IR 05000443/1993019
| ML20058A440 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/12/1993 |
| From: | Rogge J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058A439 | List: |
| References | |
| 50-443-93-19, NUDOCS 9312010087 | |
| Download: ML20058A440 (1) | |
Text
{{#Wiki_filter:. . -- . . . . s . , U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Number: 93-19l . Docket No.. 50-443 License No.- NPF-86 Licensee: North Atlantic Energy Service Corporation Post Office Box 300 . Seabrook, New Hampshire 03874 Facility: Seabrook Station . Dates: October 5 - November 8,1993 , inspectors: Noel Dudley, Senior Resident Inspector Richard Laura, Resident Inspector Approved By: -cs2 k M - /////7 V[Jdhn F. Rogge, Chief' # Date ' Reactor Projects Section 4B, DRP Inspection Summary: This inspection report documents the safety inspections conducted , during day shift and back shift hours. The inspections assessed station performance in the areas of plant operations, maintenance, engineering, plant support, and safety assessment and quality verification.
Results: North Atlantic operated the facility safely. The inmectors considered the late filing of a licensee event report to be a non-cited violation based on the licensee identifying and correcting the cause of the late filing. See the executive summary for the assessment of licensee performance, , t i
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l - j .. ! EXECUTIVE SUMMARY
l SEABROOK STATION , ' NRC INSPECTION REPORT NO. 50-443/93-19 I Plant Ooerations: Operators demonstrated good overall performance. Operators prevented a plant trip during a main steam isolation valve surveillance test by conducting an extensive pre-test briefing and by promptly responding to an equipment failure. Operators properly responded to an unexpected feedwater heater isolation and to a feed water isolation valve , =I operator low gas pressure alarm.
Plant management evaluated degraded equipment performance and repair plans at the station manager's morning meeting. The discussions focused on avoiding any challenges to plant safety. The configuration control discrepancy of an incorrectly positioned main steam valve ! resulted from a personnel error.
Maintenance: Maintenance workers performed well during the conduct of maintenance and surveillance activities. The plant staff demonstrated excellent teamwork during the repair of containment isolation valve MSD-V-44 Instrument and control technicians demonstrated a proper safety perspective during a lessons learned training session.
A configuration control discrepancy occurred during the conduct of an emergency feedwater j system test and subsequent corrective maintenance. Station management initially did not assign a human performance system (HPES) review, even though the recent personnel error i response team identified the need to conduct more HPES reviews of personnel errors.
Plant Sutmot1; Security and chemistry workers conducted routine activities well. Plant housekeeping improved as a result of direct management involvement. Although no personnel contaminations occurred, health physics technicians demonstrated poor contamination control techniques during a residual heat removal surveillance test.
Engineering;. Engineering supported plant operations in an excellent manner as exhibited during main steam isolation valve testing. Technical support engineers analyzed maintenance rework data for trends at the end of each year.
i Safety Assessment /Ouality Verification: Plant workers and managers exhibited a proper safety perspective by continuing to identify and address problems. The late submittal of a licensee event report was treated as a non-cited violation.
Discussions in a pilot training session on personnel error reduction helped to establish a common understanding among the station managers that a need existed to establish a zero tolerance for personnel errors.
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. . . . - -._ . _ _ -. ,. - , . . TABLE OF CONTENTS Page EXECUTIVE SUMMARY ...................................ii ... TABLE OF CONTENTS ..................................... iii F 1.0 PLA NT OPER ATIONS (71707)............................... 2 1.1 Pla n t A c tivi ties..................................... 2 l 1.2 Routine Plant Operations.
............................... 1.3 Trip Avoidance Maintenance Activities...................... 2- ! 2.0 M AINTEN ANCE (61726, 62703, 92701)......................... 3 2.1 Routine N7aintenance Observations.......................... 3 ' 2.2 Surveillance.....
................................ , 2.3 Maintenance Rework
l ................................ 2.4 Instrument and Control Continuing Training Program............. 7 , 2.5 Plan t Worke r Overtime................................ 7
3.0 P L A NT S U P PO RT A R E A (71707)............................. 8 i
- { 3.1 Health Physics.. . . .... ....................... 3.2 Security... .....................................-9 3.3 Housekeeping.....
. ..... ........................ 3.4 C h e m i st ry.......................................
, 4.0 ENGINEERING / TECHNICAL SUPPORT.......................
L t 5.0 SAFETY ASSESSMENT / QUALITY VERIFICATION...
............ 5.1 Corrective Action System
............................ 5.2 Auxiliary Operator Log Discrepancies: EEI 92-08-01 and eel-08-02 ' (Closed).........
' .............................. 5.3 Licensee Event Reports............ _...................
! 5.4 Personnel Error Response Team
~! ......................... a 6.0 M EETI N G S (30702).....................................
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. . " , DETAILS 1.0 PLANT OPERATIONS (71707) 1.1 Plant Activities i On October 5, the plant was in operational mode 3, hot standby. On October'6, the ' operators brought the reactor critical. On October 7, operators connected the turbine generator to the electrical grid. The reactor reached 100% power on October 9 and. .; remained at this power level for the remainder of the inspection period.
' l.2 Routine Plant Operations , The inspector conducted daily control room tours, observed shift turnovers, attended the morning station manager's meeting, and monitored plan-of-the-day meetings. Plant s management evaluated degraded equipment performance and repair plans at the morning
station manager's meeting. The discussions focused on avoiding any challenges to plant safety. The inspector reviewed plant staffing, safety system valve lineups, and compliance with technical specification requirements. The inspector conducted tours in the primary , auxiliary building, the emergency diesel generator rooms, the residual heat removal vaults, l the turbine building, the condensate storage tank building, and the circulating water pump ! ^ house. During the tours and attendance at the various meetings, the inspector noted good performance by the operations staff.
, During plant start-up, the operations staff detected an unexplained low plant efficiency.
l Operations management directed the operators to review system line-ups. An auxiliary , operator identified that MS-V-244, a main steam orifice bypass isolation valve, was open vice in the normal shut position. The opened valve allowed steam to be discharged to the condenser. During the previous unplanned shutdown, mechanics had changed the valve packing using the valve' back-seat as an isolation boundary. The operators shut MS-V-244 and initiated an operational information report to identify the root cause and to develop corrective actions.
) I The inspector reviewed the MS-V-244 work package and-noted that the operators did not use a tagging order to isolate the maintenance area. After meeting with the inspector, operations - . management issued a memorandum to operators emphasizing the need;to be conservative when establishing isolation boundaries for maintenance work.. Operations management-identified that the valve should have been entered in the miscellaneous valve list to maintain configuration control. The inspector assessed that the configuration control discrepancy resulted from personnel error.
Operators responded to a low nitrogen gas pressure alarm for the 'D' feed water isolation valve operator. The operators contacted an instrument and control (I&C) technician who installed a gauge and measured a nitrogen gas pressure of 1955 psig. The alarm response -
procedure stated that the valve may not close if nitrogen gas pressure is below 2025. psig.
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i The operators declared the valve inoperable and followed the requirements of technical specification (TS) 3.6.3 for containment isolation valves. The I&C technician recharged the nitrogen gas pressure. The operators declared the valve operable and exited TS 3.6.3. The ' inspector assessed that the operators properly followed the alarm response procedure and TS - , requirements.
Operators responded to an unexpected isolation of the E-26A high pressure feed water i heater. The third condensate pump automatically started. The operators stabilized plant
conditions. The operators identified that the copper air line to HD-LV-4492, the E-26A
heater level control valve, had failed. HD-LV-4492 shut causing level in the E-26A heater to increase, resulting in a heater isolation. The maintenance staff replaced the copper air line with a stainless steel line.
i Operators restored the heater to service following abnormal operating procedure OS 1290.02,
" Response to Condensate or Feed Water Heater System." The inspector interviewed
operators, reviewed the unit journal and determined that the operators documented an i excellent sequence of events and narrative. The inspector assessed that the operators ! responded properly to the E-26A heater isolanon.
' ! In summary, the inspector assessed that except for the configuration control problem concerning MS-V-244, operators performed activities well.
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1.3 Trip Avoidnnce Maintennnce Activities j .! The inspector observed operator actions during separate trip avoidance maintenance
' activities.
) Before replacing a primary power supply in a non-safety related control cabinet, operators identified loads supplied by the control cabinet and planned compensatory actions. The ' operators established local control of a feedwater regulating valve that receives control
signals from the cabinet. The operators determined that on loss of power from the control I cabinet, two accumulators would be inoperable due to the loss of level and pressure
indications. The shift superintendent briefed the operating crew on the shutdown required by j technical specithations. During repair of a non-safety related uninterruptible power supply.
q (UPS), the operators identified the loads supplied by the UPS. If power was lost to the-i electrical panels supplied by the UPS, the reactor coolant pump would trip causing a reactor-q trip. The shift superintendent discussed the loads with the operators and the actions to take if
the plant tripped. The inspector noted that during trip avoidance maintenance activities-l operators focused on the' potential risks of the work, and developed strategies'for mmumzmg , the risk, and for dealing with the consequences of work errors.
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Based on previous valve testing problems, the operations department revised the quarterly
main steam isolation valve (MSIV) 10% stroke test p'ocedure to require that a technical r support engineer observe the testing. When the operators tested the 'A' MSIV, the valve- ! l
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i . reached the 10% close position, than fast closed to approximately 70% and stopped. Due to
the unexpected rapid MSIV partial closure, reactor coolant temperature increased, the control i rods automatically drove into the core, and the 'A' steam generator water level decreased.
At the MSIV, the technical support engineer increased instrument air pressure to the hydraulic air motor, which increased the hydraulic pressure for opening the MSIV. In the main control room, operators took manual control of the control rods and the 'A' feedwater regulating valve, and stabilized the plant. The MSIV slowly opened over a twenty minute period. The inspector noted excellent engineering support.
. The inspector discussed the events with the operators and reviewed the strip charts. The inspector noted that as part of the trip avoidance program, the shift supervisor took additional i steps such as conducting an extensive pre-test briefing and rescheduling the test to allow technical support engineer participation. The inspector concluded that the extensive pre-test briefing and prompt operator response to an equipment failure prevented a reactor trip.
The inspector assessed that operators performed trip avoidance maintenance activities well.
Operators prevented a plant trip during the main steam isolation valve surveillance test.
2.0 M AINTEN ANCE (61726, 62703, 92701) ' 2.1 Routine Maintenance Observations " The inspector attended some morning maintenance planning meetings, the plan-of-the-day meetings and work control meetings. During routine tours, the inspector observed
maintenance activities including the following: - MSD-V-44 Troubleshootine Activities-j ! The inspector observed maintenance workers troubleshoot main steam line drain isolation valve MSD-V-44, which did not properly stroke during dynamic testing. MSD-V-44 is a ' containment isolation valve. The inspector reviewed the work package and observed maintenance management and supervisory oversight at the work site. Technical support and
' quality control personnel monitored the work activities.
_ i The mechanical maintenance technicians loosened the bolts on the valve body to motor
actuator mechanical joint. Using a dial indicator, the technicians made a small valve 'l alignment adjustment. The technicians tightened the mechanical joint bolts. The electricians
conducted static and dynamic motor actuator testing. The maintenance technicians followed
the work instructions. MSD-V-44 stroked satisfactorily. The inspector noted that the -
electricians were experienced in the use of motor actuator diagnostic test equipment.
' ! The inspector assessed that the plant staff demonstrated excellent team work during the valve ' repair.
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Emergency Feed Water System Recirculation Gage The inspector observed instrument and control (I&C) technicians conduct corrective maintenance on 1-FW-FI-4279, emergency feed water (EFW) system recirculation flow gage.
When the technicians went to close 1-FW-4279-V1-H, the high pressure process line isolation valve, the valve was shut. The technicians informed the control room operators.
An I&C supervisor initiated operational information report (OIR) 93-97 to evaluate the con 6guration control discrepancy and to develop corrective actions.
The I&C technicians disassembled the instrument lines. on the high and low' side of the pressure gage and identified that the snubber pins were damaged. The pins had been peened over and had a mushroom appearance. The technicians installed new snubbers. The inspector assessed that technicians successfully completed the work.
The inspector reviewed the action assignments that plant management designated in OIR 93-97. Plant management specified that an OIR evaluation be performed that did not include a formal evaluation such as a human performance evaluation system (HPES) review. The inspector considered the lack of an HPES review to be a weakness since the North Atlantic personnel error response team (PERT) recently identified the need to complete more HPES i reviews of personnel errors. The inspector discussed the weakness with the station manager
who initiated an HPES review and escalated the OIR to a station information report.
The inspector assessed that a personnel error caused the loss of configuration control of a recirculation flow instrument valve.
Power Supply Replacement The primary power supply for control cabinet 7 in the main control room failed. The cabinet is non-safety related and provides indication and control signals for components such as accumulators, a power operated relief valve, and a feedwater regulating valve. Planners , prepared a priority 1 work request,93W3457, to replace the failed power supply, and ] classified the work as trip avoidance.
j The inspector observed portions of the maintenance; held discussions with the shift j superintendent, the 1&C supervisor, and the technical support engineer; and reviewed the. completed work package.
l Two electricians conducted the power supply replacement. A technical support engineer provided engineering direction' and guidance for fuse replacement, replacement part compatibility, circuit logic, and expected system responses. The I&C supervisor maintained responsibility for the maintenance work and verified system configuration at the specified ' supervisory hold point.
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5 The work briefing, attended by operators, I&C personnel, and the technical support engineer, covered the consequences of losing power in the control cabinet. The shift superintendent provided directions to the I&C technicians on restoring power to the control cabinet if power was lost. The shift superintendent stressed that there was no time limit or goal for restoring power to the cabinet.
The three typed pages of the description of work in the work request contained directions for replacing the primary power supply. The directions included fuse controls, a supervisory hold-point, and use of a catch cloth spacer to prevent dropping tools or lugs into the secondary power supply. The I&C technicians recorded the date and time of maintenance work items on continuation sheets.
The inspector made the following observations. The I&C supervisor maintained broad oversight of the work effort. The technical support engineer was available in the main control room and provided excellent and timely technical assistance. The I&C technicians worked independently to verify configuration control. The completed work request package and the cooperation with other departments were excellent.
Post Maintenance Test , The inspector observed a post maintenance test that I&C technicians performed on an emergency feed water pressure indicator. The I&C technicians verified that changing the gage line snubber pin size improved the gage readability. The inspector assessed that the
1&C technicians successfully completed the post maintenance test.
The inspector assessed that maintenance workers performed well by closely following' work
package instructions. The maintenance workers were experienced and possessed the proper " qualifications.
, l 2.2 Surveillance j \\ ' l The inspector observed portions of the following surveillance test activities. The inspector verified that operators properly implemented technical specification requirements, workers used proper procedural adherence techniques, and supervisors properly reviewed the test - data.
. Emergency Bus 5 Under Voltage Test . Turbine Driven Emergency Feedwater Pump Operability Test . Emergency D:esel Generator Monthly Run ' A' Train Residual Heat Removal Pump Flow and Valve Stroke Test a a Post Accident Sampling System Instrument Calibrations The inspector observed excellent coordination between operators, electricians, I&C technicians, and health physics technicians during surveillance tests OX 1413.01, "A Train _ _ _ _ . .- . . - . ~,. -
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! RHR Quarterly Flow and Valve Stroke Test, and 18 Month Valve Stroke Observation." The inspector noted that electricians and I&C technicians conscientiously used jumper ' installation / removal forms when installing jumpers or repositioning slide links.
During the emergency diesel generator run, the inspector identified three fuel oil leaks. The
inspector informed an auxiliary operator who documented t'e leaks for future corrective actions.
'I 2.3 Maintenance Rework + The inspector conducted a review of the North Atlantic maintenance rework performance
f data. The inspector held discussions with maintenance and technical support managers. The inspector reviewed maintenance procedure MA 3.1 " Work Requests," seven past corrective maintenance activities that had the potential to be classified as rework, and the 1992 system
support department annual report.
-l North Atlantic began tracking maintenance rework performance information in 1991.
Maintenance workers evaluate corrective maintenance work request for rework. Rework is ,' any maintenance required, du. :g or following completioa of a maintenance activity, because of various deficiencies. MA.v.1 lists ten different deficiencies such as incorrect parts, failed - post maintenance test, or poor workmanship.
North Atlantic tracks monthly and annual rework data. The technical support staff evaluates ' the annual rework data for trends. The North Atlantic goal is to keep corrective maintenance.
' rework less than 51 The latest available rework data, August,1993, showed a monthly
rework of 8.0% and an annual rework of approximately 5.2%. The maintenance manager l had not assessed the data. The technical support staff reviews the rework data at the end of
the year.
) The inspector reviewed the 1992 system support department annual performance report. The j report analyzed equipment failures by cause codes and by systems. The report stated that the
principal failure mechanisms were wear-out and unknown. The report assessed that system { engineers need to be more discerning with respect to the assignment of failure codes assigned.
" by workers at the tirne of the close-out review. The report identified four systems that had j high failure rates. The system engineers completed the evaluations and implemented correctis e acti n 1 The inspector considered the performance report information to be-meaningful.
- i The inspector selected and reviewed seven corrective maintenance work packages'to verify proper implementation of the MA 3.1 rework criteria. Maintenance workers classified four of the seven work activities as rework. The inspector determined that all seven of the work . - . .
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, ! ! activities should have been classified as rework as defm' ed in MA 3.1. The inspector considered the improper classification of three work activities to be a minor implementation ' problem. The maintenance manager acknowledged the inspector's concern and indicated that the rework classification of the three work activities would be reviewed.
During this inspection period, the maintenance staffissued change No.15 to MA 3.1. North l Atlantic revised the rework criteria in an attempt to make the data more meaningful. The , change deleted three of ten criteria for classifying work as rework, removed a nine month - . time limit on rework, and moved the rework block on the work request form to a better location. The maintenance manager indicated that plant workers would be trained on the changes.
The inspector assessed that North Atlantic tracked maintenance rework and had established reasonable goals. The technical support staff analyzed the rework data for trends at the end of each year. The inspector considered the inclusion of maintenance failures during the , maintenance process and during post maintenance testing to be a strength. The inspector ' identified minor rework program implementation problems. The inspector concluded that opportunities exist to further define and examine maintenance rework data.
. 2.4 Instrument and Control Continuing Training Program The inspector attended an instrument and control (I&C) continuing training session. The
training session focused on the lessons learned from maintenance worker errors made on l main steam isolation valve MSIV-88 during the last refueling outage. Several maintenance managers attended the training. The facilitator reviewed the personnel performance issues.
The inspector observed an excellent exchange of information between the I&C technicians, supervisors, and the 1&C department supervisor. The inspector assessed that the I&C , technicians demonstrated a proper safety perspective during a lessons learned training session.
2.5 Plant Worker Overtime J The inspector reviewed pay records for maintenance and operations personnel between September 26 and November 9,1993 to inspect compliance with station overtime requirements. During that time, the plant was shutdown and maintenance was conducted twenty-four hours a day for two weeks. The pay records did not clearly present the hours that a worker did maintenance tasks.
, t In responding to the inspector's questions, the maintenance group manager determined that a
maintenance worker performing non-safety related tasks worked for 77. hours in a seven day period without receiving proper approval. Station Management Manual (SSMM), Chapter 2, i l I
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.) ! Section 6.22, requires written authorization from the department manager to allow a worker i to perform non-safety related tasks for greater than 72 hours in a seven day period. The maintenance group manager decided that the maintenance department needed a separate system for tracking work hours.
i Maintenance supervisors planned overtime during the plant shutdown and had assured each ! technician was off for a 24 hour period every seven days. However, the supervisors failed -
to consider the effects of moving a worker from the 12 hour day-shift to the 12 hour mid-j shift.
The inspector determined that the failure to control the work hours of a maintenance worker performing non-safety related tasks indicated a problem with maintenance department managing workers' overtime hours. The inspector concluded that the maintenance , department was sensitive to exceeding overtime guidelines and was working to correct the l identified problem.
'4 3.0 PLANT SUPPORT AREA (71707) ! 3.1 Health Physics , t The inspector toured the radiological controlled area and verified the current calibration of ! radiological monitoring equipment, the correct posting for radiation and contaminated areas, and the proper control of k>cked high radiation areas.
in Septe.mber, the operators cooled down the reactor coolant system with the 'B' residual , heat removal (RHR) system. The activity levels in the reactor coolant were elevated due to l crud bursts created by the starting of reactor coolant pumps following a reactor trip. As a .l result, the activity levels in the 'B' RHR vault increased. Contact readings on areas of the , 'B' RHR system piping reached 30 mSv [3 re-m]. As a result, the health physics'(HP) technicians created a locked high radiation area in the 'B' RHR vault. In preparation for the - i 'B' RHR pump quarterly surveillance test, HP supervisors preplanned activities needed to conduct the test.
' The inspector held discussions with the HP supervisors, reviewed the radiation work permit (RWP) for entry into the lock high radiation area; accompanied the HP technician monitoring . ' the test flow path; and observed HP technician coverage of an auxiliary operator (AO) working in a contaminated area on the 'B'.RHR pump pedestal.
Planning personnel revised the surveillance procedure to install temporary local gages in' low dose rate areas. During a pre-job briefing, HP supervisors detailed the radiological conditions in the RHR vault, arranged for HP technicians to monitor AOs in the RHR vault, and coordinated monitoring of the test flow path. The HP technician and AO walked through radiological controls for collecting RHR pump data.
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After the pump start, activity levels measured in the 'B' RHR vault decreased as the crud was uniformly mixed in the 'B' RHR loop. An HP technician monitored the increasing j activity levels in the test flow path as the radioactive water moved toward the primary drain tank. The HP technician communicated the progress of the RHR water and the increasing activity levels to the HP supervisor. The technician requested assistance when activity levels at 18" from the pipes approached 1 Msv [100 mrem], the activity level that requires establishing a high radiation area. After peaking at 0.9 Msv [90 mrem], the activity levels at 18" from the pipes decreased.
An AO gathered vibration readings on the 'B' RHR pump, by standing on the pump pedestal, four feet off the floor in a contaminated area. The AO wore booties, gloves, and a lab coat as required by the radiation work permit. When the AO exited the contaminated area, an HP technician removed the AO's booties with a gloved hand and placed the booties in a bag, which the HP technician held with a bare hand. The AO stepped across the contaminated area barrier onto a step ladder. The AO removed the anti-contamination gloves and placed them in the bag. The AO moved to a low dose rate area and removed his lab coat. The HP technician used his bare hand to place the coat in the bag. The inspector pointed out that a - button had fallen off the lab coat. The HP technician picked up the button with his bare hand and placed the button in the bag.
The inspector noted that the HP technician did not follow standard contamination control practices. HP supervisors had preplanned some variations from standard practices to minimize worker exposure. However, other poor practices were not preplanned. The inspector concluded that, even though no personnel contaminations occurred, the AO and HP technician demonstrated poor contamination control techniques.
The inspector and HP department supervisor discussed the advisability of practicing good contamination control techniques whenever possible. The HP department supervisor planned to have HP technicians explicitly state on radiation work permits when standard contamination practices were waived for dose considerations.
The HP department supervisor planned to hold discussions with HP technicians and provide training to radiation workers to emphasize the need for good contamination control practices.
The inspector concluded the HP supervisors effectively planned, directed, and monitored the radiological aspects of the quarterly RHR pump test.
~I 3.2 Security ! The inspector toured the protected area, verified adequate perimeter lighting, and monitored activities in the central alarm station and the secondary alarm station. The inspector observed security guards testing intrusion systems, monitoring people and packages entering the protected area, and conducting routine patrols. The security staff processed a fitness-for-duty (FFD) failure according to program requirements. The inspector verified the individual, . . . . . .... .. . .. .. .. . .. .-. .-
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who had failed the FFD test, had not entered the protected area nor worked on safety related - tasks. The inspector noted that I&C technicians effectively maintained security equipment.- The inspector concluded the security staff performance was good.
> 3.3 Housekeeping The inspector attended a planning meeting for an all hands field day. The manager of maintenance support and coordination met with the area housekeeping sponsors and reviewed the assigned areas of responsibility, number of workers available, and the items to look for i during inspection tours. Fach sponsor was assigned the task oflisting all deficiency tags hung in an assigned area. Not all sponsors attended the planning meeting.
l After the field day, the inspector noted improvement in cleanliness in certain areas'of the plant. However, the inspector identified several housekeeping deficiencies. The station l manager toured the plant and held discussions with the station staff on identified deficiencies.
On subsequent tours, the inspector noted excellent housekeeping conditions in all areas of the plant. The inspector concluded that management's commitment of resources and direct , involvement resulted in improved housekeeping, j i 3.4 Chemistry . The inspector observed two chemistry technicians draw a post accident sampling system sample. The inspector noted that the technicians followed the procedure and were j experienced.
4.0 ENGINEERING /TECIINICAL SUPPORT , The inspector observed the technical support manager's participation in the station manager's morning meeting. The system support manager maintained a detailed status of degraded equipment performance and possible repair plans. The inspector observed excellent technical support engineer involvement during the conduct of main steam isolation valve testing and during the repairs made to MSD-V-44, 5.0 SAFETY ASSESSMENT / QUALITY VERIFICATION 5.1 Corrective Action System The inspector reviewed how effectively plant workers enter problems into the North Atlantic corrective action system. The inspector reviewed the North Atlantic Management Manual chapter 12700 " Corrective Action System," the station operating experience manual (SOEM), 1993 station information reports (SIRS),1993 operational information reports (OIRs), and 1993 condition reports (CDRs). The inspector interviewed various plant workers and . management personne. i .
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. The SOEM specifies how to process operating experience occurrences.. North Atlantic uses a
' graded approach in evaluating occurrences. The CDR is used to report and evaluate non-operational conditions and events that fall outside the scope of the OIR and SIR programs.
An OIR documents non-reportable operational occurrences including near misses. The OIR _; requires final station manager review and approval for closure. SIRS document and evaluate l I potentially reportable and significant operational events. The SIR requires a SORC review and station manager approval.
The inspector determined that plant workers initiated proper corrective action documents.
l ' The inspector assessed that plant workers and management exhibit a proper safety perspective by continuing to identify and address problems.
, , 5.2 Auxiliary Operator Log Discrepancies: EEI 92-08-01 and EEI-08-02 (Closed) > On March 1,1992, a shift superintendent identified that an auxiliary operator (AO) had falsified the roving watch log sheet. Because of the finding, the North Atlantic independent review team evaluated the accuracy of AO logs dating back to March 1990. The team found many log entries that were inaccurate and identified six missed technical specification surveillances. North Atlantic suspended nine Aos and removed their qualifications.
' Additionally, four Aos resigned or had their employment ended.
The executive director nuclear production and the station manager conducted training for all station personnel on management's expectations for worker integrity and accurate record
keeping. The nuclear quality group developed a monthly surveillance, which included accountability checks of production personnel, observations ofindividuals conducting tasks, ' and reviews of documentation accuracy. The nine decertified Aos completed two weeks of classroom training, one week of on-the-job remedial training, and completed watches under observation before being certified as Aos.
The operations department revised the AO log sheets and conducted self-assessment of AO watch stander performance. On August 18, 1992, North Atlantic submitted a letter (NYN- , 92116) to the NRC, which described their AO performance action plan. The action plan contained twenty-one recommendations. The short and long term corrective actions were , assessed in NRC inspection reports Nos. 50-443/92-05, 92-08, 92-09, 92-13 and 92-15.
On October 15, 1993, the NRC issued a violation to emphasize the concern for the integrity - of personnel who conduct safety-related activities and to stress management's responsibility to assure records are complete and accurate. After considering the facts of this case, including North Atlantic's identification of the violations and the corrective actions taken, the NRC decided not to assign a severity level to the violations, nor require a response to the notice of violations. These items are closed.
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1 5.3 Licensee Event Reports Main Steam Valve Setpoint Testing Failure: LER 92-16 (Closed) The inspector observed the main steam valve setpoint testing and documented assessments of the testing in NRC inspection report no. 50-443/92-15. The inspector reviewed the LER and a subsequent report comparing the test methodology used by Furmanite for testing installed valves with the methodology used at Wyle Testing Laboratory. The report concluded there was no difference in test methodologies. The inspector determined the LER was complete and accurate. This LER is closed.
Reactor Trip Due to Unavailability of Two Circulating Water System Pumps: LER 92-25 (Closed) The inspector documented inspection of the reactor trip in NRC inspection report no. 50- , 443/92-27. The inspector reviewed the LER and concluded the report was complete and accurate. This LER is closed.
Train A Service Water Inoperability: LER 93-006 (Closed) The inspector observed this event from the main control room and documented inspection findings in NRC inspection report no. 50-443/93-05. The inspector reviewed the LER and concluded the report was complete and accurate. This LER is closed.
Protective Devices Not Analyzed to Function During Environmental Excursions: LER 93-07-01 (Closed)
Contrary to license commitments, the NRC electrical distribution safety function inspection (EDSFI) team identified that non-class lE electrical circuits were located in a harsh environment. The team assessed North Atlantic's responses to the findings in section 3.9 of NRC inspection report no. 50-443/93-80. The team identified two concerns associated with the non-class lE circuits, which the NRC will track as unresolved items.
! The inspector reviewed the L.ER. North Atlantic identified the root cause as a failure to communicate the requirements for non-lE circuits. As a result, programs such as design, testing, and procurement failed to incorporate associated circuit license commitments. The -
inspector concluded that the LER was completed and identified extensive long term corrective actions. This LER is closed.
Service Water Pump Discharge Check Valve Testing: LER 93-017 (Closed) i
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The LER reported a surveillance test condition that would cause an inoperable service water-l train following a loss of offsite power event. During testing of a service water pump , discharge check valve the motor operated discharge valve is opened and de-energized. Due
to pump interlock.s both pumps in the train would not automatically start after a loss of j offsite power.
j The inspector reviewed the LER, the revised surveillance procedure, and the service water ' [ pump logic circuits. The inspector verified that the surveillance procedure included ! appropriate steps for the manual restoration of service water flow following a loss of offsite - 'i power. The inspector noted that due to control logic differences the failing open of only two l of the four service water pump discharge valves would prevent the pumps from starting.
The inspector concluded that the LER was complete and factual.
. North Atlantic's transmittal letter identified that the LER was submitted four days beyond the
+ required 30 day period. The inspector discussed the late submittal with the regulatory compliance manager. The late submittal resulted from an administrative error during ! processing. The regulatory compliance manager plans to create a look ahead schedule for individuals in the review and concurrence chain to identify due dates for LER issuance.
j This violation of 10 CFR 50.73 reporting requirements will not be subject to enforcement - action because the licensee's efforts in identifying and correcting the violation meet the , ! criteria specified in Section VII.B of the Enforcement Policy.
, 5.4 Personnel Error Response Team The inspector observed a pilot training session on reducing personnel errors presented by the i station manager to his department managers. The station manager and the personnel error
review team (PERT) leader prepared the lesson plan. After the training, the department managers conducted a critique of the lesson plan and discussed how to best present the , training.
The lesson plan included the organizational mission statement, the management tools available to promote change, the desired cultural change and management's expectations.
The station managers concluded the training session by stressing that individual's actions' and l ownership of problems at all levels of the organization are necessary for Seabrook to
continue operations.
The department managers recognized that the training session would launch an attempt to. change the organizational culture. The manaprs debated what level of the organization should provide the initial training, what mem7ers of the North Atlantic organization should receive the training, and what type of follow-up training should be given by the department managers. The managers discussed s'iortening the training and the importance of each segment of the lesson plan.
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The inspector noted that the discussion and critique following the training was frank, professional, and insightful. Although some discussion issues were unresolved, the inspector concluded that the training and discussion helped establish a common understanding among the station managers that a need existed to establish a zero tolerance for personnel errors.
6.0 MEETINGS (30702) Two resident inspectors were assigned to Seabrook Station throughout the period. The inspectors conducted back shift inspections on October 13 and November 2, and deep back shift inspections on October 14 and 31.
.. Throughout 'the inspection, the inspector met with station management to discuss inspection -{ findings. At the conclusion of the inspection, the inspector met with the station manager and his staff to discuss the inspection 6ndings and observations. Licensee comments concerning the findings are documented in the applicable sections of this report. No proprietary information was covered within the scope of the inspection. No written material regarding the inspection Dndings was given to the licensee.
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