ML20246N743

Responds to NRC Re Violations Noted in Insp Rept 50-309/88-80.Corrective Actions:List of Plant Sys & Components,Ranked by PRA Risk Impact,Being Developed & Procedure Re Control of Vendor Instruction Manual Revised

ML20246N743
Person / Time
Site:	Maine Yankee
Issue date:	04/13/1989
From:	Whittier G Maine Yankee
To:	Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
GDW-89-137, MN-89-56, NUDOCS 8905190524
Download: ML20246N743 (7)

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3, I af i H . MaineYankee

, REUABLE ELECTRICITY FOR MAINE SINCE 1972 EDISON DRIVE .' AUGUSTA, MAINE 04330 .(207) 6224 868 h.;

l April 13, 1989 MN-89-56 GDH-89-137 United States Nuclear Regulatory Commission Region 1 475 Allendale Road

' King of Prussia PA'19406 Attention: .Mr. Robert M. Gallo, Chief Operations Branch Division of Reactor Safety

References:

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

(b) USNRC Letter to Maine Yankee dated January 20, 1989 -

Inspection Report No. 50-309/88-80 (c) Maine Yankee Letter to USNRC dated February 21, 1989 -

Response to Notice of Violation, Inspection Report 50-309/88-80

Subject:

Response to Inspection Report 50-309/88 Maintenance Gentlemen:

Reference (b) reported the results of a special maintenance team i,-nspection of Maine Yankee. The report contained a Notice of Violation to which Mdine Yankee responded in reference.(c). The report also documented

{ome aEeas of identified weaknesses in our Maintenance Program. Our response to; those areas of identified weaknesses is attached. He plan to take a more cletailEd look at the entire report over the next several' months to ensure that the strengths mentioned are institutionalized and that the weaknesses are r:emedifed.

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l 8905190524 890413 P i PDR ADOCK 05000309 L i

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MaineYankee United States Nuclear Regulatory Commission Page Two Attention: Mr. Robert M Gallo MN-89-56 Should you have any questions on our respense to this issue,'please contact us.

Sincerely, MAINE YANKEE khbV G. D. Whittier, Manager Nuclear Engineering and' Licensing GDH:CLB

Attachment:

Response to Identified Heaknesses - 5 Pages c: Mr. Richard H. Hessman Mr. Hilliam T. Russell Mr. Patrick M. Sears Mr. Cornelius F. Holden 4

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MaineYankee ATTACHHENT Resoonse to Identified Heak.nesses*

(*As Stated in Appendix B of Reference (b), '

"A potential problem or condition presented for licensee evaluation and action as applicable".)

Heakness II.4.2 - Implementation of the system engineer concept Maine Yankee Resoonse A " System Expert" concept is being developed at Maine Yankee through the Operations Department. This concept was identified to the NRC inspection team by Maine Yankee management, in the course of the inspection. The

" System Expert" Program has been established as a Quality Improvement Program initiative and is to be implemented in 1989. p L

The focus of the System Expert Program is to develop " experts" in plant systems with responsibilities to assess system performance and operational I status on a periodic basis. A concept of the program is that system experts would interface with the Engineering Department as appropriate, e.g., for problem investigation and design changes. Also, system experts would be technically qualified individuals and, in most instances, degreed engineers. These personnel would have received training in the operating systems of the plant and in plant operations.

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Heakness II.4.3 - No PRA considerations incorporated into the maintenance process liaine Yankee Resoonse Maine Yankee is developing a listing of plant systems and components, ranked by their (PRA) risk impact; this listing should be developed by May 31, 1989. A standardized method to incorporate PRA into the maintenance process of work prioritization, planning and scheduling will be implemented approximately ninety days after development of this listing.

Heakness II.4.7 - Need to consider NRC Information Notice 87-66 in a review of practices for procurement and use of commercial grade Agastat relays Maine Yankee Resoonse Maine Yankee has upgraded its procurement practices and procedures to conform with the EPRI document " Guidelines for Utilization of Commercial-Grade Items in Nuclear-Safety Related Applications", NP-5652.

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MaillBYallhee ATTACHMENT (Continued) l In adc1 tion, Maine Yankee is developing a plant relay database which will identify relays, including Agastat 7000 series relays, in use at the plant in safety related applications . The Agastat relays will be evaluated for projected qualified life as indicated by the Information Notice. He plan to complete this evaluation before the 1990 refueling outage. The Maine , t Yankee NPRDS database does not indicate any abnormal problems with our L Agastat relays to date.

Weakness II.5.1.4 - ----

(a) Lack of a clear method to identify the applicable vendor manual for instruments having the same model number but differing dates of manufacture (also see 5.1.3) ..

(b) No independent review of instrument calibration set points developed by I&C (also see 5.1.3)

Maine Yankee Resoonse (a) He plan to revise Maine Yankee Procedure 0-06-7, " Control of Vendor Instruction Manuals" by June 31, 1989 to provide a method for identifying the applicable vendor manual for instruments having the same model number but differing dates of manufacture. ,

(b) An engineered calibration setpoint document is presently being developed for all Class 1E loops. The setpoint document is expected to be issued before the 1990 refueling outage.

Additionally, we plan to implement procedural controls for independent review of instrument calibration setpoint changes by December 31, 1989.

Heakness III.5.4 - Need to provide additional information on work orders Maine Yankee Rgiponse He plan to conduct a multi-disciplined review of Maine Yankee's work control system. This review will include an evaluation of this reported weakness. He plan to complete this review and provide recommended work ,

control system enhancements to management by December 31, 1989.

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MaineYankee

, ATTACHMENT (Continued)

Heakness III.5.5 - Lack of standardized work priority system including identification of PRA significant equipment Maine Yankee Note:

This weakness has two parts, as further identified in the text of the NRC Inspection Report:

1. "...The first was that it appeared that the licensee had not performed an overall evaluation to determine which components or systems should be assigned a particular priority. The priority determination is performed case by case based on the judgement of operations supervision. Areas that may be considered in such an evaluation are EQ (Equipment Qualification components), seismic qualifications, Technical Specification, and safety significant (B0P and NSSS) equipment... Additional management attention appears warranted to the provision of a standardized priority system".

2. "

...The second weakness is that the licensee did not appear to have a method for identifying the systems or components that have a PRA significance (during the prioritization process)".

Maine Yankee Resoonse

1. Maine Yankee's current work prioritization process is based on the actual or potential impact of the reported condition on the plant.

Currently, the Plant Shift Superintendent (PSS - the senior licensed individual on shift) is charged by procedure to " establish and document the work priority number" for discrepancy reports. The PSS is provided with pre-established criteria which provides prioritization guidance, including considerations such as is suggested in note 1, above. This prioritization guidance has been developed under management direction and has management concurrence. With the exception of PRA input (see 2, below), Maine Yankee management considers that the current work prioritization system at Maine Yankee is appropriate, adequate, and not in need of change.

2. Incorporation of PRA considerations into the maintenance process (including work prioritization) is discussed in the response to Identified Heakness 11.4.3.

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, ATTACHMENT

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t[eakness III.5.8 - Inadequate technical guidance in I&C non-RPS maintenance procedures and drawings (also see 5.1.3)

Maine Yankee Responsa 1

An Instrumentation and Controls-(I&C) generic procedure will be developed I and implemented by December 31, 1989. This procedure will provide an k adequate level of detail and control, when used in conjunction with I&C preventive maintenance forms. )

1 The Inspection Report noted, in Section 111.5.1.3, that: 4

...The inadequacy of the drawing (in question) was discussed with the licensee and it was determined that the drawings are inadequate in some situations. Further discussions with the licensee established that the drawings are in procec'; of being upgraded".

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Maine Yankee believes that implementation of the above procedure coupled with our own initiative to upgrade Class IE loop drawings should be sufficient to resolve this issue.

Weakness III.6.4 - Need to improve the trending and failure analysis efforts (also see 4.2 and 5.3)

Maine Yankee Resoonse He believe that computerized integrated data management is the most feasible method to capture trends and enhance our assessment capability.

A pilot project has been implemented and a Computer Resources Steering Committee chartered. This committee will evaluate the requirements for a comprehensive maintenance history record system including trending and retrieval of historical data. These first steps could lead to computerization of tracking and trending on a system, part and manufacturer level.

The initial evaluation will be completed by December 31, 1989. )

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MaineYankee

. ATTACHMENT (Continued)

Weakness III.7.1 - Location of tne machine shop within the radiological controlled area Maine Yankee Resoonse He understand that the concern involves clean material being brought into a potentially contaminated environment with the possibility of contaminating clean material. In addition, workers may be unnecessarily exposed to radiation.

c There has been no cross-contamination to the clean side of the plant, originating from the RCA shop, in more than a decade. In addition, the radiation fields in the.RCA shop are essentially background. Large machining requirements are conducted by off-site machine shops. Though the above mentioned potential exists, it.does not seem to justify the expenditure for tooling the clean side shop.

Maine Yankee is not currently planning tooling of the clean side machine shop for full scope inachining capability. Large machining requirements are customarily conducted by off-site machine shops.

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