, status:
' All'special tests and temporary procedures which are in effect have been reviewed to ensure that each valve position is individually specified when realigning systems.
5.
Commitment:
Revise the. generic procedures governing the preparation and review of proce&res to ensure valve positions are individually specified when realigning systems.
Status:
Maine Yankee procedure 0-06-l'" Procedure Preparation, Classification and Format" has been modified to require that procedures, which involve the repositioning of valves, specify the correct final or "as left" position of each valve.
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rp MAINE YANKEE ATOMIC POWER COMPANY IE INSPECTION PEPORT 85-27 STATUS J6.
Commitment:
Redesign the.Subcooled Margin Monitor (SW ) circuitry to eliminate the
.comon connection.
Status:
The'subcooled margin monitor (SW) has been redesigned to eliminate the common connection in the selector switch.
This design change has been installed..
- 7. ~ Commitment:-
' Review all previous design changes which involve or could interact with
- the safety instrumentation systems-listed in T.S. Tables 4.1-1, -2, and -3.
Status:
. Yankee Nuclear Services Division (YNSD) has performed this review. All previous ~ plant design changes, including those being implemented this outage, were screened by a Yankee NSD Principal I&C Engineer.
This screening eliminated from further review design changes that obviously had no interface with instrumentation systems listed in Technical Specification Tables 4.1-1, 4.1-2, and 4.1-3.
The results of this screening were independently confirmed by another Yankee NSD I&C Senior Engineer.
The remaining list of design changes were considered to have the potential for interaction with Technical Specification 4.1 instrumentation. This list, consisting of 127 design changes, was then subjected to an engineering review to identify those design changes that interacted with Technical Specification 4.1 instrumentation and to confirm that interface requirements were met. This review was conducted to a procedure prepared in accordance with the YAEC Engineering Manual. The review was conducted by a REVIEW TEAM comprised of five YNSD Electrical and I&C Engineers and one I&C Engineer from Stone and Webster.
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. As a result of this review, it was determined that sixty-five (65) design changes actually interacted with Technical Specification 4.1 instrumentation. The detailed review of those design changes assured that they did not adversely affect the ability of the Technical Specification 4.1 instrumentation to perform their intended safety function. No other instances of improper design were discovered during the design review.
The results of this review have been documented and are available at the YNSD offices and at the Maine Yankee site for review.
8.
Commitment:
Provide an independent design review of all of the design changes identified in (7) above.
Status:
Maine Yankee contracted with Combustion Engineering to perform an independent review of design changes associated with instrumentation systems listed in Technical Specification Table 4.1-1 (Reactor Protective System), and with Combustion Engineering and Stone and Webster Engineering Corporation to perform an independent review of design changes associated with instrumentation systems listed in Technical Specification Tables 4.1-2 and 4.1-3.
Personnel who performed the initial review were not involved in the independent review.
The sixty-five design changes which were identified as interacting with Technical Specification 4.1 instrumentation during the YNSD review (Item 7 above) were subjected to this independent review.
In addition, eight other designs, which had been determined to have no interaction with Technical Specification 4.1 instrumentation, were also independently reviewed.
The independent review was performed in accordance with the YNSD design review procedure (see Item 7).
The results of the review were documented and are available for review in the YNSD offices or at the Maine Yankee site.
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.. The independent review confirmed that the design changes had not adversely affected the ability of the Technical Specification 4.1 instrumentation to perform their intended safety function.
9.
Commitment:
Develop functional test requirements that are more comprehensive for all systems identified in (7) above that have been significantly modified since the issuance of the facility operating license (1972), including those undergoing modification during the current outage.
Status:
The Maine Yankee safety snalyses were reviewed in order to identify assumptions which had been made relative to Technical Specification 4.1
. instrumentation. These assumptions were documented and were used as requirements for the functional tests discussed below in Item 10.
These functional test reqJirements are available at the Maine Yankee site for review.
- 10. Commitment:
Provide documented assurance that the functional test requirements identified in (9) above have been previously satisfied, and no further modifications have been performed, or perform new comprehensive functional tests to satisfy the applicable requirements.
Status:
As described in Item 9 above, functional test requirements were developed for each instrumentation system in Technical Specification Tables 4.1-1, 4.1-2, and 4.1-3.
These functional test requirements were compared with existing I&C calibration procedures associated with each instrumentation system, to determine whether the existing procedures adequately addressed the test requirements. If necessary, the existing procedures were modified or new procedures were written.
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}s L An independent rev1Nw.was cch$sted to. ensure that each functional test-I requirement was being explicitly addressed by the functional tect program.- In addition, a special PORC subcommittee.was formed to review the testeprograf6 procedures.- The" subcommittee was charged with ensuring t
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- that thejfunctional test requirements were comprehensive and that the test programpi$cedures*wereabequate.;Theresultsofthesubcommitteereview were prede7: tied to the full committee.
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. Functional testing is currently in progress and will be completed prior to s
plant startup'.
The,t' sting of each system in T.S. Table 4.1 is being e
a performed following completion of any modifications planned for this outage.. Each completed functional test procedure is being reviewed by the Functional Test Program Manager and the I&C Section Head. To date, one minor wiring disciepancy and several procedural discrepancies have been identified. Any haldware discrepancies shall be resolved prior to plant startup. We plan to develop resolutions for discrepancies affecting existing surveillance procedures and submit them to the Staff within a month following plant startup.
y Documentation of the completed functional test program will be available I
on site for review.n-e I
- 11. Comitment:
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Revise the EDCR procedures to specifically identify instrumentation lead "commoning" as requiring special design review emphasis.
, la Status:
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7 i
The design input' list contained in Waine Yankee Procedure 17-2I-2,
" Engineering Design Change Request - Maine Yankee" and the design verification list contained in Procedure 17-21-6, " Design Verification" have been revised to direct the Sesigner and design reviewer to specifically look for instrumentation and control circuit common points and to 'd$termine whether they could degrade the operation of each affected circuit or system for which the loops provide an input. YNSD has made similar changes to their des,ign control procedures.
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. 12. Commitment:
Revise the QA procedures to require that a comprehensive functional test be performed on modified circuits including any associated circuits that may be affected.
Status:
Maine Yankee Procedure 0-06-3, "Preoperational, Operational, and Special Tests and Experiments" has been revised to require a comprehensive functional test to be perforned on modified electric circuits, including instrumentation and control loops, and any associated loops or circuits which could be affected. The test is required to verify that the intent of the-design change is met, and th at associated electrical circuits are not degraded or their function inappropriately affected.
YNSD design procedures have been modified to emphasize that functional test requirements must be identified.
- 13. Commitment:
Revise the EDCR procedures to require a second independent design review of all EDCR's associated with instrumentation identified in (7) above, with particular emphasis to detecting sneak or interactive circuits.
Status:
Maine Yankee Procedure 17-21-2 " Engineering Design Change Request - Maine Yankee" and 17-21-3 " Engineering Design Change Request - YNSD" already require an independent review of all EDCR's and a second independent review of Design Grade 1 changes (includes all changes to Table 4.1
' instrumentation). Maine Yankee Procedure 17-21-6, " Design Verification" was modified to direct the design reviewer to pay particular attention to detecting circuit interconnections such as sneak circuits common points and grounds and to determining whether the interconnections which are identified could degrade the operation of the affected circuit or systea(s).
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,'e o-14. Commitment:
Revise the procedures governing design change implementation instructions to provide an independent review to ensure that the functional test requirements are appropriately comprehensive.
_ Status:
Maine Yankee Procedure 0-06-3, "Preoperational, Operational, and Special Tests and Experiments" has been revised to require a comprehensive functicaal-test to be performed on modified electric circuits (see Item 12). Maine Yankee Procedure 17-23-1, " Design Change Implementation Instructions" requires that instructions for functional tests be developed in accordance with Procedure 0-06-3 and that a review be performed to ensure that the instructions are complete and meet applicable requirements. Procedure 17-23-1 has been modified to require that functional tests be comprehensive so as to ensure the intent of the design change is accomplished and no unintended system (s) interaction is introduced.
The YNSD design procedures have been modified to ensure appropriate functional testing requirements are co, sidered during design reviews.
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