IR 05000443/1993009
| ML20046B293 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/27/1993 |
| From: | Durr J, James Trapp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20046B290 | List: |
| References | |
| 50-443-93-09, 50-443-93-9, NUDOCS 9308040031 | |
| Download: ML20046B293 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
REGION I
ENGINEERING AND TECHNICAL SUPPORT INSPECTION REPORT NO.
50-443/93-09 DOCKET NO.
50-443 LICENSE NO.
NPF-86 LICENSEE:
North Atlantic Energy Service Corporation Post Of5ce Box 300
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Seabrook, New Hampshire 03874 FACILITY NAME:
Seabrook Station INSPECTION DATES:
June 21-25,1993 o
7//6/TO INSPECTOR:
M James h frapp,' Team lkdder, EB, DRS
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APPROVED BY:
M/A/
7 jI8 acqp. Durr, Chief, EB, DRS'
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Areas Inspected: An announced inspection was conducted to verify that the program for the design, implementation, and closecut of plant modifications is conducted in accordance with controlled procedures which satisfy NRC requirements. In addition, the engineering department's effectiveness in providing support to the plant was evaluated.
Results: The program for the design, implementation, and closecut of plant modifications is effective. The plant design changes reviewed were detailed and technically sound. The process for closcout of modi 5 cations was controlled and complete for the modifications reviewed. The Engineering Department provided effective support to the plant. The self-assessment process for design changes was noted as being particularly effective in improving the quality of the design change process. No violations or deviations were identi5ed.
930B040033 930727 PDR ADDCK 05000443 PIMih
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1.0 INSPECTION SCOPE The objective of this inspection was to verify that changes made to safety-related systems which are described in the Final Safety Analysis Report (FSAR) are made in accordance with controlled administrative procedures which satisfy regulatory requirements. The effectiveness of the engineering and technical support organizations to develop, implement, and closeout plant design changes was evaluated. A review of the temporary modification process and certain temporary modifications was conducted. The control of plant design changes is important to safety to assure that the margin of safety, described in the FSAR, is not reduced by the installation of the modification.
The engineering department's ability to provide plant support was reviewed. The effectiveness of the engineering department's programs, staffing, communication / interface with the site and work backlog closcout were evaluated. In addition, engineering department initiatives were reviewed.
2.0 INSPECTION FINDINGS 2.1 Plant Design Changes 2.1.1 Administrative Controls The administrative procedures which control plant design changes were reviewed to assure
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that plant design changes are conducted in accordance approved plant procedures and the i
American National Standards Institute (ANSI) 45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plant."
Permanent plant der.ign changes are primarily controlled by the Design Change Manual, procedure DC 2.1, " Design Change Package Processing," and Nuclear Department Procedure 30040, " Design Change Processing." These procedures are supported by a number of specific administrative procedures for items such as calculations, safety evaluations, and drawing control.
The administrative procedures reviewed provided adequate detail to assure that plant design changes were designed and implemented in a safe, controlled manner. Detailed guidance was provided in the areas of program requirements, design process, interface control, design verification, document control, and design change control. The administrative procedures
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satisfied the requirements detailed in ANSI 45.2.11-1974.
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2.1.2 Design Change Packages Selected plant minor mcxlifications (MMODs) were reviewed to verify that changes to the station safety systems were controlled in accordance with station procedures and regulatory requirements. The following plant design changes were reviewed:
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1.
MMOD 92-568, "D/G Jacket Cooler SW Piping Repair," provided instructions for
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repairing a service water system field weld near the diesel generator jacket cooler heat
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exchanger. The repair was made by installing a 4" diameter weldolet, weld neck flange, and blind flange, which completely enveloped the repair area. During the hydrostatic test of this repair, a leak was identiGed on an expansion joint in the service water D/G jack cooler outlet pipe. The expansion joint was replaced with a I
flanged spool piece, due to the unavailability of a replacement expansion joint.
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Further ultrasonic inspections conducted in the vicinity of the previously identified leaks identified 5 additional field welds which required repairs or replacement.
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2.
MMOD 91-0545, "EFW Recirculation Line Vent," installed a high point vent in the
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common emergency feedwater pump recirculation line. The vent was installed to l
reduce turbulence in the recirculation line during routine surveillance testing. The turbulence in the recirculation line had caused increased wear in the recirculation line
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check valves. The vent was designed to safety class 3 and seismic category I requirements.
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MMOD 92-546, "Diese1 Generator Cooling Level Gauge Modification," had been issued for installation, but had not been installed. This design change would install American Society of Mechanical Engineers (ASME) Section 111 isolation valves to isolate the jacket coolant expansion tank level gauges. The non-nuclear safety level
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i gauges for the jacket coolant expansion tanks are not isolable by ASME Section III valves. The tanks are ASME; therefore, the current arrangement does not satisfy Code requirements. The level gauges are currently isolated using non-ASME Code valves. The jacket water expansion tank is at atmospheric pressure and the failure of
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the level gauge would not degrade diesel engine performance.
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The plant design changes reviewed were detailed and technically sound. Each plant design change was documented in accordance with the controlling administrative procedures. The design changes were reviewed by an independent engineer, cognizant implementation engineer, Nuclear Quality Manager, and the Station Operation Review Committee. Each modification is also subject to a thorough interdisciplinary review within the engineering
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department. Detailed review criteria are provided in Engineering Department Procedure 30040 for conducting the independent and interdisciplinary reviews. The modifications were approved by the Manager of Engineering and the Station Manager. The inspector
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independently verified that the installed modifications were in accordance with the design i
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documentation. Only a small number of change authorizations were required to install the design changes, which indicates that a thorough design document was provided to the l
implementation engineer.
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The post-modification tests for MMOD 92-568 were reviewed. The post-modification testing, established by the implementation engineer, provided appropriate test requirements and acceptance criteria. The test procedures developed for performing the post-modification
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tests were appropriate. The results of the tests for the installed modifications were acceptable.
In general, the station procedures were revised to incorporate appropriate procedure changes to reflect the design change. However, Operations Procedure OS1036.01, " Aligning the Emergency Feedwater System for Automatic Initiation," erroneously indicated that the installed vent valve FW-V477 (MMOD 92-0545) should be open. The design change required that this valve be closed. The operations department staff reviewed previous
revisions to this procedure and determined that the valve position had been changed from
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closed to open inadvertently during a recent procedure revision. The valve had been correctly maintained in the closed position. The procedure was corrected and the inspector verified that the valve was in the closed position.
Modifications are closed out in accordance with Maintenance Administrative Procedure MA i
4.13, " Design Change Implementation and Post Modification Testing." The category 1 drawings are updated prior to the modification being accepted for operation. The inspector verified that the drawings for the installed modifications had been revised.
The inspector noted that approximately 58 modifications which have been declared operable
have not been completely closed out by the issuance of a full service notification. Some of these modifications which have not received full service notification date back to 1986. The
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inspector noted that the Anticipated Transient Without Trip Mitigation System modification was not closed. The cognizant implementation engineer stated that the modification was on i
hold until an issue regarding fire protection coatings in the area of the modification could be resolved. This issue had recently been resolved and this modification was fully closed out
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during this inspection. The closecut of modifications is important to assure that plant programs and procedures have been revised to reflect the modification. The Technical Support Manager stated that technical support was aware of the backlog and had initiated
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actions to reduce the backlog.
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The results of an independent audit (Audit Report 92-A09-01) of the modification process
conducted by the quality assurance department was reviewed. The audit wn :=ddcd af:::
the NRC Safety System Outage Modification Inspections (SSOMI). Tie audit reviewed 5 Design Change Request (DCRs) packages and 1 Minor Modification,MMOD) package. The i
audit concluded that in general the DCRs and MMOD were well prepared and were in
compliance with existing station procedures. The audit provided htailed technical findings and was thorough.
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2.1.3 Safety Evaluations The review of safety evaluations was conducted to assure that an adequate basis was provided to conclude that the plant design change did not involve an unreviewed safety question. In addition, the administrative procedure guidance for performing safety evaluations was j
reviewed to assure that the procedure satisfied the requirements of 10 CFR 50.59, " Changes, j
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tests, and experiments."
Safety evaluations are developed in accordance with North Atlantic Management Manual
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Procedure 11210, "10CFR 50.59 Evaluations." Safety evaluations are written for the
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modifications and for all change authorizations made to the modifications. The safety l
evaluations were reviewed by an independent engineer, the Manager of Engineering, the SORC, and approved by the Plant Manager. The safety evaluations reviewed thoroughly
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documented the basis for the determinations that an unreviewed safety question was not
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involved.
2.1.4 Temporary Modincations Selected temporary modifications were review to verify that they were implemented and controlled in accordance with station procedures and regulatory requirements. Temporary modifications 88TMOD 0019, " Lifted Leads for a Pressurizer Heater," and 92TMOD 0063,
" Removal of Containment Air Purge (CAP) Valves 2 & 4," were selected for review.
Temporary modifications are controlled in accordance with Station Maintenance Manual Procedure MA 4.3, " Temporary Modifications." This procedure provides detailed guidance for controlling temporary modifications. The review and approval, technical adequacy, installation, tagging, and auditing of the temporary modifications were verified. The inspector verified that the temporary modifications reviewed were controlled in accordance
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with procedure MA 4.3. The safety evaluation for 92TMOD 0063 established that an l
unreviewed safety question was not involved with this modification. The safety evaluation l
and design documentation for this modification were detailed and thorough. There were l
approximately 72 temporary modifications installed at the time of this inspection. Several of the temporary mMihin have been installed for over 7 years and are planned to be made permanent modifications. The licensee had a plan to reduce the number of temporary modifice. tons by approximately 20 per year for the next two years. A review of the
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outstap. ting temporary modifications identified that most of the modifications are on non-i safety systems and are minor in scope.
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2.7, Work Backlog and Prioritization She Engineering Department's outstanding work is primarily tracked as Requests for Engineering Service (RES), Design Coordination Reports (DCRs), Minor Modifications (MMOD), and Document Revision Reports (DRRs). The engineering backlog reduction plan has been successful in reducing the backlog of outstanding engineering work. In 1990 the l
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total engineering backlog was approximately 1200 items. At the time of the inspection, the
backlog was approximately 600 items. The engineering department completed 43 DCRs and i
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72 MMODS in 1992. The engineering goal to provide the station with completed modifications documentation 6 months prior to the refueling outage was met for the last refueling outage. The modifications are prioritized by the Station Modification Resource Committee (SMRC). The committee membership includes managers from the station and j
engineering. The engineering department provides the committee with a modification scope and a proposed schedule which is based on engineering resources. The SMRC then approves
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or rejects the modification and schedule. The current backlog of engineering work it tracked
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and trended. The engineering department has successfully controlled the backlog of l
engineering work.
2.3 Staffing / Technical Training
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The engineering department continues to maintain a stable and highly qualified staff of j
engineers. The North Atlantic Engineering Group has approximately 50 engineering staff
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and managers. The department also has approximately 20 designers. Nearly half of the engineers have advanced college degrees and nearly half are professional engineers. The average years of overall industry experience average is approximately 20 years. The engineering staffing is currently at the full approved complement. During the refueling outage the engineering department provided approximately 13 staff to the station in various
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outage support positions. The North Atlantic staff are supplemented by approximately 18-j engineers, fully dedicated to the Seabrook engineering support, from the Yankee Nuclear Service organization. Additional engineering staff from the Yankee organization support i
Seabrook in areas such as fuel management and environmental engineering. Plant design changes are normally performed by North Atlantic or Yankee personnel.
The engineering department staff training is controlled in accordance with Engineering Department Procedure 30120, " Training." This procedure provides responsibilities and instructions to implement the orientation and internal training program for engineering staff.
The training orovided to engineering staff is documented on an engineering support personnel training matrix. Documentation of recent training provided to engineering staff regarding program deficiencies regarding the Tornado Doors and the China Flange (Bill of Materials)
issues was reviewed. The training material provided detailed information regarding the failure and provided training of the program changes implemented to correct the deficiencies.
The training provided to the engineering staff was directly applicable to the engineers'
responsibilities and was provided using well documented lesson plans. The training program was well controlled by department procedures.
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2.5 Engineering Initiatives
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The engineering department is developing design basis documents for 45 safety-related systems and components. System descriptions are being updated for non-safety systems.
The design basis document program started in 1989, and to date 19 design basis documents
have been completed. The engineering department plans to complete 8 additional design basis documents and update 6 system descriptions in 1993. The design basis document for
the primary component cooling water system was reviewed. The document provided detailed system design information. Engineering management has effectively focused resources to develop the design basis documents and has developed schedules and plans for completing this effort.
The engineering department has developed an effective self-assessment program for evaluating the quality of modifications. Engineering Department Procedure 30060, "Self-Assessments of Design Changes," provides the administrative requirements for this program.
Each Change Authorization (CA) to the design change packages is tracked and trended. The reason for the CA is identified, categorized into predetermined causes, and the cause of each CA is trended. The results of this selaassessment process is summarized in reports provided
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to enginer-ing management. Engineering management has used this information, such as changing the method to document field weld numbers without writing a CA, to improve the
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j quality of design change packages.
3.0 CONCLUSION The modification process is controlled using detailed procedures. The engineering department modifications reviewed were of high quality. The supporting safety evaluations
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provide an adequate basis to determine that an unreviewed safety question is not involved.
The installed plant modification were closed out and appropriate changes to station documents were completed prior to declaring the design change acceptable for operation.
The overall design change process was determined to be of high quality.
The engineering department interfaces with the plant were good. The backlog of outstanding engineering work was being tracked and effectively controlled. The effort to plan design
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changes in advance of planned outages is a positive effort. The engineering staff were well
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qualified and training was provided to continue to enhance staff qualifications. The engineering programs such as the design basis document development and the self-assessment were positive initiatives.
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4.0 AIANAGEMENT MEETING The inspector met with those denoted in Attachment 1, on June 25,1993, to discuss the
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preliminary inspection findings which are detailed in this report. The licensee acknowledged
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the inspectors findings and expressed no dissenting opinions.
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ATTACHMENT 1 PERSONS CONTACTED Boston Edison Company
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- T. Cooper, MG Support Supervisor D. Covill, Nuclear Quality Surveillance Supervisor
- W. Dickson Jr., BOP Systems Engr. Manager
- J. Grillo, Operations Manager
- G. Kann, Program Support Manager
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- F. Laird, I & C Department Supervisor l
- T. Murphy, Technical Projects
- J. Malone, Asst. to Exec. Director Nuclear Power l
G. Mcdonald, Nuclear Quality Manager V. Pascucci, QC Supervisor
- J. Peschel, Regulatory Compliance Manager
- J. Rickett, QA Engineering Analyst
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- B. Roach, Mechanical Maintenance Dept. Supervisor
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- J. Sobotka, NRC Coordinator
- E. Sovetsky, Technical Project Supervisor
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- J. Vargas, Manager of Engineering
L. Walsh, Manager Operations Support
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U. S. Nuclear Regulatory Commission
- N. Dudley, Sr. Resident Inspector - Seabrook
Asterisk (*) denotes those present at the exit meeting.
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