IR 05000443/1990012
| ML20055G154 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/10/1990 |
| From: | Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20055G150 | List: |
| References | |
| 50-443-90-12, NUDOCS 9007200179 | |
| Download: ML20055G154 (31) | |
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' . v - L , U.S. NUCLEAR REGULATORY COMMISSION. REGION I y - p Docket / Report No.: 50-443/90-12 License No.:~NPF-56-
- p Licensee
- Public Service Company of New Hampshire
' ' $P Facility: Seabrook Station, Seabrook, New Hampshire-F Dates: May 14'- June 24,-1990 l p
[ Inspectors: N[ Dudley, Senior Resident Inspector ' '; -R. Fuhrmeister. Resident-Inspector > . A.'~Cerne, Senior Resident Inspector, Construction a f P. Sena, Reactor Engineer i h W. Oliveira, Reactor Engineer
P. Drysdale Senior Reactor Engineer - J. Trapp,. Senior Reactor Engineer J. Yerokun, Reactor Engineer ' 04. O. bO*A. h v.
7 /l0/90 i t Approved By: _ Ebe C. McCabe, Chief, Reactor Projects Section 3B Date t OVERVIEW Ope ations: Turbine generator operations, load changes, and integrated plant-i , - tests were conducted in a safe, conservative and efficient manner.
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- Radiological Controls: A containment entry at power was well planned, super- ' vised and controlled, Contamination and dose rate control was good, '
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- Maintenance / Surveillance: Corrective maintenance on several pieces of equip-- .i - ment was conducted in a controlled manner in accordance with procedures.
No L L deficiencies were noted.
,. " t . Emergency Preparedness: The licensee conducted a Public Alert and Notification L System Test and a Medical Emergency Exercise.
The exercises were well-planned
and-effectively evaluated, i , Security:- An effective program was implemented including compensatory measures required during modification of a temporary protected area fence.
. . Engineering and Technical Support: Items from previous inspections were found l to have been properly dispositioned, ' p Safety Assessment / Quality Verification: Weld record and Operational Quality Assurance Program (0QAP) review found that provisions for handling some forms as QA records were neither followed nor revised; this is a non-cited violation.
Quality questions relating to welding were satisfactorily addressed.
Improve-ments-in the implementation of and continued management attention to and support ' of the 0QAP were noted.
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' PAGE , .. ~ ' ['1 ' 1.0: S umm a ry o f Ac t i v i t i e s..........................'..........................
, [, 2. 0. ; 0peration s (71707, 71710, 92701, : 93702, 717 N);. '......... '............
p 2.1. Plant Tours......-................................... ............ 2.
- ' . _ 2.2 Plant Events ~...........................'.....................-....
' , l 2.2.1-Ground on Generator 0utput...........'.................
% -2.2.2 Shutdown-from Outside the Control Room................ '4
- 2.2.3 Turbine Trip by Generator Ground Relay;...............
'+ <. .. L-2,3 Emergency Safety Feature System Wa1kdown........................
t ", 2.4 Facility Tour Issues............ ...............................
p; c 2.5 (90-82-01)l Tapes of Control' Room Radio Transmi ssions............
- ,_ c 3.0 Radiological Controls ~(71707,83524).................................
y , $ 4.0 ' Maintenance / Surveillance (61726, : 62703)..............................
Lk-4.1 Maintenance....................................................
E 4~ 2 Surve111ance....................................................
' . . k 4.3 (90-05-03) Procedural-Compliance for Scaffold and Temporary Sump < F Pump Contro1.............................................. ... 9-5.0' Emergency Preparedness (82203, 82206)..........._......................
^ 5.I' Siren Test....................................................... '10.
, 5.22 Med i c a l Eme rg e n cy E x e rc i s e.......................................
. 1 , 6~.0L Security (71707,81054)..............................................
7.0'. Engineering and Technical Support (25573, 92701).....................
E" ~ 7.1 (BUL 85-03) ' MOV Common Mode Failures,...........................
l '7.2- (90-07-02) Flooded Electrical Cable Vaults (RI-90-A-21).........
. " 7.3 Extension of Environmental Qualification of MSIV 0-Rings........
, -7.4 Issuance-of ASCO Environmental Qualification Files..............
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I e - f-- - , ip: b c 8.1'f(90-08-05) - . . ..--. , . ... t . ' ._ ..,,. Initiation of Plant' Shutdown'Oue;to Loss,of Both- ,. ' ,
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Cantainment! Enclosure Emergency Air Cleanup System.'...........
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. 8. 2 Re v V ew o f.;We l d i n g ; Rec o rd s.....~...........l '......,...... -........ 13 ' i , a . !? ' ~ 8.3 H 0perations Qua11ty Assurance Program.>......................... 18=. . k, - 8.4~ Evaluation'of Technical Specification Limi!.ing Condition for ~ w
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& ? ' - E C ' - .,3 lJ .; ~ i ,; DETAILS-1.0: Summary of Activities 1.1?~ Resident Inspector Activities-Three. resident inspectors were assigned.
The 208tinspection hours t[ < included 96-backshift hours, of which-76 were' deep backshift hours.
'i F j , F . .On May 31, 1990, the Resident Inspector addressed an assembly at the: Kearsarge Regional'High School in Sutton, New Hampshire.- The. address !
i 3 involved the history and mission of the Nuclear Regulatory Commission.
-t 10ther guest speakers included a speaker from the' Clamshell Alliance U ' '
and a speaker from the University of Lowell,' Department of Nuclear . i-Engineering.
t 1.2 Visitino Inspector Activities , A team of region-based inspectors and visiting resident inspectors , provided 24-hour per day coverage of operations when the reactor was ' critical.
Inspection of the power ascension test program will be < documented in-NRC Inspection Report 50-443/90-83.
, On May-16,-1990, the Region 1 Division of Reactor Projects Branch Chief. responsible for Seabrook visited the site and met with plant
management.
, s On May 21-25, 1990, two regional inspectors. inspected maintenance and' ' surveillance. The results will be documented in NRC Inspection Report 50-443/90-13.
- Orj May 23, the Region 1 Division of Reactor Projects' Section Chief responsible for Seabrook visited the site and met with plant manage-
, ment.
~l On June 6, the Director of Project Directorate 1-3 and the Seabrook l Project Manager from the Office of Nuclear Reactor Regulation (NRR) responsible for Seabrook visited the site and met with plant manage-- ) ment.
! ' On June 18-22, three regior.-based inspectors and one NRR inspector !! , inspected plant security. The results will be documented in NRC In- + spection Report 50-443/90-14.
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1.3 Plant Activities At the beginning of the inspection period, the plant was in Mode 5.. Cold Shutdown, for modification of the Low Pressure Turbine 'C' rotor.
The turbine was reassembled on May 24 and the reactor was taken to Mode 1, Power Operation, on May 26.
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On May 29, turbine torsional testing was completed.
On May 30, the ' L reactor was placed in Mode 2, Startup, to repair the turbine mechan- [ ical overspeed trip device and to improve secondary water. chemistry + , f in the condenser and the steam generators.
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On June 2,'the reactor was taken to Mode 1 and: power ascension testing.
~ . continued.
Power was raised to'30's on June 4 and to 48's on. June 11.
Testing was interrupted by a short on a main generator output'line, by main generator. voltage regulator problems, and by out of specifi-
cation. secondary water chemistry.
.; p On June'16, 1990, the reactor was shut down from outside the control ' room as a planned test.
The plant was taken critical on June 17 and [, Mode I was entered on June 20.
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i L On June 20, the reactor tripped from 30*4 power due to a turbine trip 'l caused by a 180 Hz ground protection relay actuation.
The plant re-
mained in Mode.3 while an event evaluation was conducted.
g F 1.4 Licensing Activities I 'I ,. On June 5,1990, the Atomic Safety and Licensing Board held a pre-i hearing conference on remanded emergency planning issues.
, 2.0 Operations ,
2.1 Plant Tours ' g . ' Daily-control room tours and sustained control room observations were- + made, Operator log books, technical specification action statement , N tracking logs,- tagout-logs and night orders were reviewed. Assess-ments were made of technical specification action statements in effect, control' room staffing, management oversight, operator awareness of ' plant conditions, and response to events. No deficiencies were noted.
m Operators continually referred to procedures during operations, , briefed themselves individually and in small groups prior to perform-ing procedures, and anticipated control board indications responses.
The crews worked well in groups and interfaced well with testing per-sonnel and the non-licensed staff.
F The Unit Shift Supervisor properly maintained an awareness of control-
i board operation. The Shif t Superintendent provided another level of oversight and properly maintained an overview of control room opera-tions.
Interfaces and communications between levels of management , were well-maintained, with an awareness of activities. An adequate formal review of test results was accomplished prior to changing plant conditions.
Control of non-licensed and support personnel in the ,, control room and adjacent areas was good. Nonessential personnel did not enter the control board area unless authorized.
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. . , , ... + L A prebrief technical review and discussion of the turbine resonance , -test (STP 48.1) was conducted by a knowledgeable, technical expert
who'provided a good explanation of a technically difficult subject.
[ . Pre-shift-briefings addressed important aspects of upcoming. tests and ~ j .. activities. -A11~ personnel involved in the tests attended these meet-ings.
Coordination and communications during tests were good. 0pera-
tors,'startup engineers, and maintenance personnel were knowledgeable , n; when' questioned.
Staffing was adequate to perform the required tasks.-
- The inspector observed and reviewed 'the actions taken to establish ! ' [ plant conditions for non-destructive testing'of. the service water spray header welds (see Detail 8.2)..During this evolution,' the plant ,
was-stable:in~ Mode 3, and the appropriate action; statement was pro-perly logged in the operator. log and tracked in the Action Statement ' Status =1og.
An adequate tagout was prepared, issued and controlled
in'accordance with MA 4.2, " Equipment Tagging and Isolation."
Plant tours included the primary auxiliary building.: containment, l pipe chases, turbine building, switchgear rooms, diesel building.. circulating water' building, service water building, cooling towers
and intake structures.
No equipment problems were identified.. Minor.
t discrepancies weref turned over to the licensee and adequately resolved.
-2.2 plant Events I The operations department met new operating challenges including con-- trolling secondary chemistry, placing feedwater heaters in service, placing the. turbine generator on line, varying electrical loads, con-i ducting a shutdown of the reactor from outside the control room and responding to a reactor trip.
Good command and control were demon- 'I strated by the licensed operators and involvement by management was ' evident from observations of the following events.
2.2.1 Ground on Generator Output i > On June 6, 1990, the operators conducted an emergency shut-down of the turbine generator due to arcing in the "8" phase isophase duct of the generator output high voltage 1tne.
The shift supervisor took quick and decisive action to place the generator in a safe condition.
The unit shift supervi-
sor and reactor operators reduced reactor power from 30*4 to 15% in approximately 15 minutes without creating major per- < turbations in the primary or secondary systems.
, The arcing was caused b/ a 0.01 inch thick layer of a 6-inch thick flexible copper connector which came loose and con-tacted the aluminum duct work.
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[- checket a tear.on' a "C" phase connector was ~ identified and ! repaired.. No inadequacies were identified by the inspector.
' . . L 2.2.2 ST-33,~ Shutdown From Outside the Control' Room.
On June 16, the reactor was tripped from 20% power from .outside the control room in accordance with ST-33, " Shutdown-
From Outside the Control. Room." One operating crew con- ' g trolled the plant from the remote safe shutdown panels with ' - F-the minimum shift complement allowed by the Technical.
. Specifications. A second crew monitored plant parameters J from the main control room and retained responsibility for nuclear. safety. After plant parameters were. stabilized for over 30 minutes', the crew at the remote safe shutdown panels , returned equipment control to the main control room.
No
inadequacies were identified by the inspector.
b On June 15, before the test, a full day traihing-session was conducted for all personnel involved with the test.. ' Classroom. lectures, simulator instruction, in plant in-struction and a debriefing session were included.
Discus- . sions and questions were generated and interface, responsi- ' bility and communications difficulties were resolved.. Pro-
cedure revisions were incorporated as a result of these I discussions, j 2.2.3 Turbins Trip by Generator Ground Relay
' On June 21, 1990,'the reactor tripped from 30% power due to a turbine trip. The turbine trip was caused by a 180 Hz, ,
- generator neutral volts relay which yas automatically placed in the trip circuitry at 30% generator electrical All systems responded as expected with the excepti, output.
on of an ' unexpected isolation of emergency feedwater flow to steam generator SG-A.
' The operators responded well to the trip and correctly fol-- lowed the Emergency Operating Procedures.
The Unit Shift
Supervisor correctly identified the turbine-driven emergency
feedwater pump as the cause of a continuing reactor coolant ' system cooldown and secured the pump.
The emergency feed- ' water isolation actuation was identified by the operators to have been caused by high feedwater flow.
Feed to SG-A , was re-established.
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M .the generator. neutral volts relay actuation.- The setpoint . ' ' for actuation.of the steam generator. emergency feedwater- - isolation signal was increased from 425 gpm to.525 gm.to ' 4 prevent unnecessary isolation signals. - No. inadequacies i>1 were identified by thelinspector.
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g/j(" 2.3 Emergency-Safety Features Walkdown
W[ 'c The inspector performed a valve lineup check-of the Safety. Injection-System, Low Head Injection (accumulators).
Prior'to plant.heatup_
- U u n after the turbine maintenance,utage, the inspector verified correct-
. positioning of. accessible valves. The inspector observed that accumu-sf lator drain line. spool pieces were removed and blanked off.
The in- , = spector 'also noted boric acid crystal buildup on 'several valves and' - . drain line caps.
The Utilities Department was notified of the boric.
) , @v acid buildup.
~ $ The inspector later verified that the noted conditions'had been added to the list of valves needing cleanup the next time the containment is accessible.
This unofficial listing is maintained by Utilities ,.+ Department personnel as an informal tracking mechanism for needed cleanup.
Valves are listed by valve number, azimuth, and elevation in containment.
No unacceptable conditions were identified by the inspector.
, 2.4 Facility Tour Issues i Several observations were made dur 2 a. tour of the facility on 't January 3, 1990.
These were documented in Inspection Report 50-443/ '; 89-20. The status of several of those items is given below: j n < Item 2 - 1-CBS-LE-2385-1 has oil leaking from conduit: RES'90-0014 i has been written to evaluate oil leakage on CBS-LE-2384 and 2385.
I Item 4 - A deficiency Tag program should be developed and imple-mented: A deficiency tag program was added to the latest revision of Procedure MA 3.1, " Work Request," which became effective July 1, 1990.
T Item 9 - A dedicated drain line for 1-SW-V173 should be considered: f Valve SW-V173 will be replaced under MMOD 90-537.. j Item 12 - Turbine building lighting appears-to be dark: This issue
is being evaluated under Request for Engineering Services (RES) 90-158.
i Any deficiencies identified will be corrected under Minor Modifica-tion (MM00)'90-590.
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"7, m o , y , a . ~ { Closed) Unresolved Item 90-82-01: Tapes of Control Room Radio
[N .2.5 Transmissions , c - ' An initial NRC review of a sample of-recorded control room transmis-' ! . "-
y sions was conducted and documented in NRC Inspection Report 50-443/ ',s 90-82.
A transcript was made of all tapes and provided to New . Hampshire Yankee-(NHY) on February 22, 1990.
The results'of New if Hampshire Yankee's' review of the transcripts was issued in a letter
" (NYN-90116), dated May 24, 1990.- i 'j o y
' The inspector reviewed New Hampshire Yankee's letter, reviewed a
' ,, E sample of the 608 detailed analyses of questionable communications, and held discussions with the plant staff.
The inspector concluded {E that many of the taped communications did not originate from the , n Seabrook Station, and were not received at the station..No interfer-once with site operational or security communications was noted.
The licensee took action to ensure' encryption of all plant communi- ~ cations.
Repairs and modifications were made to both the operations i and security transmitters, and NHY sampling of those communications frequencies is performed to assure continued encryption.
' The inspector noted that the corrective action discussed in New my Hampshire Yankee's response identified operation of the condensate 4,; storage tank (CST) above the CST temperature of 100 F. identified in " the Final Safety Analysis Report.
Specifically, the temperature of .! ' the-CST was at 104 F.
New Hampshire Yankee has.since reduced the high temperature alarm set point to 85 F to allow operators sufficient
time to take corrective actions before temperature rises above 100~ F.
/ The inspector reviewed the. licensee's engineering analysis evaluating operations with CST temperatures above 100 F and calculation SBC-232, CST Inventory.Available Following. Station Blackout. The inspector , concluded that the margin of' safety;provided by the Technical Speci- fication for CST inventory was not reduced by operation with the CST: temperature at 104 F and that no unresolved safety question existed , , ' in this case.
f i The inspector concluded that the transcripts provide no indication of wrongdoing, or of fitness-for-duty inadequacies, or of -improper ,, " transmission of safeguards information.
No adverse nuclear safety or (c security implications were found. This item is closed, 3.0 Radiological Controls u.
e The inspector observed the radiological controls associated with an entry into the containment with reactor power at 3*,;. The health physics (HP)
supervisor briefed three work parties prior to the entry and HP u n w
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9 , D' Ltech'nicians controlled the work parties'during the entry.: Stay times'were ' established based on containment temperature. - Authorization was: received g from the main control room prior to entry.-
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While,inside the containment, the HP technicians' continually monitored-S radiation levels, performed swipe surveys and, directed workers to:the.
J lowest radiation areas.
The control point outside the' containment air - lock was well-established.
During exit from the control point, a worker ' {' inadvertently stepped on the step off pad with.a potentially contaminated booty. The HP technician swiped the step off pad to verify it was clean-e, E prior to allowing the worker to exit the control point.
' %."~ The inspector concluded that adequate control of contamination, dose rate, and potential heat exhaustion was in effect, and that good overall' con-' " ' ' trol and discipline were maintained.
, 4.0 Maintenance / Surveillance ' 4.1 Maintenance g _ . The inspe qor observed routine maintenance in progress.
Properly-authorizea work control documents, proper safety tagging, appropriate
m* procedures, and correct material issue documents were noted.
Speci-s, fic maintenance items observed are described below: r h Startup Feed Pump (SUFP): There have been continuing problems with
erosion of the water supply piping for the oil cooler of the SUFP.
Several attempts at correction involving material which was more re-
sistant to corrosion / erosion were made without success.
It was finally.
' decided that the pressu're drop'from the pump discharge (1400 psi) was ,K excessive and that it would be advisable to reduce the pressure of-n!F the cooling water source. Minor Modification -(MMOD) 90-E56 changed ',. . the cooler's water supply from the pump discharge to the first stage '! discharge, which operates at a pressure of 150 psig.
It also incor- , porated a new orifice block using 3 stages of pressure drop. The >Y inspector reviewed MM00 90-0556, Work Order 90W003021 and supporting ' documentation.
The inspector observed work in the field and discussed o work progress and scope with workmen.
No discrepancies were found.
> Heater Drain Pumps: The plant has experienced problems with stuffing box packing on the heater drain pumps.
The pump manufacturer, Ingersoll-Rand, was consulted and assisted in the investigation.
NHY
, decided to replace the packing with a mechanical seal.
Further in-vestigation revealed that pressure bleed-off ports in the stuffing a' box had been drilled undersize, or not at all, at the factory.
NHY f' connected an additional leak-of f line to compensate for this condi- ? tion.
That did not violate NRC requirements, as these pumps are not subject to 10 CFR 50 Appendix B.
(These pumps serve only to improve the efficiency of the steam cycle and have no nuclear safety func-tion.) During troubleshooting of the ' A' Heater Orain Purt.
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It was removed and replaced with a pump _ J-from Unit 2.
Installation of the mechanical' seal was performed under Deshn' Coordination Report (DCR) 89-49 and Work Order 90 WOO 3345 (for Pump "b") ~ ' Primary Component Cooling Water (PCCW) Check Valves: During the = evening of-June 17, 1990, while aligning the Pr_imary Component Cooling , ' . Water (PCCW) System, it was noted that the. !C' pump was windmilling.
." _ 'Thisconditionindicatedsignificantleakage.through'thepump'sdis-
- charge check valve..The 'C pump and check valve (1-CC-V-1) were (
isolated and the~ check valve was repaired.
The work was controlled a under work order 90 WOO 3456.
The work was performed in accordance with procedure MS0519.65, " Disassembly.and. Reassembly of Walworth 16",18", 20", and 24" Swing Check Valves. Af ter completion of the . - rework on CC-V-1, the check valves for the "D", "B" and "A" pumps were tested-for proper functioning. All three tested satisfactorily.
j' ' Plans are being formulated to inspect.these valves at the next shut-down to Mode 5 (cold shutdown) when the PCCW loops can be drained.
, Reactor Trip Breaker Failure: Seabrook Station had experienced in- " termittent problems with a Reactor Trip Breaker (RTB) failing to close on several occasions.
The RTB was removed.and sent to the manufacturer. (Westinghouse) for evaluation and correction.
Inspec-tion by Westinghouse determined-that a-guide plate _ tor the ' spring ' release device was not properly adjusted.
This has been assessed as the cause of the malfunction, even tho,qh-the failure to close did not recur during over 200 operations of the breaker by Westinghouse.
The RTB was reworked and recertified.for Class IE use and is being l returned to Seabrook Station.
Feedwater Heater-Level 1..aication: During the startup from the tur-bine modification outage, problems were experienced with an indicated high level in_Feedwater Heater.22A, The level in the gage glass con- , tinued to show excessively high after the-dump valves were opened to ' drain all_ water'from the:feedwater heater.
Subsequent troubleshooting attributed the indicated -level to water bubbling up the gage glass from an air leak on the instrument sensing line drain. A cap was placed on the drain valve; the_ indication returned to normal.
It was decided at that point to check'all vent and' drain lines throughout , the a secondary plant to ensure caps were in place.
Turbine Modification Work: As a result of a turbine generator failure and fire elsewhere, General Electric (GE) recommended testing of its ' nuclear turbine generators _for torsional response.
NRC Inspection Report 50-443/90-10 reports the results_of that testing at Seabrook and the modification proposed to correct the problem.
Those modi- ' fications were completed during this inspection period, The work was performed by GE personnel.
Turbine disassembly and reassembly were performed under NHY work controls and procedures.
During the work, , .
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P Lwork with.the craftsmen involved and reviewed foreign material con-trol in the' vicinity' of the open condenser and lubricating oil system.
. Turbine Load Meter: Troubleshooting was satisfactorily conducted in- ' accordance with WR 90 WOO 305 for a turbine load meter that was reading: -low.
With the assistance of a GE startup representative, the problem i was-determined to be'a sticking relay, which was replaced.
+ . No unacceptable maintenance conditions-were identified.
' ' Surveillance.
4.2 / The inspector conducted an independent review of Technical Specifica- ' ' tion requirements for Mode 5, shutdown, and Mode 2, startup.
No dis-crepancies were identified.
The inspector reviewed Repetitive Task Sheet 90RMA958304_~and proce- -dure MX 0513.06, "4.16KV Loss of Voltage Surveillance." The inspec- - tor observed portions of the surveillance and determined that the technicians fully understood and properl_y implemented the procedure.
The inspector observed the operational check of the four turbine main control valves performed in accordance with OX1431.03 and Technical j Specification 4.2.4.a.2.
The operational check was interrupted be - ! cause'the Main Control Valve No. 3 sensed a 55% rather than the actual R 47% power level and responded to restrain any further power changes,. Corrective actions observed by the inspector, such as the removal of j-t U the 55*4 setpoint limit of Feed Pump "B" were satisfactorily performed.
to allow the timely completion of the operational checks.
The in- ~i spector concluded that the -surveillance activity was properly docu- ! mented by qualified personnel.
j 4.3 (0 pen) Unresolved Item 50-443/90-05-03: Procedural Compliance for
Scaffold and Temporary Sump Pump Control The Utility Department inspected the scaffolding erected around the , circulating water pumps, per MA 4.10, Installation and Removal of j Temporary Equipment, and determined that the scaffolding was impro-perly tagged.
The proper tags were hung and a similar inspection was performed on all scaffolds-logged as erected in both seismic and non- , seismic buildings and areas.
, Following the Utility Department inspection, the inspe: tor noted that several structures in the turbine building and circulating water building were not tagged.
The licensee determined thet the struc-tures should be tagged in accordance with their progrtm and identi-fied additional structures which required inspaction and tagging.
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accordance with MA 4.10.
' t The inspector found scaffolding and structures in' safety-related areas T to be properly erected and tagged. However, because the continued problems with implementation of the scaffolding control program in.
< non-safety areas could carry over into safety applicat_ ions, this item remains open.
>; y The licensee determined that use of a second temporary pump in the j fish count sump in the circulating water pumphouse was uncontrolled.
- The first temporary pump was controlled under the temporary modifica-tion system.
However, the operators correctly determined that the -! use of UN0599.047, Rev. 01, '" Installation of Temporary Pumps," was ' not applicable for the second temporary pump since it did not bypass a permanently installed pump or transfer system.
The procedure was: , revised to apply to temporary pumps used to bypass or supplement per-manent or temporary pumps or-when directed by the Unit Shif t Supervi-sor. The procedure revision also provided the clarification thai, the procedure is not: applicable to temporary pumps controlled under a work request or-routine task sheets, or.to pump use for general ' F housekeeping purposes.
The inspector concluded that the procedure revision adequately addressed the-issue of control of_ the temporary pumps.
However, be- > b.
cause-of the issue of configuration control, which is being addressed by New Hampshire Yankee in response to NRC Inspection Report 50-443/ > , 90-10, this item remains open.
5.0 Emergency Preparedness i 5.1 Siren Test On May 16, 1990, a test was conducted of the Public Alert and Notifi-cation System. This was a simultaneous test of all 94 pole-mounted and all 16 truck-mounted sirens throughout the 10-mile EPZ The test was monitored by the Federal Emergency. Management Agency (FEHA).
, FEMA also contracted for a telephone. survey of the EPZ to determine the effectiveness of the system.
The inspector observed the cenduct '! of the test from the field.
The sirens were sounded twice, for 3 minutes, between 1:00 p.m. and 1:10 p.m.
Four of the pole-mounted sirens in the New Hampshire EPZ did not sound on the first actuation but functioned properly on the second actuation.
The failure on the first actuation is believed to be due to localized Radio Frequency Interference (RFI). No unacceptable conditions were identified.
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u , -5.2L Medical ~ Emergency-Exercise ' ' On May 23, the licensee conducted a graded medical emergency exercise', '
- The inspector reviewed the scenario, observed the portion of the exercise. conducted on site and attended a debriefing session.- 1The -
exercis( involved a contaminated injured man in'the primary auxiliary building.- -The scenario was well prepared with detailed contamination - , and patient vital; sign:information, a postedLradiation-area and a - e realistic simulation of an injured man.- The monitors provided ade-o c quate~information to the players and effectively evaluated the event.
E The injured man was packaged and placed on an ambulance within fifty ] minutes. The debriefing session identified areas 'for improvement and involved monitors and players.
~ No unacceptable conditions were identified.
The inspector concluded .that the process for conducting and evaluating drills and the facility response to-this simulated medical emergency were excellent.
6.0 Security The inspector observed security personnel conducting routine activities ! . including personnel access control, vehicle searches, and plant tours.
Compensatory measures established during modifications of the protected area fence.were inspected and the remaining protected area. fences were ' walked down, No deficiencies were noted.
70 Engineering and Technical Support i 7.1- (Closed) Bulletin 85-03: Motor-Operated Valve Common Mode Failures - During= Plant Transients Due to improper Switch Settings-This bulletin asked licensees to develop and' implement programs to ' en'sure that switch settings on certain. safety-related motor-operated
" , valves are selected, set and maintained correctly.
New Hampshire- - ' Yankee's letters dated May 15, 1986, November 30, 1987, and July 18, 1988 contained responses to this bulletin, Inspector' review concluded , that the licensee's selection'of the applicable safety-related valves and the valves' maximum differential pressures met the bulletin's . . standards. The NHY program to assure operability requested by Action ' Item "e" of the bulletin was found to be acceptable.
New Hampshire Yankee's letter dated November 29, 1989 provided an I ' update of the motor-operated valve testing program.
The inspector reviewed the letter and selected revised Summary Report Data Sheets ' for 13 motor-operated valves.
The eight valves in the Emergency Feedwater System that use Ratork, Inc. actuators had been tested using .
both the Motor-0perated Valve Analysis and Test System (MOVATS) and strain gauge diagnostic tests.
The open action items identified in i L ;. '
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The inspector - concluded that initial base line data was taken and that an acceptable'
monitoring-program as specified in Bul.letin 85-03 was established.
j ' * ( This bulletin is closed.
m : - - (Closed)' Unresolved Item 90-07-02:' Flooded Electrical Cable Vaults i-7.2 . - , m'>
This item (RI-90-A-21) was opened to track the completion of chemical d analysis of water found.in underground cable vaults and corrective m ~ actions to prevent. water intrusion in the future.
The chemical an- , alyses and corrective actions are documented in Engineering Evalu-1i ' ~ ation 90-10, which was submitted to the NRC in March of 1990.
The '
- y vaults will be resealed, and monitored for leakage at six month in-
' tervals,.In the' event that water is found, that vault will be de- - , watered and the cable support structures will be examined to deter-mine their condition.
\\p The water found.in the vaults was analyzed for chemicals that could s be' harmful to the-cable jacket and/or insulation.
The only vault u where organics were identified was W12, which had 7 parts per trillios of chloroform.
Concentrated chloroform is capable of damaging cable l ~ > ". materials af ter extended contact, but the levels found-in W12 are in-- l ? sufficient to damage or degrade cable material.
Mineral deposits in the vaults were found to consist primarily of , ~ alkaline calcium' salts which;are believed to be-primarily a result of.
leakage from the. concrete structure.
These materials have no effect I on the cable jacket or-insulation, j, . This item is closed.
, 7.3 Extension of Environmental Qualification of MSIV 0-Ri.ngs d '*
The inspector reviewed the latest qualified life extension calcula-tions for the 0-rings in the main steam isolation valves (MSIVs) and the applicable portions of New Hampshire Yankee's Environmental Quali-V fication of Electrical Equipment Report No. 2938-01.
Previous quali-j 7G fied life extension calculations conducted in November 1988 indicated that the MSIV' actuator 0-rings would require replacement prior to 'l ' , April 1991.
The latest qualified life extension calculations deter- , , 9, mined a required 0-ring replacement date of February 16, 1991. The J inspector determined that the calculations were properly completed .! t and the assumptions used were reasonable. The inspector concluded ' that the MSIV 0-rings' environmental qualification was properly ex-m tended until after the first refueling outage, l y . r a
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The adequacy of the updates was confirmed during the EQ ' inspection documented in NRC Inspection, Report 50-443/90-11, -
l8,0 Safety Assessment / Quality Verification [ % $' 8.1 (Closed) Unresolved Item 90-08-05 and LER 90-008/90-008-01: Initiationt l ,, , P, of Plant Shutdown Due to Loss of Both Containment Enclosure Emergency.
Air Cleanup Systems
- L Following discussions with the inspector, New Hampshire Yankee issued d
" 1* a supplement to the original Licensee Event Report (LER) indicating.
O _that the potential for the premature failure of the latching. mechanism' W had been recognized prior to the event.
The supplement stated._that a Design Coordination Report had been initiated to reverse the swing of the enclosure-doors in order to. reduce the stress on the latches.
-Also, another potential modification, which strengthens the door latch,
was installed on a door (not required to be in place to meet Tecnnical ' ,.. . . .. " Specifications) to evaluate the reliability of the design.
The evalu- ' ation of the modified door latch and the decision on which design' '; modification to implement are anticipated to be completed by September ' 30, 1990,- P The inspector concluded that adequate corrective actions were estab-11shed by New Hampshire Yankee and are now adequately described int-the LER.
This item is closed.
8.) Reviews of Welding Quality Records i As documented in NRC Region I Inspection Reports 50-443/90-08 4 90-10, a additional inspection of pipe weld quality was initiated as a result ' of Congressional interest.
NRC resident inspector review of con- [ struction records has been continued to support the NRC response to i additional Congressional staff questions. This inspection has en-compassed welding /NDE record reviews,' construction procedure compli- ~ ance evaluations, personnel interviews, and follow-up of licensee i efforts to demonstrate effective quality record retrievability and to ! provide evidence of record completeness. Where corrective measures l were deemed appropriate, the inspectors observed and evaluated the licensee actions taken to verify acceptable weld quality and record adequacy.
Additionally, the resident inspectors have continued to provide co-I ordinating support and assistance to the NRC Independent Regulatory Review Team (IRRT) established to review certain pipe welding and NDE issues at Seabrook. As of the end of this report period, the support . - - - - -
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- a , % .{ 'q' 1 ?. '~ =.4 i i_; 'J . , 34- , p, functions'being provided to the IRRT, as well as the record review;>
andl quality ~ verification activities, were continuing.
The' status of
- findings and conclusions reached in-specific areas of inspection are discussed be' low.
' .o , . . Radiographic Inspection Report Reviews The inspector reviewed the Radiographic Inspection. Report-(RIR).
records, in conjunction with Field Weld Process Sheets and other sup-porting quality records, for s'everal welds.
It had been noted by the 'IRRT that the RIRs for certain reactor coolant (RC): system welds.had incorrectly documented the RC pipe diameter and wall thickness.
'A1.- - though the correct dimensions were accurately documented elsewhere'in.
the weld package, the effect of the RIR' errors upon the geometric - unsharpness (Ug) calculations relative to_the affected radiographic" quality were questioned.
Such calculations-are required to verify that the limitations of the ASME Boiler & Pressure Vessel Code, Sec-tion V (T-250) have not been exceeded.
Once the RIR errors were identified, the inspector requested that the licensee review the records for 911 large-diameter RC loop welds for similar-errors, recalculate Ug numbers _to ensure that code require- , ments had not been violated, and provide documented evidence of cor-rection of the affected records.
The licensee completed these tasks and the inspector reviewed the new Ug calculations to confirm that the = code-criteria for the sharpness of the radiographic = images _ had been met. The correction to the RlR records was accomplished by
- attaching a copy of a'" Corrections" memorar.dum to each affected'RIR.
This memorandum, dated June 11,.1990, listed the appropriate correc- ' tions to the RIRs, such that the weld radiographic-history records now< reflect accurate data when reviewed in conjunction with the originally submitted Pullman-Higgins documents.
l
-TheLinspector determined that no ASME Code problems or weld / radiograph' quality concerns resulted from the identification of the noted RIR ' documentation errors.. With the completion of licensee action to up- ' grade the records, all quality questions relating to this issue are considered to have been satisfactorily addressed.
Procedural Control of Records ,- The inspector examined several weld document packages to include sup-porting NDE records and referenced nonconformance reports.
The Pullman-Higgins procedures governing the generation and control of ' such records were reviewed to check QA records file retention and I retrievability provisions.
These record requirements were determined to be in general compliance with the American National Standard In-stitute standard (ANSI N45.2.9-1974) for quality assurance records associated with nuclear power plants.
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- The 1'nspector noted that certain records (e.g.,. Weld Rod Stores Re-
w quisitions)-had been controlled as quality documents during construc--
'i g tion,'but were-not turned over to the1 11censee' document ~ control center: -l cfor QA records storage. The rationale behind.that decision was that.
j ! _the requisite traceability of. material quality-or construction accept-u , ability was provided by other quality documents. :In the case of the i Weld Rod Jtores Requisitions, the filler metal' heat numbers and elec-1 q C trode lot numbers.had been recorded on the Field' Weld Process Sheet: j .for ea'ch weld.- Two'other documents which were not considered QA- . ' ' ' h . records (and therefore were not retained in the document control files) W-were the Radiographic Review Re' quests-(Forms-YRT-1) and Radiographic ,3 . Review Summaries (Forms YRT-2).
Such forms ~had:been utilized by .. P '. Yankee Atomic Electric Company (YAEC) surveillance personnel to track ', z
the in process review'of radiographs in accordance with the YAEC ' b Quality Engineering Group NDE' Review Group Procedure No. 5.
j - 'YAEC Procedure'No. 5 specifies.that the Radiographic Review Requests-i and Summaries were to have been controlled per YAEC Procedure No. 11..
- l Procedure No.11, entitled " Records," defines requirements for the
b-control:and transmittal of QA records from the YAEC Quality Assurance
Group to the Seabrook Document Control Center (DCC). However, as ! stated above, the YRT-1 and 2. forms were not considered QA. records and were not turned-over to the DCC for microfilming or storage.
..The inspector discussed this apparent discrepancy with licensee QA
Eper.sonnel, who indicated an error on their part in not revising the-QEG NDE Review Group Procedure No. 5 delineating the requirement for.
, . handling the YRT-1-&E2 forms as;QA records. While it was originally q " intended that'these. forms be treated as QA records, this need was ' obviated by the fact that evidence of the:YAEC 100% radiographic re- ' i view program was provided by YAEC signature or initials on the Radio-
< ,. : graph Inspection Reports and film packages. -Thus, the use of the YRT $ , forms was reduced to an administrative control function within the A QEG NDE' Review Groups.
The inspector confirmed that the YAEC NDE Review Group had used these forms by interviewing cognizant QA1per- ." sonnel and examining some unofficial copies of the documents which , had been retained-in individual YAEC employee files.
l l However, the fact remains that a procedure specifying handling the
YRT forms as QA records was neither followed nor revised when the decision was made that these documents did not require retention.
, While the inspector verified that other QA' records establish record
p accountability of the YAEC radiogtaphic review program and that the ~ YRT forms did not require retention as QA records for any reason other l than the procedural commitment, the noted error violated procedural L controls. Because no safety implications are evident, and because this violation is not considered representative, this matter is classified as an isolated, severity level V, non-cited violation (NCV t 90-12-01) in accordance with the NRC Enforcement Policy (10 CFR Part j 2, Appendix C, Section V. A).
Since the procedures involved are no I
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- t m , ,s ' longer in use and there are no safety inadequacies involved, the Em purpose of entering this item as a violation is merely to correct the , historical record; m-The licensee initiated corrective action by filing with the YAEC-a N, Field QA-Manual (currently not in use,'out retained as a. record) a.. J memorandum dated June 21,.1990 which documents and explains the'sub ject error in: YAEC Procedure No. 5.
The' inspector had no_further questions and identified no unresolved safety concerns as a result of- ,j.
this procedural problem.
d .y v, F Allegation Review (RI-90-A-0063) j In conjunction with.a Congressional staff request for information-regarding weld records, an allegation was received indicating that.- ! deficiencies exist with regard to the. radiographic record of the- , cooling tower piping welds. The specific concern was that certain-piping welds connecting a main "T" piece to the spray-headers had
been repaired after the discovery of radiographically identified de- ' fects, but that no radiography was conducted after the repairs were , completed, j
An NRC inspector conducted an-isometric drawing and records review of
the cooling tower piping to determine whether any radiography had
' been conducted on this section of the service water (SW) system.
The { - SW system at Seabrook Station is designed and constructed in accord - , ance with the requirements of the ASME Boiler & Pressure' Vessel Code a for Class 3 components,-the welding of. which is not required to be l ) radiographically examined.
The normal method of nondestructive j examination (NDE) of the completed welds in the carbon steel SW piping ' was magnetic particle testing (MT), although the code allows the con-duct of liquid penetrant testing (PT) or radiographic testing (RT)'on the completed. welds in lieu of the conduct of MT.
Interviews with cognizant licensee personnel, in conjunction with the record review, revealed that the only RT conducted on the cooling ,' tower piping was accomplished in accordance with the disposition de- . tails of UE&C nonconformance report (NCR) No. 566.
This NCR addressed r the repair of two welds on each of two "T" pipe pieces connecting a-SW header to the spray distribution piping in the cooling tower.
Since the subject of both the allegation and NCR No. 566 were "T" piping welds that had been radiographed, the inspector determined that a review of the disposition and handling of NCR No. 566 should j provide facts relative to the stated concern.
Also, review of re- ' lated Pullman-Higgins NCR No. 2630, along with examination of the supporting inspection records, engineering justifications, and code criteria, was conducted to address any concern regarding current weld i quality or code compliance.
it was noted that NRC inspection of hot
functional testing activities in late 1985 included witnessing of the < . . . .
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, , e i SW Cooling Tower Thermal: Performance Test (reference: ins'pectionc re ' , port 50-443/85-31).
No-operational problems. relating-to piping inte-- grity or-weld quality have been identified in the performance of the- _
cooling tower from.the, time that preoperational test was conducted.to the present.
'5 . Review of the NCRs and related records revealed the conduct of base P metal repairs' (BMRs) and weld replacement activities _in compliance
with applicable _ASME~ Code (Sec. tion III, Subsection _ND) provisions.
Specifically, the field welds which had repaired the original vendor , 'T" piece shop welds had in fact been radiographed and rejected, re- '
- quiring additional-repairs.
Subsequently, these welds were. replaced i with new field welds which, in accordance with the ASME Code, only required MT of the final welds, as had been performed on the original- ' shop welds.
~ -_The inspector reviewed a Code Interpretation (III-1-86-68) confirming the intent of the ASME Boiler & Pressure Vessel Code with respect-to i final NDE.and. acceptance of such welds. Additionally, the inspector noted that the BMRs equired only a surface examination-(MT or-PT) 'for final. acceptability in accordance with another ASME Code article on the' elimination'and repair of defects.
The records review associated with NCRs 566 and 2630 determined that the weld replacement.and BMR activities on the subject "T" piece welds ' ' had been accomplished in compliance with the-applicable code -require- -
ments without the need for subsequent radiography. Therefore, the stated concern that deficiencies exist with= regard to the radiographic-record of cooling tower piping welds was not substantiated.
' In performing the weld record review, the inspector noted that docu- > ments: establishing the final status of two:BMRs on one;of the "T"' pieces were not available with NCR No..566 records. A Liquid Pene-trant Examination Record was found that prov.ided evidence of accept- . able PT for certain base metal weld end preparations, and which might be the missing NDE re::ords.
However, the final isometric drawing (ISO FI-198, Revision 5) indicating the status of the subject field welds did not unequivocally illustrate the questioned welds to be end , preparation repairs.
Therefore, an incomplete record package was deemed to exist'with respect to two final BMR welds on the "T" pipe piece associated with the Train "A" cooling tower spray distribution piping.
Tne -licensee decided that it would be necessary to conduct MT re-examination of the two affected weldolet field welds in order to assure a complete weld record. On June 17, 1990, while in opera-tional Mode 3, MT examination of the two subject "T" p,ece pipe welds was conducted, as authorized by work request 90 WOO 31P,. The MT was witnessed by NRC inspectors who independently verified that the cor-rect welds were being examined by means of fielo weld scribe marks = - -.
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The inspectors also reviewed the
' NDE procedures. and acceptance criteria 'and confirmed: adequate cover-j age'7f the branch piping base metal, weld and weldolet material, The use of aniMT field indicator to establish the' direction __ of the mag- -netizing-force was noted and proper.MT yoke pl_acement by the NDE' c_., - "" technicians was observed during test conduct, , , &'b No weld' defects or unacceptable weld indications;were identified as a~ result of MT'on-the as-welded component configuration... At - the ' con-clusion of these weld inspections, the licensee' issued additiona~1 '
examination records to complete the weld' history record. relative to .O the "T"' piping spool; piece in question. The inspecte reviewed these n gi records and concluded that weld quality had been established.and that evidence of code compliance and record adequacy.had been provided.- ' o, No-violations or unresolved safety issues were identified as a result ' of-this inspection, record review and follow-up.of the allgation.
" 8.3 Operational Quality Assurance Program The~ Operational. Quality Assurance Program (0QAP) was ev~aluated in NRC Inspection--Report 50-443/89-03.
Initiatives undertaken by New Hampshire Yankee to enhance the' program were identified and potential areas for ' k . improvement were discussed.
1-The inspector assessed the status-of these initiatives and potential , areas'for' improvement through~ observations of implementation of the ' z 0QAP on a daily basis and through review of the following documents, n . " Nuclear Quality Group Accomplishments Over the Past Year"; Memoran-
' dum DQP-#90-010, Pillsbury to Feigenbaum, issued June' 6,1990 l "IRT Report on 0QAP Implementation - Update #6"; memorandum SSP ,
-#900262, Warnock to Distribution, issued April 25, 1990 . m.o , " [, "IRT - QA Action Item 5.46"; Memorandum SSP #900261, Warnock to ' ) Pillsbury issued April 25, 1990 " Response to IRT Act-ion Item"; Memorandum SSP #9C0250, Warnock to Pillsbury, issued April 16, 1990 - " Response to IRT Action Item 5.4.37"; Memorandum SSP #900335, Warnock
to Pillsbury, issued May 22, 1990 ' m " Nuclear Quality Trend Analysis Report July 1,1989 - December 31, 1989"; Approved by P. Epson ' " SIR Task Team Review Report"; Memorandum SPP #890940 to Feigenbaum, issued June 22, 1989 o, v ll
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' s (); i . . Lesson Plan:for " Communicating Positive Results Workshop", . Training / Seminars / Workshops Attended by NQG (Nuclear Quality Group) ' Personnel ' S Initiatives undertaken by'.New Hampshire. Yankee in early 1989-included' discussions. of the.use'of QC holdpoints during' maintenance-work. im-proved technical credibility of 0QAP inspectors,= use of licensed.in - q dividuals in QC surveillances and establishment of a' Findings Review q Board.: i q q d ,. QC holdpo.ints~are now routinely used in maintenance = procedures and ._ " are well-understood and followed by maintenance tech:icians.
Signi-
ficant, technical training of QC inspectors has been completed-and-additionalvtraining is planned.
Twelve NQG personnel hate completed'- .e Plant. System. Level III: training and five inspectors have completed-Plant System Level II training. One inspector has been certified as
a: Level IIIJNondestructive Test.(NDE) inspector and is establishing a . progrant to train and certify additional NN insoectors. Addition- ' ally, technical training courses, seminars and workshops were attended ' by and are: planned for Nuclear Quality Group (NQG) personnel.
Pre-viously' licensed. operators have been employed by the NQG, and are .I assigned to, assess the power. ascension program. The HQG'was able to l attract three. qualified Seabrook auxiliary operators into their -{ urgan.ization but has not recruited any -licensed Seabrook-operators'. The. Findings Review Board.(FRB) is composed of representatives from - , Lall departments:and meets approximately twice a month tc. review NQG .l findings.. The FRB has clarified findings and improved commu'nications j
- between;the;NQG and other departments. As.a result, NQG findings-'are j
< 1better;underptood and are of higher technical quality.
, 7n Since early 1989, an ! Independent Review Team (IRT) evaluation of the i ~ 00AP and six assist visits from a consultaat, Barteck, who' assessed 0QAP performance,.were completed. As'a result of the IRT evaluation , l' and. consultant assist visits, nineteen recommendations or initiatives ! L were undertaken by'New Hampshire Yankee management and the NQG.
An i
l '. additional 44 " good ideas" were identified for additional review and
possible action. Of the nineteen items, the rotation of personnel l between NQG'and other departments is still open.
Two other items, j providing additional nuclear quality training to plant staff and pro- .
viding programmatic and procedural direction to avoid overlaps in ' ~ Nuclear quality activities have been completed conceptually but have y not been fully implemented. The remaining items are completed or being implemented on a continuing basis.
The inspector concluded that the initiatives implemented in early d 1989 were effective in improving the quality of NQG findings and in ) improving the-interfaces between NQG and other organizations.
The j self-assessment reviews of the 00AP identified many recommendations
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Manyof:therecommendationshavebeenimplement'edI .and others are under review. The inspector concluded that significant " ~ progress has been made in implementing -improvements to the OQAP,'not- ' withstanding the~ demands placed on the' Nuclear Quality group by on-going power ascension testing and. responses to allegations and con - gressional inquiries.
'8.4 Evaluation of Technical Specification Limiting Condition of ' Operations On February 23,1990, a' leak developed on the drain line = of the 'posi-.- tive displacement' charging pump with the plant in Mode.3, Hot-Standby.
l The operators entered Technical Specification 3.4.10 for structural
integrity. and initiated a plant cooldown.
Upon further review the " licensee determined that the leak did not represent reactor coolant.
system leakage and exited the action statement.
Through discussions , with the1 0ffice of Nuclear Reactor Regulation (NRR) reviewers, the i inspector concluded that the licensee evaluation was correct and that-l no Technical Specification Limiting Conditions for Operations were exceeded.
9.0 Meetings j 9.1 An oral summary of the preliminary inspection findings was provided j to the Station Manager and the plant staff at the cone.lusion of the- 'i inspection. A copy.of a letter from Dr.:Murley, Director of the NRC.
j Office of Nuclear Reactor Regulation, to Regional Administrators' con- . cerning Temporary Waivers of Compliance, was provided9to the Station j Manager and is provided as an Attachment to this; report, ) On June 19, 1990, a public meeting was held in King of Prussia, l Pennsylvania.
During the meeting New Hampshire Yankee presented the .! status of the completed. portions of the power ascension testing. pro- ! gram and summarized the results of a Self-Assessment Team Report which was submitted to the NRC on June 18,'1990. The slides and.
I transcript of the meeting were issued in a separate meeting report.
f The NRC accepted New Hampshire Yankee's assessment and will review the report.
9.2 -Exit-Meetings Conducted by Inspectors Dates Subject Inspection Lead Report No.
Inspector 5-25 Maintenance & Surveillance 90-13 Drysdale - 6-1 Power Ascension Interim Exit 90-83 Barkley 6-8 Power Ascension Interim Exit 90-83 Prividy 6-14 Power Ascension Inter'm Exit 90-83 Drysdale 6-22 Security 90-14 Albert
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. UNITED STATES. , ' NUCl. EAR REGULATORY COMMISSION ,-
cc: T. Martin p'~ N 3,- [
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.K. Smith- ' 'V \\'
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, " FEB 2 31990 l' W .... - TTM '2/28/90 , g I
- MEMORANDUM FOR: elilliam T.desselggRecional Administrator, Region' I s
L Stewart D. Ebneter, Region ~al AdmiiMitftto,r, Ret11onY { ~A. Bert Davis, Regional ~ Administrator,; Region :II-o ' . Robert D. Martin, Regional Administrator, Region IV _{ John B. Martin, Regional Administrator, Region V
I FROM: Thomas E. Murley, Director
L Office of Nuclear Reactor Regulation ! SUBJECT: TEMPORARY WAIVERS OF COMPLIANCE I J . c i This memorandum-supersedes EGM 85-058 " Relief from Technical Specification LCOs" ' , " issued jointly by NRR and IE dated February 27 1987. The purpose,of'this revi - ! sion is to reaffirm that there are two paths for waiving compliance with technical specification;1imiting conditions for operation-(TS LCOs) or-other license condi-j - .tions.that would otherwise unnecessarily require shutdown or delay startup-absent m , some relief.
In case one, the Regions have the lead for waiving compliance for certain changes of short duration.
In case two, NRR has the lead.
In both cases,
a violation of-requirements m temporarily waive compliance. y occur but the NRC is exercising-discretion to i
- Background A 1.icensee may depart from its technical specificat'lons (TSs).- pursuant to.the provisions of 10 CFR 50.54(x), without prior NRC, approval, in an emergency when-it must act imediately to protect the public health and safety.
However, situa-tions' occur occasionally for which waiving compliance from regulatory require- ! ments may be ap '10 CFR 50.54(x)propriate, and which are not addressed by the provisions of H In these sit 6ations strict compliance wi'th the plant's TSs ! . without some imediate waiver of compliance from.the NRC wouild cause a. licensee -!
'to. initiate an unnecessary plant action. Examples include cases where a required y, plant shutdown could subject the plant to problems / challenges that-operating at < steady state conditions would not. Provided that the licensee has not abused the emergency provisions of 10 CFR 50.91 by failing to apply for an amendment i , in a timely manner, it is appropriate that the NRC have a procedure for expedi-tfous action under these limited circumstances.
> It is. emphasized that any decision of this nature will not be exercised unless ' the NRC is clearly satisfied that such action is consistent with protecting the public health and safety. Careful regulatory scrutiny must be given to any ' > CONTACT: Marylee Slosson, NRR 49-21401 s
-. . - . . - - - -. p g( p' cp q, h ' , _ .t ' Regional Administrators 1-2-- EEB 2 21990 g. .y ' " request'for waiver of compliance for circumstances involving negitgence . missing a required surveillance) or poor planning (e.g., a necessary repa(e.g... ir: part not available) or misinterpretation of a technical specification, or. some similar' avoidable situation.
Such instances may be indicative of a more per-c, i vasive problem with the plant or its management and should be identified and conveyed to the licensee via existing procedures such as SALP. However given .that-plant safety has not been unduly compromised, denying a temporary w,aiver of compliance and thereby subjecting the plant to an unnecessary transient'or .i delaying plant startup.may not be in the best interest of public health and safety.
.;
,, Regional Waiver of Compliance i
, A Regional waiver of compliance-is a vehicle for a Regional office to grant relief from TS LCOs in certain limited circumstances when the relief ~is tem-porary (not to exceed 7 days except in unusual circumstances) and nonrecurring such that a permanent license amendment would not be appropriate. The-intent of such a waiver is to promote safety by not = imposing unnecessary actions on t an operating plant and to permit a reactor startup which would otherwise be precluded by TS under those circumstances where the proposed course of action involves minimal or no safety reduction.
Some examples of circumstances for which a Region may waive compliance include (1) relief of a short duration from the limits of a function specified in an LCO, (2)' extension of an action state- , ' ' ment time limit, or (3) extension of a surveillance interval or a one-time change.in a surveillance requirement if the extension is for a short duration.
In-each of these situations, the licensee will adhere to the existing TS upon , i expiration ~of the waiver.
The' authority to exercise Regional waivers of compliance is-granted'to the - Regional' Administrator, who may delegate the authority to the Regional Division ] i 1; Director for Reactor Projects, based on a written request (or in some cases an ' i oral request followed by a written request) from a licensee.
Before waiving compliance, the Region shall consult with and receive the concurrence from the appropriate Assistant Director for Projects, NRR. Whenever a Regional waiver- = of compliance is exercised, the circumstances (including a descript. ion of com- , a pensatory measure (s) and an evaluation of the request by the staff) must be documented in a letter to the licensee from the Regional Administrator or his/ her designated official. The letter shall specify the period of time for which the waiver of compliar,ce is in effect and shall normally be issued within 1 working day of the receipt of the licensee's written request.
Copies of the letter should be placed in the public document rooms (PDRs) and sent to the.
, Director, NRR; the appropriate Director, NRR Projects Division; and the Director, Office of Enforcement. A copy should also be sent to the Technical o L Assistant, Division of Reactor Projects - I/II, NRR, who will maintain a file p of all temporary waivers of compliance.
In limited instances, a waiver may be b requested and granted orally, followed by written documentation of the waiver.
L' This is discussed further under Licensee's Request.
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Regional Adminis'trators-3 22 20 - .
. . , ' Regional! waivers of. compliance should not be exercised repeatedly for'the ' ' same sets of circumstances for the same licensee. Additionally if a waiver
is requested for~ a time period exceeding 7 days (except in unusual circum.
A stances).-an emergency or exigency technical specification chan processed and the waiver should be handled as discussed below. ge should be ,
. NRR Waiver of Compliance r b An NRR waiver of compliance is a vehicle for NRR to grant relief until an
- emergency or exigency amendment can be processed. An NRR waiver of compliance-i
. may be appropriate when-license conditions including TS LCO's would require ~
F < immediate but inappropriate action under the circumstances by the licensee or
would preclude or interrupt plant startup. Some examples of circumstances for which NRR may exercise a waiver of compliance include (1) a change in an element A
- specified in a limiting condition for operation until such time as the element
'3 , can be revised by an emergency or exigency license amendment, (2) extension of.
, an action statement. time limit for which an emergency or exigency -license amend-ment will be processed to make the extension a permanent change to the TS,
(3) an extension of a surveillance interval or change to-a surveillance require-ment that will'be-incorporated as a subsequent change'to the TS by an emergency . or exigency license amendment, and (4) a case in which a licensee has submitted ' a timely proposed TS change that would alleviate an LCO situation, but the change has not yet been approved by NRC and it will now be processed as an emergency or exigency. license amendment with suitable additional justification by the licensee.
. . The authority to exercise an NRR waiver of compliance is granted to the appro-priate Assistant Director for Projects in NRR, based upon a written request (or in some cases, an oral request followed by a written request) from a-licensee.
Before granting an NRR waiver of compliance, the Assistant Director for Projects, NRR shall consult with and receive concurrence from the responsible-Regional , , t Division Director for Reactor Projects. Whenever this waiver is exercised,<the circumstances (including a description of compensatory measure (s), and an evalu-ation of the request by the NRC) must be documented in a letter to the licensee , ' . from the appropriate Assistant Director for Projects, NRR.
The letter is to
specify the period of time for which the waiver of compliance is in effect. The letter should normally be sent within I working day of receipt of tM licensee's
written request.
Copies of the letter should-be placed in tie public document
'1 rooms (PDRs) and sent to the appropriate Regional Administrator; the Director, ' NRR; and the Director, Office of Enforcement.
A. copy should also be sent to the Technical Assistant, Division of Reactor Projects - I/II, NRR, who will maintain a file of all temporary waivers of compliance.
In limited instances, a waiver of compliance may be requested and granted orally followed by written documenta-tion of the waiver.
This is discussed further under Licensee Request.
Following
' issuance of the waiver of compliance, the NRC staff should proceed to expeditiously process the emergency or exigency TS amendment in accordance with existing NRR procedures.
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., FE8 8 8 900
. Licensee's~ Request- ' licensee shall prepare a written request including:Whether a waiver of co scussion of the - the Region or by NRR, the: e
- requirements for which a waiver is requested, (2) a discussion of circumstances surrounding the situation including the need for prompt action and a descrip-
' tion of why the situation could not have been avoided, (3) a-discussion of q' compensatory actions (if any), (4) a preliminary evaluation of the safety-significance and potential consequences of the proposed request.(S) a discus- ' sion which justifies the duration of the request . licensee'sconclusionthattherequestdoesnotInv(6)thebasisforthe olve a significant hazards consideration, and (7) the basis for the licensee's conclusion that the request- , does not involve irreversible environmental consequences.
The licensee's t request should normally be sent by electronic mail to the Assistant Director for Projects NRR or the Regional Administrator. However, if circumstances do
notpermittImeforelectronicmail and read or describe the above infor,mation to the NRC.the licensee may make the req - The licensee's oral request shall be followed promptly (usually within 24 hours) by written documentation describing its rationale for the request.
If the request is-oral , (to be followed with a written request), the NRC must have sufficient informa-tion to reach the same conclusions as if it received a written submittal. The followup written request must confirm the information which NRC relied upon in-arriving'at its conclusion-in granting the relief.
The NRC must not act on the
written or oral request until the licensee has confirmed that the-action has been reviewed and approved by the Plant Operations Review Comittee (PORC), or its equivalent.
i Termination-of Waiver if'NRC decides to terminate a waiver of compliance for any reason, the licensee must take steps to achieve the required plant status and implement the existing- , TS-required actions imediately upon oral notification of the termination by the, appropriate Project Director, NRR or appropriate Regional Division Director.
For example, assuming a 7-day action statement of which 3. days have passed, the . licensee does not have 7 days to initiate the required steps since time will i already have flapsed during the waiver period.
In that-case, the TS-required
E action is to be taken within 4 days. Alternatively, the licensee should promptly initiate an orderly-shutdown or other required TS actions if the action statement has; lapsed during the discretionary period.
However, assuming such action is , j.
.taken,. the NRC should not normally take enforcement action if the action p statement lapsed during the period and the waiver was subsequently terminated.
i } . Sumarz The Regions may temporarily-waive compliance to permit a licensee to not be in literal compliance with TS's in certain circumstances in which a license amend-ment is not-appropriate because of the nonrecurring, short duration nature of p the event. NRR may temporarily waive compliance when a license amendment is 1: appropriate but an emergency or exigency amendment cannot be processed before [ -the time limit for the action statement expires.
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' ' Ha Regional Administrators: 5- . i t. ' i t 'i i I' 1'f!a TS will'be exceeded before a decision can be made to exercise a waiver o . + ^ ' complia'nce or if it is decided not to exercise a waiver of compliance.the' d...,' ' . licensee mu,st. take the action required by the TS (except as 'provided in 10 CFR . ' t 50.54(x))' A waiver of compliance is a discretionary action available to the
. ' NRC staff that need not be exercised unless the staff is clearly satisfied that- , ,' l the exercise of such action is consistent with the public health and safety.
- " ' Notwithstanding the decision to waive compliance enforcement action is to be
- considered in accordance with the enforcement poIicy for violations that led up F
to the_ situation that merited the waiver of compliance.
. i {} - na& N. ' omasE.Murley,Dirdtor . 0 fice of Nuclear Reactor Regulation cc: See next page- ..
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