ML20006F439
| ML20006F439 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/01/1990 |
| From: | Curran D HARMON, CURRAN, SPIELBERG & EISENBERG, LLP., MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
| To: | Carr K, Curtiss J, Roberts T, Rogers K NRC COMMISSION (OCM) |
| References | |
| CON-#190-9901 OL, NUDOCS 9002280027 | |
| Download: ML20006F439 (127) | |
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HARMON, CURRAN & TOUSLEY C0CKETED 2001 S STREET, N.W.
USNRC SUITE 430 TASHINGTON, D.C. 200091125'90 FEB -2 P2:11
' GAIL McGREBT HARMoN HLEPHoNE
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DIANE CURIULN (202) 328-3500 DEAN R. 'IOUSLEY
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(202) 328 6918 5ANDRA K PIAU February 1, 1990" i
JA.
G GALLAGHER KATHERLNE A. MD*ER' 1
ERIC R. GUTZENSTEIN l
'Also admitted in Maryland Kenneth M. Carr, Chairman Thomas M. Roberts i
Kenneth C.
Rogers James R.
Curtiss i
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
SUBJECT:
Seabrook " readiness" review l
Dear. Commissioners:
4 On January 18, 1990, the NRC Staff, led by Messrs. Taylor, Murley and Russell, presented their finding that the Seabrook Applicants were ready for a full power operating license.
(Tr.
at 57)..Intervenors New England Coalition on Nuclear Pollution, Seacoast Anti-Pollution League, and Massachusetts' Attorney Gen-eral, were given five minutes to speak at the meeting.
They had' no notice that a week earlier, the Staff had issued numerous inspection and operational readiness reports relevant to its con-clusion.
The, reports relied on by the Staff were attached to cover letters dated January 8 and 9, 1990.
However, the Intervenors did not receive copies of the documents until the afternoon of.
January 18, after the Commission meeting had ended.
Thus, while-Intervenors ostensibly were given an opportunity to address the Commission on operational readiness, they did not see important documents relevant to the Staff's review -- let alone have. time to evaluate them -- before the Commission's meeting.
Given that l
these documents were dated nine and ten days before they were received, we can only conclude that the Staff deliberately with-held them.
On behalf of Intervenors New England Coalition on Nuclear Pollution, the Seacoast Anti-Pollution League, and the Attorney General of Massachusetts, I therefore respectfully seek your con-
-sideration of our written views regarding these documents.
The Staff's reports reveal a pattern of equipment failures, operator incompetence, and procedural deficiencies that should 9002290027 gog,DR.
43 PDR ADOCK P
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i HARMON, CURRAN & TOUSLEY NRC Commissioners February 1, 1990 i
Page 2
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provoke serious concern among the commissioners.
Aside from their substantive significance, the mere fact that these issues exist more than three years after the Applicants first claimed they were ready for a full power operating license is very trou-bling.
(The Applicants moved for a full power license in June of I
1986.)
The reported incidents include the following:
1)
During a " simulator" operator examination conducted in November, the operators ignored a stuck-open pressure-operated relief valve, because the emergency operating procedure being implemented at the time "did not specifically addre to be taken to correct this component malfunction."gs any actions At some undetermined later time, when the operators began using a dif-ferent EOP which provided guidane tors took the appropriate action.g for the open PORV, the opera-ER 89-11 at 3.
As the NRC noted in its Examination report, the incident shows a weakness in Applicants' policy on procedural adherence, which "does not give clear guidance for the restoration of equip-ment failures which may occur during the use of EOPs."
The Staff listed the test failure as an open item.
Idx It is clear that in addition, the operators' failure to respond promptly to a malfunction of safety equipment has other more serious safety implications.
First, had this error been committed during full power operation, it could have led to a serious accident.
It should be recalled that the operators' failure to respond promptly or correctly to a stuck-open PORV was the cause of the accident at Three Mile Island.
Second, the test demonstrated that operators were slavishly obedient to procedures, even when faced with a safety equipment 4
malfunction of potentially major significance.
We question what the operators would have done if they had not happened upon a l
different procedure that contained instructions for coping with l
the PORV.
It is impossible for EOPs to anticipate every poten-l 1
Examination report No. 50-443/89-11 ("ER 89-11"), dated Janu-ary 8, 1990.
A copy is attached.
2 The test also showed other problems not discussed at the com-mission briefing.
Three of the twelve applicants failed the examination.
The test results also revealed that even those operators-who passed the test did not have knowledge on a sig-nificant array of subjects.
Id2 at 3-4.
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HARMON, CURRAN & TOUSLEY j
NRC Commissioners February 1, 1990 j
Page 3 s
tial transient that may occur in a nuclear power plant.
There-fore, it is fundamental to any nuclear training program that i
operators must be trained to respond intelligently to unexpected events in the plant.
i It is not apparent to us that the problems demonstrated in the simulator test will be addressed in an adequate manner.
The NRC Staff states that it is treating this problem as an "open item."
IR 89-11 at 3.
However, the focus of the Staff's criti-cism is correction of the Applicants' written policy to include procedures for a stuck-open PORV.
Such a narrow approach is clearly insufficient.
The NRC should review the entire set of EOPs to determine whether other significant omissions exist.
For instance, do the EOPs anticipate the dominant accident sequences listed in Applicants' probabilistic risk assessment?
While the EOPs should be comprehensively reviewed to verify that reasonably anticipated accident sequences are accounted for, it is also important to train operators to respond appropriately to unanticipated events.
The fact that the Seabrook operators ignored the stuck-open PORV shows that the Seabrook training pro-gram is seriously -- and potentially tragically -- inadequate in this respect.
Assurances that reactor operators are trained and competent cannot wait until after the plant begins operating.
I The training program should be reviewed and improved, and opera-tors retrained before Seabrook is licensed.
1 2)
Seabrook Operational Readiness Assessment Team Inspec-tion 50-443/89-83 ("ORAT/IR 89-83") revealed that " maintenance staffisworkingsignifjcantovertimeandthebacklogofwork requests remains high."
The NRC Staff concluded that these problems constitute only "a potential detriment to effective operations support" (1d2 at 19).
However, thers is no indication that the Staff reviewed the nature of the maiscenance tasks that remain outstanding to determine their safety significance.
Significant maintenance overtime and a large backlog of maintenance work has historically been a serious concern to the Commission.
For Instance, the Pilgrim plant-was shut down between April of 1986 and December of 1989, in part because of a t.
J.
large maintenanc3 backlog.
The problems experienced at Seabrook would be negative performance indicators at an operating plant and are especially significant for a plant which, at the time of 3
ORAT/IR 89-83, dated January 9, 1990, at 2.
A copy is attached.
HARMON, CURRAN & Tousu:Y NRC Commissioners February 1, 1990 Page 4 l
the inspection, had been shut down for five months.
The passage of over three years since Applicants first claimed to be ready for full power operation makes it hard to understand how the staff could conclude, in January of 1990, that " maintenance staffing needs licensee consideration in relation to long term adequacy," (Idx, Section 2.3), but raises no " readiness" issues.
Before Seabrook can be allowed to operate, the nature of the outstanding maintenance problems should be reviewed for their safety significance.
In addition, the Commission should investi-gate the cause of a maintenance backlog during an extended period
[
of plant shutdown.
3)
Inspection Report 50-443/89-13 ("IR 89-13") details a number of mechanical breakdowns and procedural errors occu{ ring over a two-month period between October and December 1989.
While train "B" of the residual heat removal ("RHR") system was out of service for maintenance, a suction valve for RHR train "A"
stroked closed, resulting in a loss of all RHR cooling flow.
IR 89-13 at 8.
According to the NRC Staff, this transient resulted from a procedural error.
Idx at 9.
The nature of this error was not explained in the inspection report.
However, it is clear that the failure of the procedures to account for an out-of-service RHR train could be a potentially serious safety problem if this incident had occurred under accident conditions.
The report does not indicate that operational steps have been developed and verified, but merely that the issue remains "open."
Idi Moreover, despite the potential seriousness of this event, and despite the fact that this procedural defect was only one of many discovered by the NRC in the course of its inspec-tions, the Staff's report gives no indication that the procedures will receive the comprehensive review that is warranted under the circumstances.
4)
In addition, the Staff reported that on November 21, a
nonsafety-related tank in the Waste Processing Building was found in a partially collapsed and buckled condition.
The Stuff attributed the tank's collapse to misinterpretation of operating procedures, and to a lack of clarity in the procedures.
IR 89-13 at 9.
Again, however, despite the clear pattern of inadequacies in the Seabrook operating procedures, there is no indication that the Staff intends to conduct a comprehensive review of those procedures before the plant goes into operation.
4 A copy of the inspection report is attached.
i HARMON, CURRAN & Totsi tY NRC Commissioners I
February 1, 1990 Page 5 i
5)
The Staff also reported.that on November 9, "a loss of train
'A' power for a few seconds caused the control room emer-gency filter to start and align the control building air system in the recirculation mode."
The Staff attributed this to an electrical failure in the plant, but stated that the equipment could have been controlled through " proper procedural control and implementation,"
IR 89-13 at 10.
As in the previous examples, i
while the plant's procedures were implicated in the inspection, no comprehensive review is prescribed.
6)
In addition to the operators' failure to follow proce-dures, the low power test revealed several equipment failures which could have been prevented by competent installation and/or t
adequate surveillance and maintenance.
These include failure of an RHR valve to open remotely due to thermal binding, inoperability of eight frame vibratory indicators due to improper wiring, and backwards installation of an RCP flow element.
Idx r
at 9.
Thus, not only does NHY have a serious maintenance back-log, but there is a strong indication of a general failure in surveillance and correction of improperly installed equipment.
The incidents described above form a disturbing pattern of operator failures, incomplete or unclear procedures, and equip-ment breakdowns.
Yet, the Staff has treated them as isolated events, bearing relative unimportance.
Despite the potential seriousness of the incidents, no violations were cited in the inspection reports discussed above, and remedial steps have not been completed.
The reports discussed above simply do not describe a plant that is ready to operate at full power.
Moreover, the Staff's superficial treatment of the events described in the reports, its withholding of the reports from Intervenors, and its failure to discuss the issues raised in them with the commissioners, demonstrate an inappropriately partisan and biased attitude toward safety at Seabrook, which taints the reliability of the Staff's conclusions.
We therefore ask the Commission to make an independent review of the problems raised in the recent inspec-l L
tions and examination, including principally:
a) deficiencies in plant operating procedures; b) lack of adequate training for plant operators; and c) the nature and cause of the maintenance backlog.
Moreover, the Commission should investigate the reasons why a utility that was ostensibly ready for full power operation three years ago continues to have significant problems in these areas.
L
HARMON, CURRAN & TOUSLEY NRC Commidsioners February 1, 1990 Page !
In order to assure that the Seabrook plant will operate safely, these issues should be resolved before operation of the Seabrook reactor is approved.
Sincerely, Diane Curran I
Encl.
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aM ALL8h0AUE ROAD oNG OF PRUSSM. PENNeYLVANE 19406 JAN 88 Dockat Nc. 50-4a3 i
Public Service Company of New Hampshire ATTW: Mr. E*ard A. Brown, President i
and Chief Executive Officer I
New Hampshire Yankee Division Post Office Box 300 Seabrook, New Hampshire 03874 t
St E ECT:
Examination Report No. 50-443/89-11 (OL)
Gentlemen:
During the week of November 13, 1989, the NRC administered written and oserating examinations to twelve (12) employees of your company who had applied for licenses to operate Seabrook Station in Seabrook, New Hampshire.
t Based on the results of these examinations, nine (9) individuals were granted i
licenses.
Details of these examinations are described in the NRC Region 1 Examination Report which is enclosed with this letter.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of 1
this letter and its enclosure will be placed in the NRC Public Document Room.
While no reply to this letter is recuired, we ask that you pay particular attention to.the open item in section 4 of the enclosed examination report.
Should yev have any questions regarding the above statement or examination resvits, please contact us immediately.
Sincerely, f
1
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I R
rt M. Ga o,
it Operations Branch t
Division of Reactor Safety
Enclosure:
Examination Report No. 30-443/89-11 (OL) w/ Attachments 1, 2, and 3
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J. C. Duffett.
- esider.t and Chief Ezeevtive Officer, PSNH
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T. C. Feige-ta'.. Senier Vice President and Chief Operating Officer, NHY
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J. M. Pesche:. C;erational Programs Manager, NNY i
O. E. Moody. Station Manager. NHY
- i. Harpster, Director of Licensing Services P. W. A;nes, Jr., Assistant Secretary of Public Safety, Commonwealth of Massachusett l
Pelic Docurert Room (PDR)
Lccal Public Oo:v ent Room (LFOR) l Nuclear Safety Information Cer.ter (NSIC)
NRC Resident Insee:ter State of New Ha=:$ hire Conraonweahh f Massachusetts Seab-eck Fea-4.; ServiceList(w/ enclosure;w/oattachments) r t
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- .::i F MI. 0 3 U.S. NUCLEAR REGULATORY CC*NISSION REGION I i
0FER.ATOR LICENSING EXAMINATION REPORT i
i EXMINATION REPORT NO.: 50-443/89-12(OL) i i
FACILITY DOCXET NO.:
50-443 FACILITY LICENSE No.:
NDF-67 LICENSEE:
Public Service Co. of New Hampshire 1
P.O. Box 330 Manchester, New Hampshire 03105 FACILITY:
Seabrook Station EXAWIKATION DATES:
November 13-l',', 1989
!!$ 90 CMIEF ETAMINER:
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, Edward Yachimiak, Opeptions Engineer
[Qate APPROVED BY:
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_ 4:E; r Peter W. Eselgroth, Chief PWR Iection
' Cate SlDMARY:
(RO) license examinations were administered.Eight (8) S fully completed the written part of.their respective examinations.All ca Three (3) SRO applicants, however, failed the operating portion of their respective examinations.
license were granted, Five (5) SRO licenses and Four (4) R0 l
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TYPE OF EX&.INATIows:
5 Replae:Meent 1
EIAMINATICW RESULTS:
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- 3. CHIU EXAMINER AT SITE:
i E. Yachimiak (NRC)
- 2. DiWER EXAMINERS:
D. Wallace (NRC)
J. D' Antonio (NRC)
P. Doyle (NRC)
T. Gut 1 foil (Sonalysts)
- 3. Pre-Erastnation Review:
Reactor Operator (RO) written examinationsPrior t or ($RO) and the examinations'at our offices'in King of Pruss two 1989.
The results of this review resulted in a content v se ovember 2, operationally oriented examination.
.In addition, all simulator scenarios were reviewed and simulater instructors, also under security ag i
their use during the operating tests.
in scenarios which were both realistic and operationally orient I
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F eM. 0a0 JAN 14 90 1122?
3 Summary of Generie Stnneths _and Weaknesses I
a.
The fc11 ewing is a suonary of generic strengths or deficier.cies noted from This the administration and grading of the OPERATING and WRITTEN tests.
infctsation is being provided to aid the licensee in upgrading their J
No licensee initial license and requalification training programs.
response is required.
STADeGTHS i
Communicatices during the simulator examinations were clear and succinct.
1 The flow of information between operators was generally smooth and accurate. thus allowing all sembers of the crew to be equally i plant status.
of well develcred and maintained simulator training program.
WEAKNESSES l
QPERATING (Simulator) i The examiners noted that. during the performance of the emerg.ncy opera-ting peccedures (EOPs), a pressurizer PORY failed to resent after it had The EOP being implemented when this event opened to relieve pressure. occurred did not specifically address any actions The operators did not immediately take any this component malfunction.
action in response to this valve,'silure, but continued to follow their Af ter trar.sitioning to another E0P which provided guidance for the open PORV, the operators took appropriate steps to isolate the procedure.
7 valve.
The facility's policy on procedural adherence, OPMM Section 2.1, does not give clear guidance for the restoration of equipment failures The facility should ensure which may occur during the use of E0Ps.
that proper direction is provided in its policy on procedural adherence, consistent with the Westinghouse E0P User's Guide, for the instruction of operators on how to respond to equipment failures.
This ites will be reviewed by the NRC during subsequent inspection 50-443/89-11-01.
activities and will be identified as Open Item i
WRITTEN b
Operators generally did not have knowledge of the following:
the emergency load capacity of the station batteries (2.01/5.01) why the RCP seals are locally isolated during ECA-0.0 (2.02)
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when E-D is not implemented upon a reactor trip (2.04)
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the purpcse for adjusting $G A$DV controller to 1125 psig (
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-the RCP thermal barrier cooling system minimum temperature an reason for this limit (2.20/5.24)
I' how generator gas pressure is controlled (3.03) fa11ure alarm (3.12)the difference between a control red sy]
l, control rod system response upon failure of PT-505 (3.13) the events which occur durirg a D/G startup (3.19) l<
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which directly affect reactivity (3,35) conditions which operation of the containment s l
and without removal of the "3" pray system during RWST switchover with.'
signal (3.39) hydrogen gas explosive limit (3.47)
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man.eup pethods to the RCS when a loss of all RHR pumps occurs f
during shutdown cooling (5.30) i
- $. Simulatten Facility Fidelity Report l
During the conduct of the simulator examinations, no significant.
malfunctions occurred and the overall simulator performance was good However, the following list of deficiencies are items of concern which to be addressed so that the simulator's performance remains at a level I
training: commensurate with the continuation of effective initial and requalific i
Unavailability of component and instrument malfunctions without.
extensive instructor over-ride input.
Incorrect or inaccurate modelling of steam generator " Dry-Out" phenomena, Low Temperature Over-Pressurization (LTDP containment isolation valve 0 point (computer) values). peration, and o
RVLIS unavailability.
We are aware of your current activities in the area of simulator performance upgrades, and recognize that your schedule for completion of the above items will be based upon your established priority rating system.
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Carne, A.,
McCabe, E. Senior Resident Inspector Section Chief Yachiniak,E., Operation,E Division of Reactor Projects, RI s
f.asflit.L!fty_ stir;,tl ngineer Carlson L.
Hanley, R.,,
Operations TGrille,J.
, Ope; rations Ma0 erattons Training Supe Moody,,D nager ser Peterson., St raining Manager Richarcso,n,J., ation Manager A
P., ssistant Operations Manager Training Manager Attachments:
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- 3. Simulater $cera79,3 amination MASTER Key 0" M S M Key
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NUCLEAM REGULATORY COMMIS$1CN
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KINO OF PRUSSIA. PENNSYLVANIA 1940e Occket No. 50 443 Public Service Company of New Hampshire ATTN:. Mr. Edward A. Brown President and Chief Executive Officer
'New Hampshire Yankee Division Post Office Box 300 Seaerook, New Hampshire 03874 Gentlemen:-
Subject:
- 3eabrook Operational Readiness Assessment Tecm Inspection EO-443/39-83
..(11/13-20/89)
The enclosec report _ describes the findings of an llRC Operatierti Reaciness assessment Team (ORAT) ins;ection.
For the arecs reviewec, safe centrol of activities and :ompliance with NRC requirements were demonstrat:c, Progrmn-elements for ssfe operation were present.
Positive findings in each. inspection area incluced kanagement :nd st.tf f emphasis on operational programs.- The GRAT-concluded that' upon resolution of the three itema noted in this letter, Nei.
~~
Hampshire-Yankee (NHY) is ready and able to safely operate the Secorook Nuclear Power Plant.
As discussed'with members of your staf f at' the inspection exit meeting on November 20, 1989, - you agreed to tne following:
'(1) _ Verify that local operating and alarm response proccdures are availabla
.and useable at local operating and alar;n stations.
Safety-related proce-
!dures were to be verified prior to restart; non-safety-relatad procedures
'will;be completed prior to entering Mode 4
-Your staff'has since indi-cated partial completion of this item, which is being inscected sepa-rately.
(2) Verify that Technical'5cecification Clarifications and Interpretations'do not contravene the Final Safety Analysis Report or Technical Specifica-tions prior to entering the applicable operating mode.
-(3).. Provide a summary of the effectiveness of correctivo actions based-en NRC
' Confirmatory Action Letter 39-ll (accomplished by NHY letter dated Decem-ber 21, 1989) and obtain Regional Administrator. concurrence that the plant
'may be restarted (addressed in separate correspondence).
In addition to the items identified above, the ORAT sssessed the following items as having a significant potential for improving performance. These items are forwarded for your consideration, u
Reducing maintenance backlog and maintenance personnel overtime, s
.t.m.'
h2 -
SEAER00K WEARIN'i SERVICE IJST Public Service Company of New Hamoshire USNRC Resident Inspector ATTN:
Mr. E:,.a r:: A. Brown, Presicen:
Post Office Box 1149 and Chief Executive Officer Seacrook, New Hampshire 03874 Post Office Eox 300 Seaorook, New Hampshire 03874 Public Service Company of-New Hampshire Mr. T. Harpster ATTN:
Mr. John C. Duffett Public Service Company of Presicent anc Chief Execut1se New Hamoshire Officer P.O. Box 300 P. O. Eox 320 Seabrook, New Hampshire 03374 1000 Ehn Street Mancnester, New Hampshire 03105 Mr. Donald E. Moocv Mr. James H. Petchel Public Service Comoar.y of New Hameshire Public Service Company of N:tw Post Office Eox 300 Hampshire
!eabroot, New Hampsnire 03374 Dost Office Box 300 Seabrook, New Hampshire 03874 Mr. Ted C. Feigenbaum Mr. R. Hallisey, Directer
~
Public Service Comoany of New Harrpsnire Dept. of Public Health Senior Vice President & Chief Operating Commonwealth of Masssachusetts Officer Radiation Control Program Pes. Office Box 300 150 Tremont Street, 4th Floor Seaoreck, New Hampshire 03874 Boston, MA 02111 Massachusetts Transoortation E. Tupper Kinger, Esq.
Building Assistant Attorney General ATTN:
Sarah Woodhouse Of fice of Attorney General Legislative Assistant 208 State House Annex Ten Part Pla:a - Suite 2200 Concord, New Hampshire 03301 Boston, Massachusetts 02116 Thomas Dignan, Esq Jerard A. Crouteau, Constable John A. Ritscher, Esq.
82 Beach Road Ropes and Gray P. O. Box 5501 225 Franklin Street Salisbury, Massachusetts 01950 Boston, Massacnusetts 02110 Mr. Bruce Beckley, Project Manager Dr. Murray Tye, President New Fampshire Yankee Sun Valley Association P.O. Box 330 209 Summer Street i
Manchester, New Hampshire 03105 Haverhill, Massachusetts 08139
e L'
Seabrook Hearing Service List 2
Robert A. Backus, Esq.
George D. Bisbee, Esq.
Backus, Meyer and Solomon Assistant Attorney General 116 Lowell Street Office of the Attorney General P. O. Box 516 25 Capitol Street Manchester, New Hampshire 03106 Concord, New Hampshire 03301 Dhillip Ahren Esq.
Diane Curran Esq.
Assistant Attorney General Harmon and Weiss Office of the Attorney General 2001 S. Street, N.W.
State House Station #6 Suite 430 Augusta, Maine 04333 Washington, D.C.
20009 Steven Olesky, Esa.
D. Pierre G. Cameron, Jr., Esq Office of the Attorney General General Counsel One Asburton Place Public Service Company of P. O. Box 330 New Hampshire Boston, Massachusetts 02108 Manchester, New Hampshire 03105 Ms. Diana P. Ranoall Mr. Alfred V. Sargent, Chairman 70 Collins Street Board of Selectmen Seabrook,,New Hampshire 03874 Town of Salisbury, MA 01950 Richard Hampe, Esq.
Ms. Suzanne Breiseth New Hampshire Civil Defense Agency Town of Hampton Falls 107 Pleasant Street Drinkwater Road Concord, New Hampshire 03874 Hampton Falls, New Hampshire 03844 Mr. Calvin A. Canney, City Manager Senator Gordon J. Humphrey City Hall ATTN:
Tom Burack 126 Daniel Street U.S. Senate Portsmouth, New Hampshire 03801 531 Hart Senate Office Building Washington, D.C.
20510 Board of Selectmen Mr. Owen B. Durgin, Chstrman RF0 Dalton Road Durham Board of Selectmen Brentwood, New Hampshire 03833 Town of Durham Durham, New Hampshire 03824 Chairman, Board of Selectmen Rye Nuclear Intervention Committee Town Hall c/o Rye Town Hall South Hampton, New Hampshire 03827 10 Central Road Rye, New Hampshire 03870 Mr. Angie Machiros, Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Comm, for the Town of Newbury 825 North Capitol Street, N.E.
25.High Road Room 8105 Newbury, Massachusetts 01950 Washington 0.C.
20426 l
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Seabrook Hearing Service List 3
Ms. Rosemary Cashman, Chairman Mr. R. Sweeney
-Board of Selectmen New Hamoshire Yankee Division
' Town of Amesbury Public Service Company of Town' Hall
.New Hampshire Amesbury, Massachusetts 01913-Suite 610, Three. Metro Center Bethesda, Maryland 20814 Honorable Peter J. Matthews.
Administrative Judge Mayo,r, City of Newburyport Howard A. Wilber City Hall Atomic Safety and Licensing Appeal
-Newouryport,' Massachusetts 01950 Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Administrative Judge Alan S. Rosenthal, Chairman Thomas S. Moore, Esq.
Atomic Safety and. Licensing Aooeal Atomic Safety and Licensing Appeal Soard Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge a
Emmeth_A..Luebke, Jerry Harbour
-Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Wasnington, D.C.
20555
. Washington, D.C.
20555 Edwin J.-Reis, Esq.
H. Joseph Flynn, Esq.
Office of the General Counsel Assistant General Counsel
'U.S. Nuclear Regulatory Commission Federal Emergency Management Agency Wasnington, D.C.
20555 500 C. Street, S.V.
Washington, D.C.
20472 Edward A. Thomas Carol s', Sneider, Esq.
- Federal Emergency Manageme'nt Agency Assistant Attorney General 442 J. ' W. McCormack.(PDCH) -
Office of the Attorney General Boston,-Massachusetts 02109 One Ashburton Place, 19th Floor Boston,= Massachusetts 02108 Paul McEachern, Esq.
Richard A. Haacs, Esq
.Shaines and McEacnern.
Haaps and McNicholas
'25 Maplewooo Avenue' 35 Pleasant Street Portsmouth, New Hampshire 03301 Concord, New Hampshire 03301 Board cf Selectmen
-Allen Lampert 10 Central Street Civil Defense Ofrector Rye, New Hampshire 03870 Town of Brentwood 20 Franklin Street Exeter, New Hampshire 23833
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Seabrook Hearing Service List.
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..'l William Armstrong Sancra Gavutis, Chairman
- Civil Oefense Director Board of Selectmen' 1
~ Town of Exeter RF0 #1', Box 1154-i 10' Fient - Street...
Kensington, New Hampshire Exeter, New Hampshire 03833-03827:
1 Anne Goodman, Chairman Stanley V. Knowles, Chairman Boa'c'of Selectmen
.Boarc of Selectmen r
13-15 Newmarket Road f
- P. O. Box 710 Durham,'New Hampshire 03324 1 North Hampton, New Hampshire 03862' Norman C'. Kantner Judith H..Mittner.
Superintencent of' Schools Stiverglate.: Gertner,' Baker Fine,.
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LSchool Administrative Unit No. 21 Good, and Mitzner
'Aluani Drive 88 Broad Street t
-Hamoton, New.Hampshiri _03S42 Boston, Massachusetts 02110 Jane Ocugnty Gary W. Holmes, Esq.
Seacoast Anti-Pollution League ~
Holmes and Ellis 5 Market Street.
47 Winnacunnet Road i
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-Portsmouth,'New Hampshire-03801
~Hampton, New Hampshire- 03842
- i Mr.L Robert Carrigg, Chairman Adjudicatory File i
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Board of-S'electmen-Atomic' Safety and Licensing. Board y
- Town Of fice ~
Panel Oocket-
'Atlant Avenue' U.S. Nuclear Regulatory Commission-cNorth'Hampton, New Hampshire 03573 Washington, DC 20555 1
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U. S. NUCLEAR REGULATORY COMMISSION REGION I License:
NPF-67 Docket No.:
50-443 Report No.:
50-443/89-83 Licensee:
Public Service Company of New Hampshire New Hampshire Yankee Division Post Office Box 300 Seabrook, New Hampshire 03874 Inspection At: Seabrook, New Hampshire Dates:
November 13-20, 1989 Inspection Team:
Team Leader:
F. Young, Senior Resident Inspector, TMI Assistant Team Leader:
L. Kolonauski, Project Engineer, ORP Inspecters:
A. Cerne, Senior Resident Inspector, Seabrook S. Barr, Reactor Engineer, DRP N. Dudley, Project' Engineer, ORP H. Gray, Senior Reactor Engineer, DRS R. Nimit:, Senior Radiation Specialist, DRSS W. Oliveira, Senior Reactor Engineer, DRS J, Trapp, Senior Reactor Engineer, DRS G. Wunder, Project Manager, NRC:NRR purpose: To assess readiness for safe power operation through reviews of operations and operations support programs.
Findings:
This inspection found the Seabrook Nuclear Power Station capable of i
conducting and supporting safe power operation.
Items identified for resolu-tion were: assuring that local operating and alarm response procedures are nsable and available at local stations; and confirming that Technical Specif1.
cation (TS) clarifications and interpretations do not change any TS or alter the intent or commitments in the Final Safety Analysis Report. All Confirma-tory Action Letter CAL 89-11 items inspected by the ORAT were found acceptable; the remaining CAL 89-11 items were assinged to other inspections.
Approved by:
& C.
Od bh l[6[TC' E. C. McCabe, Jr., Team Manager '
Date i
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I TABLE OF CONTENTS i
PAGE 1.0 FIN 0!NGS
SUMMARY
I g
2.0 0VERVIEW.............................................................
1 2.1 Background......................................................
2.2 Inspection Scope................................
I 2
2.3 Results Summary.................................................
2 y
3.0 F A C I L I T Y MAN AG EM E N T ( 9 3 8 0 6 )..........................................
3 3.1 Review Scope....................................
3 3.2-Findings........................................
3 3.3 Conclusions.............................................
'6 L
4.0 PLANT OPERATIONS (40500, 42700, 71707, 93806)........................
6 4.1 Review Scope.......................................
6 4.2. Findings'..........................................
7 L
4.2.1 Operations Staff......................................
7 4.2.2 Operations Procedures.................................
9 4.2.3 Equipment Configuration and Operabilit 9
Hous e keepi ng..........................y C on t rol s......
4.2.4 10 4.2.5 Response to Operational Events........................
10 4.2.6 Self-Assessment Programs..............................
10 4.2.7 Technical Operations Support Programs.................
12 0
4.3 Assessment................................................
4...
12 4.4 Conclusions.............................,..
13 L
5.0 MAINTENANCE ( 35701,62700,62702,62703).............................
13 5.1 Review Scope....................................................
13 5.2 Findings........................................................
13 5.2.1 Management, Organization, and Staf fin 13 5.2.2 Work Contro1.........................g................
14 Table 5.2.a - Overall Maintenance Backlog.............
15 Table 5.2.b - Mode Department Maintenance Backlog.....
15 5.2.3 Material Control and Procurement......................
16 5.2.4 Calibration and Test Equipment Control................
17 b;
5.2.5 Personnel contro1.....................................
18 5.2.6 Management Support and Assurance of Quality...........
18 5.3 Assessment......................................................
19 5.4 Conclusions.....................................................
20 1
l Table of Contents o
PAGE 6.0 SURVEILLANCE ( 35701, 51700, 61725, 61726)............................
20 6.1 Review Scope....................................................
20 6.2 Findings........................................................
20 6.3 Assessment...................................................<...
21 i
6.4 Conclusions.....................................................
21 7.0 RADI AT I ON P ROTECTION ( 8 3 521).........................................
22-7.1 Review Scope....................................................
22 7.2 Findings........................................................
22 7.2.1 Organization and Staffing.............................
22 7.2.2 Qualification and Training............................
22' 7.2.3 Communications, Morale, and Attitude..................
23 7.2.4 Facilities and Ecu1pment..............................
23 7.2.5 External Exposure Controls............................
24 7.2.6 Internal Exposure Controls............................
24 7.2.7 Safety-Related Ventilation Systems....................
25 7.2,8 A LA R A P r o g r a m.........................................
26 7,2.9 Industria l Sa fety and Housekeeping....................
26 7.2.10 Process and Area Radiation Monitors...................
27 7.2.11 Radioactive Material and Contamination Control........
27
~ 2) Conclusions.....................................................
28
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7 8.0 ENGINEERING AND TECHNICAL SUPPORT ( 35701, 37700, 37701)..............
28 8.1 Review Scope....................................................
28 8.2 Findings........................................................
28 8.2.1 Engineering and Technical Support Staffing............
28,
8.2.2 Station Modifications.................................
29 8.2.3 Plant Safety and Reliab111ty..........................
29 8.2.4 Integrated Readiness Document (IRD)...................
30 8.2.5 QA/0C Interfaces in Engineering Modifications.........
30 8.2.6 Confirmatory Action Letter 89-11 Items................
31 8.3 Conclusions.....................................................
32
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' 9.0 J CONFIRMATORYr: ACTION LETTER (CAL).89-11 CORRECTIVE ACTION ~ PLAN (CAP) q f ",
. ( 4 0 5 0 0, 9 3 80 6 ).............. -................... i.............. c......
32
?9 1 LBackground;........................................../.............#: 32
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- 9.2.. Management. Oversight.'.....-......c..
............................. 133L
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- 9'3 Precedure Compliance.......L................;................... a..z 34 7
9.4; Power Ascension Test. Program Review.............................
35
~ 9.5 Assessment......-........................r.'......................
'36
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9 ; 6 ' C o n c l u s i o n s '........................................................ i 3 8 ;
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- 10. 0 E X I T M E E T I N G ' ( 3 0 7 0 3 ) ;.......-'.. c...... i........ :..... ;.....,......... -. -... :3S;
-ATTACHMENTS-Attachment.51:? )RC. Confirmatory Acti:n Letter 89-11 Items Reviewtc y
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' ' f: ' Maintenance. Procedures Reviewed or Observed 1
Attacnment 3:
Epit Meeting Attendees 1
FIGURES 5
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. 1, NHY Management-Organization
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NHY Operations Division-s 3A,-:NHYENuclear Engineering Department.(Corporate)
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33.; NHY Engineering Department (Technical Support)
Js NHYlSitetMaintenance Division:.
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'NHY! Health-Physics Organization' N
6.:. NHY Outage /Mecifications' Division 3
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' 3.0 FINDINGS'
SUMMARY
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This -Operational Readiness. Assessment. Team (ORAT). inspection-sample showed l
that e upon resolution of the items below, New Hampshire Yankee (NHY) is pre--
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.y, pared to safely operate Seabrook above five percent power,
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- 43) - Verification that local operating and alarm response procedures are avail-aole"and useable at local operating and alarm stations.
1 (2). Verification thatL all Technical Specification clarifications and inter-pretations do-not. contravene-the intent of the Final Safety Analysis 'Re-p
-port'or,the Technical Specifications.
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-(3) Completion of-licensee actions required by CAL 89-11..
px The ORAT'also identified the following for consideration as potential per-i formance-tmprovements.
Increasing tne in-field presence of middle m nagement.
Providing formal refresher and significant process change training.on l
,s CFR 50.59 safety evaluations for Station Operations Review Committee-
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(SORC).
Reducing the' administrative burden.on the SORC.
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-Reducing maintenance backlog and maintenance personnel overtime.
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Providing continuing radiological controls training for temporary radio
-locical controls personnel who are employed for' extended continuous'-
- periods, 1
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Establishing challenging ALARA goals and training job supervisors.and radiological controls. technicians in ALARA techniques, Providing. specific training for radiological-controls and operations:per-
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sonnel on'the radiological hazards expected from power operation, r
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'Providing additional engineering review of' Annunciator Response Procedures.
2,0-.0VERVIEW 2,1 Backaround
)I On'May 26, 1989, New Hampshire-Yankee (NHY or the licensee) was gran+ed i
low power license NPF-67 ~ for Seabrook Station Unit.1 -(Seabrook, the plant or
- the. facility).
NPF-67 superseded zero power license NPF-56.
Upon receipt of the low power li;ense, New Hampshire Yankee completed a transition from zero
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power operating procedures to normal operating procedures.
The NRC specified
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s that, before the Seabrook Nuclear Power Station would be authorized to operate "above 5% power, an operational readiness assessment would be made. An initial-operational-readiness assessment was made during inspection from May 27-June 1, 1989, and the results were acceptable.
On June 22, 1989, the operating crew failed to manually' trip the reactor during a natural circulation test when required by the startup test procedure.
Low power. operation was suspended.
The licensee and the NRC reviewed the event in detail. NHY ceveloped specific corrective actions tnat were be to performed prior to resuming low power operation.
2.2 Inspection Scope This ORAT inscection was conducted to furth r assess'the licensee's abil-ity to operate at power.
Team members inspected licensee readiness for plant startup, power ascension, and operation.
Radiological controls, maintenance, surveillance, engineering and technical sucport, and selected licensee commit-ments (based on :ne June 22 event) were also reviewed.
The ORAT ins:ection involved 358 inspection hours and emphasized activi-ties subsequent tc. June 1039, with program and procedure changes retoiving par-ticular attention.
In aedition to compliance with NRC requirements and licen-e see commitments, ORAT members assessed licensee readiness fcr safe operation based on their jucgement.
During the inspecticn and associated licensee meetings, the inspectors contacted and interviewed workers, first line supervisors, section, department, and division managers, and corporate personnel.
2.3 Retults Summary-o Facility management sygf fing, qualifications, and performance were found to be acceptable.
Key stafr members were found to have the proper safety per-spective and demonstrated a good understanding and a conservative approach to Seabrook operation, The Operations Department was adequately staffed with capablo managers,
. licensed operators, and administrative personnel. Operators were knowledgeable of their responsibilities and were provided with the equipment and procedures
.needed-for safe operation.
Station configuration control and self-assessment methods.were rigorous.
Interfaces between operations and operations support groups were acceptable.
. The maintenance organi:ation staf f and experience were adequate to support power ascension. Work control, material control, procurement, equipment cali-
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bration, and management functions were in place to support maintenance.
How-ever, the maintenance staff is working significant overtime and the backlog of work requests remains high.
Maintenance staffing needs licensee consideration in relation to long-term adequacy.
3 The Technical Specification Surveillance Program has been successfully implemented for Mode 5 operation.
Staffing levels and procedures are in place to support full power operation surveillance testing. The professionalism and knowledge of personnel conducting technical specification surveillances were strong.
NHY has established and implemented a generally well defined radiological controls program cabable of supporting power ascension and full power opera-tions.
Some areas for improvement were identified, and the licensee initiated immediate and appropriate corrective actions during the inspection.
The licen-see was in the process of reassigning responsibilities for radwaste management and transportation.
That reorganization was not assessed during this ORAT.
(Programmatic inspection of this area is scheduled for January 8-12, 1990 and will be documer.ted in Report 90-03.)
Engineering and Technical Support programs were in place to adequately support full power operation.
Inspector findings regarding the availability and useability of'the local emergency diesel generator procedures were resolved by the licensee curing the inspection.
No other safety-related local procedure deficiencies were found.
The licensee initiated action to confirm the avail-e ability and useability of all local alarm response procedures.
Licensee implementation and management oversight.of the Corrective Action LPlan for CAL 89-11 has been good.
The ORAT inspection concluded that the lic-ensee, upon completion and closure of all CAL items, and within the scope of this review, will be able to operate Seabrook Station safely and in accordance with NRC regulations.
W 3.0 FACILITY MANAGEMENT 3.1 Review Scope i
The inspectors reviewed facility management-readiness by examining the Seabrook organization and staffing (see Figures 1 through 6), interviewing licensee managers, and observing management involvement in activities.
The purpose of this assessment was to:
assess whether the NHY managerial organization is able to assure safe operation; confirm that the station was adequately staffed and that employees ex-hibited an appropriate safety attitude; and 4
' evaluate the effects of the recent NHY upper management changes.
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3.2 Findings
After the natural circulation test event, the licensee undertook NHY man-agement changes and realignment.
(Figure 1 represents the revised NHY organi-zation.) First, the licensee relieved the Vice President - Nuclear Production
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3-(VP-NP) of his duties at the Seabr:ok Station.
That individual subsequently-a resigned. (CAL 2.A-1)" To improve management control and' accountability,,the r
p VP-NP position _was replaced with the new position of. Executive Director -
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L Nuclear Procuction. A new positten, Senior Vice President and Chief Operating; Officer, was also added. (CAL 2.A-2) This restructuring placed more emphasis on pl, ant operations.
Functions not cirectly contr_ibuting to the support of l-plant operations were moved into etner areas of the company. With this change,
.NHY more clearly defined tne resD0nsibility and authority of key positions.
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The 0 RAT found the:above-mentiened -senior managers to be ' appropriately trained for their positions with res;e' t to formal education and experience.
c The team did note that the Executive Director - Nuclear Production was_a. Yankee i
. Atomic Electric Co. employee on lean to NHY, The licensee indicated that.this was a temocrary assignment.
The CUT noted no inadequacy-because of this tem-1 porary assignment.
Through in_terviews, the ORAT :: cluded that the NHY upper managerial team
- demonstrated a conservative.approa:n to ;.roblem resolution and an appropriate safety perspective. Management was informally tracking performance ano was adequately determining the status :f ;roblem areas.
The ORAT observed an absence of middle management oversight in the plant.
I No associated in plant activity inacecuacy was-noted.
Several licensee man-
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agers indicated that they recogni:ec this as a problem, and that actions would
'be taken to increase management's in-plant presence.
The ORAT concluded.that
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this issue _ represents a potential area _for performance improvement.
3
. Station Ocerations Review Committee (50RC)
The. inspectors evaluated the SCRC process:through document review and atteRdance' at 50RC meetings. 'SORC members were'found to be knowleogeable cf their1hresponsibilities and of the matters discussed.
n ORAT review found the licensee-lesson pl'an (TS1002C) and instructor guide.
i on 10.-CFR 50. 59 - safety evaluations to be accurate and thorough.
In-reviewing SORC member training, the inspector noted that the 50RC members last received formal 10 CFR 50.59 training in 1987.
The licensee had no plans to_ schedule periodic 50RC member refresher _ training on the-safetyf evaluation process.
1 In addition, the inspector noted that' the -licensee recently incorporated l
NSAC 125, " Guidelines for 10 CFR 50.59 Evaluations," developed by the Nuclear Safety Analysis Center for the-Electric Power Research Instituto-(EPRI), into
_its safety evaluation process and planned to. provide adcitional SORC member training.through the required reacing process.
The inspector questioned the adequacy of-such training in view of the complexity and importance of the pro-cess. The lack _of. formal 10 CFR 50.59 refresher training and of formal train--
'ing on significant' changes to the process were considered program weaknesses and were identified to the licensee for consideration, s
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" Refers to. licensee corrective action identification per CAL 89-11; see Paragraph 9.0 and Attachment 1.
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All 50RC meetings have a formal agenda that is prepared and distributed by the'SORC secretary well in advance of the meetings. All documents for SORC review, with the exception'of " walk-thrus," are distributed to SORC subcommit-tee memoers in advance of the meeting. The agendas include review items with a listing of their respective subcommittees.
50RC members not designated to-serve on a particular subcommittee can participate in the subcommittee review.
Subcommittee members provide written comments to.the person responsible for the item; trese comments normally are resolved prior to the SORC meeting.
If com-ments are not received or remain unresolved, the item is dropped from the agenda anc is rescheduled.
The inspector noted that the Seabrook Station Man-agement Manual (SSR'1) provides explicit review instructions to SORC subecmmit-J tee memoers.
Walk-thrus'were evaluated for adequacy of SORC review.
50RC members stated inat walk-thrus are rare.
SSMM 5.0 limits walk-thrus to those which the 50RC' Chairman considers impractical to conduct during a normally scheduled meeting cr.which require 'immediate attention during normally scheduled meet -
ings.
Faccedure changes are normally treatec as walk-thrus.
Procedure changes dif fer from procedure revisions, which are major upgrades and require full oro-cessing. Changes are lesser modifications which alter only a small part of a procedure. Some changes are nonetheless intent changes (i.e., the, alter pro-cedure method, scope or acceptance criteria).
Intent changes require 50RC re-view price to implementation.
The ORAT found that both the observed SORC re-
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- view of soecific changes and the change review practices were adequate.
How-ever,' inasmuch as some changes may neither require immediate attention nor ce impractical to conduct during regularly scheduled meetings, the licensee was
- encouraged to modify SSMM 5.0 to specifically authorize the existing practice or to mocify the existing practice to conform to the NHY policy on strict pro-cedure compliance.
Non-intent changes can be implemented prior to SORC review and receive the review and approval of the onsbif t Shif t-Superintendent (SS) or Unit Shif t Supervisor (USS) and a station staff. supervisor knowledgeable in the area af fectec ty the change.
Additionally, non-intent changes receive responsible department manager approval prior to 50RC review and approval, which is re-ouired within 14 days of implementation.
Intent changes cannot be implemented l
prior to 50RC review and approval; they also receive responsible department j
head review and approval prior to SORC review. -The SSMM requires that :0RC members evaluate all procedure changes for 10 CFR 50.59' considerations and the l
potential effect on their respective areas of responsibility. Through inter-i views, tne inspectors found individual SORC members to be aware of this re-sponsibility.
The inspectors concluded that procedure changes receive adequate l
review prior to their implementation.
There was increased management emphasis on strict procedure compliance
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aftar the June 22 event, and the licens3e noted a marked increase in the number of procecure changes initiated by plant personnel. ORAT inspectors noted that, for the SCRC meetings observed, procedure changes consumed almost half of the i
50RC meeting time.
In oiscussions with the SORC Vice Chairman (VC), the in-spectors learned that plant personnel find that what was previously acceptable i
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[E Lin: terms of procedure accuracy.-is no longer acceptable.. While the increased
- sensitivity to procedural compliance is aporopriate, the increase in procedure
, changes has= introduced an increased ~ SORC burden and reduced the time available to SORC members for their otheri responsibilities._ The 50RC VC stated that he ifelt the burcen would not continue at this level indefinitely as.the procedures J
'would eventually-become " fine-tuned." He was also' reluctant to decrease SORC--
- review efforts because he wanted _ the responsible managers to' thoroughly assess
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- thefpotential'effect of each change on their departments _and provide additional unreviewed -safety Question reviews. ORAT review found no safety inadequacies-k.~
fully address this issue ~to assure that both'SORC and departmental. functions in the'present approach, and noted that licensee management continues to care-are_ adequately implemented.-
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-The inspector reviewed the licensee's Independent. Review Team (IRT) assess-ment of the 50RC function and found it to be well. prepared and thorough.
Recom-t mendations, especially those related to the reduction of SORC burden on-SORC J
members, identified important considerations.- (CAL 3-3) 7 3.3 Conclusions Facility management, as structur d, is capaole of directing and supporting-safe power operation, Facility management staffing, qualifications, and per-formance were acceptable.
The reorganization strengtnened lines of responsi-
'bility,-authority, and.accountaDility.
By creating a Chief' Operating Officer, _
the ' licensee developed a single focal point.for control and operation of Sea'-
- brook.
The -ORAT concluded that key individuals exhibited the proper safety-p perspective and that-the necessary managerial attributes exist. ~
3 4.01 PLANT OPERATIONS
.4;1-Review ~Scoce
- Thel inspectors reviewed operations and operations support functions.to evaluate the licensee's capability to safely operate the facility.
The purpose
-of the. evaluation was to:
determine whether the 0;irations Department is sufficiently staffed withL
' capable operators and managers;
-- determine whether the licensee has provided the Operations Department with the necessary' procedures, equipment, administrative and technical support; and,-
assess the effectiveness of the interface between the operations ~and
. operations support departments.
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4.2 Findings
-4.2.1 Doerations Staff The inspectors found the Operations Department to be adequately-staffed with experienced and knowledgeable operators and managers.
It was noted, how-ever, that NHY has.22 operators with active licenses, and the six-shift rota-tion requires 24.
Active _ license holders staff the two open positions on an overtime basis.
The ins;ectors determined that this did not place an undue burcen on the operating shifts, mainly.because of the current plant outage con-dition. The inspectors also noted that 12 candidates sat for NRC license ex-aminations during the inspection (November 13,1939).
The two senior reactor operator (SRO) licensed positions required by Tech-nical Specifications are canned by the Shift Supervisor (55) and Unit Shift Supervisor (USS).
Currently, all but one of the Supervisory Control Reactor
' Operators (SCR0s), who are required to have only reactor operator (RO) licenses, hold SRO licenses.
The Ocerations Management Manual (OPMM) states that it is expected that all SCROs will obtain SRO licenses within a reasonable time.
This is more than is required by -Technical Specifications (TS).
The inspectors founc this to be a positive operations management decision to increase onshift qualifications.
in addition to the licensed operators, each nperating shift is staffed with a minimum of five Auxiliary Operators ( A0s) and two fire fighters.
Three A0s serve on the fire brigade to supplement the two fire fighters assigned to each shift, Both the A0s and the fire fighters report directly to the USS.
The: fire fighters perform routine inspections and surveillances in support of the fire protection and housekeeping programs as outlined in the Station Fire Protection-Manual (SSFP).
Currently, no A0s hold R0 licenses, and it is not required that they do.
NHY has established the Alternate Control Room Operator (ACRO) position, which is an R0-licensed position, in addition to those requirec by the regulations.
.The inspectors viewed this as a positive initiative, but noted that this posi-tion is not presently staffed due to unavailability of licensed operators.
The' inspectors found that NHY has a number of alternate position _s avail-able for licensed operator advancement.
In addition to the training depart-ment, licensed' operator promotions are available in the Independent Review Team (IRT), which is discussed below, and _in the planned Operations Support Group (OSG),
Such advancement opportunities provide an incentive for operators to obtain NRC licenses beyond those required and thereby improve overall station operating qualifications.
Currently, all designated SSs are qualified to serve as Shif t Technical Advisors (STAS).
Several USSs are also qualified as STAS, and-would serve in this position if the onshift SS was not qualified.
As specified in the OPMM, while the SS and the USS are allowed to assume the.TA position as a collateral duty, other NHY personnel qualified to serve as STAS (including SCR0s, CR0s and l
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g personnel outside of the Operations Department) are prohibited from assuming other duties while serving as an STA because of the potential for, interference r
with the STA function.
(CAL 2.B-2)
The onshift operations staff has experienced an approximate 10% annual
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.turno'ver rate.
The inspectors did not view this as excessive; 75% of the cur-rent onshif t operators have held licenses at Seabrook for over four years.
In addition, many have previous comnercial or naval nuclear power o;erating ex-
.perience.
The licensee stated that several of those leaving the enshif t opera-tions staf f had relocated te other positions within NHY and their operating experience was not lost to the organitation.
The inspectors noted that the licensee is planning to institute an Opera-tions Sucport Group (OSG) to alleviate the operations administrative workload and provice Operations with their own technical review group.
The OSG will report to the Operations Administrative Supervisor (OAS) and will consist of two subgroups: a tecnnical support group with a supervisor and three engineers, and a procedure group with a supervisor and two procedure writers / reviewers.
The inspectors concluced that the proposed OSG could reduce the acministrative loac on Operations and improve the consistency and quality of procecure pre-paration and review.
While the proposal for establishing an OSG is a positive
. initiative, it has no bearing on tne existing readiness to conduct power opera-
, tion.
Tne inspectors found the enshift operators to be capable and professional.
High operator morale was indicated by their positive attitudes and pride in tneir work.
Operators maintained a professional control room atmoschere.
The SS and USS asserted appropriate control and command.
Control room access and activities were appropriately controlled.
Potentially distracting activities were n:t observed.
Operator response to annunciators was found to te appro-priate and timely.
The ORAT observed several shift turnovers and found them to be thorough 4
and cceplete.
The formal shif t turnover checklist was ef fective in assuring comolete and consistent turnovers.
Onshif t operating logs (TS log, locked valve log, temporary modifications log, temporary setpoint change log) were detailed.. concise, and useful to the onshift crew.
The inspectors observed effective operator communications and cooperation with other departments. The interface between operations and the Quality Assurance group was particularly noteworthy.
In addition to their control room responsibilities, the OPMM rPquires that SSs make monthly tours with the A0s, such that each of the three major plant A0 assignments is covered during each quarter.
The SSs are directed to inspect plant areas for equipment material condition, housekeeping, safety, radiolo-gical' controls, and security.
The inspectors viewed this as a positive'licen-see initiative.
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4.2.2 Doerations Procedures The inspectors found the operations procedures to be suf ficiently detailed and accessible by control room personnel. Operators were observed to adhere to these procedures, including those for configuration control.
A w~eakness in document control was identified and corrected by the licen-see during the inspection: the licensee's initial practice.was to remove all controlled copies of procedures that had exceeded _their routi_ne review period.
When ' document control personnel attempted to remove an overdue abnormal pro-I cedure from the control room, the operators prohibited the removal.
Recurrence was prevented 'by revising procedures to omit this practice.
This was an in-
' stance of effective upgrading of facility practices.
The missed procedure review was initiated.
This was an isolated instance of f ailure to review-a procedure listed on the monthly listing of procedures due for review curing the next 12 months. The licensee is assessing whether additional controls' are needed to cssure reviews are timely.
The ORAT had no further questions.
c 4.2.3 Eculoment Conficuratien and Ocerabilitv Controls Operations establishes proper system configuration by using system lineup
~
sheets that are included as part of each. specific system operating procedure.
Once a system is lined up for the relevant plant mode, the lineup sheets are logged and maintained in the control rocm. 'Any variations to the required l.ineup are documented in lineup exception sheets which are also filed in the
^
control room for reference.
To control system lineups for a mode change, the Operations Department has developed mode change checklists-that operators use to ensure that systems are properly aligned for the-new mode. Operations sup-port departments are' alerted to the approaching mode change through mode change notices. These notices allow a controlled and integrated licensee effort to ensure compliance with Technical Specifications and other operating require-
-ments during mode changes.
Additional system configuration control is 'provided by the locked-compon-ent log, in which the operating crew tracks normally locked components which have been placed out of position.
For systems or components on which work is being performed, configuration is controlled with a tag-out log.
System tag-outs are prepared outside of the control room; this reduces control room dis-tractions. and the administrative burden on the onshif t operators.
Random ORAT comparisons of local component indications-and associated con-trol room documentation identified no discrepancies.
The system configuration control system was assessed as thorough and effective.
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'4.2.4
-Housekeeoing
,I The' plant.was 'in_an outage during the inspection, and the ORAT noted that-4
. housekeeping and material control improvements could be made.
This was par-3 k
ticularly true where work had been completed but the area not subsequently.
cleaned.. However, the ORAT identified no housekeeping issues that threatened equipment _ operability. Overall, housekeeping = was-assessed as adequate.
I c
h 4.2.5 Resoonse to Operational Events To assess-the NHY response to operational events, the ORAT' reviewed NHY.
~
programs for anc performance of event reporting, post-event review, and self-H assessment. The NHY Reporting Manual (NYRE) provides for-the timely' submittal
'of. periodic.anc special-reports to NHY management and regulatory agencies, j
n y-ENYRE Chapter <2, " Report and Commitment Identification," contains require-f-
~ ments!and procecures for the initiation and preparation of Station information C
E Reports (SIRS). An SIR-is used to report and evaluate operational, events which may require furtner invest gation or regulatory' agency notification. _ NYRE-i Chapter 2 lists-conditions and events which require initiation of an SIR. The procedure requires tnat the Shif t Superintendent be. info.med of any question-able conditions anc be provided a copy of the SIR in order to determine any..
-l
- immediate reporting requirements.
NYRE Chapter 3 " Regulatory Reports," con-
~-
e tainsi he directions for' reports required by the NRC and previoes instructions -
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for.how~and where to submit them.
p Subsequent to an event, to documentation in an SIR, and to. the submittal-of required immeciate NRC reports, NHY evaluation is provided for in Procecure 1
12830, " Event. Evaluation and Reduction Program." The program is-normally-used
~
1to evaluate reactor. trips and Engineered Safety Feature.actuationsL but may 'also
'beused.foriother events as-requested by NHY management, -Initial evaluation-13
'of SIRS and-Post-Trip Reviews (Station Operating Procedure 051000.08) is fol--
lowed:by ' review anc assignment of appropriate correctiv'e actions by the' Station.
~'
J0perations Review Committeef(50RC) with further review by a' standing-Nuclear.
Safety Audit and Review Committee (NSARC) subcommittee.
1 a
As_part_of the event evaluation process, a root cause evaluation is per-
-formed in accordance with NHY Procedure 12810. " Root Cause Analysis." Analysis; i
results are included in the SIR : package, which must be completec by' the Event c
Evaluation Team Leader within five business days of-the event.
SORC review must be_ accomplished'within ten days. The-final NSARC report, including any
- assigned action items -is required to be issued within 30 business days of the -
event.
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4.2.6 Self-Assessment procrams p
'In addition to the above event evaluation process, the licensee has
.,^'
several programs to provide self-assessment of NHY operations.
The NSARC,
- esides its NHY 12830 responsibilities, is committed through Technical e
s o
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Specifications to provide to the licensee President a means of independently ascertaining whether' activities related to nuclear safety are performed safely and in accordance with the policies of NHY and the requirements of the NRC.
Anot'her program committed-to in Technical Specifications is the Indepen-dent Safety Engineering Group (ISEG), which is responsible for maintaining sur-E veillance of-station activities to improve station safety.
The ISEG examines station operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other station design and operating experience information which may indicate areas for improving station safety.
NHY Procedure 12B20, " Human Performance Evaluation System (HPES)," out-lines an additional program to reduce human errors. The HPES provides a pro-cess-for reviewing and evaluating situations where human performance either did-cause, or could have caused, an inappropriate occurrence.
The licensee has also provided for a top level, incependent assessment group in' NHY Procedure 11260, " Independent Review Team (IRT)." The IRT per-forms independent reviews, evaluations and assessments and provides reports and recommendations as directec ey senior licensee management.
The IRT is pre-sently composed of an IRT Ma.'ager and a team of on-loan NHY personnel forming a
.Self-Assessment Team (SAT).
The current SAT was formed in October 1989 and is charged with assessing and evaluating the licensee full power and power ascen-
'sion program.
The previous SAT existed from August 1958 until September 1989 and evaluated the-low power testing program.
Since its inception in 1984, the IRT has performed over 250 evaluations for NHY management.
In addition to on-loan personnel, the licensee plans to permanently assign two individud s with operational backgrounds as core members of the IRT.
Through review of the NHY Manual, the NHY Reporting Manual', and the Sea-brook Station Unit 1 Technical Specifications, the ORAT concluded that NHY has established a well-defined program for event tracking and self-assessment..The above-mentioned procedures and programs were all cross-referenced, Land all re-quirements for further review of an event were noted to be clearly delineated intthe inspected documents.
To verify that the in place programs have been properly implemented, the inspectors. interviewed several licensed operators, memoers of the Operations
[.,
Department management staff, the IRT Manager (who is also a standing member of the NSARC) and the Directer of the Office of Quality Programs.
The operators interviewed.were Supervisory Control Room Operators, Unit Shif t Supervisors and Shift Superintendents.
All were aware of what types of events were reportable
_per 10 CFR 50.72 and what events required initiation of an SIR.
The inspector reviewed the lesson plan for operator training on event f
identification and reporting.
No discrepancies were noted. All interviewed members of NHY management were knowledgeable of their roles and responsibili-ties in the event evaluation and self-assessmant processes.
22-As a follow-up to the personnel interviews, the inspector audited the SIR-documentation for two of the more significant events which had recently occurred at'Seabrook: a f ailure-to manually -trip during the natural circulation test (SIR 89-039) and the loss of residual heat removal shutdown cooling cap-ability (SIR 89-066).
Both SIR packages contained-the required documentation, including the SIR initiation sheet,-NRC Event Notification Worksheet, Event Evaluation Team report, and root cause analysis worksheets.
In addition, SIR 89-039~ included the post-trip review documentation and an IRT analysis report.
Both SIRS were determined to be thorough and complete.
The inspectors noted that, subsequent to the natural circulation test reactor trip event, the licensee improved their event reporting and evaluation.
process.
For example, the Event Evaluation Report for that event was required to be completed before the reactor could be restarted.
This was accomplished just prior 'to the ORAT arriving on site. (CAL 2.A-3) Also, procedure 051000.08 was revised to require discussion of any reactor. trip with the NRC prior to reactor restart, and Revision 21 of the NHY Reporting Manual was implemented to require the SS and the USS to comolate an NRC Event Notification Worksheet prior to making a 10 CFR 50.72 report to tne NRC Operations Center. (CAL 2. A-4
&-CAL 2.A-5)_
Based'on the discussions with NHY personnel, the review of the in place orograms, and the inspection of completed SIR packages, the ORAT concluded that the NHY staf f is able to effectively assess and respond to operational events.
4.2.~7 Technical Ocerations succort Procrams The licensee has established two operating experience feedback programs.
One reviews plant events and the other reviews industry events. The ORAT found these programs to be acequately staffed with experienced engineers.
Licensee actions in' response to events are tracked to completion using the licensee's.
SIR process (for internal events) or the Integrated Commitment Tracking System
.(ICTS, for industry events.) The inspectors concluded that the feedback pro-grams are capable of performing their intended function.
In' addition to the operating experience feedback programs, the licensee's l
engineering group recently established a scram avoidance-program. _ Because a 4
large percentage of pressurized water reactor trips are caused by/feedwcter-j system problems, the group is currently focusing on the feedwater and feedwater 1
control systems. _ The group is working with a computer model for these systems and plans to incorporate their findings into the operator trairing program.
j Operations personnel are also involved with the scram avoidance, program through l
specialized training and evaluations.
The ORAT assessed this p'ogram as a j
positive. licensee initiative.
"j 4.3 Assessment
)
The Operations Department is adequately staffed with capable managers, l
licensed operators, and administrative personnel.
Operators are knowledgeable j
of their responsibilities and are provided with the necessary pr ocedures, 5
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-equipment, and administrative support to allow them to conduct safe operations.
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The ORAT observed that the operators interfaced effectively with 'each other and control room equipment.
Station, configuration control and self-assessment methods are rigorous.
~ Interfaces'between operations' and the operations support groups are acceptable.
4.4: Conclusions The Seabrook Operations Department is capable of conducting safe power operations.
5.0 MAINTENANCE 3
5.1 Review Scooe i-The' inspectors reviewed the New Hampshire Yankee maintenance program to ascertain wnether the program was implemented effectively and could supoort tha power ascension program and power operation.
The review included the mainten-ance organi:ation manuals, procedures, work control programs, and the planning 1
and tracking programs.
Interviews were conductec with management personnel,
.supervi sory: personnel,- and technicians.
Observations were made of the assign-ment and performance of work.
~
y 52 Findings b'
5.2.1 Management, Oraanization, and Staffino
.The Station Management Manual describes the organization of the mainten-ance function. -(See Figure 4.) The Maintenance Manager reports directly to a
the Station Manager;.three Department Supervisors report to the Maintenance 1
Manager. ;The Maintenance Department Supervisor is responsible for corrective.
O Tand preventive maintenance on mechanical and electrical equipment.
The Instru-i mentation and Cortrols (I&C) Department Supervisor is responsiole._for. maintain-ing.the on site station instrumentation'and control equipment and for 'coeration-ofithe calibration facility.
The Utilities Department. Supervisor.is respons-ible for operation of dryL radioactive waste packing equipment and performance of' maintenance on. fire doors and other general utility and upkeep work on Lbuildings.
. The Maintenance Department Su~pervisor is supported by 87 personnel includ-ing a Mechanical Supervisor, an Electrical Supervisor, a Training Coordinator, a Lead Planner, seven. working mechanical foremen, four~ working electrical fore-men and.four contractors.
The I&C Department Supervisor is supported by 64 personnel including' four I&C Supervisors, a Training ~ Coordinator, a Leac Plan-rer, nine ILC, working foremen, and three contractors.
The Utilities Department
- Jpervisor. is supported by 37 personnel including three supervisors, a planner and five working foremen.
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'Themanpober.resourcesmatchthestationallotmentsasindicatedon:the-
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organizational chart providedL in Figure 4.
However,' the techniciansxare work-gy ing a 60-hour work week.
This extensive overtime-useiwas assessed as warrant-
~
Ling' specific licensee management' attention.
- 5.2.2 Work Control
^
The ORAT. int'rviewed and oeserved.the working foremen and tecnnicians'in e
~
cthecconduct of their duties.
.4
~ The' Maintenance Manager meets with the-department supervisors'and:the
--mechanical and electrical supervisors eacn morning.to review major joos'sched-uleo for;thejday and to resolve potent.ial! conflicts. A plan of the day (POD).
s
-meeting is_' held at 1:30.p".m.; daily at the supervisor : working foreman, and g
planner level;to review planned maintenance -including proper documentation,
. plant conditions,: avail' ability of parts and support from other groups.
The: working foremen report to 5;;ervisors and are responsible-for main-
~
taining the eoui.pment in their assigned systems.
As a result, the same' system-engineers ano technicians routinely-work together.
The cepartment planners identify emerging work;1and -the~ working foremen a. e responsible for accompi.ish-n' 1
ing the. work.
A working foreman cirects the work of five lor six technicians
,.and coordinates; and interfaces witn Other. departments - to. resolve problems.
~
1
~The licensee uses a cumputert:ec system to track Work Requests, Oesign Coordination Repo~rts, Occument Revision Reports, Requests-for Engineering Ser-vices,?Nonconformance Reports, and Facility ~ Service Recuests.
The tracking system follows each-document through 21 stages from initiation to final do:u-jo
. ment' control center closeou~t. Over -ten dif ferent types.of reports can be pro-
~
duced. A report : listing. the outstancingJsork requests, by ' responsible working fo reman = i s-Li s sued. da i ly.
A weekly report on the ~ backlog 1of work requests receives wide distribution and;is, displayed throughout the station.
The licensee's. goal is.tc have less
~than 750 work requests outstanding, not coanting' work' requests held.for' plant 1
-conditions 1or paper work _close out.
The present back log is approximately 1200-work requests and has been decreasing since mid-October 1989. 'The following
-tablesLsummari:e licensee report information or naintenance work status.
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TABLE 5.2.a b
OVERALL MAINTENANCE BACKLOG OLDER THAN OLCER THAN*
TYPE-NUMBER 3' MONTHS 12 MONTHS L<
Emergency and Priority-1: Needed to 2
0 0
Restore System to Operaole Status-a gl,'
Priority:2: Could Lead to System
-83 13 0
Inoperaoility Priority 3: Can Ee Performed As 708 243*
60*-
Hanpower and Senecule Allow Priority 2: To Be Comoleted.As' 245 Fill-In Work, e
" Includes Ecth priority 3 and 4 Items.
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TABLE 5.2 b-
~
n MODE DEPENDENT MAINTENANCE BACXLOG j
TYPE.
NUMBER Needed to-Enter Mode 4 142 Jeeded to Enter Mode 3 12 j
'Needed.to Enter Mode 2 4
Needed to Enter Mode 1 13 ORAT review concluded that maintenance.wa.; being adequately tracked and j
prioriti:ed.
Review and observation of selected portions of the maintenance j
' activities and. procedures listed in Attachment 2 identified no deficiencies.
.The ORAT' concluded that the P00 meetings were effective in establishing i
ithe' status of work requests and establishing priorities for planning and pro-curement. Working foremen were effective in' implementing and supervising the-i in conduct.of the prioritized work.
The ORAT concluded that the open requests
~
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- were ef fectively tracked. that the status of each open work request was well 2 documented, and'that the open work requests were appropriately coordinated with
- operational. controls so that the trnpact on component operability was being pro--
perly addressed.
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5.2.3 Material Control and Procurement h
The ORAT reviewed the Procurement Manual, held discussions with the Mate-rial hecuirements Deoartment Supervisor,.the Acministrative Services Manager, and receipt inspectors, and coserved a portion of the receipt inspection of h.;
valves in the warehouse.
The licensee has ceveloped a computeri:ed program for common components
~
and is completing the data base.
This program assigns a tag number to every component in the plant.
The tag number identifies the technical attributes of p
the component, the parts needed to repair it, and the number of parts in inven-tory.
Since common components have the same tag. number, inventories for. common replacement parts are better managed by this system.
The licensee has undertaken a program for improving the dedication of com-mercial grade carts for use in safety systems. That program is described in Engineering Procecure 32510, " Engineering Review of Commercial Grade Oedica-tion," and provices for imolementation of EPRI NP-5552, " Guidelines for the Ut;1.i:ation of Commercial Grade Items in Nuclear Safety-Related Applications,"
1 which was conditionally accepted by the NRC in Generic Letter 89-02.
Procram devei;pment is beginning, and 15 contractors have oeen hired to' conduct the
- work, The ORAT. concluded that installed equipment and spares are presently accept,ble based upon construction, precoerational, and operational controls and tesis, and licensee reviews.
The irocurement Department identifies the receipt of all quality con-trolled ittms with a company identification number (CID)-which is entered in a computer tra: king program.
The ccmputer p.mgram tracks the detailed informa-tion on the component's shelf-life (if aoplicdle), the work order under wnien j
the component is. issued. and the location of the item in the warehouse.
Receipt inspections are conducted by the Procerement Depart,ent.
The ORAT reviewed the documentation for the receipt inspecti:n of Copes-Vulcan, Inc.
l
. valves and discussed the receipt and issuing trackiag system with licensee re-ceipt inspectors.
Receipt inspection included review of documentation of iden-l tification numbers, shipping list certification of conformance, physical dam-
- {
age, and special tests needed.
For the receipt inspections reviewed, over ten J
Purchase Information Requests had been issued requesting clarifications, autho-
~j ri:ation for acceptance, and identification of noted deficiencies.
The inspec-tor concluded that this limited sample of receipt inspection for the reworked valves showed extensive, detailed and well-documented receipt inspection.
The inspector concluded that the procurement and receipt programs are ade-quate to support power ascension and that program ennancements are ceing de-veloped.
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17 5.2.4
, Calibration and Test Ecuioment control
-The ORAT reviewed the Measuring and Test Equipment (M&TE) chapter of the Station Maintenance Manual, held discussions with the working foreman of the M&TE Laboratory and the Maintenance Supervisor, and toured the calibration lab.
The calibration lab maintains standards for electronic meters, accelero-meters and pressure, temoerature, time, leak rate, and radiation equipment.
Special test equipment is calibrated by vendors on an as-needed basis.
Equip-ment used in the-field is staged in one of four major tool cribs for sign-out by users.
Equipment calibration frequency is determined by date or frequency of use.
The calibration las provides a computer listing to each tool crib, indicating instruments whicn are due for calibration.
For equipment calibrated on a usage. basis, the tool crib supervisors maintain a sign-out list and re-turn instruments for calibration when the usage limit is met.
Equipment users are aware of the usage limits and notify the tool crib supervisor when equip-ment requires calibration. Wnen a user icentifies a problem with a piece of equipment, the equipment is taken out of service, tagged, and returned to the calibration lac.
If a piece of ecuipment is not used for six months, it is L
removed from the crib anc is storea by the calibration lab.
Five technicians work in the calibration lab and are assigned responsi-bility for icecific types cf measuring devices.
Experience for technicians at Ethe lab ranges from three months to six years.
The laboratory has operated for seven years and the calibration program has been changed to meet the needs of the station.
Next day calibration service is provided for urgent requests.
The backlog is presently 200 pieces of equipment and the technicians are work-ing an overtime senecule.
No associated work delays or inadequacies were iden-tified.
While calibration equioment is stored in the Radiological Controlled Area, the licensee has not established a hot (radioactively contaminated) calibration lab.
Plans have been discussed for a temporary hot calibration lab; a trailer and most-required calibration equipment are onsite.
The licensee estimates that a temporary facility could be placed in service within two months, but no definitive plans have been developed.
The absence of a hot calibration facil-ity was assessed as a potential problem with calibration efficiency.
- However, NRC requirements were found to be met.
The calibration program was well established.
It provides adequate track-ing and control of equipment requiring calibrations.
The technicians who use calibrated equipment are conscious of calibration requirements, A larger staff-could reduce backlog and overtime, but the present staff was assessed as ade-quate to maintain equipment in calibration.
[
The ORAT concluded that the present calibration facilities are adequate to support power ascension and that support of extended power operation would be enhanced by a facility for calibrating contaminated equipment.
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5.2.5?
. Person'nel Control The ORAT observed maintenance personnel'during assignment-of work and dur-b ing the performance of maintenance and calibration activities, held discussions with working supervisors,_ training coordinators, department supervisors, and t
the Maintenance Mar.ager, and reviewed selected training records and qualifica-tions of technicians.
Maintenance support is provided on shift,' requiring each technician to-N 0
, work on a rotating shif t for a six week period twice a year.
The maintenance'
> staff is working ten-hour days, six days a week to complete the required work curing tne current outage.
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~ '
Most' maintenance technicians, working foremen, and supervisors nave held their positions for. over four years and are qualified to the highest licensee
. level, : Specialty and refresner training is ongoing to maintain and increase technicians!-knowledge and proficiency. Working supervisors maintain a listing of the technicians who have completed specialty. training courses anc ensure l
tnat tecnnicians are _ assigned to jobs for which they are qualified, The main-9 tenance training programs are being prepared for-industry accreditation'in the summer of 1990.
Department. training coordinators and technicians are assigned
~
to assist in job task analyses and lesson plans preparation.
L' Leac technicians and supervisors are taught the responsibilities of the 3
level-of management by on-the-job training and through acting.for their
-next
-1emediate supervisor when the supervisor is-absent,
_. The ORAT concluded that the Maintenance Department is adequately staffed
- with motivated and technically competent personnel and that the maintenance
-ceoartments can support power ascension. Maintenance personnel ~ interface fef fectively within their assigned craf ts, with other craf ts, with engineers,.
-and with. operations personnel.
The-maintenance personnel observed displayed a.
professional' attitude toward'the completion of their assigned tasks,
?!
5.2.6 Manacement Succort and Assurance of'Ouality'
- The.ORAT discussed management support with managers and supervisors and lassessed the effectiveness of the quality assurance program by observing tech-nicians and supervisors in 'the field, UManagementprovidesdirectionandguidanceforcompletingthemaintenance c
program, Daily staff meetings and plan of the day meetings are used to track-anc plan-identified maintenance work, The work' request system provides direc-tion to working supervisors and the technicians for the completion of-identi-fied tasks.
s.
. 0 RAT observations found quality to be an integral part of the conduct of
' jobs,- The ORAT observed the following examples of technicians stopping work to veri fy that proper quality assurance was maintained.
An I&C technician-stooped work _on the diesel generator and requested engineering support to t
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evaluate the acceptability of-a split in the plastic covering on the cable of a temperature detector. -An electrician stopped work on an isolated residual-heat i t removal. cross-connect valve when he sensed flow and requested operations veri-fication of the isolation of the valve. A mechanic assisted an operator in determining the status of the diesel generator fuel racks.
An I&C technician L
stopped work on repair of an accumulator level meter to verify that the issued repair part was the proper replacement part.
Second person verifications, QA hold points, and working-foreman reviews
[
cre included in procedures and work requests. Working foremen were observed at most job sites, but supervisors and managers were not observed in the field.
['
The ORAT observed the pretest briefing prior to testing the diesel genera-tor.
The mechanical working forerran and centrol room personnel discussed the test, the sequencing of required actions, and the operating precautions.
Based on the inspectors' observations and the successfully conducted test, the ORAT concluced that the pre-test briefing was effective.
The ORAT concluded that management supoort and assurance of quality is adequate to support power ascension anc power operation.
5.3' Assessment Preventive and corrective. maintenance is being adequately. performed by a technically competent and highly motivated staff which exhibited high morale.
That staf f is routinely working significant overtime.
No associated inadequate-work was identified, but excessive overtime and a high work backlog are a potential detriment to ef fec_tive operations support.
The assignment, conduct, and do'cumentation of maintenance work ~is well defined and was implemented in accorcance with the licensee's program. Out-standing work requests and overdue preventive maintenance items are closely 1
tracked.
Material-procurement and control adequately supports maintenance.
Receipt inspections and the tracking of material is well established.
The procurement process, inclucing the qualification of commercial grade parts is evolving and
. improving.
The calibration lab is well established and.adeouately supports the main-tenance work. However, the lack of a hot calibration facility will complicate calibration of contaminated components.
The maintenance staff is experienced and well qualified.
Communications within the maintenance organization are good and effective interfaces are h;
established with other on-site organizations.
Management provides adequate direction and support.
Assurance of quality function is effective at the technician level, with appropriate independent evaluation and verification.
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t 5.4 Conclusions V
The maintenance-organization is adeauattly staffed and experienced.
Effec-tive work. control, material control, procurement, equipment calibration,'and management functions are in place.
The staff is working significant overtime and the backicg of work requests remain high.
Present staffing levels,3and.
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. calibration facilities may not be fully effective in supporting extended power operation.
-6.0 SURVEILLANCE l
i 6.1' Review S::ce The 0 RAT reviewed.the Technical Specification Surveillance Program and
~
1 implementing proteauros for readiness to assess the following.
Whether administrative procedures are available and adequate to control Technical Soecification' surveillance testing, b
Wnether station staffing is adeouate to administer and conduct the Tech-
.ical Specification Testing Program,
- Whether surveillance testing is being successfully executed and adequately'
~
p' controlled.
Whether the SOECAPPRAISAL computer data base assured that Technical Speci-fication.surveillances are properly modeled in the cata base.
6.2 Findines The Technical Specification (TS) Test Program is controlled by administra-tive procedure MT10.1,.Rev 2, " Technical Specification Survei11ance Scheduling.
and Performance." Surveillances are tracked:and scheduled using a computer-based system.
Routine surveillances which are performed more of ten then once every seven days are administratively controlled by department procedures and
.are not tracked on a computer-based system.
The Surveillance Test Program is controlled by the Technical Support De-partment.
The Lead Surveillance Engineer, who reports to the Program Support
-Department Manager, has two Engineering Analysts and an Engineering Aide work-
'ing for him.
Both Engineering Analysts are contract engineers; the licensee is pursuing filling these positions with NHY personnel.
The ORAT reviewed License Event Reports (LERs) for the past two years to-
. identify missed Technical: Specification (TS) Surveillances.
Two 1988 LERs (88-02 and 88-06) identified missed surveillances.
Both missed surveillances were attributed to not properly identifying equipment required to be tested.
.The ORAT concludeo that these missed TS surveillances (in two years) did not
+
indicate a generic program weakness.
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21' Station Information Reports (SIRS) were reviewed for the past two years by 8
the. licensee to identify surveillance deficiencies.
SIR 89-061 describes TS surveillance tests 4.3.3.9 and 4.3.3.10 for the liquid and gaseous effluent monitoring systems as being missed: monthly source checks of various effluent gas and-liquid monitors were not conducted per the surveillance procedure.- The licensee later. identified that the source checks had~been performed automatic-
-ally by the monitoring systems, therefore, the monitors were operable.
Because the-monitors were. operable, an LER was not required.
The root cause of the missed surveillance test was identified as inability of the SPECAPPRAISAL com-puter program to track and reschedule partially completed surveillances.
MT10.1 was changed so that partially completed surveillance tests can be input into the SPECApPRAISAL program, and equipment not tested is now maintained on
- the limiting concition for operation (LCO) action statement status log-sheets.
The ORAT independently verified the accuracy of the daily TS surveillance i
4.1.1.2 for shutdown margin.
The shutdown margin was recorded as item 31 on tne TS Mode 5 log sheet.
i The ORAT ooserved selected portions of surveillance procedures OX1413.01, Rev. 5, "RHR Ouarterly Flow and valve Stroke Test and 18 Month Valve Stroke Cbservation," and OX1426.05, Rev. 3, "D/G IB Monthly Operability Surveillance."
During performance of section 8.2 of procecure OX1413.01, the licensee identi-fied that the discharge pressure gage was not adequate for the Inservice Test-
'ing (IST) surveillance of the RHR pump.
The gage was temocrarily replaced by i
oressure gage of acceptable accuracy.
The licensee stated that the test pro-cedure would be changed to specify installation of a more accurate pressure gage.
1 During performance of procedure OX1426.05 the inspector observed strong Ovality Control involvement.
Also, Maintenance provided assistance in test-performance.
In addition, Operations used the assistance of the system eng6-neer and system I&C foreman to resolve the-discharge pressure gage issue de g scribed above.
-6.3 Assessment Administrative procedures were available and adequate to successfully exe-i cute the Technical Specification Surveillance Program.
Staffing to schedule i
and track surveillances was adecuate; all positions were filled. Test proce-dures reviewed were detailed and technically sound.
The professionalism and i
knowledge of personnel conducting TS surveillances was evaluated as. strong, 6.4 Conclusions The Technical Specification Surveillance Program has successfully been implemented for Mode 5 operations at Seabrook. Staffing levels and procedures are in place to support power operation surveillances.
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-7.0 RADIATION PROTECTION
~7.1 Review Scoce The readiness and capability of the licensee's radiological controls pro-gram to support power ascension and full power operations was reviewed by the ORAT.. Readiness and capability were evaluated against ' criteria in applicable regulatory requirements, Final Safety Analysis Report Commitments, and Tech-nical: Specification requirements.
The ORAT evaluated the licensee's perform-ance in this area by independent observations during plant tours, discussions with personnel, reviews of documentation, and independent walkdown of systems.
l 7.2 Findinos 7.2.1 Orcanization and Staffing
.The licensee has a well defined radiological controls organization (see Figure.5).
The current, approved organization is fully staffed. ORAT review noted that.the. licensee hired 12 contractors to augment the organization and.
tnat there may be'a need to provice additional' permanent personnel (e.g. in dosimetry records) if the contractor support is terminated.
This was based on inspector observation of work cctivities.
The licensee's radiological controls representatives indicated that additional permanent personnel have been re-quested and that the qualified contractor personnel would be retained if needed.
The ORAT found the organization and staffing of the radiation protection portion'of the radiological controls organization, with its contractor support, to-be fully capable of supporting power operation.
The'ORAT noted, during discussions with the licensee's radiological con-trols representatives, that the radwaste management and radwaste transportation organizational responsibilitses were being changed.
Those changes were not evaluated during this ORAT' inspection.
(This aspect will be reviewed-from January 8-12, 1990 and documented in Report 90-03).
7.2.2 Qualification and Training The ORAT reviewed the qualifications, training and continuing training for radiation protection personnel in the radiological controls: organization.
The t
review included technicians, supervisors, and managers.
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The ORAT considered the personne.1 to be highly qualified and trained.
l Continuing training was being provioed to permanent personnel as appropriate.
l Both permanent and contractor personnel were provided with timely training in new.or revised procedures and industry events.
The' ORAT noted that the contactor radiological controls technicians, hired to augment the staff during initial plant startup, have not been included in the formal continuing training program.
Those contactors were provided initial i
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The licensee indicated'that the-continuing training of contractors would be reviewed.
Licensee attention is warranted to assure that this lack of continuing training does not develop into a ' qualification inadequacy.
Qualifications and training of radiation workers were reviewed during the May-June 1989 readiness inspection and were found acceptable.
Current training was found by the 09AT to be acequate to support full power operation.
The ORAT noted that there was no specific training for radiological con-trols or operations personnel on the expected radiological conditions asso:1-ated with plant systems which will present raciological hazards during power operation (e.g., expected areas of continuing and transient high radiation dose-
- rates).
These personnel may access such areas during startup and operation.
Such training is especially appropriate for operations personnel since they are permittec to monitor their own entries into high radiation areas.
The licensee initiatec a review of this matter, which the ORAT considers a potential prcgram-improvement.
7.2.3 Communications, Morale and Attitude The CRAT evaluated radiological. controls, communications, morale and atti-tude.
A cositive attitude was evident during ORAT discussions with personnel.
' Radiological controls personnel communications with operations department per-j sonnel was. acceptable.
Generally, communications were good and were enhanced 1
- by attencance at frequent meetings with all levels of the organizatinn.
The ORAT'noted that the licensee had identified two instances where radio-logical controls personnel had not performed assigned tasks as expected.
The-
- licensee nad thoroughly evaluated these instances and concluded-that the indi-viduals displayed poor attitudes and an apparent lack ef professionalism ano pride in-'tneir work. 'The ORAT noted that the licensee'g management was noti-
. fied of the-apparent problem by the workers' peers.
The ORAT found that the licensee Pad performed a thorough review of the issue and instituted measures to more-closely monitor worker performance.
These instances were considered to j
be isolated and not indicative of a pervasive problem.
The ORAT considerec overall attitude and morale to be very good.
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7.2.4 Facilities and Equioment The ORAT reviewed the radiological controls facilities and equipment and i
noted that there were ample supplies (both consumable and nonconsumable) to
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support the radiological controls program, including the external, internal and respiratory protection programs.
The inventory of consummables (e.g. protec-tive clothing) was computer tracked.
Supplies were reordered when needed.
A state-of-the-art instrument calibration facility, which provides for i
calibration of monitoring instruments directly traceable to the National In-stitute of Standards Technology, was operational.
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'7.2.5 External Exoosure Controls' a,
The ORAT reviewed the following elements of the external exposure c'ontrol i
program.
[y Procedures.
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Dosimetry devices.
Radiation work permits.
Records and reports.
p" Number:and types-of survey meters, i
High~ radiation area access controls.
Post ng-and' barricading 'of radiological areas.
i Calibration' f acilities and ' radiation' sources-used,:
~ Area radiation monitors and calibrations.
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Control and leak checking of radioactive sources.
The ORAT found that the'overall external exposure controls-program-was-well defined and capable.of-suoporting power ascension and full power opera-
-tion. : Procedures were of.goodicuality.
Tours by ORAT members found radio-1 logical controlled areas'to'be properly posted.
s The-licensee has assigned a radiological controls in'dividual to-the plan-
. ning and' scheduling department,. That. individual reviews work = requests and acts
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as an_. intermediary between the radiation protection < group and work groups, This coordination:was assessea as a benefit to raciological controls work re--
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- view and planning.
The. inspector identified the following weaknessesLfor which the licensee' implemented prompt and acceptable corrective ' actions.
- r',' ~~- - ' Procedure guidanc'e explaining the methods of continuous coverage: of-p
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sonnel working in-high radiation areas were subjective and open to inter '
1 pretation.
Procedures did not provide good controls for.' tracking of extremity expo-sures'during= work.
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Procedures did' not provide a clear indication of the minimum radiological surveys.needed to support radiation-work permit work,
-7.2.6
' Internal-Exoosure Controls f Tne ORAT reviewed the following elements of the interaal exposure control
. p ro g. ram.
Frocsdures.
Bioassay methods and equipment.
Records and reports.
Ky Respiratory protection equipment.
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_ Engineering contrels.
- Posting, k
The ORAT concluded that the overall internal exposure control program was generally well defined and capable of supporting power ascension and full power
- operation. Ample supplies of respiratory protection and airborne radioactivity sampling eouipment'were available.
The internal dos! metry program was fully implemented.
Bi:, assay metnocs were established and implemented.
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The ORAT observed candy wrappers.in the radiological controlled area
_(RCA).
Ingestion of food is prohibited in the RCA.
The licensee initiated acceptable action to reinform personnel of the prohibition.
b 7.2.7 Safetv-Related Ventilation System s The ORAT reviewed the surveillance testing of the control room emergency ventilation system ano tne containment enclosure ventilation system.
These systems were visually ins:ected by the CRAI to determine their condition and to comoare them to approvec crawings.
The two systems were ceing retested to determine their operability as de-fined-in the Technical Specifications (TSs).
The retesting was consistent witF-
,TS requirements, with'the following being noted.
A' test to determine if the control room emergency ventilation system appropriately realigns and goes into the filter recirculation mode when p
ordered has not yet been done.
That test is to be completed prior to going into Mode 4 af ter completion of the control room emergency ventila-tion system design cnange.
Licensee controls to assure conduct and ade-quacy.of this testing were agsessed as acceptable.
The wattage test results for ?he installed heaters for the control room emergency ventilation system exceeded the TS specified wattage.
No-in-
- ,;ility to meet operational requiremer.ts was involved, fhe licensee had. completed a-technical clarification specifying-that the.
heater wattage was acceptable and no change in Technical Specification was re-
- quired, The inspector informed the licensee that the TSs should be changed to reflect the higher wattage._ The licensee indicated tnat this and other tech-nical' clarifications were under review to evaluate the need to change the.TSs.
This unresolved item is considered part of an overall issue of whether any TS or FSAR provision has been altered by the licensee's interpretations and clari-fications-(443/89-83-01).
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7.2.8 ALARA Procram The licensee has established a orocedurally described program to control personnel ALARA (as low as reasonably achievable) exposures to ractation and radioactive material.
That program places the ALARA review responsibility on joo supervisors.
The ORAT noted that job supervisors have received limited ALARA training.
The ALARA program also allows radiological controls technicians to issue raciation work permits for work involving accumulated personnel radiation expo -
sure of less than two person-rem.
These individuals have also received limited t
ALARA training.
In addition, the inspector noted that no formal program for establishing -
challenging ALARA goals was in place.
The ORAT concluced that a basic ALARA program was in place, with room for improvements in the assurance of ALARA proficiency of job supervisors and 1
raciological controls tecnnicians, and in establishing-challenging and specific -
ALARA goals.
7.2.9 Industrial Safety and Housekeeping The ORAT reviewed incustrial safety and housekeeping during. clant tours.
NHY has establishec procedures for industrial safety and housekeeping.
Tours of the station by ORAT members noted some examples of f ailure of-workers to use the safety eauipment supplied by the licensee.
For example, I
personnel were not using safety glasses or-safety belts when working in the Refuel.ing Cavity.
The licensee immediately initiated review and acceptable corrective action.
During tours, questionable safety and fire protection practices were-ob-served. Painters were noted to be cleaning brushes in an enclosed, non-ventilated' room, and the paint fume smell.was strong.
Safety personnel had not been notified of this concern by the work supervisor, and no airborne sampling of atmospheric contaminates was done.
The painters did not wear respirators, and lef t flammable, thinner-soaked rags in plastic bags.
The conditions noted above were assessed as poor practices which, though uncharacteristic, merit licensee attention.
(Subsequent inspection confirmed correction of.the specific items noted.) Continued adequacy of industrial safety and housekeeping will be regularly evaluated during routine NRC inspec-
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4 7.2.10 Process and Area Radiation Monitors The ORAT. reviewed the calibration and surveillance of process and area radiation monitcrs described in the TSs.
Instruments reviewed included control s
room-isolation instrumentation, main steam line radiation monitors, and reactor coolant leakage detection instrumentation.
The ORAT also reviewed the calibra-tion of general area radiation monitors.
The ORAT found that the licensee established well defined procedures for p
survelliance testing and calibrating the instruments. All instruments were-tested in accorcance with TS requirements, and alarms were properly set.
The ORAT observed that the individuals performing calibration and testing.
had a high degree of system and procedure knowledge. Also, the ORAT noted that-procedures required a second individual to verify that instrumentation was pro-perly returned to service.
7.2.11
- Radioactive Material and Contamination Control The ORAT reviewed radioactive material and contamination control, includ-ing personnel contamination and thc surveys and equipment used to check mate-rial being released from radiologically controlled areas (RCAs).
The ORAT found-that the licensee had established well-defined procedures for posting and labeling of radioactive and contaminated material, for provid-1 ing guidance for surveying material removed from RCAs, and for use of protec-tive clothing. Material removed from the RCAs was surveyed by radiological controls personnel.
There was limited radioactive material stored at the station.
The radio-t i
.act ve mates ai l present was primarily residue from calibration of equipment.
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. No contaminagpd areas were identified. A routine survey program to' check for station contamination has been established. Although no significant contami-nationicurrently exists, equipment and materials were thoroughly checked prior.
i to being removed from the RCAs.
Properly calibrated state-of-the-art personnel l
contamination monitors were being used by personnel exiting RCAs.
The ORAT noted no formal. identification of all areas in.the station where radioactive material was authorized to be stored.
Identification of such areas i
as authori:ed for storage is a good practice. This was. identified to the lic-ensee for consideration.
I The ORAT concluded that the radioactive material and contamination control f
program is capable of supporting power ascension and full power operation.
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L 28 7.3' Conclusiens The licensee has established and implemented a generally well-defined radiological controls program capable of supporting power ascension and full power operation. NHY initiated immediate corrective actions on the concerns
-identified.
8.0 ENGINEERING AND TECHNICAL SUPPORT 8.1 Review Scoce
~1 The ORAT evaluated operational readiness of the engineering and technical V
support organi:ations through review of organization and staffing, modification and configuration controls, and interdepartmental interfaces.
Some ongoing and recently completed modifications were reviewed for the quality of design plan-ning, independent verification, installation, and testing.
Also, the inspec-tors reviewed the licensee's precess for determining whether a modification required completion prior to power operation.
Planning for accomplishment of outstanding modifications was reviewed as well.
Engineering sta'fing levels and qualif.ications were evaluated for acequacy of engineering _ support to the operating staff.
During interviews with engintars and engineering supervisors, staf f cttitude anc morale were assessed.
Working relationships between the organi:ational elements involved in I
engineering support activities were evaluated through interviews and by observa-I tions-during licensee meetings.
In addition, the ORAT reviewed the licensee's recent self-assessment and QA audits and actions on the findings to assess the effectiveness'of the licensee's management oversight and commitment to program improvements.
8.2 Findinos 8.2.1 Enoineerino and 7-chnical Supoort Staffing a
The on-site Seabrook Station engineering structure consists of the Plant i
Technical Support Department and the New Hampshire Yankee (NHY) Engineering Group.
(See Figures 3A and 38.) These staffs are supplemented by engineers from the Yankee Atomic Electric Company (YAEC) headquarters office.
The Engi-neering and Technical Support staffing _ was assessed as adequate and had a very low turnover rate. The inspectors.noted good working conditions, including.
]D sufficient facilities and equipment.
Persons contacted in the Engineering, Technical Support, and Quality.
Assurance (QA) areas were enthusiastic about their work'and participation in preparation for plant operation.
The overall favorable staff attitude and 1
morale.was further evidenced by the low turnover.
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8.2.2 Station Modifications The Technical Support Department evaluates reovests for engineering ser-
< ices (RESs) that have been initiated by plant departments including Operations and Maintenance.
RESs requiring plant changes are converted to Design Coordi-nation Reports (DCRs) or minor moaifications (M-Mods) by NWY Ergineering through evaluation, review and approval prior to Work Recuest (WR) preparation.
Technical Support implemento Station Operation Review Committee (50RC) approved DCRs and M-Mod packages. This is accomplished by preparation of a WR that defines the work to be acecaplished and provides the acplicable crawings, _
procedures, instructions and cocumentation requirements.
Technical support to' accomplish a DCR or M-Mod work is performed by systems engineers from the Tech-nical Support staff.
The ORAT reviewed the RES. DCR, and M-Mod processes and sampled DCRs and M-Mods to establish their tecnnical quality. Associated WRs and the field con-dition of affected comoonents were examined.
The inspectors found that the Engineering Group and Technical Support Department were effectively controlling plant modifications to ensure that plant system and components were in the con-dition required by plant cesign and regulatory requirements. Where work was not completed, review of scheduling anc tracking of work progress, including operational hold points, showed that the licensee's program was effective in
- preventing component or system startup until work was completed.
Proper equip-ment and system operability are confirmed by post-installation and startup testing.
The NHY Engineering Group staff's time is divided among DCR development, processing operational experience concerns, commitments and regulatory require-ments, and conducting engineering reviews and developing improvements.
O 8,2,3 PjantSafetyandReliability Tb3 ORAT found that both Engineering and Technical suoport personnel were involved in. tasks related to optimizing plant safety and reliability.
These tasks include items such as emergency diesel generator (EDG) failure modes and ef fects analyses, non-nuclear balance of plant (BOP) systems review, and de-veiopment of a motor-operated valve operational test method using valve stem strain gage measurements to quantify valve loading.
The control room and local annunciator response procedures (ARPs) for the emergency diesel generators (EDGs) were sampled by the ORAT inspectors.
Opera-i tions had precared these procedures and they had !een reviewed by SORC.
Other than through the SORC process, Engineering and 1 cnnical Support were not in-
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volved with the review and evaluation of the ARPs to establish that the defined t
operator actions are optimum.
Such review and evaluatian was assessed as a potential performance improvement item.
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-The ORAT evaluated the availability and. useability of the EDG ARPs and
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noted the following.
The reviewed EDG ARPs were adecutte in that they defined a suitable set of operator actions for each annunciator.
I l-EDG. local panel ARPs were not available for operator use in either of the l
two EDG buildings.
'The index or identification of the ARPs was not consistent with the panel annunciator identifications; that is, the procedures used an alpha-numeric identification while the panel annunciators were identified by numoers only.
This could delay operator response while the appropriate procedure was located.
1 The above problems were acknowledged by the licensee and corrected prior to the-close of this inspection.
Further, the licensee committed to review the availability of all safety-related A;Ps for operator use at the local panels and conf rm procedure useability, including verification that a cirect corte -
lation between the panel designator and the procedure designator existed.
This l
was-identified as an unresolved item (4a3/89-83-02) ano is scheduled for resolu-'
i tion prior to plant restart.
1 In summary, the ORAT found that Engineering and Technical Support had i
generally provided the input necessary to assure that plant systems are in the as-designed cond~ tion and will function as intended.
8.2.4 Integrated Readiress Docenent (IRD)
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The ORAT reviewed the licensee's Integrated Readiness Document (IRD) pro-gram with the Licensing Manager, who is responsible for the IRD. The objec-tives of the IRD are: (1) to track all activities required to be completed be-
' fore issuance of the full power _ operating license (FPOL); and (2) to track ac-tivities-for which the NRC has requested status at the time of licensing.
The
-IRD consisted of 120 items and was being updated weekly.
It included data on i
NRL Bulletins, Safety Evaluation Reports (SERs) Confirmatory Action Letter (CAL) 89-11 actions, Generic Letters, Inspection Reports, 10 CFR 21, NUREG-0737, Emergency Preparedness issues, Licensee Event Reports, and Self-Assessments.
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The inspectors selected regulatory-driven Design Coordination Reports
~(DCRs)87-311, 89-045, and 89-055.
These DCRs were found in the IRD and their status was current and complete.
1 8,2.5 OA/QC Interf ace in Engineering Modifications Design Coordination Reports (DCRs) for engineering modifications are re-viewed'and approved by Nuclear Quality Assurance (NQA) in accordance with Sec-s tion 6 of the NHY QA Management Manual and Engineering Procedure 31312. The QA i
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engineer's scope of review includes the 10 CFR $0.59 safety evaluation, the L
analyses and calculations, the FSAR changes, procurement QA, and procecural and document changes, i
When a DCR is SORC approved, the Technical Support Implementing Engineer develops the associated Work Request (WR) package.
QA and Quality control (QC) review the WR package, establish OC hold points,_ determine OA surveillances to be conducted during the implementation phases (e.g., walkdowns, testing, and turnover to Operat;ons).
0A engineers also support OC by participation in hold-I.
points. The OA engineers interface with the Technical Support Engineers in defining the OA recuirement in areas such as nondestructive evaluation, weld-ing, test procecures, corrective and preventive action.
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The ORAT reviewed CA/0C involvement during the walkdown of DCRs87-311, L
87-4.I, and discussions regarding DCRs88-182, 89-055, and 86-709.
The first four DCRs cealt mainly with valve workt DCR 86-709 dealt with the control Room i
Habitability System, It as concluded that these engineering modifications were reviewed by an adeouately staf fed and trained NQA Engineering Group.
The CRAT reviewed Safety Audit and Review Committee Meeting 89-06 minutes of Octocer 25, 1989.
Those minutes included trending and analyses of Manage-ent Action Requests (MARS) and QA reports of Inspection, Surveillance, Audit.
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'and Corrective Action. ~The ORAT also reviewed 15 Quality Assurance Surveil-
' lance Reports (OASRs), four 0A Audit Reports (QAARs), one MAR, and Indecencent l
Review Team (IRT) CA Review Update Report No. 4 That update report monitors
.the IRT recommendations based on SALP Report 50-443/87-99.
The ORAT found that r
NOA was keeping management apprised of the quality of work at the Seabrook Station.
' To meet their Operational QA Program responsibilities, NQA identified plans to acd selected tecnnical expertise on the QA_ Audit Teams, use a more selective, in-depth technical and integrated approach to DCR review, increase OA Engineering involvement in DCR implementation, complete Level II (plant specifics; e.g., component design) and Level !!I (system) training for NQA per-sonnel, are add permanent personnel with licensed operator experience on their
- taff, (NOA currently has two contractors with SRO experience.) ORAT review concluded that these are positive initiatives but do not affect present readi-ness for. power operation,
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8,2.6 Confirmatory Action letter 89-1) Items
- With respect to Confirmatory Ac*. ion Letter 89-11. Engineering actions were noted to be comolete or in progress.
(Attachment I to this report contains CAL item status.)-
f Ou' ring the inspection of the Engineering and Technical Support area and the review of related Quality Assurance activities, certain DCRs, M-Mods, LERS, and Maintenance and Operations Manual procedural changes were examined to con-firm timely completion of CAL items.
The team verified that significant t
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I engineering involvement and effort had contributed to the corrective action imple-mentation of the IB CAL area.
As a result of this inspection, CAL Items 1.B-1 through 1.B-8 were found to have been adecuately addressed by licensee correc-l tive measures and NHY management attention to their completion.'
8.3 Conclusions j
The ORAT concluded that Engineering and Technical Support have appropriate programs in place and have provided the engineering input to assure that plant sys-tems and components are in the as-designed condition and will function as de-signed.
'lt The integrated Readiness Document (IRD) adeouately tracks items required
.fcr completion.. Engineering and Technical Support activities have been audited and are ender periodic surveillance by Nuclear Quality Assurance (NOA).
Overall; the ORAT concluded that Engineering and Technical Support is ready for power operation.
9.0 CONFIRMATORY ACTION LETTER CAL 29-11 CORRECTIVE ACTION PLAN (CAP) 9.1 Backcround Based upon the licensee's failure to manually trip the reactor as required during the natural circulation test on June 22, 1989 and the failure to imple-ment a comprehensive post-event-analysis, CAL 59-11 was issued by NRC Region I on June 23, 1989.
That CAL documents the licensee's agreement to review cor-rective actions and post-trip review results with the NRC.
The licensee sub-mitted.: as an enclosure to its response (NYN-89086) to the CAL, a Corrective Action Plan which detailed specific areas for evaluation and action.
On i
October 23, 1989, the licensee provided an updated submittal (NYN-89128) of its Corrective Action Plan.
This' document included a total of 55 corrective action items divided into seven general areas as follows:
1A - Procedural Compliance I
IB - Ecuipment Readiness t
'IC - Pretest Preparation 10 - Power Ascension Test Progrt ;
2A - Post Event Management 28 - Operations. Management
- 3. - Management Oversight
.j The ORAT reviewed several of these corrective actions (discussed in this i
report as CAL items 1A-1 thru 3-8).
Attachment I to this. report documents the ORAT review status for CAL items and references the ORAT report section where j
the CAL item is discussed.
All CAL items reviewed were found acceptable.
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r 9.2: Management Oversi;ht
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The ORAT examined licensee management attention to, involvement in, and oversight of CAL 89-11 for CAL items 3-1 through 3-S.
Documented evidence of the progress, tracking and review of specific corrective actions to completion was examined.
Also, the ORAT reviewed the New Hampshire Yankee Core Values and Vork Ethic Policy and the associated development of a " Values for Excellence" culture.
NHY has conducted incerendent assessments of the effectiveness of the CAL corrective measures.
The results of several evaluations of the overall content and direction of tne Corrective Action Plan have been providec to NHY executive management. - The ORAT interviewed several onsite managers and discussed the impact of the newly imoletented policies and program revisions on employee morale, uncerstanding, conouct of work, and organizational goals, h"
The NRC had previously aitnessed formal 11:ensee training on the NHY pro-cedural adherence and core values policies.
In succeeding weeks, there were examples of management's cissemination of policy.information in weekly news flyers, in the " Week in Review." anc in the " Station Manager's Messenger."
l-These contained articles on values for excellence, work cerformance, station goals and problem areas, anc ciscussed both NHY policy and examples of.where the work ethic can be approcriately applied.
Random interviews with plant per-
'sonnel by the ORAT confirme: that station personnel were receiving and acknowl-edging tne intent of managerent's messages. One indicator was the increase in t
procedure changes initiate: ty employees, as discussed earlier in this report.
The ORAT also reviewec a Nuclear Quality Group review of the effectiveness of the NHY procedure compliance policy upgrade, a June 22 event case study which has been or is to be presented to personnel involved wi;h the power -
I ascension test program, and plans for the review of cperating experience gained-from startup test problems icentified at other plants. Additionally, in assessing the effectiveness of the Station Operation Review Committee (50RC),
the ORAT reviewed a 50RC Effectiveness Evaluation conducted by an independent team of experienced nuclear personnel 'under the auspices of the NHY Independent p
Review Team.
Management oversight of the licensee's overall program of corrective meas-ure implementation of CAL 89-11 was discussed with the NHY Senior Vice Presi-dent and Chief Operating.0fficer (C00).
He was thoroughly cognizant of both y
the status of corrective and ongoing review efforts and the need to assess the
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implementation of adoitional recommendations resulting from internal reviews.
The' Senior VP and CCO was asked to -provide the NRC with a letter discussing the NHY upper management perspective on the effectiveness of the corrective action program and_upon the. insights gained from the several independent reviews that have been conducted. -The Senior VP and C00 agreed to provide such an as>ess-ment as part of any further request to the NRC to lift the CAL constraints from Seabrook operation, af ter ccmpletion of the NHY Corrective Action Plan program implementation.
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9.3 Procedure Compliance Items 1.A-1 through 1.A-11 of the licensee's Corrective Action Plan con-stitute the licensee's response to improving operator understancing of the'NHY Procedural Compliance Policy.
This response consisted largely of developing, issuing, and conducting training on an improved policy on Procedural Compli-ance. The response also contained an instruction for the establishment of a Human Performance Evaluation System (HPES) and a revision of the Natural Cir-culation Test Procedure, f
ORAT inscection consisted of a review of the licensee's proposed correc-tive action for each issue, and a comparison of the completed corrective action to=the intent of the proposed corrective action.
In addition, the ORAT re-
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viewed training and Quality Assurance programs as they related to procedural l
compliance.
To address procedure compliance, the licensee took three basic steos.
First, the. policy on precedural compliance was clarified to more accurately reflect management's intent that all procedures are to be followed unless an overriding safety concern prohibits such action.
The second step was to issue the revised policy statement once it was approved.
The third step was to en-sure that all site workers were aware of and understood the Procedure Compli-ance Policy.
To meet this' goal, a program designed to ensure that all workers
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t receive training on the policy was established.
Station Procedure 10000. discusses the NHY policy on procedural compliance-and states in part-that. " procedure compliance is the foundation for the con-i duct of business..."
It goes on to state that noncompliance with precedural requirements is only permissible when there are immediate overriding safety cencerns involving:
I protection of the health or safety of the public, prevention of injury or life threatening situation, or
[-
prevention of damage to major plant eouipment.
f The policy also provides guidance on what to do if an approved procedure is found to be unclear or in error.
The Procedure Compliance Policy, as stated in Station Procedure 10000, is quoted in the Seabrook Station Management Manual-($$MM), in the Production Management Manual (NPMM), and in the Operations Man-agement Manual (OPMM).
As an additional indication of the emphasis management
[
places on procedural compliance, NHY meetings were held with all shifts to i
discuss the issue-.
Ensuring that all workers are aware and have a proper understanding of.
L procedural compliance was addressed in items 1.A-9 and 1.A-11 of the Corrective T
P Action Plan.
Item 1.A-9 specifically deals with the. problem of ensuring that all site workers receive training on the basic Procedural Compliance Policy.
In resolving this item, a training lesson on procedural compliance was prepared for approval by the Training Group Marager.
In addition, a memorancum from the Executive Director-Nuclear Production was distributed to managers, department
35
[
supervisors, and training liaison personnel. That memorandum emphasized the importance of ensuring that al'l people for wnom the individual manager was re-
,sponsible received training. A memorandum from the Training Group Manager to the Exeevthe Director-Nuclear Procuction accressed the actions being taken to resolve the problems encountered in achieving 100% compliance.
I In a memorandum dated Octcber 12, 1989, the Training Group Manager stated that current simulator training scenarins satisfactorily challenge operator judgement on procedural compliance.
' s memorandum dated November 10, 1989, the Training. Group Manager went on tt,; ate that Procedural Compliance Policy F
training for all operators and instructors is complete, that extensive E0P training on procedural compliance was conducted and witnessed by QA personnel, i
L and that further intensive training for operating crews is scheduled.
Some items did not specifically deal with procedural compliance, yet were designeri to improve procedures, their develcoment and revision and overall con-
' tents (1 A-7, 1.A-8 and 1.A-10).
Item 1.A-B dealt with the reorganization of the Operations Department to provide people to perform the required development and review of Operations procecures.
The resolution of this issue involved
-increasing Operations Department staffing from 94 to 103 people.
In addition, each shift would be reorganiced in an attampt to better support both ongoing maintenance and procedural review.
l Item 1.A-10 involved the implementation of a Human Performance Evaluation L
System (HPES). The resolution of this item invoked the appointment and quali-fication of a HPES Coordinator, and the acoption of industry accepted methodo-logies into a NHY program.
Items 1. A-7 involved the rewriting of the Natural Circulation Test proce-dure to allow for testing on decay heat rather than during low power critical operations.
This change will involve a change to the FSAR and to previous commitments. The licensee has submitted a reouest to perform.the test under actual cecay heat conditions.
This issue is under review by the NRC staff.
9.4 Power Ascension Test Program Review L
CAL 89-11 identified items that required significant Startup Test Program involvement.-
Listed below are the stated corrective actions and the documents reviewed by the ORAT team to verify completion of the actions. - No inadquacies were identified.
l (1.0-2) Revise the Startup Test Program to remove the reactivity computer from the horseshoe area when it is not required for testing. Station Management Manual, SM 8.1, Power Ascension Test Program, Section 4.2.3, test performance, y
now requires this.
r=z 36 3
(1.0-3)' Revise the Start.up Test Procedures to provide additional guidance l
for terminating a test and exiting the test procedure when equipment malfunc-l tions cecur. ORAT review confirmed that this had been provided in the Station i
i Management Manual, P 8.1, Power Ascension Test Program, Section 4.2.3, 4.2.6 and 4.2.7.
(1.0-6) Revise the Power Ascension Test Program to include NHY Executive
~
Management " review points" at the key plateaus of 5%, 30%, 50% and 75%.
This i
is now required by the Station Management Manual, SM 8.1, Power Ascension Test Program, Section 4.3.2, Review and Approval of Results.
(1.0-7) Revise the Power Ascension Test Program to require that each pro-cedure has a background document that describes the reason the test is being conducted, the basis for any set point and criteria, or other such information i
related to the test.
The background document will be included in the procedure throughout the review, approval and implementation cycles.
Doing so is now recuired by the Station Management Manual, SM B.1, Power Ascension Test Pro-gram, Section 4.6.12, Attachments and Figure 5.4, Power Ascension Test Back-ground Document Guideline.
9.5 Assessmen*,
The development and issuance of the Procedural Compliance Policy as dis-
~
cussed in items 1.A-1, 1.A-2, 1.A-3, 1.A-4, and 1.A-6 was assessed as conser-vative. Management's intent that all procedures are to be followed unless an overriding safety concern prevents such action is abundantly clear. Guidance as to what constitutes an overriding safety concern and what to do if-a pro-cedure is ambiguous or in error is also provided in the policy' The_ policy was formally issued as a part of Station Procedure 10000.
In addition, it has been 9
quoted in the SSMM, the NPMM'and the OPMM.
The policy and its issuance have received ample management attention'at all levels.
The effect that the enhanced policy on procedural compliance has had on station activities is discussed in other parts of this inspection report, as applicable (e.g., the increase in the number of procedures requiring revision because of increased sensitivity to procedural wording on the part of_ licensee personnel).
Attention to operations has been high, and ORAT and other reviews have found very rigid adherence to procedures.
The licensee's policy is con-servative, clear, and has received adequate emphasis and managemant attention.
There fore, items 1. A-1,1. A-2, l. A-3,1. A-4,1. A-5 and 1. A-6 of the Corrective Action Plan have been adequately implemented.
The training conducted on procedural compliance, as discussed in item 1.A-9, is adequate to provide reasonable assurance that all site workers are or will be made aware of NHY policy. The various memoranda from the Training Group Manager indicate that management is taking a serious and active role in r
ensuring 100% training.
Further, the lesson plan for Procedural Compliance L
Policy training has received adequate management review.
The training program a
b 37 L
I is ongoing, and there is reasonable assurance that it will continue to be man-F aged properly.
Therefore, item 1.A-9 has been properly implemented by the i
licensee.
As part of the response to item 1.A-11, Licensed Operator Training Pro-i gram, the Training Group Manager reviewed current simulator scenarios with re-gard to their ability to challenge operator judgement on procedural compliance.
Tne scenarios were found to be adequate.
As anotner part of the response to this item, a fnemorancum from the Training Group Manager stated that extensive E0P training with the focus on procedural compliance had been conducted and witnessed by OA personnel.
NHY OA observers made no written comment on the s'
training.
Licensee training and QA managers were advised of the benefits of written QA assessments of training.
l-As the final part of the response to this item, a series of freetings be-i tween management and the operating crews was held. A summary of the questions that arose during these Pf;etings, along with the answers to those questions, was distributed to all cperators.
Although formal test results and comments by the QA department would have imoreved the licensee's respons; to this issue, it was apparent that management has given adequate attention to the review of the Licensed Operator Training Program as it regarcs procedural comoliance.
Licensed operator training will
'be the subject of future NRC inspections and Item 1.A-11 will receive addi-tional NRC attention during those inspections. No evidence of inadequate training or lack of attention on the part of the training department to this issue were identified during this ORAT inspection.
The response to item 1.A-8, reorgani:ation of Operations, was found to be r
appropriate to the needs of the NHY organi:ation. An increase in the size of
-the Operations Department is ongoing.
The form of the reorgani:ation has not been finali:ed, but if ias apparent that there was a dedicated management effort to complete the project.
No further inspection of Item 1.A-8 is re-quired because'of the NHY management attention and direction to this area.
The response to item 1. A-10 consisted of the inception of a Human Perform-ance Evaluation System (HPES).
NHY procedure 12820 establishes the HPES and defines responsibilities. The HPES coordinator and the training manager were trained on the principles of HPES management.
The HPES instruction references the proper documents.. Therefore, the licensee's response adequately meets the commitment to establish a HPES.
The ORAT had no further questions on Item 1.A-10.
NHY's response to item _1. A-7 was revision 3 to the Natural Circulation Test procedure.
That procedure is currently under review by the NRC staff.
p This issue will be addressed in the context of the NRC review of the licensee's submittal (NYN-89140) of FSAR Chapter 14 revisions to their Power Ascension Test
- Program, Additionally, NRC inspection of the conduct of Natural Circulation u
- p..
38 l
l Testing'e FSAR changrWhile Item 1.A-7 cannot be considered finally closed i
is planned.
until th is approved, the planned resolution mechanism is con-
.sidered acceptable, and no further direct inspection of CAL 1.A-7 is required.
j With regard to items 3-1 througn 3-B, review of licensee training mate-
[
rial, internal evaluation reports, procedural revisions and policy messages, i
and interviews with NHY employees from the senior management level down have
{
confirmec a strong management involvement with the NHY CAL corrective action program. While continued upper management oversight of the overall program is
~
L essential to the effectiveness of the implemented corrective measures, no addi-tional NRC inspection, other than the routine planned operations and test pro-gram efforts of items 3-1 through 3-S, is required.
Future NRC inspections of t
h a routine nature will check station ccerator and support personnel attitudes, knowledge, and compliance with the revised NHY programs and procedures and how i
such programs effectively ensure an overall policy of safe plant operation.
['.
The ORAT had no further questions on the arlecuacy of licensee actions on these items.
9,6 Conclusions f
i The licensee's imolementation of a Cor,ective Action Plan in response to CAL 89-11 is ongoing and well directec.
Corrective measures are substantially complete for the corrective action items.
~
Management oversight of the NHY integrated program of corrective action i
implementation has been a strong and continuous effort.
Senior licensee man-t agement personnel are aware that sucn monitoring and oversight must continue.
1 i
The independent assessments of corrective action effectiveness of individual items were a positive initiative.
l Overall, licensee implementation and management oversight of the Correc-tive Action Plan to CAL 89-11 has been good. ORAT inspection of licensee cor-rective measure response has providea evidence that the licensee, upon comple-tion and closure of all CAL' items, will be able to competently and safely operate Seabrook Station in accordance with NRC regulations and a conservative station philosophy.
10,0 EXIT MEETING L
An exit meeting was held on November 20, 1989.
Attendees are listed in
' Attachment 3 to this report.
P 5-
L ATTACHMENT 1 TO rep 0RT 50-443/39-83
}
NRC CCNFIRMATORY ACTION LETTER 89-11 ITEMS REVIEWED On June 23, 1939, the NRC issued Confirmatory Action Letter (CAL) 89-11 in response to the June 22, 1989 natural circulation test event.
On July 12, 1989, tha licensee accressed CAL 89-11 by submitting a detailed corrective action plan.
Se licensee submitted plan updates on August 25 and October 23, 1989.
The plan incluces specific action items which address the root causes of the event.
The CRAT reviewed the completion of selected CAL action items and found each ite'n reviewed to be acceptable.
Those CAL items inspected are listed be-low, witn reference to a'oplicable sections of this inspection report.
[
r IA Pre:edure Comoliance Measures to assure procedure compliance were assessed as acceptable (see Rec:rt Details 9.7 through 9.5).
(Items 1. A.1 through 1. A.10 were closec.)
IB Eeuierent Readiness Ecuicment readiness was found by the ORAT inspection to be properly assured through ;taff qualifications, appropriate operations procedures, are system configuration and operability controls (see Detail 8.2,6).
(Items 1.B.3 through 1.B.8 were closed.)
IC Pretest Preoaration Adecuacy of pretest preparations was not assessed oy the ORAT. This as-pect is addressed in Inspection Report 50-443/89-21, 10 Powe-Ascension Test Procram ORAT review found acceptable Startup Test Program Corrective Action, (see Detail 9.4),
(Items 1.D.2,1.D.3,1.D.6, and 1.D 7 were closed. ) Accept-ability of the Startup Test Program is further documented in Inspection Report 50-443/S9-21.
2A Post Event Manacement Complete review of post-event reviews requirements for comprehensive con-sideration of-human performance and other evaluative criteria was not accomolished by the ORAT, but the conclusion was drawn that NHY upper man-agement showed a conservative approach to problem resolution and ar. appro-priate safety perspective (Detail 3.2).
Also, the ORAT found plant opera-tors and managers to be appropriately trained (Detail 4.2).
Further, the ORAT found NHY's program for response to operational events to be accept-able (Detail 4.2.5) and noted that the NHY event reporting and evaluation process had been improvec (De: il 4.2.6).
The ORAT did confirm NHY plans
,y.. g
,. o
, Attachment 1-
- 2.
4 for corrective measures to ensure that post-event review requirements
~
specifically recuire resolution of both human' factors and equipment f ail-c'
- ure aspects.
(Items 2.A.1 through 2.A.5 were closed.) Final inspection of these Event Evaluation and Post-Trip Review issues 1s-addressed in In-spection. Reports;50-443/89-13 and 50-443/89-21.
2B lOperationsManagement Operations staffing' and management was found to_ be acceptable for power operation (see Details 3.2,_3.3, 4.2).
(Item 2.B.2 was closed.)
3-
.Manacement Oversicht d'
Management oversight of facility activities was'found t'o be acceptable-
- (see-Details'3.0, 9.2 through 9.8).
(!tems 3.1;through 3.8 were closed.)
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' ATTACHMENT 2 TO REPORT 50-443/89 'l MAINTENANCE PROCEDURES REVIEWED OR OBSERVED l
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. R 88-648S Emergency Diesel Generator Exhaust System; Repair Leaks y
l TWR.89-2648 Disassemble' Valve RH-21; Examine Seat.and Otsk
^
MS 0514.05 Movats Testing of Raising Stem Motor Operated-Valves ES 1809.001
- Master Integrity Test. Procedure
,i ix OX,1456.81 Operability Testing of IST Valves-k' WR 89-5278 SW/PCCW HX Eddy Current Testing iy MS 0515.19.
PCCW "A"'anc "B" Heat Exchanger Channel Head Cover Removal /In-I
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sta11ation
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MS 0517.03-Installation of Piping, Pipe-Supports and STOW Supports 11
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MS 0517.08 Installation of Structural Steel m
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MS,0517.10 Installation and Repair
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e OCR 87-193 Lifting Device for 1-CC-E17A&B Covers I
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MS 0518.08-Piping Suppert Spring Can Setting and System Balancing
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ATTACHMENT 3 TO REPORT E0-443/89-83 EXIT MEETING ATTENDEES New Hamoshire Yankee W. Temple, NRC Coordinator R. Conolly, Lead QC Insoector i
J. Warnock, Nuclear Quality Manager D. Sov111, NQG Surveillance Supervisor J. Cady, Independent Safety Engineering Group Supervisor D. Perr. ins, Licensing Engineer D. McLain, Production Services Manager
.E R. Sweeney, Eethesda Licensing Manager
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F. Sowetsky, Tecnnical Projects Supervisor J. Peterson, Assistant Operatinns Manager.
J. Malone Ooerations-Administrative' Supervisor E
I W.! Cash, Health Physics Departrent Supervisor
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J. Linville, Chemistry Department Supervisor
~T. Murony. I&C Department Supervisor 7
F. Ricnarcson, Training Managet j
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C. Vincent.QC Department Supervisor L
J. Peschel, Regulatory Compliance Manager R. DeCoach, Executive Director - Engineering / Licensing
- i. Haroster,-Cirector,. Licensing Services t
S Buchwald, QA Supervisor-F
- 0. Moccy, Station-Manager N,! Pillsbury, Director of Quality Programs
/
S. Draworidge, Executive Director-of Nuclear Production T,-Feigenbaum, Senior Vice President and Chief. Executive Officer J.'. Grille, Operations Manager R. Cyr,. Maintenance Manager V. DiProfio, Assistant Station Manager i
N V-.S. Nuclear Reculatory Commission I
-J. Johnson, Chief, Projects Branch No. 3, Division of Reactor Projects (DRP) t Kolcoauski, Project Engineer,-Technical Support Section, DRP
- 1. Fuhrmeister, Resident Inspector, Seabrook
'R. 'iessman, Director, Project Directorate 1-3, NRR V., Nerses,'. Project Napager, PD I-3, NRR N, Dudley. Project Engineer Projects Branch No. 4, DRP v*!S A. Cerne, Senior Resident-Inspector..=Seabrook MS
, Fn Young, Senior. Resident Inspector, Three Mile. Island 1s 4
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UNift0 STATES et t
NUCt.EAM CEQULATORY COMMIS$10N meOloN 1 j
i US ALLI.NOALE ROAO h
CNO CF PRUSSIA. PENNSYLVANIA 164ee Docket No. 50-443 09m Public Service Company of New Hampshire ATTN:
Mr. Edward A. Brown President end Chief Executive Officer New Hampshire Yankee Division Post Office Box 300 i
Seabrook, New Hampshire 03874 Gentlemen:
5
}
$ubject: HRC Region ! Inspection 50-443/89-13 (10/11/89 - 12/11/89)
Unit No. 1. Seabrook, New Hampshire.This refers to the above s Aspects inspected included operation.11 safety. ESF system walkdowns, reportable events, open items and event f i
up, the Containment Integrated Leak Rate Test, quality assurance activ The results of the inspection were discussed with M t
bers of your staff.
Two violations of NRC requirements, identified by your staff, were review One-involved f ailures - to follow maintenancs procedures; the other inv compliance with technical specification action statements.
These violations ment Policy (10 CFR 2, Appendix C) have been satisfied.are:
However, management other procedural or personnel errors is warranted. attention to p No reply to this letter is required. Thank you for your cooperation.
j Sincerely, L
n 11, f YW Jon R. Jo'ifnson, Chief Projects Branch No. 3 Division of Reactor Projects
Enclosure:
NRC Region ! Inspection Report No. 50-443/89-13*
f
- Contains Safeguards Information i
t P
f Public Service Company of 2
SU4N 8 8 INO New Hampshire t
ec w/o Page 22 of enc 1**
i J. Duffett, President and Chief Executive Officer, PSNH T. Feigenbaum, Senior Vice President and Chief Operating Officer, NHY J. P2schel, Operational Programs Manager, NHY D. Moody, Station Manager, NHY T. Harpster, Director of Licensing Services R. Hallisey, Director, Department of Public Health, Commonwealth of Massachusetts 1
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector (w/cy of enc 1)*
State of New Hampshire Commonwealth of Massachusetts Seabrook Hearing Service List
'Contains Safeguards Information i
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SEABROOK HEARING SERVICE LIST Pubite Service Company of New Hampshire ATIN: Mr. Edward A. Brown, President USNRC Resident Inspector l
Post Office Box 1149 and Chief Execustve Officer Post Office Box 300 Seabrook, New Hampshire 03874 Seabrook, New Hampshire 03874 Public Service Company of New Hampshire ATTN: Mr. John C. Duf fett Mr. T. Harpster President and Chief Executive Public Service Company of i
Officer New Hampshire P. O. Box 330 P.O. Box 300 2000 Elm Street Seabrook, New Hampshire 03874
~3 Manchester, New Hampshire 03105
[
Mr. Donald E. Moody Mr. James M. Peschel Public Service Company of New Hampshire Public Service Company of New Post Office Box 300 i
Hampshire Seabrook, New Hampshire 03874 Post Office Box 300 Seabrook, New Hampshire 03874 r
Mr. Ted C. Feigenbaum Mr.. R. Hallisey, Director Public Service Company of New Hampshire Dept-of Public Health Senior Vice President & Chief Operating Commonwealth of Masssachusetts Officer t
Post Office Box 300 Radiation Control Program 150 Tremont Street, 4th Floor Seabrook, New Hampshire 03874 Boston, MA 02111 Massachusetts Transportation Building E. Tupper Kinger, Esq.
ATTN: Sarah Woodhouse Assistant Attorney General Legislative Assistant Office of Attorney General Ten Park Plaza - Suite 3220 208 State House Annex Concord, New Hampshire 03301 Boston, Massachusetts 02116 Thomas Dignan Esq John A. Ritscher, Esq.
Jerard A. Crouteau, Constable 82 Beach Road Ropes and Gray 225 Franklin Street P. O. Box 5501 Salisbury, Massachusetts 01950 Boston, Massachusetts 02110 Mr.. Bruce Beckley, Project Manager Dr. Murray Tye, President New Hampshire Yankee P.O.. Box.330 Sun Valley Association 209 Summer Street Manchester, New Hampshire 03105 Haverhill, Massachusetts 08139 r-e
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Seabrook Hearing Service List 2
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i Robert A. Backus, Esq.
Backus, Meyer and Solomon George D. Bisbee, Esq.
116 Lowell Street Assistant Attorney General P. O. Box 516 Office of the Attorney General 25 Capitol Street Manchester, New Hampshire 03106 Concord, New Hampshire 03301 Phillip Ahren, Esq.
Assistant Attorney General Diane Curran, Esq.
Office of the Attorney General Harmon and Weiss State House Station #6 2001 S. Street, N.W.
Suite 430 Augusta, Maine 04333 Washington, D.C.
20009 Steven Olesky, Esq.
Office of the Attorney General D. Pierre G. Cameron, Jr., Esq One Asburton Place General Counsel P. O. Box 330 Public Service Company of New Hampshire Boston, Massachusetts 02108 Manchester, New Hampshire -03105 Ms. Diana P. Randall 70 Collins Street Mr. Alfred V. Sargent, Chairman I
Board of Selectmen Seabrook, New Hampshire 03874 Town of Salisbury, MA 01950 Richard Hamoe,_ Esc.
Ms. Suzanne Breiseth New Hampshire C1'vil Defense Agency Town of Hampton Falls i
107 Pleasant Street Drinkwater Roao Concord, New Hampshire 03874 Hampton Falls, New Hampshire 03844 Mr. Calvin A. Canney, City Manager Senator Gordon J. Humphrey City Hall 126 Daniel Street ATTN:
Tom Burack U.S. Senate Portsmouth, New Hampshire 03801 531 Hart Senate Office Building Vashington, D.C.
20510 m
Board of Selectmen RF0 Dalton Road Mr. Owen B. Durgin, Chairman Durham Board of Selectmen Brentwood, New Hampshire 03833 Town of Durham Durham, New Hampshire 03824 Chairman, Board of Selectreen Town Hall Rye Nuclear Intervention Committee c/o Rye Town Hall South Hampton, New Hampshire 03827 10 Central Road Rye, New Hampshire 03870 Mr. Angie Machiros, Chairman Board of Selectmen Jane Spector for the Town of Newbury Federal Energy Regulatory Comm.
25 High Road 825 North Capitol Street, N.E.
Room 8105 Newbury, Massachusetts 01950 Vashingtan. D.C.
20426
Seabreak Hearing Service List i
3 1
Ms. Rosemary'Cashman, chairman l
Board of Selectmen Mr. R. Sweeney
{
Town of Amesbury New Hampshire Yankee Division
}
Town Hall Public Service Company of i
New Hampshire Amesbury, Massachusetts 01913 Suite 610, Three Metro Center Bethesda, Maryland 20814 j
i Honorable Peter J. Matthews Mayor, City of Newburyport Administrative Judge City Hall Howard A. Wilber i
Atomic Safety and Licensing Appeal Newburyport Massachusetts 02950 Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
Administrative Judge Alan S. Rosenthal, Chairman Administrative Judge Atomic Safety and Licensing Appeal Thomas S. Moore, Esq.
)
t Board Atomic Safety and Licensing Appeal Beard U.S. Nuclear Regulatory Commission Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Emmeth A. Luebke Administrative Judge Jerry Harbour Atomic Safety an'd Licensing Board
~
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Wasnington, D.C.
20555 U.S. Nuclear Regulatory Commission Vashington, D.C.
20555 Edwin J. Reis. Esq.
Office of the General Counsel H. Joseph Flynn, Esq.
U.S. Nuclear Regulatory Commission Assistant General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C. Street, S.W.-
Washington, D.C.
20472 Edward A. Thomas Federal Emergency Management Agency Carol S. Sneider, Esq.
442 J. W. McCormack (POCH)
Assistant Attorney General Office of the Attorney General Boston, Massachusetts 02109 One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Paul McEachern. Esq.
Shatnes and McEachern Richard A. Haaps, Esq L
25 Maplewood Avente Haaps and McNicholas 35 Pleasant Street l
Portsmouth, New Hampshire 03801 Concord, New Hampshire 03301 Board of Selectmen 10 Central Street Allen Lampert Civil Defense Director Rye, New Hampshire 03870 Town of Brentwood 20 Franklin Street Exeter, New Hampshire 03833 i
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Seabrook Hearing Service List 4
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l William Armstrong Civil Defense Ofrector Sandra Gavutis, Chairman Town of Exeter Board of Selectmen 10 Front Street RF0 #1, Box 1154 Exeter, New Hampshire 03833 Kensington, New Hampshire 03827 Anne Goocman, Chairman Board of Selectmen Stanley W. Knowles, Chairman 13-15 Newmarket Road Board of Selectmen P. O. Box 710 Durham, New Hampshire 03824 North Hampton, New Hampshire 03862 i
Norman C. Kantner Superintendent of Schools Judith H. Mit:ner School Administrative Unit No. 21 Silvergiate, Gertner, Baker, Fine, Aluani Drive Good, ano Mit:ner j
88 Broad Street Hampton, New Hampshire 03842 Boston, Massachusetts 02110 Jane Doughty Seacoast Anti-Pollution League Gary W. Holmes, Esq.
Holmes and Ellis 5 Market Street 47 Winnacunnet Road Portsmouth, New Hampshire 03801 Hampton, New Hampshire 03842 Mr. Robert Carrigg, Chairman Board of Selectmen Adjudicatory File Town Office Atomic Safety and Licensing Board Atlant Avenue Panel Docket U.S. Nuclear Regulatory Commission i
North Hampton, New Hampshire 03870 Washington, DC 20555 Y
i U.S. NUCLEAR REGULATORY CDMMISSION, REGION I 1
Docket / Report No:
50-443/89-13 License No.: NPF-67 Licensee:
Public Service Company of New Hampshire 1000 Elm Street Manchester, N.H.
03105 Facility:
Seabrook Station, Unit No.1. Seabrook, New Hampshire f
Dates:
October 11 - December 11, 1989 Inspectors:
A. Cerne, Senior Resident Inspector R. Fuhrmeister, Resident Inspector
- 5. Barr, Reactor Engineer N. Dudley, Project Engineer W. Lancaster, Physical Security Inspector E. Sylvester, Senior Reactor Engineer J. Yerokun, Reactor Engineer Reviewer:
N. Ervin, NRC Office of Nuclear Reactor Regulation Approved By:
044 0, b b '
___ Il6 ho Ece C. McCabe, Chief, Reactor Projects Section 38 ~
Date Areas Insoected:
Operationul safety, ESF system walkdowns, reportable events, open items, the Containment Integrated Leak Rate Test, quality assurance acti-vities, security, and design modification activities.
1 Results:
Licensee planning, corrective measure implementation and overall re-sponse to potential problems with plant equipment (e.g., Westinghouse Technical Bulletin section 3.5.4; Rosemount Part 21 Report section 8.2) has been com-prehensive and technically sound.
I Two non-cited violations (sections 3.4 and 8.1) were identified by the lican-Both procedural adherence and personnel errors were involved.
see.
amples where licensee action was required to correct procedure / personnel inter-Other ex-action problems are also discussed in this report (sections 3.5.2 and 8.3).
Ccntinued management emphasis upon associated interdepartmental coordination and monitoring of work is appropriate.
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Successful performance of the Containment Integrated Leak Rate Test was wit-L nessed.
that a repeat valve repair may not prevent recurrence (sectio involvement of Quality Assurance personnel in work and corrective action in-Routine plementation, as well as in surveillances and audits, was evident.
A revision to the Seabrook Station Physical Security Plan is needed to resolve safeguards issues raised by an NRC security evaluation (section 9).
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TABLE OF CONTENTS -
PAGE 1.
Persons Contacted.....................................................
1 2.
Summary of Activities (30702).......................................
1 l
3.
Ope ra t i ona l - S a fe ty ( 71707)...................................
3 3.1 Plant Operations......
3.2 Plant Tours....................................................
3 3.3 Operating Procedures Review...............
4 3.4 Follow *ep of Operating Equipment Questions from Plant Heatup....
6 3.5 Operating' Event Follow-up.......................................
6 8
4.,
Engineered Safety Fea tures fys tem Walkdown (71710)...................
11 5.
Containment Integra ted Lea k Ra te Test (70313)........................
12:
S.
Installation and Testing of Design Modifications (37828).............
14 I
7.-
Quality Assurance / Corrective Action Activities (40500, 92702)........
16 7.1 Low Power Test Program Audit.................
7.2-Corrective Action Plan Review................
16 16 8.
Follow-up' of Licensee Reports and Open Items (92700, 92701)..........
17 8.1 Licensee Event Reports...................
E 8.2.10 CFR 21 Report.........................
17 8.3 Licensee Action on Previously Identified Items..................
...................... 18 m
19 9.
Physical Security Plan Implementation and Controls.(81052)...........
20.
10.
Management Meetings (30703)..........................................
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u OETAILS 9'
1.
persons Contacted - New Hampshire Yankee (NHY)
E. Brown, President and Chief Executive Officer J. DeLoach, Executive Director of Engineering and Licensing
- 8. Drawbridge, Executive Director of Nuclear Production T. Feigenbaum, Senior Vice President and Chief Operating Officer "J. -Grillo, Operations Manager R. Hanley, Operations Training Manager T. Harpster, Director of Licensing Services J. Hart -Licensing Manager q
G. Kann, Program Support Manager S.- Kulback, Operations Security
- 0. Moody, Station Manager J. Peschel, Operational Programs Manager
- N. Pillsbury, Director of Quality Programs C. Roberts, Manager, Security and Compensatory Systems J Vargas, Manager of Engineering
- J. Warnock, Nuclear Quality Manager
' Attended exit meeting conducted on December 12, 1989.
Other licensee and contrac' tor personnel were also contacted.
2.
Summary of' Activities L
2.1 Resicent Inspector Activities i
entire inspection period.One senior resident inspector (SRI) was assigned to t On November 20, 1989, a new resident inspector was assigned to the Seabrook resident office.
inspections, witnessed the Containment Integrated Leak na
- lant security.
p report section appropriate to the inspection effort. Regional inspector and reviewed backshift hours. were 6xpended.- A total of 243 inspection hours, including i:
L The SRI also participated in a meeting on October
- Assessment of Licensee ' Performance (SALP) Report No. St 11, 1989 at Seabrook 50-443/87-99, ceveting the raried frcr August 1,1987 - June 30,1983. Another meeting to discuss the f'
"itensee's-schedule and action plan for ope, inspection issues was also held o site on' October 11, 1989.
meeting in' King of Prussia, Pennsylvania on OctoberThis meeting was a pre 18, 1989 to discuss the NHY Corrective-Action Plan status and the self-assessment program for the Unit 1 a
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2 9-power ascension program. -The SRI attended these meetings, as well as ones con-ducted by Region I and NRR personnel onsite on November 8,1989 to review is, plementation of certain sections of the Seabrook Station Physical Security Plan and on November.20, 1989 to further discuss the licensee schedule for Correc-tive Action Plan and open item closure and readiness for testing. During November 13-20, 1989, the SRI participated in the Operational Readiness Assess-ment Team (ORAT) inspection of Seabrook Unit 1.
From October 23-27, 1989 while the SRI inspected another nuclear power station, a regional reactor engineer was assigned to Seabrook Station for rou-tine coverage and safety system and equipment modification reviews. During the week of December 4, 1989, the SRI also attended training and a resident coun-terpart meeting in King of Prussia, Pennsylvania.
2.2 Visiting'Insoector Activities On October 12, 1989 an NRR Radiation Protection Branch reviewer visited the site to examine system modificatices and documentation related to todine effluent sampling, as discussed in the Safety Evaluation Report (SER) for Sea-brook Station, confirmatory item no. 60.
On October 16-20, 1989, a regional inspector reviewed licensee response anidual heat removal system was returned to service.
buses, the diesel generator supportMajor work was conducted en the electrical systems and the control building air, con-L tainment tuilding spray, service water and primary. component cooling water (PCCW) systams.
Inspection, eddy current testing and repair activities related to tubing in the PCCW heat exchangers represented the major train related out-age work in progress on the primary side of the plant.
The Containment Inte-grated leak Rate Test (CILRT) was conducted over a four-day period commencing on November 19, 1989.
3.
Doerational Safety 3.1 Plant Ooerations The inspector observed plant operations during regular and backshift in-spections of the control, room and during routine tours of the plant.
In the-control room, plant logs, night orders, technical specification action state-l ment _ status, and alarm conditions were reviewed, and operators were interviewed regarding control board indications and system lineups., Tagging controls and
. plant valve positions, used to support field work, were spot-checked and the Monthly Temporary Modification (TM00) Report was reviewed to verify proper TM00 controls and tagging.
The inspector also verified that control room personnel were properly utilizing temporary pump requests for field situations requiring the installa-tion of portable pumping equipment in pi' ant sumps. Discussion with the rad-waste and utilities-(R&U) supervisor confirmed adequate control of the proce-durally required temporary pump request forms.
Additional discussions were held with the R&U supervisor concerning the control of Administrative Site Pro-cedures (ASPS), fire barrier integrity, and containing the leakage of rain t
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4 water into the plant.
ties have been cancelled and a request for engineerinct serv has been issued to address the water leaks.
89-1054) removing water as leakage occurs were assessed as acceptable. Interim corre tion action statement status sheets for two specific lim Room Ventilation) for a one-month period. operation (LCO 3.3.3.1, C mon intake radiation monitoring which affects each LCO compliance statement differently.
Thus, at any given time, either or both of -the: tech-ticular component failure.nical specification action statements may be enter for the other action statement's applicability. Exiting an action statement The inspector's review of eight action statement entries and seven exits during-the sampled month re-vealed precise accountability and documentation by the control room operato All questions raised by the log book review were satisfactorily answered action statement status sheets.
The inspector witnessed licensed operator personnel in the performance of watch-standing duties for the purpose of upgrading their inactive licenses to t
active status.
Recualification training for licensed operators was discussed with training and operations-management personnel and the station policy of L
removi'ng from shif t duties any operator who has f ailed requalification E
was confirmed.
In such situations, the inspector noted that the licensee pro-r gram for remedial training and appropriate retesting is flexible to fit inci-
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viciual training needs and has been effectively used.
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,The inspector's witness of cold shutdown operations and review of work
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- control activities within the control room identified no concerns.
were cognizant of overall plant and equipment status and performed board mani-Operators.
pulations and system realignments in a controlled manner in accordance with procedural requirements. O
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served in the control room,perations management personnel were frequently ob--
particularly during shif t changes, i'
3.2 Plant Tours The inspectors observed activities and plant status during general inspec-tions of the plant.
Work was examined for defects or noncompliances, and sta--
l tion staff. and contractor personnel were interviewed in their work areas.
. The inspector verified proper positioning, in accordance with oper tional L
procedures or work controls, of various valves, switches a Similarly, temporary modifications and component-tagging, maintenance work, a design change implementation activities, as observed-during plant inspection the work with the control room and operations personnel on sh 1
In certain p
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-5 cases, the operability of specific components and the applicability of the ob-served work to the technical specification requirements were discussed with the operators.
ing, the control of temporary equipment and staging, t miscellaneous equipment within the radiologically controlled area (RCA), RC access controls, and the compensatory measures in place for degraded secur systems and fire barriers. Generally good work practices were in evidence.
For areas where work is in progress ov,er several days, it is difficult to con-firm small work item and tool controls until the job is finished.
" roll back" out of certain plant areas is planned prior to plant heatup, in-
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While a creased attention to work controls during jobs in' progress should be emphasized by station management.
During a tour of the Unit I tank farm, the inspector noted the existence of several floor drains within the diked area surrounding the refueling water storage tank.
From a review of the piping and isometric drawings, it appeared that these drains were connected to the floor drains inside the di rounding the reactor water makeup tank.
That would bypass the RWST dike.
have separate drain systems with isolation valves which Dis-draining.- Cross connecting of the floor drains is also precluded.
t tor ha'd no further questions, The inspec-l i
going' activities involving eddy-current inspection of the tu i
I primary component cooling water (PCCW) heat exchanger.
heat exchanger. presence of broken off rolled ends of tube sleeves in the lowe noting the advanced erosion evident on several.The inspector also exam i
Notable by its absence was the corrosion, biofouling, and debris often associated with sea water cooling sys-
- tems, i
A' tour of other plant areas and buildings resulted in specific observa-tions as follows:
door problems) and posting, and material condition of equip verified access control ( a guard-was posted due to i
material which could become missle> due to seismic activity was evident.
No loose basin was filled.
The spite of ongoing work). Containment tour - housekeeping was good (no loose m Containment sump screens were in place and intact.
Mesh barriers were being erected at accesses to areas which could become n radiation areas once the plant has operated at power.
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i Diesel generator building portable catwalks secured, cranes / hoists secured, no equipment / debris lying,about loose. An air-operated pump was used
- to circulats fuel oil through a filter.. Oil soaked rags and filters were in plastic bass on the catwalk in the bay for the tank being cleaned ('B' tank).
With respect to all of the above area inspections, building tours and ob-servations, no violations or unresolved safety concerns were identified.
e 3.3 Ooeratino Procedures Review On, September II,1989, the licensee completed a review of all operating procecures for consistency.
The review was conducted as part of a commitment documented in NRC Region I Inspection Report 50-443/87-10. As a result. of the
. review,'the licensee issued Operating Procedures OP 11.2, " Operating Procedures i
Writer's Guide," and OP 11.1, " Surveillance Test Procedure Writer's Guide." to establish a consistent format, style, and content for writing procedures. The inspector-reviewed OP 11.1 and OP 11.2 and concluded that the procedures pro--
vided.acequate detailed guidance for procedure writers.
The inspector had no questions.
The inspector reviewed the new Operations Department Instruction 001.21,
" Direction for Inoperable Snubbers," which provides directions for dealing with inoperable snubbers as described in NRC Region I Inspection Report 50-443/
89-087 The instruction requires an evaluation by the technical support grouc prior to removal of a sqgbber from service and the tracking of snubber removal under the action statement tracking system for snubbers covered under technical specification action statement 3/4.7.7, " Snubbers." A ~11 sting' of snubbers by number and system location is available in the control room.
The inspector concluded that 001.21 provices an appropriate method for determining-the'oper-ability of snubbers and provides adequate guidance to the Unit Shift Super-visor. The inspector had no questions.
3.4 Follow-uo of Ooerating/Ecuiement Ouestions from plant Heatuo During plant heatup for low power testing, several equipment' failures occurred and were discussed in NRC Region I Inspection Report 50-443/89-80.
Subsequent inspector follow-up was: conducted to detennine the cause of and cor-rective actions taken for each of the-failures.
During heatup prior to initial criticality, residual heat removal cold leg injection valve RH-14 failed to open remotely. The valve was manually stroked without problem.
Investigst.isn determined that the motor pinion key had sheared. The motor pinion iey was replaced on May 31, 1989, and the valve operability test was satisfactory. The pinion key was seneduled to be replaced af ter low power testing as a result of recommendations made in NRC Information Notice 88-84. The pinion key had not been replaced prior to low power testing because of the planned operability tests and the planned replacement of all keys during system outages af ter low power testing, and also because of the l$
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consideration of low decay heat levels during low power testing,-
All other similar pinion keys in safety-related motor-operated valves have since been replaced.
Residual heat _ removal (RHR) crossover valve RH-V21 would not open re-motely.
Af ter being manually opened, the valve was successfully stroked from the main control room.
Investigation determined the valve had stuck on its seat due to thermal binding.
Operational steps to prevent future binding were being developed and the inspector has no further questions in this regard.
During initial operation of the reactor coolant pumps (RCPs) for heatup prior to-initial criticality, a vibration alarm was received on RCP-B.
Inves-tigation of the vibration meters on all four RCPs determined that seven of the eight frame vibrator indicators were inoperable.
taken on the pump shafts and motor frames and were within limits. Local vibration Further troubleshooting identified that all eight probes-had been wired incorrectly, seven in one configuration and the eighth in another.
The licensee determined that the vibration monitors were most likely improperly wired during replace-ment and testing conducted after initial installation in October 1985.
Post-maintenance testing involved only continuity tests and did not include func-tional or calibration tests.
New calibration procedures have been written based on information obtained from the vendor, Bentley Nevada, and are to be incorporated into the 18-month-functional checks for the indicator probes.
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inspec' tor had no further questions.
During heatup prior to initial criticality, an alarm received in the con-trol room indicated low flow in loop 1 with the RCP running.
Licensee inves-4 tigation determined-that the flow element was installed backward.
Further in-l vestigation determined that the loop 2 flow element was also installed bacK-L ward.
All four flow elements had been removed and reinstalled in December 19 to repair. gasket leaks.
p and 3 ~did not require verification of proper orientation of the flow ele l
while the work request for the finw element in loop 4 required QA verification.
Loop 1 and 2 flow elements were ' removed and properly. reinstalled on June 3 1989.
The licensee performed a 100%' quality assurance check of all flow elements,. flow orifices and restricting orifices. for instrumentation located in safety-related systems. The' inspector reviewed the results of the quality checks and verified that all flow orifices were determined to be installed cor-1 l;
rectly. The licensee later added a check.for proper orifice installation on l;
the final inspection checklist for piping as part of maintenance procedure MS L
0517.03, " Installation of Piping, Pipe Supports and STOW Supports."
The in-spector had no further questions, s
'The final equipment question raised during the readiness inspection for low power testing involved demineralizer three way divert valve CS-TCV-129, which would not stay in the 'demin' position with the control switch in the
' auto' position.
Investigation found that one lead in the control circuit was l
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not terminated and that dynamic testing af the valve was not conducted. -Con-tinuity checks and relay operation of relay R1 contacts were conducted rather than the specific dynamic valve position verification due to the inability to establish required plant conditions for dynamic testing.
The licensee identified that this deviation from the required retest was not in accordance with maintenance instruction MT 3.1, section 4.1.23, and that-the incomplete documentation of lifting the lead was a failure to follow the requirements of maintenance procedure MA 4.5.
These two licensee-identified examples of-failure to follow maintenance procec.mes violated regulatory re-quirements which require that procedures be preserly implemented.
tion 's not being cited because' the criteria specified in 10 CFR 2, Appendix C -
i The viola-Section V.G.1 of the Enforcement Policy were satisfied; The licensee identi-
-fied the problem.
Corrective actions for procedur&l compliance are being effected as part of the. license response to Confirmatory Action Letter 89-11. A non-cited violation (NCV 89-13-01) which concurrently is heremy closed. documents identification of this issue, On September 25, 1989, the Nuclear Quality Group issued Corrective-Action Request 89-005 to express concern regarding seven station information reports which identified problems with post-maintenance testing, in response to the'
'a CAR, a committee was taskee with review of the reasons for the inadequate post-maintenance tessing.and with developing recommendations to improve the
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post-maintenance test program.
The committee has not completed its review.
The prerent post-maintenance testing program was reviewed by the' 0perational i
Readiness Team in NRC Region I Inspection Report 50-443/89-83 and found ac able.
i 3.5 Operating Event Followuo 3.5.1-Loss of RHR Shutdown Cooling Capability o
On October 11, 1989,
'A' residual heat removal (RHR) pump stroked close.one of the two suction valves l
.Since the train 'B' RHR system was out of service for maintenance, the loss of train 'A' RHR suction flow resulted in the loss of all RHR cooling. This condition was corrected less than an hour later when the valve that was closed, RC-V-22 reopened, the 'A' RHR pump was restarted and full RHR flow was r,eestablished.was manua
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With negligible decay heat in the reactor core, reactor coolant system tempera-tures did not rise during this. event.
ters.Outy Officer via the Emergency Notification System (EMS) in accordan with 10 CFR 50.72.
Licensee Event Report (LER) No.89-012 was issued to evalu-ate the root cause, safety consequences and corrective actions.
Since valve RC-V-22 is energized from a train 'B' electrical bus, valve closure was traced.to the reenergization of the train 'B' motor control center
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k) supplying power to RC-V-22.
the valve stroked closed because control pWhen the supply breaker for RC-V-22 wa for the valve.
ower had not yet been reestablished figuration at the time.The valve performed as designed for the electrical power con-
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The root cause of this event was procedural. While ongoing maintenance.
activities and plant conditions required only partial restoration of train 'B' electrical power, the procedure used to restore power was written to provide-1 Lfor complete restoration of the AC bus. No consideration was given to-the re-storation of DC control power to RC-V-22 prior to motive power restoration.
In this cast, the actual electrical configuration for the work was not properly considered. in restoration planning.
Complete licensee corrective action in response.to this event will be re-
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viewed as follow-up to LER 89-012, which remains open.
3.5.2 Primary Orain Tank (PDT) Collapse On November. 21, 1989, the 'A' Primary Drain Tank (BR5,TK-66A) was found in a partially collapsed and buckled condition.
Station Information Report. (SIR)89-079 documented this discovery and an event evaluation team was established to determine the cause. The PDT is a non-safety-related tank located in the Waste Processing, Building._ -Two tanks are located side by side and designed to service two nuclear units. With the 'A' tank collapsed, the 'B' tank remains i
available to. support Unit 1 operation.
Licensee. evaluation of.this event for reportatility under 10 CFR 50 requirements made a_ determination vf nonreport-ability.
The' inspector reviewed the Ev'ent Evaluation for SIR 89-079, noting that the failure to provide vacuum protection, due to isolation of the nitrogen purge supply valves to the tank during tank pump down, was the cause of the tank collapse.
During tank pump down, an auxiliary operator (AO) misinter-preted a gauge reading normal atmospheric pressure (i.e., approximately 15 psia)~ to represent 15 psig overpressure on the tank.
Thus, the A0 believed that the crocedural precaution regarding positive tank pressure to be main-tained was met. ~This mistake was compounded by the misaligned' nitrogen purge-valves and a procedure which should have stressed the importance of monitoring tank pressure during pump down (the tank is net constantly vented).
The inspector _ reviewed the licensee recommendations resulting from.the event evaluation team review. An NRC Region I effluents specialist _ inspector also examin'ed the tank, reviewed this event and discussed his follow-up in NRC Region I Inspection Repert 50-443/89-18. The licensee's Event Reduction Com-mittee also will be reviewing this' event and is required to report its-findings-to the Nuclear Safety Audit and Review Committee (NSARC).
The inspector has no further questions on the collapse of the 'A' POT.
The licensee's evaluation of this event was thorough and the resulting recom-mendations were found technically correct and comprehensive.
3.5.3-Engineered Safety Features (ESF) Actuation v.
On November 29, 1989, a loss of train 'A' power for a few seconds caused the _ control room emergency filter fan to start and. align the control building air system in the recirculation mode.
This is considered an ESF actuation and 4
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was reported to the NRC Headquarters duty officer via the ENS in accordance with 10.CFR 50.72.
scheduled LER 89-14 to be issued no later than Decembe
.-g 29, 1989.
The inspector reviewed SIR 89-0B0 associated with this event.
While all systems operated as required, the failure of battery charger EDE-BC-1A while restoring the train 'A' vital batteries from a cross-connected condition appears to require additional investigation and causal analysis.
ation was not caused by a valid signal and thus The ESF 'actu-while reportable, represents an electrical failure ed interaction problem., Alignment of the station train
'A' vital battery buses in a cross connected configuration is allowed by the station DC electrical. design, with two 100% 125 volt batteries in each train.
However, proper procedural control and implementation should allow restoration
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of each DC bus to its own battery supply without loss of vital equi battery charger. Further-NRC review will follow LER 89-14 issuance.pment like a 3.5.4 Westinchouse Technical Bulletin NS0-TB-89-06 Follow-up On November 1,1989, the Westinghouse Electric Corporation (W) issued a
. Technical Bulletin acdressing the possibility of incorrect termi point clip connections being installed in the solid state protection system (SSPS).
along with a sample of pull tests were recommended 100% visual in A
The licensee implemented these recommendations and*1dentified a pull test failure in the' train 'B' SSPS resulting~in the requirement to implement a 100% pull test inspection.
. The inspector witnened a portion of the pull test inspections in SSPS control panel 1-MM-CP-13.
Correct use of the applicable procedure and the use of calibrated tools were confirmed, as was the presence, of knowl-IS 89-1-1, edgeable quality control inspection personnel.
The inspector. interviewed the r
technicians. responsible for the test and determined that the quality checks were being performed in accordance with the published acceptance criteria (re-ference:
tion).
Operator's Quality Check Procedure for AMP TERMI-POINT Clip Applica-The inspector also discussed the results of the train 'B' inspection and the plans for the train 'A' SSPS inspection with the responsible system support No inadequacies were found with the licensee response to W Technical manager.
There was appropriate QC involvement in the inspection proce l.
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Completion of the recommended inspection requirements for all safety-related termi point clip l
installations is scheduled prior to plant heatup. Since the non safety-related connections are not scheduled for inspection at this time, the inspector re-quested confirmation that visual inspection, in accordance with the W recoa-E mencation, would be performed.
The licensee committed to conducting such in-spection and tracking its accomplishment on the licensee's integrated commit-1 sment tracking system (ICTS), reference No. RE03104.
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Additionally, the licensee
. requested that W evaluate any delay of the non safety connection inspections I
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until after completion of-the power ascension test program.
i November 16, 1989, W responded that there was no need to conduct an immed By letter dated J.
inspection of. the non-safety related termi point clip installations.
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and replacement work.The inspector had no further questions on the termi poin i
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En.nineered Safety Features (ESF) System Walkdown (RHR) system.The inspector walked down accessible portions of the Residual He circulation mode and RHR train 'B' was in a system outage.At the time, RHR train
'A' was in operation.in the hot leg-re--
L The purpose of the walkdown of train 'A' was to check on conformance with the most recent valvelineup an train 'B' was-performed to check the progress of outage work, mafr,enance and modifications.
L The inspector checked the ESF lineup of the RHR train 'A' system.from the primary loop connections =inside containment to the penetration area and RHR equipment vault outside the containment.
inspector utilized the licensee's operations form OSTo verify proper valve lineup, the 1013.03A Lineup," and drawing 9763-F-805808, "RHR System Piping and Instrumentation"RH Orawing "
The inspector found two valves out of position per OS1013.03A; how-ever, both discrepancies had been previously identified by the licensee and-were being acceptably controlled and tracked with form OP10.38, " System Linvuo s
Review and Exception Sheet."
reviewed the overall material condition of the system.In addition to the syste The ",tspector noted perly labeled, instrument calibration was up-to-date, and were properly aligned and attached.
rial condition'was valve RH-V-8,: the RH-P-8A pump. discharge sample i
valve was found.to be leaking, but the licensee had. positive control of the The 3
. situation.
was.being collected in a funnel and directed to= a flour drain. Rad Subsequent to the walkdown, the inspector reviewed a Request for Engineering Services (RES) that had been submitted by the licensee RHR System Engineer concernit? N V-8 and other similar valves in the RHR system.
The RES requested thas type vent and drain valves be replaced with globe valves due to tin o, asive
<its-mainMnance required for the gate valves. Based on the inspection of Zn ' rain
'T ad in light of the proper documentation for-all noted discrepancies, the i m pector determined that the system was being effectively maintained and.was capable of performing all required ESF functions.
. Following the inspection of RHR train
'A', the inspector walked down the RHR 'B' train accompanied by the licensee RHR System Engineer.
The purpose:of this walkdown was to inspect the modifications made to train 'B' during-the system outage.
The same modifications had been made to train'A' during its previous outage.
One design change inspected was the addition of a check valve in series with each of two existing check valves that provide isolation of RHR r.
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.c train 'Bfrom the' Containment Building Spray system.
confirmatory item in the Seabrook Safety _ Evaluatien Aeport, Supplement !
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- documenting the licensee commitment to add the additional check valves.
Other modifications inspected were the substitution of a globe valve in place of a gate valve for the RHR pump flow control valve and the correction
.a problem relating to pump vibration for the RHR pump impeller.
work was found to have been performed effectively and in a controlled manner.
Modification Mo discrepancies were identified.
was_the system material condition. Also inspected during the train 'B' walkdown.
With the exception of some pipitig insula-tion awaiting instaliation, the material condition of train 'B' was acceptable and the system appeared ready _ to be returned to service.
5.
Containment Inteorated Leakage Rate Test From November 19 to November 22, 1989, ment Integrated Leakage Rate Test (CILRT) for the Unit 1 Containment a quired by 10 CFR 50, Appendix J.
The test was performed in accordance with station procedure number EX 1803.001, grated -Leak Rate Test - Type A",
Revision 01, " Reactor Containment Inte-spect5r and a resident inspector. The test was observed by a region-based in-The inspectors reviewed the test procedure,
- witnessed preparations for test, and observed various portions of the test.
Other documents reviewed include the C1LRT test log, instrument calibration j'
records, piping and instrument drawings and test results.
Pre-Test Setuo identified.in station e ocedure EXThe inspector verified, on a sampling ba 1803.001, Rev. 01. A drain valve,1-FP-V-0922, at containment penetration X-38 was found not to be closed, which is the required-test position. This valve also had 2 test tags on it instead of 1.
- When informed of this situation, the licensee investigated the cause of the L
discrepancy and then properly aligned and tagged the valve for the test.
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penetrations walked down were found to be in the required configuration.
Other The ' inspector-reviewed and found acceptable the results of station proce-
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L dure EX. 1803.004, Rev. 00, " Containment and Containment Enclosure Surface In-L spection," which was used to perform the inspection of the :entainment internal and' external surfaces in accordance with 10 CFR 50 Appencix J (V.A.).
q Instrumentation The inspector reviewed the calibration records for the resistance tempera-ture detectors (RTDs), dew cells, pressure detectors and mass flowmeters' used L
for the test.
The instruments' calibrations met the accuracy and time require-fl-
.ments of ANSI /ANS 56.8-1987 and wore traceable to the National Bureau of Stand-ards.
A total of 26 RTDs, 6 dew cells (with 6 back-ups), 2 pressure detectors and 1 mass flowmeter (with I backup) were used for the test.
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The. test data collection and analysis were as follows:.
The two pressure detectors indicated the containment pressure on the Data Logger at-the test center.
The 26 RTDs provided input into the data logger and the temperature read-ing of each RTD cotid be selected.
The dew cells (and_ backups if selectad) provided input into the data-log-
.ger through 2 " phys-chem" monitors.
The data logger transmitted all data to the CILRT test computer at the test center.
The computer continually monitored instrument readings, and analyzed and printed test data and calculations every 20 minutes.
No' unacceptable conditions were identified.
CILRT Chronolooy 11/19/89 1800 ILRT measurement system fully operable and ready.
11/20/89.0130-Began containm'ent pressurization.
1830 Test pressure reached, test boundary isolated'from-compressors (51 psig).
1843 Began stabilization period.
2343 Temperature stabilization ~ criteria met.
2343 Began ILRT (50.39 psig).
11/21/89 0625 Test terminated because of valve leakage.
~0643
. Test restarted.
11/22/89 0643-ILRT ended (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration),
i 0823' Stand. verification flow. test.
Imposed flowrate of 12.22 scfm (0.15%/ day).
L 1223 Verification flow completed.
1223 Test completed.
L 1829 f tart depressurization.
L 11/22/89 0845-Exit interview held.
11/23/89 1514 Containment depressurized.
l Test performance and Control Tours were made by the inspector before and during the CILRT to ensure that test activities were being conducted in accordance with the test procedure o
and within regulatory requirements. Test boundaries were surveyed for evider.ce I
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_ of leakage and proper valve positions.
The inspector observed that the licen-i see'.s quality control group was monitoring the test and keeping abreast of
-situations.
During a walkdown of test boundari:rs with test arsonnel, a major leak was identified at penetration X-36 through vent valve RW-V-94.
This leak was de-termined to be coming through containment isolation valve PMW-V-30.
The lican-see evaluated the leak and elected to re minate the test, isolate the leak, and re-start the test.
The inspector verified that this was acccmplished within the scope of the station's procedure.
The inspector independently examined the penetration-area and then reviewed the last local Leak Rate Test results of the leaking containment isciation valve (RMW-V-30).
(Sca Findings paragraph be-low.)
CILRT Results The containment successfully passed the "As-left" Integrated Leak Rate Test, demonstrating :entainment acceptability for power operation. The calcu-t lated leak rate using the " Mass Point Analysis" method was 0.0545 wt %/ day (0.75 La is 0.1125 wt %/ day).
The "As Found" It ak rate was indeterminate as described below.
Findings
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The containment leak rate met the acceptance criteria for power operation -
in the "As-lef t" condition.
The "As-found*; condition is still indeterminate because of a need to add in subsequent LLRT data for RMW-V-30._ The implica-tions of these results were discussed with the licensee and the inspector con-firmed that they were understood by the licensee.
The test was performed with-in the-guidelines of the procedure. All test personnel interviewed were know1-edgeable and-competent to perform the:r duties.
The licensee's cuality control organization monitored on going testing A review of the previou: Type C test results of containment isolation valve R W -V-30 showed "As-tound". leakage as "ur,'letermined" and "As-left" leakage of 5.54 scfh (after repairs).
Since the problems with leakage of valve RMW-V-30 appar to be recurrent and have not been corrected by prior repairs, a root cause evaluation and determination of proper corrective action, beyond another val te repair, are warranted to ensure effective resolution.
"As-found" leakage implications will be further assesst;d during routine review of the CILRT report.
il 6.
Jnett ation-and Testing of Design Modifications The inspector reviewed the documentation for and observed portions of the installation and testing of design coordination request (DCR)86-481. ~ This design change provides & high speed, automatic, static transfer swi,tch between
. inverters UPS-I-1E and IF and their respective maintenance supplied. The r
switch allows for uninterruptible transfer of power to vital insfrument buses 1E and 1F,'frein inverter to maintenance supply and vice versa.,
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'The uninterruptible power supplies-(UPS) for buses 1E and IF are the nor-mal sources of' power to the distribution panels that make up each bus.
Each UPS unit consists of two major components: an AC-to-0C rectifier type power i
supply that converts 480 VAC power to 125 VOC and a DC-to-AC inverter that changes the 125 VDC to 120 VAC.
On a loss of the 480 VAC supply or a failure of the rectifier, _ backup 125 VOC power is supplied to the inverter by the vital DC distribution system.
If the UPS is not operational or malfunctions, the static transfer switch was to be installed to provide an alternate source of 120 VAC power.
This power-is supplied by a motor control center powered from the same emergency bus'as the UpS, through a stepdown transformer and the static transfer switch to the power panel.
The switch automatically selects between the inverter output or the alternate power source, whichever is most.
reliable. Once shif ted to the alternate power source, the switch will auto-matically shift back to the inverter output when the UPS is functioning pro-perly. The transfer _ switch can also be controlled manually using control push-buttons located on the switch.
E Prior to inspecting the installation, the inspector reviewed the docuna-l' tation.in the DCR package. This included the technical rtquirements and spect-fications for the UPS from the vender, the Elgar Corporation, the licensee's engineering evaluation, the OCR implementa;. ion plan, and tha DCR functional test requirements.
Also reviewed as part of the DCR package was the 10 CFR Sr.E9 safety evaluation. DCR documentation was extensive and complete.
The it nallation and test procedures w'ere clear and thorough in their precautions and directions.
The installation of the static transfer' switch involved mounting the switch, running additional conduit and cable from the vital instrument power panel to the transfer switch, and from the switch to the inverter, and UPS in-
- ternal wiring modifications. The modifications were all centained within the essential switchgear room. Over a four day period, the inspector observed the completion of the UPS-I-IF static transfer switch installation and portions of the functional testing of the switch.
The inspector noted that, during the installation and testing, the licensee maintained an adequate staff in the
.switchnear room to accomplish all work in a safe manner.
As a minimum, an electrician, a work group supervisor, the system engineer and a quality control.
supervisor were present.
The inspector inspected the modifications made to the IF vital instrument power panel and to the IF UPS cabinet and was satisfied that all work had been performed in an acceptable manner.
The testing portion of the DCR was intended to demonstrate operability of both the UPS and the newly installed transfer switch by a performance test.
The test included loaded transfers of the static switch and UPS, as well as the placement of intentional grounds on the 480 VAC bus and the 125 VDC bus feeding the UPS. The plac~aent of the grounds verified that the static switch /UPS out-put was not interrupted as a result of grounding. Through direct observation of the testing, the inspector determined that the tests were conducted in a controlled and rafe manner. Proper barriers were placed around the work area ant access to the switch gear room was controlled. Communications were estab-115hed with the control room, and the DCR test procedures were rigorously fol-lowed. At one point during the testing, the system engineer had a question 1
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16 concerning a procedure step. Af ter discussing the matter with the shift super-
'intendent, the conservative decision was made to convene a Station Operation Review Committee (50RC) to resolve the question rather than take the chance of changing or violating the procedure.
The inspector identified no inadequacies in the licensee implementation of thi s ON 'or UPS-I-IF.
DCR implementation for UPS-I-1E is scheduled to be per-
't formed. < conjunction with the required ' A' train elec^.ri:al system outage.
7.
Quality Assurance / Corrective Action Activities 7.1 Lew Power Test Prooram Audit As discussed in NRC Region I Inspection Report 50-443/88-12, inspectors noted that the licensee QA-department had not formulated any plans for provid-ing a. level II oversight review of the facility's proposed startup test pro-gram. As a result of this NRC concern, the licensee committed to performing a test surveillance program during low power tests.
NHY OA Audit Report No.
89-A-05-05, " Low Power Test Program," dated August 15, 1989, summarizes the results-of an audit designed to evaluate the licensee's, compliance and imple-mentation of the Low.aower Testing Program.
The inspector reviewed the OA audit report.
The report fulfills the com-mitment made by the licensee documented in Inspection Report 50-443/88-12.
The audit provided broad coverage including review of control room activities and-administrative controls associated with mode changes, housekeeping, chemistry, health physics and security. The multidisciplined team conducted the audits over a two month period and identified no deficiencies.
However, the audit i
report did provide recommendations to enhance program performance. The inspec-tor concluded that an adequate audit of the Low Power Test Program was con-ducted.
7.2 Corrective Action Plan Review Item 1.C-1: revise policy on control room access to establish the maximum l
- number of personnel allowed in the control room and the horseshoe area of-the p
control room.
Operations Management Manual (OPMM) Revision 18 included changes to Chap-E ter 3, Shift Operations, regarding-control room manning and access. Subsection l
1.F, Watch Station Conduct, has been revised to indicate that additional opera-tors may be assigned to perform specific functions during complex evolutions.
It-further specifies that each operator be informed of the presence of addi-tional personnel and be made aware of their function and limits.
The revision also requires that access be limited to persons with official business or man-agement authorized activities.
The authority and responsibility for controlling access is assigned to the control room commander (defined elsewhere in the OPMM).
Examples of persons
- with official business in the control room are given. Additionally, require-ments on Special Testing Activities and termination of those activities, along 1
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with provisions for handling observers and visitors, are specified. Specific numerical limits for observers and visitors have been established. These nuar-bers may only be exceeded with written authorization of the Operations Manager, who will specify by name personnel permitted. access as observers and visitors for a specific activity. Authority and responsibility for controlling access to the horseshoe or " sacred" area is assigned to the senior on-shif t operator.
The inspector' reviewed Revision 23 to the OPMM, dated November 10, 1989 and.
confirmed that the requirements have been carried over in subsequent revisions.
2.A-6: review the event evaluation procedure to determine if enhancements are required concerning the post-trip review, assignment of personnel, post-trip critiques and written chronologies.
The inspector reviewed Revision 2 to New Hampshire Yankee Procedure 12830, Event Evaluation and Reduction Program.
The procedure has been strengthened.
It now clearly states, as a requirement, that personnel are to receive training in the evaluation program prior to being called upon to perform an evaluation.
The most significant improvement is the requirement to perform a critique for any event on site.
This criticue is to be. conducted with all personnel who participated in or witnessed the event.
This critique is to be conducted prior.
to releasing personnel from the site.
The critique includes written descrip-tions of the event by all involved personnel and the generation of a synopsis and chronology by the Event Team Leader.
This will ensure that the information-l 15 gathered and collated while it is still fresh in the minds of the partici-pants.
Based upon the licensee's implementation of actions to address the control room access / work control and event evaluation concerns raised in Correction Action Plan items.1.C-1 and 2. A-6, no additional NRC inspection effort of this o
L issue is required.
Routine inspection of control room activities and the event analysis and evaluation process in the future will monitor the effectiveness of these corrective measures.
8.
Follow-vo of Licensee Reoorts and Ooen Items 8.I'_ Licensee Event Rcoorts (LERs)
(Closed) LER No.89-009, Technical Specification Surveillance Not Properly Performed and LER No.89-013, Noncompliance with Technical Specification Action Requirements.
Both of these LERs involved a. violation of technical specifica--
tion action statements caused by separate personnel errors.. In the first case, a chemistry. technician incorrectly performed the analysis of an affluent sample taken from the primary component cooling water (PCCW) head tank. SincelLhe PCCW head tank rate of change alarm was out of service, sampling was required every twelve hours by a technical specification 3.3.3.9 action statement. Cor-rectly analyzed samples taken before and after the subject sample indicated n9 L
actual activity problems,' but the time duration between these valid samples L
exceeded the allowable technical specification duration.
Hence, the violation was. reported as a. licensee event under 10 CFR 50.73.
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In the second case, a portable monitor, installed to meet the action statement of technical specification 3.3.3.1 with the containment post-LOCA monitor out of service, was mistakenly unplugged for approximately five hours.
~The HP technician who unplugged the monitor to use the electrical receptacle for another purpose was not familiar with the technical. specification require-ments or: aware of the consequences of unplugging the portable monitor.
In both cases, the technicians involved were counseled,. additional train-
-e ing was conducted within the departments, and procedures were reviewed to en-sure accuracy and clarity of directions provided to-the technicians performing the work. A-caution as to the consequences of unplugging energized equipment within the plant was also discussed in a station newsletter disseminated throughout the site and caution tag usage for electrical power cords was in-corporated into health physics procedures for portable equipment.
The inspector reviewed the LERs and the licensee corrective action and determined:that the discretionary criteria of 10 CFR 2, Appendix C, section JV.G.1 have been satisfied.
Based upon licensee identification, reporting and initiation' of ccmorehensive corrective measures with respect to both of these examples of noncompliance with technical specification requirements and also in consideration-of the minimal safety significance.of the actual events, these violations are not being cited.
Non-cited violation number 89-13-02 documents identification of this issue, whic,h is hereby closed.
8.2 10 CFR 21 Reoort (Closed) 10 CFR Part 21 Report No. 89-00-01:
Potential Failure of Rose-L mount Transmitters.
As-discussed in NRC Region I Inspection Report 50-443/
L 89-01, a potential defect involving the loss of oil in the transmitter sensing h
-module was identified by Rosemount, Inc., for certain transmitters manufactured prior.to' July, 1989.
The licensee's review has found 61 of the subject Rose-mount Model 1153 and 1154 transmitters installed at Seabrook.
Since the problem with potential oil loss occurs slowly over time, the licensee's corrective action plan includes a special calibration program, transmitter performance trending, and replacement of the pressurizer pressure
-transmittars and any spare Rosemount transmitters in stock on a schedule which is consistent with the support of station activities. The inspector verified that all the subject transmitters had been or were bein which would check for any degradation due to oil-loss. g calibrated in a manner
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The. inspector also re-L viewed the Rosemount 10 CFR_21: notification, dated February 7,1989, and evalu-ated the licensee's plan for addressing the stated concerns, based upon Rose-mount's discussion of how th'e transmitters would exhibit reduced performance.
It was also noted that testing by Rosemount, Inc. was conducted to determine limits in the performance degradation and methods in the detection of affected transmitters.
The inspector confirmed that the licensee has reviewed and evaluated all of the latest relevant Technical Bulletin and report information from Rosemount,- Inc., on this potential problem.
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19 The inspector determined that licensee response and corrective action planning for this Rosemount Part 21 report to be both timely and comprehensive.
i Given the slowly developing nature of the potential problem, the licensee's.
t monitoring program was assessed as adequate. Quarterly channel checks, over-
't range tests and_ normal calibratiens of the subject transmitters should indicate performance degradation prior to component failure.
Special calibrations, re-cently accomplished, provide adequate indication of transmitter acceptability and a baseline for future performance.
The inspector considers Itcensee meas-1 ures to address this vendor identified _ problem to be extensive and conducive to the identification of any actual hardware problems in the future.
10 CFR 21 Report No. 89-00-01 is closed.
8.3 Licensee Action on Previously identified Items S
.t (Closed) Unresolved item 89-08-01: Unmonitored Release from the Turbine I
Building Sump.
The inspector reviewed the licensee analysis of technical specification action statement requirements relative to Station Information Report SIR 89-042. The spect fic incident involving bypass of the turbine building-sump radiation monitor was evaluated from both design basis and con-trol adequacy standpoints. While it was determined that the turbine building sump was not intended to be dedicated solely to processing radioactive efflu-ents, the program used to control temporary sump pump usage and coordinate ac-tion statement status requirements with control room operators required in-provement. A procedure for the installation of temporary pumps was issued on October 5,1989 to delineate the necessary administrative controls and coordi-nation requirements. The use of Temporary Pump Regaest forms was formalized.
The inspector reviewed station operating procedure UN0599.047 governing temporary pump controls and checked other operating procedures affected by its issuance. Temporary Pump Requests were spot-checked, both in process in the control room and in their final documented closeout-format.
Technical specifi-cation action statement coordination and clearance were noted to be properly controlled for the times the temporary turbine building sump pump was
~c installed. The inspector also determined that the program of controls estab-lished by the licensee to address the original problem was broad enough in scope to adequately cover all temporary pump usage within.the protected area.
Licen:ce controls in this area have been strengthened and procedural com.
pliace with the new program of controls was checked by the inspector. The inspector identified no concerns with the licensee's current program for in-stalling-temporary pumps within the station and no specific problems were found with the use of the temporary turbine building sump pump.
This unresolved item.
1s closed.
(
(Closed) Unresolved item 89-09-03: Failure to Perform Technical Specif1-cation Surveillances. The inspector reviewed the licensee's reportability de-termination for SIR 89-061, in which it was documented that certain radioactive liquid effluent and gaseous effluent monitoring instrumentation surveillances O
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-had _not been performed in the time intervals required by the technical spect-l fications. Although repetitive task sheets (RTS) had been issued to conduct monthly source checks of'the subject radiation monitors, these surveillance activities are redundant to the automatic source check accomplished by the monitors on a daily basis. This daily source check is logged into the plant computer and an alarm would be generated if the check were not completed.
The inspector discussed the automatic source check feature of the radt-ation monitors with licensee personnel, verifying that failure of the check would alarm similar to a monitor failure.- In. fact, the monthly RTS work re-quirements actually use the daily source check feature in the performance of the technical specification surveillance activities.
The inspector also spot-checked the computer logging history for certain radiation monitors to confirm evidence and documentation of daily instrument source checks.
Based upon the fact that the internal source check design ' feature of the radiation monitors provides compliance with surveillance requirements, the lic-ensee's failure _ to complete the RTS activities represents neither a technical specification noncompliance nor a reportable event.
This issue is therefore resolved and closed.
However, as discussed in section 8.1 of this inspection report, a non-i cited violation resulted from personnel errors leading to noncompliances with tschnical-specification action requirements. While no noncompliance resulted from the failure to perform the radiation monitor RTS surveillance discussed in
- this section, the cause of the failure to perform a scheduled RTS activity 1 should be analyzed by the licensee in the same vein as the personnel errors 1
- resulting in the-non-cited violation.
9.
Physical Security plan Implementation and Controls 1
Protected Area Barrier On November 7,1989, NRC on-site review of the protected area barrier (PAB) identified a need to upgrade the PAB between Unit I and Unit 2 to meet l
the criteria for a. permanent PAB for Unit 1.
Existing compensatory measures L
were found adequate. On November 8,1989, the following exceptions relative to NRC criteria for a PAB were identified to the licensee.
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THIS PAGE CONTAINS SAFEGUARDS INFORMATION
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AND IS NOT FOR PUBLIC'0!SCLO50RE.
IT 15 INTENTIONALLY LEFT BLANK.
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22 Following a discussion of the above concerns, the licensee committed:to t
submit, within 10 working days, a schedule for completing an engineering study to resolve the concerns, and a revision to the Plan to update the Plan and in-corporate additional compensatory measures. The licensee also committed to
- provide a schedule for_ implementation of the separation barrier upgrades upon completion of the engineering study. The engineering study would also inves-tigate the possible existence of-additional separation barrier weaknesses, other than those discussed above, and address their resolution.
- 10. Management Meetinos At' periodic ' intervals during the course of this ' inspection, meetings were-held with _ licensee personnel to discuss the scope and findings of this inspec-tion. An exit meeting was conducted on December 12, 1989, to utscuss the in-spection findings during the period.
During this inspection, the NRC inspector-received no comments from the licensee that any of their inspection items or t
issues-contained proprietary information. No written material was provided to the licensee,during this inspection.
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.i 08/a6290" 88i32
'NRC RI DOCKET ROOM NO 167-
'P033/0&S l
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JAN 0 8 ING l
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Docket No. 50-443 I
PublicServiceCompanyofNewHampshtrj ATTNr Mr. Edward A. Brown. President ;
I and~ Chief Executive Officer New Hampshire Yankee Division ~
Post Office Box 300 Seabrook, New Nampshire 03874 Gentlemen:
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Subject:
Inspection Report No. 50-4.'.3/89-15 This refers to the special licensed operator proficiency evaluati n. inspection-corducted by-Mr. L. Briggs of this office on November 27 through ecember 1, 1989. Also discussed in this report are the results of the Decem er 14 and.15, 19S9 inspection of your corrective ac; tons taken to: address certa n Corrective-Action Plan items which resulted from the June 23,1989 Confimat ry Action Letter, 89-11.
Both portions of the inspection were conducted at the simulator training facility, Seabrook, New Nampshire. Mr. Briggs discussed the results of this.special inspection with Messrs. D. Moody-ane B. Drawbridge a d others of-your staff-on December 1 and 15, respectively.-
l Areas examined during this inspection are described < in the NRC Re ion I'Inspec-
. tion Report which is enclosed with this letter. Within these are s, the in-spection consisted of selective examinitions of-procedures and re resentative records, interviews with personnel, and observation;of all six op rating-crews performing simulator scenario exercise, develooed by the NRC di;ri g the operator proffciency evaluation.
I We have concluded that all six crews demonstrated at sattsfactory evel of performance during the operator proficiency evaluation.
Within the scope of this inspection, no violations w{ ere observed.
i I
No reply to this letter is required.
Your cooperation with us in this matter is appreciated.
i
- Sincerely, M
8 M 31 scad hr:
l Robert M. Gallo, Chief l Operations Branch
,' Division of Reactor Safet i
Enclosure:
NRC Region I Inspection Ra' ort No. 50-443/89-15 p
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Oa/85/90' 38:33 NRC RI DOOKET ROOM NO.16?
P033/0aa I
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R Pubite Service Company of New Hampshire 2 I
cc w/ enc 1:
J. C. Duffett, President and Chief Exa'cutive Officer, P5NH T. C. Feigenbaum, Senior Vice President and Chief Operating Offic tr, NNY J. M. Peschel, Operational. Programs Manager, NHY D. E. Moody, Station Manager NHY T. Harpster, Director of Licensing Services R. Hallisey, Director, Dept. of Public Health, Commonwealth of Ma ssachusetts S. Woodhouse, Legislative Assistant Public Document Room (POR)
Local Public Document Room (LPOR)
Nuclear Safety Infomation Center (NSIC) 4 NRC Resident Inspector State of New Hampshire, SLO Commonwealth of Massachusetts, SLO Designee i.
Seabrook Hearing Service List
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i bec w/ encl:
j Region I Docket Room (with concurrerens)
T. Martin, ORA M. Hodges, DRS E. McCabe, DRP J. Johnson, ORP.
SRI - Seabrook (w/ concurrences)
V.--Nerses, NRR _
K. Abraham, PA0 (20) SALP Reports ar.c :All Inspection Reports l
P. Eselgreth,' ORS E
L. Brigg, DRS
- 0. Silk,-ORS L. Sherfey, PNL DRS Files (3) bec w/o enc 1:
-Hanagement Assistant, ORMA f
i DRS:RkT ORS:RI DR :RI O :R 0 1RI Briggs /dmg/ajk Eselgro6 Gal' Johnston Hodge s M rt):
01/c /90 01/jL /90 01/) /90 01/y/90 01/$ /90 01/f /90 b
RA: RI Russell 01/{/90 0FFICIAL RECORD COPY BRIGGS /SEABROOK 50-< 43/89 0001.0.1 01/02/90 I
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01/10/50l 10 33.
NRC RI DOCKET ROOM NO.16?
P024/01%
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U.S. NUCLEAR REG'JMTORY comis510N l
REGION !
i Report No.:
50-443/89-15 i
License No. :
NPF-67 q
PublicServiceCompanyofNewHampshi Licensee:
as 2000 Elm Street Manchester, New Hampshfr) 03105 Facility:
Seabrook Station, Unit 1; Location:
Seabrook, New Hampshire i Dates:
November 27 - Decenber 1.and December 14 and 15, 19 9
Inspectors:
L. Briggs, Sr. Operations Engineer
-D. Silk,Sr. Operations (ngineer l
R. Temps, Resident Inspector l
L. Sherfey, PNL Examino,*l Subtritted by:
ec-.2
//
C L. Brty, Sr. Operspratn Engineer D< te Approved By:
6-t 0
P. Eselgroth Chief. N4 5ection.
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Operations Branch, Division of Reactor Safety
-i INSPECTION'5UMMARY The November 27 through December 1 inspection was a special announ<ed inspec-tion which assessed the Seabrook Unit 1 operator proficiency and ule of fact-lity procedures, primarily the Emergency Operating Procedures (EOP:, during emergency situations-and transients.. This inspection evaluated th< performance of the on-shift operating crews using NR0 developed scenarios on tl e Seabrook, plant specific simulator.
i No violations or deviations were identitied. All sit operating cr<ws demon-strated satisfactory performance on the simulator scenaries.
The Do: ember 14 and 15 inspection reviewed and closed five items f1 on the Corrective Action Plan.
Details of the review are contained in Seition 4.0 of this report.
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01/16/90
.1603-NRC RI DOCKET ROOM NO.167 P027/011' 1
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3.1 CONCLUSION
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The NRC Operating. Crew Perfor'mance Evaluation Team detsi nined that
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the performance of all six (6) Operating Crews satisfaci brily met the rating factors and acceptance criteria of Attachment 1.
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The team did note some specific operational program area n that could a
1 be strengthened to further enhance the operating crews y trformance.
Each area is discussed below.
1.
COMMUNICATIONS The inspection team noted that the level of detail of the commu-l-
'nications varied from crew to crew and even within
- Pews between the different crew members.
In particular the feetsack fret some crew members in response to directicas given t / the USS during E0P performance was not formal' and standardi tod. The
- team determined that overall communicaticas were sa Lisfactory, but could be improvec by! additional training emphas is on stand-ardization and formalization.
The licensee stated that, a Standard herk Practices focument addressing communications was in draft and would be issued and fully implemented by June 1,1990.
In the interim period, cation cycle which will nddress all c;rews within tri next six communications will be enphasized'during the currer L requalifi-
-e (6) wooks.
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STANDARDIZATION OF CREV OPERATING pRACTICIS Ouring: the team evaluatihn the NRC observed minor c lfferences in eperations conununications and shift turnover practi:ss between.
the various operating cr'ws. Although the facilit) has a: shift t
turnover procedure, the varicus crews implemented 1; to dif forent i
degrees prior to the start of the sce,narios.
Sone examples of differences observed durling crew turnover and sinul Ltor operations-were:
1 Theformalityanddhtailofcre briefings dur Ing shift turnover for the simulator scenarios was not 4 >nsistent between operating :Fews.
1 Annunciator testing although not required by
>rocedure, was performed by most crews when assuming the Limulater shift; however, some crews did not.
The -level of detail! of communica)tions varied t etween operating crews (addressed above).
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The team noted that, althcugh!the above differences were slight and did not significantly impact crew performarce during the simulator scenarios, a stronger emphasis on standard servetofurtherenhancecrew: performance.jzationofopeationswould I
The licenses stated that the identified differenras will be addressed during the current cycle of requalification training, i
a 4.0 CORRECTIVE ACTION Pl.AN REVIEW In response to the events of June 22, 1989, Regjon ! issued C1 nfirmatcry i
Action 1.etter 89 1] on June 23, 1989. Subsequently Wow Hampsl tre Yankee (NHY) developed a Corrective Action Plan (CAP) 4ddressing spot ific action items. The CAP was submitted to the NRC on July 12. 1989 witl additional CAP-information on August 25, 1989. The following CAP items, using the NHY's alpha-numeric designators, were reviewed to ensure that corrective actions tekwn by NHY Lu address identtfied weaknesses were adt quate to g
correct the problem.
Following each item is a discussion of I RC findings for that item.
Item 1.A-11. Enhance the Licensed Operater! Training Prog 1 as to in-clude simulator training which challenges the operators )ith regard i
to following procedures.
The licensee developed a list of procedure compliance re'sted ques-tions that was used as discussion and trai ing toples in the current operator requalification training phase that began-on Oci ober 10, i
1989.
Also, all operators and instructors,d of January l p90, all have attended srocedural compliance training. classes.
Before the en J
operating crews.will have uncargene a week'of training wt ich will include classroom and simulator-training on 13 of the moi e complex
. Power Ascension Testa and the Corrective Action Letter (t LL) items addressing the June 22 Natural Circulation! Test.
Classrcsm training
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is conducted in the morning, followed by simulator train 1 ng in the afternoon (as of December 15,J1989 two of six crews had c ompleted thistraining). $1mulator scenarios incorporating power tscension tests were used by the licensee to train and evaluate the operators regarding procedural compliance. The licerisee esed crita ria'similar to that of the examiner standards, NUREG-1021. to evaluai s crew per -
formance. The NRC observed the two crews in.four scenar1as that challenged procedural compliance.- The NRC l determined the L the crews performed satisfactorily. during the simulator-scenaries'< sserved.
f Ites 1.C-2, Revise the Startup Test PrograN to require tt it a com-prehensive pretest briefing be provided prior to the erst assuming the shif t to ensure that the crew understarids the test ci!teria, expected parameters and required actions.
The Startup Test Program Description was ed,nverted to tht Power
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I6 Ascension Test Program (PATF) and was approved as Statlos Management Manual (SSMM) Procedure SM 8.1'.
Section 4.-2.2 of SM 8.1 states that -
a pretest briefing will be cenducted to ensure that the e icoming crew of test engineers and operations personnel! understands tfI test criteria, expected parameters, and required actions prici to operations personnel. assuming the shift.
Individual duties and res; snsibilities are to be reviewed and abnormal plant conditions or -systa n configura-
. tions to be encountered during the test' are to be discuss pd.
Figure 5.3 of SM 8.1, PRETEST BRIEFING COCUMENT GUIDEL]NESc proi(des direc-tions on how to conduct the briefing. The four pretest tFiefings observed by the NRC during.the simulator scenarios on Deckmber ll, 1989 were extensive and detailed with good interface bett pen-the test engineers and operations personnel.
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l' Item 1.C-3, Revise the Startup Test Program to require ttit additional preparation, including simulater rehearsals when feasibla, be given to b
test crews assigned to perferm complex-tests, l-Section4.4of'SM8.1statesthatspecific'licensedoperatorsand p
l test personnel will receive simulator-train'ing and/or ela isroom L'
training on. tests listed in section 4.4.
T; raining is to se conducted within three months of the actual performance of the tesi, The NRC 1
audited classroom training for ST-23, Dynamic Automatic 1 Leam Dump Control, and ST-19 Loss of Offsite Power Test.- The tra111ng was conducted by the Shift Test Director responsible for that test.- The training was thorough. with in:teraction.between the inst, actor and the participants to discuss details and' questions relatec to the tests. Simulator training was also satisfactorily conduc ted by-the operations and test personnel and observed by the-NRC, as discussed in Item 1.A-11 above.
Item 1.0-9.RevisetheOperatihnsMana'gemanhHanvalandtriPower l
Ascension Test program to clearly state tho' responsibiliiles of the L
Operations and Power Ascension Test personn'el to~ raise ar r issue that is not understood,:or to.stop an evolution 'if they do noi understand L
their responsibilities in the conduct of-the test.
Operations Management Manual.(DPMM) section' 1.1.1 and,SM l.1 section 3.0 states-the responsibilities of the operations-and tes ; personnel, respectively, to raise any issue that is not understood c a to step an-evolution;if'their responsibiljtfes in the ' conduct of the test are not understood. During the prutest briefings, the-NRC ot served good-interaction between the test engineers and" operations personnel. Any area that was not understood was fully disciussed until all personnel understood the pl~anned evolution.
Responsibilities of irtolved personnel were also discussed, with a clear, understanding prior to-assuming the shift that licensed operations personnel wer i in charge of plant activities and responsible for safe plant operailon. During each of the scenarios observed by the NRC the operations tnd test 4
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personnel were challenged with procedural i:cepliance or est result
~ validity problems induced by simulated equipment failure or plant anomalies.
During each scenario the test and gerations personnel discussed the issue and either interrupted!or terminated the test as appropriate for the plant conditions.
. Item 2.B-3,RevisetheOperationsManagemektManualto:
) Clarify the integration of Startup Test personnel with the shift operating crew; 2) Clarify responsibility and authority den suppl mental operators'are assigned to a shift; 3) Encourage ncn-shif licensed Ocerations personnel to provide a point ofl clarification or informa-tion when an assigned operator's actions a ppear to be in,ppropriate or are not under. stood by the observer; 4) tequ11re the Op rations Management licensed personnel'to define their msponsibt ities when l
they enter the horseshoe area of the Control Room during testing.
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OpMM section 1.1.3, Tes-Group Responsibilities. cefines the integra-tions of test engineers personnel with operations person 1lal including coordination of anc recormendations regarding plant cond tions.
Section 1.7.1, number 5., clarifies the respont,ibilities of additional operators assigned to perfo m:various control mom activ ties such as E,
reactor startup,- or feedwatar control. Section 1.6.2 enc
'urages input.
from operations personnel ooserving the test if an apparrnt abnormal condition arises.
In a Nevanter 10, 1989 memomncum, th t Executive Director of Nuclear Production stated company policy reg rding manage-ment personnel responsibilities in the control rocm " hor,eshoe area,8 such as being knowledgeable of' the safety and operationa limits'of 4 l
special evolution or, when iris not possible te be fami iar with an L
evolution, to inform the US3 cr the 55 that they are cbs'rvers; and if inside the control room, but outside the " horseshoe a ea," the-managers are,to be considersd'as observers'.
$Lrict form lity was-practiced when entry was made into the " horseshoe area" if the simu-lator control room with esca person stating the purpose if entry prior to being allcwed initial access.
During each seen rio the OPMM was properly implemented.
4.1 CONCLUSION
NRC review of the changes to the OPMM dischssed above,1 idicates that changes were appropriate and address the concerms of the CAL.
In addition ~, the NRC noted that test engineers and the oper itions staff functioned well as a team during simulator scenario perf irmance'and freely exchanged information during both the scenarios a ld the pretest briefings, i
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$.0 EXIT MEETINGS Anexitmeetingwasconductedon04 camber 2,19h9,at-thetra ning complex with the licensee representatives noted in Para 9raph 1.0 of.ti is report.
The inspection scope and findings as detailed in this report t are summari-2ed-at the meeting.
1 AsecondexitmeetingwasconductedonDecember!15,1989,ini hich the NRC informed the licensee that five of the Corrective Action'l lan items were considered closed.
J At no time during the inspection was written manorial concern' ng inspec-tion results or determinations provided to the licensee by the inspectors.
This report does not contain any information subject to 10 CFI 2.790 restrictions.
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NUCLEAR RE*ULATORY COMMISSION '
-d e-REQlON 1
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' 478 ALLENDALE ROAD
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KING OF PRUSSIA. PENNSYLVANIA 194o6.
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' Docket'No.-50-443 M 0IE Public Se'rvice Company of New Hampshire ATTN: Mr. Edward A. Brown President and Chief Executive Officer
.New Hampshire Yankee Division i
L Post Office Box 300 Seabrook, New Hampshire 03874 3
Gentlemen:
Subject:
NRC Region I Inspection Report No.
50-443/89-21 Thi's refers to the above subject safety inspection at the Seabrook Station, Uniti No.-1, Seabrook, New Hampshire.
The results of the inspection are described in the enclosed report, and were discussed wjth Mr. O. Moody and other memeers of
.your staff at an extt meeting on January 5, 1990.
.This report documents acceptab'ility of certain issues relating to Confirmatory' Action. Letter CAL 89-11.
Review and' evaluation of the remaining issues'related
-to the CAL ~are.being performed separately..
No reply to this letter is required.
Thank you for iour cooperstion.
Sincerely, l
L m.12.
(bf on R. Jo nson, Chief
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Projects Branch No 3 Division of Reactor' Projects
Enclosure:
NRC Region;I Inspection Report No. 50-443/89-21~
cc w/ encl:
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l J. C. Duffett,'. President and Chief Executive Officer, PSNH T. C. Feigenbaum, Senior Vice President and Chief Operating Officer, NHY-J. M..Peschel, Operational Programs Manager, NHY 0 E, Moody, Station Manager, NHY,
T. Harpster, Director of. Licensing Services R. Hallisey,'Oirector, Dept. of Public Health, Commonwealth of Massachusetts-i l,,
- 5. Woodhouse,. Legislative Assistant Public Document. Room (POR) y Local Public Document Room (LPOR)
Nuclear Safety Information Center-(NSIC)
NRC Resident Inspector
~ State of New Hampshire, SLO
-Commonwealth of Massachusetts, SLO Designee Seabrook Hearing Service List i
4
ye I
- y SEABROOK HEARING SERVICE LIST 1
Public. Service Company of New Hampshire USNRC Resident Inspector ATTN:
Mr. Edward A. Brown, President Post Office Box 1149 and Chief Executive Officer Seabrook, New Hampshire 03874 Post Office Box.300 Seabrook, New Hampshire 03874 Public Service Company of New Hampshire Mr. T. Harpster ATTN:
Mr, John C. Duffett Public Service Company of President and Chief Executive New Hampshire Officer P.O. Box 300 P. O. Box 330 Seabrook,'New Hampshire 03874 1000 Elm Street Manchester, New Hampshire 03105 Mr. Donald E. Moody Mr. James M. Peschel Public Service Company of'New Hampshire Public Service Company of New Post-Office Box 300 Hampshire Seabrook, New Hampshire 03874 Post Office Box 300 Seabrook, New Hampshire 03874 Mr. Ted C. Feigenbaum Mr. R. Hallisey, Director
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Public Service Company of New Hampshire Dept. of Public Health Senior Vice President & Chief Operating
' Commonwealth of Masssachusetts Officer Radiation Control Program Post Office Sex 300 150.Tremont Street, 4th Floor Seabrook, New Hampshire 03874 Boston, MA 02111 Massachusetts Transportation E. Tupper Kinger, Esq.
LButiding
~ Assistant Attorney General ATTN: Sarah Woodhouse Of fice of Attorney General legislative Assistant 208 State House-Annex Ten-Park Plaza - Suite'3220 Concord, New Hampshire 03301 Boston, Massachusetts ~02116 Thomas Dignan, Esq Jerard A. Crouteau Constable John A. Ritscher, Esq.
82 Beach Road Ropes,and Gray P. O. Box 5501 225 Franklin Street Salisbury, Massachusetts 01950 Boston, Massachusetts 02110 Mr. Bruce Beckley, Project Manager Dr. Murray Tyo, President New Hampshire Yankee
-Sun Valley Association P.O. Box 330 209 Summer Street Manchester, New Hampshire 03105 Haverhill, Massachusetts 08139
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L' Seabrook Hearing Service list 2'
L Robert A. Backus,- Esq.
George D. Bisbee, Esq.
Backus, Meyer and Solomon Assistant Attorney General 116-Lowe11 Street Office of the Attorney General P. 0. Box 516 25 Capitol Street
~ Manchester, New Hampshire 03106 Concord, New Hampshire 03301 Phillip Ahren, Esq.
Diane Curran, Esq.
I Assistant Attorney General Harmon and Weiss Office of the Attorney General 2001 S. Street, N.W.
State Hvuse Station #6 Suite,430 i
Augusta, Maine 04333 Washington, D.C.
20009 Steven Olesky, Esq.
D. Pierre G. Cameron, Jr., Esq Office of the Attorney General General Counsel One Asburton Place Public Service Company of
- p. O. Box 330 New Hampshire s
. Boston Massachusetts 02108 Manchester, New Hampshire 03105 Ms. Diana P, Randall-Mr. Alfred V. Sargent, Chairman 70 Collins Street Board of Selectmen Seabrook, New Hampshire 03874 Town of Salisbury, MJ 01950 Richard Hampe, Esq.
Ms. Suzanne Breiseth
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New Ham;; shire CiYil Defense Agency Town of Hampton Falls 107 Pleasant Street Orinkwater Road Concord, New Hampshire 03874 Hampton Falls; New Hampshire 03844 Mr. Calvin A. Canney, City Manager Senator Gordon J. Humphrey City Hall ATTN:
Tom Burack 126 Daniel Street U.S. Senate Portsmouth, New Hampshire 03801 531 Hart Senate Office Building Washington, 0.C.
20510 Board of Selectmen Mr. Owen B. Ourgin, Chairman PFD' Dalton' Road Durham Board of Selectmen
-Brentwood, New Hampshire 03833 Town of Durham s
Durham,.New Hampshire 03824 Chairman, Board of Selectmen Rye Nuclear Intervention Committee Town--Hall c/o Rye Town Hall South Harroton,L New Hampshire : 03827 10 Central Road l
Rye, New Hampshire 03870 1
' Mn Angie Machiros, Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Comm.
for the-Town of Newbury 825 North Capitol Street, N.E.
25'High Rosd Room 8105 L
Newbury, Massachusetts 01950 Washington, D.C.
20426 l
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Seabrook Hearing Service ~ List 3
Ms. Rosemary,Cashman, Chairman Mr. R. Sweeney Board of Selectmen Town of Amesbury New Hampshire Yankee Division Town Hall Public Service Company of New Hampshire Amesbury, Massachusetts 01913 Suite 610, Three Metro Center Bethesda, Maryland 20814
' Honorable Peter J. Matthews Mayor,- City of Newburyport Administrative Judge Howard A. Wilber City Hall Atomic Safety and' Licensing Appeal Newburyport, Massachusetts 01950 Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555-Administrative Judge Alan S. Rosenthal, Chairman Administrative Judge Thomas S. Moore, Esq.
Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge Emmeth A. Luebke Jerry Harbour
. Atomic Safety and Licensing Coard Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. -20555 Washington, D.C.
20555 Edwin J. Reis, Esq.
H. Joseph-Flynn, Esq.
Office of the General Counsel Assistant General Counsel U.S. Nuclear Regulatory Commission Federal Emergency Management Agency Washington, 9.C.
20555 500 C. Street, S.W.
r Washington, D.C.
20472 Edward A. Thomas Carol S. Sneider, Esq.
Federal Emergency Management, Agency Assistant Attorney General 442 J. W. McCormack (POCH)
Office of the Attorney General Boston, Massachusetts 02109 One Ashburton Place,19th Floor Boston, Massachusetts 02108 Paul McEachern, Esq.
Richard A. Haaps, Esq Shaines and McEachern Haaps-and McNicholas 25 Maplewood Avenue 35 Pleasant Street
'Portsmouth, New Hampshire 03801 Concord, New Hampshire 03301 Board'of Selectmen Allen Lampert 10 Central Street Civil Defense Director Rye, New Hampshire 03870 Town of Brentwood 20 Franklin Street Exeter, New Hampshire 03833
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Seabrook Hearing Service List 4
William Armstrong Sandra Gavutis, Chairman Civil Defense Director' Board of Selectmen Town of Exeter RF0 #1,. Box 1154 10 Front Street Kensington, New Hampshire 03827 Exeter, New Hampshire 03833 Anne Goodman, Chairman Stanley W Knowles, Chairman Board of Selectmen-Board of Selectmen 13-15'Newmarket Road P. O. Box 710-Durham, New Hampshire 03824 North Hampton, New Hampshire 03862 Norman C. Kantner Judith H..Mitzner Superintendent of Schools School Administrative Unit No. 21 Silverglate, Gertner,- Baker, Fine, Good, and Mitzner Aluani Drive 88 Broad Street i
Hampton, New Hampshire 03842 Boston, Massachusetts 02110 Jane Doughty Gary W. Holmes, Esq.
Seacoast Anti-Pollution League Holmes and Ellis i
5 Market Street 47 Winnacunnet Road Portsmouth, New Hampshire 03801 Hampton, New Hampshire 03842 Mr. Robert Carrigg, Chairman Adjudicatory File i
L Board of Selectnlen Town Office Atomic Safety and Licensing Board l
Panel Docket Atlant Avenue 4
U.S. Nuclear Regulatory Commission LNorth Hampton, New Hampshire 03870 Washington, DC 20555 i
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U.S,' NUCLEAR REGULATORY COMMISSION
. REGION I Docket / Report No.:
50-443/89-21 License No.:
NPF-67 Licensee:
'Public Service Company of New Hampshire 1000 Elm Street Manchester, N.H. -03105 Facility:
Seabrook Station, Unit No. 1 Seabrook, New Hampshire Dates:
December 11, 1989 - January 5,1990 Inspectors:
A. Cerne, Senior Resident Inspector N. Dudley, Project Engineer J. Trapp, Senior Reactor Engineer R. Fuhrmeister, Resident Inspector S. Barr, Reactor Engineer J. Yerokun, Reactor Engineer Approved By:
& G. b M, b".
fl 9 I90 Ece C. McCace, Chief, Reactor.Projtets Section 38 Date-
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Areas'Insoected:
Corrective Action Plan Items, a TMI' Action Plan Item, an s
allegation, NRC Open Items, and security issues.
I Results:
Corrective Action Plan implementation was found to be appropriate.
NUREG 0737, Item II.B.2 was found to be adequately addressed.
The allegation was found to be without substance.
Two violations-were' closed.
Security com-
-pensatory measures were found to be properly implemented.
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d TABLE OF CONTENTS PAGE 1.0 Summary..............................................................
I 2.0 Confirmatory Action Letter Issues (92701)............................
1 3.0 TMI Action Plan Requirements (2515/65)...............................
7 4,0 Allegation RI-39-A-0146 on Procedure Inadequacies (71707)............
8 5.0 Licensee Action on Previous NRC Open Items (92702)...........
9 6.0 Security (81052).....................................................
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DETAILS 1.0 Summary This inspection-addressed issues raised in Confirmatory Action Letter 89-11.
It also reviewed other issues related to' readinessifor safe full power operation.
The inspection included review of documentation, obser-vation of work in progress, observation of training, and interviews.
Cor-rective Action Plan status (Section 2), TMI Action Plan status (Section-3), allegations (Section 4), previously issued NRC violations (Section'5),
and Site Security (Section 6) were inspected.
2.0 Confirmatory Action Letter Issues (92701)
In response to the problems associated with the June 22, 1989 Natural-Cir-culation Test, NRC' Region I issued Confirmatory Action Letter 89-11.
Sub-sequently, New Hampshire Yankee (NHY) developed a Corrective Action Plan (CAP) addressing 55 specific points.
The following paragraphs discuss NRC inspection of items from the CAP, using their corresponding alpha-numeric designations (e.g., 1,A-11).
a.
CAP Item 1.B-9: Expand the MODE change checklist process to allow it to be used to perform the-pre-test checklist for major system testing s
and integrated system testing.
Station Management Manual, SM 8.1, " Power Ascension Test Program,"
Form SM 8.1G, " Verification of Plant Material Condition," and Form SM 8.1H, " Outstanding Activity List," have been added to test procedures requiring " Specific Crew" training.
A prerequisi+e for these proce-dures will be to complete-these forms, which are essentially the same as those for mode changes.
Each manager of major support organiza-tions must review outstanding items and identify those whien may affect test performance. Activities identified are-tracked on Form SM B.IG and must be closed'prio~r to' test. performance.-
A second prerequisite for test procedures requiring " Specific Crew" training requires the Test Director and the Shift Superintendent to verify. that no open work requests on the systems / components identi-fied on the System Readiness List will affect the performance or re-sults of the test.
The administrative control for the System Readi-ness List is presently in draft form.
The inspector reviewed Startup Test procedures and verified that.the prerequisites required system readiness reviews. Test procedures, which did not require " Specific Crew" training, were also found to contain operability prerequisites for specific equipment required for test performance.
The inspector found the action taken by the lic-ensee to determine readiness of plant equipment, prior to power ascension testing, to be adequate.
This item is closed.
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b-CAP Item 1.C-2: Revise the Startup Test Program to require a more comprehensive pre-test briefing prior to a test crew going on. shift to ensure. that thr; crew understands the test criteria, expected para-meters, and required actions.
Station Management Manual SM 8.1, " Power Ascension Test -Program,"
section 4.2.2 requires a pre-test briefing for all oncoming test and operations personnel prior to the oncoming crew assuming the shift.
!a The briefing is to be conducted by the Test Director using the Pre.
test Briefing Document.
The Pretest Briefing Document is required to be written and sucmitted for'50RC coproval with the test procedure.
L Pretest Sriefing Document Guidelines are provided in SM 8.1, Figure-5.3.
The licensee has improved the training on conducting pre-tes* brief-ings by including pre-test briefings by the Test Directors as part of the simulator training.
The briefingt are then evaluated as is the rest of the training-on the simulator.
The inspector reviewed SM 8.1 with regard to pretest briefing re--
cuirements and observed briefings being conducted as part of simula-l ter training.
The inspector concluded that the licensee has taken aapropriate steps to assure quality pre test brief'ngs during the
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Power Ascension Program.
This item is' closed, c.
CAP Item 1 C-3: Revise the Startup Test Program to require that a;di-tional preparation, including simulator rehearsals when feasible, be given to test crews assigned to perform complex tests.
1 See Detail 2.d w ite-up on CAP Item 1.C-4 below.
This item is closed.
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CAP Item 1.C-4: Revise the Pcwer Ascension Test Program to require that test specific training be conducted wfsnin three months of the conduct of the test, o
Station Management Manual SM 8.1, " Power Ascension Test Program,"
section 4.4, " Training for Power Ascension Tests," describes training requirements for each power ascension test procedure.
Licensed Operators and Test Personnel-receive one week of training on power ascension test procedures.
SM 8.1 specifies that this training sha'l be conducted no more than three months prior to test performance.
Control of personnel training qualifications and records for power ascension tests are to be controlled in ST-1, "Startup Progran Ad-minfstration." Supplementary additional test specific training is to be provided, prior to test conduct, to individuals performing the more complex power ascension tests.
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-The inspector reviewed the: administrative changes made to the Power Ascension Test Program-and found the changes enhance the training-provided to the power ascension test personnel and to the licensed-optera tors.
Providing additional simulater training within three months of test conduct-is satisfactorily controlled by the procedures and is presently-being accomplished, l
This item is closed.
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CAP Item 1.0-1: Review the Startup Test Program and remaining start-u' p Test Procedures and revise as appropriate-to incorporate the guid-ance in the Station Management Manual and other applicable NHY manuals, and to ensure that the test procedure format and guidance are consistent with current Station Operating Procecure guidance.
The licensee has updated the-Startup iest Program and Startup Test Procedures to incorporate guidance in Station Management Manual.
NRC sampling cnecks found the test procedure format and guidance con-i sistent with Station Operating Procedure guidance.
The format of the test procedures reviewed was in accordance with
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Station Operating Procedure SM 6.2, Revision 9, which provides the standards for preparing, reviewing and approving station' operating and-special procedures.
Power Ascension Test Program-(PATP) procedure SM 8.1, Revision 0, contains guidance to ensure that test procedures are consistent with station operating procecures.
SMS.1 requires that test procedures for power ascension be _ reviewed and revised in accordance with pro-cedure SM 6.2.
The inspector (1) concluded that the licensee guidance provided in j
Procedures SM 8.1 and SM 6.2 was acceptable and (2) reviewed several l
power ascension test-procedures and found that they were in accord-ance-with SM 6,2.
This item is closed.
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. CAP Item 1.0-4: Revise the Startup Test Procedures which will be used i
for power ascension and similar_ testing to make them part of the Station Operating Procedure System.
i See Detail 2.e write-up on CAP Item 1.0-1 above.
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CAP Item 1.0-5: Establish a new Power Ascension Test organization which that will work closely with Operations and which has clearly defined responsibilities specifying who is responsible for all as-
-pects of the Power Ascension Test Program.
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The licensee has established a new Power Ascension Test' Organization.
Station Procedure SM 8.1., revision 0, was issued to outline the ad-
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ministration of the power Ascension Test Program. The inspector re-viewed SM 8,1 and found that it adequately outlines the responsibili-
' ties of the personnel involved with the PATP, The procedure provides directions on the Program's interface with operations and other de-partments within the station.
SM 8.1 exp1ains-the organizational setup of the PATP and the responsibilities of the various groups and i
members of the organization.
It also outlines the proper methods of-conducting tests, reviewing test results, training personnel for test performance, and writing test procedures.
The inspector witnessed implementation of the PATP procedure regarding personnel training.
Ongoing simulator training of test personnel was observed. This training. involved _the Program's management, Operations and Quality Control departments, and PATP test directors.
This item is closed, h.
CAP Item 1.0-8: Review the Power Ascension Test Program to ensure that the Power Ascension Test Program Manager provides frequent briefings to the Executive Director - Nuclear Production, Station Manager and Operations Manager on program status and upcoming evolu-tions to ensure management involvement.
The Power Ascension Test Pr 9 am ensures that the PATP Manager pro-vides frecuent briefings to tr,a Executive Director - Nuclear produc-tion, Station Manager and Operations Manager on program status and upcoming evolutions to ensure management involvement in the power
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Related instructions are provided in PATP Proce-dure SM 8,1, Revision O.
Section. 4.1.1 of the procedure describes the responsibilities of the program Manager and also specifies that the Manager will provide frequent briefings to associated personnel.
The inspector reviewed program Procedure SM 8.1 and found that it-adequately provides for keeping the licensee's. upper management-abreast of program situations.
This item is closed.
1.
CAP Item 1.0-10: Perform a safety evaluation of the Power Ascension Test Program procedures to verify that the conduct of the tests with-in the test parameters will not involve an unreviewed safety. ques-tion.
r To further assure that testing within the test parameters during the r
power Ascension Test Program will not involve an unreviewed safety question, the licensee is having Yankee Nuclear Services Division (YNS0) perform independent engineering reviews of all Power Ascension test procedures. After performing these reviews, YNSO transmits engineering evaluations to the Station.
The purpose of the reviews is to ensure that the procedures' test objectives will be achieved
5 and that Regulatory Guide 1.68 and the commitments of the FSAR will be met.. This review also evaluates the potential 'for unplanned trips -
n or ESFAS actuation.
The 10 CFR 50.59 applicability determination ~
developed by the station is also reviewed for concurrence or improve-ment. ~YNSD.then makes recommendations for improvements in the proce-dures, if any are deemed necessary. These-YNSD comments are reviewed and discussed at the station and incorporated into the procedures prior to Station Operations Review Committee (50RC) approval.
If a pr:cedure has already been 50RC approved, the procedure is revised (per Procedure SM 6.2).to incorporate YNPO's comments and taken through the SORC process again.
The inspector reviewed the engineering' evaluations of ST-22 (Natural Circulation Test) and ST-24 (Automatic Reactor Control),
These evaluations showed an in-depth technical review by YNSO.
This addi-tional and indenendent review and evaluation increases.the assurance that testing within test parameters will not involve an unreviewed i
safety question.
This item is closed, i
j.
CAP Item 2.A-7: Revise the Post-Trip Review Procedure and the Event Evaluation Procedure to require that the Human Performance Evaluation 1
System be utilized in the ultimate evaluation' and resolution of un-plannea reactor trips.
The-licensee has made changes to the Post-Trip Review Procedure and to the Event Evaluation Procedure to include Human Performance Evalu--
ation into the procedures.
L The Human Performance and Evaluation System Coordinator is notified u
any time there is a Reactor Trip or ESF actuation.
Post-Trip Review Procedure Step 7.4.la-requires' human performance issues to be l
addressed prior to authorizing restart.
The Event Evaluation and Reduction Program has.been expanded to require an event evaluation and preliminary recommendations to' be made prior to restart after trips which occur during the Power Ascension Program.
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The inspector reviewed the changes made to assure human factors-issues are addressed following reactor trips and found the action taken to be adequate.
This item is closed.
k.
CAP Item 2.B-1: Issue letters of-reprimand to the Operations chain of command management personnel who were present in the Control Room during the Natural Circulation Test, the personnel who were spoken to
6 s
by'the NRC inspectors regarding the 17% pressurizer level trip cri-terion during the test, and the onshif t operators and startup engi-J neers who had the authority and responsibility to prevent the proce-dure violation.
The inspector reviewed eight letters of reprimand which were issued.
All were dated July 11 or July 12, 1989.
Each letter was signed by the appropriate manager and discussed the appropriateness of the re -
primand action and the specific bases for the conclusion that the reprimand was necessary.. Also discussed in the letters were expecta-1 tions for improvement in each individual's future performance.
The inspector interviewed licensee personnel and received confirmation that the letters were officially placed in the individual personnel files.
This item is closed, l.-
CAP Item 2.B-4: Establish management personnel policy and briefing that focuses.on the obligation to be cognizant of safety and opera-tional limits associated with operations and test activities observed in the' Control Room.
A memorandum was issued November 10, 1989 by the Executive Director -
Nuclear Production promulgating the policy regarding performance of New Hampshire Yankee Line Management when they visit the Control Room. Managers in the Operations chain of: command are encouraged to spend time in the plant and the Control Room.
When in the " horseshoe area" of the Control Room, it.is their responsibility to be knowl-edgeable of. safety and operational limits of evolutions in progress in order to provide appropriate guidance and direction to the operat-ing crew:if required.
In those mses where it is not possible for them to become familiar with a speial evolution prior to entering the "horseshe9 area,'"'they are required to inform the Unit shift Supervisor (045) or Shift Superintendent (SS) that they are there as an observer.
When outside the " horseshoe area" they are understood to be acting as observers only, unless they inform the USS or SS otherwise.
A11 line managers were briefed regarding this policy when
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it was implemented. This policy, which was found acceptable during this inspection, is to be included in the next revision of the Pro-cuction Management Manual.
This item is closed.
m.
CAP Item 2.B-5: Conduct operating philosophy and event analysis semi-nars for production management and licensed personnel.
The inspector observed an event analysis seminar on December 15, 1989.
The seminar was led by the Executive Director - Nuclear Pro-duction.
Participants were an operating crew consisting of licensed s
operators, startup personnel, and system engineers.
The seminar re-viewed two case studies of events at licensed reactors: the 1985 loss
-(-
i 7
1 of feecwater at Davis-Besse and the Natural Circulation Test at Sea-brook.
The crew review of the sequence of events in both cases-pointed out problems and their probable causes.
It was reiterated-several times that the purpose of these-case studies was to identify problems and possible solutions, not to lay blame. The session con-cluded with a discussion of the procedural compliance policy and i
effectiveness of the training being performed, whether or not it addressed identified problems from the June 22 event. NRC review cc..zluded that such seminars provide valid training which met NHY CAP commitments and was acceptable.
.j This item is closed, I
n.
CAP Item 2.B-6: Rotate additional station operations managers through i
the INPO Senior _ Plant Management Course.
New Hampsnire Yankee'(NHY) plans to send one additional person to the National Academy for Nuclear Training course titled Senior Nuclear Plant Management Course to be conducted in 1990.
By the same_ letter, NHY reouested slots be allocated for 2 more Seabrook management per-b sonnel in future courses.
NRC review concluded that this planning acceptably fulfilled the NHY CAP commitment and was acceptable.
This item is closed.
3.0. TMI Action Plan Recuirements (2515/65)
- NUREG 0737, " Clarification of TMI Action Plan Requirements," forwarded the
. post-TMI requirements which had been approved for implementation by the Commission to operating power reactor licensees and applicants for operat-ing licenses. -During the inspection period the inspector reviewed the.New Hampshire Yankee (NHY) response to the requirements of Clarification Item II.B.2, " Design Review of Plant Shielding and Environmental Qualification of Equipment for Spaces / Systems Which May Be Used in Post Accident Opera-tions." This item required licensees to perform a radiation and shielding design review of the spaces around systems that may, as a result of an accident, contain highly radioactive materials, and to provide for ade-quate access-to vital areas and protection of safety equipment during post accident' operation of these systems.
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1 The inspector initially discussed the matter with the NHY Health Physics Department supervisor and was informed that the required radiation and shielding review had been-performed and was documented in the "Seabrook Station Post-Accident Dose Engineering Manual."' A copy of the manual was
- provided to the inspector, and upon review, _it was determined that the manual addressed-the majority of the requirements stated in Item II.B.2.
The manual. describes the post-accident radiation environment for Seabrook Station, including accident dose rate zone maps and post-accident dose-rates and time-integrated _ doses for various pipe / equipment configurat
- n s.
1 Also contained in the manual are several chapters describing the methoco-logy and bases useJ to generate these zone maps and dose tables. Through
8 l
discussions'with the Health Physics supervisor and inspection of the
" Post-Accident Dose Engineering Manual," the inspector determined that the guidelines provided in NUREG 0737. Item II.B.2, had been used by NHY in s
tneir post-accident radiation and shielding reviews. All required source terms, vital areas, systems, and dose rate-criteria were four,d to be pro-perly addressed by the licensee.
The one area required by Item II.B.2 to be reviewed but not addressed by the " Post-Accident Oose Engineering
)
Manual" is radiation qualification of safety-related equipment.
To ensure that this area had been addressed, the inspector interviewed the NHY Equipment Qualification (EO) Program supervisor and was provided access to the licensee EO files and reports.
Through inspection of Qualification Evaluation Worksheets and qualification reports of equipment important to safety, the inspector determined'that the proper source terms had been-considered and'that all required safety-related equipment had been quali-fied per Item II.B.2.
Through discussions with NHY personnel and through inspection of licensee documentation, the inspector concluded that all requirements of NUREG 0737, Item II.B.2, had been met by the licensee. This item is closed, 4.0 Alleoation RI-89-A-0146 on Procedure Inadecuacies (71707)
The NRC Region I office received an allegation in the beginning of the
. inspection period concerning procedure inaccuracies at Seabrook Station.
'Specifically, the alleger stated that a breakdown in the accuracy of pro-cedures had occurred during the transition from the use of symbols in pro-Cedures to-the strict use of text.
The alleger also. stated that proce-dures: lacked' complete information such as leaving procedure cross-refer-ences blank, and specified two procedures that.did so.
Inspector follow-up found that the procedure numbers provided by the alle-ger did nnt exist at Seabrook.
Procedure numbering at the site is dif-ferent than that referred to by.the alleger.
The inspector reviewed cer-3
'tain procedures whose numerical designations resembled those specified by tne alleger, but no deficiencies of the type alleged were identified.
Beginning in early 1986, operating procedures at Seabrook have been in-spected in accordance with the NRC manual chapter governing inspection of operating reactors. Initial review had questioned some procedure aspects (e.g., reference usage), but overall procedure adequacy has not been a To address NRC concerns, NHY established a continuing Procedure concern.
Consistency Review Program in 1986.
NRC inspection of procedures, includ-ing procedural consistency and overall quality, have since identified acceptable corrective actions, no unresolved safety concerns, and overall acceptability of-station procedures.
To further assess whether-problems exist in this area, the inspector re-viewed a sampling of operating, maintenance, chemistry and radiological control, and emergency operating procedures.
The inspector identified no problems described by the alleger.
Two typographical errors with no
9 A
safety significance were found.
The procedures reviewed were adequately written. ' As additional follow-up,' the inspector discussed the matter with the NHY Production Services' Manager (who supervises the Records. Management Department), the reactor engineer who had supervised the Procedure Con-sistency Review Program over the past three years, several. operating crew Shif t Superintendents, and the Assistant Cperations Department Manager.
i The inspector determined that the Operations Department was the only'de-partment on site that had a dedicated effort to convert symbols to text-in n
their procedures, and that neither the Procedure Consistency Review Pro-
_i gram, the operating crews, nor operations management had identified any problems with the conversion process. The personnel interviewed by the inspector cited one typographical' error that had been identified and cor-rected by the normal, in place procedure review process and, in addition, explained that the " greater than" and "less than" symbology had been re-moved from Emergency Operating Procedure E.0, Attachment 1, in order to avoid any misunderstanding,by the operators who use that procedure.
Both of_ these corrections / changes to procedures were licensee-identified and 1
accomplished months prior to the submission of the allegation. The in-l spector found the interviewed personnel aware of and familiar with the guidelines and rules for procecure writing and correction as delineated in
. station administrative procedures OP-11.2, " Operating Procedures Writer's Guide," and SM-6.2, " Station Operating Procedures."
The inspector reviewed various station procedures and discussed the issues of symboi-to-text conversion and incomplete information-in station proce-
-dures with' licensee _ personnel in light of the received ellegation. That effort identified no deficiency described by the alleger.
This allegation i
was unsubstantiated.
5.0 Licensee Action on Previous NRC Open Items (92702) a.
(Closed) Violation (89-82-01), Failure to Follow Startup Test Proce-dures.
New Hampshire Yankee (NHY) undertook a number of actions to address this violation. These actions are' described in, and were
~ implemented as part _ of, the. Corrective Action Plan.
Actions taken in g
response to this violation included shift meetings to review the pro-l cedure compliance policy, issuance of a memorandum by the NHY Presi-dent to all Seabrook site staff re-emphasizing the requirement to L
_ follow procedures, revising-the Startup Test Program Description to include it in the Power Ascension Test Program, and strengthening its requirements for equipment status verification and pre-test brief-ings, replacement of the Startup Test Department with a Power-Ascen-sion Test Program organization that has more clearly defined and documented interfaces with the Operations department, revising the remaining Startup Test Procedures-to include the changes implemented in the programs and to provide additional guidance on terminating tests and exiting test procedures, and providing crew training on -.
PATP test procedures in the simulator.
CAL 89-11 is being separately processed for closure and, upon completion of tnat action, this viola-tion is also closed.
p k-20 n
b.
(Closed) Violation (89-82-02), Inadequate Correct 4 Natural n
Circulation Test. Actions taken by NHY to addres tion included including the Startup Test Prograd in inston C
Test Program with strengthened requirements fo
( p re-test briefings; additional guidance on terminati.
exiting test procedures; simulator training.of operating ce y it pro-cedures; more clearly defined authority, responsibility, end inter-faces for operations and testing personnel; relievim the Vice Presi-
' dent - Nuclear Production and replacing him with a.. c;xecutive Direc-ter - Nuclear Production; requiring Event Evaluation Reports to be
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complete prior to recommending restart if a reactor trip occurs dur-ing testing; and making the human performance evaluatinn system a part of the post-trip review, CAL 89-11 is being separately pre-i cessed for closure and, upon completion of that action, this viole-tion is also closed.
c.
(0 pen) Unresolved Item (89-07-01), Emergency Feedwater Pump Turbine (EFWpT) Control Valve Leakage.
NHY has taken the following actions in order to resolve the problem of steam leaking through th'e EFWPT E
control valves and causing cycling of the downstream check <shes:
Engineering evaluation 89-021 has been performed to determine the effects of leakage past the steam supply control valves.
~
The steam supply control valves were replaced under Design Change
The replacement valves were designed and manu-factured to the codes and standards applicable to the original valves.
The differences in style are to provide improved reliability and reduce maintenance.
The replacement valves are considered by NHY to be better suited to operate under the anticipated system condi-tions.
t A drain trap has been installed on each steam supply header between the isolation valve (MS-V-393/394) and the downstream check valve.
(MS-94/96) to help prevent check valve cycling (the MS-V-393/394 re-
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t placement valves were ordered to the lowest achiev&ble seat leakage criteria, but an absolutely steam tight condition is not-exp'ected).
' Each steam trap arrangement includes a normally open maintenance i
isolation valve, a flow restricting orifice, and a 'Bestobell' steam trap.
. Check valves 94 and 96-were disassembled and inspected for damage.
Valve 94 was found to be damaged and-was refurbished.
Valve 96 was found to be excessively degraded and was cut out and replaced.
post-maintenance testing is to be performed under Special Test STP-121,
" Turbine Driven Emergency Feedwater Pump Start Verification Test."
The inspector reviewed the response to the unresolved item, the Engi-neering Evaluation, the DCR, and the work requests used to refurbish /
replace the check valves. Discussions were also held with personnel
....,,,m..y.... m. v,.y'..n ;,, w ' - ' ;".;.ra. 6 m w ;. f.s.v m d.',
M 6
a 11 t
i in the NHY Engineering. organization. The inspector. conducted an in-
+
dependent walkdown of the installed drain / trap arrangement and the new steam supply control valves. This item remains open pending com-t pletion of the testing under STP-121.
d.
(0 pen) Unresolved-Item (89-07-02), RHR Check Valves RH-15,- 29, 30, and 31 Leakage.
The following corrective actions have.been taken regarding the resolution of the RHR Check Valve lea 6 age problem:
A " Request for Engineering Services" (RES) was issued and NHY con-suited.the check valve supplier.
All four check valves were disassembled and refurbished.
The vcive seats were. lapped and proper seating was verified using the " Blue Dye Testing" method.
NHY reviewed pressure isolation valves in other systems connected to
-the Reactor Coolant System to determine if similar seat leakage con-ditions could be' encountered.
NHY has committed to performing post-maintenance testing on these valves by subjecting them to the same conditions under.which the leakage had originally occurred (low differential pressure).
The-inspector reviewed the Engineering Evaluation-(89-025) and dis-cussed its contents with members of the station engineering group.
2 The work documents used for refurbishing the leaking valves were re-viewed to determine what work was performed.,and what post work test-L ing is appropriate.
In addition to the required seat leakage and In-Service tests, NHY plans to perform a leak rate test under condi -
~
tions duplicating those which originally resulted in the leakage i
problem (Iow differential pressure). This item remains open pending i
successful completion.of post-maintenance testing.
6.0 Security'(81052)
Short term compensatory measures and long-term upgrades of the plant i
security barriers have been reviewed by regional security specialists in 1
NRC Region I Inspection-Report 50-443/89-13.
The inspector verified that the short term compensatory actions to which NHY. committed were in place and that additional compensatory actions were l
planned if a full power license is issued, and had no further questions.
y I
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