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U.S. NUCLEAR REGULATORY COMMISSIONREGION I '

Iteport 92-20 License DPit-36 .

Inspection At: Maine Yankee Atomic Power PlantWiscatet, Maine(Maine Yankee Atomic Power Company)

Conducted: October 15 through November 19,1992

Inspectors: Charles S. Marschall, Senior Resident InspectorWilliam '. Olsen, Resident Inspector

/A|[f 2-WApproved: s' _

wW. [<{$7artkflief, Reactor Project Section 3B Date.

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SCOPE

Resident inspection of operations, radiation protection, rnaintenance/ surveillance, security,engineering / technical support, and safety assessment / quality verification.

OVEl(VIEW

Operations Overall, operators insured safe piant performance. A Plant Shift Supervisoradequately determined operability for a leaking feedwater check valve. He also recognizedareas for improving the timeliness and quality of the operability determination.

Radiological Controls in response to a medical emergency drill, plant staff dealt compe ;ntlywith the postulated event, and proficiently controlled the spread of simulated contamination.

Maintenancs ana Surveillancs hant staff demonstrated good control of repair and testactivities. An electrician insured a high degree of quality during Motor Operated Valvemaintenance, and an auxiliary operator properly completed and documented surveillance of anemergency feedwater pump. Maine Yankee's control of scaffolding it,sured that scaffoldingdid not adversely affect safety related equipment. -

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Srsyrity The security staff efficiently controlled access for ambulans *rsonnel during theMedical Emergency drill.

: Engineering and Technical Suonort In responding to a long history of problems with the ,'

Containment Control Air system, Mair.c Yankee initiated a systematic approach to improvingsystem reliability. Corporate Engineering Department personnel provided significant-assistance during maintenance on a safety related MOV.

Safely _ Assessment and Ouality Verification Inspectors closed an open item associated with.,

"mideop operation.

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9212160081 92120e., "PDR ADOCK 05000309G PDR }

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TABLE OF CONTENTS

OV E R V I EW ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -i_. . . . . . . . . .. .

TA B LE OF CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , , - ii

1. OPERATIONS l'.. ........................... . . .....

l.1 Operability Determination for Feedwater Valve FW-331 . . . . . . . . . . . 1

"2. RADIOLOGICAL CONTROLS . . . . . . . . . . . . . . . . 2. . . . . . . .. . .

. .. ... - 2.12.1 Radiological Controls for the Medical Emergency Drill . .

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3. M AINTENANCE and SURVEILLANCE 2. . . . . . . . . . , . . . . . . .

3.1 Motor Operated Valve (MOV) Maintenance . . . . . . . . . . . . . . . . . -2.

3.2 Emergency Feedwater Pump (P-25C) Surveillance . . . . . 3. . ....

3.3 Control of Scaffolding . . . . . . . . . 3. . . . . . . . . . . . . . ......

4. SECURITY -4........ ....................... . . . ....

4.1 Security Force Participation in Medical E.nergency Drill . 4. . . ..

4.2 (Closed) Violation 92-014-001, Inattention to Duty 4. . . . . . . ......

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5. ENGINEERING and TECHNICAL SUPPORT . 5. . . . . . . . . ...

5.1 Comainment Control Air . . . . . . 5. . . . . . . . . . . . . . . .....

5.2 Engineering involvement in MOV Maintenance 6-. . . . .. .

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6. SAFETY ASSESSMENT and QUALITV VERIFICATION 6. . . . . . .... .

6.1- (Closed) Open Item 91-17-03, Venting of the Reactor Coclant SystemDuring Mid-Loop Operation , , 6-............. . . .... .

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7. A DMINISTRATIVE , . . . . . . . . . . . . . . . . , , . 7. . . . . . . . . .,

7.1 Persons Contacted 3..... 7.. .. . . . . . . . . .

7.2 Summary of FOlity Activities 1.. . . . . . . , . . . . . . ...

7.3 Interface with the State of Maine 47. . . . . . . . . , .. .

7.4 Exit Meeting 7..... . ... . . . . . . . ..

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DETAILS ;

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1. O PI'R ATIONS l

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On a daily basis, inspectors verified adequate staffing, appropriate access control, adherence

| to procedures and Limiting Conditions for Operation, operability of protective systems, status; of control room annunciators, status of radiation monitors, emergency power source

operability, and operability of the Safety Parameter Display System (SPDS). Each week, the o

inspectors veriGed operability of selected Engineered Safety Features (ESF) trains and

I assessed the condition of the plant equipment, radiological con /ols, security and safety. The ,

o inspectors performed biweekly review of a safety-related tagout, chemistry sample results,shift turnovers, portions of the containment isolation valve lineup, the posting of notices to jworkers and operability of selected ESF trains. The inspectors evaluated plant housekeeping !

and cleanliness.

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1.1 Operability Determination for Feedwater Valve FW-33J _ |'|

| On October 27, during a routine containment inspection, plant staff found FW-331, a; fen! water check valve, leaking steam through the insulation moped around the valve The

statf initiated Work Order (WO) 92-6107 to address the leakage. The Plant Shift Supervisor(PSS) tecognized that FW-331 leakage was a potential containment integrity concern as it is a ;containment insolation valve,

| |The containment boundary, for the fe:dwater system, is formed by the feedwater hnes made|

centainment acting as a membrane, and feedwater check valves in each of the feedwater lines(FW-131, 231, and 331). The check valves provide a means of isolating the feedwater linesfrom the containment atmosphere. In the event that any er the check valves becameinoperable, Technical Specification (TS) 3.11 requires Maine Yankee to restore the

| inoperable valve to operable status or isolate the penetration within 'four hours. Technical| Specifiuenn 3.3. A.2 requires operation of three coolant pumps with their steam generators

capable or performing their heat *.ransfer function whenever the reactor is critical. Therefore,an inoperable feedwater containment isolation check valve would require operators to isolate

| feedwater to a steam generator and to begin a plant shut down within four hours.|

The PSS consulted with the Plant Engineering Department (PED) to develop a basis for anoperability determination. The PED staff concluded that the valve cemained operable, based

L on a history of leakage for similar valves. Six identical valves. had developed leaks on eight.-| previous occasions. Each leak path had been through bolted, gasketed flanges in the valve

body. Engineering reasoned that the leak in FW-331 probably came from gasket leakage at, the body-to bonnet or hinge pin cover flange. Based on engineering input, the PSSL considered FW-331 operable.

On October 28, however, when questioned by the inapector, the PSS was somewhat

| uncomfortable with the engineering basis, since it depended on an assumption of the source| of the leak. The PSS realized that the source of leakage night have been a weld failure

L upstream of the valve seat, rendering the membrane inoperable. Later that day, in response

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to the WO initiated on October 27, plant staff removed the insulation and confirmed that agasketed flange was the source of the leak. The PSS also documented that, based on -conservative estimation of feedwater leakage, the leakage from containment through FW 331,under accident conditions, would not exceed leakage assumed in the accident analysis.

The PSS concluded, in-retrospcci that he could have improved the timelinessi ad quality of -the operability determination by immediately requesting that maintenance personnel removethe insulation to identify the source of the leakage.

2. IRADIGI,0GICAL CONTitOLS,

inspectors routinely reviewed radiological controls including Organization and Management,-extcrnal radiation exposure control and contamination control. The inspectors also monitoredstandard industry radiological work practices, and conformance to radiological controlproceduies and 10 CFR 20 requirements.

2.1 Itadiological Controls for the Medical Emergency Drill

On No < ember 5, Maine Yankee conducted a medical emergency drill. The drill scenatioinvolved -injuries to a worker in the radiologically controlled area (RCA). Emergencyresponse personnel administered emergency first aid, and effectively implemented proceduresto minimize spread of contamination from the RCA. Operations, radiological controls-technician.e, and security staff responded to the simulated emergency. Drill observersincluded supervisors from several departments. The response team dealt competently with thepostulated event, and demonstrated proqciency in emergency medical and contamination

- control procedures.

3. MAINTENANCE and SUltVEILLANCE

The inspectors observed and reviewed maintenance and problem investigation activities toverify complian.;e with regulatioas, administrative and maintenance procedures, codes andstandards, proper QA/QC involvement, safety tag use, equipment alignment, jumper use,personnel qualifications, radiological controls for _ worker protection, retest requirements, andrepouability per Technical Specifications.

3.1 Motor Operated Valve (MOV) Maintenance-

On November 4, an electrician replaced the limit switch rotors in the motor operator for high'pressure safety injection valve HSI-M-5L The electrician used work order (WO) 9MO51,-to

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'control the switch replacement. Although operators initiated the WO toxorrect faulty non- <

'safety related position indication in the control room, replacement of the limit switch totors _.

also affected safety 4 elated valve functions. Plant staff closed and dectrically isolated the-

talve prior to beginning the maintenance activity, ard appropriately entered the action yi

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statements of Technical Specifications 3.B and 3.C.2. The electrician replaced the rotors inthe motor operator actuator, and adjusted the limit switches using procedure 5-18-1,Limitorque Limit and Torque Switch Adjustment and Checkout, revision 8.

The electrician carefully adhered to the mai".tenance instructions contained in the work ordertechnical instructions and procedures. In several instances, he stopped work to obtainclarification of procedure steps, and in one instance initiated a procedure change to correct aninaccuracy in the procedure for initial limit switch adjustment. The electrician carefully.

- documented completion of the maintenance activity, paying particular attention to approp :teuse of "Not applicab'a in compiming the procedures. He expended extra effort in ensuring

i quality in the activity, beyond tL cequirements of the procedure, to ensure proper _

_ de-tern.ination and re-termination of the limit switch electrical leads.

The electrician's efforts to ensure high quality maintenance of a safety related component'

F demons' rated strong motivation to insure a high quality maintenance activity, in addition, theelectrician's concerted effort to use and adhere to procedures indicates improved performaacein tlus regard.

3.2 Emergency Feertwatcc Pump (P-25C) Surveillance

On November 2, plant staff performed the monthly surveillance of P-25C as required byTechnical Specification 4.6.B. The plant staff performed the test as required by procedure3-1-5.4, Emergency Feed Pump P-25C Test, resision 1, with acceptab'e results,

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demonstrating operability of the emergency feedwater (EFW) gump and the associated. auxiliary shutdown panel EFW controls. -

After completion of the surveillance, the inspectors independently verified that operatorscorrectly restored EFW alignment.for normal operation. In addition. the inspectors reviewed

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_ the completed procedure to verify that it adequately ccurolled the activity, and that operatorsadhered to the procedure and properly documented performance of the test.

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3.3 Control of Scaffolding

' Maintenance staff instahed scaffolding to faciiitate repair or the FW-331 leak. Mainicnancepersonnel used procedure 24-103-l, Scaffolding Safety, revision 2, to control the scaffolding

y installation. The inspector reviewed the procedure to insure that Maine Yankee had adequatecontrols in place to prevent an adverse impact ou plant or personnel safety from theinstallation of scaffolding. The procedure requires that plant staff secure stationaryscaffolding to a building or structure at intervals not to exceed 30 feet horizontally and 26feet vertically to prevent movement or tipping, requires Plant Engineering Department (PED)approvai prior to attaching scaffolds to any system or equipment. and that PED conduct aseismic evaluation prior to building scaffo!ds on or around safety related equipment.

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Maine Yankee uses the Work Order (WO) process to implement procedure 24103-1 when amaintenance activity requires construction of scaffolding. The mechanical maintenance -section head indicated that maintenance personnel have responsibility to notify PED wheninstalling scaffolding on or around safety related equipment. The inspector noted, however,that responsible maintenance personnel may not have training to enable them to recognizesafety related equipment. The maintenance department sation head mplemented a .temporary change to the WO process to insure that PED evaluates all scaffolding instructionuntil a permanent measure can be implemented to address the weakness in ' control ofscaffolding.

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The Plant Engineering Department aggressively pursues evaluation of scaffolding, frequentlyinitiating communication with maintenance personnel. The maintenance staff routinelyimplements measures to present movement or tipping of stationary scaffolding regardless of .its proximity to safety related equipment. Although the scaffolding control process had a' fewminor areas for improvement, conservative implementation of the process insured thatinstalled scaffolding did not adversely impact safety related equipment.

4.. SECURITY

The inspectors veri 6ed that security conditions met regulatory requirements, the requirementsof the physical security plan, and complied with approved procedures. The checks includedsecurity staf6ng, protected and vital are: Sarricrs, vehicle searches and personnelidentification, access controi, badging, and compensatory measures when required. No,

discrepancies were identified.,

4.1 Security Force Participation in Medical Emergency Drill

As discussed in section 2.1, above, on November 5, Maine Yankee conducted a medicalemergency drill. The scenario called for transportation of a contaminated worker offsite fortreatment at medical facility. Following the requirements of security orocedures, the security '

staff admitted the ambulance and medical personnel into the turbine hall'to retrieve the plant-

worker with simulated injuries. Security staff ef6ciently permitted ent_ry to the plant while,

maintaining the security requirements. The security shift supervisor oversaw the evolutionand effectively directed the response of guard force personnel, and senior securitymanagement monitored the effectiveness of the guard force.

4.2 (Closed) Violation 92-014-001, Inattention to Duty

The inspector observed a Naine Yankee security of6cer inattentive to duty at his post during.deep back shift inspection on August 28,1992. Maine Yankee immediately replaced theofficer and placed the officer on administrative leave pending the outcome of aninvestigation. Based on the investigation, Maine Yankee concluded that the inattentiveness,

was an isolated problem associated with the officer's general performance. No other

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-instances of inattentiveness have been noted, and Maine Yankee had adequate measures inplace to mitigate the effects of fatigue on the security staff. As a result of the officer's-performance problems, Mainc Yankee terminated his employment. '

Maine Yankee discussed the occurrence with the entire security force and reiterated theseverity if this siteation and the seriousness of being inattentive to duty.

The inspector concluded that Maine Yankee took appropriate immediate and long termcorrecti"e actions. This item is closed.

5. ENGINEERING nnd TECIINICAL SUPPORT,

5.1 Contninment Control Air

The containment control air (CCA) system consists of two independe,it trains of reciprocatingair compressors, receiver tanks, aftercoalers, 61ters, and refrigerant type dryers located insidecontainment. These components supply 100 psi air to independent headers serving air loadsincluding blowdown trip valves, duct dampers, letdown control valves, and reactor coolantpump motor air cooler primary component cooling trip valves. Maine Yankee has'

experienced numerous difficulties with the CCA system since initial plant startup. Loss ofcontainment control air, with no operator actior., would result in a plant trip on highpressuriter pressure, due to isolation of the letdown control valves, and might eventually-result in damage to the reactor coolant pump motors and seals, leading to a loss of coolant

| acident. Loss of CCA with operator action requires immediate operator response to restoreL air pressure. On many occasions, failure of the standby compressor to restore pressure

reqtared emergency cortainment entry. Inability to start the standby compressor or restart thetripped compressor can be mitigated by opening normally closed containms aclatis *i valvesto cross-connect the service air header, outside containment, with the CCA syaem.However, opening the containment isolation valves requires entry into the containmentintegrity Technical Specification Limiting Condition of Operation, and would require a plant i

shutdown within four hours, if the isolation valves could not be re closed sooner.

Recently, plant management initiated a coordinated effort to wdyze CCA nerformance andimprove reliability. Plant htaff completed a rigorous analysis of the history of problems withthe CCA system. The analysis concluded that contaminants in the air system have interferedwith discharge valves, unloading suction valves, pilot valves, ad small instrument lines.The analysis found that contaminants accumulate in the receivers, then migrate Lack to thecompressors where they interfere with suction and discharge valve assemblies. In addition,plugged or stuck open float pilot valves caused moisture trap malfunctions.

The analysis recommended removing all sources of contaminants by upgrading equipment inthe air flow path. Specifically, the analysis recommended installing replacement air receiverswith manways to permit preventive maintenance. In addition, the analysis recommended,

! improved monitoring of v :ompressor performance, increased frequency for preventive

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maintenance, and proposed several other possible courses of long term m. tive action. - At-the conclusion of the inspection report, the Plant Engineering Departn :m vas dueloping aclose out plan for management consideration.

The systematic approach to resolution of e long history of poor containment control airsystem performance represents an improved focus on long terni reliability by the . ,meeringand maintenance organizations.

5.2 Engineering involvement la MOV Maintenance.

During the MOV maintenance, described in section 3.1, above, Corporate EngineeringDepartment (CED) personnel observed and contributed to the maimenance activity. TheCED enginects supplied clarincation of limit s'vitch adjustments, and assisted the electricianin verifying that electrical leads were properly re-terminated. In one instance, however, aCED engineer proposed to change a limit switch setting specification by making a change tothe speciScation sheet during the ,naintenance activity. When the inspector noted that atechnical evaluation justified the limit switch settings, the engiacer stopped the maintenanceactivity, revised the technical evaluation, and obtained the necessary review and approval.Althrigh the engineer initially overlooked the required review for the setting sheet change,overall, the CED personnei provided significant assistance to maintenance in restoring -HSI-M-51 to reliable condition.

6. SAFETY ASSESSMENT and QUALITY VERIFICATION

6.1 (Closed) Open item 91-17-03, Venting of the Reactor Coolant System DuringMid-Loop Operation

in September 1991, an NRC inspector evaluated Maine Yankee's response te Generic Letter88-17, Loss of Decay Heat Removal. The Generic Letter (GL) discussed loss of decay heatremoval during non-power operation and recommended that licensees pro Je short termexpcaitious actions and long term programmed enhancements t > resolve Le issue.

The inspector found that Maine Yankee had not included a provision to vent the reactorcoolant syaem (RCS) in a procedure for mid-loop operation. Maine Yankee n anagementstated their intent to include a vent path requirement in the station procedure prior to the nextrefueling outage.

.The inspector reviewed station procedure 1-17-7, Lowering Reactor Vessel Level From (19') .to (15') for Maintenance Work, revision 8, dated April 8,- 1992. Step 7.2.21 requires thatmaintenance personnel remove the pressurizer manway, during reduced inventory operation, .to insure an adequate vent path. The procedure change provided acceptable assurance that

; Maine Yankee will provide an adequate RCS vent path during reduced inventory operation.=

- This item is closed.

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7. ADMINISTRATIVE

7.1 Persons Contacted

During this report period, interviews and discussions weie conducted with various licenseepersonnel, including plant operators, maintenance technicians and the licensee's managementstaff.

7.2 Summary of Facility Activities

Maine Yankee operated at power throughout the inspection period. On October 21 throughOctober 23, a team of Region I inspectors observed and evaluated Maine Yankee'sperformance during the annual Emergency Preparedness exercise.

7.3 Interface with the State of Maine

Periodically, the resident inspectors and the onsite representative of the State of Mainediscussed findings and activities of their corresponding organizations. No unacceptable plantconditions were identified,

7.4 Ihit Meeting

Meetings were peiiodically beld with senior facility management to discuss the inspectionscope and findings. A summary of findings for the re;crt period was also discussed at theconclusion of the inspection.

During the inspection period the inspectors conducted backshift inspection on October 19,20,21,22,27,28 and November 15 and deep backshift on October 18, 21, 24, 25, 26, 27, 28,31, November 11, and 14.

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