ML20012E160

Evaluation of Seabrook Station.

ML20012E160
Person / Time
Site:	Seabrook
Issue date:	09/30/1989
From:	INSTITUTE OF NUCLEAR POWER OPERATIONS
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ML19324G680	List: ML19324G679 ML20012E157 ML20012E159 ML20012E160 ML20012E163
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NUDOCS 9003300146
Download: ML20012E160 (61)

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SEPTEMBER 1989 Evatuation Exe la l RESTRICTED DISTRIBUTION

-l SEABROOK STATION Puntic SERVICE COMPANY OF NEw HAMPSHIRE l

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• RESTRICTED DISTRISUTION EVALUATION of SEABROOK STATION Public Service Company of New Hampshire Copyright 1999 by lastltute of leuclear power Operations. All rights reserved. teot for sals, Reproduction of this report without the weltten gensent of I M la empressly prohibited. Unauthor.

Isod reproduction is a violotles of appliceD14 law.

The peceons and organisettone that are furnished cooles of this report should not dellver or transfer this resort to any third person, or aske this report er its contents public, without the prior agreement of 8190 and the member of 18F0 for whom the report was meltten.

September 1989

CONTENTS Purpose and 5c ope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 E xecu t ive Su m mar y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 R esponse Su m mary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $

Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Operating Experience R eview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 T ec hn ica l S u ppor t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Ope r a t ions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 5 Ma in t e nanc e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2 Ra d io log ic al P r o t ec t ion . . . . . . . . . .'. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 0 C he m i s t r y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 4 Outstanding Response Actions from Previous Evaluations . . . . . . . . . . . . . . . . . . . . Appendix !

Additional Supporting Details . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Appendix 11 i

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PURPOSE AND SCOPE i i

I INPO conducted an evaluation of site activities to make an overall determination of plant j safety, to evaluate management systems and controls, and to identify areas needing i improvement. Information was assembled from discussions, interviews, observations, and i reviews of documentation. l The INPO evaluation tearn examined station organization and administration, operations, maintenance, technical support, training and qualification, radiological protection, chemistry, and operating experience review. The team also observed the actual perfor-mance of selected evolutions including surveillance testing. As a basis for the evaluation, INPO used its April 1987 Performance Objectives and Criteria for Operating and Near-term Operating I.icense Plants: these were applied anc evaluated in light of the expertence of team members, INPO's observations, and good practices within the industry.

INPO's goal is to assist member utilities in achieving the highest star dards of excellence in nuclear plant operation. The recommendations in each area are based on best practices, rather than minimum acceptr.ble standards or requirements. Accordingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory perfor-mance.

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IEsTRICTED DisTRimffl0N Copyright 1999 by institute of Nuclear Power Operations. All rights reserved, lest for sale.

Reproduction of this report without the written consent of Ifr0 is empressly prohibited. Unauthor-Ired reproduction is a violation of applicable law.

The persons and organtrations that are furnished copies of this report should not deliver or transf er this report to any third porton, or eeke this report or its contents public. without the prior egreement of Ilro and the esener of 119o for whom the report was weltten, i

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Page 2 EXECUTIVE

SUMMARY

The Institute of Nuclear Power Operations (INPO) conducted an evaluation of Public Service Company of New Hampshire's Seabrook Station during the weeks of September 11 and it, 1989. The station is located near Seabrook, New Hampshire. Seabrook is a single unit, four-loop Westinghouse pressurized water reactor plant rated at 1,150 MWe Low power testing was completed June 22,1989. The unit was shutdown for modification work during the evaluation.

The following beneficial practices and accomplishments were noted:

o Dedicated personnel who exhibit a positive approach to their job.

o A sense of teamwork between groups at the working level, o Experienced personnel in key management and supervisory positions, o Innovative approaches to problem solving such as testing techniques for motor-operated butterfly valves.

Improvements were recommended in a number of areas. The following are considered to be among the most significant areas in need of improvement:

1. Application of lessons learned from in-house and industry experience needs attention as indicated by the followings

a. The station has experienced a number of recurring events due to inadequate identification and investigation of in-house operational events. (OE.2-1)

b. Some events have occurred at the station that could have been prevented by improved application of industry operating experience. (CE.3-1)

2. Improvements are needed in consistently exercising positive control over operational activities. (OP.2-1)

3. The ability of the turbine-driven emergency feedwater pump to respond reliably to as-demanded conditions needs to be demonstrated periodically. (TS.5-2)

4. Weaknesses in some station programs could adversely affect reliable plant operation as follows:

a. Many plant changes do not receive appropriate technical review and are not incorporated into plant drawings and procedures. (TS.3-1)

b. The station equipment tagging and isolation procedure needs improvement to ensure protection for personnel and equipment. (CP.3-1)

c. Many plant operating procedures contain technical deficiencies and human factors problems similar to those that have caused operator errors in the industry. (OP.5-1)

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5. Monitoring of piant activities and programs by managers and supervisors is of ten ineffective in identifying needed improvements. . Examples include the use of vendor manuals to conduct work and completion of required training. (OA.3-1)

6. In the long term, maintenance facilities appear inadequate to accommodate shop work on contaminated components and decontamination of plant equipment.

(MA.8-2)

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Page4 Findings and recommendations are listed under the performance objectives to which they pertain. Findings describe conditions that detract from meeting the performance  !

objectives. Particularly noteworthy conditions that contribute to meeting performance i objectives are identified as good practices and strengths. Good practices are considered j sufficiently unique within the industry such that they would be useful to other utilities.

The recommendations following each finding are intended to assist the utility in ongoing efforts to improve all aspects of its nuclear programs. In addressing these findings and recommendations, the utility should, in addition to correcting or improving specific conditions, pursue underlying causes and issues. Additional supporting details for selected findings are provided in Appendix !!. '

i The findings listed herein were presented to Public Service Company of New Hampshire management at an exit meeting on October 18,1989 findings, recommendations, and responses were discussed on November 30,1989, and the responses are considered satisfactory.

To follow the timely completion of the improvements included in the responses and any SOER recommendations evaluated as not satisfactory, including each red-tab SOER recommendation received subsequent to this evaluation, (see Appendix !!), INPO requests a written status report by June 1990. A final update will be requested six weeks prior to the next evaluation.

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1 PUBLIC SERVICE COMPANY OF NEW HAMP5 HIRE l Response Summary As the operating agent for Public Service Company of New Hampshire's Seabrook i Station, New Hampshire Yankee finds the Institute of Nuclear Power Operations (INPO)  !

evaluation of Seabrook Station to be both insightful and useful. New Hampshire Yankee supports the overall goals of INPO and the nuclear industry in ensuring safe and reliable electrical production using nuclear technology. We are pleased that INPO observed some beneficial practices and accomplishments during their evaluation. We ,

also appreciate the findings and observations of the INPO team where they noted areas ,

for improvement. New Hampshire Yankee is committed to improving its methods and procedures to correct these areas of weakness. Specifically, New Hampshire Yankee will strengthen programs in the following areast o Application of lessons learned from in-house and industry experience will be ,

strengthened by ensuring that such experiences are thoroughly reviewed and  ;

completed in a timely manner and by holding individuals accountable for implementation.

o Improvements wi!! be made to ensure consistent exercise of positive control over ,

operational activities by providing additional staff support within the Operations Department. This will allow operations management to focus on operational issues and activities.

o The ability of the turbine-driven emergency feedwater pump to respond reliably to as-demanded conditions will be periodically demonstrated, o Weaknesses in some station operating procedures will be corrected to ensure s reliable plant operation by providing additional operations staff and by utilizing feedback from the operators. The equipment tagging and isolation procedure will also be impt oved.

o The monitoring of plant activities and programs by managers and supervisors will be strengthened by clearly communicating station management's expectations to

• all managers and supervisors and by reinstating the Supervisory Walkdown Program.

o Maintenance facilities will be improved to accommodate shop work on contaminated components and decontamination of plant equipment by the

( implementation of our facilities five-year plan.

in summary, New Hampshire Yankee supports both INPO and the industry in the pursuit of excellence in nuclear power plant operations. We believe the implementation of the improvements committed to in this evaluation report will help us in that effort.

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Page 6 ORGANIZATION AND ADMINISTRATION s STATION ORGANIZATION AND ADMINISTRATION PERFORMANCE OEDECTIVE: Station organization and administration should ensure effective implementation of policies and the planning and control of station activities.

Finding (OA.1-1) Incufficient management direction in some areas has resulted in problems continuing to exist. Additionally, management i expectations are not clearly understood at all levels of the i organization. Examples are as follows:

a. Responsibilities for the review and disposition of

, industry and in-house operating experience reports i have not been established. This has resulted in ineffective corrective actions for some plant events and recurrence of some significant events at the station. (See Finding OE.3-1.)

b. Expectations of station management for the

- minimization of radioactive waste have not been l effectively communicated. Several supervisors stated that they had not received guidance on minimizing radioactive waste and, as a result, worker practices generate unnecessary waste. (See j Finding RP.1-1.)

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c. Management expectations for the implementation of l

the station goals is not being carried out in some areas. For example, two departments that were directed by management to estabilsh goals for 1989 to support the plant goals, have not developed goals. Additionally, many of the goals that have

, been estabilshed, have been ineffectively communicated to the supervisors, foremen, and workers. Consequently, these individuals are not aware of management's expectations resulting from the station goals program.

Recommendation Clearly define expected performance standards in areas such as those noted above and communicate them to all leveis of the station staff. Develop and implement an effective goals and objectives program that addresses areas of needed improvement. INPO 86-019 (Good Practice OA-103),

Management Objectives Program, may be of assistance in this effort.

Response Management expectations for employee responsibilities related to the disposition of industry operating experience and the minimization of radioactive waste will be presented to

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effactive goals and ob}ectives program will be developed and i established by February 1990. This program will clearly defirw i expected performance standards to all levels of the station staf f  !

and will include all station departments. The goals program will I include, but not be limited to, the areas of industrial safety, .

reliability, ALARA, minimizing radwaste generation, and the disposition reports. INPOof86-019 industry (Goodand in-house Practice OA-103 operating

, Management ) experience Objectives Program, will be used as an aid in this program development. I 1

l MANAGEMENT ANSWENT ,

4 PERFORMANCE OBJECTIVE: Management and supervisory personnel should monitor and I assess station activities to improve all aspects of station performance. j Finding (OA.3-1) Monitoring of plant activities and yograms by managers and supervisors is often ineffective in dentifying needed improvements. Additionally, some problems implementing station policy have not been communicated to senior station management. Examples are as follows:  :

a. Senior station managers were unaware that vendor manuals are used to conduct station activities contrary to station policy. Interviews with instrument and control technicians indicated that vendor manuals are routinely used to troubleshoot and repair process equipment. Vendor manuals do '

not receive the equivalency of station operating review committee approval, and a program is not in place to keep the manuals up-to-date.

b. The extent of worker deviation from station industrial safety policies was not known by managers and supervisors. (See Finding OA.5-1.)

c. Many managers were unaware that a significant number of station supervisory personnel have not received initial behavioral observation training in fitness-for4uty and that others are beyond the expiration date for riequalification training. (See Finding OA.8-1.)

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d. Supervisory monitoring of day-to-day station activities is infrequent. One manager stated incorrectly that supervisors were expected to monitor plant activities only once monthly.

Recommendation increase the presence of managers and supervisors in the work spaces to ensure that personnel meet the performance standares  ;

expected of them.  ;

Response Station management's expectations of supervisors and managers regarding their presence in station work areas will be restated and reemphasized. This restatement will describe management's ,

overall expectations for the monitoring of plant activities and I programs and the expected feedback to senior management. i This restatement will be completed and implementation i Initiated by December 1989. The station will also reinstitute, by j January 1990, its program for supervisory walkdowns based on i INPO 87-023, Plant inspection Program. Follow-up and i monitoring of this effort wi!! be ongoing.

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INDUSTRIAL SAFETY PERFORMANCE OBJECTIVE: Station industrial safety programs should achieve a high l Wee of personnel safety. ,

Finding (OA.5-1) Personnel often do not wear required personnel safety equipment. Many personnel, including supervisors, were observed not wearing eye protection, hard hats, and ear protection where required by station policy. For example, two electricians were observed working on the residual heat removal system without eye protection, and one of these workers worked below a scaffold without a hard hat. Personnel were also

observed working at heights or climbing without required safety belts. A worker was observed walking on piping for the SF6 bus ducts approximately 20 feet above the ground without a safety harness. One lost-time accident at the station in 1989 was a back injury due to a fall from a cabinet.

L Recommendation Emphasize the importance of adherence to station industrial safety policies and procedures. Improve the monitoring and enforcement of industrial safety requirements by station supervision, hold supervisors accountable for the performance of their subordinates. .

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Page 9 Response The importance of adherence to the industrial safety policies and procedures will be reemphasized by redistribution of the company's policy to all New Hampshire Yankee employees. At that time, a progressive disciplinary action procecs will be -

announced. The industrial safety performance of each worker will be reviewed as part of the annual performance appraisal. In 3 addition, the performance appraisais of supervisors will include i a review of the industrial safety performance of those workers  !

reporting to that supervisor. Line managers and supervisors will  !

closely monitor adherence to industrial safety requirements and provide correction or coaching as appropriate. The overall j monitoring of the industrial safety program will be performed by )

the executive safety committee. The redistribution of the industrial safety policy is scheduled for February 1990.

FITNESS-FOR-DUTY PROGRAM PERFORMANCE OEL7ECTIVE: The fitness-for-duty program should identify persons who are unfit for their assigned duties as a result of drug or alcohol use, or other physical or psychological conditions, and remove them from such duty and from access to vital areas of the plant. In addition, the program should provide for a drug-free working environment. l Finding (OA.8-1) Behavioral observation training for supervisory personnel has

been ineffectively implemented. Initial training has not been  ;

l conducted icr many managers and supervisors. These managers and supervisors have been assigned to the site or corporate office for a significant period of time and supervise personnel with access to protected areas of the plant. In addition, requalification training for some other managers and supervisors has not been conducted as required.

Recommendation Ensure managers and supervisors are appropriately trained to detect abnormal behavior of personnel.

Response Effective December 1989, New Hampshire Yankee will l

Implement the new fitness-for-duty program. To ensure  !

effectiveness of this new program, supervisor attendance at behavior observation training is a requirement for protected area badging. As of January 1990, badges will be pulled for anyone deficient in this training. As part of our ongoing training program, annual fitness-for-duty and behavior observation refresbar training will be a requirement for protected area badging renewal.

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Page 10 OPERATING EXPERIENCE REVIEW IN-HOUSE OPERATING EXPERIENCE REVIEW PERFORMANCE OEUECTIVE: In-house operating experiences should be evaluated, and appropriate actions should be undertaken to improve safety and reliability.

Finding (OE.2-1) The station has experienced a tumber of recurring events due to inadequate identification and investigation of in-house operational events. The following problems were found

a. Root cause analyses of station events and recommended corrective actions have frequently not been adequate to prevent the recurrence of events.

The following are examples of events that have recurred due to inadequate corrective actions: ,

1. On three occasions between September 1986 and October 1988, the refueling water storage tank was drained to the reactor coolant system

- via the residual heat removal suction piping.

The evaluation of the first event did not l identify any potential procedural problems. )

The second event was not identified for 1 investigation in the station's !n-house operating experience program. The evaluation of the l third event, which was determined to be caused by procedure inadequacy, identified numerous procedures that required revision to prevent l

this event from recurring.

2. Between August 6 and September 9,1989, water was inadvertently drained from the '

refueling water storage tank or the condensate storage tank on three occasions. The first event was due to a valve being open that was thought to be danger-tagged shut. The second event was due to not performing a required j

valve lineup. The third event occurred while restoring eight valves that were discovered to I be previously mispositioned.

3. On three occasions between November 1987 .

and June 1989, an inverter used for balance-of-plant loads, ED-I-4, caused transients to station instrumentation. The evaluation of the first event recommended observing the inverter to determine a permanent solution. The second event caused a steam generator blowdown isolation but was l _

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not identified for investigation in the station's in-house operating experience program. The l third event occurred during low power testing j and caused a steam generator blowdown isolation, blowout of the blowdown tank manway gasket, and a loss of instrumentation.

A failure of this inverter at power would trip the main feedwater pumps and cause a reactor  :

trip. i l- b. Several recent station events were not investigated  ;

l in the station's in-house operating experience  !

pregram. The following are examples of events that i were not identified for investigatiom

1. During low power testing, the residual heat l removal system was overpressurized, causing a l relief valve to lif t, when four cold leg injection l check valves failed to close. The four safety injection accumulators discharged 500 gallons of wtter before the check valves were l reseated.

2. The A emergency feedwater pump turbine l experienced an overspeed condition on three 1 occasions during startup testing due to l problems with the governor. )

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3. Electrical breakers to the safety injection t accumulator discharge valves were found i closed (energized) when the valve operators were required to be de-energized by technical '

specifications. The governing procedures gave ,

t conflicting guidance on the required position of l these breakers.

A contributing cause of the recurring events is that some f' important event investigations were initiated, but not completed.

Recommendation Ensure station events are identified and thoroughly investigated in a timely manner to determine the root causes and necessary corrective actions. The guidarme in INPO 89-005, Guidelines for ,

the Use of Operating Experience, should be of assistance in this offort.

Response The stathn information report (SIR) procedure will be revised or a new reporting method will be developed to ensure that in-house operating events, such as those noted, will be investigated thoroughly and completed in a timely manner. As part of this investigation, a determination of the root causes and necessary corrective actions will be made. In addition, the

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Page 12 initiating threshold for event review will be lowered to conform .

with corporate management 4 expectations. INPO 89-005, Guidelines for the Use of Ommating Experience, will be utilized in this procedure revision. This procedure will be updated and implemented by February 1990.

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Page 13 INDUSTRY OPERATING EXPERIENCE REVIEW PERFORMANCE OBJECT!YE Significant industry operatin5 **Periences should be evaluated, and appropriate actions should be undertaken to improve safety and reliability.

SOER STATUS The status of Significant Operating Experience Report (50ER) recommendations is as follows: ,

Total number of recommendations issued to date 417 Number previously evaluated as satisfactorily implemented or not applicable 236 Number reviewed this evaluation (including 46 previously reviewed and evaluated as satisfactorily implemented or not applicable)  !!8 o Number satisfactorily implemented 76 o Number not satisfactorily implemented (4 red tab) 25

o Number not app!! cable 0 o Number pending - awaiting decision (0 red tab) 0 o Number pending - awaiting implementation (4 red tab) 17 The following recommendations have not been satisfactorily implemented and itsther actions are needed. Five of these recommendations, previously considered by INPO to have been satisfactorily addressed, have been reopened as subsequent review has determined that ,

the action taken was not effective; e.g., subsequent actions removed procedural requirements or deleted necessary training or the action intended was not completed.

SOER Recommendation Number Topic 81-9, rec. 2b Maintenance on instrument air filter elements 82-9, rec.1 Procedures for monitoring and trending ,

hydrogen gas usage 82-12, rec. 5 red tab Training for plant personnel on preventing miscellaneous objects from being lef t in steam generators 82-13, rec.11 (reopened) Chronic contamination by organic chemicals 82-13, rec.12 (reopened) Training employees on chemir.at intrusion l into the reactor coolant system l

82-13, rec.13 (reopened) Caution contractors on uncontrolled chemical usage l

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Page 14 82-15, rec.I Seasonal reminders on freeze protection for critical instrumentation q 82-15, rec. 2 Procedures on freeze protection for critical systems 82-15, rec. 3 Seasonal reminders to operations concerning freeze protection of safety-related equipment 82-15, rec. 4 Training on cold weather operations 82-15, rec. 5 Recalibration of thawed equipment prior to returning to service r 82-15, rec. 6 Examination of thawed equipment prior to returning to service l 83-8, rec.10, red tab Procedures for incorporating safety-related vendor data into preventive maintenance programs 85-8, vec.12, red tab Technical staff and manager / supervisor training on safety classification determinations 83-9, rec. 7 Operability testing for manually seated or backseated motor-operated valves j 84-3, rec. 5 Preventive maintenance program for l check valves in the auxiliary feedwater system l 84-7, rec. 3 (reopened) Recovery from the pressure

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locking / thermal binding of gate valves 85-2, rec. 2 (reopened) Valve position and procedure compliance training 86-1, rec. 3 Periodic testing of auxiliary feedwater pumps 86-2, rec.1 Motor-operated valves with single rotors 86-3, rec.1 Preventive maintenance procedures for check valves 86-3, rec. 2 Check valve design review l

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88-!, rec.3 Training on the importance and potential for common mode failures of instrument air systems 88-2, rec. 6, red tab Reactor startup procedure premature criticality monitoring 88-3, rec. 2 Residual heat removal operations procedures (See Appendix !!, p.! for further details)

I Finding (OE.3-1) Some events have occurred at the station that could have been -

prevented by improved application of industry operating experience. Implementation of corrective actions to prevent occurrence of events described in significant operating *

, experience reports (SOER) is frequently not effective or timely. Responsible station personnel are of ten not held accountable for timely and effective implementation of t corrective actions. As a result, the station has experienced events similar to those identified in industry operating experience documents. Examples are as follows:

a. SOER 82-13 " Freezing of Safety-Related Equipment," recommends that critical system ,

instrumentation and equipment that may be affected by severe cold weather be reviewed to identify ,

needed modifications. The control building '

ventilation system has iced-over several times during adverse weather conditions due to freezing rain and snow being drawn into the intake filters,

b. SOER 85-2," Valve Mispositioning Events,"

recommends that operations, maintenance, and supervisory personnel be trained in procedures used i

to position and verify valve positions. On five occasions from July 1988 through September 1989, water from the refueling water storage tank or the condensate storage tank was inadvertently transferred due to mispositioned valves,

c. SOER 86-3," Check Valve Failure or Degradation,"

recommends that preventive maintenance procedures l be established to identify existing and incipient l failures of check valves in appropriate systems. The safety injection cold leg injection check valves and

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Page 16 the residual heat removal cold leg injection check valves have recently experienced failures. The failure of the latter valves resulted in lif ting the j residual heat removal safety relief valves and 1 discharging 300 gallons of borated water from the safety injection accumulators.  !

Corrective actions taken in response to !!8 SOER 1 recommendations were reviewed during the evaluation. Of ,

. these,23 station responses were determined to be not satisfactory due to either insufficient progress being made, er  !

the actions taken not being implemented completely or .

effectively. Details are conta,ned in Appendix 11. .

Review of significant event reports (SER)is frequently not .

complete'or timely as indicated by the fo!!owing:

a. Five SERs, one 1987 and four 1988, were closed out without being reviewed for applicability and appropriate corrective actions.

b. Five 1988 SERs have not received initial screening l

. for applicability.

Recommendation improve the effectiveness and timeliness of implementation of

• lessons learned from industry operating experience. Periodically ,

monitor implementation of identified corrective actions and their effectiveness. Hold personnel accountable for completion of assigned actions.

Response The New Hampshire Yankee industry operating experience review program will be improved and strengthened to ensure effectiveness and timeliness in the implementation of lessons learned from industry operating experience. A schedule has been developed for the rfview and implementation of outstanding SOERs and SERs. The backlog of open SOERs will be reviewed and corrective actions determined by October 1990. Personnel will be held accountable for completion of assigned actions by means of an improvement to the integrated commitment tracking system. Progress on completion of these items will be monitored by the executive director of nuclear production.

In addition, a goal has been established within appropriate organizations requiring new SOERs issued in 1990 to be reviewed and corrective actions determined within 90 days of assignment for red tab SOER recommendations and 180 days for all other SOER recommendations. If, due to the nature of the SOER

! recommendation, these time frames are not practical, the l executive director of nuclear production will specify an l appropriate due date.

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TECHNICAL SUPPORT PLANT MODIFICATIONS PERFORMANCE OBJECT!YE: Plant modification programs for permanent and temporary modifications should ensure proper design, review, control, implementation, and  ;

documentation of plant design changes in a timely manner. (NTOL: During start-up, all '

changes made as a result of system or component testing should be controlled under formal modification programs.)

Finding (TS.3-1) Many plant changes do not receive appropriate technical review  :

and are not incorporated into plant drawings and procedures.

The lack of adequate desi$n review and documentation has resulted in plant events anc reportable conditions. The following examples were noted:

a. Some plant changes are not included in the configuration control process. For example, at least I five temporary sump pumps were observed to be in use, but are not controlled as temporary plant

. changes, despite a recent plant event that was caused by use of a temporary sump pump in the turbine building that bypassed an effluent release monitor.

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b. Some .emporary modifications and changes made during the startup program that have been converted j to permanent installations do not include the same  !

level of supporting plant procedures or technical l documentation as originally installed equipment. For i example, the Centac air compressor, temporarily )

installed during startup, does not have a controlled I

vendor manual or maintenance procedures even l l though it is now considered a permanent 1 installation.

c. Some temporary vendor supp!!ed equipment attached I l , to and used as permanent plant systems has not l received an adequate technical review. For 1 example, a bulk nitrogen tank truck is connected to l the plant nitrogen header and used to maintain l header pressure. The connection point is shown on plant drawings and controlled by an operating procedure, but a technical assessment of continued use of this method has not been made. Previously, copper contamination of the steam generators was traced to impurities picked up from temporary hoses used to connect the truck to the header. Existing procedures do not provide precautions or limitations that may prevent a recurrence.

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d. Excluding temporary modifications required to .l support the power ascension test program, there are i 64 outstanding temporary modifications with some )

installed more that four years ago. Fifty-two of  !

these 64 require design engineering decision to be  ;

made permanent or to cance!. Twenty-one are being l worked or are scheduled to be completed by 1990  !

however,10 are not scheduled for completion until i 1991 or later, and 21 have no dates currently estab!!shed.  :

i It is recognized that the piant has a program in place to  ;

minimize the use of future temporary modifications and is attempting to significantly reduce the current backlog, j Recommendation Assess the current scope of the temporary modification program and implement improvements to ensure appropriate control is +

maintained over changes to plant configuration. INPO 85-016 (T5-412), Temporary Modification Control, may be helpful in this review. In addition, review previously installed temporary modifications or startup changes made as engineering change authorizations that have been mada permanent to ensure appropriate plant maintenance procedures and vendor technical information are available. Continue to reduce the backlog of existing temporary modifications.

Response An assessment of the current scope of the temporary modification program will be performed by March 1990. As part of this assessment, existing controls will be enhanced to further ensu.e plant configuration control. INPO 85-016 (Good Practice T5-412), Temporary Modification Control, will be utilized in this review. In addition, previously installed temporary modifications that have t een made permanent will be reviewed to ensure that maintenance procedures and vendor technical information are accurate. This effort will be compteted by June 1990.

PLANT PERFORMANCE MONITORING PERFORMANCE OEL7ECTIVE: Performance monitoring activities should optimize plant reliability and efficiency.

Finding (T5.5-1) Preventative maintenance measures have not been established to identify check valve performance problems or degradation in some important systems. Recent plant check valve problems,  !

including a case of seat leakage that resulted in the residual l

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heat removal system suction piping overpressurization and two I stuck open volume control tank nitrogen supply check valves, demonstrate the need for such measures. The fo!!owing problems were noted:

a. Some important check valves that industry exprience has shown to be susceptible to failure are  ;

on;y tested by demonstrating that they open and  !

close. They are not leak checked or inspected. This j limited testing is required by the plants in-service j testing and inspection program. Dependence on the in-service testing and inspection program to monitor valve condition may not identify degraded internal  !

conditions such as worn hinge pins, loose or missing ,

non-pressure retaining Arts or erosion of internal surfaces. These conditions have been identified as l precursors to functional valve failure at other ,

l plants. Examples of check valves that are only i

tested to open and close include the following: J

1. emergency feedwater pump discharge check valves

2. residual heat removal pump discharge check '

valves

3. check valves in the emergency diesel generator air start and cooling water systems

b. Test and inspection requirements have not been specified for 64 of the 220 valves listed in the check valve monitoring program,

c. The check valve monitoring program instruction does not contain specific accentance criteria for inspections.~ Industry experience has shown that quantitative acceptance criteria for wear of internal parts is necessary to ensure check valve reliability.

d. The check valve monitoring program instruction does not contain provisions for adjusting testing frecuency based on analysis of test results.

l Additionally, a design review of check valve installations to L

ensure their appropriateness has not been conducted. These issues were addressed in SOER 86-1oromulgated in October 1986 and emphasized in an INPO letter of March 1987 to utility executive points of contact.

Recommendation include important check valvelin preventive maintenance ef forts H recommenced by 50EB 16-3. Establish inspection and testing based on industry and plant experience. Conduct a

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Page 20 design review of check valves for applicability. Use the results of this design review to further improve the preventive maintenance of check valves. EPRI Report NP-3479, j

" Application Guidelines for Check Valves in Nuclear Power  !

Plants," may be of use in this effort.

Response A review of the current check valve design and monitoring ,

program will be conducted and completed by October 1990. This 1 effort willinclude the following: j o an assessment of the appropriate preventive maintenance measures such as inspections and leak checks for the check valves in the current monitoring program o an assessment of acceptance criteria and provisions to revise test frequencies based upon inspection results

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l o a desian review of check valves for applicability with l respect to EPRI Report NP-3479 and INPO SOER 86-3.  ;

Where feasible, check valve preventive maintenance and I monitoring improvements will be completed as part of this ,

. program development effort. It is anticipated that certain '

aspects of the program improvements will be dependent upon the results of the design review for applicability. These activities will be scheduled for completion as the results of this effort become known. Preventive maintenance on selected check valves will be performed prior to the completion of the first refueling outage.

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J Finding (TS.5-2) The ability of the turbinMiven emergency feedwater pump to respond reliably to as<iemanded conditions needs to be demonstrated periodically. The plant has experienced numerous l problems with emergency feedwater system reliability such as I l

water hammer, failure of the turbine steam admission valves to  !

operate properly, and turbine overspeed trips. In addition, pump  !

survelliance tests do not provide assurance that the system will perform reliability or equipment degradation will be identified.

Examples of problems include the following:

a. The startup testing of the turbine-driven emergency ,

l feedwater pump in June 1989 did not demonstrate an l l

on-demand start. Although successful quick starts '

were demonstrated previously, system modifications had been made and the system was not in a normal idle condition prior to the starts.

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b. The station % experience with turbine-driven emergency feedwater pump problems involving -

i steam supply valves, governor oscillations, and overspeed trips demonstrate the need for periodic testing that simulates demand conditions. The-quarterly turbine-driven emergency feedwater pump-test procedure does not address the following items:

1. operability of the turbine governor ramp-up feature and the capability of the turbine governor to control the start-up transient-Governor problems in the industry have led to overspeed trips of turbine-driven pumps.

y.

2. proper sequencing of the steam supply valves under demand conditions

3. opention of the steam trap drain system under demand conditions

4. evaluation of as-found turbine speed-Absence of this information could mask a turbine speed governor problem. -

5. acceptance criteria for vibration, dif ferential pressure, flow, and speed ,

c. The turbine-driven pump overspeed trip mechanism is not periodically tested. Failure of this mechanism has caused system over-pressurization incidents at other plants.

d. Industry experience with similar turbine steam supply design configurations suggests _the need for an additional evaluation to enhance long-term reliabill_t y of the system as indicated by the following:

1. The plant has experienced a number of problems with the use of two normally closed, air-operated turbine steam supply valves in series including failure of valves to open, and uneven valve stroking and leakage that have resulted in some overspeed trips.

2. The use of an eight-second turbine ramp-up to full speed makes the turbine more susceptible to overspeed trips than other turbines in the industry which typically use 10-12 second ramp-ups. The plant experienced five overspeed trips in June 1989 with this 8-second ramp-up.

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3. The sta:Sn uses a steam trap system that I must, on4 mand, drain sufficient condensate to p event turbine wrspeed trips. A plant -

witt a simitar design recently experienced an overspeed trif on an operational demand j because the Icaps did not remove a sufficient amount of condensate.

Recommendation Revise surveillance testing procedures such that system performance is adequately demonstrated to identify equipment degradation. Specify testing requirements for the overspeed trip mechanism. Include quarterly starting of the pump under_

demand conditions after the system has been returned to normal idle conditions.

Perform post-modification testing to verify system response under design requirements such as loss of electrical power and instrument air.

Utilize industry operating experience to re-evaluate the. use of two normally closed steam supply valves and the requirement to

, establish full flow within 60 seconds. Make design changes if appropriate.

Response The turbine-driven emergency feedwater pump will be tested to demonstrate governor ramp-up, governor startup control, sequencing of steam supply valves, and operation of the steam trap drain system during post-modification testing scheduied for January 1990. Evaluation of the as-found turbine speed and acceptance criteria for vibration, differential pressure, flow and speed will be included in surveillance procedures by January 1990. A method of testing the overspeed trip mechanism will be

+ evaluated by June 1990. "he overspeed trip mechanism will be tested periodically consistent with vendor recommendations and L technical specification requirements.

l A start of the pump under demand conditions, from an initial idle condition, will be performed during plant heatup in January 1990. An evaluation of quarterly starts of the turbine-driven emergency feedwater pump and related equipment, under demand conditions, will be performed by March 1990.

Surveillance procedures will be revised to require quarterly testing if supported by this evaluation.

In addition, a reevaluation of the use of two normally closed l steam supply valves and the requirement for full flow within 60 seconds will be conducted by March 1990.

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Page 23 Results of the reviews discussed above will be summarized in the six-month status report.

Finding (TS.5-3) Performance monitoring of some important equipment may not detect long-term degradation. Undetected degradation of some important equipment can lead to unexpected failures. Examples include the following:

a. The residual heat removal, emergency feedwater, containment building spray, and safety injection pump tests do not require fixing either differential pump pressure or flow to allow trending of the other arameter. This practice could mask a pump trend acause changes in the data could be due to either system and/or pump changes.

b. The residual heat removal pumps are tested at low

- flow, about 20 percent design flow, through a recirculation path. Data from these tests may not be representative of pump performance at demand conditions. Pump deficiencies could be masked because the pump is operating in a relatively unstable region at low load. Monitoring pump performance while the residual heat removal system is operating could provide more representative pump performance data.

c. Acceptance criteria for emergency diesel generator data have not been established to indicate when corrective actions should be taken to ensure equipment reliability.

Recommendation Review and modify test procedures for important safety-related equipment to ensure that tests effectively assess equipment performance.

Response All surveillance testing is currently conducted in strict compliance with ASME XI code requirements. A review of the current program and procedures will be performed to assure that proper trending of equipment parameters occurs. Acceptance criteria for emergency diesel generator data will be established. An evaluation will be performed to determine the feasibility of changing the technical specifications to allow for a residual heat removal pump testing configuration that will yield a higher flow region. The evaluation and review will be completed by July 1990.

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Page 24 DOCUMENT CONTROL PERPORMANCE OB3ECTIVE: Document control systems should provide accurate, legible, and readily accessible information to support station requirements.

Finding (TS.7-1) Unapproved vendor technical manuals are being used to perform various maintenance activities. In addition, some of the manuals lack sufficient technical direction for the conduct of maintenance activities. The following problems were noted:

a. Some maintenance activities are not addressed by approved procedures resulting in workers using vendor manuals to troubleshoot equipment such as the plant process computer and radiation monitors.

Additionally, some work requests reviewed specifically directed the technician to use the vendor manual rather than provide approved work procedures.

b. An initial review to ensure that plant procedures Incorporate vendor operations and maintenance recommendations has not been performed in some cases. Additionally, vendor manuals are not pi.ciodically reviewed and updated to incorporate

~

current industry and vendor experience.

Management expectations described in Preventive and Corrective Maintenance Procedure MA.2-1 are that plant procedures or detailed work instructions are to be used in the conduct of plant activities and that vendor manuals are to be used for reference only.

Recommendation Reevaluate station policy concerning use of vendor manuals.

Develop procedures for appropriate maintenance activities or review, approve, and control selected manuals for the conduct of maintenance activities. Ensure selected vendor manuals reflect the most recent revisions. Consider contacting equipment suppliers on a periodic basis to ensure manuals are current. INPO 87-009 (Good Practice DE-102), Control of Vendor Manuals, may be helpful in this review.

Response The New Hampshire Yankee program for vendor manuals is presently being revised and strengthened. Part of this revision will define which vendor manuais will be available for use, how they can be used and what review process must be completed.

Full implementation of this program is scheduled for December 1990.

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OPERATIONS l CONDUCT OF OPERATIONS PERFORMANCE OBJECTIVE: Operational activities should be conducted in a manner that ensures safe and reliable plant operation. Reactor safety should be a foremost consideration in plant operations. Management policies and actions should actively support this operating philosophy.

Finding (OP.2-1) Improvements are needed in consistently exercising positive control over operational activities. Plant events indicate shif t personnel need to pay closer attention to detail and that more direct involvement by operations management and supervision is t

needed during plant evolutions. The following are examples of problems noted:

a. In September 1989, approximately 200 gallons of water was drained from the refueling water storage .

tank (RWST) to the spent fuel pool while performing a system lineup. A modified lineup approved by the

- unit shift supervisor was used that resulted in a gravity flow path from the RWST to the spent fuel pool because of the sequence of valve operations specified.

b. In August 1989, while water was being pumped from the spent fuel pool to the RWST, approximately 50 gallons drained to the A residual heat removal vault. Operators thought the valve from the RWST l was danger tagged shut, but did not realize that the

!- governing tagout had been modified and the valve L had been opened. This allowed water to drain through a drain valve the operators thought was l

isolated from the flow path,

c. In August 1989, approximately 2,000 gallons of water was drained from the condensate storage tank to the i floor drains via three open drain valves. A tagging order was being modified to allow wet layup of the condensate and feedwater system when the draining occurred. The prerequisite valve lineup for the layup procedure, which would have verified closure of the drain valves, had not been performed prior to commencing modification of the tagging order.

l l d. In July 1988, the valve from the RWST to the suction L

of the A RHR pump was opened while the valves

! from a reactor coolant system (RCS) loop hot leg j' were open. The alarm occurred and the operator I shut the valve. In the one minute it took the valve to shut,5,000 gallons of water drained from the RWST to the RCS.

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e.. In October 1988, during the performance of a surveillance test, the valve from the RWST to the suction of the B RHR pump was opened while the valves from an RCS toop hot leg were open. The . ,

alarm occurred and the operator shut the valve. In the one minute it took the valve to shut,7,000 ,

gallons of water drained from the RWST to the RCS, raising pressurizer level from 25 percent to 80:

percent. T i

f. During performance of a natural circulation test in June 1989, pressurizer level decreased below the value in the test procedure requiring a manual reactor scram. The reactor was not scrammed as required but was operated for some period outside the limits established by the governing procedure.

Although management was observing the test, they did not direct that the reactor be tripped.-

Additionally, measures were not taken to ensure that-suf ficient training for the natural circulation test -

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L . held with appropriate operations personnel prior to' commencing the test. .~ (. ,

l Recommendation Re-emphasize station policy that establishes the Operations L

Department as the lead organization for plant operational evolutions, including startup testing. Increase operations management involvement in operational activities to identify l and correct weaknesses in operating practices. Provide operators with a clear understanding of the following:

a. the need for attention to detail

b. the need for positive supervisory / management control of operational activities

c. developing an inquisitive attitude, that helps identify adverse consequences and corrective actions if evolutions do not occur as planned Response The executive director of nuclear production has initiated meetings with licensed shift members during their training weeks to reinforce the need for attention to detail, and to l

reemphasize the role of the Operations Department. An organizational change has been approved to supply more staff support within the Operations Department and allow more operations management involvement in operational activities.

This organizational change will be staffed in December 1989.

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Page 27 The policy on establishment of operations as the lead organization for all operating evolutions including testing has been verbally communicated within the station organization and will be reemphasized in writing by December 1989.

PLANT STATUS CONTROLS PERFORMANCE OBJECTIVE: Operations personnel should be cognizant of the status of plant systems and equipment under their control and should ensure that systems and equipment are controlled in a manner that supports safe and reliable operation.

Finding (OP.3-1) The station equipment tagging and isolation procedure needs improvement to ens're protection for personnel and equipment. The foLwing problems were noted:

a. Station procedure MA 4.2," Equipment Tagging and Isolation," does not require da.'ger tags on control switches when removing a component from service.

For example, tagging order 89-3029 directed that the breakers for the steam generator bottoms pumps be opened, but the pump's control switches were not tagged out. Although extension control tags are used on control switches to advise operators that a component is tagged out, they are not required as part of component isolation.

Failure to tag out a component's control switch can result in personnel injury or equipment damage if someone attempts to operate the component's electrical supply breaker while it is being removed or returned to service,

b. Procedure MA 4.2 does not contain guidance for the proper sequence of component isolation and restoration. The following are examples of sequencing problems that were noted:

1. The tagging orders for residual heat removal pump 1-RH-P8A (89-1882) and charging pump 1-CS-P2A (89-3119) directed that their suction valves be closed before their discharge valves. Industry experience has shown that this practice could result in equipment damage or personnel injury from overpressurization of the suction piping.

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Page 28

2. Tagging order 89-2031 directed that the B service air compressor discharge valve be shut before the electrical supply breaker was opened. Standard industry practice is to first de-energize a component's prime mover to prevent the component from being started while it is mechanically isolated.

3. Tagging order 89-3119 directed that charging pump 1-CS-P2A electrical supply breaker be opened and racked out prior to positioning and tagging its control switch. This creates the possibility of the breaker being remotely operated while the worker is attempting to rack the breaker out.

c. Procedure MA 4.2 requires audits of tagging orders on an annual basis or following a refueling outage.

This frequency is insufficient to ensure that potential tagging problems are identified in a timely manner. Standard industry practice is to audit tagging orders on at least a quarterly basis.

Recommendation include requirements in procedure MA 4.2 for tagging component control switches. Include guidance in MA 4.2 for the proper sequence of removing a component from service and returning it to service. Conduct tagging order audits on a frequency that assures timely identification of potential tagging problems. INPO 85-017, Guidelines for the Conduct of Operations at Nuclear Power Stations, and 87-002 (Good Practice OP-203), Tagging Procedures for the Protection of Personnel, Components, and Systems, should be of assistance in this etfort.

Response A review and revision of station procedure MA 4.2 will be accomplished. INPO 85-017, Guidelines for the Conduct of Operations at Nuclear Power 5tations, and 87-002 (Good Practice OP-203), Tagging Procedures for the Protection of Personnel, Components, and Systems, will be used as part of this effort. This review and revision will include the requirement to tag component control switches, the sequence of component removal and return to service and the frequency of tagging order audits. The review of the current procedure with suggested modifications will be completed by June 1990. The subsequent procedure revisions and training will be completed by September 1990.

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Finding (OP.3-2) The independent verification pre gram needs upgrading to include '

all components important for rol able plant operation.

Additionally, program requirements need improvement to ensure that independent verification is performed when appropriate.

The following problems were noted:

. a. Many components important for reliable plant operation are not included in the component-configuration list as indicated by the iollowing examples:

1. The position of the turbine-driven emergency' feedwater pump steam admission valves (MS-V127,128,393,394, and 395) are not independently verified. Mispositioning of these valves could result in failure of the system to automatically start if required.

2. Excess letdown valves CS-HCV-123, CS-V172, and CS-V175 are not independently verified.

Excess letdown is necessary to control pressurizer level during a loss of normal-

. letdown,

b. Independent verification is not performed in modes 5 and 6 for components that are not required to be operable in these modes. Standard industry practice is to perform' independent verification on all specified components in all modes to ensure that the status of safety-related and other significant systems is consistently tracked and known.

c. Independent verification is not performed when removing a component from service for maintenance because it is not required by operations procedure OP 10.1, " Component Configuration Control," under these circumstances. This is contrary to the station management manual which requires that independent verification be performed when a " system or component is being removed from service under a tagging order." Industry experience has shown that failure to independently verify components when removing them from service can result in the wrong component being disabled.

Recommendation Upgrade the component configuration list to include all components necessary for reliable plant operation. Upgrade procedure OP 10.1 to require independent verification in all modes and when removing a component from service. INPO documents85-017, Guidelines for the Conduct of Operations at Nuclear Power Stations, and 87-003 (Good Practice OP-214),

Independent Verification, should be of assistance in these efforts.

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. SEABROOK (1989)1 Page 30 Response INPO 85-017, Guidelines for the conduct of Operations at l Nuclear Power Plants, and INPO 87-003, independent verification, will be reviewed and the need to change or modify .

existing practices will be determined. The evaluation and -

determinations will specifically include reconsideration of the .

components included on the component configuration list, the independent verifications to be performed during modes 5 and 6 and the independent verification requirements associated with removing a component from service. These reviews and determinations, including changes or modifications to existing practices, will be completed by May 1990. A summary of the .

reviews and resulting actions will be provided in the six-month status report.

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OPERATIONS PROCEDURES AND DOCUMENTATION PERFORMANCE OBJECTIVE: Operations procedures and documents should provide appropriate direction and should be effectively used to support safe operation of the plant.

Finding (OP.5-1) Many plant operating procedures contain technical deficiencies and human factors problems similar to those that have caused operator errors in the industry. The following problems were noted:

a. Many procedures provide insufficient technical guidance to assure consistent performance of required actions. For example,051000.10

" Operation at Power," directs the operator to monitor operation of the feedwater heaters, but does not identify specific parameters to be monitored.

051201.01,"RCS Leak," directs the operator to shut down the continuous on-line purge system, but does not provide instructions either in the body of the procedure or by reference to another procedure.

b. Some procedures provide improper technical guidance. For example,051000.07," Approach to Criticality," directs alternate operator actions if criticality is achieved at greater than 500 percent milli-rho (PCM) above the estimated critical position (ECP). The more appropriate approach would be to direct these actions before exceeding 500 PCM

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Page 31 above the ECP if criticality is not achieved. In addition,051000.07 directs the operator to begin control rod withdrawal prior to giving instructions limiting reactor startup rate.

c. Many notes and cautions contain instructions that should be included in procedure steps. For example, the caution preceding step 2 in ON1233.01, " Loss of Condenser Vacuum," directs the operator to trip the turbine if condenser vacuum is less than 25 inches of mercury after load reduction to 360 MWe. .

Instructions contained in notes and cautions could be overlooked if notes and cautions are scanned.

d. Some notes and cautions are placed af ter the steps to which they apply. For example, in 051008.01,

" Chemical and Volume Control System Makeup Operations," steps 6.7.11 and 6.8.12 direct the operator to place the boric acid blender in service.

The notes that follow advise the operator that valve leakage may cause changes in reactor coolant system boron concentration. Placing notes and cautions

. after steps may result in the operator not being aware of important information until af ter a step is performed.

Recommendation Correct problems such as those noted above during the periodic review process. INPO 84-020 (Good Practice OP-210), Review of Operations Department Procedures, could be of assistance in this ef fort.

Response In order to assure accurate and reliable procedures, feedback from all Operations Department personnel is considered vital. A memorandum to all shif t superintendents will be issued by December 1989 to highlight the need for this feedback. The operations procedure group, which is currently being established, will review all recommendations for improvement of operations procedures. INPO 84-020 (Good Practice OP-210), Review of Operations Department Procedures, will be reviewed as part of this etfort.

Routine enhancements to operating procedures will be accomplished during the bi-annual review process. Full implementation is expected by December 1991.

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Page 32 MAINTENANCE MAINTENANCE ORGANIZATION AND ADMINISTRATION PERFORMANCE OBJECTIVE: The maintenance organization and administration should ensure effective implementation and control of maintenance activities.

Finding (MA.2-1) The materiel condition of some plant equipment and piping is degraded due to corrosion. In addition, many equipment deficiencies are not identified in the work control system. The following are examples of problems noted:

a. The original protective coating for the main condenser water boxes and circulating water inlet and outlet pipes has been removed due to problems with adhesion. As a result, these components nave extensive surface corrosion pitting.

b. All circulating water pump suction and discharge piping and flange bolts are rusting. General

. deterioration of protective coatings on piping, flanges and equipment mounting bedplates is evident,

c. The majority of exposed surfaces on the component cooling piping inside the containment building are covered with flaking corrosion deposits,

d. Most surfaces in the chlorination building including pumps, valves, and piping are corroding badly due to chemical residue and lack of protective coating.

e. Nearly 50 percent (18 of 38) of a sample of equipment deficiencies checked were not identified in the work control system. Examples of deficiencies not in the work control systems include the following;

1. excessive boric acid crystal buildup on core spray and residual heat removal system valves

2. excessive packing leakage from valves

3. seat leakage on several valves

f. Equipment deficiencies are not routinely identified or tagged in the field. A formal system or process for marking materiel discrepancies has not been developed. This contributes to uncertainty of station personnel as to which equipment deficiencies have been identified for corrective action. A deficiency tag program is planned for implementation by the first refueling outage.

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Page 33 It is recognized that a recoating program is in progress current!y focused on the primary auxiliary building.

Recommendations Place additional emphasis on identifying and correcting plant equipment and piping corrosion problems. Review the adequacy of existing work scope and schedules for the recoating program. Establish clear expectations for identifying equipment deficiencies, and convey these standards to station personnel.

Complete plans for implementation of a deficiency tagging program. INPO 85-038, Guidelines for the Conduct of Mainte-nance at Nuclear Power Stations, should be used in this effort.

Also, INPO 87-023 (Good Practice MA-312), Plant inspection Program and INPO 83-045 (Good Practice MA-301), Plant Materiel Deficiency Identification, may be of assistance in this area.

Response The station currently has a five-year plan to paint all building areas. Implementation of this plan was started in February 1989. A review of the schedule and resources assigned to this program will be completed by April 1990. The results of this review and resulting actions will be provided in the six-month status report.

Station management will stress the importance of routine reporting of problems using the work request system. The Seabrook Station Management Manual (SSMM) will be reviewed and changed as necessary to ensure that management expectations of station personnel are clear. These changes will be completed and the str. tion will reinstitute by January 1990 its program for supervisory walkdowns which is based on INPO 87-023. The new program will assure that reported deficiencies are resolved in a timely manner. A deficiency tagging system based on INPO 85-038 and INPO 87-045 will be added to the work control program. This system will complement and enhance routine reporting and supervisory walkdown reporting.

These changes will be made by September 1990.

WORK CONTROL SYSTEM PERFORMANCE OBJECTIVE: The control of mamtenance work should support the completion of tasks in a safe, timely, and efficient manner such that safe and reliable plant operation is optimized.

Finding (MA.3-1) Inadequate scheduling of maintenance activities often results in job deferrals, delays, and inefficiency. Current scheduling

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Page 34 i

R generally'does not include routine maintenance tasks such as technical specification surveillances, many preventive  !

maintenance activities, and a high percentage of corrective' l

!' maintenance work list items. In addition, the availability of ; I L spare parts is often not confirmed prior to scheduling work-activity. Problems noted include the followings

a. Many preventive maintenance activities are not scheduled. This sometimes results in repetitive equipment clearances or deferral of the activity.

For example, the 1 A RHR pump motor preventive maintenance actions were recently deferred because -

they were not accomplished during the A train outage due_to a scheduling oversight. . ,

l b. Individual maintenance shop work lists contain large ,

h numbers of corrective maintenance activities that are not scheduled. As a result, the majority of these tasks are not visible to plant management or to the ,

operations work control center. Interviews with <

operations work control center personnel indicated a general unfamiliarity with tasks that were not  :

, currently in progress. Consequently, these pending .

tasks receive low priority and support. Work list items are generally treated as fill-in work.

c. Spare parts are not routinely verified to be available and staged prior to scheduling maintenance work. As -

a result, many jobs are started and subsequently- -

stopped due to the lack of spare parts and materials as indicated by the following examples:-

1. Work on a cable spreading room return fan could notpart required be motor p(erformed starter)when beingplanned due to a held by a non-conformance report.

2. Work on an SMB-000 motor-operated valve could not be performed as planned due to a tee vent not being available.

3. Capping of spare cables inside a shutdown panel had to be deferred due to lack of cable end caps.

Recommendations improve maintenance scheduling to reduce deferrals and coordination problems. Expand the scope of the scheduling process to include technical specification surveillances, preventive maintenance, and corrective maintenance activities requiring coordination, interface, and support. Ensure availability of spare parts and consumables prior to scheduling activities. INPO 85-038, Guidelines for Conducting Maintenance at Nuclear Power Stations, should be used in this area.

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' Response A requirement will be added to the scheduling programs to j include, in the P-2 scheduling network, any maintenance activities that require tagging. This change will serve _to ensure that the operations work control desk and other support functions are aware of upcoming planned work. INPO 85-038, Guidelines for the Conduct of Maintenance at Nuclear power Station, will be reviewed for scheduling guidance, and changes in scheduling practices will be made as necessary. These changes will be made by July 1990.

Current programs require pre-staging of materials for installation of design changes. Pre-staging of materials for known work to be done for forced outages and planned maintenance outages will be required by January 1990.

Pre-staging will be done for spare parts and jobs requiring large quantities of consumables. Consumable quantitles normally carried in inventory will not be pre-staged. .

MAINTENANCE FACILITIES AND EQUIPMENT PERFORMANCE OBJECTIVE: Facilities and equipment should effectively support the performance of maintenance activities.

Good Practice (MA.8-1) The station has developed an effective diagnostic' test system for motor-operated butterfly valves. The system uses strain gauge technology to measure valve operating shaft forces. The system has also been successfully used on rising stem motor-op-erated valves under laboratory conditions. The compactness and repeatability of the system are improvements over equipment commonly used in the industry. Other advantages include the following

a. Less valve actuator disassembly is required for system set-up and test.

b. Test equipment set-up time is reduced by at least 30 percent.

c. Strain gauges may be left on the motor-operated valve between tests.

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Finding (MA.8-2) in the long term, maintenance facilities appear inadequate to '

accommodate shop work on contaminated components and

- decontamination of plant equipment. - Shop work on contaminated equipment is currently performed either in tempo .

rary enclosures or areas in the " cold" shop are zoned for contaminated work with the result that clean work areas are over crowded. The decontamination room is only equipped for manual decontamination of small components. - In addition,:

limited space is available for tool issuance and storage. -The following additional problems were noted during tours: -

a. Recent work on the IB residual heat removal pump -

required zoning of approximately half of the maintenance shop as a contaminated area. This reduced work capability within the remaining shop space.

b. The only decontamination equipment currently installed in the decontamination room is a two-basin sink to be used for manual decontamination of relatively small items. Commonly used equipment such as ultrasonic cleaners, freon cleaners, and/or abrasive cleaners is not available to support major decontamination of forts.

c. The instrument and control shops are cramped and overcrowded. Sufficient storage space is unavailable for vendor manuals, test equipment, and tools. Also, areas have not been allocated for contaminated instrument work.

d. Interim facilities for electrical maintenance are -

planned for an existing temporary building. This facility will not support work on large electrical-components including many plant motors and circuit breakers and will have limhed utility services.

e. Issue points for both contaminated and clean tools have insufficient storage and staging capacities.

These areas are congested and contain specialty tools, measuring and test equipment, consumable supplies and heavy rigging equipment. Normally, these items are separated for ease of identification and handling. Plant personnel have difficulty identifying and retrieving needed equipment.

Additional tools'and rigging were stored in work areas throughout the plant.

A five-year plan has been develeped, but specific approvals and scheduling to correct these deficiencies need to be developed.

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Recommendation- ' over time, provide additional permanent maintenance shop and decontamination facilities. Ensure that plans provide adequate facilities to support extended plant operation and major outages. INPO 85-038, Guidelines for the Conduct of Mainte-nance at Nuclear Power 5tations, and EPRI NP-4330, Human Engineering Design Guidelines for Maintainability, should be

. used in establishmg these facilities.

Response A five-year plan has been developed to provide permanent, expanded maintenance and decontamination facilities. Those

' facilities scheduled for implementation in 1990 have been included in the budget and those projects stated for implementation in future years will receive final approval as current analyses and engineering activities for these f acilities are completed. The analyses will include consideration of extended plant operations and major outage requirements. In addition, guidance contained in INPO 85-038, Guidelines for the Conduct of Maintenance at Nuclear Power Stations, and EPRI NP-4350, Human Engineering Design Guidelines for Maintainability, will be used in the analyses.

MAINTENANCE PERSONNEL KNOWLEDGE AND PERFORMANCE PERFORMANCE OBJECTIVE: Maintenance personnel knowledge and periormance should support safe and reliable plant operation.

Finding (MA.10-1) Maintenance work assignments are made without reference to task qualification of workers. Industry experience has shown that this practice may result in tasks being performed incorrectly. In addition, deficiencies were noted in the qualification process and content of continuing training. The following problems were observed:

a. Work assignments are based on the supervisor's knowledge of worker capabilities rather than on task qualification of workers. While few performance problems by maintenance personnel were observed, industry experience has shown that this practice can result in assigning people to perform tasks in the plant for which they are unqualified.

b. Approximately 60 percent of the on-the-job training qualification standards for initial training of maintenance groups have not been developed.

Examples of tasks for which qualification standards are not complete include the following:

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l. use of volumetric flow unit by the measuring and test equipment calibration group

2. performance of environmentally qualified wire splices by. instrumentation and control technicians and electricians

3. maintenance of relief valves by mechanical =

maintenance personnel in addition, maintenance training materials presently developed are not in use.

c. The following deficiencies were noted in the maintenance continuing training program:

1. Many topics identified by maintenance and training management in 1988 for inclusion in 1989 continuing training are not scheduled to be delivered to the respective disciplines. For example,23 of 43 courses identified by

-instrumentation and controls supervision for

- continuing training to upgrade the knowledge and skills of technicians are not scheduled to be given in 1989. These courses include training on safety-related equipment st.ch as reactor vessel level system, loose parts monitoring system, and process control systems.

Forty of 33 courses identified by training, mechanical, and electrical supervision for inclusion in the 1989 training program are not scheduled. These include batteries, relays, -

advanced air conditioning and ventilation systems, reactor coolant pump seals, confined space entry, analytical instrumentation, and diesel generators.

2. Information on plant and industry operating experience is provided to maintenance personnel entirely through a required reading program. Industry experience has shown this method to be less effective than some others in conveying operating experience information.

It is recognized that developmental work is presently underway to correct several of the problems noted above.

Recommendation Implement a qualification program for maintenance personnel and assign only personnel qualified for a task to work independently. Continue development of the initial and l

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continuing training material for instrumentation and control, ,

mechanical and electrical groups. . Implement the on-the-job .

training modules as they are approved for implementation.

Implement a performance-based continuing training program that includes the topics requested by line management and lessons learned from operating experience. INPO 86-018, Guideline for Training and Qualification of Maintenance Personnel, should be of assistance in this effort.

Response A qualification manual has been developed to provide direction for consistent qualification of technicians, including i

maintenance personnel. The Station Maintenance Manual, Section 1.12, currently provides direction for assignment of '

. qualified er trained personnel to accomplish maintenance tasks. This manual will be reviewed and revised as necessary to '

assure that only quallfled personnel will be assigned to work independently. This review and revision will be completed by March 1990.

- Training program development is continuing. OJT modules are being developed and OJT instructors are being trained. These modules will be implemented as they become available.

. Continuing training on operating experience is under development and scheduled for delivery each quarter in 1990.

INPO accreditation of the mechanical, electrical, and instrument and control training is currently on schedule. INPO 86-018, Guideline for Training and Qualification of Maintenance '

Personnel, will be used as part of this effort.

The maintenance group has qualified instructors and evaluators for all job performance measures approved to date and is prepared to qualify instructors and evaluators for OJT training modules as they are made available for implementation.

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RADIOLOGICAL PROTECTION SOLID RADIOACTIVE TASTE PERFORMANCE OBJECTIVE: Solid radioactive waste controls should minimize the volume of radioactive waste and ensure safe transportation of radioactive material.

1 Finding (RP.7-1) Implementation of the solid radioactive waste program has been  !'

Insufficient to fully support plant needs. Problems observed included the following:

a. A program to minimize the volume of material taken -

into the radiologically controlled area (RCA) and to minimize the volume of dry active waste leaving the RCA has not been implemented. An excessive amount of equipment, tools, and material was observed being taken into the RCA. This includes power cords, air hoses, hand tools, chain falls, and multiple copies of procedures and work orders.

Af ter plant operation, it will be dif ficult to release this material as clean due to the need to survey all surfaces and the lack of facilities to decontaminate this volume of material.

b. Tools and small equipment in the RCA are not uniquely identified to clearly distinguish them from similar items intended for non-radiologically controlled areas of the station. As a result, workers may not be aware of the potential hazard associated with the use of these tools and there is an increased potential for releasing these tools outside the RCA.

c. Specific plans for temporary storage of all solid radioactive active waste generated at the station have not been formalized or approved. The station is currently not permitted to ship solid radioactive waste off site.

d. Trained personnel are not available to process wet and dry radioactive waste material.

Recommendation implement a program to minimize the volume of material taken L into the RCA and to control tools and equipment used in the RCA. INPO 89-008, Control of Tools and Equipment in Radiolostically Controlled Areas, should be of assistance in this effort. Additionally, formalize plans for the temporary storage of solid low level waste generated during operation and ensure qualified personnel are available to process this waste.

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Pageel Response A comprehensive radioactive waste program will be developed by January 1990 and will include staffing and training requirements. A training program for radioactive waste technicians has been established and will be fully implemented in the first quarter of 1990.

Transfer of the chairmanship of the established radwaste minimization committee from nuclear services to station staff (Radwaste/ Utilities Department supervisor) will be accomplished by January 1990. A final minimization program and final plans for temporary storage of solid low level waste will be in place by April 1990. In the interim, information will be distributed to the plant staff as to the expectations and methods to be use ' to minimize waste. Review of INPO 89-008, Control of Tools and Equipment in Radiologically Controlled Areas has been accomplished. An ongoing review of potential identification methods is currently in progress. Tools and small equipment intended for "RCA USE ONLY" will be clearly identified and distinguishable from similar items intended for non-radiologically controlled areas. This marking will be completed prior to the first refueling outage currently scheduled for March 1991.

RADIOACTIVE CONTAMINATION CONTROL PERFORMANCE OBJECTIVE: Radioactive contamination controls should minimize the contamination of areas, equipment, and personnel.

Finding (RP.9-1) The station's contamination control program needs strengthening to prevent the spread of contamination after sustained plant operation. In addition, the potential exists for cross-contamination of personnel at the access and egress points of the radiologically controlled area (RCA). The following are examples of problems observed:

a. There are many leaks in plant systems likely to become contaminated after plant operation. Leaks were observed in the residual heat removal, boron recovery system, safety injection, and containment spray systems. Due to limited station operation, most systems currently have little or no internal contamination. Af ter operation, these systems may contain internal contamination.

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b. Leak containment devices and temporary equipment-

• drain lines have been installed throughout the plant.

Some of these devices are deteriorating, and others are constructed of material that could easily rupture or are not secured to ensure system leakage is directed into the floor drains. The installation of these devices is not controlled or tracked to ensure proper installation and maintenance.

c. Many installed equipment drain lines do not terminate over the floor drains. Flow.from these lines would spread onto the floor resulting in unnecessary contamination of the areas.

d. Current traffic' flow patterns and equipment placement in access control and the dress out area provide potential for cross contamination of personnel entering and exiting the RCA. The current arrangement of these facilities does not separate entry and egress. As a result, individuals entering _

the RCA must cross the path of potentially contaminated individuals who have not yet used the

. whole body friskers.

Recommendation Take action to improve the station's contamination control program including the followings

a. Repair known leaks in potentially contaminated -

systems prior to sustained plant operation.

b. Consider instituting controls over the installation of leak containment devices and temporary equipment drain lines, including installation and tracking of installed devices and periodic monitoring to ensure integrity.-

c. Correct improperly installed drain lines using temporary or, where possible, permanently installed connections to floor drains,

d. Implement necessary modifications to access control and dress out areas to minimize the potential for cross-contamination.

Response All known leaks in potentially contaminated systems will be prioritized and corrected. The intent is to repair all known leaks in the RCA prior to entry into mode 4, currently scheduled for January 1990. Periodic monitoring of leak containment devices will be performed by a new procedure scheduled for development and implementation by December 1989. Additional controls are currently being incorporated into the existing RWP procedure for removal of leak containment devices. This action

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Page 43 is scheduled for completion and implementatl'on by January  ;

1990. A request for engineering services (RES) has been ,

initiated requesting engineering to develop a generic

-. specification and/or minor modification to allow the installation of drain lines to floor drains where possible. An RES has been submitted to engineering to modify the RCA access point and dress-out areas to provide better traffic control and limit.

potential for cross-contamination. Both RES responses are

-expected by June 1990. A permanent and final redesign of the

'i- control point will occur as part of the five-year facilities plan.

Interim solutions to prevent cross-contamination will be '

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. evaluated and implemented prior to the first refueling outage.

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. CHEMISTRY CHEMISTRY CONTROL

. l l PERFORMANCE OBJECTIVE: - Chemistry controls should ensure optimum chemistry

. conditions during all phases of plant operation.

Good Practice (CY.3-1) An effective biological monitoring program has been developed for the station circulating and service water systems. The program includes test specimens, bio-plates, and bio-boxes that are introduced into various points in the systems. On a prescribed frequency, typically weekly, the specimens are removed and screened for biomass under a microscope. Based on the results, adjustments are made to the chlorination scheme for improved control. Further, for more positive indication of treatment effectiveness, the specimens are re-inserted into their respective locations where they are reviewed at the r; ext scheduled frequency.

The program has been effective in protecting plant components i

from bio-fouling and in optimizing the plant chlorination processes.

n Finding (CY.3-2) The analytical performance of some laboratory instruments and on-line chemistry analyzers is insufficient for measuring low levels of some impurities. . Problems noted include the following:

a. The station's lower limit of detection for steam generator blowdown samples is approximately ten times higher than the industry average. - For example, chloride and sulfates-two corrosive contaminants that contribute to intergranular stress corrosion cracking--cannot be detected by the i

station using the ion chromatograph at levels below 10 and 50 parts per billion (ppb), respectively.

Similarly, sodium levels cannot be detected using the atomic absorption unit with graphite furnace at levels below 12 ppb. Typical industry lower limits of detection for these impurities using the same analytical equipment are in the one to two ppb l range. The station has demonstrated the ability to I

measure at the one to two ppb level for these I

contaminants in other high purity water samples (e.g., makeup water treatment system effluent).

Identifying impurities in steam generator blowdown )

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at the one to two ppb level enhances the ability to diagnose the source and to take timely corrective action for the protection of the steam generators.

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o b. Sample temperature conditioning is insufficient for on-line analyzers in the makeup water treatment i system and the condenser hotwell. Typical sample t temperatures in the makeup system are five degrees or more lower than the 25 degrees centigrade at which the data is reported. These colder

! temperatures tend to creste non-conservative .

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responses to alarm or trip setpoints for the makeup demineralizers. As temperature decreases from 25 - '

degrees centigrade, analyzer indications will reflect a value much lower than actual, which may allow the production of inferior quality water without alarm or trip response. Additionally, hotwell sodium and cation conductivity analyzers are not equipped with

< sample coolers to reduce temperatures to the recommended 25 1 2 degrees centigrade. Without -

proper sample temperature conditioning, these -

analyzers can produce readings that are biased high, thus masking real problems, such as condenser tube leaks. i Recommendation Upgrade analytical sensitivities for routine plant sample streams with particular emphasis on the parameters noted above.

Provide sample temperature conditioning for on-line analyzers.

l Response The Chemistry Department has changed its protocol for steam-side sampling to ensure optimum analytical sensitivities with the-present laboratory equipment. Ion chromatography samples will be passed through a cation. column before they are analyzed. -

This gives a sensitivity for chlorides and sulfates of one ppb.

Sodium analyses will be run on the atomic absorption furnace which has a sensitivity of one ppb. All other analytical sensitivities will be reviewed on an ongoing basis to optimize them to the greatest extent possible. First and second line supervision is visiting operating nuclear stations in the northeast to observe their analytical methods and sensitivities.

Techniques that are observed will be evaluated for use at Seabrook Station.

L Chemistry has written a request for engineering services (RES)

L for an engineering evaluation to add sample temperature l conditioning for hotwell samples piped to CP186. Additionally, chemistry has written an RES for an engineering evaluation to add sample temperature conditioning to the water treatment system effluent samples. The results these engineering evaluations are expected by June 1990 with implementation expected no later than the first refueling outage, currently scheduled for March 1991. l 1

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Page1 APPENDIX I OUTSTANDING RESPONSE ACTIONS FROM PREVIOUS EVALUATION (S)

Appendix I is a listing of findings from previous evaluations where corrective actions have not been completed, but are progressing on a reasonable schedule. A current status, as determined by the INPO team, is also provided.

There are no Appendix I Items for this evaluation.

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Appendix !!L Page1-APPENDIX D ADDITIONAL SUPPORTING DETAILS Appendix 11 provides additional information concerning selected findings which should be useful in determining corrective action.

OPERATING EXPERIENCE REVIEW The following Significant Operating Experience Report (SOER) recommendations were evaluated as not satisfactory and further actions are needed:

SOER 81-9 " Desiccant Carry-over to the Instrument Air System" Recommendation 2b Perform regularly scheduled maintenance on the downstream filter element of the instrument air system.

Present Status: Repetitive task sheets (RTS) for scheduling preventive maintenance activities have not been developed for individual

. component filters (i.e., for equipment in the plant). RTSs do exist for the skid mounted pre-filters and post-filters.

Actions Planned to Close Recommendation: The Maintenance Department will develop repetitive task sheets for the downstream filter elements by March 1990.

SOER 82-9 " Turbine Generator Excitor Explosion" Recommendation 1: Ensure procedures address monitoring and trending of hydrogen gas usage. Procedures should include guidance for actions to be taken when usage exceeds a specified level.

Present Status: Trending of hydrogen gas usage is not performed. A procedure has not been developed to address actions required when usage exceeds a predetermined level. An upper limit of gas usage has not been defined.

Actions Planned to Close Recommendation: A hydrogen gas usage trending program will commence upon achievement of full power. The trending program will be included in the technical support monitoring program. Guidance will be provided addressing action required when usage exceeds a precetermined level.

SOER 82-12 " Steam Generator Tube Ruptures Caused by Loose Parts on Secondary Side" Recommendation 5: Train plant personnel (including contractors) involved with steam generator repair and maintenance on the importance of preventing miscellaneous objects from being left in steam generators.

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Present Status: Training has not been developed or conducted. A training  :

development request, TDR 89-016, has been issued to develop i this training program.-

Actions Planned to Close Recommendation: Training development request 89-016 is ongoing. A complete s revision to the lesson plan for MA 3.3, " Housekeeping," will be developed by December 1989 for future initial training.

Continuing training on this SOER will be conducted during the ,'

first quarter of 1990.

SOER 82-13 " Intrusion of Resin,1.ubricating oil, and Organic Chemicals into Reactor

- Coolant Water

• Recommendation 11: Consider additional process steps to remove organic L contamination if chronic contamination by organics exists.

i Present Status: Design change request DCR-00238, issued in 1986, has not been implemented and no implementation date has been assigned.

This DCR addresses the installation of a check valve in the fuel pool drain line to prevent backflow from the floor drain system r mto the fuel pool.

Actions Planned to Close Recommendation: Design coordination report 86-238 will install a check valve in the refueling cavity drain line. Implementation of the design change is scheduled for the first refueling outage (March 1991).

t Recommendation 12: Train station employees on the potential adverse effects of introduction of resin, oil, and chemict.ls into the reactor coolant sy. stem.

Present Status: Expendable material training, including chemical control, is not '

included in recurring General Employee Training. Beginning in December 1989, General Employee Training will include a segment of the "whats" and " whys" of the program and will be presented to all new personnel.

Actions Planned to Close Recommendation: Training development request 89-107 is ongoing. A complete revision to the lesson plan for MA 3.3, " Housekeeping," will be developed by December 1989 for future initial training.

Continuing training on this SOER will be conducted during the first quarter of 1990.

l General Employee Training lesson plan S-35 will be revised to

reference this SOER for initial and continuing training by December 1989.

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Appendix 11 l Page 3 Training for the Chemistry Department is in progress. This  !

SOER recommendation will be formally incorporated into i Chemistry Department continuing training by December 1990.

Recommendation 13: Caution contractor personnel about the potential oflects of  !

usage of uncontrolled chemicals.  !

j Present Status: Training has not been conducted for contractors on the station upendable material control program, including chemical control. A revision to the station General Employee Training module has been draf ted for presentation beginning in December 1989 that includes the pertinent aspects of the program.

1 Actions Planned to l Close Recommendation: Training development request 89-107 is ongoing. General Employee Training lesson plan 5-35 will be revised to reference 1 l this SOER for initial and continuing training by December 1989. This training will be provided to all contractors by May 1990.

SOER 82-15 " Freezing of Safety- related Equipment" Recommendation 1: Review critical system instrumentation and equipment that may -

be affected by severe cold weather to identify needed modifications. ,

Present Status: The station has not developed a program to ensure adequate l

freeze protection of affected systems. This problem was recognized by plant management during the 1987 evaluation.

This item has been tracked on the integrated commitment ,

I tracking system since 1986 as an open item.

Actions Planned to Close Recommendation: The design of critical instrumentation and equipment was reviewed for severe cold weather provisions during the construction phase subsequent to the release of NRC I&E Buitetin 79-24. Since that time, no freeze up of safety-related instrumentation or equipment has occurred as a result of a design deficiency. NHY maintains a " Freeze Log" in the control room which is reviewed annually to assess the need to modify systems or structures.

Recommendation 2: Ensure plant procedures include provisions for protecting l critical systems.

Present Status: The station has not developed a program to ensure adequate freeze protection of affected systems.

Actions Planned to Close Recommendation: Procedures addressing freeze protection of critical system instrumentation and equipment have been implemented.

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Appendix il Page 4 Recommendation 3: Provide seasonal reminders to operations personnel concerning freezing protection of safety-related equipment.

Present Status: The station has not developed a program to ensure adequate freeze protection of affected systems.

Actions Planned to Close Recommendation: A general procedure to identify plant readiness for cold weather operations is under development and will be implemented by March 1990. A reminder will be sent to operations personnel concerning freeze protection by December 1989.

Recommendation 4: Provide continuing training on lessons learned from cold weather operation.

Present Status: The station has not developed a program to ensure adequate freeze protection of affected systems.

Actions Planned to Close Recommendation: Training development request 89-284 will incorporate ongoing cold weather lessons learned at Seabrook into initial and

, continuing training by June 1990.

Recommendation 3: Recalibrate thawed instrument lines prior to returning to service.

Present Status: The station has not developed a program t'o ensure adequate freeze protection of affected systems.

Actioris Planned to Close Recommendation: Standard work practice IC-006 has been issued to address maintenance guidelines to recover from frozen instrument lines or equipment.

Training development request 89-284 will incorporate guidance into initial and continuing training by June 1990.

Recommendation 6: All frozen equipment that has been thawed should be examined to ensure structural integrity before return to service.

Present Status: The station has not developed a program to ensure adequate freeze protection of affected systems. This has been a problem with the control building air ventilation system. This system has iced-over during adverse weather conditions by drawing freezing rain and snow into the intake filters.

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Actions Planned to l Close Recommendation: Standard work practice IC-006 has been issued to address  ;

maintenance guidelines to recover from frozen instrument lines j or equipment.  !

Training development request 19-284 will incorporate guidance into initial and continuing training by June 1990.  !

SOER 83-8 " Reactor Trip Breaker Failure"

]

Recommendation los Ensure procedures are established for incorporation of safety-related vendor data and changes into preventive i maintenance programs. j l

Present Status: Plant procedures have not been developed for Mechanical, i Electrical, or I&C Departments to ensure that vendor i information (manuals and updates) are incorporated into applicable procedures. This item is a past due action item in the integrated commitment tracking system (ICTS).

Actions Planned to '

Close Jtecommendation: The New Hampshire Yankee program for vendor manuals is presently being revised and strengthened. Part of this revision  !

will define which vendor manuals will be available for use, how they can be used and what review process must be complete. [

Full implementation of this program is scheduled for December 1990.

Recommendation 12: Ensure appropriate technical staff and managers / supervisors receive training tot

a. Determine the safety classification of equipment and activities for which they are responsible. l l

b. Implement QA/QC policies in procurement of parts and components and in performance of work on safety-related equipment,

c. Conduct and review post-trip analyses.

l Present Status: Training on " Classification of Structure, Systems, and Components, Seabrook Station Engineering Design Standard 37180" has not been conducted or scheduled. The standard was

lasued in February 1989.

I t Actions Planned to '

Close Recommendation: Training development request 89-248 will incorporate this SOER into lesson plans for initial and continuing training by June 1990.

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SOER 83-9 " Valve Inoperability Caused by Motor Operator Failures" Recommendation 7: Ensure plant procedures require an evaluation of valve operability when valves that perform safety functions must be manually seated or backseated. Declare motor-operated valves j that perform a safety function inoperable if they have been either manually seated or backseated until MOV operability is verified by electrically stroking the valve.

Present Status: Plant procedure CN1090.01, " Manual Operation of Remote Valves," does not address operability of backseated valves.-

Also, the procedure states to use the handwheel rather than to electrically backseat valves.

Actions Planned to Close Recommendation: Plant procedure ON1090.01, " Manual Operation of Remote Operated Valves," will be revised with respect to adding a requirement to evaluate valve operability if a valve has been  ;

manually seated or backseated. This action will be completed by June 1990.  ;

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SOER 84-3 " Auxiliary Feedwater Pumps Disabled by Backleakage" Recommendation 5: Ensure that the preventive maintenance program includes periodic inspection or testing of all check valves in the auxiliary feedwater systm.  ;

l Present Status: Emergency feedwater check valves are not tested to verify

abi!!ty to prevent backflow. The present testing program only  ;

tests for flow through check valves.

Actions Planned to l Close Recommendation: Feedwater backflow that may cause steam binding of an EFW pump during EFW idle conditions is monitored by auxiliary operators using a hand-held temperature probe.

EFW pump discharge check valves FW-V44 and 70 are ,

individually backflow tested imp!!citly during periodic EFW ,

sump surveillance testing because of the common discharge wader. The backleakage through the idle train discharge check valve, if any, is not quantified during this surveillance, but acceptable forward feed flow of the running train is measured to demonstrate, among other things, adequate closure of the idle pump's discharge check valve.

Check valves FW-V44 and 70, as well as the downstream check valves in the EFW system, will be included in the check valve monitoring program to be developed by October 1990, and -

implemented by the first refueling (March 1991).

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50ER 84-7 " Pressure Locking and Thermai Binding of Gate Valves" I

Recommendation 3: Train operations and maintenance personnel on how to diagnose and recover from the pressure locking and thermal binding valve  :

failure mechanism. j Present Status: Training has not been provided to maintenance personnel on the elements of the recommendation. Lesson plan N1270 has been  ;

developed on this topic. l Actions Planned to Close Recommendation: Training development request 88-285 will incorporate this SOER l into lesson plans. Mechanical and electrical continuing training will be completed by March 1990.

. This SOER is included in auxiliary operator initial training. It j wl!! be incorporated into electrical initial training by June 1990.

SOER 85-2 " Valve Mispositioning Events involving Human Error" Recommendation 2: Train operators, maintenance, and supervisory personnel in -

procedures used to position and verify valve positions. This training should stress the need to comply with procedures and the need to identify incorrect procedures so that they can be corrected.

Present Status: Training of plant personnel has been ineffective in preventing valve mispositioning events. Numerous valve misposition events were identified through a review of station log books and station event reports.

Actions Planned to Close Recommendation: Training development request 89-286 will incorporate the recent five valve mispositioning events and generic lessons learned from industry events into continuing training for operators by May 1990.

Lesson plan 05 regarding the tagging program will incorporate lessons learned from this SOER by March 1990. This training provided to appropriate operations, maintenance, and will supervt be,sory personnel.

SOER 86-1 " Reliability of PWR Auxiliary Feedwater Systems" Recommendation 3: Test auxiliary feedwater pumps periodically under conditions and configurations expected during any operational event l demand, include fast, cold starting of the pumps; simultaneous and automatic starting of all pumpst and testing of the pumps for various steam supply, condensate supply, and pump discharge flow configurations that may reasonably occur.

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Page3 1 Present Statust On-demand start testing is performed on an 18-month basis or following a shutdown greater than 30 days. The testing is not .

performed on a quarterly frequency. l Actions Planned to Close Recommendation: The turbine-driven emergency feedwater pump will be tested to  !

demonstrate governor ramp-up, governor startup control, sequencing of steam supply valves, and operation of the steam  ;

trap drain system during post-modification testing scheduled for i January 1990. Evaluation of the as-found turbine speed and acceptance criteria for vibration, differential pressure, flow and speed will be ircluded in surveillance procedures by January 1990. A method of testing the overspeed trip mechanism will be evaluated by June 1990. The overspeed trip mechanism will be tested periodically consistent with vendor recommendations and j technical specifications requirements.

A start of the pump under demand conditions, from an initial i idle condition, will be performed during plant heatup in January 2 1990. An evaluation of quarterly starts of the turbine-driven emergency feedwater pump and related equipment, under -

. demand conditions, will be performed by March 1990.

Surveillance procedures will be revised to require quarterly testing if supported by this evaluation.

SOER 86-2 " Inaccurate Closed Position Indication on Motor-operator Valves" Recommendation 1: Identify motor-operated valves with remote position indication in which existing limit switch settings can result in a closed

, indication while the valve is actually partially open. Take l

actions where necessary to prevent premature closed indication due to limit switch settings.

Present Status: Actions have not been taken to address important non-safety related valves. Actions are planned for elimination of single motor / dual function limit switches in safety-related MOVs.

Actions Planned to Close Recommendation: Design coordination report (DCR)86-403 is working in the field to address priority systems. Expected fleid completion is December 1989, i DCR 89-024, to be issued by January 1990, will address the balance of MOVs.

All fleid work is scheduled for completion by February 1991.

SOER 86-3 " Check Valve Failures or Degradation:

Recommendation 1: Establish preventive maintenance procedures (e.g., a test and inspection program) that identify existing and incipient f ailures of check valves in appropriate systems. The program should 1

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Appendix !!

Page 9 l

- include periodic testing, surveillance monitoring to identify seat l leakage and other developing problems, and disassembly and i inspection on a sampling basis to ensure check valve internals I are intact and are not experiencing abnormal wear.

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Present Status: The preventive maintenance program has identified 220 check i valves, but 64 have no inspection requirements. The program  ;

only addresses inspections specified by the in-service testing  :

program. At a result, most elements in the recommendation are  !

not addressed. ,

i Actions Planned to l Close Recommendation: The actions planned for recommendation 2 are the same as for SOER 86-3, recommendation 1. A review of the current check i valve design and monitoring program will be conducted by October 1990. This effort w,ll include the following:  ;

i

a. an assessment of the appropriate preventive maintenance measures such as inspections and leak checks for the check valves in the current monitoring program

~

b. an assessment of acceptance criteria and provisions to revise test frequencies based upon inspection results, and

c. a design review of check valves for applicability with respect to EPRI Report NP-3479 and INPO SOER 36-3 There feasible, check valve preventive maintenance and monitoring improvements will be completed as part of this

program development effort. It is anticipated that certain L aspects of the program improvements will be dependent upon -

l the results of the design review for applicability. These activities will be scheduled for completion as the results of this effort become known. Preventative maintenance on selected check valves will be performed prior to the completion of the first refueling outage.

Recommendation 2: Perform design reviews on those check valve included in the station check valve preventive maintenance program. The review should determine if check valves are sized properly, are the proper types of check valves installed for the required service, and are properly oriented and located a suitable distance from upstream components that cause turbultat flow.

Based on this review, initiate design changes or perform additional preventive maintenance and testing for check valves determined to be misapplied.

Present Status: The design review has not been conducted.

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Appendix 11

• Page 10 Actions Planned to Close Recommendation: The actions planned for recommendation 2 are the same as for SOER 86-3, recommandation 1. A review of the current check valve design and monitoring pogram will be conducted by October 1990. This effort wLil include the following

a. an assessment of the appropriate preventive maintenance measures such as inspections and leak checks for the check valves in the current monitoring program

b. an assessment of acceptance criteria and provisions to revise test frequencies based upon inspection results, and

c. a design review of check valves for applicability with  :

respect to EPRI Report NP-5479 and INPO SOER 36- '

3 Where feasible, check valve preventive maintenance and .  !

monitoring improvements will be completed as part of this

. program development effort. It is anticipated that certain aspects of the program improvements will be dependent upon ,

the results of the design review for applicability. These activities will be scheduled for completion as the results of this effort become known. Preventative maintenance on selected check valves will be performed prior to the completion of the l l

first refueling outage.  !

l SOER 88-1 " Instrument Air System Failures" Recommendation 3: Provide training on the importance of instrument air systems and the potential for common mode failures caused by such things as particulate, hydrocarbon, and water contamination for >

operators and maintenance personnel who work on air systems and air-operated components.  !

Present Status: A training program has not been established for maintenance and I&C personnel.

Actions Planned to Close Recommendation: Training development request 88-072 will incorporate this SOER into initial and continuing training for maintenance and !&C personnel by July 1990.

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Appendix !!

Page 11 SOER 88-2 " Premature Criticality Events During Reactor Startup" Recommendation 6: Ensure the reactor startup procedure includes the following l informations  !

a. a section that stresses the need for conservative actions and for strict compliance with written  !

procedures when repositioning control rods

b. a section that provides detailed guidance on actions ]

to be taken when criticality will be or is achieved ]

outside the allowable tolerance band of the j estimated critical condition (when estimated critical j

conditions are provided)- This guidance should include the allowable tolerance band and the correct  !

actions to ensure adequate shutdown margin is l maintained.

c. avoidance of activities that can distract operators and supervisors involved with the reactor startup,  ;

. such as a shift turnover and surveillance testing during the approach to critica!!ty  ;

i

d. directions for use of all pertinent instrumentation to $

monitor the approach to criticality to a!!ow errors in j the estimated critical condition or preblems with other instrumentation to be detected early -

Consider the use of audio count rate speakers as an ,

aid to determine increasing flux rate.

e. periodic pauses during rod withdrawal to allow stabilization of neutron level and collection of data for estimating the proximity to criticality - Count '

rate doubling methods or inverse count rate ratio (1/M) plots should be required for all reactor startups.

Present Status: Startup procedures 051000.02 and 0510000.07 do not adequately control shift activities during reactor startup. In particular, guidance is not provided regarding conservative actions and strict procedure compilance addressed in item a. of the recommendation. .

Actions Planned to

, Close Recommendation: Operations will review plant procedures 051000.02 and 051000.07. Revisions will be made as appropriate to incorporate the concerns of this SOER by January 1990.

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Appendix !!

Page 12 SOER 88-3 " Losses of Residua 1 Heat Removal with Reduced Reactor Vessel Water Level at PWRs" Recommendation 2: Review the procedures that support residual heat removal system operation to ensure that procedure improvements necessary to support plant actions in response to SOER 83-4  ;

have been incorporated, j Present Status: Methods (such as graphs) to determine reactor core heatup and c

boil-off rates as a function of reactor coolant system volume j and the time since shutdown, are only partially addressed in 051213.01. This procedure states only as a caution prior to step 1, " Loss of RHR during typical refueling conditions could result  ;

in an RCS heatup of 3 degrees to 6 degrees F per minute and j RCS saturation within 20 to 30 minutes." Graphs of heatup rate ,

are not provided. l Actions Planned to Close Recommendation: Operations will review plant procedure 051213.01. A revision will be made as appropriate to incorporate the concerns of this

. SOER by January 1990.

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