IR 05000443/1997001

Insp Rept 50-443/97-01 on 970114-0303.No Violations Noted. Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support

ML20137S185
Person / Time
Site:	Seabrook
Issue date:	04/08/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137S179	List: IR 05000443/1997001 ML20137S175
References
50-443-97-01, 50-443-97-1, NUDOCS 9704150052
Download: ML20137S185 (23)

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. U. S.' NUCLEAR REGULATORY COMMISSION

REGION I  !

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, .4 Docket No.: 50-443 License No.: NPF-86 Report No.: 50-443/97-01

. Licensee: North Atlantic Energy Service Corporation-l

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Facility: Seabrook Generating Station, Unit 1  ;

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Location: Post Office Box 300 I Seabrook, New Hampshire 03874 .]

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Dates: January 14,1997 - March 3,1997-9

. Inspectors: John B. Macdonald, Senior Resident inspector l David J. Mannai, Resident inspector l Lonny L. Eckert, Radiation Specialist, DRS  :

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John R. McFadden, Radiation Specialist, DRS j i

- Accompanied by: Javier Brand, Resident inspector intern )

Approved by: John Rogge, Chief, Projects Branch 8

- Division of Reactor Projects

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t 9704150052 970408 PDR ADOCK 05000443 PDR t[

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EXECUTIVE SUMMARY i

Seabrook Generating Station, Unit 1 NRC Inspection Report 50-443/97-01 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 7-week period of resident inspectio Additionally, radiation specialist inspectors from NRC Region I performed an inspection of the radiation protection progra Ooerations:

• Cooling tower pump flow surveillance activities were performed effectively, with operators demonstrating sound communications and coordination. Control room management reflected good safety perspectives. (Section 02.1)

• The corrective actions and program improvements associated with a NRC-identified violation regarding foreign material exclusion controls were effective and focused on station-wide performance improvement. (Section 08.1)

Maintenance:

• New fuel transfer activities from the new fuel storage vault to the spent fuel pool were performed effectively. A sound safety focus was demonstrated when the activity was stopped when the number and experience of maintenance personnel assigned to the task was questioned. (Section M1.1)

• The licensee adequately addressed the potential for seismic interaction between a chainfall that had been attached to containment recirculation sump valve CBS-V .

008 for a previously unresolved item. (Section M8.1)

Enaineerinal

• Leak sealing activities performed on a main steam pressure transmitter root isolation valve were well-controlled with excellent Seabrook Station supervisory oversight and control of leak sealing vendor personnel. Sound engineering analyses supported the leak sealant activities. (Section E2.1)

E! ant Suonort:

• Radiological protection program controls were observed to have been properly implemented. Station personnel were observed complying with established procedures, programs and controls. Several strengths were exhibited especially in regard to the efforts expended in evaluating the need for programmatic changes as a result of the potential impacts of fuel defects. (Section R1-R8)

• Conduct of an emergency preparedness drill was effective with appropriate licensse self-assessment and critique of the emergency response activities. (Section P1.1)

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' EXEC UTIVE SU M MARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . il _ l

1. Operations .................................................... 1 'l 01 Conduct of Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 j

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01.1 General Comments (71707) . . . . . . . . . . . . . . . . . . . . . . . . . . 1 O2 Operational Status of Facilities and Equipment . . . . . . . . . . . . . . . . . . . 1  !

02.1 'A' Train Cooling Tower Pump Flow Surveillance ............ 1 i 08 Miscellaneous Operations issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 i 08.1. (Closed) Violation 96-02-01 Lack'of Foreign Material Exclusion

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l C ont rol s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 _

11. Maintenance .................................................. M1 Conduct of Maintenance ..................................4 .;

M1.1 New Fuel Offloading ................................ 4 )

M8 Miscellaneous Maintenance issues ........................... 5 j M8.1 (Closed) URI 50-443/96-02-02, Chainfall Hoist Attached to i Safety-Related Equipment ............................ 5 Ill . Engi ne e ring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 E2 Engineering Support of Facilities and Equipment . . . . . . . . . . . . . . . . . . 5 E2.1 Secondary Plant Leak Sealing Activities . . . . . . . . . . . . . . . . . . . .j IV. Plant Support .................................................

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R1 Radiological Protection and Chemistry Controls .................. 7 R 1.1 General Comments ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 R1.2 Response to Primary to Secondary System Leakage and Preparations for Fuel Defects . . . . . . . . . . . . . . . . . . . . . . . . . . 7 R1.3 Planning and Preparation for the Upcoming Refueling Outage .. 11 R1.4 Other Changes to the RP Program . . . . . . . . . . . . . . . . . . . . . . 12 R2 Status of RP&C Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . 12 R6 RP&C Organization and Administration ....................... 13 R7 Quality Assurance in RP&C Activities ........................ 13 R8 Miscellaneous RP&C lssues ............................... 14 S1 Conduct of Security and Safeguards Activities . . . . . . . . . . . . . . . . . . 15 S1.1 General Comment (71707, 71750) . . . . . . . . . . . . . . . . . . . . . 15 P1 Conduct of EP Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 P Emergency Preparedness Drill (71707, 71750) . . . . . . . . . . . . . 15 ,

V. Management Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 X1 Exit Meeting Summ ary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 i'

PARTI AL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

' INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 LIST OF ACRONYM S USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 i

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b Report Details .)

i Summarv of Plant Status )

- The facility operated at approximately 100%~of rated thermal power throughout the inspection period with routine minor power reductions performed to support instrument  ;

calibrations and turbine valve testin ]

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l. Operations I

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01 Conduct of Operations {

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ii 01.1 . General Comments (71707) ',

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Using. Inspection Procedure 71707, the inspectors conducted frequent reviews of- {

ongoing plant operations. In general, routine operations were performed in

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j accordance.with station procedures and plant evolutions were' completed in a  !

deliberate manner with clear communications and effective oversight by shift _

> supervision. Control room logs accurately reflected plant activities and observed ,

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shift turnovers were comprehensive and thoroughly addressed questions posed byL l the oncoming crew. Control room operators displayed good questioning j perspectives prior to releasing work activities for field implementation. The !

Inspectors found that operators were knowledgeable of plant and system status.

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02 Operational Status of Facilities and Equipment 0 'A' Train Cooling Tower Pump Flow Surveillance Inspection Scope (71707,62707)

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On February 27,1997, the inspectors observed portions of the cooling tower pump SW-P-110A quarterly flow surveillance performed in accordance with procedure

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. OX1416.05, " Service Water Quarterly Operability Test Cooling Tower Pump" (RTS ,

97ROO304001). Additionally procedure ES1830.OO2, "SW-P110 Pump Head '!

Verification" was performe j The inspectors attended the pre-evolution brief, observed portions of the actual !

surveillance, reviewed the on-line maintenance assessment form, applicable procedures, completed test results, UFSAR Section 9.2 and held discussions with .

operations, system engineering and inservice test program personne j i

b.- Observations and Findinas -

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The inspectors noted the pre-evolution brief was attended by appropriate involved !

personnel. The Shift Manager and Unit Shift Supervisor demonstrated critical l

- questioning attitudes regarding flow instrumentation venting procedures and the

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- need for stationing an operator at service water (SW) valve SW-V-54 during pump {

head curve data acquisition when the valve is in the throttled positio !

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. The licensee had made the decision to establish new reference pump head curve -

values since the service water flow instrumentation can be affected by entrained air !

in the service water system. The entrained air.can affect the differential pressures j '

and thus impact pump performance data. Previously, pump perforrnance data changes may have been caused by inconsistent venting practices rather than actual .

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' pump performance changes. To ensure consistent and repeatable flowrates are '

obtained for ASME Section XI IST flow surveillance testing, a detailed venting procedure was develope '

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. ,The surveillance was performed in a deliberate well-controlled manner using sound ;

i -- communication and coordination. The Shift Manager directed the test be put on

hold while control room shift turnover took place. The inspectors observed good turnover between control room operators with an excellent focus on procedure

, , steps.' involved personnel were knowledgeable of their roles and responsibilitie ,

The inspectors also observed vibration data acquisition for the "A" train cooling l tower pump and questioned the operator stationed at valve SW-V-54.

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i i~ The inspectors noted excellent self-checking practices when a control room operator j

- realized that the procedure did not require placing a main control board remotely I

operated valve switch from the closed position back to the auto position (unlike most switches this switch is not spring return to auto) after the valve was closed.

l The operator recognized this as a change from the former surveillance procedure

prior to the Procedure Upgrade Program (PUP) revision. Previously, management

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made the decision to remove the specific procedural direction regarding control ,

, switch position to ensure the switch is returned to the auto position. Similarly, ACR i

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.97-128 had recently documented a control switch that was found mispositioned- 4

.(closed vice auto / closed ) following surveillance testing. A procedure change was -

. Initiated for the applicable procedure. The inspectors reviewed the completed ACR evaluation. The ACR evaluation was a trend only with no generic implications considered for the station procedure program. The inspectors found that operations !

, management expects operators to know that these switches must be manually ,

returned to the auto position. Notwithstanding, department management is i reevaluating the operations procedural program direction relative to this issue.

i I Conclusions

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The inspectors concluded the surveillance was performed satisfactorily. The

inspectors independently verified the surveillance acceptance criteria were satisfie !

involved personnel performed the evolution while maintaining critical questioning l

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safety-perspectives. Sound communication and coordination among allinvolved 1 personnel was observed. Operations personnel properly executed service water j system lineup changes. The operations procedure program for procedural l

verification of components is being reevaluated by operations management. The l inspector had no further questions at this time.-

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08 Miscellaneous Operations issues .

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, 08.1 (Closed) Violation 96-02-01 Lack of Foreign Material Exclusion Controls

- Inspection Scope (71707,62707)  :

NRC Inspection Report No. 50-443/96-02 documented a violation of Seabrook  ;

Technical Specifications 6.7.1 which requires that written procedures shall be  ;

established and implemented and maintained covering the activities referenced in

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Appendix A of Regulatory Guide 1.33. Station management manual Chapter 2, Policies, Section 7, " Housekeeping / Cleanliness / Foreign Materials Exclusion" requires ,

that controls for FME be implemented per procedure MA 3.4, " Foreign Material [

Exclusio ;

t Contrary to station requirements, the inspection identified the lack of FME controls :

for temporary jumpers used for surveillance testing of the risk significant turbine i driven emergency feedwater pump. The inspector reviewed the licensee's reply to a notice of violation, Review Procedure MA 3.4, and completed ACR 96-308 evaluation. The inspector held discussions with station personnel.

' Observations and Findinas i The licensee implemented the program enhancements described in the violation response and completed ACR evaluation. Additionally, the inspector verified the completion of corrective actions associated with ACR 96-30 .

l The licensee's review concluded station personnel have historically viewed FME as j the responsibility of the maintenance group without the full recognition and  ;

understanding that FME is the responsibility of all station personnel. Operations !

personnel performing the surveillance were not aware of the FME requirements regarding small components that interface with plant system A new position has been created and staffed that will be responsible for overseeing the conduct of housekeeping and FME practices in the plant. This willinclude  ;

oversight of production activities performed by the various departments at the  !

station. The responsible individual will work with the responsible line organizations ,

to implement sound practice l

The inspector reviewed the revised program contained in procedure MA 3.4,  ;

" Foreign Material Exclusion." The FME program enhancements were, in part, I developed by benchmarking industry best practices. The inspector found the  ;

procedural controls comprehensive regarding both FME planning and l implementation. The attribute requiring performance of an FME surveillance with a ch6cklist is noteworth l

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4 Conclusions The inspector concluded FME program enhancements and changes were sound and focused on station wide responsibility and accountability. Corrective actions associated with the ACR and violation response were comprehensive and complet The industry beach marking effort and the establishment of a staff position for FME were considered notable strengths. The inspector had no further questions and considered the violation closed. (CLOSED, VIO 50-443/96-02-01)

11. Maintenance M1 Conduct of Maintenance M1.1 New Fuel Offloading , insoection Scone (62707.60705)

On February 25 and 26,1997, the inspectors observed portions of transfer of new fuel froni the fuel storage vault into the spent fuel pool. The activity was performed (WR 96 WOO 1025) using appropriate station procedure The inspectors directly observed new fuel transfer activities, reviewed procedures, and held discussions with reactor engineering, maintenance, operations and health physics personnel, Observations and Findinas The inspectors found the new fuel transfer activity was performed safely, effectively and according to procedure. Good coordination and communication were demonstrated. Good self-checking practices were noted. Documentation of the various fuel movements were performed in a step-by-step manner. Foreign l Material Exclusion (FME) controls were properly implemente l The reactor engineer supervising the activity demonstrated outstanding safety perspectives by promptly informing shift management of a concern regarding the number (two vice three mechanics) and the experience of maintenance personnel assigned to the task. The activity was resumed when an additional experienced mechanic was provided by the maintenance group. Operations personnel operated the spent fuel crane carefully and deliberately. The inspectors noted that there was no operations management direct oversight in the fuel storage building during the inspection. Discussions revealed no specific operations oversight was planned or performe Conclusions Station personnel performed new fuel transfer activities correctly and carefully according to station procedures. The inspectors found involved personnel were knowledgeable and experienced. Although the activity was performed well, the lack

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of deliberate operations management oversight was considered an area for improvement. The inspectors had no further question M8 Miscellaneous Maintenance issues M8.1 (Closed) URI 50-443/96-02-02, Chainfall Holst Atteched to Safety-Related Equipment NRC Inspection Report No. 50-443/96-11 documenteu an updated NRC review of the completed evaluation for ACR 96154. The unresolved item was originally documented in NRC Inspection Report No.50-443/96-02. The inspector questioned the lack of a qualitative or quantitativt, analysis of the potential for seismic interactions with the chainfall attached to the containment recirculation sump valve CBS-V-00 Engineering performed a qualitetive review using the stress report for the encapsulation tank (FPS 3312). The licensee concluded the vibration induced forces due to the added mass of the chainfall acting on the trolley and encapsulation tank would be minimal. This was primarily due to the flexibility of the slackened chainfall. The engineering review was documented in an addendum to ACR 96-154, which was approved by the Management Review Team (MRT).

The inspector reviewed the ACR addendum and the stress report. The documented .

I engineering review was considered adequate. The inspector considered the lack of the documented engineering analysis in the original ACR evaluation may have e.,een i attributed to the maintenance department responsibility for ACR resolutio Although there were no adverse consequences the need for engineering involvement in the resciution of certain aspects of this particular ACR was not fully recognized by the maintenance group or the Management Review Team (MRT). The )

inspector had no further cuestions and this item is considered closed. (CLOSED, URI j 50-443/96-02-02)  !

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111. Enaineerina E2 Engineering Support of Facilities and Equipment E2.1 Secondary Plant Leak Sealing Activities l inspection Scoce (62707.37551)

On February 21,1997, the inspectors observed leak sealing activities (WR96 WOO 2839) for main steam valve MS-V-14, The root isolation valve for main steam line pressure transmitter 1-FW-PT-516. The leak sealing was performed due to a packing leak on the valve. Prior attempts at tightening the packing were ensuccessfu ,

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i The inspectors reviewed the work package, engineering analyses, attended pre . )

evolution briefings, and held discussions with control room personnel, system engineer and the work group superviso b. Observations and Findinas The inspector used inspection guidance contained in NRC inspection manual chapter l 9900 while reviewing leak sealing activities. The inspectors found the necessary I engineering controls and analyses were used in developing the work packag The injections were performed by vendor personnel under the direct observation and supervision of Seabrook Station personnel which included a maintenance supervisor and the system engineer. Activities were performed according to Seabrook Station j procedure The inspectors questioned the adequacy of the pressure gauge range of the leak sealant injection pump. The injection assembly was supplied and controlled by the vendor. The gauge had a range of 15,000 psig (calibrated for 0-10,000 psig) and the procedure limited the maximum sealant injection pressure to static pressure plus l 2000 psi. ASME code requirements for pressure gauge ranges are applicable to !

hydrostatic or pneumatic testing. However, the licensee decided to require the use of a pressure gage range of 0-5000 psig in the future which is consistent with ASME requirement The inspectors noted that maximum injection pressure was not exceeded during the two attempts. Between injection attempts, a decision was made between field personnel with control room concurrence to slightly loosen the packing gland J fasteners and cycle the valve off its backseat and return it to the backseated position and tighten the packing gland fasteners to facilitate better sealant flow. The inspectors questioned field personnel if this contingency should have been placed in the work package since it may be routinely required when for packing leaks. The system engineer directed the leak sealing activity be secured after two unsuccessful attempt c. Conclusions The inspectors found the leak sealing activities were accomplished in a controlled manner according to station procedures with good direct oversight and control of vendor personnel and practices. Field communications with control room personnel were very good. Licensee leak sealing activities were performed consistent with the NRC inspection guidance. The decision to stop leak sealing activities after two unsuccessful attempts was considered prudent. The inspector had no further question .

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IV. Plant Sunoort R1 Radiological Protection and Chemistry Controls l

R1.1 General Comments Inspection Scone (71701,71750)

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During the inspection period, the inspectors toured the radiologically controlled area ;

(RCA) on several occasions to observe radiological controls practices.

~ Observations and Findinas The Seabrook Station radiological controls technicians at the RCA checkpoint were attentive and provided assistance to radiation workers to assure proper work practices were used when radiation workers signed in and out of the RCA. The inspector determined that radiation area postings were proper and well marked and survey results were current and posted properly. All personnel observed were properly wearing dosimetry while in the RCA. A sampling of high radiation area doors identified no discrepancies with locking or posting requirements, Conclusions The inspector determined that Seabrook Station was properly implementing the station radiological controls program requirements in the areas inspecte Radiological controls personnel were knowledgeable of station procedures and provided good oversight of radiation workers. Department managers were observed in the field observing and supervising department personne R1.2 Response to Primary to Secondary System Leakage and Preparations for Fuel Defects 4 Inspection Scope (83750-01)

Reviews were performed of the licensee's responses to the primary to secondary system leakage and of their initiatives, evaluations, and actions in preparation for the effect of fuel defects on outage activities. Information was gathered through observation of activities, tours of the RCA including the CTB, PAB, FSB, and WPB, discussions with cognizant personnel, and review and evaluation of procedures and documents, Observations and Findinas in November 1996, the licensee identified primary to secondary system leakage, and, in December 1996, the licensee identified an increasing concentration of radioactivity in the primary system due to suspected fuel defects. During this time frame, operation of the letdown degasifier resulted in airborne radioactive gas levels in the containment building and on the 53 foot level of the WPB which peaked at i

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several DACs. Sources of the gas leaks on the letdown degasifer system are baing :

Identified and corrected. The licensee reported that, although the airborne radioactive gases have not posed a sigr.ificant personnel dose problem due to their

relatively low average concentrations, the particulate daughters from these gases have reached levels that are detectable on personnel in the IPM whole body frisk booth Over the past year, the licensee stated that numerous reviews and initiatives have been implemented or are currently under evaluation in response to the potential for changing radiological conditions due to the existence of fuel defects, including

1) HP group internal issues, such as event specific training, response checklists, meetings and daily newsletter articles to increase station awareness, review of HP instrumentation needs (i.e., supply of teletectors and alpha instrumentation), review of the plant's monitoring of isotopic mix and evaluation of any changes, review of the adequacy of whole body counting parameters, visits to other plants with experience with fuel defects to benefit from lessons learned, and a review of current and potential changes in plant dose rates and ALARA concerns; 2) Station operational issues, such as radiological conditions encountered on

. security rounds, impact of IPM alarms due to noble gas, the potential for fuel fleas (hot particles to date have been limited to discrete particles of activation product; skin dose conversion factors to be reviewed based on any new isotopic data on fuel fleas), increased dose rates during filter and resin changes (consideration of post-sluicing flushing), identification and correction of leaking components / airborne areas, containment and RCA work, crud burst response plans, head lift and pressurizer venting issues, and fuel repair issues, decision process for balancing clean-up time and outage extension if. activity concentration limits cannot be met prior to flooding up the refueling cavity (concern about dose rates on the refuel bridge),

potentially higher tritium levels during refueling operations due to earlier use of boron removal resin and less dilution at the end of the cycle; and 3) Design issues, such as the spent fuel heat exchangt,rs (located in an unshielded, high traffic area), the cavity drain system, pressurizer steam space venting, letdown monitor location on the 25-foot level of the PAB (unshielded, high traffic area), the floor drain system, the RWST cleanup

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(potential for elevated dose rates due to a large volume source), and primary to secondary system leak The inspectors reviewed 1) health physics technician training handouts, HP1106C and HP11116C, titled Source Term increase,2) Seabrook Today articles dated December 12,1996 and January 27,1997 which addressed the issue from the-

. radiation worker perspective, 3) a memo from the health physics group to distribution including station management dated March 27,1996 and titled Station Response to a Significant Source Term increase, which listed 30 potential issues to be addressed,'4) a presentation package titled Source Term Management,

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5) Procedure HNO958.47 (Rev. 00, Effective date '02-13-97) titled Health Physic j

. Response to Failed Fuel,6) the current Failed Fuel Preparations Summary checklist .J of 26 issues which listed 15 actions which had been taken in response to the l existence of fuel defects and four on-going actions, and 7) a draft ORO5 fission gas -

I response protocol for limiting personnel access into RCAs or evacuation of personnel from RCA Other specific actions reported to have been taken by the licensee were:

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1 ) .. Generation of an outline for radiation worker event briefing;

2) Issuance of a memo by the radioactive waste group on filter change-outs to address the potential significant exposure during the dropping of expended ]

p t . filters from the shielded transfer cask in the WPB (a dose saving techniqu j

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identified at a neighboring nuclear station was under review);-

i' 3) Revision of the PCR nmcedure to address IPM alarms due to noble gas '

including a policy on ru idium-88/ cesium-138 decay; 4) Request for a cavity drain modification to provide a traveling hydrolazing lance (cavity drain lines have low flow and horizontal runs which lead to significant hot spots during cavity draining);

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5) Installation of water loop seals on several floor drains connected to the vents of various components to prevent leakage of noble gas;

6) Documentation of the need for rapid determination of changes to the isotopic

, mix in order to assess the impact on various radiation detection processes

since the calibration of various instruments will be effected by any significant change in the isotopic makeup; changes to the average beta and gamma

, energies as well as the introduction of alpha emitters may impact:

i) whole body count times and scaling factors (to achieve required j' MDAs for isotopes of interest);

ii) passive internal monitoring effectiveness (presence of transuranics

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may impact need for annual WBCs and for irlyitra bioassay);

iii) count room efficiencies for gross alpha and beta counting systems; e

iv) SAM calibration;

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i v)' air sample results (may need to account for hard-to-measure i radionuclides in gamma spectroscopy results); and j

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vi) Part 61 assessment for waste characterizatio l

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10-7) Action item to develop trigger pe:nts in the isotopic monitoring program and air sampling program to initiate Lrl vitro bioassay on selected workers, to reassess the sensitivity of passive monitoring, to reconsider the WBC

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frequency, and to evaluate the need to modify the PCR procedure guidance; 8) Routine HP survey program and surveillance schedule reviewed as follows:

i) the VCT, letdown demineralizer, A & B carbon delay beds, and PDT degasifier changed to LHRAs (operation and maintenance of the letdown and waste gas system will be adversely affected by the source term increase; the iodine guard bed and the first carbon delay bed have estimated dose rates of 840 R/hr contact for O.12% failed fuel);

ii) increase in surveys and addition of a particulate / iodine / noble gas !

sampler on the 53 foot level of the WPB;

I lii) addition of a quarterly survey to the waste gas system iodine guard '

beds and HEPA filters; iv) review of the surveillance schedule for determination of change in survey frequency, review of routine RWPs for sufficiency of radiological controls, and monitoring of selected in-service filters placed on the immediate respon'se checklist; 9) Review of the impact of significant levels of radiciodine and review of the use of ventilation including:  !

i) respirator use and checking of supply of iodine absorbent respirator cartridges;

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ii) TEDE ALARA assessments; j iii) assignment of internal dose; iv) WBC frequency; l l

v) preparation of hardware and procedures for the use of carbon absorbers for HEPA units; and vi) use of HEPA unit ventilation for waste gas oxygen sensor calibrations, i

c. Conclusions 1 Overall, the efforts in evaluating the need for programmatic changes as a result of ;

the impacts of fuel defects demonstrated a self-critical and continuous improvement !

approach and were considered to be comprehensive, pro-active, and commendabl .

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11 i R1.3 Planning and Preparation for the Upcoming Refueling Outage Insoection Scope (83750-01)

Reviews were performed of the licensee's planning and preparation activities for the upcoming refueling outage. Information was gathered through observation of i activities, discussions with cognizant personnel, and review and evaluation of procedures and documents, Observations and Findinas i

An additional person has been added to the HP planning function to handle the !

routine planning activities in order to allow the senior HP analyst to concentrate on 1 outage planning and coordination with HP and the development of outage RWP ;

The overall outage schedule and individual project schedules, which are provided by ,

the outage management system, are reviewed for evolutions requiring HP support and for the type and scope of support which is needed. Based on this review, an HP outage schedule will be produced which will be used in conjunction with the Plan-of-the-Day reports to coordinate the HP outage scheduling process during the outag !

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In addition, in preparation for the outage, the licensee also consults a HP/ Chem /Radwaste system of outage-specific action items which contains lessons learned and proposed improvements based on experience during previous outage ALARA review packages for approximately twelve outage projects were in various stages of development. Several packages, which were close to completion, were reviewed by the inspector. This review included those for steam generator eddy current testing and for RCP seals and "A" RCP motor replacement. The scope and depth of these reviews were extensiv The inspectors attended an RSC meeting on February 24,1996 in which OROS preparations for steam generator eddy current testing and tube plugging, preparations for reactor disassembly and reassembly, radiological issues related to crud deposits and fuelleaks, and the man-rem goal for the outage which was 90 (86.26 man-rem was incurred for OR04) were discusse The inspectors noted that the licensee is continuing to implement a broad task-based approach for the RWPs which has resulted in a smaller number of total RWPs (approximately 15 during non-outage time and approximately 30 during a refueling outage) and is continuing to use HP Operational Guidelines to provide RWP-type instructions for the radiation protection technicians which has resulted in shorter RWPs. These changes were intended to help radiation workers to not unintentionally sign onto the wrong RWP and to more easily understand the RWP information pertinent to them, especially during outage .- _ . .

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12 Conclusions Based on this review, the inspectors concluded that HP planning and preparation for outages and ALARA reviews were strengths and that the approach to writing RWPs demonstrated a good radiation worker orientatio ;

R1.4 Other Changes to the RP Program Several other programmatic changes were reviewed by the inspector The licensee stated that, if a TLD result is less than or equal to the cumulative ED -

dose and if the cumulative ED dose is greater than or equal to one millirem, the ED dose was being used as the record dose. This approach is conservative on the side of safet '

The licensee was conducting a pilot study on the use of dose rate familiarization maps. These maps use color-coded dots on posted maps to provide prevailing dose rate information to radiation worker The licensee was planning for the implementation of a " scrub" program which would allow the wearing of scrubs instead of coveralls for entries into low contamination areas to perform light work and inspections. The anticipated benefits are worker comfort, reduced heat stress potential, timesaving aspect on dressing and undressing, and laundry cost saving Based on this review, the inspectors noted that the licensee demonstrated a very cor.servative approach to recording record dose and further efforts for continuous improvemen R2 Status of RP&C Facilities and Equipment  !

l Insoection Scope (83750-01)  ;

Reviews were performed of the status of health physics facilities and equipment, especially automated access control of the RCA, UFSAR commitments, and new equipment. Information was gathered through observation of activities, discussions with cognizant personnel, and review and evaluation of procedures and document . Observations and Findinas The licensee reported that a modification of the automated access control software

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was under development which, along with TLD barcoding, would provide automatic checks for use of proper dosimetry during the RCA entry process. This TLD barcoding and incorporation of it into the electronic access control process appeared to be a good initiative. The inspectors verified that the RP&C facilities were being maintained per UFSAR Section 1 l

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. Conclusions  ;

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' Based on this review, the inspectors concluded that the licensee is properly j maintaining the health physics facilities and equipment and that the licensee's j

' efforts demonstrated a continuous improvement approac '

l 4 R6 RP&C Organization and Administration lj

i l Insoection Scone (83750-01) .,

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. A review of the' licensee's current health physics. organization was performed, -j

- especially changes since the last inspection. Information was' gathered through -l

observation of activities, discussions with cognizant personnel, and review and l

evaluation of procedures and document !

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Observations and Findinas j

Since the last inspection of this program area, the licensee has moved the HP l Services Group under the Health Physics Department Supervisor. The licensee

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l reported that this reorganizstion was made so that more efficient use of personnel l

could be attained. . The inspectors noted that five positions have been lost since the

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! last inspection: 1 scientist (certified health physicist),1 ALARA analyst, and 3

, operational radiation protection technicians.

4 Conclusions No degradation of the RP&C program is evident at this time, but RP&C staff.ng will

. be the subject of further review during the upcoming refueling outage and in the

. longer term.

i R7 Quality Assurance in RP&C Activities

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I Inspection Scope (83750-011 f Reviews were performed of the implementation by the radiation protection "

organization of the ACR process, of the HP and Chemistry group's programmatic self-assessment and management walkdown procedures, and oversight of vendor services. Information was gathered through observation of activities, discussions with cognizant ' personnel, and review and evaluation of procedures and document Observations and Findinas, implementation of the ACR process by the Health Physics Department was

reviewed. The licensee stated that the threshold for identifying issues is lower as

. compared to the threshold when the ROR system was used. The inspectors noted  !

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- that ACRs receive a higher level of management review as compared to the ROR system. The licensee reported that an individual within the HP department has been

, - trained as a root'cause specialist and that the use of root cause specialists is

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' intended to provide consistent root cause analysis results. The current system  ;

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provides for reporting of identified adverse conditions, the assessment and trending -l l

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of causes, and the tracking of completion of scheduled corrective actions. The

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licensee stated that a change in the assessment methodology was being evaluated .

which would lower the number of ACRs receiving a medium-level assessmen l

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In addition to the ACR system, there are also procedures both for chemistry and a health physics group programmatic self-assessments (thirteen conducted in 1996 to i

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evaluate radiation protection program elements) and for chemistry and health - ,

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physics group field management walkdowns and observation assessments (sixteen  :

in radiation protection in 1996)(including off-hours walkdowns). Deficiencies noted -l

, by.these mechanisms, which are lower than the ACR threshold, are trended by this group, and corrective actions are tracked to completion. Also, HP has their own

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.proceduralized walkdown and observation progra ; - A very high level of oversight on the TLD radiation badge vendor _ service has been- l demonstrated. Considerable time was expended by Seabrook Station staff in

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evaluating the services provided by their then-current TLD laboratory vendor service .

and several instances of TLD vs. ED discrepancies. As a result of findings revealed  !

by these assessments, the licensee decided to switch to a new badge service  !

,  ; vendor. The new badge service commenced in January 1997, and the first badge .!

pull under the new service is scheduled for April 199 .l

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Section 12.5.2.3 of the UFSAR dictates that the HP Department must take efforts

to ensure the quality of vendor-supplied bioassay services. The inspectors reviewed an audit conducted in 1996 of the Yankee Atomic Electric Laboratories in yltre i bioassay program and in which no deficiencies were noted. The inspectors l

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assessed that this UFSAR commitment had been met.

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l Conclusions '

i Based on this review, the inspectors concluded that the licensee is properly addressing quality assurance in the health physics activities and that the licensee's efforts demonstrated a strong emphasis on being self-critical and on maintaining a continuous improvement approac R8 Miscellaneous RP&C lssues

a. -Insoection Scone (83750-01)

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A recent discovery of a licensee operating their facility in a manner contrary to the

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updated FSAR description highlighted the need for a special focused review that

- compares plant practices, procedure and/or parameter to the updated FSAR descriptions. ' Selected portions of UFSAR sections 12.1 and 12.5 were reviewed, f-

' Observations and Findinas While performing th'e inspections discussed in this report, the inspectors reviewed

, the applicable portions of the updated FSAR that related to the areas inspected.

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observed plant practices, procedures, and/or parameter A review of selected portions of the UFSAR and limited reviews of record clothing program were p,erformed. Information wa activities, a tour of the RCA including the CTB, PAB, FSB, and WP8, discuss

' with cognizant personnel, and review and evaluation of procedures and do . Conclusions Department were as described in Sections 12.1 and 1 .

S1 Conduct of Security and Safeguards Activities S General Comment (71707, 71750)

The inspectors observed security force performance during inspection activitie Protected area access controls were found to be properly implemented du

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random observations. Proper escort control of visitors was observed. Secur officers were alert and attentive to their dutie P1 Conduct of EP Activities P Emergency Preparedness Drill (71707, 71750) Insoection Scoce (71707)

On February 19,1997, the licensee conducted a practice combined functional improvement while demonstrating the zeplant's the personnel in accordance with Station Emergency Response Man

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Classification of Emergencies, and to develop solutions foraplacing the station safe, stable condition. The inspector observed portions of the initiating event a operator response in the Simulator, and subsequent activation and staffing of the Technical Support Center (TSC). The inspector also observed n response acti the Emergency Operations Facility (EOF) which was activated attended the licensee drill critiqu r ,and during the d ill Observations and Observations The inspector found the drill was performed in a highly profession # 1 ma .

emergency response organization personnel involved. The licensee concluded tha the drill objectives in the areas of facilities management on ,

andand control detecti classification of emergency events, protective action decision making, notific

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and communication, etc, were met. The licensee's goal to identify areas for improvement was properly achieved and documente ;

c. Conclusions The inspector concluded the observed portions of the practice emergency drill and plant personnel activities and responses performed were effect:ve in demonstrating the drill objectives. The licensee held adequate critique briefings and properly  ;

documented the results. The inspector had no questions regarding the conduct of this practice dril .

V. Manaaement Meetinas X1 Exit Meeting Summary j The resident inspectors presented the inspection results to members of licensee  !

management, following the conclusion of the inspection period, on April 7,199 The licensee acknowledged the findings presente l

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The radiation specialist inspectors presented the inspection findings to members of licensee management on February 28,1997. The licensee acknowledged the .

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finding .

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie ]

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i 17 i PARTIAL LIST OF PERSONS CONTACTED

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Licenser

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B. Drawbridge, Exec. Director-Services * ,

W. DiProfio, Station Manager * +

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G. Kline, Technical Support Manager ,

R. White, Design Engineering Manager '

J. Grillo, Operations Manager

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B. Seymour, Security Manager W. Leland, Chemistry and Health Physics Manager A. Callendrello, Licensing Manager * ~

W. Cash, HP Dept. Supervisor * +

R. Cooney, Assistant Station Manager + ,

S. Dodge, Radiation Technical Specialist * + -l F. Haniffy, Radwaste Operations & Shipping Supervisor + '

' D. Hapta, HP Supervisor * i J. Marchi, Audit Manager * + l J. Peterson, Maintenance Manager * + ,

J. Rafalowski, C&HP Prcjcet Supervisor * i

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J. Sobotka, NRC Coordinator * +

R. Sterritt, ALARA Coordinator *

G. St. Pierre, Operations Manager * +

L. Tardif, Chernist +

R. Thurlow, HP Technical Supervisor * +

NRC

- Albert W. DeAgazio, Project Manager J. Brand, Reactor Engineer *

L. Eckert, Radiation Specialist * +

J. McFadden, Radiation Specialist * + )

D. Mannai, Resident inspector *

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+ Denotes those present at entrance meeting on February 25,1997

• Denotes those present at exit meeting on February 28,1997 )

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INSPECTION PROCEDURES USED IP 37551: Onsite' Engineering IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems

'IP 61726: Surveillance Observation  ;

IP 62707: Maintenance Observation  ;

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IP 64704: Fire Protection Program IP 71707: Plant Operations 3 IP 71750: Plant Support Activities  !

IP 73051: Inservice inspection - Review of Progra I IP 73753: Inservice Inspection IP 83729: Occupational Exposure During Extended Outages ,

. IP 83750: Occupational Radiation Exposure l lP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities

' IP 92902: Followup - Engineering IP 92903: Followup Maintenance IP 93702: Prompt Onsite Response to Events at Operating Power Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened l None Closed 50-443/96-02-01 VIO Lack of Foreign Material Exclusion Controls 50-443/96-02-02 URI Chainfall Hoist Attached to Safety-Related Equipment Discussed None l

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LIST OF ACRONYMS USED ACR Adverse Condition Report ALARA As Low As is Reasonably Achievable ASME American Society of Mechanical Engineers CAS Central Alarm Station CBS Containment Buuding Spray CTB Containment Building DAC Derived Air Concentration ED Electronic Dosimeter -

EDG ' Emergency Diesel Generator EFW Emergency Feedwater FME Foreign Material Exclusion FSB Fuel Storage Building GPD Ga!!ons Per Day GPM Gallons Per Minute HEPA .High Efficiency Particulate HP Health Physics LCO Limiting Condition for Operation LHRA Locked High Radiation Area MOV motor operated valve MPCS Main Plant Computer System NSARC Nuclear Safety and Audit Review Committee NSARC OS NSARC Operations Subcommittee PAB Primary Auxiliary Building PCR Personnel Contamination Report PDT Primary Auxiliary Building PSIG Pounds Per Square Inch Gauge QC Quality Control RCA Radiologically Controlled Area RCP Reactor Cooling Pump RHR Residual Heat Removal ROR Radiological Occurrence Report RP&C Radiological Protection and Chemistry RSC Radiation Safety Committee RWP Radiation Work Permit RWST Refueling Water Storage Tank SAM Small Article Monitor SG steam generator SIR Station Information Report SORC Station Operations Review Committee SUFP Startup Feedwater Pump SW Service Water TDEFW ~ Turbine Driven Emergency Feedwater Pump TEDE Total Effective dose Equivalent TLD Thermoluminescence Dosimeter TS Technical Specifications UFSAR Updated Final Safety Analysis Report i

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, } WPB " Waste Processing Building  :

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'WR Work Request

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